ML20236F983
| ML20236F983 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 07/29/1987 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20236F972 | List: |
| References | |
| GL-83-28, NUDOCS 8708040082 | |
| Download: ML20236F983 (7) | |
Text
_..... - _....
SAFETY EVALUATION BY THE OFFICE OF NUCLEA9 REACTOR REGULATION RELATED TO GENERIC LETTER 33-28, ITEMS 3.1.1, 3.1.2, 3.2.1, AND 3.2.2 GEORGIA POWER COMPANY EDWIN I. HATCH NUCLEAR PLANT, UNITS 1 AND ?
DOCKET NOS. 50-321 AND 50-366 1.
Introduction Generic Letter (GL) 83-28 was issued by the staff on July 8, 1983.
It described intermediate-term actions to be taken by licensees and appli-cant's to address the generic issues raised by the two Anticipated Transients Without Scram (ATWS) events that occurred at ' Unit 1 of the 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." Actionr, to be perfonned included development of programs to provide for post-trip review, classification of equipment, vendor interface, post-maintenance testing, and Reactor Trip System (RTS) reliability improvements. The Generic Letter stated that for Action Items 3.1.1, 3.1.2, 3.2.1 and 3.2.2, NRC Regional Offices would perform a post-implementation review and issue Safety Evaluations. This report is the Regional Safety Evaluation of the Georgia Power Company response to the above items.
2.0 Evaluation By letters dated November 7,1983 and February 29, 1984, Georgia Power i
Company (GPC), the licensee for Edwin I. Hatch Nuclear Plant, Units 1 and 2, provided information regarding their compliance with Items 3.1.1, 3.1.2, 3.2.1, and 3.2.2 of GL 83-28.
We evaluated the licensee's re-sponses against the NRC positions described in the GL for completeness and adequacy. We found the responses to Items 3.1.1, 3.1.2, 3.2.1, and j
3.2.2 to be incomplete, thus requiring additional information to deter-j mine acceptability. A Request for Additional Information was transmitted to the licensee by NRC letter dated December 23, 1985.
By letter dated August 21, 1986, Georgia Power Company supplemented its earlier letters of November 7,1983 and February 29, 1984. The August 21, 1986 letter complied with comitments made in the February 29, 1984 sub-mittal, which stated that Georgia Power Company (GPC) would have reviews completed by June 1986, and issue a report to NRC by August 1986. However, the response revealed that the review and update of test and maintenance procedures for the Reactor Trip System (RTS) and other safety-related components had not been completed. This was due to GPC's identifying the need to incorporate vendor and engineering recommendations and post-maintenance testing into all plant procedures, not just safety-related procedures. The licensee stated that approximately 5,000 procedures were involved and estimated a completion date of late 1986 for the mechanical and electrical maintenance procedures and late 1987 for the remaining procedures.
j The statcs of GPC's program for procedure upgrade was discussed with p
representatives of the GPC Nuclear Engineering Department during several MS AB85!E83lip P
=
. telephone calls in June 1987, as a result of which GPC submitted additional i
infonnation by letter SL-2709 dated July 1,1987.
Review of the July 1,
]
1987 letter indicated that the responses to Items 3.1.1 and 3.12 only q
briefly discussed how the Maintenance Work Order program worked and did not present a status of the procedure review and update program. To obtain
{
more information, NRC called again on July 7, 1987. During the latter 4
telecon, GPC representatives stated that the current estimated completion date for surveillance procedures'was December 1987, and December 1988 for all other procedures.
The licensee had not completed the review and update of all procedures, j
due to extending the program to cover all plant proceduras, not just i
safety-related procedures. However, the status and progress of the licensee's procedure review and upgrade program were discussed with the licensee and appeared reasonable, based on approximately 5000 procedures l
being reviewed.
l Delineated below are the results of Region II's evaluations and a brief I
sumary of the licensee's supplemental responses:
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 j
Specifications to ensure that post maintenance operability testing of I
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 i
service.
l The licensee stated in their supplemental response dated August 21, 1536, that their original plan and comitment was to review and update the test and maintenance procedures and the Technical Speci fications associated with the Reactor Trip System (RTS) and other safety-related components. However, during their review, they iden-tified the need to incorporate vendor and engineering recommendations and post-maintenance testing into all plant procedures. As a result, the licensee indicated that a Procedure Upgrade Program (PUP) had been developed and is being implemented to provide assurance that post-maintenance operability testing is adequately presented in all maintenance procedures; that appropriate vendor and engineering infonnation is included or referenced in the procedures; and that applicable regulatory requirements and GPC comitments are accurately reflected in procedures.
