ML20203L874
| ML20203L874 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 08/26/1986 |
| From: | Bailey J GEORGIA POWER CO. |
| To: | Youngblood B Office of Nuclear Reactor Regulation |
| References | |
| 0689V, 689V, GL-83-28, GN-1060, X6BK10, NUDOCS 8609020004 | |
| Download: ML20203L874 (5) | |
Text
= Georgia Pt>ver Company Post Offica Bau 282 WaynesborcL Georgia 30830 Telephone 404 554-9961 404 724 8114 Southern Company Services,Inc. '
Post Office Box 2625 B'rmingham, A!abams 35202 Telephone 205 8704011 Vogtle Project -
l August 26, 1986 l
Director of Nuclear Reactr.r R::gulation File: X6BK10 Attention:
Mr. B. J. Youngblood Log:
GN-1060 PWR Project Directorate #4 Division of PWR Licensing A U. S. Nuclear Regulatory Commission Washington, D.C.
20555 NRC DOCKET NUMBERS 50-424 AND 50-425 CONSTRUCTION PERMIT NUMBERS CPPR-10d AND CPPR-109 V0GTLE ELECTRIC GENERATING PIANT - UNITS 1 AND 2 SER OPEN ITEM 5: GENERIC LETTER 83-28
Dear Mr. Denton:
Attached is additional information concerning paragraphs 3.1.1, 3.1.2, 3.1.3, 3.2.1, 3.2.2, 3.2.3 and 4.5.1 of the referenced letter. A review of our previous submittals indicates that to the best of our knowledge all items in the referenced letter have now been addressed.
Should you have any questions, please inquire.
Sincerely, J. A. Bailey Project Licensing Manager JAB /caa Enclosures xc:
R. E. Conway G. Bockhold, Jr.
R. A. Thomas D. C. Tepe r J. E. Joiner, Esquire NRC Regional Administrator B. W. Churchill, Esquire NRC Resident Inspector M. A. Miller W. C. Ramsey B. Jones, Esquire L. T. Gucwa Vogtle Project File 0689V f
hs 8609020004 860326 l
PDR ADOCK 05000424 E
3.1 POST-MAINTENANCE TES7!NG ( REACTOR TRIP SYSTEM COMPONENTS )
1.
Licensees and applicants shall submit the results of their review of test and maintenance procedures and Technical Specifications to assure that post-maintenance operability testing of safety-related components in the reactor trip system is required to be conducted and that
.the testing demonstrates that the equipment'is capable of performing its safety functions before being returned to service.
RESPONSE
l Prior to the performance of work on a system or equipment, the work must be authorized.
This is done via the use of Maintenance Work Orders (MWO).
- Also, the work must be authorized by the Shift Supervisor of the Operations-Department and the issuance of a clearance when needed.
The VEGP Maintenance Program requires that the MWO packages be i
sent to the Work Planning Group Operations Supervisor for operations closeout.
The equipment clearance shall be closed out and the system / equipment should b.e restored to normal per the applicable operating procedure as-determined by the Shift Supervisor.
Surveillance, functional, acceptance, and/or special tests shall be completed as required.
If the Shift Supervisor is satisfied that the equipment / system is acceptable, he 4
signs the MWO.
If testing shows that the equipment / system is not acceptable, then a new MWO is generated.
If the system is Tech.
Spec.
- related, the Shift Supervisor shall ensure a verification of operability is accomplished when the system is being returned to service following maintenance or testing.
2.
Licensees and applicants shall submit the results of their check of vendor and engineering recommendations to ensure that any appropriate test guidance is included in the test and maintenance procedures or the Technien1 Specifications, where required.
RESPONSE
At VEGP, procedures'are written referencing vendor manuals, if applicable.
When procedures are reviewed, part of the review criteria is to review the procedure against the applicable vendor manuals.
Vendor manuals are controlled at the site in accordance with Administrative Procedure 00108-C
" Control, Approval and Use of Vendor Manuals and Revisions".
1
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s i
In
- addition, VEGP has procedures which include measures to ensure that pertinent operating experience information (such as industry event reports, vendor reports, inhouse event reports and Nucleat-Regulatory Commission publications) that originates from both within and outside of the plant organization is feedback to operators and other appropriate personnel-in accordance with NUREG-0737, item I.C.5.
The VEGP operating experience program has established controls to ensure Westinghouse TE0hnical Bulletins which are used by Westinghouse to communicate technical information and recommendations are acknowledged,
- reviewed, and controlled for the life of.the plant.
For vendor interface information, refer to the response to items 2.1 and 2.2 in reference 1.
3.
