W3P83-3911, Reissues 831104 Response to Generic Ltr 83-28, Required Actions Based on Generic Implications of Salem ATWS Events. Ltr Number Corrected

Reissues 831104 Response to Generic Ltr 83-28, Required Actions Based on Generic Implications of Salem ATWS Events. Ltr Number Corrected

ML20082G816
Person / Time
Site:	Waterford
Issue date:	11/04/1983
From:	Cook K LOUISIANA POWER & LIGHT CO.
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
GL-83-28, W3P83-3911, WC-3(83-3911, NUDOCS 8311300359
Download: ML20082G816 (16)

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Nevenber 4, 1983 WS?5 mSSti W3P83-3911 Q-3-A20.02.02 3-A1.01.04 L.02 Mr. Darrell C. Eisenhu:

Dir:ctor, Division of Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Cc==issien Wnshington, D. C. 20555 SU3 JECT: Waterford SES Uni: 3 Decket No. 50-382 Generic Letter 83-2S Required Actions Based on Generic Implications of Salen ATWS Events ,

REFERENCE:

NRC Letter dated October 18, 1983 frc= G. W. Knighton to R. S. Leddick Daar Mr. Eisenhut:

Tha referenced le::ar requested that we trans=it cur response to Generic Letter 83-28 to the NRC by November 5, 1983. Accordingly, attached is :he requested inf orma tion.

Due to our par:icipation in the CE Owners Grcup and INFO Nuclear Utility Task Action Cc==10:ee, as well as the extensive nature of certain require:ents, a cc=plete status or schedule is not available for all iters a: this ti=e.

However, the attached response includes the status, schedule for i=ple=en:stien, or plans for development of a schedule for submittal of i=ple=entation dates, as appropriate, for each ite= in the Generic Let:er. The respenses are nu=bered in accordance vi:h Generic Letter 83-28. Future sub=ittals will be =ade on an individual 1:e basis en the schedules provided herein.

If yeu have any questiens, please advise.

Very truly yours,

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K. W. Cook '

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Nuclear Supper: and Licensing Manager 0y'I -

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bec,2 -- ,R. S'. Laddick, L.-F. Starz, F. J. Drummond, R. P. 3srkhurst, S. A.'Allaman, T. F. Garrots, R. F. Burski, K. 17. Cook,'

R. A. Savoie, D. W. Herrin, W. A. Cross, Central Records, Nuclear Records, Licensing Library i

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1.1 P.OST-TRI? REVIEW (PROGRAM DESCRIPTION AND PROCEDURE)

LP&L is presently refising General Operating Procedure 0?-10-001 to address the concerns raised by :his section of Generic Le::er 33-28. A report su==arizing car implements:ica of these recuirements vill be sub=1tted to

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1.2 POST-TRIP REVIEW - DATA AND INFORMATION CAPA3ILITY ,

1. The Sequence of Events file is scheduled to be integrated into the Plant Monitoring Computer software and tested prior to fuel load.

2. The Post Trip Review file is scheduled to be integrated into the Plant Monitoring Computer software and tested prior to fuel load.

3. The Safety Parameter Display System is scheduled to be integrated into the Plant Monitoring Computer prior to the 5% power plateau of Power Ascension Testing.

4. A report su==arizing our program to implement this item vill be submitted February 1,1984.

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F 2 .1. EQUIPMENT CLASSIFICATION AND VENDOR INTERFACE (REACTOR TRIP SYSTEM CCMPONENTS)

LP&L is presently conducting a thorough docu=entation review 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 use.d in the plant to control safety-related accitities, including maintenance, work orders, and parts replacement.

As noted in Section-2.2.2 of this report, LP&L is participating in an INP0 program to develop actions necessary to establish a vendor interface program. The results of the INPO progra= will be used to establish a near-term vendor interface program for reactor trip system components. This program may later be incorporated into the larger vendor interface program for all safety-related components on a schedule consistent with Section 2.2.2.

A final report, detailing our docu=entation review and vendor interface

. program for reactor trip system components will be submitted to the NRC by March 30, 1984.

