ML20211L105
| ML20211L105 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/27/1986 |
| From: | George Thomas PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | Noonan V Office of Nuclear Reactor Regulation |
| References | |
| GL-83-28, SBN-1146, NUDOCS 8607010269 | |
| Download: ML20211L105 (17) | |
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George S. Thomas Vice Pre 90er+Nuctect Produchon Pub 5c Service of New Hampshire New Hampshire Yankee Division June 27, 1986 SBN-1146 T.F. B7.1.2 United States Nuclear Regulatory Commission Washington, DC 20555 Attention:
Mr. Vincent S. Noonan, Project Director PWR Project Directorate No. 5
References:
(a) Construction Permit CPPR-135 and CPPR-136, Docket Nos. 50-443 and 50-444 (b) USNRC Letter, dated July 8,1983, " Required Action Based On Generic Implication Of Salem ATWS Events (Generic Letter 83-28)" D. G. Eisenhut to all licensees of operating reactors, applicants for operating license holders of construction permits Subj ect:
Generic Letter 83-28; Additional Information
Dear Sir:
Enclosed please find the Summary Status concerning the responses to Generic Letter 83-28.
We trust that the enclosed provides sufficient information for the Staff to close out the remaining open items.
Very truly yours,
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George. Thomas Enclosure cc: ASLB Service List 8607010269 860627
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PDR ADOCK 05000443 0(.7 A
PDR L
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j P.O. Box 300 Seabrook.NHO3874 Telephone (603)474-9521
'Dicne Currsn, Esquire Patar J. Mathawa, Mayor Harmon & Weico City Hs11 2001 S. Street, N.W.
Nawburyport, MA 01950 Suite 430 Washington, D.C.
20009 Judith H. Mizner Silvergate, Gertner, Baker, Sherwin E. Turk, Esq.
Fine, Good & Mizner Office of the Executive Legal Director 88 Broad Street U.S. Nuclear Regulatory Commission Boston, MA 02110 Tenth Floor Washington, DC 20555 Calvin A. Canney City Manager Robert A. Backus, Esquire City Hall 116 Lowell Street 126 Daniel Street P.O. Box 516 Portsmouth, NH 03801 Manchester, NH 03105 Stephen E. Merrill, Esquire Philip Ahrens, Esquire Attorney General Assistant Attorney General George Dana Bisbee, Esquire Department of The Attorney General Assistant Attorney General Statehouse Station #6 Office of the Attorney General Augusta, ME 04333 25 Capitol Street Concord, NH 03301-6397 Mrs. Sandra Gavutis Chairman, Board of Selectmen Mr. J. P. Nadeau RfD 1 - Box 1154 Selectmen's Office Kennaington, NH 03827 10 Central Road Rye, NH 03870 Carol S. Sneider, Esquire i
Assistant Attorney General Mr. Angie Machiros Department of the Attorney General Chairman of the Board of Selectmen One Ashburton Place, 19th Floor Town of Newbury Boston, MA 02108 Newbury, MA 01950 Senator Gordon J. Humphrey Mr. William S. Lord U.S. Senate Board of Selectmen Washington, DC 20510 Town Hall - Friend Street (ATTN: Tom Burack)
Amesbury, MA 01913 i
Richard A. Hampe, Eng.
Senator Gordon J. Humphrey I
Hampe and McNicholas 1 Pillsbury Street 35 Pleasant Street Concord, NH 03301 Concord, NH 03301 (ATTN: Herb Boynton) l Thomas F. Powers, III H. Joseph Flynn, Esquire Town Manager Office of General Counsel
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Town of Exeter Federal Emergency Management Agency 10 Front Street 500 C Street, SW Exeter, NH 03833 Washington, DC 20472 Brentwood Board of Selectmen Paul McEachern, Esquire RFD Dalton Road Matthew T. Brock, Esquire Brentwood, NH 03833 Shaines & McEachern 25 Maplewood Avenue Gary W. Holmes, Esq.
