ML20209G969

Safety Evaluation Re Generic Ltr 83-28,Items 3.1.1,3.1.2, 3.2.1,3.2.2,4.1 & 4.5.1.Addl Info Required for Item 3.2.2 Re Check of Vendor & Engineering Recommendations for Testing & Maint

ML20209G969
Person / Time
Site:	Farley
Issue date:	09/10/1985
From:	NRC
To:
Shared Package
ML20209G961	List: ML20209G956 ML20209G969
References
GL-83-28, NUDOCS 8509190768
Download: ML20209G969 (6)

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ENC'LOSURE SAFETY EVALUATION FOR GENERIC LETTER 83-28, ITEMS 3.1.1, 3.1.2, 3.2.1, 3.2.2, 4.1 AND 4.5.1 JOSEPH M. FARLEY NUCLEAR plt'ii, UNITS 1 AND 2 DOCKET N05. 50-348 AND 50-364 J

I. Introduction In February 1983, the Salem Nuclear Power Station experienced two failures of the reactor-trip system upon the receipt of trip signals. These failures were attributed to Westinghouse - Type DB-50 reactor-trip system (RTS) circuit breakers. The failures at Salem on February 22 and 25,1983, were believed to have been caused by a binding action within the undervoltage trip attachment (UVTA) located inside the breaker cubicle.

, Due to problems of the circuit breakers at Salem and at other plants, NRC issued Generic Letter (GL) 83-28, Required Actions Based on Generic

Implementations of Salem Anticipated Transient Without Scram (ATWS) Events, i

dated July 8, 1983. This letter required the licensees to respond on imediate-tem actions to ensure reliability of the RTS. Actions to be perfomed included development of programs to provide for post-trip review, classification of equipment, vendor interface, post-maintenance testing, j and RTS reliability improvements. The Generic Letter stated that for Actions 3 1.1., 3.1.2, 3.2.1, 3.2.2, 4.1, 4.4 and 4.5.1, NRC Regional Offices would perform a post-implementation review and issue Safety Evaluation Reports (SER). This report is the Regional SER for Farley Units 1 and 2 and includes the results of RII's review of the licensee's i submittals to GL 83-28. A Regional inspection was conducted at the Farley facility during March 18 - 22, 1985, to review the licensee's current program, planned program improvements, and implementation of present procedures associated with post-trip review, equipment classification, vendor interface, post-maintenance testing, and reactor-trip system reliability. The details of the inspection findings are discussed in Inspection Report No. 348, 364/85-17.

II. Review Guidelines The licensee's responses dated September 6, 1983, November 4, 1983 February 6, 1984. February 15, 1984, June 25, 1984, and July 17, 1985, were ,

evaluated for compliance to the NRC staff's positions delineated in l GL 83-28 for Action Items 3.1.1, 3.1. 2, 3. 2.1, 3.2. 2, 4.1 and 4.5.1. The requirements of the above action items as described in GL 83-28 are paraphrased below:

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1 e 1 j 3.1. Post-Maintenance Testing (Reactor Trip System Components)

Position

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l 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 4

being returned to service.

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2. Licensees and applicants shall submit the results of their check  !

i of vendor and engineering recommendations to ensure that any j i appropriate test guidance is included in the test and maintenance t i procedures or the Technical spec 171 cations, where required.

L j 3.2 Post-Maintenance Testing (All Other Safety-Related Components) 1 ,

i Position f i l The following actions are applicable to post-maintenance testing: i f

1. Licensees and applicants shall submit a report documenting the [

j extending of test and maintenance procedures and Technical Speci- i

fications review to assure that post-maintenance operability i testing of all safety-related equipment is required to be  ;

{ conducted and that the testing demonstrates that the equipment is  !

i capable of performing its safety functions before being returned l to service. ,

4 j 2. Licensees and applicants shall submit the results of their check of vendor and engineering recomendations to ensure that any l' appropriate test guidance is included in the test and maintenance procedures or the Technical Specifications where required.

l 4.1 Reactor Trip System Relbbility (Vendor-Related Modifications) I Position ,

1 All vendor-recomended reviewed reactor(1 to verify that either: trip) each breaker modificationmodifications has, in shall fact, be i been implemented; or (2) a written evaluation of the technical reasons l for not implementing a modification exists.

