ML20236M384

Safety Evaluation on Generic Ltr 83-28,Items 3.1.1,3.1.2, 3.2.1 & 3.2.2 Re post-maint Testing.Licensee Programmatic Controls & Procedures for post-maint Testing of Components in Reactor Trip & safety-related Sys Acceptable

ML20236M384
Person / Time
Site:	Grand Gulf
Issue date:	07/31/1987
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20236M382	List: ML20236M379 ML20236M384
References
GL-83-28, NUDOCS 8708110040
Download: ML20236M384 (4)

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i. ENCLOSURE SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO GENERIC LETTER 83-28 ITEMS 3.1.1, 3.1.2, 3.2.1 AND 3.2.2 SYSTEM ENERGY RESOURCES, INC.

GRAND GULF NUCLEAR STATION, UNITS 1 AND 2 DOCKET NOS. 50-416 AND 50-417

1.0 INTRODUCTION

Generic Letter (GL) 83-28 " Required Actions Based on Generic Implications of Salem ATWS Events" was issued by the staff on July 8, 1983. It described intermediate-tenn actions to be taken by licensees and applicants to address the generic concerns 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." The generic concerns are categorized into four areas: post-trip review; equipment classification and vendor interface; post-maintenance testing; and reactor trip system reliability improvements. This safety evaluation addresses concerns in the third category, post-maintenance testing.

By letters dated November 4, 1983. December 14, 1984, and September 30, 1985, the licensee for Grand Gulf Nuclear Stction (GGNS)* provided information regarding their compliance to Items 3.1.1, 3.1.2, 3.2.1 and 3.2.2 of GL 83-28.

The staff evaluated the licensee's responses against the NRC positions described in GL 83-28 for completeness and adequacy. The licensee's responses to Items 3.1.1, 3.1.2, 3.2.1 and 3.2.2 were found to be incomplete, thus reauiring additional infomation to determine acceptability. These deficiencies were l described in the stat.'s request for additional information by letter dated l December 6, 1985. The licensee's supplemental responses to our request for additional infonnation for Items 3.1.1, 3.1.2, 3.2.1 and 3.2.2 were submitted by the licensee's letter dated March 7, 1986. This safety evaluation addresses the licensee's supplemental responses to Items 3.1.1, 3.1.2, 3.2.1 and 3.2.2 for GGNS Units 1 and 2. j 2.0 EVALUATION Item 3.1.1, Review of Test and Maintenance Procedures and Technical Specifications l (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 i in the reactor trip system is required to be conducted and that the testing l

! *0n December 20, 1986, the Commission authorized the transfer of control and  !

performance of licensed activities for Grand Gulf Nuclear Station from '

Mississippi Power & Light Company to System Energy Resources, Inc. (SERI).  !

"The licensee" refers to Mississippi Power & Light Company before December 20, )

1986 and to SERI on or after December 20, 1986. l i

l l 8708110040 870731 DR ADOCK0500g6 l l i

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L demonstrates that the equipment is capable of performing its safety functions j before being returned to service.

The licensee's supplemental response dated March 7, 1986, stated that the  !

work control program used at GGNS does not require advance preparation i of generic type retest procedures which are used over and over again. Instead, 1 their program allows the scope and type of work perfonned to dictate the  !

testing / retesting required. These test requirements are identified for each  !

specific work activity and are developed along with the work plan on a case- l l by-case-basis, thereby assuring that the test is correct, complete and germaae to the specific maintenance activities. The licensee did not perform a review 3~

of previously developed and completed work packages which include. the specific test / retest instructions, but instead they reviewed the programmatic controls  !

i and built-in checks and reviews to assure that post-maintenance testinc was adequately addressed. The work packages are processed through a t m iew/

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l approval cycle to further ensure that adequate test / retest have been specified. -

The licensee also indicated that they have specific requirements that appropriate surveillance tests be performed to determine operability and that the Shift Superintendent / Supervisor makes a final decision on the component operability as defined in the GGNS Technical Specifications. The licensee stated that the procedures and many other built-in checks, such as quality assurance, engineering '

and management reviews, assure that post-maintenance testing will be performed and will demonstrate that the equipment will perform its intended safety function prior to being returned to service.

