ML20154K010

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Safety Evaluation Supporting Util 840309,850621 & 860606 Responses to Generic Ltr 83-28, Required Actions Based on Generic Implication of Salem ATWS Events, Items 3.1.1, 3.1.2,3.2.1,3.2.2 & 4.5.1
ML20154K010
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 09/19/1988
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20154K001 List:
References
GL-83-28, NUDOCS 8809230197
Download: ML20154K010 (5)


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UNITED STATES i

NUCLEAR REGULATORY COMMISSION 1

a W ASHING TON, D. C. 20655 I

l SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION l

i RELATED TO GENERIC LETTER 83-28. ITEMS 3.1.1, 3.1.2, 3.2.1, 3.2.2_AND 4.5.1 i

c LONG ISLAND LIGHTING COMPANY SHOREHAM HUCLEAR POWER STATION I

DOCKET NO. 50-322 l

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i 1.0 INTRODHCTION f

i On Februar.y 25, 1983, both of the scran circuit breakers at Unit 1 of the Salem Nuclear Power Plant failed to open upon an automatic reactor trip signal from the reactor protection system. This incident occurred during the plant startup, and the reactor was tripped manually by the operator l

about 30 seconds after the initiation of the autoratic trip signal. The J

failure of the circuit breakers has been detemined to be related to the

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l sticking of the undervoltage trip attachment.

Prior te this incident, on February 22, 1983, at Unit 1 of the Salem Nuclear Power Plant, an i

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I automatic trip signal was generated due to a steam generator low-low level during plant startup.

In this case, the reactor wes tripped manually by the operator alinost coincidentally with the autoratic trip.

Following these incidents, on February 28, 1983, the NRC Executive f

Director for Operations (E00), directed the staff to investigate and j

report on the generic implications of these occurrences at Unit 1 of the Salem Nuclear Power Plant. The results of tbc staff's inquiry into the l

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generic implications of t!ie Salem incidents are reported in NUREG-1000, t

j "Generic Implications of ATWS Events at the Salem Nuclear Power Plant."

j As a result of this investigation, the Director, Divisten of Licensing, Office of Nuclear Reactor Regulation requested (by Generic Letter 83-28 dated July R.1983) all licensees of eperating reactors, applicants for i

an operating license, and holders of construction pemits to respond to I'

certain gereric concerns. These concerns are catecorized into four areas: (1) Fest-Trip Review. (2) Equipment Classification and Vendor i

Interface (3) Post-Maintenance Testing, and (4) Reactor Trip System i

(RTS) Reliability Improvements. With each of these areas, various i

specific actions were delineated, j

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i This safety evaluation (SEi addresses the followine actions of Generic Letter 83-28:

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3.1.1 and 3.1.2, Post Maintenance Testing (Reactor Trip System Components) f 4

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3.1.2 and 3.2.2, Post Maintenancs Testing (All Other Safety-Related Components) 4.5.1, Reactor Trip System Reliability (System Functional Testing)

By the letters dated March 9, 1984. June 21, 1985 and June 6, 1986, Long I

Island Lighting Company described their planned and completed action regarding the above items for the Shoreham Nuclear Power Station (SNPS),

2.0 EVALUATION AND DISCtlS$10N l

2.1 General l

Generic Letter 83-28 included various NRC staff positions regarding the specific actions to be taken by operating reactor licensees and

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operating license applicants. The Generic Letter 83-28 positions and discussions of licensee compliance regarding Actions 3.1.1, L

3.1.?, 3.2.1, 3.2.2 and 4.5.1 for Shorehan Nuclear Power Station are presented in the section that follows.

l 2.? Action 3.1.1. Fost Maintenance Testing t

(Reactor Trip System Components)

Position Licensee and applicants shall submit the results of their review of test and maintenance precedures and Technical Specifications tn assure that post mainterance operability te2 ting of safety-related I

compenents in the reactor trip system is required to be conducted and the testing demonstrates that the equipment is capaH e of

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rerforming its safety functions before being returned to nervice.

Evaluation in letters dated March 9, 1984 and June 6, 1986, the licensee stated j

that their Station procedures SP12.013.01, "Maintenance Work Request." (MWR) outlines the recuirement for post maintenance operability test (Postwork Tests) following a component maintenance or repair. The recuired post maintenance operability test is detemined by the Operations Section and documented on the PWR fom. An Operations Section procedure SP21.001.02, "Return of Safety Related Components to an Operable Status." supplementing SP12.013.01 "Maintenance Work Request " was issued to improve the method by which MVRs are handled for retests.

The procedure also provides cuidelines for detervining the extent of post-maintenance operability testing for the various plant em ponents.

3 The staff's review of the station surveillanse and maintenance work request procedures determined that the licensee documentation

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- reflected the requirements of their Technical Specifications in that post-maintenance operability testing of safety-related components in the reactor trip system is required.

Based on the above and a review of Operating Station Procedures, the staff concluded that the i

licensee's actiuns are consistent with the staff's position for action 3.1.1 of Generic letter 83-?8 and, therefore, are acceptable.