P.O. Box 360 Holmes & Ells Portsmouth, NH 03801 47 W5g.tacunnet Road Hampton, NH 03842 Robert Carrigg Town Office l
Mr. Ed' Thomas Atlantic Avenue FEMA Region I North Hampton, NH 03862 442 John W. McCormack PO & Courthouse Boston, MA 0?109
ENCLOSURE TO SBN-1146 i.
Generic Letter 83 Summary Status NHY i
Position Response Ref.
Comments 4
1.1 Post Trip Review (Program Description and Procedure)
I 1.1 Licensees and applicants shall describe their SBN-576 Post Trip Review procedure program for ensuring that unscheduled reactor Nov. 4, 1983 OS1000.08 was submitted in shutdowns are analyzed and that a determination SBN-1137 SBN-1137. This response i
is made that the plant can be restarted safely.
June 24, 1986 should close out Item 1.1, l
A report describing the program for review and including 1.1.1 through 1.1.7, analysis of such unscheduled' reactor shutdowns of Generic Letter 83-28.
should include as a minimum:
1.J.1 The criteria for determining the acceptability of restart.
i l.1.2 The responsibilities-and authorities of personnel
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who will perform the review and analysis of these events.
1.1.3 The necessary qualifications and training for the responsible personnel.
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1.1.4
.The sources of plant information necessary to i
conduct the review and analysis. The sources of information should include the measures and equipment that provide the necessary detail and-type of information to reconstruct the event
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accurately and in sufficient detail for proper understanding.'(See Action 1.2) i 1,
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NHY Position Response Ref.
Comments
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1.1.5 The methods and criteria for comparing the event information with known or expected - plant behavior (e.g., that safety-related equipment operates as required by the Technical Specifications or other performance specifications related to the safety functions).
1.1.6 The criteria for determining the need for independent assessment of an event (e.g., a case in which the cause of the event cannot be posi-tively identified, a competent group such as the Plant Operations Review Committee, will be consulted prior to authorizing restart) and guidelines on the preservation of physical evidence (both hardware and software) to support independent analysis of the event.
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1.1.7 ltems 1 through 6 above are considered to be the
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basis for the establishment of a systematic i
method to assess unscheduled reactor shutdowns.
The systematic safety assessment procedures compiled from the above items, which are to be used in conducting the evaluation, should be in the report.
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WY Position Response Ref.
Comments
'l.2 Post Trip Review - Data and Information Capability 1.2 Licensees and applicants shall have, or have SBN-576 NRC's " Technical Evaluation planned, a capability to record, recall, and display Nov. 4, 1983 Report for Generic Letter data and information to permit diagnosing the causes SBN-961 83-28, Item 1.2" was addressed - l of unscheduled reactor shutdowns prior to restart Mar. 6, 1986 in SBN-961. This response and for ascertaining the proper functioning of should close out Item 1.2, safety-related equipment.
including 1.2.1 through 1.2.4, of Generic Letter 83-28.
l Adequate data and information shall be provided to correctly diagnose the cause of unscheduled reactor shutdowns and the proper functioning of safety-related equipment during these events using systematic safety i
assessment procedures (Action 1.1).
The data and information shall be displayed in a form that permits ease of assimilation and analysis by persons trained in the use of systematic safety assessment procedures.
A report shall be prepared which describes and justifies the adequacy of equipment for diagnosing an unscheduled reactor shutdown. The report shall describe as a minimum:
1.2.1 Capability for assessing sequence of events (on-off SBN-576 indications).
Nov. 4, 1983 SBN-961 1.
Brief description of equipment (e.g., plant Mar. 6, 1986 computer, dedicated computer, strip chart).
2.
Parameters monitored.
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Time discrimination between events.
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Position Response Ref.
Comments 4.
Format for displaying data and information.
5.
Capability for retention of data and information.
6.