Based on the licensee's descriptions of programmatic controls and statements e that post-maintenance operability testing is required and will verify that components are capable of performing their safety functions, the staff concludes l that the licensee's response to Item 3.1.1 meets the guidelines of GL 83-28 {

and is therefore acceptable. '

Item 3.1.2 ,

Maintenance, Check (Reactor ofSystem Trip Vendor and Engineering)

Components . Recommendations for Testing and l 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 procedures or the Technical Specifications, where required.

The licensee's supplemental response dated March 7,1986, stated that a review of each previously completed individual work instruction was not conducted, but the programmatic controls and built-in checks were reviewed to ensure that the vendor and engineering recommendations will be reviewed, evaluated, and included in test and maintenance procedures. The licensee's response included the following statements:

(1) Procedures detail how retest requirements will be determined after inaintenance activities.

(2) Work packages are reviewed to ensure that maintenance retest requirements can be satisfied by existing approved vendor documents or parts thereof.

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t l (3) Vendor representatives are used when additional expertise is required. l l

(4) General Electric Service Information Letters (SIls), Service Advisory l Letters (SALs), and special engineering notifications are utilized as 1 appropriate.

(5) INP0's Operating Experience Reports are reviewed end pertinent information ,

is used.  !

(6) Vender technical manuals and other vendor and industry information are i controlled, reviewed, and used to support plant activities.

1 (7) Plant procedures and vendor technica, manuals are cross-referenced by a 1 fonnal tracking method. l (8) Appropriate administrative and section level procedures have been reviewed to ensure that they require the use of vendor and engineering recommendations l when developing retest instructions for a given work document. l l

(9) Controls in place effectively ensure that GGNS test and maintenance l procedures include adequate guidance to ensure that appropriate vendor and I engineering recommendations are considered. l (10) Special instructions require a detailed review of vendor manuals, drawings, specifications, and handbooks to generate appropriate test requirements.

Based on the above statements, the staff concludes that the licensee's response i to Item 3.1.2 meets the guidelines of GL 83-28 and is therefore acceptable.

Item 3.2.1, Review of Test and Maintenance Procedures and Technical Specifications TAllOtherSafety-RelatedComponents).

Item 3.2.1 requires licensees and applicants to submit a report documenting the results of their review of test and maintenance procedures and Technical Specifications to ensure that post-maintenance operability testing of all other safety-related equipment (in addition to components of the reactor trip system) is required to be conducted and that the testing demonstrates that the equipnent is capable of performing its safety function before being returned to service.

The licensee's supplemental response dated March 7,1986, stated that they made no formal procedure distinction between the safety-related reactor

trip syste; aponents and other safety-related components; therefore, their response to item 3.1.1 for reactor trip system components is applicable to Item 3.2.1 for all other safety-related components. Accordingly the staff's evaluation for Item 3.1.1 is valid for Item 3.2.1.

! The staff concludes that the licensee's response to Item 3.2.1 meets the guidelines of GL 83-28 end is therefore acceptable.

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Item 3.2.2 Check of Vendor and Engineering Recommendations for Test and Maintenance Procedures (All Other Safety-Related Components). I 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 Technical Specifications for all other safety-related components, where required.

The licensee's supplemental response dated March 7,1986, stated that no l distinction was made between reactor trip system components and other I safety-related components; therefore, the responses for Item 3.1.2 and Item 3.2.2 are identical. Accordingly the staff's evaluations are the same for these two items. _

The staff concludes that the licensee's response to Item 3.2.2 meets the guidelines of GL 83-28 and is therefore acceptable.

3.0 CONCLUSION

Although the licensee did not review completed work packages to determine l if test or retest instructions were present, they reviewed their programmatic l controls, procedures, and reviews required by personnel in quality assurance, l engineering, and management, which if implemented, should ensure that equipment l 1s properly tested and will perform its safety function. l The licensee stated that vendor and engineering recommendations related to equipment maintenance and operability testing are included in procedures and '

that technical manuals are cross-referenced to applicable plant procedures.

1 Based en itt, review, the staff concludes that the licensee's responses tc Items 3.1.1, 3.1.2, 3.2.1 and 3.2.2 meet the guidelines of GL 83-28 and are therefore acceptable.

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