ML20238A314

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Safety Evaluation of Encl Technical Evaluation Repts EGG-NTA-7243,EGG-NTA-7720 & EGG-NTA-7463 & Licensee Submittals in Response to Generic Ltr 83-28,Items 2.1.1, 2.1.2 & 4.5.2.Responses Acceptable
ML20238A314
Person / Time
Site: Calvert Cliffs  Constellation icon.png
Issue date: 08/24/1987
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20238A285 List:
References
GL-83-28, NUDOCS 8709090242
Download: ML20238A314 (3)
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/,,prea . ,oy UNITED STATES n NUCLEAR REGULATORY COMMISSION I, ' 'f WASHINGTON D. C. 20555 k +'..../

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION BALTIMOPE GAS AND ELECTRIC COMPANY CALVERT CLIFFS NUCLEAR POWER PLANT, UNITS 1 AND 2 DOCKET NOS. 50-317 AND 50-318 REGARDING GENERIC LETTER 83-28, ITEMS 2.1.1, 2.1.2, AND 4.

5.2 INTRODUCTION

On February 25, 1983, both the scram circuit breakers at Unit 1 of the Salem Nuclear Power Plant failed to open upon an automatic reactor trip signal from the reactor. protection system. This incident was terminated manually by the operator about 30' seconds after the initiation of the automatic trip signal.

The failure of the circuit breakers was determined to be related to the sticking of the undervoltage trip attachment. Prior to this incident, on

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February 22, 1983, at Unit'l of the Salem Nuclear Power Plant, an automatic trip signal was generated based on steam generator low-low level during plant startup. =In this case, the reactor was tripped manually.by the operator  :

almost coincidentally with the automatic trip.

Following t'hese incidents, on February 28, 1983, the NRC Executive Director for Operations (ED0), directed the staff to investigate and report on the generic implications of these occurrences at Unit 1 of the Salem Nuclear Power Plant. The results of the staff's inquiry into the generic implications of q the Salem unit incidents are reported in NUREG-1000, " Generic Implications of the ATWS Events at the Salem Nuclear Power Plant." As a result of this investigation, the Corrrnission (NRC) requested (by Generic Letter 83-28,

" Required Actions Based on Generic Implications of Salem ATWS Events," dated July 8, 1983) all licensees of operating reactors, applicants for an i operating license, and holders of construction permits to respond to generic 1 issues raised by the analyses of these two ATWS events. .

This report is an evaluation of the responses submitted by the Baltimore Gas ,

and Electric Company, the licensee for the Calvert Cliffs Nuclear Power Plant, t Units 1. and 2, dated November 5,1983 and February 29, 1984, as supplemented on j April 6,1987, for Items 2.1.1, 2.1.2, and 4.5.2 of Generic Letter 83-28. I i

Item 2.1.1 requires the licensee to confinn that all Reactor Trip System (RTS) components are identified, i :sified and treated as safety-related. Licensees and applicants were required to confirm that all components whose functioning is required to trip the reactor are identified as safety-related on documents, procedures, and information handling systems used in the plant to control 9 fety-related activities, including maintenance, work orders, and parts replacement. q

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r f- d Item 2.1.2 requires the licensee to confirm that an interface has been established with the NSSS or with the vendors of each of the components of the RTS. This interface includes periodic communication between the licensee /

applicant and the NSSS of the vendors or each of the components of the RTS, and a sustem of positive feedback which confirms receipt by the licensee /

applicant of transmittals of vendor technical information.

Item 4.5.2 states a staff position which requires on-line functional testing of the RTS, including independent testing of the diverse -trip features of. the reactor trip breakers, for all plants. Item 4.5.2 requires applicants and licensees with plants not currently designed to permit this periodic on-line testing to justify not making modifications to permit such testing.

A detailed review and technical evaluation of the licensee's submittals were performed under contract by EG&G Idaho, Inc., with general supervision by the NRC staff. This work was report by EG&G in the attached Technical Evaluation Reports (TERs): "Conformance to Generic Letter 83-28 Item 2.1 (Part 1)

Equipment Classification (RTS Components)." dated July 1986; "Conformance to Item 2.1 (Part 2) of Generic Letter 83-28, Reactor Trip System Vendor Interface" dated June 1987; and " Reactor Trip System Reliabil'cy Conformance to Item 4.5.2

. of Generic Letter 83-28" dated February 9, lho EVALUATION In response to the requirements of Item 2.1.1 of Generic Letter 83-28, the licensee stated in the November 5, 1983 and February 29, 1984 submittals that the components whose functioning is required to trip the reactor are identified as safety-related on documents, procedures, and information handling systems used in the plants to control safety-related activities.

Based on our review of these responses, we find the licensee's statements confirm t Nt a program does exist for identifying, classifying and treating components that are required for performance of the reactor trip function as safety related. The staff has determined that this program meets the requirements of Item 2.1.1 of the Generic Letter 83-28.

The ;icensee, in response to the requirements of Item 2.1.2 of Generic Letter 83-20, submitted letters dated November 5, 1983 and February.29, 1984. This response was further supplemented by the submittal of April 6,1987. The licensee stated in these submittals that Combustion Engineering is the NSSS vendor for the Calvert Cliffs, Units 1 and 2 plants and that the RTS is included as part of the Combustion Engineering interface program established for these plants. The response also confirms that this interface program includes both periodic communication between Combustion Engineering and the licensee and oositive feedback from the licensee in the form of signed receipts for technical information transmitted by Combustion Engineering.

Based on our review of these responses, the staff finds 'the licensee's state-ments confirm that a vendor interface program exists with the NSSS vendor for components that are required for performance of the reactor trip function. This program meets the requirements of Item P.1.2 of the Generic Letter 83-28.

t 4 In response to Item 4.5.2 of Generic Letter 83-28, the licensee stated in the November 5,1983 and February 29, 1984 submittals that the Calvert Cliffs Nuclear Power Plant, Units 1 and 2, are designed to allow on-line testing of the RTS and that the undervoltage and shunt trip attachments are independently tested on-line.

The staff finds that the Calvert Cliffs Nuclear Power Plant, Units 1 and 2 is desianed to permit on-line functional testing of the RTS, including independent testing of the diverse trip features of the reactor trip breakers. Thus, the licensee meets the requirements of Item 4.5.2 of Generic letter 83-28.