Power source (s) (e.g., Class lE, non-Class lE, noninterruptable).
i 1.2.2 Capability for assessing the time history of analog SBN-576 variables needed to determine the cause of Nov. 4, 1983 unscheduled reactor shutdowns, and the functioning SBN-961 of safety-related equipment.
Mar. 6, 1986 1.
Brief description of equipment (e.g., plant computer, dedicated computer, strip charts).
2.
Parameters monitored, sampling rate, and basis for selecting parameters and sampling rate.
3.
Duration of time history (minutes before trip and minutes after trip).
4.
Format for displaying data including scale (readability) of time histories.
5.
Capability for retention of data, information, and physical evidence (both hardware and software).
1.2.3 Other data and information provided to assess the SBN-576 j
cause ' of unscheduled reactor shutdowns.
Nov. 4, 1983 SBN-961 Mar. 6, 1986 1.2.4 Schedule for any planned changes to existing data SBN-576 and information capability.
Nov. 4, 1983 I,
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m NHY Position Response Ref.
Comments 2.1 Equipment Classification and Vendor Interface (Reactor Trip System Components) 2.1.1 Licensees and applicants shall confirm that all SBN-576 In SBN-861, NHY stated that l
components whose functioning is required to trip Nov. 4, 1983 an engineering review of the reactor are identified as safety-related on SBN-861 applicable documents had been documents, procedures, and information handling Aug. 22, 1985 performed and the reactor systems used in the plant to control safety-related trip system components had activities, including maintenance, work orders, and been identified and classified parts replacement.
as safety related. This response should close out Item 2.1.1 of Generic Letter 83-28.
2.1.2 In addition, for these components, licensees and SBN-576 In SBN-576, NHY stated that applicants shall establish, implement, and maintain Nov. 4, 1983 this requirement is satisfied a continuing program to ensure that vendor informa-by existing provisions of tion is complete, current, and controlled throughout Seabrook Station Administra-the life of the plant, and appropriately referenced tive and Quality Assurance or incorporated in plant instructions and procedures.
procedures. This response i
should close out Item 2.1.2 of Generic Letter 83-28.
2.1.3 Vendors of these components should be contacted and SBN-576 In SBN-576, NHY stated that l
an interface established. Where vendors can not be Nov. 4, 1983 this requirement is satisfied identified, have gone out of business, or will not by existing provisions of supply the information, the licensee or applicant Seabrook Station Administra-shall assure that sufficient attention is paid to tive and Quality Assurance j
equipment _ maintenance, replacement, and repair to procedures. This response.
I compensate for the lack of vendor backup to assure should close out Item 2.1.3
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reactor trip system reliability.
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Comments t
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2.1.4 The vendor interface program shall include periodic SBN-576 In SBN-576, NHY stated that communication with vendors to assure that all appli-Nov. 4, 1983 this requirement is satisfied cable information has been received. The program by existing provisions of i
l should use a system of positive feedback with vendors Seabrook Station Administra-for mailings containing technical information. This tive and Quality Assurance could be accomplished by licensee acknowledgment for procedures. This response receipt of technical mailings, should close out Item 2.1.4 of Generic Letter 83-28.
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2.1.5 The program shall also define the interface and SBN-576 In SBN-576, NHY stated that i
division of responsibilities among the licensees and Nov. 4, 1983 this requirement is satisfied j.
the nuclear and nonnuclear divisions of their vendors by existing provisions of that provide service on Reactor Trip System components Seabrook Station Administra-to assure that requisite control of and applicable tive and Quality Assurance instructions for maintenance work are provided.
procedures. This response should close out Item 2.1.5' of Generic Letter 83-28.
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NHY l
Position Response Ref.
Comments 2.2 Equipment Classification and Vendor Interface (Program for All Safety Related Components) 2.2 Licensees and applicants shall submit, for staf f review, SBN-576 NHY provided its original a description of their programs for safety-related equip-Nov. 4, 1983 response to Item 2.2.1.1, i
ment classification and vendor interface as described below:
through 2.2.1.6 in SBN-576.
