ML20236F588

Safety Evaluation Supporting Util 831104,841102,1231 & 851203 Responses to Items 3.1.1,3.1.2,3.2.1,3.2.2 & 4.5.1 of Generic Ltr 83-28

ML20236F588
Person / Time
Site:	Catawba
Issue date:	07/29/1987
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20236F560	List: ML20236F557 ML20236F588
References
GL-83-28, NUDOCS 8708030394
Download: ML20236F588 (4)

Text

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ENCLOSURE SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO GENERIC LETTER 83-28, ITEMS 3.1.1, 3.1.2,,e3. 2.1, 3.2.2, and 4.5.1 DUKE POWER COMPANY CATAWBA NUCLEAR STATION UNITS 1 AND 2 l l

DOCKET NOS. 50-413 AND 50-414 I

1. Introduction l

Generic Letter (GL) 83-28 was issued by the staff on July 8,1983. It I described intermediate-term actions to be taken by the licensees and i 7 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. Items 3.1.1, 3.1.E. 3.2.1, 3.2.2, and 4.5.1 of the generic letter requires licensees and applicants to submit results of their review of test and maintenance procedt.res for components in the reactor tric system and all other safety-rtlated components to assure that the equipment is capable of perforning its safety function; to ensure that ,

engineering and vendor recommendations were included in procedures or the j Technical Specifications, where required; and that on-line functional (

testing of the reactor trip system is required, including independent J testing of the diverse trip features, including the breaker undervoltage '

and shunt trip features in Westinghouse plants.

_ By letters dated November 4 '1983, November 2,1984, December 31, 1984, and December 3,1985, Duke Power Company (DPC), the licensee for Catawba Nuclear Station, provided information regarding their compliance to Items 3.1.1, 3.1.2, 3.2.1, 3.2.2, and 4.5.1 of Generic Letter 83-28. We -

evaluated the licensee's responses to the above items against the NRC positions described in the GL for completeness and adequacy. Our review finds the licensee's responses to be acceptable. This Safety Evaluation (SE) presents the evaluation of the licensee's responses and our conclusions.

2. Evaluation By letter dated November 4,1983, Duke Power Company responded to the requested information concerning the status, plans, and schedules for conformance with the NRC positions contained in GL 83-28. Subsequent letters dated November 2, 1984 December 31, 1984, and December 3,1985 provided sufficient additional information to allow an evaluation to be made against the NRC positions as stated in the GL.

8709030394 070729 PDR ADOCK 05000413 p PDR

1 Enclosure 2 i

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Delineated below are the results of NRC's evaluation of Items 3.1.1, 't 3.1.2, 3.2.1, 3.2.2, and 4.5.1 of GL 83-28. -

a. Item 3.1.1, Review of Test and Maintenance Procedures and Technical Specifications (Reactor Trip, System Components) l Item 3.1.1 requires licensees and applicants to submit the results of their review of test procedures, maintenance procedures, and Technical Specifications to ensure that post maintenance operability testing of safety-related components in the reactor trip system is required to be conducted ar,d that the testing demonstrates that the equipment is capable of performing its safety functions before being returned to service.

The licensee stated in their response dated November 4,1983, that existing procedures and programs require that all safety-related and

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Technical Specification-related components be tested after maintenance before being returned to service. The licensee stated that the testing demonstrates that the equipment is capable of performing its intended safety function. The licensee's response to this item is acceptable.

b. Item 3.1.2, Check of Vendor and Engineering Recommendations for Testing and Maintenance (Reactor Trip System Components)

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Item 3.1.2 requires licensees and applicants to submit the results l of their check of vendor and engineering recommendations to ensure that any appropriate test guidance is included in the test and i maintenance procedures or the Technical Specifications, where J required.  !

The licensee stated in their response dated November 4,1983, that -

they had reviewed the technical information for the Reactor Trip -

Breakers and verified that the information is appropriately incorporated into plant procedures and Technical specifications. The licensee stated that they had not reviewed all components in the Reactor Trip System, but would complete the review by December 31, 1984. The licensee's response of December 31, 1984, stated that the l t licensee had completed a review of all applicable Data Letters and  !

Bulletins, including Westinghouse Data Letters and Technical  !