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2.;t -EQUIPMENT CLASSIFICATION AND VENDOR INTERFACE (?RCGRAMS FOR ALL

• SAFETY-REI.ATED COMPONENTS) 2.2.1 A listing of safety-related structures, syste=s and components is contained in Table 3.2-1 of the Waterford FSAR. Safety-related systems are further expanded to the component level in other sections of the FSAR,'for exinple, the = aster equipment list submitted in response to NUREG 0588 as referenced in FSAR Section 3.11; submittals made in accordance with seismic qualification review as referenced in FSAR Section 3.10;'and the listing of safe shutdown equipment required for Appendix R and detailed in FSAR Section 9.5.1.

In response to Generic Letter 83-28 LP&L has committed to a comprehensive review of our equipment classification sche =e in order to develop a refined listing of safety-related components by October, 1985.

The program that will be developed to generate this list will include:

1) criteria for identifying safety related co=ponents, 2) a system to identify safety related components using the criteria and a sethod for development and validation of the data, 3) procedures for use of the data by various plant groups, 4) require =ents for appropriate levels of management review and approval of the program and procedure used in the list developcent, and 5) a priorization of syste=s to ensure that all safety-related components are included in the listing. ,-

Procedures are presently in place to ensure that design verification and qualification testing are specified for procurement of safety related components. The procedures vill be reviewed to ensure actions required by this section are adequately addressed.

With respect to the equip =ent classification program in use at Waterford 3 for' structures, systems and components important to safety, we are participating in the Utility Safety Classification Group and are seeking a generic resolution to the staff's concern in this regard through the efforts of this Group. We do not agree that plant structure and components i=portant to safety constitute a broader class than the safety related set. We nevertheless believe that non-safety related plant structures, syste=s and components have been designed, and are maintained, in a =anner coc=ensurate with their i=portance to the safety and operation of the plant.

A report concerning our i=ple=entation of the requirements for this section will be submitted by November 15, 1985.

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2.2.2' -

LP&L is cetivaly participnting in tha INFO Nuclear Utility Task Action Committee (NUTAC) which is exploring actions that can be taken to address vendor interface problems utili:ing an industry vide approach.

.The results of the NUTAC actions are scheduled for review and approval by me=ber utilities in February,1984 Upon approval of the NUTAC results L?&L will begin develop =ent of a vendor interface program for all safety-related components. This-

. program vill be fully i=ple=ented upon ecmpletion of the safety-related equipment classification.

A description of the program and confirmation of its i=ple=entation vill be provided to the NRC by November 15, 1985.

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3.1 POST-MAINTENANCE TESTING (REACTOR TRIP SYSTEM COMPONENTS)

We are in the process of incorporating post-caintenance testing requirements for Reactor Trip System Cocponents into plant procedures. We are also reviewing vendor and engineering reco==endations to ensure appropriate test guidance is included in our test and maintenance procedures. Additionally, we are reviewing cur entsting techniccl specifications to deter =ine if any reactor trip system post-=aintenance test requirements could possibly degrade rather than enhance safety.

A statement concerning our completion of items 3.1.1 and 3.1.2 vill be submitted March 1, 1984 along with a request for any necessary technical specification changes as required by item 3.1.3.

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O 'l 3 d POST-MAINTENANCE TESTING (ALL OTHER SAFETY-RELATED COMPONENTS)

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The.present plant procedures requira post-maintenance testing of all l identified safety-related equipment to assure that the equip =ent is capable 1 of perforning its safety functions before being returned to service.

Post-Maintenance testing is included in test and =aintenance procedures. i The administrative procedures covering control of caintenance requires that the post-naintenance testing requirements be identified and the testing ,

signed off by the" Nuclear Operations Supervisor. In conjunction with^the licensing process, the Technical Specifications have been closely reviewed by LP&L. The procedure development procedure requires procedures to be consistent with all Technical Specificatica 11:1 ting conditions for operation and applicable vendor-recommended operating limits. This is also reviewed as part of the Technical Review Checklist which is completed for all procedures.

Maintenance procedures are reviewed whenever a revision is written or every two years. The post-caintenance operability testing and vendor and engineering reco==endations will be reviewed in conjunction with the normally scheduled procedure reviews. The reviews will be completed and docu=ented in a submittal to the NRC by November, 1985.

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'4.1 REACTOR TRIP SYSTDi RELIABILITY (VENDOR-RELATED MODIFICATIONS)

'Je have sought the assistance of Ebasco Services and Co=bustion Engineering to review all vendor-reco== ended reactor trip breaker =odifications. By February 17, 1984, we will submit to the NRC a report that will:

1) verify that each modification has been imple=ented; or 2) present a schedule for imple=enting any re=aining =edifications; or 3) provide a written evaluation of the technical bases for not imple=enting recc== ended modifications.

