ML20135G105

SER Supporting Licensee Response to Items 3.1.1,3.1.2,3.2.1, 3.2.2,4.1 & 4.5.1 of Generic Ltr 83-28, Required Actions Based on Generic Implications of Salem ATWS Events

ML20135G105
Person / Time
Site:	Crystal River
Issue date:	09/09/1985
From:	NRC
To:
Shared Package
ML20135G101	List: ML20135G100 ML20135G105
References
GL-83-28, NUDOCS 8509180160
Download: ML20135G105 (5)

Text

- , ,,. ._ - . - . . - _. . .

- . - - ~ - - . - - . . . - ~

.{..

I i

~

l SAFETY EVALUATION REPORT FOR GENERIC LETTER 83-28. ITEMS 3.1.1.

3.1.2. 3.2.1, 3.2.2. 4.1 AND 4.5.1

-l CRYSTAL RIVER PLANT, UNIT 3

$ D0CKET NO. 50-302 ,

J I. INTRODUCTION  !

' In February 1983, the Salem Nuclear Power Station experienced two failures i of the reactor trip system upon the receipt if trip signals. These failures i

were attributed to Westinghouse - Type 08-50 reactor trip system (RTS) circuit breakers. The failures at Sales on February 22 and 25,1983, were ,

believed to have been caused by a binding action within the undervoltage trip attachment (UVTA) located inside the breaker cubicle. Due to problems

)

of the circuit breakers at Salem and at other plants, NRC issued Generic Letter (GL) 83-29 Required Actions Based on Generic Implementations of i

Salem Anticipate. Transient Without Scram (ATWS) Events, dated July 8,1983.

This letter' required the licensees to respond on immediate-term actions to j

ensure reliability of the RTS. Actions to be performed included development j of programs to provide for post trip review, classification of equipment.

vendor interface, post-maintenance tasting, and RTS reliability improve-ments. The Generic Letter stated that for Action Items 3.1.1, 3.1.2, 3.2.1, 3.2.2, 4.1, and 4.5.1 NRC. Regional Offices would perform .a post-implemen-i tation review and issue Safety Evaluation Reports. This report is the Regional Safety Evaluation of Florida Power Corporation (FPC) submittals l '

dated November 4,1983 and July 31,1984, to GL 83-28 for Crystal River

{ Unit 3. A regional inspection was conducted at the Crystal River facility '

i during February 11 - 15, 1985, to review the licensee's current program, planned program improvements, and implementation of present procedures associated with post-trip review, equipment classification, vendor inter-i face, post-maintenance testing, and reactor trip system reliability. The j details of the inspection findings are discussed in Inspection Report No.

j 302/85-07.

II. REVIEW GUIDELINES l The licensee's responses were evaluated for compliance to the staff's

. positions delineated in GL 83-28 for Action Items 3.1.1, 3.1.2, 3.2.1, I

l DR 302 -

p PDR ~

[ .

l..

Enclosurt 2 3.2.2, 4.1 and 4.5.1. The requirements of the above action items, as

described in the Generic Letter, are paraphrased below

, 3.1 Post-Maintenance Testing (Reactor Trip System Components) r l Position

1. Licensees and applicants shall submit the results of their review of test and maintenance procedures and Technical Specifications to ,

assure that post-maintenance operability testing of safety-related components in the reactor trip system is required to be conducted i

and that the testing demonstrates that the equipment is capable of performing its safety functions before being returned to service. ,

'., 2. Licensees and applicants shall submit the results of their check 4

of vendor and engineering recommendations to ensure that any ,.

appropriate test guidance is included in the test and maintenance procedures or the Technical spectfications, where required.

r j 3.2 Post-Maintenance Testing (All Other Safety-Related Components)

Position The following actions are appl'icabin to post-maintenance testing: ,

i

' 1. Licensees and applicant shall submit a report documenting the extending of test an.d maintenance procedures and Technical Speci-1 fications review to assure that post-maintenance operability testing of all safety-related equipment is required to be conduct-l ed and that the testing demonstrates that the equipment is capable

! of performing its safety functions before being returned to

service.