CONCLUSION Ba' sed on the staff's review of the attached Technical Evaluation Reports (EGG-NTA-7243, EGG-NTA-7720 and EGG-NTA-7463) and on the licensee's submittals, it finds that the Calvert Cliffs Nuclear Power Plant, Units 1 and 2, responses for Generic Letter 83-28, Items 2.1.1, 2.1.2 and 4.5.2 are acceptable.

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PRINCIPAL CONTRIBUTORS:

D. Lasher A. Toa?ston Date:

Attachments: EGG-NTA-7243 EGG-NTA-7720 EGG-NTA-7463

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CONFORMANCE-TO GENERIC LETTER 83-28 ITEM 2.1 (PART 1) EQUIPMENT CLASSIFICATION (RTS COMPONENTS)

ARKANSAS 1 AND 2 CALVERT CLIFFS 1 AND 2 CRYSTAL RIVER 3 DAVIS-BESSE 1 1

R. Haroldsen .q y

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i Published July 1986 j i

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, a EG&G Idaho, Inc. l Idaho Falls, Idaho 83415

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Prepared for the i U.S. Nuclear Regulatory Connission {

Washi.zton, D.C. 20555 l Under DOE Contract No. DE-AC07-76ID01570 .

FIN No. 06001 )j f

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i ABSTRACT This EG&G Idaho, Inc. report provides a review of the submittals from selected operating and applicant Pressurized WaterThe Reactor (PWR) plants for following conformance to Ger.eric Letter 83-28. Item 2.1 (Part 1).

plants are included in this review; TAC Number Docket Nurr.ber

_ plant Name 50-313 52816 Arkansas 1 50-368 52817 Arkansas 2 50-317 52825 Calvert Cliffs 1 50-217 52826 {

Calvert Cliffs 2 l 50-302 52830 Crystal River 3 50-346 52831 Davis-Besse 1 4

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.c s, CONTENTS ABSTRACT .............................................................. 11

. 'FOREWOR0'.............................................................. tii

1. . INTRODUCTION AND

SUMMARY

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2.' PLANT RESPONSE EVALUATIONS ........................................ 3 x 2.1 Arkansas One 1 and 2 ....................................... 3 2.2 Conclusion ................................................. 3 2.3 Calvert Cliffs-1 and 2 ..................................... 4 2.4 Conclusion .................................................. 4 2.5 Crystal River 3 ............................................ 5 2.6 Conclusion.................................................. 5 2.7 Davis-Besse 1 .............................................. 5 2.8. Conclusions ................................................ 6
3. GENERIC REFERENCES ............................................... 6 l

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1. INTRODUCTION AND

SUMMARY

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On February 25, 1983, both of the scram circuit breakers at Unit 1 of J 1

the Salem Nuclear Power Plant failed to open upon an automatic reactor trip l signal from the reactor protection system. This incident.was terminated manually by the operator about 30 seconds after the initiation of the automatic trip signal. The failure of the circuit breakers was determined to be related to the sticking of the undervoltage trip attachment. Prior )

to the incident, on February 22, 1983, an automatic trip signal was

. generated at Unit 1 of the' Salem Nuclear Power Plant based on steam I generator low-low-level during. plant startup. In this case, the reactor  !

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was tripped manually by the operator almost coincidentally with the automatic trip.

Following these inci. dents, on February 28, 1983, the NRC Executive

' Director of Operations (EDO), directed the staff to investigate the report

. on the generic implications of these occurrences at Unit 1 of the. Salem Nuclear Power Plant. The results of the staff's inquiry into the generic .

implications of the Salem Unit 1 incidents are reported in NUREG-1000,

" Generic Implications of the ATWS Events at the Salem Nuclear Power Plant." As a result of this investigation, the Comission (NRC) requested (by Generic Letter 83-28, dated July 8, 1983) all licensees of operating reactors, applicants for an operating license, and holders of construction permits to respond to generic issues raised by the analyses of these two ATWS events.

This report is an evaluation of the responses submitted from a group I

, of similar pressurized water reactors for Item 2.1 (Part 1) of Generic Letter 83-28. -

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'The results of the reviews of several plant responses are reported on in this document to elhance review efficiency. The specific plants reviewed in this report were selected based on the similarity of plant  !

design and convenience of review. The actual documents which were reviewed i

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for each evaluation are- isted at the end of each plant evaluation. The generic document.referen ed:in this report are listed at the end of the report.

Part 1 of Item 2.1 of Gene ic Letter 83-28 requires the licensee or.  !

applicant to confirm that all reactor trip system components are

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Licensees and applicants shall confirm that all components whose

. functioning is required to trip the reactor are identified as

i. safety-related on documents, procedures,'and information handling I' systems'used in the plant to control safety-related activities, including maintenance, work orders, and parts replacement.

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2..'FLANT RESPONSE EVALUATIONS o

R 72.1 Arkansas Nuclear One. Units 1 and 2. 50-318/368. TAC Nos. 52816/52817 s

The. licensee for Arkansas Nuclear One, Units 1 and 2 (Arkansas Power

'and. Light Co.) provided response to Item 2.1 (Part 1) of Generic 1 Letter 83-28 in submittals dated November 5, 1983, May 27, 1985 and July 26,' 1985. - The first submittal describes the plant equipment

. classification system as.it existed at that time. It:also describes the

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program used-to control the safety-related activities at t'he plant. The Q-list is the basic document used to determine the classification of components but had been developed only to the systems level. A plan was described lfar. upgrading the Q-list to the component level. The subsequent suomittals_(the May 27, 1985 submittal for Unit 1 and July. 26, 1985 submittal for Unit 2) confirmed.that the development of the component listing had been completed for reactor trip system components. The I procedures utilized for the identified components were also reviewed and

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l found to require the appropriate measures required for' safety-related components.

2.2 Conclusion Based on the review of the licensee's submittals, we find that the L components necessary to perform reactor trip are classified as safety-related and that activities relating to safety-related components are controlled by procedures which reflect the necessary requirements for handling safety-related components. We, therefore, find that the licensee's responses meet the requirements of Item 2.1 (Part 1) of Generic

' Letter 83-28 and are acceptable.

N 3eferences p 1. Letter, J. R. Marshall. & kansas Power and Light Co., to D. G. Eisenhut, NRC, November 5, 1983.

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i 2.. Letter, J. T. Enos Arkansas Power and Light Co., to J. F. Stolz, NRC, May 27, 1985.

l 3. Letter, J. T. Enos, Arkansas Power and Light Co., to E. J. Butcher,

'NRC, July 26, 1985.

