ML20136D145

Safety Evaluation Re Response to Generic Ltr 83-28,Items 3.1.1-3,3.2.1-3 & 4.5.1 Concerning post-maint & Reactor Trip Sys Functional Testing.Response Acceptable

ML20136D145
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	11/19/1985
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20136D104	List: ML20136D100 ML20136D145 ML20138M277
References
GL-83-28, NUDOCS 8511210233
Download: ML20136D145 (3)

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION FOR GENERIC LETTER 83-28, ITEMS 3.1.1, 3.1.2, 3.1.3, 3.2.1 3.2.2, 3.2.3, AND 4.5.1 (POST-MAINTENANCE AND RTS FUNCTIONAL TESTING)

CONSUMERS POWER COMPANY BIG ROCK POINT PLANT DOCKET NO. 50-155

1.0 INTRODUCTION

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~r s On February 25, 1983, both of the scram circuit breakers at Unit 1 of-the Salem Nuclear Power Plant (SNPP) failed to open upon an automatic reactor trip signal from the reactor protection system. This incident occurred during plant start-up and the reactor was tripped manually by the operator about 30 seconds after initiation of the automatic trip signal. Failure of the circuit breakers has been determined to be re-lated to sticking of the undervoltage trip attachment. On February 22, 1983, an automatic trip occurred during the start-up of SNPP, Unit 1, as the result of steam generator low-low level. In this case, the reactor was tripped manually by the operator almost coincidentally with the automatic trip. On February 28, 1983, the NRC Executive Director for r Operations directed the staff to investigate and report on the generic j implications of these occurrences. The results of this staff investi-

! gation are reported in NUREG-1000, " Generic Implications of ATWS Events ,

[ at the Salem Nuclear Power Plant." As a result of this investigation, j the Comission 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 certain generic con-cerns. These concerns are categorized into the following four areas:

Post-Trip Review, (2) Equipment Classification and Vendor Interface; Post-Maintenance Testing; and (4) Reactor Trip System Reliability Improvements.

The third action item, Post-Maintenance Testing, consists of Action Items 3.1.1, 3.1.2 and 3.1.3, " Post-Maintenance Testing (RTS Components)" and 3.2.1, 3.2.2 and 3.2.3, " Post-Maintenance Testing (All Other Safety-Related Com-ponents)." All of these action items are addressed in this evaluation.

The fourth action item, Reactor Trip System Reliability Improvements con-sists of five areas. Item 4.5, " Reactor Trip System Reliability (System Functional Testing) consists of Action Items 4.5.1, 4.5.2, and 4.5.3.

This evaluation addresses Action Item 4.5.1 only.

8511210233 851119 PDR ADOCK 05000155 P PDR

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l 2.0 EVALUATION By letters dated November 7, 1983 February 2, 1984, October 2, 1984, June 28, 1984, and June 1, 1984, Consumers Power Company responded to specific items of GL 83-?8. The licensee sumarized the results of the requested review and concluded that all items have been appropriately

addressed.

2.1 Items 3.1.1 and 3.1.2 " Post-Maintenance Testing (RTS Components) y lhe review criteria for these items require that the licensee submit i a statement indicating that it has reviewed plant test and maintenance procedures and Technical Specifications to ensure that post-maintenance

operability testing of safety-related components in the reactor trip

system is required. Also, the licensee's statement should contain a i

verification that vendor recomended test guidance has been reviewed,

evaluated, and where appropriate, included in the test and maintenance

Fi.." procedures or the Technical Specifications. The staff has evaluated i

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the licensee's October 2,1984,~ submittal for this item and has deter-i mined it to be adequate in content.

2.2 Items 3.2.1 and 3.2.2, " Post-Maintenance Testing (All Other Safety- '

i Related Components)"

i The review criteria for these items require that the licensee submit

, a statement indicating that it has reviewed plant test and maintenance i procedures and Technical Specifications to ensure that post-mainte-nance operability testing of all safety-related components is required.

1 Also, a statement is required that contains a verification that vendor ,

4 recommended test guidance has been reviewed, evaluated, and where i appropriate, included in the test and maintenance procedures or the 4 '

Technical Specifications. The staff has evaluated the licensee's June 28, 1984, submittal for this item and has determined it to be

• t j adequate in content.

2.3 Items 3.1.3 and 3.2.3, " Post-Maintenance Testing" l

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The licensee was required by Generic Letter 83-28 Items 3.1.3 and i i 3.2.3 to review its existing Technical Specifications for post  !

maintenance testing requirements that may degrade rather than enhance safety. The licensee has responded by submittals dated November 7, i 1983, February 2, 1984, October 2, 1984 and August 16, 1985. A review of the responses as documented in the attached contractor's report (EG8G EA-6906) finds the licensee's responses to GL 83-28 i Items 3.1.3 and 3.2.3 to be acceptable. Our staff concurs with

the contractor's findings and finds the licensee's responses for

these items, therefore, to be acceptable.

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2.4 Item 4.5.1, "RTS Reliability (System Functional Test Description)"

The review criteria for this item requires that the licensee submit a statement committing to independent, on-line functional testing of the diverse trip features. The staff has evaluated the licensee's June 1,1984, submittal for this item and has determined it to be adequate in content.

3.0 CONCLUSION

The staff concludes, based on the licensee's programs outlined in its submittals as well as its submittal statement that no post-maintenance test requirements were found in the Big Rock Point Technical Specifications that degraded safety, that the licensee has adequately address the require-ments of GL 83-28 for the items specified in this Safety Evaluation.

4.0 ACKNOWLEDGEMENT ,

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Principal contributors to this evaluation were: T. E. Taylor, D. Lasher -

and T. Rotella.

Date:

Attachment:

TER EG8G EA-6906 k

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