The supplemental response dated July 1,1987, described how the licensee's Hatch Nuclear Plant Maintenance Program requires maintenance work orders to be reviewed by the Supervisor On-Shift and technical experts. These reviews ensure that post-maintenance testing is per-formed and that the equipment meets its intended safety functions.
The response further stated that "At no time is a system component
declared operable until satisfactory completion of post-maintenance operability." However, the response did not specify whether the above statement is a procedural requirement or just a general under-standing at Hatch plant. To be effective, the requirement must be in an approved procedure.
The licensee's representadve confirmed during a telephone con-versation on July 7, 1987, that Maintenance Procedure No.
50AC-MNP-001-0S and LCO Procedure No. 31GO-OPS-006-0S require testing of equipment prior to closing out a maintenance work request.
J Although the licensee did not meet the original commitment dates at the end of 1986 and 1987, their representative stated that approx-l imately 40% of the procedures have been reviewed, that all procedures associated with Technical Specifications have been identified, and I
the surveillance test procedures are being revised. The new expected completion dates are December 1987 for surveillance pro-cedures and end of 1988 for all other procedures.
Based on review of the licensee's responses, the continuing program to uodate procedures, and telecon discussions, the response meets the intent of GL 83-28 and is acceptable.
b.
Item 3.1.2, Check of Vendor and Engineering Recommendations for Testing and Maintenance (Reactor Trip System Components)
Item 3.1.2 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 procedure or the Technical Specifications, where required.
The licensee's response to Item 3.1.2 states that a Procedure Upgrade Program (PUP) has been developed and 1:; being implemented to complete.]y revise all Hatch Nuclear Plant procedures, including test and post-maintenance operability procedures. Procedures developed under the PUP include requirements to ensure that applicable vendor and engineering recommendations and vendor manuals are included in all procedures, not just test and maintenance operability procedures.
The response further indicated that controls have been established to ensure that General Electric Service Information Letters are l
acknowledged, reviewed, controlled, and incorporated into plant
]
procedures. Other procedures are being implemented to ensure that i
pertinent operating experience information, such as industry events, vendor reports, INP0 Operating Experience Reports, and NRC publi-cations are fed back to operators and other appropriate personnel.
Although the licensee has not completed the committed review of all i
vendor and engineering recommendations and related procedures, the responses and telephone discussions indicated that programs have i
been developed and are being implemented to ensure that vendor and I
engineering recommendations are controlled, evaluated, and utilized j
in plant procedures.
Based on the above programmatic descriptions and the licensee's statements, the licensee's response meets the intent of GL 83-28 and is acceptable.
c.
Item 3.2.1, Review of Test and Maintenance Procedures and Technical Specifications (All other. Safety-Related Components) l 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 operability testing demonstrates that the equipment is capable of performing its safety functions before being returned to service.
]
The licensee's responses to Item 3.1.2 stated that a Procedure Upgrade Program (PUP) has been developed and is being irr,lemented to completely revise all Hatch Nuclear Plant procedures, including maintenance and post-maintenance testing procedures. This program l
includes the review and revision, as applicable, of all procedures to ensure that vendor and engineering recommendations are included or referenced in maintenance and test procedures or the Technical Specifications.
The licensee indicated that their program for reviewing and updating procedures will ensure that post-maintenance operability testing is specified and that the testing demonstrates that the equipment is l
capable of performing its safety function.
The licensee further indicated that the procedure review and update program is being implemented for all safety-related equipment, including the Reactor Trip System; therefore, our previous evaluation for Item 3.1.1, Reactor Trip System is valid for Item 3.2.1, All I
Other Safety-Related Components.
Based on the above, the licensee's response meets the intent of GL 83-28 and is acceptable.
d.
Item 3.2.2, Check of Vendor and Engineering Recommendations for Testing and Maintenance (All other Safety-Related Components)
Item 3.2.2 requires licensees and applicants to submit the results of l
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 supplemental responses dated August 21, 1986, and July 1, 1987, to Item 3.2.2 stated that a procedure upgrade program has been developed and designed to provide assurance that appropriate vendor and engineering information is either included or referenced in the procedures. The licensee indicated that Hatch Procedure DI-ADM-05-1085, Revision 2, includes a requirement to ensure that applicable vendor manuals and vendor and engineering recommendations l
are reviewed and are included in all procedures, not just test and
4 maintenance procedures. The licensee further stated that the pro-cedure update program is being implemented to completely revise all Hatch procedures and that.approximately. 40% of Hatch procedures have been revised.