2.3 Calvert Cliffs 1 and 2. 50-317/318, TAC Nos. 52825/52826 The licensee for Calvert Cliffs 1 and 2 (Baltimore Gas and Electric Co.) provided a response to Item 2.1 (Part 1) of Generic Letter 83-28 in a submittal dated November 5, 1983. The submittal states that the components whose functioning is required to trip the reactor are identified as safety-related on documents, procedures, and information handling systems used in the plants to control safety-related activities. This statement j was said to be based on a review of the plant Q-list, Maintenance Requests, Facility Change Requests, Preventative Maintenance Cards and Stock Spa.e Parts Index.

2.4 Conclusion Based on the review of the licensee's submittal, we find that the ,

licensee's response confirms that the components required to trip the f reactor are identified as safety-related, and that documents used to initiate design, maintenance, or procurement require identification of safety-related components. The licensee's response, therefore, meet the i requirements of Item 2.1 (Part 1) of Generic Letter 83-28, and is acceptable.

Reference ,.

1. Letter, A. E. Lundvall, Jr., Baltimore Gas and Electric Co., to D. G. Eisenhut, NRC, November 5, 1983.  ;

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2.5 Crystal River Unit 3. 50-302j TAC No. 52830 -

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l The licensee for the Cry:tal River Unit 3 Nuclear Plant (' Florida Power L 'Crerp.) provided response to Item 2.1 (Part 1) of Generic Letter 83-28 in I

submittals dateil November 4, 1983 and July 31, 1984. The submittals state

[' that the licensee has verified that all components whose funct[on is

, required to trip the reactor are classified as safety-related. The plant

" Safety Listing". identifies the safety-related coraponents'and,)s used to determine if an activity is safety-related during the activity, planning stage.

2.6 Concluskn l

5 Based on the review of the licensee's,submittals, we find that the i licensee's responses confirart thatJsecomnonentsrequiredtotripthe i reactor are identifiedtas saf' sty-r' elated. Ard'that documents used to

. initiate design, maintenance, or procurement require identification of safety-related components. The licensee's responses, therefore, meet the requirements of Item 2.1 (Part 1) of Generic Letter 83-28, and are acc epta b'.e.

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, References

1. Letter, G. R. Westafer, Florida Power Corp., to D. G. Eisenhut NRL, November 4, 1983.
2. Letter, G. R. Westafer, Florida Power Corp., to D. G. Eisenhut, NRC, July 31, 1984.

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, 2.7 Davis-Besse 1. 50-346 TAC No. 52831 The licensee for the Davis Besse Nuclear Plant (Toledo Edison Co.)

provided a response to Itera 2.1 (Part 1) of Generic Letter 83-28 in a submittal dated December 9, 1983. The submittal describes the equipment classification system used at the plant. The system is based on a Q-list 5

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l which is system oriented but which has been developed to the component level for. the reactor trip system.

Quality Assurance requirements Jre defined for the safety-related structures, systems and components identified in the Q-list in plant documents such as engineering drawings, bills of.nwterial. design specification, contracts, purchase orders, procedures and instruction.

2.8 Conclusion i

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Based on'the review of the licensee's submittal, we find that the 4 j

licensee's response confirms'that the compcnents required to trip the reactor are identified as safety-related, and that documents used to initiate design, maintenance, or procurement require identification of safety-related components. The licensee's response, therefore, meets the requirements of Item 2.1 (Part 1) of Generic Letter 83-28, and is 1 acceptable.

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i References

1. Letter, R. P. Crouse, Toledo Edison Co., to J. F. Stolz, NRC, December 9, 1983.

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3. GENERIC REFroENCES
1. Generic Implications of ATWS Events at the Salem Nuclear Power Plant, j NUREG-1000, Volume 1 April 1983; Volume 2, July 1983. )

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2. NRC Letter D. G. EisenhLt-to all Licensees of Operating Reactors, j 3

Applicants for Operating License, and Holders of Construction Permits,

" Required Actions 3ased on Generic Implications of Salem ATWS Events (Generic Letter 83-28)," July 8, 1983.

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EGG-NTA-7720 June 1987 1

INFORMAL REPORT Idaho l National CONFORMANCE TO ITEM 2.1 (PART 2) 0F GENERIC LETTER 63-28, REACTOR TRIP SYSTEM VENDOR j

i Eng/neer/ng INTERFACE. CALVERT CLIFFS-1 AND -2, MILLSTONE-2, i Laboratory AND PALISADES I

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Managed by the U.S. F. G. Farmer Department ]

ofEnergy .

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a DlSCLAIMER This book was prepared as an account of work sponsored by an agency of the United States Govemment. Nether the United States Government nor any agency thereof, nce any of their empiovees, makes any warranty, express or imoised, or assumes any

, legal liability or respor!sibility for the accuracy, Completeness, or usefulness of any infu,Ntion, apparatus, product or process dtSClosed, or represents that its use would not intnn9: onvatesy owned rightc. References here.n to any specife commercial product, process, or service by trace name, tracemark, manufacturer, or otherwise, does not necessanly constitute or imply its endorsement, recommendation, or favonng by tne United States Government or any agency thereof. The views and opineens of authors exproued herein do not necessanty state or reflect those of the United States Government or any agency thereof.

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R, EGG-NTA-7720

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CONFORMANCE TO ITEM 2.1-(PART 2).0F GENERIC LETTER 83-28 REACTOR TRIP SYSTEM VEN00R INTERFACE CALVERT CLIFFS-1 AND -2 MILLSTONE-2 PALISADES y

F . G. Farmer l

Publishad June 1987 Idaho National Engineering Laboratory EG&G Idaho, Int.

IGaho Falls, Idaho 83415-l Prepared for the i U.S. Nuclear Regulatory.Comuission Washington, D.C. 20555 Under DOE Contract No. DE-AC07-76ID01570 FIN Nos. 06001 and 06002

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r ABS, TRACT This EG&G Idaho, Inc, report provides a review of the submittals.for sone of the CombustionLEngineering (C-E) nuclear plants for conformance to Generic Letter 83-28, Item-2.1 (Part 2).