Licensees and applicants shall identify, if applicable, any post-n.aintenance test requirements in existing Technical Speci11 cations which can be demonstrated to degrade rather than enhance safety.
Appropriate changes to these test requirements with supporting justification, shall be submitted for staff approval.
Response
A comprehensive review of post-maintenance testing requirements was performed prior to the submittal of the VEGP proposed Tech-nical Specifications to the NRC.
From our review we have not identified any post-maintenance testing requirements in our Technical Specifications submittal which would degrade rather than enhance safety.
t 3.2 POST-MAINTENANCE TESTING ( ALL OTHER SAFETY-RELATED COMPONENTS )
1.
Licensees and applicants shall submit a report documenting the extending of test and maintenance procedures and Technical Specifications review to assure that post-maintenance operability testing of all safety-related equipment is required to be conducted and that the testing demonstrates that the equipment is capable of performing its safety functions before being returned to service, j
2
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RESPONSE
Prior to the performance of work on a system or equipment, the work mus.t be authorized.
This is done via the use of Maintenance Work Orders (MWO).
- Also, the work must be authorized -by the Shift Supervisor of the Operations Department and the issuance of a
clearance when needed.
The. VEGP Maintenance Program requires that'the MWO packages be sent to the Work Planning Group Operations Supervisor for operations closecut.
The equipment clearance shall be closed out and the system / equipment should be restored to normal per the applicable operating procedure as determined by the Shift Supervisor.,
Surveillance, functional, acceptance, and/or special tests shall be completed as required.
If the Shift Supervisor is satisfied that the equipment / system is acceptable, he signs the MWO.
If testing shows that the equipment / system is not acceptable, then a new MWO is generated.
If the system is Tech. Spec. related, the Shift Supervisor shall ensure a verification of operability is accomplished when the system is being returned to service j
following maintenance or testing.
I 2.
Licensees and applicants shall submit the results of their check of vendor and engineering recommendations to ensure i
that any appropriate test guidance is included in the test and maintenance procedures or the Technical Specifications where required.
RESPONSE
l 1
i At VEGP, procedures are written referencing vendor manuals, 1
if applicable.
When procedures are reviewed, part of the review criteria is to review the procedure against the applicable vendor manuals.
Vendor manuals are controlled at the site in accordance with Administrative Procedure 00108-C
" Control, Approval and Use of Vendor Manuals and Revisions".
t
[
In
- addition, VEGP has procedures which include measures to
)
ensure that pertinent operating experience information (such j
.as industry event reports, vendor reports, inhouse event reports and Nuclear Regulatory Commission publications) that originates 'from both within and outside of the plant organization is feedback to operators and other appropriate personnel in accordance with NUREG-0737, item I.C.5.
The VEGP operating experience program has established controls to ensure Westinghouse Technical Bulletins which r
are used by Westinghouse to communicate technical 1
information and recommendations are acknowledged,
- reviewed, 3
2
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and controlled for the life of the plant.
For vendor interface information, refer to the response to items 2.1 and 2.2 in reference 1.
3.
Licensees and ~ applicants shall
- identify, if applicable, any post-maintenance test requirements in existing Technical Specifications which are perceived to degrade rather than enhance safety.
Appropriate changes to these test requirements with supporting justification, shall be submitted for staff approval.
Response
A comprehensive review of post-maintenance testing requirements was performed prior to the submittal of the VEOP proposed Technical Specifications to the NRC.
From our review we have not identified any post-maintenance testing requirements in our Technical Specifications submittal which 'would degrade rather than enhance safety.
The only area of review remaining is the testing of the diesel generator.
This item is being addressed in our resolution of VEGP SER Confirmatory Item 36.
4.5 REACTOR TRIP SYSTEM RELIABILITY (SYSTEM FUNCTIONAL TESTING)
On-line functional testing of the reactor trip system, including independent testing of the diverse trip features, shall be performed on all plants.
1.
The diverse trip features to be tested include the braaker undervoltage and shunt trip features on Westinghouse, B&W (see Action 4.3 above) and CE plants; the circuitry used for power interruption with the silicon controlled rectifiers on B&W plants (see Action 4.4 above); and the scram pilot valva and backup scram valves (ircluding all initiating circuitry) on GE plants.
RESPONSE
Testing of the Undervoltage and Shunt trip features is covered by plant surveillance procedures in accordance with the VEGP Technical Specifications.
Plant Vogtle is designed to permit on-line testing of the reactor trip system through the use of the bypass breakers with the exception of the manual reactor trip function which is tested during shutdown conditions as described in FSAR subsection 1.9.22.
The manual reactor trip switches on the control board are not testable when the unit is on-line and, when actuated, will trip both trains and cause a reactor trip.
4
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