ML20209H841

Safety Evaluation Re Response to Generic Ltr 83-28,Items 3.1.1,3.1.2,3.2.1,3.2.2,4.1 & 4.5.1.Response to Item 3.2.2 Incomplete & Addl Info Required

ML20209H841
Person / Time
Site:	Summer
Issue date:	11/04/1985
From:	NRC
To:
Shared Package
ML20209H813	List: ML20209H807 ML20209H841
References
GL-83-28, NUDOCS 8511110237
Download: ML20209H841 (6)

Text

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i rNCLOSURE 1 dAFETY EVALUATION F0K UENERIC LETTER 83-ze, 11tMS 3.1.1, 3.1.2, 3.2.1, 3.2.2, 4.1 AND 4.5.1 v1HGIL C. SUMMER hUCLLAK dlATION UutKti NO. 50-395

1. INTRODUCTION In teDruary 1983, the Salem Nuclear Power Station experienced two failures of tne reactor trip system upon the receipt of trip signals. These failures were attributed to westinghouse - Type De-du reactor trip system (Kid) circuit breakers. The failures at Salem on February ze and 25, 1983, were believed to have been caused by a binding action within the undervoltage trip attacnment (UVTA) located insice the breaker cubicle. Due to problems with the circuit breakers at Salem and at other plants, NRL 1ssued Generic Letter (GL) 83-26, Kequired Actions.-Baseo on Generic Implications of Salem Anticipated Transient Witnout Scram (ATWS) Events, dated July 8,1983. Inis letter described intermeciate-term actions to De taken by licensee's and applicants as a result of the Salem anticipated transient without scram events. These actions were developed by the staff based on information contained in NURtu-1000, Generic Implications of ATWS Events at the Salem Nuclear Power Plant. Actions to De performed included development of programs to provide for post-trip review, classification of equipment, vendor interf ace, post-maintenance testing, and RTS reliability improve-ments. 1he Generic Letter stated that for Action Items 3.1.1, 3.1.2, 3.2.1, J.z.z, 4.1, and 4.5.1 NRL Regional Offices would perform a post-implementa-tion review and issue dafety Evaluations. Inis report is the Safety tvalua-tion of Soutn Larolina Electric ana uas submittals dated September 2, 1983; November 4,1983; April 30,1984; September 28, 1984; and February 29, 1984, to GL 83-28 for V. C. Summer Nuclear Station. An NRC inspection was conauct-ed at the Summer facility during January 14 - 18, 19ed, to review the licen-see's current program, planned program improvements, and implementation of present procedures associated with post-trip review, equipment classifica-tion, vendor interrace, post-maintenance testina, and reactor trip system rellatili ty. The detat is or the inspection fbiaings 'are discussed in Inspection Keport No. 50-395/ed-ua.

II. REVIEW uututLINES i

The licensee s responses were eieluatea for compliance to tne staff's l

pos'1'ns oelineated in GL 83-ze ter Action Items 3.1.1, 3.1. 2, 3. 2.1, 3.2.i, 4.1 ana 4.5.1. The requirements of the above action items, as described in tne beneric Letter, are paraphrased below:

8511110237 851104 PDR P ADOCK 05000395 PDR

I tnclosure 1 2 J.1 Post-Maintenance lesting (Reactor Trip System Components)

Fosition

1. Licensees and applicants shall suomit the results of tne1r review of test and maintenance procedures and technical Specifications to assure tnat 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 tunctions before being returned to service. l Z. 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 lechnical Specifications, where required.

3.2 Post-Maintenance Testing (All Other Safety-Related Components)

Position The following actions are appl cable to post-maintenance testing:

1. Licensees and applicants snail submit a report documenting the i extending of test and maintenance procedures and Technical I Specific.itions review to assure that post-maintenance operanslity testing of all safety-related equipment is required to De conducted and that the testing demonstrates tnat the equipment is ,

capable of performing its safety functions before being returned '

to service.

