ML20214D389

Safety Evaluation Supporting Applicant Response to Generic Ltr 83-28,Item 4.4,re Commitment to Use safety-related Procedures to Maintain & Test Silicon Controlled Rectifiers & to Complete Draft Procedures 1 Yr Prior to Fuel Load

ML20214D389
Person / Time
Site:	Washington Public Power Supply System
Issue date:	11/12/1986
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20214D364	List: ML20214D360 ML20214D389
References
GL-83-28, NUDOCS 8611240063
Download: ML20214D389 (3)

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',, UNITED STATES E" o NUCLEAR REGULATORY COMMISSION 3 ,E WASHINGTON, D. C,20555 k . . . . . ,o/ .

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION GENERIC LETTER 83-28, ITEM 4.4 IMPROVEMENTS IN MAINTENANCE AND TEST PROCEDURES FOR B&W PLANTS WASHINGTON NUCLEAP PROJECT, UNIT 1 DOCKET NO. 50-460 I. INTRODUCTION On February 25, 1983, at the Salem Nuclear Power Plant (SNPP) Unit 1, both of the scram circuit breakers failed to open on an automatic reactor trip signal from the reactor protection system. This incident occurred during plant start-up and the operator tripped the reactor manually about thirty 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 undervM tage trip attachment. On February 22, 1983, during start-up of SNPP, Un o 1, an automatic trip signal occurred as a result of steam generator low-low leve.. 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 staff started to investigate and report on the generic implications of these occurrences.

The results of the staff's inquiry into these incidents are reported in NUREG-1000, " Generic Implications of ATWS Events at the Salem Nuclear Power Plant." As a result of this investigation, the NRC requested, by Generic Letter

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83-28, dated July 8,1983 (Reference 1), all licensees of operating reactors, applicants for an operating license, and holders of construction pennits to respond to certain generic concerns. These concerns are categorized into four areas: (1) Post-Trip Review, (2) Equipment Classification and Vendor Inter-face, (3) Post-Maintenance Testing, and (4) Reactor Trip System Reliability Improvements.

Item 4.4 of Generic Letter 83-28 required licensees and applicants with B&W reactors to confinr that safety-related maintenance and test procedures are applied to the diverse reactor trip feature provided by interrupting power to the control rods through the silicon controlled rectifiers (SCRs). The test procedure should verify that the SCRs have degated, thereby removing power from the control rods. Item 4.4 also required that the SCRs be included in the appropriate surveillance and test sections of the Technical Specifications.

II. EVALUATION '

By letter dated March 30, 1984 (Reference 2), Washington Public Power Supply System, the applicant for Washington Nuclear Project, Unit 1 (WNP-1), responded to Item 4.4 of Generic Letter 83-28. The staff and its consultant, EG&G Idaho, Inc. (EG8G), have reviewed the applicants response. As a result of its review EG&G issued the attached Technical Evaluation Report (TER). The staff has reviewed this TER and concurs with its findings. This TER is considered a part of this Safety Evaluation Report.

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The applicant committed to use safety related procedures to maintain and test the SCRs and to complete the draft procedures one year prior to fuel load.

The applicant did not describe the required procedures. However, because WNP-1 is currently under an extended construction delay, the acceptability of the procedures and associated technical specifications will be determined by the staff when its technical review and evaluation of the WNP-1 operating license application resumes.

III. CONCLUSIONS Based on its review, the applicant's commitment, and the delayed construction status of WNP-1, the staff concludes that the applicant's response to Item 4.4 of Generic Letter 83-28 is acceptable. This item is, therefore, closed.

Dated: November 12, 1986 Principal Contributor:

D. Lasher l

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f REFERENCES

- 1. NRC Letter, D. G. Eisenhut to all Licensees of Operating Peactors.

Applicants for Operating License, and Holders of Constructinn Permits,

" Required Actions Based on Generic Implications of Salem ATWS Events (Generic Letter 83-28)", July 8, 1983.