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The NRC's Request for-1 2.2.1 For equipment classifications, licensees and applicants SBN-576 Additional Information i
shall describe their program for ensuring that all components Nov. 4, 1983 letter of June 18, 1985, I
of safety-related systems necessary for accomplishing indicated that in a required safety functions.are identified as safety-related preliminary review of all on documents, procedures, and information handling systems of the 2.2 items, no further used in the plant ~to control safety-related activities, information was requested including maintenance, work orders and replacement parts.
and the original response This description shall include:
in SBN-576 was adequate.
NHY assumes that all 2.2.1.1 'The criteria for identifying components as safety SBN-576 ltems 2.2.1 are acceptable l
related within systems currently classified as safety Nov. 4, 1983 and closed.
related. This shall not be interpreted to require changes in safety classification at the systems level.
2.2.1.2 A description of the information handling system used SBN-576 to identify safety-related components (e.g., computer-Nov. 4, 1983 4
ized equipment list) and the methods used for its development and validation.
2.2.1.3 A description of the process by which station personnel SBN-576 use this information handling system to determine that Nov. 4, 1983 an activity is safety related and what procedures for maintenance, surveillance, parts replacement, and other activities defined in the introduction to 10CFR50, i
Appendix B, apply to safety-related components.
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NHY Position Response Ref.
Comments 2.2.1.4 A description of the management controls utilized to SBN-576 verify that the. procedures for preparation, validation, Nov. 4, 1983 and routine utilization of the information handling system have been followed.
2.2.1.5 A demonstration that appropriate design verification SBN-576 and qualification testing is specified for procurement Nov. 4, 1983 of safety-related components. The specifications shall
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include qualification testing for expected safety service conditions and provide support for the licensee's receipt of testing documentation to support the limits of life recommended by the supplier.
2.2.1.6 Licensees and applicants need only to submit for staff SBN-576 review the Equipment Classification Program for safety-Nov. 4, 1983 related components. Although not required to be sub-mitted for staff review, your Equipment Classification Program should also include the broader class of struc-tures, systems, and components important to safety required by GDC-1 (defined in 10CFR50, Appendix A,
" General Design Criteria, Introduction").
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NHY I
Position Response Ref.
Comments 2.2.2 For vendor interface, licensees and applicants shall SBN-556 NHY stated in SBN-576 that establish, implement, and maintain a continuing program Sept. 6, 1983 they would be participating i
to ensure that vendor information for safety-related SBN-564 in the program establ.ished by components is complete, current, and controlled Sept. 6, 1983 NUTAC.
In SBN-676, NHY throughout the life of their plants, and appropriately SBN-576 reestablished this commitment i
referenced or incorporated in plant instructions and Nov. 4, 1983 to be a full participant in procedures. Vendors of safety-related equipment should SBN-676 the newly established Nuclear be contacted and an interface established. Where June 29, 1984 Plant Reliability Data System vendors cannot be identified, have gone out of business, (NPRDS) by commercial 4
or will not supply information, the licensee or appli-operation. This effort is cant shall assure that sufficient attention is paid to ongoing and NHY fully intends equipment maintenance, replacement, and repair to to have this program in place compensate for the lack of vendor backup to assure by commercial operat. ion.
This reliability commensurate with its safety function response should close out (GDC-1).
The program shall be closely coupled with Item 2.2.2 of Generic Letter Action 2.2.1 above (equipment qualification). The 83-28.
program shall include periodic communication with vendors to assure that all applicable information has been received. The program should use a system of positive feedback with vendors for mailings containing technical information. This could be accomplished by i
licensee acknowledgment for receipt of technical mailings.
It shall also define the interface and division of responsibilities among the licensee and i
the nuclear and nonnuclear divisions of their vendors that provide service on safety-related equipment to assure that requisite control of and applicable instructions for maintenance work on safety-related equipment are provided.
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l NHY Position Response Ref.
