ML20215N688

Safety Evaluation Supporting Util Responses to Generic Ltr 83-28,Item 4.4 Re Improvements in Maint & Test Procedures for B&W Plants

ML20215N688
Person / Time
Site:	Rancho Seco
Issue date:	11/04/1986
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20215N676	List: ML20215N675 ML20215N688
References
GL-83-28, TAC-53958, NUDOCS 8611070161
Download: ML20215N688 (2)

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NUCLEAR REGULATORY COMMISSION g  : WASHINGTON, D. C. 20555

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO GENERIC LETTER 83-28, ITEM 4.4 .

IMPROVEMENTS IN MAINTENANCE AND TEST PROCEDURES FOR B&W PLANTS SACRAMENTO MUNICIPAL UTILITY DISTRICT RANCHO SEC0 NUCLEAR GENERATING STATION DOCKET NO. 50-312 INTRODUCTION AND

SUMMARY

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-Generic Letter 83-28 describes intermediate term actions to be taken by licensees and applicants to address the generic issues raised as a result of the staff's evaluation of the two ATWS events that occurred at Unit 1 of the Salem Nuclear Power Plant.

Item 4.4 of Generic Letter 83-28 required licensees and applicants to confirm that safety-related maintenance and test procedures are applied to the diverse reactor trip feature provided by interrupting power to the control rods throuah the silicon controlled rectifiers (SCRs). In addition, the test procedure should verify that the SCRs have degated, thereby removing power from the control rods and the SCRs should be included in the surveillance and test requirements sections of the Technical Specifications.

This report is an evaluation of the response submitted by Sacramento Municipal Utility District, the licensee for the Rancho Seco Nuclear Generating Station, for Item 4.4 of Generic Letter 83-28. The actual documents reviewed as part of this evaluation are listed in the references at the end of this report.-

EVALUATION ThelicenseefortheRanchoSecoNuclearGeneratingStationrespgndedtothe requirements of Item 4.4 with a submittal dated November 4. 1983 . The licensee confirmed in this submittal that safety-related procedures are being used to maintain and test the SCRs. The licensee further stated that the procedures used to test the SCRs verify that the SCPs under test have degated and opaned the power supply to the control rods. The licensee also stated that Technical Specification changes were being made that would include the SCRs in the maintenance and test requirements section of the Technical Specifications. The acceptability of these Technical Specification changes will be reported in the SE for Generic Letter 85-10 (Item 4.3-T.S.-MPA B-90).

CONCLUSION Based on our review of these responses, we find the licensee's statements confirm l that the SCRs are maintained and tested using safety-related procedures. The l testing will confirm the openino of the power supply to the control rods, and Technical Specification changes are being made to include the SCRs in the main-tenance and test requirements section of the Technical Specifications. These actions meet the requirements of Item 4.4 of Generic Letter 83-28 and are acceptable.

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2-REFERENCES

- 1. MRC Letter, D. G. Eisenhut to all Licensees of Operating Reactors, Applicants for Operating License, and Holders of Construction P4rmits,.

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

2. 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.

Principal Contributor:

D. Lasher Date: November 4, 1986 p

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EGG-NTA-7910 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 F. G. Farmer

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Published October, 1986 Idaho National Engineering Laboratory

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Idaho Falls, Idaho 83415

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-- Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C. 20555

? Under DOE Contract No. DE-AC07-761001570 FIN No. D6001 and D6002 ,

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l I 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:

l Plant Docket Number TAC Number Arkansas Nuclear One, Unit 1 50-313 53952 s Crystal River Unit 3 50-302 53953

! Oavis-Besse Unit 1 50-346 53954

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Oconee Unit 1 5'0-269 53955 Oconee Unit 2 50-270 53956 Oconee Unit 3 50-287 53957

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Rancho Seco 50-312 1 i 't 53958 Three Mile Island Unit 1 50-289 53959 WNP 1 50-460 N/A

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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. 06001 and 06002.

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e CONTENTS ABSTRACT ............................................................. 11 FOREWORD ............................................................. iii

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

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

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

4. REVIEW RESULTS FOR ARKANSAS NUCLEAR ONE, UNIT 1 ................. 4 4.1 Evaluation ................................................ 4 4.2 Conclusion ................................................ 4

5. REVIEW RESULTS FOR CRYSTAL RIVER UNIT 3 ......................... 5 5.1 Evaluation ................................................ . 5p 5.2 Conclusion ................................................. 5

6. REVIEW RESULTS FOR DAVIS-BESSE UNIT 1 ........................... 6 6.1 Evaluation ................................................ 6 6.2 Conclusion ................................................ 6

7. REVIEW RESULTS FOR OCONEE UNITS 1, 2 AND 3 ...................... 7' 7.1 Evaluation ................................................ 7 7.2 Conclusion ................................................ 7

8. REVIEW RESULTS FOR RANCHO SEC0~.................................. 8 8.1 Evaluation ................................................ 8 8.2 Conclusion ................................................ 8 i

l 9. REVIEW RESULTS FOR THREE MILE ISLAND UNIT 1 ..................... 9 l 9.1 Evaluation ................................................ 9 9.2 Conclusion ................................................ 9

10. REVIEW RESULTS FOR WNP 1 ........................................ 10 10.1 Evaluation ................................................ 10 10.2 Conclusion ................................................ 10 tii

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31. GROUP CONCLUSION *******************''

32. 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 r 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."2 (his report documents the EG&G Idaho, Inc. review of~the submittals from Arkansas Nuclear One, Ur:it 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 maintenance 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 I- to conduct periodic surveillance, testing and maintenance of the SCR diverse reactor trip-feature, that includes degating the SCRs and verifies that they have opened the power supply circuit to 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 reactor trip system are submitted to the NRC, or verify that these requirements are included in the existing plant Technical 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

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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 f0R 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 I response, the licensee states that AP&L supports the B&W Owners Group l 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 p procedures and the test procedures now meet the B&W guidelines.

4.2 Conclusion 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 November 4, 1983, January 16, 1984, and July 31, 1984. In those responses FPC confirmed implementation of Item 4.4, identified the Crystal River Surveillance 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 documentation of verification that the SCRs have appropriately responded to a RPS signal.

7.2 Conclusion

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The licensee's response does confirm that the procedures used for neintenance 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 SECO 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 l

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 9.1 Evaluation 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

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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.

9.2 Conclusion The licensee's response does confirm that the SCP 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.

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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4 11. GROUP CONCLUSION i

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' The staff concludes that the licensee responses for Item 4.4 of i

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' Generic Letter 83-28 are acceptable, i t

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12. REFERENCES i

1. NRC Letter, D. G. Eisenhut to all licensees of Operating Reactors, j Applicants for Operating License, and Holders of Construction Permits,

" Required Actions Based on Generic Implicationsof Salem ATWS Events (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 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, Director, 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. B. Tucker to H. R. Denton, Director, Office of Huclear Reactor Regulation, August 9, 1985.

13. Sacramento Municipal Utility District letter to NRC, R. J. Rodriguez 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, 1923.

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14 .' GPU Nuclear Corporation letter to NRC, H. D. Huktil to D. G. Eisenhut.

Director, Division of Licensing, NRC, " Required Actions Based on Generic Implications of Salem /ATWS Events," November 8, 1983.

15. Washington Public Power Supply System letter to NRC, G. C. Soren:on 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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