2. Washington Public Power Supply System letter to NRC, G. C. Sorenson to Director of Nuclear Reactor Regulation, " Nuclear Project No.1 Response to Ger.eric Letter 83-28, Salem ATWS Event", March 30, 1984.

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TECHNICAL EVALUATION REPORT CONFORMANCE TO GENERIC LETTER 83-28 ITEM 4.4 ARKANSAS NUCLEAR ONE, UNIT 1 CRYSTAL RIVER UNIT 3 DAVIS-BESSE UNIT 1 OCONEE UNITS 1, 2 AND 3 RANCHO SECO THREE MILE ISLAND UNIT 1 WNP 1 E

F. G. Farmer Published October, 1986 Idaho National Engineering Laboratory EG&G Idaho, Inc.

Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Under DOE Contract No. DE-AC07-76ID01570 FIN No. D6001 and 06002  :

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ABSTRACT This EG&G Idaho, Inc. report provides a review of the submittals for Babcock & Wilcox (B&W) nuclear plants for conformance to Generic Letter F 83-28, Item 4.4. The group includes the following plants:

Plant Docket Number TAC Number Arkansas Nuclear One, Unit 1 50-313 53952 Crystal River Unit 3 50-302 53953 Davis-Besse Unit 1 50-346 53954 Oconee Unit 1 50-269 53955 Oconee Unit 2 50-270 53956 Oconee Unit 3 50-287 53957 Rancho Seco 50-312 53958 Three Mile Island Unit 1 50-289 53959 WNP 1 50-460 N/A

2 FOREWORD This report is provided as part of the program for evaluating licensee / applicant conformance to Generic Letter 83-28, " Required Actions .

based on Generic Implications of Salem ATWS Events." This work is conducted for the U. S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, Division of PWR Licensing-A, by EG&G Idaho, Inc.

The U. S. Nuclear Regulatory Commission funded the work under the authorization, B&R 20-19-19-11-3 and 20-19-40-41-3, FIN No. D6001 and D6002.

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CONTENTS

' 11 ABSTRACT .............................................................

iii FOREWORD .............................................................

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1. INTRODUCTION ....................................................

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2. REVIEW REQUIREMENTS .............................................

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3. GROUP REVIEW RESULTS ............................................

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4. REVIEW RESULTS F OR ARKANSAS NUCLE AR ONE , UNIT 1 . . . . . . . . . . . . . . . . .

4 4.1 Evaluation ................................................

4 4.2 Conclusion ................................................

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5. REVIEW RESULTS FOR CRYSTAL RIVER UNIT 3 .........................

5p 5.1 Evaluation ................................................

5 5.2 Conclusion .................................................

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6. REVIEW RESULTS FOR DAVIS-BESSE UNIT 1 ...........................

6 6.1 Evaluation ................................................

6 6.2 Conclusion ................................................

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7. REVIEW RESULTS FOR OCONEE UNITS 1, 2 AND 3 ......................

7 7.1 Evaluation ................................................

7 7.2 Conclusion ................................................

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8. REVIEW RESULTS F OR R ANCHO SEC0 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

8 8.1 Evaluation ................................................

8 8.2 Conclusion ................................................

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9. REVIEW RESULTS FOR THREE MILE ISLAND UNIT 1 .....................

9 9.1 Evaluation ................................................

9 9.2 Conclusion ................................................

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10. REVIEW RESULTS FOR WNP 1 ........................................

10 10.1 Evaluation ................................................

10 10.2 Conclusion ................................................

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11. GROUP CONCLUSION ................................................ 11 j 12  !