I For example, the modifications recomended by Westinghouse in NCD-l' Elec-18 for the DB-50 breakers and a March 31, 1983, letter for the D5-416 breakers shall be implemented or a justification for not imple- -

4 menting shall be made available. Modifications not previously made j shall be incorporated or a written evaluation shall be provided.

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3-o 4.5 Reactor Trip System Reliability (System Functional Testing)

Position 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 breaker under-voltage and shunt-trip features on Westin Wilcox (B&W) and Combustion Engineering (ghouse, CE) plants; the Babcock and circuitry used for power interruption with the silicon-controlled rectifiers on B&W plants and the scram pilot valve and backup-scram valves (including all initiating circuitry) on General Electric (GE) plants.

III. Evaluation and Conclusion By letters dated September 6,1983, November 4,1983 February 6,1984 February 15, 1984, June 25, 1984 and July 17, 1985 Alabama Power Company (APCo), the licensee of Farley Plant, Units 1 and 2, provided infomation regarding their compliance to Sections 3.1, 3.2, 4.1 and 4.5 of GL 83-28.

We have evaluated the licensee's responses against the NRC positions de-i scribed in Section II above for completeness and adequacy. We concluded

, that the licensee's responses to all items were acceptable, except item 3.2.2. In a letter dated June 13, 1985, NRC requested the licensee to provide additional information regarding Item 3.2.2 of GL 83-28. The licensee responded to our request for additional infomation in a letter dated July 17, 1985. This response has been reviewed and determined to be i in need of supplemental infomation.

Delineated'below is a brief sumary of the licensee's responses and the results of the Regional Evaluations:

A. Item 3.1.1, Review of Test and Maintenance Procedures and Technical Specifications (Reactor Trip System Components)

The licensee's response to this item is acceptable and meets the intent of GL 83-28. The licensee has verified that procedures covering testing and maintenance and Technical Specifications related to the reactor trip system require post-maintenance testing of 4

safety-related components before the system is returned to service.

The licensee also states that required post-maintenance testing demonstrates that the equipment is capable of perfoming its safety functions before being returned to service, i 8. Item 3.1.2, Check of Vendor and Engineering Recomendations for i Testing and Maintenance (Reactor Trip System Components) 4

) The licensee's response to this item is acceptable and meets the

intent of GL 83-28. The licensee states in their submittal that they

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• have verified that applicable vendor and engineering recomendations relative to testing the reactor trip system have been implemented.

C. Item 3.2.1, Review of Test and Maintenance Procedures and Technical Specifications (All Other Safety-Related Components)

The licensee's submittal dated February 15, 1984, is the final response to action item 3.2.1. The licensee's response to this item is acceptable and meets the intent of GL 83-28. The licensee states in this submittal that they have verified that procedures covering Technical Specifications, surveillance testing, other testing and maintenance require appropriate post-maintenance operability testing of safety-related components before the system is returned to service.

The licensee also states that required post-maintenance testing demon-strates the equipment is capable of performing its safety functions  ;

prior to being returned to service. '

D. Item 3.2.2, Check of Vendor and Engineering Recomendations for Testing and Maintenance (All Other Safety-Related Components)

The licensee's responses to this Action Item do not meet the intent of GL 83-28 without further clarification. The licensee has not performed a review of vendor and engineering recomendations to ensure that any appropriate test guidance is included in the test and i

maintenance procedure or the Technical Specification and has not provided adequate justification for this review not be being performed.