! 2. Licensees and applicants shall submit the results of their check  :

of vendor and engineering recomunendations to ensure that any '

t appropriate test guidance is included in the test and maintenance procedures or the Technical Specifications where required.

'. s 4.1 Reactor Trip System Ralf ability (Vendor-Related Modifications)'  ;

) .

{ Position  !

4 All ' vendor-recossended reactor trip breaker modifications shall be reviewed to verify that either: (1) each modification has, in fact, I i been implemented; or (2) a written evaluation of the technical reasons i

for not implementing a modification exists.  !

I For example, the modifications recommended by Westinghouse in NCD- [

j Elec-18 for the DB-50 breakers and a March 31, 1983, letter for the  !

i f

. . . . , . . - - ~ ~ , _ . _ , . , - - . . - . - . . - , . ~ . - . _ _ , _ . - . _ . . , _ _ _ _ _ . _ , . , _ _ . _ , , _ _ _ , . - _ - _ , _ , . _ _ _ , _

. . . ,~ .

Enclosure 3 DS-416 breakers shall be implemented or a justification for not imple-menting shall be made available. Modifications not previously made shall be incorporated or a written evaluation shall be provided.

4.ii Reactor Trip System Reliability (System Functional Testing)

Position On-line functional testing of the reactor trip system, including independent te:. ting of the diverse trip features, shall be performed on all plants.

1. The diverse trip features to be tested include the breaker under-voltage and shunt trip features on Westinghouse, B&W (see Action 4.3 of GL 83-28) and CE plants; the circuitry used for power interruption with the silicon controlled rectifiers on B&W plants (see Action 4.4 of GL 83-28); and the scram pilot valve and backup scram valves (including all initiating circuitry) on GE plants.

III. EVALUATION AND CONCLUSION By letters dated November 4,1983 and July 31, 1984 Florida Power Corpora-tion (FPC), the licensee of Crystal River Plant, Unit 3, provided informa-tion regarding their compliance to Sections 3.1, 3.2, 4.1 and 4.5 :f GL 83-28. We have evaluated the licensee's responses against the NRC positions described in Section II above for completeness and adequacy. We conclude

-that the licensee's responses to Action Items 3.1.1, 3.1.2, 3.2.1, 3.2.2, 4.1 and 4.5.1 are acceptable and meet the intent of GL 83-28.

Delineated below are the results of Region II's evaluation and a brief summary of the licensee's responses:

A. Item 3.1.1, Review of Test and Maintenance Procedures and Technical Specifications (Reactor Trip System Components)

The licensee's response to this item is acceptable and meets the intent i of GL 83-28. The licensee states in their submittals that post-main-j tenance testing is required on safety-related reactor trip system j components once maintenance is complete. In addition, this requirement is delineated 'in Compliance Procedure CP-113, Handling ed c.ontrolling l Work Requests and Work Packages. The licensee further stated in their

! submittals that each procedure affecting maintenance on safety-related j reactor trip system components will be reviewed to verify that ti:e post-maintenance test section of the procedures adequately demonstrates that the equipment is capable of performing its safety function prior

to being returned to service. The licensee committed to have the procedure reviews completed by December 31, 1984. Furthermore, if any changes to existing plant procedures or any new procedures are required

\. .-- . - , - ,, -- - .-- - - - - - - - --- --~--- ---- - - --

1

J t

l Enclosure 4 s

as a result of this review, the licensee committed to have them in

, place by March 1, 1985. During NRC inspection 50-302/85-07 (February 11 - 15, 1985), the inspectors confirmed that the licensee had completed reviews of reactor trip system components and was contin-uing to update procedures to include post-maintenance testing.