12. REFERENCES ...................................................... .

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CONFORMANCE TO GENERIC LETTER 83-28 ITEM 4.4 ARKANSAS NUCLEAR ONE. UNIT 1 CRYSTAL RIVER UNIT 3 DAVIS-BESSE UNIT 1 OCONEE UNITS 1. 2 AND 3 RANCHO SECO THREE MILE ISLAND UNIT 1 WNP 1

1. INTRODUCTION I

On July 8, 1983. Generic Letter 83-28 was issued by D. G. Eisenhut, Director of the Division of Licensing, Nuclear Reactor Regulation, to all licensees of operating reactors, applicants for operating licenses, and .-

holders of construction permits. This letter included required actions based on generic implications of the Salem ATWS events. These requirements have been published in Volume 2 of NUREG-1000, " Generic Implications of ATWS Events at the Salem Nuclear Power Plant."

This report documents the EG&G Idaho, Inc. review of the submittals from Arkansas Nuclear One, Unit 1, Crystal River Unit 3, Davis-Besse Unit 1, Oconee Units 1, 2 and 3, Rancho Seco, Three Mile Island Unit 1 and WNP 1 for conformance to Item 4.4 of Generic Letter 83-28. The submittals from the licensees utilized in these evaluations are referenced in Section 12 of this report.

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,. 2. REVIEW REQUIREMENTS Item 4.4 (Reactor Trip System Reliability - Improvements in Maintenance and Test Procedures for B&W Plants) requires licensees and applicants with B&W reactors to apply safety-related saintenance and test procedures to the diverse reactor trip feature provided by interrupting power to control rods through the silicon controlled rectifiers (SCRs).

The Item does not require any hardware changes nor additional environmental or seismic qualification of these components, but it does require inclusion of safety related maintenance and test procedures for the SCRs in the appropriate surveillance and test sections of the Technical Specifications.

Responses from the included B&W plants were evaluated against a minimum description of how safety related maintenance and test procedures can be applied to the SCRs in the Control Rod Drive Control System. Each  ?

response should:

1. Confirm that the required action has been implemented.

2. Include a brief description of the safety related procedures used l to conduct periodic surveillance, testing and maintenance of the l SCR diverse reactor trip feature, that includes degating the SCRs

! and verifies that they have opened the power supply circuit to j the control rod drive holding coils.

3. Confirm that Technical Specification changes which include requirements for safety related surveillance and tests of the SCRs to be performed at intervals commensurate with existing test intervals for other safety related portions of the reactpr trip system are submitted to the NRC, or verify that these requirements are included in the existing plant Technical i Specifications.

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3. GROUP REVIEW RESULTS The relevant submittals from each of the BW reactor plants were reviewed to determine compliance with Item 4.4. First, the submittals from each plant were reviewed to establish that Item 4.4 was specifically addressed. Second, the submittals were evaluated to determine the extent to which each of the BW plants complies with the staff guidelines for Item 4.4.

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4. REVIEW RESULTS FOR ARKANSAS NUCLEAR ONE, UNIT 1 4.1 Evaluation Arkansas Power and Light Company (AP&L), the license for Arkansas Nuclear One, provided their response to Item 4.4 of the Generic Letter in submittals dated November 5, 1983, and April 24, 1985. In the first response, the licensee states that AP&L supports the B&W Owners Group generic guidelines for SCRs, is evaluating those guidelines and will incorporate those guidelines into procedures "as applicable." That response also states that the safety related Reactor Protection System channel functional test provides for monthly testing of the SCRs with the exception of verification of actual degating. Their response of April 24, 1985, states that testing of the SCRs is conducted using safety related test procedures; verification of degating of the SCRs was added to the  ;

procedures and the test procedures now meet the B&W guidelines.

4.2 Conclusion 4

The licensee's submittals confirm implementation of Item 4.4 of the Generic Letter: testing of the SCRs is conducted using safety related procedures, verification of degating of the SCRs is included in those procedures, and the procedures comply with the BWOG guidelines for this testing. The staff finds this acceptable.

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5. REVIEW RESULTS FOR CRYSTAL RIVER UNIT 3 5.1 Evaluation Florida Power Corporation (FPC), the licensee for Crystal River Unit 3, provided responses to Item 4.4 of the Generic Letter on In those responses November 4, 1983, January 16, 1984, and July 31, 1984.

