ML20235J944

Safety Evaluation Supporting Supplemental Responses to Generic Ltr 83-28,Items 3.1.1,3.1.2,3.2.1,3.2.2 & 4.5.1 Per NUREG-1000

ML20235J944
Person / Time
Site:	Vogtle
Issue date:	07/07/1987
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20235J900	List: ML20235J897 ML20235J944
References
RTR-NUREG-1000 NUDOCS 8707160068
Download: ML20235J944 (3)

Text

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t g ENCLOSURE SAFETY EVALUATION RELATED TO GENERIC LETTER 83-28, ITEMS 3.1.1, 3.1.2, 3.2.1, 3.2.2, and 4.5.1 GEORGIA POWER COMPANY V0GTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2 DOCKET NOS. 50-424 and 50-425 INTRODUCTION Generic Letter (GL) 83-28 was issued by the staff on July 8,1983. It described intermediate-term actions to be taken by the licensees and applicants to address the generic issues raised by the two anticipated transients without scram (ATWS) events that occurred at Unit 1 of Salem Nuclear Power Plant. These actions were developed by the staff based on information contained in NUREG-1000, " Generic Implications of ATWS Events at the Salem Nuclear Power Plant." Actions to be performed included development programs to provide for post-trip review, classification of equipment, vendor interface, postmaintenance testing, and reactor trip system reliability improvements. The GL s tated that for Items 3.1.1, 3.1.2, 3.2.1, 3.2.2, and 4.5.1 NRC Regional Offices would perfom a post-implementation review and issue safety evaluations. This report is the Regional safety evaluation of Georgia Power Company responses to the above items.

EVALUATION By letters dated November 8, 1983, and August 26, 1986, the licensee provided information regarding compliance with items 3.1.1, 3.1.2, 3.2.1, 3.2.2, and 4.5.1 of GL 33-28. The staff evaluated the licensee's responses aaainst the NRC positions described in the GL for completeness and adequacy. The staff found the licensee's responses to be incomplete, thus requiring additional information to determine acceptability. These deficiencies were transmitted to the licensee by letter dated December 31, 1986 and in SSER 5.

i The licensee's supplemental responses to Items 3.1.1, 3.1.2, 3.2.1, 3.2.2, and  !

4.5.1 submitted by letters dated January 15 and June 9,1987 were reviewed ana  !

found acceptable.

Delineated below are the results of the staff's evaluations and a brief summary of the licensee's supplemental responses: ,

l l Generic Letter 83-28, Item 3.1.1 l Item 3.1.1 requires licensees and applicants to submit the results of their l review of test procedures, maintenance procedures, and Technical i Specifications to ensure that postmaintenance 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.

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The licensee stated in its final response dated January 15, 1987, that l procedures had been established which require postmaintenance testing of the  ;

reactor trip switchgear. The response also stated that test procedures had been developed to utilize the solid state protection system panel or the main control board trip handswitch to demonstrate operability of the reactor trip switchgear. During its review, the staff did not interpret the licensee's trip switchgear statement to encompass all safety-related components in the reactor trip system. The licensee's use of " reactor trip switchgear" instead of reactor trip system components was discussed during a telecon between the licensee and NRC on June 1, 1987. The licensee's representative stated that the statement " reactor trip switchgear" meant all safety-related components in the reactor trip system. This was confirmed by letter dated June 9,1987.

Based on the above, the licensee's response is acceptable.

Generic Letter 83-28, Item 3.1.2 Item 3.1.2 requires licensees and applicants to submit the results of their i check of vendor and engineering recommendations to ensure that any appropriate I test guidance is included in the test and maintenance procedures or the Technical Specifications, where required.

The licensee's supplemental response dated January 15, 1987, to Item 3.1.2 stated that procedures are written referencing vendor manuals, if applicable, and when procedures are reviewed, the review criteria requires that the procedure be reviewed against applicable vendor manuals. The licensee also indicated that engineering and vendor recommendations were checked to ensure that appropriate test guidance has been included in the test and maintenance procedures or the Technical Specifications. The licensee's response to Item 3.1.2 is acceptable.

Generic Letter 83-28, Item 3.2.1 Item 3.2.1 requires licensees and applicants to submit a report documenting the extending of test and maintenance procedures and Technical Specifications review to ensure that postmaintenance operability testing of all safety-related equipment is required to be conducted and that the testing demonstrates that the equipment is capable of perfonning its safety functions before being returned to service.

The licensee's supplemental response dated January 15, 1987, to Item 3.2.1 stated that maintenance of safety-related systems / components is controlled and processed via Maintenance Work Order (MW0) procedures. These procedures provide controls which require postmaintenance testing of safety-related systems / components to prove their operability. The licensee also stated that it has completed a review of test and maintenance procedures and appropriate Technical Specifications to ensure that the testing demonstrates that the equipment is capable of performing its safety function. The licensee's response to Item 3.2.1 is acceptable.

g l Generic Letter 83-28, Item 3.2.2 Item 3.2.2 requires licensees and applicants to 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 Technical Specifications, where required.

The licensee's response to Item 3.2.2 states that procedures are written referencing vendor manuals and when procedures are reviewed they are checked against the applicable manual. The licensee indicated that vendor manuals are  :

controlled by Administrative Procedure 00108-C and that vendor and engineering I recommendations are reviewed and are included in the test and maintenance i procedures or the Technical Specifications. The licensee's response to Item l 3.2.2 is acceptable.

I Generic Letter 83-28. Item 4.5.1 1 Item 4.5.1 requires that online functional testing of the reactor trip system including independe~nt testing of the diverse trip features be performed. The breaker undervoltage and shunt trip features in Westinghouse plants should be included.

The licensee's supplemental response dated January 15, 1087, stated that a surveillance procedure has been developed which verifies the capability of the undervoltage and shunt trip features to independently trip the reactor trip

< breakers. The surveillance test is performed each month, and each train is tested at least once every 62 days on a staggered test basis. The response stated that a Westinghouse automatic shunt trip panel had been added to the reactor trip switchgear cabinets and provides the capability to independently test the undervoltage and shunt trip devices. The licensee's response to Item 4.5.1 is acceptable.

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CONCLUSION l Based on the above statements, the staff finds the licensee's responses to Items 3.1.1, 3.1.2, 3.2.1, 3.2.2, and 4.5.1 acceptable, thereby meeting the intent of GL 83-28. The licensee has procedures to ensure that vendor and engineering recommendations are included in test and maintenance procedures.  ;

The licensee also confirmed that it had reviewed test and maintenance procedures and Technical Specifications and that postmaintenance testing is required on the reactor trip system components and all other safety-related components.

The licensee stated that it has installed equipment to independently verify the capability of the undervoltage and shunt trip devices to trip the reactor trip breakers.

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