ML20214C638

Safety Evaluation Re Util Submittals on Generic Implications of Salem ATWS Event (Generic Ltr 83-28),Items 3.2.1 & 3.2.2. Response Acceptable

ML20214C638
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	02/12/1986
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20214C267	List: ML20214C266 ML20214C638
References
GL-83-28, TAC-53808, NUDOCS 8602210215
Download: ML20214C638 (4)

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' ko UNITED STATES NUCLEAR REGULATORY COMMISSION a I

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\.....* SATITY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION GENERIC IMPLICATIONS OF SALEM ATWS EVENT I

GENERIC LETTER 83-28 3 ITEMS 3.2.1 AND 3.2.2 PORTLAND GENERAL ELECTRIC COMPANY THE CITY OF EUGENE, OREGON PACIFIC POWER AND LIGHT COMPANY TROJAN NUCLEAR PLANT DOCKET NO. 50-344 I. INTRODUCTION-On February 25, 1983, during startup of the Gales Unit 1 Nuclear Plant, both circuit breakers in the Reactor Trip System failed to open automatically upon receipt of a valid trip signal. As a result of that 3- event, the NRC's Office of Inspection and Enforcement issued IE Bulletia 83-01 which described the event and requested specified prompt corrective and preventive actions by licensees. As the cause and ramifications of .-

the~ event were.more clearly developed, the NRC's Office of Nuclear Reactor Regulation issued on July 8,1983, Generic Letter 83-28,

" Required Actions Based on Generic Implications of Sales ATWS Events."

This letter addressed issues related to reactor trip system reliability and general management capability. The letter was sent to all licensees of operating reactors, applicants for operating licenses and holders of construction permits.

One of the areas of reactor trip system reliability considered in' Generic Letter 83-28 (GL 83-28), is that of post-maintenance testing of safety-related components other than those in the reactor trip system.

This is identified in GL 83-28 as Items 3.2.1 and 3.2.2. This evaluation addresses the acceptability of the response to these items provided by ~

Portland General Electric Company, et al. (the licensee) for the Trojan Nuclear Plant (the facility).

II. EVALUATION Items 3.2.1 and 3.2.2 of GL 83-28 state as follows:

"1. Licensees and applicants shall submit a report documenting the extending of test and usintenance procedures and Technical Specifications to assure that post-maintenance operability testing of all safety-related equipment is required to be conducted and that the testing demonstrates that the equipment is capable of performing its safety functions before being returned to service.

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"2. Licenseesandapplicantsshallsubmitth'eresbitsoftheircheckof vendor and engineering recommendations to ensure that any appropriate test guidance is included in the test and maintenance

• procedures or Technical Specifications, where required."

By letter dated Novesber 4, 1983,.the licensee responded to a number of GL 83-28 items,' including Items 3.2.1 and 3.2.2. In respons~e t'o questions raised by the staff, additional information was provided by licensee letters dated July 19 and October 17, 1985.

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Regarding Item 3.2.1, the licensee's letter of November 4, 1983,

indicated that, in general, post-maintenance operability testing of all safety-related equipment was conducted. The detailed response, however, suggested there coulo be instances when testing was not performed.

Because of this ambiguity, the licensee.was requested to provide clarification. This was supplied by the licensee's letter of July 19, ,

1985. In this response, the licensee explained that proper equipment l performance was determined in one of three ways: use of an approved permanent procedure, use of an approved temporary procedure or by means 1

of an " installation check". This latter method was stated to be used l where the characteristic to be verified could be checked by a qualified

! craftsman without detailed procedures, detailed acceptance criteria, or

) technical assistance. As examples of " installation checks", the licensee

cited verification that electrical circuits, controls and relay settings

! were correct; verification that instrumentation was calibrated and in j service as required; and verification that limit switches, interlocks and j stops are properly adjusted and set.

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In this regard, we note both Regulatory Guide-1.33, Rev. 2, Quality .