The report includes the following

~ Combustion Engineering plants, and is in partial' fulfillment of the following. TAC'Nos.:

plant' Docket Number _ TAC Number Calvert C11ffs 50-317 52825 Calvert Cliffs 50-318 52826-M111 stone-2 50-336 52855 Palisades

,, 50-255 52864 e

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, M FOREWORD This_ report is provided as part of the program for evaluating licensee / applicant'conformance to Generic Letter 83-28, " Required Actions Based on Generic' Implications of Salem ATWS Events." This work is-

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. . conducted for the U. S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, Division of Engineering and System Technology by EG&G

t. Idaho, Inc.

The U.TS. Nuclear Regulatory Commission funded the work under the authorization, L&R 20-19-19-11-3, FIN Nos. 06001 and 06002. >

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.c e CONTENTS

a85 TRACT'................................................. ........... it FOREWORC ................................... ..........................

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INTRODUCTION .................................... ................ 1

.GROUP REVIEW REQUIREMENTS .................................

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3. REVIEW 2 A.

RESULTS'............................... ............. 3 -

REVIEW RESULTS FOR'CALVERT CLIFFS-1 ................ AND.-2 4 4.1 4.2 Evaluation ............................ ............. ...... 4 S.

Conclusion ...................................... .......... 4

- RE VIE W RE SUL TS F OR MIL L S TONE-? . . . . .

. 5 .1 .. 5 Evaluation ...........................................

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Conclusion ....................................... ......... 5 REVIEW RESULTS F OR PALISADES . . . . . . . . . . . . 6. . . . . . .

6.1' 6.2 Evaluation ............................................ .... 6

7. Conclusicn .......................................... ...... 6 8.

GROUP CONCLUSION .................................... ............ 7 REFERENCES ..................................... ................. 8 i

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CONFORMANCE TO-

~ ITEM'2.1 (PART 2) 0F GENERIC LETTER 83-28 REACTOR TRIP SYSTEM VENDOR INTERFACE CALVERT CLIFFS-1 AND -2 MILLSTONE-2 PALISADES

1. INTRODUCTION On July 8, 1983, Generic Letter 83-28 was issued b'y D. G. Eisenhut,

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Director of the Division of Licensing, Office of Nuclear Reactor Regulation, to all licensees of operating reactors, applicants for operating licenses, and holders of construction permits. This letter included required actions based on generic implications of the Salem ATWS events. These requirements have been published in Volume 2 of NUREG-1000,

" Generic Implications of ATWS Events at the Salem Nuclear Power Plant."

This report documents the EG&G Idaho, Inc. review of the submittals of four of the Combustion Engineering plants, Calvert Cliffs-1 and -2, M111 stone-2 and Palisades, for conformance to Item 2.1 (Part 2) of Generic  !

Letter 83-28. The submittals from the licensees and applicants utilized in these evaluations are referenced in Section 8 of this report.

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2. REVIEW REQUIREMENTS Item 2,1 (Part 2) (Reactor Trip System - Vendor Interface) requires licensees and applicants to establish, implement and' maintain a continuing program to ensure that vendor information on Reactor Trip System (RTS) components is complete, current and controlled throughout the life of the plant, and appropriately referenced or incorpor ated in plant instructions and procedures.

The vendor interface program is to include periodic communications with vendors to assure that all applicable information has been received, as well as a system of positive feedback with vendors for mailings containing technical information, e. g., licensee / applicant t

acknowledgement for receipt of technical information. -

i That part of the vendor interface program which ensures that vendor information on RTS components, once acquired, is appropriately controlled,

" referenced and incorporated in plant instructions and procedures, will be evaluat'ed as part of the review of Item 2.2 of the Generic Letter.

Because the Nuclear Steam System Supplier (NSSS) is ordinarily also the supplier of the entire RTS, the NSSS is also the principal source of i information on the components of the RTS.

This review of the licensee and applicant submittals will:

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1. l Confirm that the licensee / applicant has identified an interface with eithertheNSSSorwiththevendorsof'e5thofthecomponentsofthe Reactor Trip System.

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Confirm that the interface identified by licensees / applicants includes f

periodic communication with th6 NSSS or with the vendors of each of 1' the components of the Reactor Trip System.

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Confirm that the interface identified by licensees / applicants includes a system of positive feedback to confirm receipt of transmittals of technical inf ormation.

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3. GROUP REVIEW RESULTS I

,The relevant submittals from each of the included reactor plants were reviewed to determine compliance with Item 2.1 (Part 2)-. First, the submittals from each. plant were reviewed to establish that. Item 2.1 (Part

2) was.specifically addressed. Second,.the submittals:were evaluated to b s determine the extent to which.each of the plants complies with'the staff guide ~ lines for. Item 2.1 (Part 2).

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4 REVIEW RESULTS FOR. CALVERT CLIFFS-1 AND -2 5.1 Evaluation..

l' Baltimore Gas and Electric Company, the licensee for Calvert Clif fs, provided 6, 1987. their response to Item 2.1 (Part 2) of the Generic Letter on April In that response, the licensee confirms that the NSSS for Calvert Cliffs is Combustion Engineering and that the RTS for Calvert Cliffs is included as a part of the C-E interface program established for the Calvert Cliffs NSSS.

The C-E interface program for the NSSS includes periodic communication between C-E and licensees / applicants such as "INF080LLETINS" containing information and recommendations concerning C-E systems, a system of positive feedback from licensees / applicants in the form of signed receipts for technical information transmitted by-C.E, and periodic issuance by C-E of indices of JNF0 BULLETINS.

5.2 Conclusion We find the licensee's statement confirming that Calvert Cliffs is a participant in the Combustion Engineering interface program for the RTS, which meets the staff position on Item 2.1 (Part 2) of the Generic Letter, is acceptable.

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5. REVIEW RESULTS FOR MILLSTONE-2 5.1 Evaluation

. Northeast ~ Utilities, the licensee for Mtlistone-2', provided their response to Item 2.1 (Part- 2) of the Generic Letter on April'2,1987. In

.that response, the licensee confirms that the NSSS.for M111 stone-2 is' Combustion Engineering and that the RTS for Millstone-2~is' included as a part of the C-E interface program established for the Millstone-2 NSSS.

The C-E interface program for the NSSS includes periodic consnunication between C-E and licensees / applicants such as "INF0 BULLETINS" containing information and recommendations concerning C-E systems, a system of positive feedback from licensees / applicants in the form of. signed receipts for technical information transmitted by C-E, and periodic issuance by C-E of indices.of INF0 BULLETINS.