In a letter dated June 1, 1985, NRC requested the licensee to provide additional information regarding Item 3.2.2 of GL 83-28. The licensee responded to our request for additional infonnation in a letter dated July 17, 1985. We reviewed this response against the review guidelines described in Saction II above and concluded that their response remains unacceptable. The licensee has not perfonned a review of vendor and engineering recomendations as specified in the Generic Letter. The licensee's justification for not performing this review is as described below:

Adequate assurance currently exists that appropriate vendor and engineering test guidance is included in test and maintenance procedures or Technical Specifications. It is therefore APCo's belief that the intent of Item 3.2.2 is satisfied without the completion of a specific review of vendor and engineering recom-  :

mendations at a particular point in time for the sole purpose of responding to GL 83-28. AP;c s belief in this regard is based on the following:

1. As stated in the APCo responses dated November 4,1983 and February 15, 1984, vendor and engineering recomendations were considered in the initial development of test and maintenance procedures currently in use at Farley Nuclear Plant (FNP).

2. APCo has, over the course of plant life, reviewed significant recomendations and incorporated these into

plant procedures as appropriate.

3. APCo has reviewed all recomendations issued by Westinghouse Electric Corporation, the NSSS supplier for FNP, and General Electric Corporation, the major supplier of electrical equipment at FNP.

4 A vendor contact program has been established with Colt 4

Industries, the diesel generator supplier, to upgrade all existing diesel generator manuals.

5. A fomal vendor contact program has been established with Westinghouse, General Electric and Colt Industries for receipt of vendor and engineering recommendations from these organizations.

6. Procedures have been established and are currently in place at FP.P which require a formal review be conducted whenever vendor and engineering recomendations are received to determine their applicability to equipment at FNP.

7. APCo believes that the current procedures in use at FNP, which require appropriate operability testing prior to returning equipment to service, coupled with surveillance requirements, demonstrate that equipment is capable of perfoming its safety-related function.

We have evaluated the above response and have concluded that additional steps must be taken by the licensee before this item can be deemed acceptable. The licensee indicated in their response that they have reviewed all recomendations issued by Westinghouse and General Electric and are establishing a vendor contact program with Colt Industries. We concur with the licensee's actions in this area and consider these actions to be in line with the intent of the Generic Letter. However, we also believe that these same steps should be taken with respect to all other safety-related components. The licensee should establish an interface program with all vendors of safety-related equipment supplied at Farley Nuclear Plants 1 and 2, to verify that they have the latest vendor recommendations and are notified of any new recomendations. Then a femal review should be perfomed by the licensee to verify that appropriate vendor infomation has been incorporated into maintenance and test procedures or Technical Specifications. The above reviews and interfaces are considered to be the preferred method for assuring that all appropriate vendor and engineering recomendations have been incorporatedintocurrent(in-use)maintenanceandtestprocedures. ,

! However, during a telecon between the NRC Project Manager, Region 11 staff and APCo personnel on September 3,1985, APCo indicated that most safety related components fell within the scope of the major vendors noted above. Procedures existing prior to the generic letter

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also included some vendor interfacing but not to the extent now required by the generic letter. APCo agreed to provide supplemental information by October 1, 1985 supporting their contention that the intent of the generic letter has been met.

E. Item 4.1, Reactor Trip System Reliability (Vendor-Related Modifications)

The licensee's response to this action item is acceptable and meets the intent of GL 83-28. The licensee states in their submittal that all vendor recomended reactor trip breaker modifications issued after August 1977 have been reviewed to verify that either (1) the modifica-tion was implemented or (2) a written evaluation of the technical reasons for not implementing the modification exists. The licensee also states that Reactor Trip Breaker modifications issued prior to August 1977 were included in the original plant design for Farley 1 and 2 and this was further confirmed with Westinghouse.

F. Item 4.5.1, Reactor Trip System Reliability (System Functional Testing)

The licensee's response to this item is acceptable and meets the intent of GL 83-28. The licensee confirmed in their response that they independently test the undervoltage and shunt trip features of the reactor trip breakers while the plant is on-line. This was also verified by the Region and is discussed in Inspection Report 348, 364/85-17.

G. Conclusion Based on our review of the licensee's response, we conclude that the licensee's responses to items 3.1.1, 3.1.2, 3.2.1, 4.1 and 4.5.1 are acceptable and meet the full intent of GL 83-28. The response to item 3.2.2 requires additional infomation to detemine acceptability.

During a telecon on September 3,1985 the licensee agreed to provide additional justification for Item 3.2.2.

Principal Contributor:

K. Landis