FPC confirmed implementation of Item 4.4, identified the Crystal River i Surveil. lance and Maintenance procedures and requested an amendment to the Crystal River Technical Specifications to explicitly include SCR operability and SCR degating.

5.2 Conclusion The licensee submittal confirms implementation of Item 4.4 of the Generic Letter, complete with verification of SCR degating. The staff finds that this is acceptable.

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6. REVIEW RESULTS FOR DAVIS-BESSE UNIT 1 6.1 Evaluation Toledo Edison, the licensee for Davis-Besse Unit 1, responded to Item 4.4 of the Generic Letter on December 9, 1983, and on July 9, 1985.

The latter response states that Davis-Besse 1 has installed the capability to test the ability of the SCRs to trip the reactor, and that he does intend to apply safety related maintenance and test procedures to the SCRs.

6.2 Conclusion The licensee submittal comfirms implementation of Item 4.4 of the Generic Letter. We have reviewed information describing the testing of the SCR trip feature that is classified as safety related and that includes  ;

verification that the SCRs degate and interrupt power to their holding coils. The staff finds this acceptable.

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7. REVIEW RESULTS FOR OCONEE UNITS 1, 2 AND 3 7.1 Evaluation Duke Power Company, the licensee for Oconee units 1, 2 and 3, responded to Item 4.4 of the Generic Letter on November 4, 1983, and August 9, 1985. In those responses, the licensee concurs with the contents of the B&W Owners Group position. The responses also confirm that surveillance and maintenance of the SCRs will be performed under procedures which comply with all requirements of safety related procedures, and state that the surveillance test will be revised to include adequate dotamentation of verification that the SCRs have appropriately responded to a RPS signal.

7.2 Conclusion The licensee's response does confirm that the procedures used for maintenance and testing of the SCR trip feature comply with all the requirements of safety related procedures, that the testing of the SCRs is included in Technical Specifications, and that the testing will verify that the SCRs respond to a trip signal. The staff finds that this is acceptable.

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8. REVIEW RESULTS FOR RANCHO SEC0 8.1 Evaluation Sacramento Municipal Utility District (SMUD), the licensee for Rancho Seco, provided a response to Item 4.4 of the Generic Letter on November 4, 1983. That response states that SMUD has satisfactorily tested the SCRs using the test procedure prepared by B&W for the B&W Owners Group, and that the SCR test procedure will be incorporated into the monthly Reactor Protection System instrument test procedure. The response did not include the test procedure prepared by B&W, nor did it include a description of the procedure. We have reviewed the BWOG proposed test procedure which provides for the verification of degating of the SCRs by noting a decrease in output current of the affected power supply.

8.2 Conclusion The licensee response does confirm that the B&W Owners Group recommended test procedures will be used for testing the SCRs and will be incorporated in the RPS monthly test procedure. The staff finds that this

! is acceptable.

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. 9. REVIEW RESULTS FOR THREE MILE ISLAND UNIT 1 l

9.1 Evaluation I

GPU Nuclear Corporation, the licensee for Three Mile Island Unit 1 (TMI-1), responded to Item 4.4 of the Generic Letter on November 8, 1983.

That response states that the SCRs are classified as Nuclear Safety Related at TMI-1, and that, while the trip function of the SCRs was not previously verified, the Reactor Protection System test procedure has been revised to include confirmation of the trip function by verifying a reduction in current from the affected power supply. Administrative Technical Specification changes were submitted to provide explicit inclusion of the SCRs on September 30 and October 9, 1985.

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The licensee's response does confirm that the SCR trip feature'is safety related and that procedures would be revised to confirm that the

! SCRs will open the holding coil circuit when degated. Review of the licensee's safety related procedure confirms that his test procedure includes verification of degating of the SCRs. The staff finds this acceptable.