5.2 conclusion We find the licensee's statement confirming that Millstone-2 is a participant in the Combustion Engineering interface program for the RTS, which meets the staff position on Item 2.1 (Part 2) of the Generic Letter, is acceptable.

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6. REVIEW RESULTS FOR PALISADES 6.1 Evaluation Consumers Power, the licensee for Palisades, provided their response to Item 2.1 (Paft 2) of the Generic Letter on May 8, 1987. In that response, the licensee confirms that the NSSS for Palis'ades'is Combustion Engineering and that the RTS.for Palisades is included as a part of the C-E it.terface program established for the Palisades NSSS.

The C-E interface program for the NSSS includes periodic communication between C-E and. licensees / applicants such as "INF0 BULLETINS" containing information and recommendations concerning C-E systems, a system of positive feedback from licensees / applicants in the form of' signed receipts for technical information transmitted by C-E, and periodic issuance by C-E of indices of INF0 BULLETINS.

6.2 Conclusion We' find the licensee's statement confirming that Palisades is a participant in the Combustion Engineering interface program for the RTS, which meets the staff position on Item 2.1 (Part 2) of the Generic Letter,  !

is acceptable.

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l We conclude that the licensee / applicant responses for the listed Combustion Engineering plants meet the staf f position for Item 2.1 (Part 2) of Generic Letter 83-28 and are acceptable, d

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8. REFERENCES 1.

NR; Letter, 0. G. Eisenhut to'all licensees of Operating Reactors, Applicants for Operating License, and Holders of Construction Permits,

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"RequiredLActions Based on Generic Implications of Salem ATWS Events

'(Generic Letter 83-28)," July 8, 1983.

2.

Generic Implications'of NUREG-1000,. Volume 1,- ATWS Events'at the Salem Nuclear Dower plant j

April 1983; Volume 2, July 1983. 1 3.

Baltimore Gas'and Electric Company-letter to NRC, J. A. Tiernan to 4 Office of Nuclear Reactor Regulation, " Additional Information Concerning BG&E Responses to Generic Letter 83-28," April 6, 1987. .

4.

Northeast Utilities letter to NRC, E. J. Mroczka to Document Control-Desk, " Generic Letter 83-28,. Salem ATWS,"-April 2, 1987.

5.  !

Consumers Power letter to NRC,'J. L.,Kuemin to Document Control Desk,

" Additional .Inf ormation - Vendor Interface and Equipment Classification - Generic Letter.83-28," May 8, 1987.

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CONFORMANCE'TO. ITEM 2.1 (PART 2) 0F. GENERIC LETTER 83-28, REACTOR TRIP SYSTEM VENDOR INTERFACE, CALVERT CLIFFS-1 AND -2, MILLSTONE-2, AND PALISADES a o." a"ca' co au no uo ,- ....

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June. l 1987

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EG&G Idaho, Inc.

p. O. Box 1625. ' a oa oa'a ' aw'*"

Idaho Falls, Idaho 06001/06002

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Division of Engineering and System Technology Office of Nuclear Reactor Regulation ~

U.S.. Nuclear Regulatory Commission * ""'oo c ov "' o "~~~ ~ ~

Washington, DC 20555

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This EG&G Idaho, Inc. report presents the results of our evaluation of the submittalg of some of the. Combustion. Engineering nuclear plants for conformance to Generic Letter 83-28, Item 2.1 (Part 2).

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r EGG-NTA-7463 1 TECHNICAL EVALUATION REPORT

, ' REACTOR TRIP SYSTEM RELIABILITY CONFORMANCE TO ITEM 4.5.2 OF GENERIC LETTER'83-28 ARKANSAS NUCLEAR ONE, UNIT 2 CALVERT CLIFFS UNITS 1 AND 2 FT..CALHOUN-MAINE YANKEE MILLSTONE UNIT 2 PALISADES PALO VERDE' UNITS 1, 2 AND 3 SAN ONOFRE UNITS 2 AND 3 ST. LUCIE UNITS.1 AND 2 WATERFORD SES UNIT 3 WNP 3 ~

F. G. Farmer f

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Published January 9, 1987 ]

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Idaho National Engineering Laboratory EG&G Idaho, Inc. jl Idaho Falls, Idaho 83415 '

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l Prepared for the i U.S. Nuclear Regulatory Commission Washington, D.C. 20555  !

Under DOE Contract No. DE-AC07-76ID01570 FIN Nos. D6001 and D6002 l

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ABSTNACT

. Th'is EG&G Idaho, Inc. report provides a review of the submittals'for.

Comb'usti on. Engi neeri ng - (CE) nuclear plants f or. conf ormance to Generic LGtter 83-28, Item'4.5.2s .

The report includes the following plants, all CE, and is'.in partial fulfillment of the f ollowing _ TAC Nos. :

' Pl ant Docket Number TAC Number

- Arkcnsas. Nuclear'One,. Unit 2 50-368 53961  ;

4 Calvert. Cliffs Unit 1 50-317 53969'

. Colvert Cliffs Unit 2 50-318 53970 Ft. Calhoun 50-285 53983 -

LMaine Yankee. . 50-309 53996

< . Millstone Unit 2 50-336 54000  ;

'Polisades 50-255 54009  !

Polo Verde Unit 1. 50-528 59173 -

Polo Verde Unit 2 (OL)' 50-529 N/A .

Polo Verde Unit 3 (OL) 50-530 N/A

'Scn Onofre Unit 2 50-361 5402*

1 Ern Onofre Unit 3 50-362 54025 i St. Lucie Unit 1 50-335 54028

'it . Lucie Unit 2 50-389 54029 Waterford'SES Unit 3 (OL) 50-382 -

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WNP"3 (OL) 50-508 N/A -

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FOREWORD This' report is provided as part of the program f or evaluating ilicensee/ applicant conformance'to Generic Letter 83-28, " Required Actions '

Beced:on Generic Implications of Salem ATWS Events." This work is conducted for the U.'S. Nuclear Regulatory Commission, Office of Nuclear Reactor

.Ragulation, Division of-PWR, Licensing-A by EG&G Idaho,.Inc.

The'U. S. Nuclear. Regulatory Commission funded the. work under the authorization, B&R.20-19-19-11-3, FIN Nos. D6001 and D6002.

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p 9" L# CONTENTS' L  !

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JABSTRACTD.............................................................. ii l-1 iFOREWORD ............................................................. iii g .1.

