ML20235Z284

Safety Evaluation Supporting Util Responses to Generic Ltr 83-28,Items 3.2.1 & 3.2.2

ML20235Z284
Person / Time
Site:	Brunswick
Issue date:	03/08/1989
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20235Z239	List: ML20235Z236 ML20235Z284
References
GL-83-28, NUDOCS 8903150287
Download: ML20235Z284 (3)

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. SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION

.RELATED TO GENERIC LETTER 83-28 ITEMS'3.2.1 AND 3.2.2 CAROLINA POWER AND LIGHT COMPANY' BRUNSWICK STEAM ELECTRIC PLANT.

UNITS 1 AND"2 DOCKET NOS. 50-325 AND 50-324 y

1.0 ' INTRODUCTION, ,

' Generic Letter (GL)' 83-28 was . issued by the staff on July 8,1983. 'It describes intermediate-term actions to be taken by licensees and applicants to address. the generic' issues raised by the two anticipated ' transients

-without-scrams (ATWS) that occurred at Unit 1 of Salem Nuclear. Power Plant. GL 83-28 required licensees to develop and implement improved.

programs for post-trip review, classification of equipment, vendor interface, post-maintenance testing, and RTS reliability. j That letter also states-that the licensee's programs will be reviewed by Nuclear Regulatory Comission (NRC) and that- a Safety Evaluation (SE) will be issued.

On November 7,1983, Carolina Power'and Light.(CP&L) provided the NRC staff with responses-to GL'83-28.~ An Interim SE was transmitted to the-licensee' by a July 5,- 1985 NRC letter. :In this~ letter, the NRC requested that additional information be submitted, as committed to in'the licen-see's November 7, 1983' letter on Action Items 3.1.2, 3.2.1, and 3.2.2.

2.0 EVALUATION CP&L provided supplemental information on Action Item 3.2.1 by letter dated August 28, 1985 (NLS-85-309), and supplemental information on Action Item 3.2.2 by letters dated December 23, 1985 and December 22, 1986 (NLS-85-458 and NLS 86-293). Our evaluations of these supplemental responses are as follows:

A. Item 3'.2.1-- Review of Test and Maintenance Procedures and Technical Specifications (All Other Safety-Related Components)

Evaluation:

The licensee committed to review procedures and Technical Specifica-tions '(TS) to verify that testing of safety-related components is-required after maintenance has been performed. This testing is to ensure that safety-related equipment is capable of performing its safety function prior to being returned to service.

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. mc v The licensee's. supplemental response (Letter NLS-85-309), dated

. August 28, 1985, stated that the procedure reviews have been completed,and Jocumented. .The; licensee!s,reyjew,ofnprocedures'and TS-confirmed ~that"their post-maintenance testing program is being

' implemented to ensure that the components will perform their safety!

function when returned to' service. Based'on this review, the licensee's action. described in-the supplemental response is acceptable.

Conclusion The licensee's supplemental responses to GL 83-28' Action Item 3.2.1, noted the.following: ., ,n q,

1. Applicable vendor and engineering test guidance were reviewed and incorporated into test and maintenance procedures.

2. Review of procedures and TS confirms that. testing is required after maintenance to assure.that the components will function when returned to service.

Based on review of the-information submitted by.the licensee ~in their supplemental responses,. dated August 28, 1985, we conclude'that the licensee's action on GL 83-28, Action Item 3.2.1, is acceptable and meets' the intent of GL 83-28.'

B. ~ Item 3.2.2 - Post-Maintenance Testing (All'other' Safety-Related Components)

~.t Evaluation:

By letter. dated November 7,1983, CP&L committed to review their vendor and engineering recommendations to ensure that appropriate ,

test guidance is included in the test and maintenance procedures or the TS, where applicable. Also, they agreed to submit the results to s the NRC in a supplemental response by December 1985. In the interim Safety Evaluation issued on July 5, 1985, the staff concurred with i the licensee's plans and schedules for completing their review of vendor and engineering recommendations; however, this item was considered open pending receipt and evaluation of the licensee's supplemental response.

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In supplemental responses dated December 23, 1985, and December 22, 1986, the licensee provided information regarding the status and scope of their: reviews of vendor and engineering recommendations for safety-related equipment other than.the reactor trip system. The licensee indiccted in the De:: ember 23, 1985, response that they have initiated reviews ~of information supplied by the nuclear steam supply system vendor (General Electric), as well as other suppliers of l safety-related equipment, to ensure that appropriate test guidance is included in procedures or the Technical, Specifications; however, the licensee indicated that this task would not be completed until the.

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end of 1986. In a letter dated December 23, 1985, the licensee submitted the final results of their check of vendor and engineering recommendations. 'In this response, the licensee-made the following statements:

Identification of vendor recommendations from CP&L's NSSS vendor (as well as other safety equipment vendors) received through December 31, 1985, have been reviewed by plant personnel for applicability. Such vendor recommendations I

consist of Service Information Letters, Field Disposition Instructions, Service Advice Letters, Technical Information Letters, and Engineering Change Notices. Items identified but not yet implemented have been incorporated into the plant tracking system and currently await ) reparation of plant modification packages, material purc1ases, or budgeting approvals. Vendor recommendations received since December 31, 1985, are also incorporated into the vendor recommendation tracking program.

Investigation by the Vendor Recommendation Task Force into recommendations requiring incorporation into plant procedures is complete. Two related projects, however, are on-going--the Maintenance Procedure Rewrite effort and Equipment Data Base System development. Together, these three projects have helped incorporate additional or

. revised vendor information concerning plant equipment into the appropriate plant procedures and documents.

An existing plant procedure ENP-20. " Engineering Work Request," is utilized to track the implementation of newly received or currently outstanding vendor recommendations.

In addition, .AI-72, " Control Approval of Vendor Technical Manuals," provides the approved method for review of vendor information prrtdr to incorporation into plant documentation.

The program asN efined in these.two procedures, is an on-going method of reviewing and implementing vendor recommendations into plant procedures.

Conclusion -

Based on our review of these licensee statements, the staff finds the licensee's supplemental responses to be acceptable in meeting the intent of GL 83-28. The licensee has completed a check of vendor and engineering recommendations, as prescribed by Action Item 3.2.2, and has established controls to track the implementation of newly received or currently outstanding vendor recommendations. In addition, the licensee has established controls to ensure that a continuous program exists at Brunswick Steam Electric Plant. for reviewing and incorporating vendor recommendations into plant procedures. The staff considers this to be acceptable.

Principle Contributor: N. Merriweather, RII Dated: March 8, 1989

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