Comments t
3.1 Post-Maintenance Testing (Reactor Trip System Components) 3.1.1 Licensees and applicants shall submit the results of their SBN-576 Procedures have been developed review of test and maintenance procedure and Technical Nov. 4, 1983 to provide the necessary guid-Specifications to assure that post-maintenance operability ance to perform post-maintenance testing of safety-related components in the Reactor Trip operability testing of safety.
System is required to be conducted and that the testing related components in the demonstrates that the equipment is capable of performing Reactor Trip System. This its safety functions before being returned to service.
response should close out Item 3.1.1 of Generic Letter 83-28.
l 3.1.2 Licensees and applicants shall submit the results of SBN-576 A Westinghouse modification has I
their check of vendor and engineering recommendations to Nov. 4, 1983 been incorporated at Seabrook ensure that any appropriate test guidance is included in Station for the Reactor Trip the test and maintenance procedures or the Technical System, and maintenance and Specifications, where required.
post-maintenance procedures have been developed to incorporate these changes.
This response should close out Item 3.1.2 of Generic Letter 83-28.
3.1.3 Licensees and applicants shall identify, if applicable, SBN-576 Item 3.1.3 was accepted by any post-maintenance test requirements in existing Nov. 4, 1983 the NRC in the SER letter of Technical Specifications which can be demonstrated to December-24, 1985.
degrade rather than enhance safety. Appropriate changes l
to these test requirements, with supporting justification, shall be submitted for staf f approval.
(Note that Action 4.5 discusses on-line system functional testing.)
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NHY l
Position Response Ref.
Comments l
3.2 Post-Maintenance Testing (All Other Safety-Related Components)
I 3.2.1 Licensees and applicants shall submit a report document-SBN-576 In SBN-576, NHY stated that four ing the extending of test and maintenance procedures and Nov. 4, 1983 general procedures already in Technical Specifications review to assure that post-place required a specific review i
maintenance operability testing of all safety-related for post-maintenance testing equipment is required to be conducted and that the requirements and that such testing demonstrates that the equipment is capable of testing will be included in the i
performing its safety functions before being returned to individual procedures. All l
service.
post-maintenance operability testing procedures for identi-fled safety related equipment l
will be developed and in place as required. This response should close out Item 3.2.1 of Generic Letter 83-23.
I 3.2.2 Licensees and applicants shall submit the results of SBN-576 Procedures that have been j
their check of vendor and engineering recommendations Nov. 4, 1983 developed for post-maintenance to ensure that any appropriate test guidance is included operability testing have been-in the test and maintenance procedures or the Technical reviewed to incorporate any Specifications where required.
vendor and engineering recommendations. This response should close out Item 3.2.2 of Generic Letter 83-23.
3.2.3 Licensees and applicants shall identify, if applicable, SBN-576 Item 3.2.3 was accepted by any post-maintenance test requirements in existing Nov. 4, 1983 the NRC in the SER letter of Technical Specifications which are perceived to degrade SBN-861 December 24, 1985.
rather than enhance safety. Appropriate changes to these Aug. 22, 1985 test requirements, with supporting justification, shall be submitted for staff approval.
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NilY Position Response Ref.
Comments 1
1 4.1 Reactor Trip System Reliability (Vendor-Related Modifications) 4.1 All vendor-recommended reactor trip breaker modifica-SBN-576 In SBN-868, NHY provided
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tions shall be reviewed to verify that either:
- 1) each Nov. 4, 1983 information to the NRC about modification has, in fact, been implemented; or 2) written SBN-868 the reactor trip breaker evaluation of the technical reason for not implementing Sept. 9, 1985 modifications. This response a modification exists.
should close out Item 4.1 of l
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Comments 4.2 Reactor Trip System Reliability (Preventing Maintenance and Surveillance Program for Reactor Trip Breakers) 4.2.1 A planned program or periodic maintenance, including SBN-576 In SBN-855, NHY provided lubrication, housekeeping, and other items recommended by Nov. 4, 1983 additional information to the the equipment supplier.