1 INTRODUCTION .................................................... 1

2. - REVIEW REQUIREMENTS

............................................. 2

3. GROUP REVIEW RESULTS............................................. 5 4.

REVIEW RESULTS FOR ARKANSAS NUCLEAR ONE, UNIT 2 .................

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6-4.1 Evaluatica

................................................. 6 4.2 Conclusion i

................................................. 6 5.

~ REVIEW RESULTS FOR CALVERT CLIFFS UNITS 1 AND 2 ................. 7 5.1 Evaluation ................................................ 7 5.2 Conclusior

................................................ 7 6.-

REVIEW RESULTS FOR FT. CALHOUN ..................................

. 8

'6.1 Eval u'ati on

................................................ 8 6.2 Conclusion ................................................ S

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REVIEW RESULTS FOR MAINE YANKEE ................................. 9 7.1 E v al u a t i o n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 7.2 Conclusion ................................................ 9 8.-

REVIEW RESULTS FOR MILLSTONE UNIT'2..............................

10 B.1 Evaluation ................................................ 10 8.2 Conclusion ................................................ 10 9.- REVIEW RESULTS FOR PALISADES ..................................., . 11 9.1 Evaluation ................................................ 11 9.2-Conclusion ................................................ 11

10. REVIEW RESULTS FOR PALO VERDE UNITS 1, 2 AND 3 .................. 12 10.1 Evaluation

................................................ 12 10.2 Conclusion

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11. REVIEW RESULTS FOR SAN ONOFRE UNITS 2 AND 3 .................'....

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1 11.1 Evaluation ................................................ 13 11.2 Conclusion ................................................ 13

12. REVIEW RESULTS FOR ST. LUCIE UNITS 1 AND 2 ...................... 14 l

12.1 Evaluation .............,.................................. 14 12.2 Conclusion ................................................ 14

- 13. REVIEW RESULTS FOR WATERFORD SES UNIT 3 ......................... 15 j 13.1 Evaluation ................................................ 15 l

  • 15 13.2 Conclusion ................................................. I
14. REVIEW RESULTS FOR WNP 3 ........................................ 16 14.1 Evtiuation ................................................ 16 14.2 Co:.1clusion ................................................ 16

' 15. GROUP CONCLUSION ................................................. 17

16. REFERENCES ...................................................... 18 6

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TECHN!g,AL EVALUATION REPORT REACTOR TRIP SYSTEM RELIABILITY ,

i CONFORMANCE TO (2 , ITEM 4.5.2-OF'GENERI'C LETTER 83-18

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ARKANSAS NUCLEAR ONE. UNIT 2.

CALVERT CLIFFS UNITS 1-AND 2

  • FT. CALHOUN I

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' MAINE' YANKEE '

MILLSTONE UNIT 2

' PALISADES

-PALO VERDE UNITS 1. 2-AND 3

SAN 2ONOFRE UNITS 2 AND'3

.ST. LUCIE UNITS 1 AND 2:

WATERFORD SES UNIT 3 WNP 3 E

1. INTRODUCTION l;. On" July-G, 1983, Generic. Letter 83-285 was issued by'D. G. Eisenhut, Director of the Division of Licensing, Office of Nuclear Reactor Regulation, to a11[ licensees of operating ' reactor s, applicants for operating licenses,

.cnd' holders of construction permits. This. letter included. required actions

~beced on-generic' implications of the Salem ATWS events. These requirements have been published in Volume ~2 of NUREG-1000, " Generic Implications of ATWS:

Events'at the Salem Nuclear Power Plant."*

This report documents the EG&G Idaho, Inc. review of' the submittals of all the CE plants including Arkansas Nuclear One, Unit 2, Calvert Cliffs Units 1-and 2, Ft. Calhoun, Maine Yankee, Millstone Unit.2, Palisades, Palo LVsrde Units 1, 2 and 3, San Onofre. Units 2 and 3, S t". Lucie Units 1 and 2, Waterford SES Unit 3 and WNP 3 for conformance to Item 4.5.2 of Generic Lotter 83-28. The submittals from the licensees utilized in these

" evaluations are re-f erenced in Section 16 of this report.

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2. REVIEW REQUIREMENTS Item 4.5.2 (Reactor Trip System Reliability - System Functional Tcsting - On-Line Testing) requires licensees and applicants with plants not currently designed to permit on-line testing to justify not making mo'ifications d to permit such testing. Alternatives to on-line testing will be considered where special circu;nstances exist and where the objective of high reliability can be met in another way. Item 4.5.2 may be j interdependent with Item 4.5.3 when there is a need to justify not performing on-line testing because of the peculiarities of a particular I daaign.

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All portions of the Reactor Trip System that do not have on-line '

tasting capability will be reviewed under the guidelines for this item.

However, the existence of on-line testability for the Reactor Trip Breaker undervoltage and shunt trip attachments on Westinghouse, B&W and CE plants; tho silicon controlled rectifiers in the CRDCS on B&W plants; and the scram

  • pilot and backup scram valves on GE plants will only be confirmed here since they are specifically addressed in Items 4.4 and 4.5.1. Maintenance and tacting of the Reactor. Trip Breakers are also excluded from this review, as thay are evaluated under Item 4.2. This review of the licensee / applicant submittals will:
1. Confirm that the licensee / applicant has identified those portions of the Reactor Trip System that are not on-line testable. If the entire Reactor Trip System is verified to be on-line testable, with those exceptions addressed above, no further review is required.
2. Evaluate modifications proposed by licensees / applicants to permit on-line testing against the existing criteria f'or the design of the protection systems for the plant being modified.
3. Evaluate proposed alternatives to on-line testing of the Reactor Trip System for acceptability based on the following:

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o.LTha liccncua/applicent cubmittel substantiates the impracticality of-

-the modifications necessary to permit on-line testing, and l

b. High Reactor Trip System availability (comparable to that which  !

would be possible with on-line testing) is achieved in another way. Any such proposed alternative must be described in detail suf ficient- to permit an independent ' evaluation of the basis and analysis provided in lieu of perf orming on-line testing. Methods I that may be used to demonstrate that the objective of high j reliability has been met may incit.de the f ollowing:

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1. . Demonstration by systematic analysis that testing at )

shutdown intervals provides essentially equivalent reliability to that obtained by on-line-testing at shorter j intervals.