2. Licensees ano applicants shall submit the results of their cneck of vendor and engineering recommendations to ensure tnat any appro-priate test guidance is included in the test and maintenance procedures or the Technical Specifications where requireo.

4.1 Reactor irip System Reliability ivendor-Related Mod 171 cations)

Position All vendor-recomended reactor trip breaker modifications snail be rev1ewed to verify that either: (1) each modification has, in fact, been implemented; or (z) a written evaluation of the technical reasons s for not implementing a modification exists.

t g ror example, the modifications recomeitded by Westinghouse in NCD-Elec-18 for tne 08-50 breakers and a March 31, 1983, letter for tne

\ 05-416 breakers shall be implemented or a justification for not imple-menting snali be made available. Moo 1fications not previously made shall be incorporated or a written evaluation shall be provided.

Enclosure 1 3 4.5 Heactor Trip System Reliability (System Functional Testing)

Position Un-line functional testing of the reactor trip system, including independent testing of the diverse trip teatures, shall* be performed on all plants.

1. The diverse trip teatures to be testea include the breaker under-voltage and shunt trip teatures on Westingnouse, B&W (see Action item 4.3 of GL 83-28) and Lt plants; the circuitry used for power interruption with the silicon controlled rectifiers on e6W plants (see Action item 4.4 of GL 83-28); ana Ine scram pilot valve ana backup scram valves'(including all initiating circuitry) on ut plants.

III. EVALUnlION AND CONCLUSIUN By letters dateo deptember 2,1983; november 4,1983; February zy, 1984; April 30, 1964, and September 26, 19e4, South Carnlina Electric and Gas Company, tne licensee of V. C. Summe'r Nuclear Station, provided information regarding their compliance to Sections 3.1, J.2, 4.1, and 4.5 of bL es-28.

We nave evaluated the licensee's responses against the NRC positions described in Section : 1 above for completeness and adequacy. We concluded that the licensee's responses to Action Items 3.1.1, 3.1.2, 3.2.1, 4.1, and 4.5.1 were acceptable and met the intent of GL eJ-28. The licensee's response to Action Item J.z.2 is considered incomplete and additional information is needed to determine acceptaoliity. Enclosure 2 to tne transmittal letter for tnis SE describes the additional information needed from the licensee.

Uelineated below are the resul ts of our evaluation and a brief summary of the licensee *s response:

A. Item 3.1.1, Review of lest and Maintenance Procedures and Technical Spec 1tications (Reactor Irip dystem Components)

The licensee's response to this item is acceptable and meets the intent of GL 83-28. The licensee stated that post-maintenance operability testing of Reactor Irlp System components is conducted in accordance with approved test procedures and that the testing demonstrates that the equipment is capaDie of performing its safety functions before Deing returned to service.

B. Item 3.1.2, Check of vendor and Engineering Mecommendations for testing i and Ma1ntenance (Reactor Trip dystem Components)

' The licensee's response to this item is acceptable and meets tne intent of GL es-ze. The licensee performed a review cf vendor ano engineering recommendations for Westinghouse supplied Reactor Trip System components and verified tnat vendor recommendations nave been properly incorporated into appropriate test and maintenance procedures with the exception of Technical Bulletin nSD-TB-77-11. The licensee indicated i

tnclosure 1 4 that the applicability.ot this bulletin to the dummer facility was being discassed with Westingnouse.