P3 Action 3.1.?, Post Maintenance Testing (Reactor Trip System Components)

.P. 9_s i tion Licensees and applicants shall suteit the results of their check of vendor and engineering recewendations to ensure that any appropriate test outdance is included in the test and maintenance procedures or the Technical Specifications, where required.

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I Evaluation I

In letters dated Parch 9,1984 and June 6,1986, tne licensee stated that apperpriate vendors and engireering recomendations have been or are being ircorporated in the test and maintenance procedure and i

technical specification.

The licensee stated that their Station Procedure SP12.007.01, "Technical Correspondence and Bulletins "

assures that all incomirg correspondence such as bulletin and vendor infomation is properly tracked and assigned for action within the i

Shoreham Plant Staff and the necessary updates to existing procedures and programs are made, as appropriate. The review of engineering and vender data are being incorporat2d in the test and maintenance procedures ard the Technical Specification through the I'

direction of Pepartment level procedures. Licensee procedure i

SP12.007.01 defines the method used by the various Departrents to i

review their procedures to assure that engineerinq and vendor data i

are applicable to the procedure.

During the staff review of the licenre's station procedures it was detemined that the vendor and othei source material were included in the "references" section of the procedures. Based on the licensee's responses and the review of I

the procedures, the staff concluded that the licerisee's actions are consistent with the staff position for action 3.1.2 of Generic i

Letter 83-28 and, therefore, are acceptable.

?.4 Action 3.2.1 and 3.?.7. Post Paintenance Testino (All Other Safety-Related Components) position Item 3.?.1, licensees end applicants shall suteit a report doeurenting the extending of test and maintenance procedures and 1

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Technical Specifications review to assure that post-naintenance operability testing of all safety-related eoutpment is required to be conducted and that the testing demonstrates that the equipment is capable of performine its safety functions before being returned to service.

Item 3.2.2, licenstes and applicants shall submit the results of their check of vender and engineering recorrendations to i

ensure that any appropriate test guidance is incluied in the test and maintenance procedures or the Technical Specifications were required.

Evaluation

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In letters dated March 9, 1984 and June 6, 1986, the licensee states l

that their response to NRC's Generic Let* 'r 83-28 item 3.1 was applicable to all other safety-related nonents.

j The staff review detemined that all sa-

-related components are i

required to be reviewed and th'.t this review does verify that both j

engineering and vender data are considered to assure that appropriate i

guidance is included. Based on the review of test procedures, test l

data results and maintenance instructions, the staff concludes that l

the licensee's actions are consistent with the staff's position for i

actions 3.P.1 and 3.2.? of Generic letter 83-28 and, therefore, are

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acceptable.

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2.5 A: tion 4.5.1, Reactor Trip System Reliability ($ystem Functional Testing) position

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i On-line functional testing of the reactor trip system, including i

j independent testing of the diverse trip features, shell be performed l

on all plants. The diverse trip features to be tested include the j

breaker undervoltage and shunt trip features on Westinghouse, PAW and CE plants: the circuitry used for power interruption with the j

silicon controlled rectifiers on B&W plants; and the scram pilot valve and backup scram valves (including all initiating circuitry)

J en GE plants, i

I Evaluation q

1 In a letter dated June 21. 1985 the licensee indicated that they will recomend an appreoriate change to the SNPS Technical i

Specifications which will incorporate the requirement for testing the backup scram valves during each refueling outage. Their present procedures require testing of the scram system including the scram pilot valves to comply with their Technical Specificatiens j

requirement. The licensee has explained and the staff agrees, that l

. the reactor trip system currently is not designed to permit periodic on-line functional testing of backup screm valves.

Justification for r.ot making modifications to pennit on-lins testing has been reviewed separately by the staff under Acticn Items 4.5.2 and A.5.3 of Generic Letter 83-28, as stated in the staff's letter to the licensee dated April 11, 1985.

Pursuant to Generic Letter (GL) 83-28 and the staff's prior evaluation letter to the licensee dated April 11, 1985, the backup scrar,i valves (including all initiating circuitry) shall be functionally tested on a refueling frequency.

The staff concibdes that the licensee shall complets the first such testing prior to initielly exceeding 5% power.

The staff further concludes that 1

pursuant to GL 83-P8, item 4.5, the licensee shall submit a technict specification change at least six months prior to the first refueling outage stipulating a surveillance requirement to circuitry) y test the backup scram valves (including initiating functionall at a refueling outage frequency.

Based on the above, the staff concludes that the licensee has complied with the NRC staff position for Action 4.5.1 of Generic Letter 83-28,

3.0 CONCLUSION

Based upon the foregoing discussion, the staff concludes that the licen,ee has complied with Actions 3.1.1, 3.1.2, 3.2.1, 3.2.2 and 4.5.1 of Generic Letter 83-28.

Prinicipal Contributor:

A. Finkel, Division of Reactor Safety. Region I Dated: September 19, 1988 1

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