11. e Demonstration that reliability 'quivalent to that obtained by on-line testing is accomplished by additional redundant and diverse components or by other features.

iii. Development of a maintenance program based on early j replacement of critical components that compensates for the lack of on-line testing. Such a program would require analytical justification supported by test data.

iv. Development of a test program that compensates for the lack ,

of on-line testing, e. g., one which uses trend analysis i and identification of safety margins for critical parameters of safety-related components. Such a program would require analytical justification supported by test 1 i

data.  ;

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4. Verify the capability to perform independent on-line testing of the reactor trip system breaker undervoltage and shunt trip attachments on I 1

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CE plante.- Inf ormation from licensees and ; applicants with CE plants -

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- will be'reviewedito verify that:they require.. independent on-line-

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3. GROUP REVIEW RESULTS

,The relevant submittals'from each'of the CE reactor plants were reviewed to determine compliance with Item 4.5.2. First ,. the' submi ttal s n :f rom _ea'ch plant werel reviewed to establish that Item 4.5.2 was specifically

'cddressed. Second, the submittals were evaluated to determine the extent to which eachbof.ithe.CE plants complies with the staff guidelines for

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. Item 4.5.2.'!

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4.- , REVIEW RESULTS FOR ARKANSAS NUCLEAR ONE, UNIT 2 4.1 Eval uati on Arkansas. Power and Light Company (AP&L), the license for Arkansas Nuclear One, provided their respons'e to Item 4.5.2 of the Generic Letter ca November 5, 1983. In that response, the licensee states that AP&L performC

-on-line testing of the Reactor Trip System,. including independent verification of the shunt and undervoltage trip attachments to the RTBs.

4.2 Concl usi on We' find that ' the licensee's statement that they currently perf orm on-line testing of the RTS meets the staff position on Item 4.5.2 of'the Generic-Letter and is, we believe, acceptable.

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5. - REVIEW RESULTS FOR~CALVERT CLIFFS UNITS 1 AND 2 l 5.1- Evaluation l

1 Baltimore Gas and Electric, licensee for Calvert Cliffs 1 and 2, rocponded'to the Generic Letter on November 5, 1983, and February 2T, 1984.

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The licensee's responses confirm that Calvert Cliffs is designed to permit on-line testing of the Reactor Trip System and that the shunt and undrrvoltage trip attachments are independently tested on-line.

5.2 Conclusion We find that the licensee's statement that they urrently perform on-line testang of the RTS meets the staff position on Item 4.5.2 of the Gsnaric Letter and is, we believe, acceptable.

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6. REVIEW RESULTS FOR FT. CALHOUN

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1 The Omah& Public Power District, the licensee for Ft. Calhoun, l responded to Item 4.5.2 of the Generic Letter-on November 4, 1983. In that

'recponse, the licensee states that Ft. Calhoun perf orms on-line testir.; of tha Reactor Trip System, that Ft. Calhoun has contactors rather than reactor trip breakers, and therefore Ft. Calhoun does not have a diverse trip

'footure.

6.2 Concl usi on

.We-find that the licensee's statement that they currently perform on-line testing of the RTS meets the staff position on Item 4.5.2 of the j 'Gsnsric Letter and is, we believe, acceptable.

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7. REVIEW RESULTS FOR MAINE YANKEE 7.1 Evaluation Maine Yankee Atomic Power Company, the licensee for Maine Yankee, rarponded.to Item 4.5.2 of the Generic Letter on November 10, 1983. In that-roeponse the licensee states that Maine Yankee performs on-line testing of
the Reactor Trip System, and is pursuing modifications that will pertai t on-line independent testing of the shunt and undervoltage attachments.

7.2 Conclusion We~ find that the licensee's statement that they perform ca-line testing of the RTS meets the staff ~ position on Item 4.5.2 of the Generic Letter and

.ic, we believe, acceptable.

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REVIEW RESULTS FOR HILLSTONE UNIT 2 o

8.1 Eval uati on Northeast Utilities, the licensee for Mill' stone 2,' responded to Itcm 4.5.2 of the Generic Letter on November 8, 1983. In that response the

-licensee states that Millstone 2 performs on-line testing of the Reactor Trip System.

Hocaever , the response also states that independent tecting of tha shunt and under voltage attachments is performed at eighteen month intervals; it is not clear from the response that the plant is designed to pcrmit independent on-line verification of operability .cf the shunt and undervoltage attachments.

B.2 Concl usi on We find. that the licensee's position on Item 4.5.2 of the Generic Lotter i s unacceptab'le.

l 1 The licensee must confirm that the plant has the i

ccpcbility to perform independent on-line testing of the f. hunt and undarvoltage attachments.

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9. REVIEW RESULTS FOR PALISADES -

9.1 Evaluation Consumers Power Company, the licensee fer Palisades, responded to Item 4.5.2 of the Generic Letter on February 19, 1985, and July 1, 1985. In tha latter response.the licensee states that Palisades currently performs on-line testing of the Reactor Trip System, that Palisades has contactors rather.,than reactor trip breakers, and theref ore Pali sades does not have - a diverse trip feature.

4 9.2 . Goncl usi on We find that the licensee *s statement that they perform on-line testing of the RTS meets the staf f positiot; on Item 4.5.2 of the Generic Letter and 10, we believe, acceptable.

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. 10.' ' REVIEW RESULTS FOR PALO VERDE UNITS.1,.2 AND 3' 10.1 Eval uati on

' Arizona Public Service Company, the' licensee for Palo' Verde Unit 1 and Japp'licant for Palo Verde Units.2 and 3, responded to Item 4.5.2 of the G2nsric Letter on November 3,'1983. In that response, the licensee. states

-thet the Palo Verde design allows performance of on-line testing of the

-_Rasctor Trip System, and that the applicable procedures for the on-line

tooting includes independent testing of the reactor trip breaker shunt and

.undarvoltage trip attachments.

10.2 Concl usi on We find that the licensee's statement that they currently perform

.on-line testing of the RTS at.Palo Verde 1 and will perform on-line testing of the RTS at Palo Verde 2 and 3 meets the staff position,on Item 4.5.2 of i

- ths Generic Letter and is, we believe, acceptable.

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11. REVIEW RESULTS FOR SAN ONOFRE UNITS 2 AND 3 11.,1 Eval uati on Southern California Edison Company, the licensee for San Onofre Units 2 cnd 3, responded to Item 4.5.2 of the Generic Letter on Novembe'r 29, 1983, cnd October 2, 1985. In the latter response, the licensee states that the San Onofre Unit 2 and 3 design allows performance of on-line testing of the Rasctor Trip System. However, it is not clear from the responses that the plcnt is designed to permit independent on-line-verification of oper abi l i t-of the reactor trip breaker shunt and undervoltage trip attachments.