B. Item 3.1.2, Check of Vendor and Engineering Recommendation for Testing  ;

and Maintenance '

i The licensee's response to this item is acceptable and meets the intent of GL 83-28. The licensee states in their submittals that they will

] review the test and maintenance procedures and Technical Specifications for safety-related components in the reactor trip systen. to ensure that the test guidance reflects appropriate vendor infonnatio.1 and engineer-  ;

ing recommendations.

The licensee committed to have the reviews '

a completed by December 31, 1984. Furthennore, if any changes are

required to existing plant procedures or any new procedures are identi-i fied. as a result of. this review, the licensee comitted to have them in l place by March 1, 1985. During NRC inspection 50-302/85-07 the inspec-tors confinned that the licensee has been evaluating vendor information and utilizing this infornation during their development of procedures and instructions.

}

C. Item 3.2.1, Review of Test a'd Maintenance Procedures and Technical Specifications (All Other Safety-Related Components)

.i 4

The licensee's response to this item is acceptable and meets the intent 1

of GL 83-28. The licensee states in their submittals that post-main-tenance operability testing is perfonned on safety-related components once maintenance is complete. In addition, this requirement is delin- '

j eated in Compliance Procedure CP-113. Handling and Controlling Work Requests and Work Packages. The licensee further states in their j

submittals that each procedure affecting maintenance on safety-related '

i components will be reviewed to verify that the post-maintenance test i

section of the procedures adequately demonstrates that the equipment is capable of perfonning its safety function prior to being returned to t

service. The licensee conuitted to complete this review as part of the

' 24 month procedure review cycle, ~but not later than December 31, 1985.

i Furthermore, if any changes to existing plant procedure or any new procedures are required as a result of this review, the licensee i

connitted to have them in place by March 3,1986,

D.

Item 3.2.2, Check of Vendor and Engineering Recomunendation for Testing l and Maintenance (All Other Safety-Related Components) .

l The licensee's response to this item is acceptable and meets the intent of GL 83-28. The licensee states in their submittals that they will i

j review the test and maintenance procedures and Technical Specifications for safety-related components to ensure that the test guidance reflects  ;

l s

a I

.- ~, L~ .

Enclosure 5 appropriate vendor information and engineering recommendations. The licensee committed to complete this review as part of the 24 month procedure review cycle, but not later than December 31, 1985. Further-more, if any changes to existing plant procedures or any new procedures are required as a result of this review, the licensee connitted to have them in place by March 3, 1986.

E. Item 4.1, Reactor Trip System Reliability (Vendor-Related Modifica-tions)

The licensee's response to this action item is acceptable and meets the-intent of GL 83-28. The licensee indicated in their submittals that all GE recommendations are being implemented at Crystal River Unit 3.

During NRC inspection 50-302/85-07 (February 11 - 15, 1985) and subse-quent discussions with licensee personnel, Region II was informed that Crystal River 3 will continue to use the GE AK reactor trip breakers and that the bearing are being replaced with bearing lubricated with Mobil 23.

F. ' Item 4.5.1 Reactor Trip System Reliability (System Functional Testing)

] The licensee's response to this item is acceptable and meets the intent

of GL 83-28. The licensee confirmed in their response that surveil-J 1ance procedures require on-line testing of the undervoltage trip i feature and the circuitry used for power interruption with the silicon

! controlled rectifiers. In addition, the planned shunt trip modifica-i tion will include circuitry to provide for on-line testing of the shunt trip feature.

The licensee has scheduled the shunt modification to be

installed during the present refueling outage. The above items were j also confirmed during NRC site inspection 50-302/85-07 performed during i February 11 - 15, 1985.

G. Conclusion I

l i

Based on our review, we conclude that the licensee's responses to items 3.1.1, 3.1.2, 3.2.1, 3.2.2, 4.1 and 4.5.1 are acceptable and meet the i intent of GL 83-28.

i l

i i

,