SBN-855 NRC about Seabrook Station's Aug. 5, 1985 Periodic Maintenance Program for Reactor Trip Breakers.
This response should close out item 4.2.1 of Generic Letter 83-28.
4.2.2 Trending of parameters affecting operation and measured SBN-576 In SBN-855, NilY provided during testing to forecast degradation of operability.
Nov. 4, 1983 additional information to the SEN-855 NRC about Seabrook Station's Aug. 5, 1985 trend infornation that will be used to fo' recast degradation of operability. This response should close out Item 4.2.2 of Generic Letter 83-28.
4.2.3 Life testing of the breakers (including the trip SBN-576 In SEN-576, NHY stated that the attachments) on an acceptable sample sis:e.
Nov. 4, 1983 Westinghouse Owners Group has a a contract with Westinghouse for cycif c life and clase 18 quali-fication of shunt trip cyclic testing of undervoltage trip of l
DS breakers.
4.2.4 Periodic replacement of breakers or components consistent SBN-576 Dependent on the results of the with derdonstrated lif e cycles.
Nov. 4, 1983 Westinghouse report, periodic replacement of breaL?rs or com-ponents will be schens?ed.
These responses should close.out Items 4.2.3 and 4.2.4 of Generic Lettar 83-28..,,
NHY Posi_ tion Response Ref.
Comments 4.3 Reactor Trip System _ Reliability (Automatic Actuation of Shunt Trip Attachment for Westinghouse and B&W Plants) 4.3.
Westinghouse and B&W reactors shall be modified by SBN-576 In SBN-868, NHY submitted providirig automatic Reactor Trip System actuation of Nov. 4, 1983 information to Item 4.3 and the breaker shunt c'cip attachments. The shunt trip SBN-677 additional information was attachment shall be considered safety related (Class IE).
June 29, 1984 issued in SBN-967. This SBN-747 response should close out Jan. 7, 1985 Item 4.3 of Generic Letter SBN-868 83-28.
Sept. 9, 1985 SBN-967 Mar. 17, 1986 NHY Position Response Ref.
Comments 4.5 Reactor Trip System Reliability (System Functional Testing) 4.5.1 The diverse trip features to be tested include the breaker SBN-576 Testing procedures have been undervoltage and shunt trip features on Westinghouse, B&W Nov. 4, 1983 developed to independently (see Action 4.3 above), and CE plants; the circuitry check the shunt and the used for power interruption with the silicon-controlled undervoltage trips. These rectifiers on B&W plants (see Action 4.4 above); and the procedures will be available scram pilot valve and backup scram valves (including all to the NRC open request.
initiating circuitry) on CE plants.
4.5.2 Plants not currently designed to permit periodic on-line SBN-576 In SBN-956, NilY provided testing shall justify not making modifications to permit Nov. 4, 1983 additional information to such testing.
Alternatives to on-line testing proposed SBN-956 address Item 4.5.2.
This by licensees will be considered where special circum-Mar. 4, 1986 response should close out stances exist and where the objective of high reliability Item 4.5.2 of Generic Letter i
can be met in another way.
83-28.
4.5.3 Existing intervals for on-line functional testing SBN-576 In SBN-956, NHY stated that since required by Technical Specifications shall be reviewed to Nov. 4, 1983 Seabrook Station is an NTOL, determine that the intervals are consistent with achieving SBN-956 no on-line testing history is high Reactor Trip Systems availability when accounting for Mar. 4, 1986 available. A review of Generic consideration such as:
Letter 85-09 for on-line func-tional testing requirements has 1.
Uncertainties in component failure rates.
been conducted during the review 2.
Uncertainty in common mode failure rates.
stage of the Seabrook Station 3.
Reduced redundancy during testing.
Technical Specifications.
4.
Operator errors during testing.
Changes resulting from this 5.
Component " wear-out" caused by the testing.
review have been discussed with the staff. Any changes result-ing from the WOG testing will be discussed with the staff as it becomes available.