. Assurance Program Requirements, and ANSI Standard ANS-3.2/ ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Powe.r Plants, recognize that certain tasks

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may not require detailed step-by-step procedures when they involve skills normally possessed by a qualified craftsman. Based on the examples provided by the licensee, we conclude the use of " installation checks" is.

an acceptable practice as part of the overall post-maintenance testing

! program. Regarding such checks, the licensee notes _the work group 4

supervisor is responsible for ensuring that-installation checks used in

, post-maintenance testing are appropriate. The licensee also notes that I

any other surveillance required to verify the performance of the j equipment / system is required on the Maintenance Request (MR).

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' The licensee states the administrative controls in' Administrative Order -

A0-3-9, Maintenance Requests, will be revised to require a senior reactor

operator (SRO) to review MRs and discuss the work performed with Maintenance personnel to ensure the required testing is adequately ,

specified on the MR. In addition, if work is performed outside the scope

of the MR, it will be the responsibility of the Maintenance personnel to review the new scope of work with an SRO to define new testing as

! appropriate. Finally, the licensee notes safety-related equipment outage

] worksheets are generated per Administrative Order A0-3-14, for safety-related equipment removed from service, but not covered by a Plant j Review Board approved procedure which returns the equipment to service.

1 The licensee states Item 8 of this worksheet, " Verification Before l

Returning to Service", contains a signoff line to confirm that the required operability tests have been performed. .

Based on the foregoing, we conclude post-maintenance operability testing,

! appropriate to the equipment involved, is required to be performed not.

i only for reactor trip system components, but also for all safety-related equipment- '

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3-1 i Regarding Item 3.2.2, (incorporation of vendor recommendations in test

and maintenance procedures), the licensee's November-4, 1983 response

, stated vendor recommendations had been utilized at'the time the

maintenance and-test procedures had first been developed, and that a review of vendor and engineering recommendations beyond those contained in Westinghouse Bulletins and Letters was not planned. Because this did not appear to conform to the intent of the guidance stated in Item 3.2.2, the licensee was requested to provide justification for not conforming to this guidance. The licensee responded _by letters dated July 19 and October 17, 1985.

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L The licensee's July 19, 1985 letter stated it was their position that operating experience gained since 1975, combined with operational feedback from the NRC, Vendors, INPO and other utility sources, was sufficient to provide reasonable assurance that significant problems which might have existed (in maintenance and test procedures) have 4

already been identified. Based on this, the licensee expressed the view that the cost of the review requested by the NRC was unwarranted. _The licensee also stated, however, they had established a task force to i review all safety-related technical manuals for accuracy and consistency,

' and update. the manuals as necessary. The licensee stated this review was scheduled to be completed by July 1987.

Because the review of technical manuals planned by the licensee

] constituted a major element, but not all of the action requested by Item 3.2.2, the staff contacted the licensee to discuss the provision in the facility technical specifications requiring periodic review of I facility procedures. The staff noted this review could be expanded to

! include verification that the technical content of~each reviewed j procedure conformed to current vendor guidance. The licensee's letter of

! October 17, 1985 responded to this discussion by committing to revise Nuclear Division Procedure NDP 100-3, Updating Technical Manuals, to j require review of applicable safety-related procedures when a significant ~

revision to a technical manual is required.

I-From the above we can summarize that the licensee has committed to review

! all safety-related technical manuals for accuracy and consistency by July 1987, and has committed to revise the applicable safety-related procedures when a significant revision to a technical manual is required.

We conclude these actions are equivalent to those requested by j Item 3.2.2.

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, III. CONCLUSIONS l

Based on the licensee's confirmation that facility procedures require i post-maintenance testing of all safety-related equipment to demonstrate.

its operability, we conclude the licensee has satisfattorily completed the actions requested by Generic Letter 83-28, Item 3.2.1. Accordingly, this item is closed. .

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r a:: '4 8 Based on the licensee's earlier review of Westinghouse Bulletins and Letters, the current review of all'other vendor. literature for safety-related equipment, and the commitment to revise associated procedures when a significant revision'to_a technical manual is identified, we conclude the licensee is in the process of acceptably performing the actions requested by Generic Letter.83-28, Item 3.2.2.

Accordingly, this item is closed.

Date: February 12, 1986 Principal Contributor:

G. Zwetzig A

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