ML20205E360

Safety Evaluation on Util 830806,1109 & 840330 Responses to Generic Ltr 83-28,Items 3.1.1,3.1.2,3.2.1,3.2.2 & 4.5.1. Licensee Complied W/All Items

ML20205E360
Person / Time
Site:	FitzPatrick
Issue date:	08/06/1986
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20205E337	List: ML20205E331 ML20205E360
References
GL-83-28, NUDOCS 8608180328
Download: ML20205E360 (4)

Text

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s j SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO GENERIC LETTER 83-28, ITEMS 3.1.1, 3.1.2, 3.2.1, 3.2.2, AND 4.5.1 POWER AUTHORITY OF THE STATE OF NEW YORK l

JAMES A. FITZPATRICK NUCLEAR POWER PLANT l i/CKET N0. 50-333 i 1.0. Introduction On February 25, 1983, both of the scram circuit breakers at Unit 1 of the Salem Nuclear Power Plant failed to open upon an automatic reactor trip l signal from the reactor protection system. This incident occurred during '

the plant startup, and the reactor was tripped manually by the operator about 30 seconds after the initiation of the automatic trip signal. The ,

failure of the circuit breakers has been determined to be related to the  !

sticking of the undervoltage trip attachment. Prior to this incident, on February 22, 1983, at 'Jnit 1 of the Salem Nuclear Power Plant, an automatic, trip signal was generated due to a 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 these incidents, on February 28, 1983, the NRC Executive Director for Operations (EDO), 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 genericimplicationsoftheSalemIincidentsarereportedinNUREG-1000, Gencric Implications of ATWS Events at the Salem Nuclear Power Plant."

As a result of this investigation, the Director, Division of Licensing, Office of Nuclear Reactor Regulation requested (by Generic Letter 83-28 l dated July 8,1983) all licensees of operating reactors, applicants for an operating license, and holders of construction permits to respond to car-tain generic concerns. These concerns are categorized into four areas:

(1) Post-Trip Review, (2) Equipment Classification and Vendor Interface, (3) Post-Maintenance Testing, and (4) Reactor Trip Systera (RTS) Reliabi-lity Improvements. Within each of these areas, various specific actions were delineated.

This safety evaluation (SE) addresses the following actions of Generic Letter 83-28:

3.1.1 and 3.1.2, Post-Maintenance Testing (Reactor Trip System Components) 3.2.1 and 3.2.2, Post-Maintenance Testing (All Other Safety-Related Components) -

4.5.1, Reactor Trip System Reliability (System Functiohal Testing)

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By letters dated September 6, 1983; November 9, 1983, and March 30, 1984, 1 New York Power Authority (Licensee) described their planned and completed ,~

i actions regarding the above items for the James A. Fitzpatrick Nuclear l Power-Plant. -

2.0. Evaluation 2.1. General Generic Letter 83-28 included various NRC staff positions regarding the specific actions to be taken by operating reactor licensees and operating license applicants. The Generic Letter 83-28 positions

. and discussions of licensee compliance regarding Actions 3.1.1, -

3.1.2, 3.2.1, 3.2.2, and 4.5.1 for Fitzpatrick are presented in the sections that follow.

2.2. Actions 3.1.1 and 3.1.2, Post-Maintenance,, Testing (Reactor Trip System Components)

Position 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 (RTS) is required to be conducted and that the testing demonstrates that the equipment is capable of performing its safety functions before being returned to i service.

Licensees and applicants shall submit the results of their check of j vendor and engineering recommendations (regarding safety-related components in the RTS) to ensure that any appropriate test guidance is included in the test and maintenance procedurps or the Technical Specifications, where required.

Discussion By a letter dated November 9,1983, the licensee indicated that its reviews of procedures, technical specifications, and vendor recom-mendations were completed to assure that post-maintenance testing of safety related components in the reactor trip system was required to be performed. The licensee further stated that the BWR Owners Group would provide additional information with respect to the generic in-plications of the Salem ATW5 event,'and that revisions or additions

.to post-maintenance testing programs or procedures would be completed

- after receipt of final recommendations of a Nuclear Utility Task Action Committee (NUTAC) and the vendor group.