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

The 11censee's response to tnis item is acceptable and .neets the intent of GL 83-26. Ine licensee stated in their response that applicable i

procedures nave been reviewed and post-maintenance operability testing is performed as appropriate, subsequent to maintenance activities, on safety-related equipment identified in the Technical Specifications,

u. Item 3.2.2, Check of vendor and Engineering Mecommendations for lesting ano Maintenance (All utner Safety-Related Components)

Ine licensee's response to In1s item is considerea incomplete and l additional infonnation is needed to determine acceptability. Ine licensee indicated in their response dated November 4,1983, that a eneck of vendor and engineering recommendations concerning test guidance for safety-related components other than the West 1ngnouse i suppliea Keactor Trip System components would be performed in 1 accoraance with the schedule oeveloped in response to item 2.2.2. The licensee's final response to item 2.2.4 was submitted on Septemoer 28, 1964; nowever, it did not specifically state that tne above review was performed. The licensee needs to submit a statement confirming tnat vendor recommended test guidance has been reviewed, evaluated, and wnere appropriate included in the test and maintenance procedures or tne Technical Specifications for all safety-related components otner tnan the Westinghouse supplied Reactor Trip dystem components which nave been reviewed in accordance with Item 3.1.2.

t. Item 4.1, Reactor t rip System Reliability (vendor-Related Moditi-cationsJ The licensee *s response and subsequent action concerning tnis item are acceptable and meet the intent of GL 83-28. The licensee stated in their November 4, ne3 response that a review of vendor recommended reactor trip breaker modifications has been performed and each modifi-cation, with the exception of the automatic actuation of the breaker shunt trip attacnment, hN been implementec. Subsequent t:. this response, NRC approved th:: 11censee's i)roposed design change for automatic actuation of tne breaker snunt trip attachment le a letter dated November 23, 1083. However, acring a Regional Inspection performed on January 14 - IS,1985, it was revealed that the shunt modification had been inspiled ard tested.

t .' Item 4.5.1, Reactor Pip syyte*2 Reliability tdystem Functional Testing) j lhe licenne's res;me at ubsequent action concerning this item are acceptable and trat the intent of GL 83-zo.

in the response cated November 4, 333, ete lii?nis et. uJicated that the uncervoltage and shunt tri7 device > t.o..id ret. be indepenaently tested on-line Decause of

the plant usign. Tht 1kerrat suomitted a design change to NRC in

Enclosure 1 5 letters dated August 31, 1983 and October 20, 1983, lhe design change was reviewed and approved by NRC in a letter to the licensee dated November 23, 1983. The Region verified during inspection bu-395/85-03 that tne licensee had installea the shunt modification (Plant Modification Mut 20208) and had developed surveillance proceaures which test the automatic shunt trip attachment indepenaently of the

• undervoltage trip device.

G. Conclusion Basea on our reviews and plant inspection, 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 anc meet the intent of GL 64-z6; however, item 3.2.2 is incomplete and additional information, as descriced in Enclosure 2 to the transmittal letter for this SE, is neecea tor us to complete our evaluation. Acceptable response to tne aoove noted deficiency is required before we can complete our Safety Evaluation of the V.C.

Summer Nuclear Station. We will review this response when received and will report our findings in a supplement to this Safety Evaluation.

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ENCL 0dukt z Kt0 VEST FOR ADDITIONML INFORMATION

v. L. SUMMER NUCLEAR STAllVN GENERIC LtiltK 83-28, ITEM 3.2.2

• D. Item 3.z.z, Check of Vendor and tngineering Recommenaations for Testing ano Maintenance (All Otner dafety-Related Components) lhe licensee's response to this item is consiaered incomplete ana additional information is needed to determine acceptability, ine licensee indicated in their response dated Novemoer 4, 1983 that a eneck or vendor and engineering recommendations concerning test guidance for safety-related components other than the Westinghouse supplied Reactor Trip dystem components would De performed in accordance with the scneaule developed in response to item 2.2.2. Tne licensee's final response to item 2.2.2 was suomitted on September ze, 1964; however, it did not specifically state tnat the above review had been performed. ine licensee needs to suomit a statement confirming that vendor recommended test guidance has been reviewed, evaluated, and where appropriate included in the test anc maintenance procedures or the technical Specifications for all safety-related components other than the Westingnouse supplied Reactor trip dystem components wnicn have been reviewed in accordance with item 3.1.2.

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