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10. REVIEW RESULTS FOR WNP 1 10.1 Evaluation Washington Public Power Supply System, the applicant for WNP 1, responded to Item 4.4 of the Generic Letter on March 30, 1984. The response states that the applicant intends to apply safety related maintenance and test procedures to the SCRs.

't 10.2 Conclusion The applicant submittal comfirms implementation of Item 4.4 of the Generic Letter. However, the licensee's submittal does not include a description of the procedures used. It is evident that the concern of Item 4.4 of Generic Letter 83-28 will be resolved on an industry-wide basis ;

prior to completion of the technical specifications for WNP-1 and will be resolved for this plant during the review and approval process of its technical specifications. Therefore, the staff considers this Item to be closed for this evaluation.

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11. GROUP CONCLUSION The staff concludes that the licensee responses for Item 4.4 of Generic Letter 83-28 are acceptable.

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12. REFERENCES

1. NRC Letter, D. G. Eisenhut to all licensees of Operating Reactors, .

Applicants for Operating License, and Holders of Construction Permits,  ;

" Required Actions Based on Generic Implicationsof Salem ATWS Events l (Generic letter 83-28)," July 8, 1983. '

2. Generic Implications of ATWS Events at the Salem Nuclear Power Plant NUREG-1000, Volume 1 April 1983; Volume 2, July 1983.

3. Arkansas Power and Light Company letter to NRC, J. Ted Enos to D. G. Eisenhut Director, Division of Licensing, NRC, "B&W Owners Group Response to Generic Letter 83-28," November 4, 1983.

4. Arkansas Power and Light Company letter to NRC, J. R. Marshall to D. G. Eisenhut, Director, Division of Licensing, NRC, " Arkansas 1 Nuclear One Response to Generic Letter 83-28," November 5, 1983.  !

5. Arkansas Power and Light Company letter to NRC, J. Ted Enos to Director of Nuclear Reactor Regulation, NRC, " Response to RFI - Items 4.4 and 4.5.3," April 24, 1985.

6. Florida Power Corporation letter to NRC, G. R. Westafer to D. G. Eisenhut, Direct)r, Division of Licensing, NRC, " Crystal River Unit 3 Response to Generic Letter 83-28," November 4, 1983.

7. Florida Power Corporation letter to NRC, G. R. Westafer to D. G. Eisenhut, Director, Division of Licensing, NRC, " Crystal River Unit 3 Technical Specification Change Request No. 111,"

January 16, 1984.

8. Florida Power Corporation letter to NRC, G. R. Westafer to D. G. Eisenhut, Director, Division of Licensing, NRC, " Crystal River Unit 3 Updated Response to Generic Letter 83-28," July 31, 1984.

9. Toledo Edison letter to NRC, R. P. Crouse to Director of Nuclear Reactor Regulation, NRC, December 9, 1983.

10. Toledo Edison letter to NRC, Joe Williams to Director of Nuclear Reactor Regulation, NRC, July 9, 1985.

11. Duke Power Company letter to NRC, H. 8. Tucker to H. R. Denton, Director, Office of Nuclear Reactor Regulation, November 4, 1983.

12. Duke Power Company letter to NRC, H. 8. Tucker to H. R. Denton, Director, Office of Nuclear Reactor Regulation, August 9, 1985.

13. Sacramento Municipal Utility District letter to NRC, R. J. Rodriquez to D. G. Eisenhut, Director, Division of Licensing, NRC, " Required Actions Based on Generic Implications of Salem ATWS Events (Generic Letter 83-28)," November 4, 1983.

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14. GPU Nuclear Corporation letter to NRC, H. D. Hukill to D. G. Eisenhut, Director, Division of Licensing, NPC, " Required Actions Based on Generic Implications of Salem /ATWS Events," November 8, 1983.

15. Washington Public Power Supply System letter to NRC, G. C. Sorenson'to Director of Nuclear Reactor Regulation, " Nuclear Project No. 1 Response to Generic Letter 83-28, Salem ATWS Event," March 30, 1984.

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