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The licensee stated that a review of the Technical Specifications was c6mpleted to determine if any post-maintenance test requirements de- ,_

grade safety, and that the review did not identify any of such cases.

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The licensee has completed a major revision of the Work Activity Con- 1 trol Procedure (WACP) 10.1.1, Procedure for Control of Maintenance, on January 31, 1986, which specified the testing requirements of the reactor trip system components before being returned to service fol-lowing maintenance.

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Based on the above, the staff concluded that the licensee has compli- )

ed with the NRC staff position for actions 3.1.1 and 3.1.2 of Generic l Letter 83-28.

2.3. Actions 3.2.1 and 3.2.2, Post-Maintenance Testing (All Other

'Saifety-Related Nmponents)

Position

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Licensees and applicants shall submit a report documenting the ex-

tanding of test and maintenance procedures and Technical Specifica-tions review 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.

Licensees and applicants shall submit the results of their check of vendor and engineering recommendations (all other safety-related com-ponents) to ensure that any appropriate test guidance is included in

, the test and maintenance procedures or the Technical Specifications, I where required.

l Discussion s l

In letters of September 6, 1983, November 9, 1983, and March 30, 1984, the licensee indicated that a program was implemented to incorporate both current and future vendor and/or engineering recommendations into test performance, maintenance, post-maintenance tests or techni-cal specifications. .

Safety-related maintenance work and subsequent post-maintenance test-ing requirements were addressed in the station procedure WACP 10.1.1, Procedure for Control of Maintenance, Revision 10, January 31, 1986. .

, The licensee also stated that Operations Department standing Order i i number 18 and the procedure WACP 10.1.1 provided instructions and >

guidance to the Shift Supervisor and Quality Control Personnel on test performance, inspection and acceptance, assuring that all

• i . safety-related equipment is operable when .it is returned to service.

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4 Based on the above and the licensee's commitment to incorporate any future vendor recommendations into the station procedures, the staff concluded that the licensee. has . complied with.the NRC staff position

_for actions 3.2.1 and 3.2.2 for Generic Letter 83-28. .

2.4. kction 4.5.1. Reactor Trip System Reliability (System Functional Testina)

Position On-line functional testing of the reactor trip system, including in-dependent testing of the diverse trip features, shall be performed on all plants. The diverse trip features to be tested include the- i breaker undervoltage and shunt trip features on Westinghouse, 86W and CE plants; the circuitry used for power interruption with the silicon controlled rectifters on B&W plants; and the scram pilot valve and backup scram valves (including all initiating circuitry) on GE plants.

Discussion -

i In a letter dated November 9,1983, the licensee stated that the re-liability of the reactor trip system is demonstrated by the on-line functional tests and calibrations required by Technical specification Table 4.1-1, in conjunction with control red scram time testing. The i licensee indicated that the tests periodically demonstrate function and reliability of the entire reactor trip system. The Itcensee fur-ther stated that the design of the backup scram valves does not permit a qualitative on-line test and they are not required to be

. tested by Technical Specifications.

Justification for not making modifications to permit on-line testing has been reviewed separately by the staff under. Action Item 4.5.2 of Generic Letter 83-28, and the staff found that'such modifications are not required.

I l Based on the above, the staff concluded that the licensee has com-i plied with the NRC staff position for Action 4.5.1 of Generic Letter l ss-2s.

3.0. Conclusion Based upon the foregoing discussions, the staff concludes that the Itcensee has complied with Actions 3.1.1, 3.1.2, 3.2.1, 3.2.2, and 4.5.1 of Generic Letter 83-28.

l Dated:

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l.- . Principal Contributor:

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[~ J. Chung, Division of Reactor Safety, Region !

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