11.2 Conclusion We find that the licensee's responses are inadequate to evaluate the extant of compliance with the staff position on Item 4.5.2 of the Generic Lotter and are, therefore, unacceptable. The licensee is required to

  • confirm that the plants have the capability to perform on-line independent verification of reactor trip breaker shunt and undervoltage trip attachment operability. .

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12. REVIEW RF' 'TS FOR ST. LUCIE UNITS 1 AND 2 12.1 Evaluation

' Florida Power and Light Company, licensee for St. Lucie Units 1 and 2, rocponded.to the Generic Letter on November 8, 1983. The licensee's rocponse confirms that St. Lucie is designed to permit on-line testing of tha Reactor Trip System and that monthly on-line testing of the RTS, including. independent testing of the shunt and undervoltage trip attach-m:nts, is performed.

12.2 Concl usi on We find that the licensee's statement that they currently perform on-line testing of the RTS meets tee staff position on Item 4.5.2 of the G3neric Letter and is, we believe, acceptable.

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13. REVIEW RESULTS FOR WATERFORD SES UNIT 3 .

g 9.1 Evaluation -

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Louisiana Power.and Light, the licensee for Waterford 3, provided a ra ponse to Item 4.5.2.of the Generic Letter on November 4, 1983. In that rceponse, the licensee states that Waterford is designed to permit on-line

.toating of the Reactor Trip System, and that.the applicable procedure is l

boing revised to include the required functional testing of the diverse trip fostures. It is not clear from the response that the on-line testing of the divcrse trip features includes independent verification of the shunt and undsrvaltage trip attachment operability.

9.2 Conclusion We find that the licensee's statement that Waterford 3 is designed to p;rmit on-line testing of the RTS meets the staff position on Item 4.5.2 of ths Generic. Letter and is, we believe, acceptable, provided the licensee confirms that Waterford 3 has the capability to perform independent on-line verification of the shunt and undervoltage trip attachment operability.

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11. REVIEW.'RESULTS FOR.WNP 3 1.

11.1 Eval ua t i on -

Wa'shington Public Power Supply System, the applicant for WNP 3, rocponded to Item 4.C.2.of the Generic Letter on August 23,~1983. In that roCponse,-the' applicant states.that construction'of WNP 3 is currently

. .dalayed and that i t;is not possible to commit to a schedule for compliance with the requirements.of. Generic Letter 83-20.

11.2 Conclusion

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-Item.4.5.2 of the Generic Letter will be resolved for WNP 3'during the review and approval process subs =@ent to resumption of ' construction and

1icansing activities for WNP'3.- Therefore, we consider this Item to be

. closed for this evaluation.

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15. GROUP CONCLUSION _

We conclude that the licensee / applicant responses for the listed CE plants for Item 4.5.2 of Generic Letter 83-28 are acceptable, with the excsption'of.those for Millstone Unit 2, San Onofre Units 2 and 3 and Wotorford 3, which were found to be incomplete as indicated in the plant specific review results. WNP 3 it in a state of extended construction delay and the staff has r;1osed this Item for this evaluation because it will be resolved _'during the resumption of licensing activities.

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13. REFERENCES
1. NRC Letter, D. G. Eisenhut to ali licensees of Operating Reactors, Applicants for Operating License, and Holders of Construction Permits,

" Required Actions Based on Generic Implications of Salem ATWS Events (Generic Letter 83-28)," July 8, 1983.

2. Generic Implications of ATWS Events At ; the Salem Nuclear Power Plant j NUREG-1000, VoIume 1, April 1983; Volume 2, July 1983.
3. Arkansas Power and Light Company letter to NRC, J. R. Marshall to D. G. Eisenhut, Director, Division of Licensing, NRC, " Arkansas Nuclear One Response to Generic Letter 83-28," November 5, 1983.
4. Baltimore Gas and Electric letter to NRC, A. E. Lundvall to D. G. Eisenhut, Director, Division of Licensing, November 5, 1983.
5. Baltimere Gas and Electric letter to NRC, A. E. Lu'ndvall to D. G. Eisenhut, Director, Division of Licensing, February 29, 1984.
6. Omaha Public Power District letter to NRC, W. C. Jones to D. G. Eisenhut, Director, Division of Licensing, NRC, " Required Actions Based on Generic Implications of Salem ATWS Events (Generic Letter 83-28)," November 4, 1983.

. 7. Maine Yankee Atomic Power Company letter to NRC, C. D. Frizzle to Director of Nuclear Reactor Regulation, NRC, " Required Actions Based on Generic Implications of Salem ATWS Events (Generic Letter 83-28),"

November 10, 1983.

8. Northeast Utilities letter to NRC, W. G. "ounsil to D. G. Eirrnhut, Director, Division of Licensing, Novemhe n. 1983.
9. Consumers Power Company letter to NRC, um.nes L. Kuemin to Director, Nuclear Reactor Regulation, " Supplemental Response to Generic  ;

Letter 83-28," July 1, 1985. l 1

10. Arizona Public Service Company letter to NRC, E. E. Van Brunt, Jr., to Director, Nuclear Reactor Regulation, November 3, 1983.
11. Southern California Edison Company letter to NRC, F. R. Nandy to Director, Office of Nuclear Reactor Regulation, " Response to Generic Letter 83-28," November 29, 1983.
12. Southern California Edison Company letter to NRC,,M. O. Medford to Director, Office of Nuclear Reactor Regulation, October 2, 1985.
13. Florida Power and Light Company letter to NRC, J. W. Williams, Jr., to D. G. Eisenhut, Director, Division of Licensing, " Generic Letter 83-28," November 8, 1983.

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s u 1.4..'Louiciona Powgr cnd Light letter to NRC, K._W. Cook to D. G. Eisenhut,  !

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Director, Division of Licznning, " Required Actions Based on Generic Implications November 4, of Salem ATWS Events (Generic Letter 83-28),"

1983.

15.- Washington Public Power Supply System letter to NRC, G. C. Sorenson to Director, Division of Licensing, "Nucl ear Project No. 3, Response to )

Generic Letter 83-28, Salem ATWS Event," August 23, 1983. l

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