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4.1 REACTOR TRI? SfSTEM RELIABILITY (PREVENTATIVE MAINTENANCE AND SUR7EILLANCE

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4.2.1 The Technical Specifications recuire a functional test of the Reactor Trip 3reakers =onthly during operation, each startup and following =aintenance- This functional test (OP-903-006) vill independently test the undervoltage and shunt trip devices in accordance with Co=bustion Engineering Availability Data Progra: Info Bulletin 81-02 Supple =ent 1.

Preventive maintenance is performed in accordance with ME-4-155.

This procedure includes inspection and cleaning, contact adjust =ents, =echanism adjust =ents, insulation testing and functional testing as reco== ended by the vendor technical =anual, General Electric Service Advice Letter (SAL) 175 dated April 2, 1979 and the Supple =ent to SAL 175 dated' April 15, 1983.

4.2.2, The CE Owners Group is considering a joint effort with the 35W 4.2.3, Owners Group to develop a reliability assurance progra= for the 4.2.4, reactor trip breakers. This progra= is intended to gather data on AK2 breakers frc= in-place surveillance and =aintenance programs over a two year period to assess the reliability of the breakers and their subcomponents for the reactor trip function. This progra= vould be in lieu of any life cycle testing of the breakers.  ;-

LP&L presently intends to participate in this effort should the CECG adopt the progra=. After the next CEOG =eeting scheduled for late January, L?&L will be in a position to supply a = ore definitive schedule and response for these items. This infornation v111 be sub=itted by March 1, 1984.

L?&L is also using ti=e response data to trend breaker operation according to the guidance provided by Co=bustion Engineering ADP Information Sulletin 83-07 dated June 15, 1983. This progra= =ay be re-evaluated or combined with the above tasks after their progra=s and schedules beco=e clear.

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4.3. REACTOR TRI? SYSTEM RELIABILITY (AUTOMATIC ACTUATION OF SEUNT TRIP ATTACEMENT FOR WESTINGHOUSE L'D 3&W PLANTS)

This sec:icn is ac: applicable to Waterford 3, which is a Ocabustion

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L ILIII ( RV NTS IN MAINTENANCE L'TD TEST PRCTC90'R FO 3&T ?u This section is not applicable to tiaterford 3.

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4.5 . REACTOR TRIP SYSTEM RELIABILITY (SYSTEM FUNCTIONAL TESTING) 4.5.1 Procedure OP-903-006, " Manual Reactor Trip Test" is being revised to include the requirec functional testing of the diverse trip features. A statzment indicating i=ple=entation of this item will be submitted by January 1, 1984 4.5.2 The Reactor Trip System is currently designed to per=it periodic on-line testing. The FSAR provides adequate infor=ation for staff review of this ites. No further submittals are required.

4.5.3 The C-E Owners Group has proposed a review of the existing interval for on-line functional testing as required by Technical Specifications. LP&L presently intends to participate in this effort.

> Further information and schedules will be provided by March 1, 1984, following the next =eeting of the CEOG.

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STATE-0F' LOUISIMTA) '

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PARISH OF ORLEANS )- l K..W. Cook, being duly sworn, states that he is Nuclear Support and Licensing l M:neger of Louisiana Power & Light Company and that he is authorized on the part cf said company to sign and file with the liuclear Regulatory Commission this rarp:nse to Generic Letter 83-28.

0 K.' W. Cook Z-

-SUBSCRIBED AND SWOPli to e me, a No. f Publief in and for the Parish and State above named, this day of / (/ #s /ar, 1983, 1

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Before the UNITED STATES NUCLEAR REGULATORY COMMISSION Docket No. 50-382 In the Matter of LOUISIANA POWER & LIGHT CCMPANY Respense to Generic Letter S3-28 Lcuisiana Power & Light Company, Applicant in the above captioned proceeding, h:raby files a response to Generic Letter 33-28, for Waterford SES Unit No. 3.

Respectfully subcitted, LOUISIAA ?0NER & LIGHT COMPANY By: I LL' bt I K. W. Cook Nuclear Support and Licensing Manager DATE: . November 4, 1983