Estimated completion date for-all proceduris is near-the end of 1988.
The licensee's responses tithis item are almost identical to I
responses for Item 3.1.2, Reactor Trip System Components, as,the i
licensee's program is applicable to all components.
j i
Based on review of responses and the licensee's continuous. review l
and upgrade of procedures, this response meets the. intent'of GL 83-28 and is acceptable.
3.
Conclusion The licensee has a. procedure upgrade program in operation to ensure that procedures contain requirements for post-maintenance testing. -They also confirmed that they have procedures to ensure that' vendor and engineering l
recommendations are included in test and maintenance procedures. Their i
plant maintenance program also requires-review of maintenance work orders by the Supervisor On-Shift and other technical experts to detennine what l
post-maintenance testing is necessary to ensure that the equipment is j
capable of performing its intended safety function. The licensee con-
'l firmed that they are continuing to review and revise plant procedures for j
compliance with GL 83-28 Action Items. Based on the above, the staff j
finds the licensee's supplemental. responses and actions relating to f
Items 3.1.1, 3.1.2, 3.2.1, and 3.2.2 meet the intent of GL 83-28 and are acceptable.
4.
Reference Documents a.
NRC letter, D. G. Eisenhut to all Licensees of Operating Reactors, Generic Letter 83-28, Required Actions Based on Generic Implications ~
of Salem ATWS Events, dated July 8,1983.
b.
Georgia Power Company letter, NED-83-546, dated November 7, 1983, Status Report on GL 83-28 Requirements, c.
Georgia Power Company letter, NED-84-054, dated February 29, 1984, Response to GL 83-28.
d.
NRC letter, G. Rivenbark, Project Manager, to D. T. Beckham, Jr.,
Vice President, Georgia Power Company, dated December 23, 1985, Request for Additional Information for items 3.1.1, 3.1.2, 3.2.1, and 3.2.2.
e.
NRC Inspection Report Nos. 50-321/84-46 and 50-366/84-46.
i f.
Georgia Power Company letter, SL-1105, dated August 21, 1986, Response to NRC Request for Additional Information for Items 3.1.1, 3.1.2, 3.2.1, and 3.2.2.'of GL 83-28.
i.
g.
Georgia Power Company letter, SL-2709, date'd July 1, 1987, Response to NRC Generic Letter 83-28.
l h.
Telephone conversations on June 16 and June 24, 1987, between L. E. Foster, NRC contractor's consultant, and D. Crow.' Georgia Power Company.
i.
Telephone conversation on July 7,1987, between L.. E... Foster, NRC contractor's consultant, and J. C. Jones, Georgia Power Company i
I I
- i l.
i l
l I
l
. I i,
t L7-D i
t ab
}
1' u.
Mr. James P. O'Reilly Edwin I. Hatch Nuclear Plant, Georgia Power Company Units Nos. I and 2 cc:
G. F. Trowbridge, Esq.
Shaw, Pittman, Potts and Trowbridge 2300.N Street, N. W.
1 Washington, D.C.
20037 Mr. L. T. Gucwa Engineering Department Georgia Power Company P. O. Box 4545 Atlanta, Georgia 30302 Nuclear Safety and Compliance Manager Edwin I. Hatch Nuclear Plant Georgia Power Company P. O. Box 442 Baxley, Georgia 31513 Mr. Louis B. Long Southern Company Services, Inc.
P. O. Box 2625 Birmingham, Alabama 35202 l
Resident Inspector I
U.S. Nuclear Regulatory Commission l
i' Route 1, P. O. Box 725 i
Baxley, Georgia 31513 Regional Administrator, Region II l
7.
U.S. Nuclear Regulatory Commission I
E 101 Marietta Street, Suite 2900 l
k Atlanta, Georiga 30323 ii 7
Mr. Charles H. Badger Office of Planning and Budget l
Room 610 270 Washington Street, S.W.
Atlanta, Georgia 30334 Mr. J. Leonard Ledbetter, Commissioner Department of Natural Resources 270 Washington Street, N.W.
Atlanta, Georgia 30334 Chairman Appling County Commissioners County Courthouse j
Baxley, Georgia 31513 1?
P l5 L
- - - - - - - - - - - - _ - - - - - - - - = = ~
-