Bulletins for all other safety-related components. The licensee's responses to this item is acceptable.

c. Item 3.2.1 Review of Test and Maintenance Procedures and Technical 1 Specifications (All Other Safety-Related Components)

• 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 post-maintenance

f Enclosure 3 operability testing of all safety-related equipment 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.

The licensee stated in thsTr' response dated November 4,1983, that j existing procedures require that all safety-related and Technical Specification-related components be tested after maintenance before j being returned to service. The licensee stated that this testing demonstrates that the components will perform their intended safety j function. The licensee's response is acceptable. l 1

d. Item 3.2.2 Check of Vendor and Engineering Recommendations for '

Testing and Maintenance (All Other Safety-Related Components) 1 Item 3.2.2 requires licensees and applicants to submit the results of  !

, their check of vendor and engineering recommendations to ensure that i any appropriate test guidance is included in the test and maintenance  !

procedures or the Technical Specifications, where required. l The licensee's response of November 4,1983, stated that they had established administrative procedures to control the distribution of vendor manuals and to ensure that vendor's guidance is appropriately incorporated into plant procedures. The licensee further stated i that these procedures were being reviewed and revised to resolve i weaknesses identified by internal audits. The licensee stated that all vendor manuals at Catawba Station will be given a substantial review to ensure that the manuals are complete and cor.sistent.

Subsequent responses dated December 31, 1984 and December 3,1985 stated that they had reviewed Westinghouse Technical Letters and Bulletins and Technical Specifications. A substantial review of l vendor manuals will be started at Catawba by January 1987, completion i is scheduled for December 1987. The licensee stated that procedures .,-

will be revised to incorporate appropriate changes resulting from the i manual review. The licensee also stated that they had developed a i data base, titled, " Procedure Reference Document Data Base", which contains all station procedures, titles, number, and general information. The licensee believes that this procedure will help assure that vendor documents referenced in procedures are properly reviewed and procedures revised, if appropriate. Although some deficiencies in the implementation of the licensee's procedures were identified in NRC Inspection Report Nos. 50-413/86-26 and 50-414/86-29, the licensee's response meets the intent of GL 83-28 and is acceptable.

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Enclosure 4 i

e. Item 4.5.1, Reactor Trip System Reliability (System Functional '

Testing) __

Item 4.5.1 requires that on-line functional testing of the reactor trip system, including i,nde. pendent testing of the diverse trip features, be performed. The. breaker undervoltage and shunt trip i features in Westinghouse plants should be included.

The licensee's response dated November 4,1983, stated that the capability to perform on-line testing of the reactor trip system would be provided. The test would also provide for independently testing of the undervoltage and shunt trip features. Testing will be performed in accordance with the Technical Specifications. Recent NRC site inspection revealed that the licensee had developed

' procedure IP/0/A/3200/10 A&B which specifies the fur.ctional testing of the independent trip capabilities by the undervoltage and shunt w trip devices. The licensee's response is acceptable.

3. Conclusions Based on the above statements, the staff finds the licensee's responses to be acceptable and meeting the intent of GL 83-28. The licensee indicated that procedures require post-maintenance testing of the reactor trip system components and all other safety-related components. The licensee

further indicated that they have a continuous program to ensure that vendor and engineering information and recommendations are reviewed and incorporated into test and maintenance procedures, as applicable. The

, staff considers the licensee's responses to Items 3.1.1, 3.1.2, 3.2.1,

[ 3.2.2, and 4.5.1 of Generic Letter 83-28 to be acceptable.

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4. References

a. NRC Letter, D. C. Eisenhut to all Licensees of Operating Reactors, Applicants for Operating License, and Holders of Construction Permits, "Re ATWS EventsGeneric (quiredLetter Actions Based 83-28), on8, July Generic 1983. Implications of Salem

b. Duke Power Company letter to D. G. Eisenhut dated November 4,1983, Catawba Nuclear Station,

c. Duke Power Company letter to H. R. Denton dated November 2,1984, Catawba Nuclear Station.

d. Duke Power Company letter to D. G. Eisenhut dated December 31, 1984, Catawba Nuclear Station.

e. Duke Power Conpany letter to H. R. Denton dated December 3,1985, Catawba Nuclear Station.

f. NRC Inspection Report Nos. 50-413/86-26 and 50-414/86-29 dated

! August 26, 1986.

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