ML17277B465

Requests Confirmation of CRGR Review Re Specific Uncertainties Conservatively Treated in GE Instrument Setpoint Methodology for Bwrs.Concern Should Be Treated as Generic

ML17277B465
Person / Time
Site:	Columbia
Issue date:	08/02/1984
From:	Sorensen G WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	Schwencer A Office of Nuclear Reactor Regulation
References
GO2-84-445, TAC-55579, NUDOCS 8408070333
Download: ML17277B465 (8)

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~a REGULATVR) INFORMATION DISTRIBUTION S 'TEt< (RIDS)

NBR:8408070333 DOC DATE: 89/08/02

~ NOTARIZED; NO 'CCESSION DOCKET FACIL:50-397 NPPSS Nuclear Project< Unit ?i Nashin'gton Public Powe 05000397 AUTH, NAME AUTHOR AFFILIATION SORENSEN,G AC, Nashington Public Power Supply System RECIP NAME RECIPIENT AFFILIATION SCHNENCERgA ~ Licensing Branch 2 SUBJECT; Requests confirmation of CRGR review re -specific uncertainties conservatively treated in GE instrument setpoint methodology for BNRs,Concern should be treated as generic.

DISTRIBUTION CODE: A001S COPIES RECEIVED:LTR ENCL SIZE:

TITLE; OR Submittal: General Distribution 05000397 NOTES'L:12/20/83 RECIP IENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL NRR LB2 BC Ol 7 7 INTERNAL: ADM-LFMB 1 0 ELD/HDS2 1 0 NRR/DE/MTEB 1 1 NRR/DL DIR 1 1 NRR/DL/ORAB 1 0 NRR/DS I/METB 1 1 NRR/DS I/RAB 1 G 04 1 . 1 RGNS 1 1 EXTERNAL: ACRS 09 6 6 LPDR 03 1 1 NRC PDR 02 1 1 NSIC 05 1' NTIS 1 1 TOTAL NUMBER OF COPIES REQUIRED: LTTR 26 ENCL. 23

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Washington Public Power Supply System P.O. Box 968 3000 George Washington Way Richland, Washington 99352 (509) 372-5000 8408070333 840802 PDR ADOCK 05000397 August 2, 1984 P PDR G02-84-445 Docket No. 50-397 Director of Nuclear Reactor Regulation Attention: Mr. A. Schwencer, Chief Licensing Branch No. 2 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

NUCLEAR PLANT NO. 2 REQUEST FOR CONFIRMATION OF CRGR REVIEW

Reference:

Letter, T. M. Novak (NRC) to J. F. Carolan (PECO) with blind copy to Supply System Docket No. 50-397, "Transmittal of NRC Staff Report on Setpoint Methodology for GE Supplied Protection System Instrumentation", dated May 15, 1984 The reference letter:requested twelve utilities, constructing or operating Boiling Water Reactors, to provide additional confirmatory information to affirm that specific uncertainties have been conservatively treated in the General Electric instrument.setpoint methodology.

The Supply System objects to the manner in which this concern has been brought to the attention of the utilities addressed by the letter. In the latter part of 1982, various utilities received inquiries with regard to instrument setpoint methodology via several routes: formal Requests for Information addressed to a specific docket, informal copies of similar requests for-information, either provided by hand or telecopied to utility employees, approved licensing conditions addressed in staff Safety Evaluation'Reports or proposed licensing conditions.

A review of the inquiries to date and other documentation applicable to this concern readily, leads to the conclusion that the concern, as expressed by the staff,,is generic. It is the Supply System position that the issue is generic to.all utilities supplied protection system instrumentation by General. Electric and not restricted to the twelve utilities addressed by the reference.

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A. Schwencer Page Two A'ugust 2, 1984 REQUEST FOR CONFIRMATION OF CRGR REVIEW The Supply System has.been unable,to.confirm that this concern has received formal review by the'Committee to Review Generic Requirements (CRGR) and considers the methodology of implementation to date, to be contrary to the policies of the Nuclear Regulatory Commission and in particular the spirit, if not the letter, of the CRGR charter. As stated in revision I to the CRGR charter, the CRGR "has the responsibility to review and recommend to the Executive Director for Operations (EDO} approval or disapproval of requirements to be imposed by the NRC staff on one or more classes of power reactors". Additionally, the CRGR is charged to develop controls to "make sure that requirements in place or to be issued (a} do 'in fact contribute effectively and significantly to the health and safety of the public, and (b) do lead to utilization of both NRC and licensee resources in as optimal a fashion as possible in the overall achievement of protection of public health and safety". The Supply System can not confirm that this concern has been subject to these controls.

The referenced letter states that "the staff considers the Technical Speci-fications for instrument channel setpoint allowable values for licensed GE/BWR plants (and those specifications in preparation for NTOL plants in the licensing review process}, established based on the GE setpoint method-ology developed to date, to.be sufficiently conservative to permi t continued licensing of the NTOL plants and operation of licensed plants until this issue is resolved . . .". This statement confirms the generic applicability of this concern". Additionally the perceived method of implementing this concern on the twelve utilities in question without appropriate CRGR review casts doubt that the concern has -indeed had appropriate analysis. Also no verification exists that implementation of the concern will affect an effective and significant contribution to the health and safety of the public. Based on the significant costs, presented by the NSSS supplier to the utilities in question for obtaining the requested information, without CRGR review it evident that the staff has evaluated the burden placed on the utilities nor the is not consequences on the public, supporting those utilities.

Accordingly, the Supply System requests that confirmation of the CRGR review of this concern, with the attendant information package described in the CRGR charter, be provided. .Additionally, there is no clear indication that this request to over.ten utilities has received an Office of Management and Budget approval per public law: Paper Work Reduction Act of 1980, PL 96-511.

Should you have any questions regarding this request, please contact Mr.

P. L. Powell, Manager, WNP.-2 Licens,ing.

Very truly yours, G. C. Sorensen, Manager Regulatory Programs PLP/tmh cc: R Auluck - NRC WS Chin - BPA AD Toth - NRC Site V Stello - NRC R Grunseich - LILCO

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0 Mr. Pat Powell Mr. Dale Holtzscher WPPSS Illinois Power Co.

P. 0 ~ Box 968 500 S. 27th Street Mail Drop 956B Mail Code F-33 Richland, WA 99352 Decatur, IL 62525 Mr. Al Wegele Ms. Eileen Buzzelli Detroit Edison Co. Cleveland Electric Ilium. Co.

6400 N Dixie Highway

~ P.O. Box 84 Mail Drop 346 NOC Rm. Py-R 230 Newport, MI 48166 Perry, Ohio 44081 Mr. Neil Coddington Mr. John Price Pennsylvania Power 5 Light Co. Gulf States Utilities Two North Ninth Street P.O. Box 2951 All entown, PA 18101 Beaumont, TX 77704 Mr. John Morin Mr. Gerald Tenenbaum Long Island Lighting Co. Public Service Electric 5 Gas Shoreham Nuclear Power Station 80 Park Plaza P.O. Box 618 T-21' Wading River, NY 11792 Newark, NJ 07101 Mr. Charles Schroeder Hr. Tony Zallnick Commonwealth Edison Co. Niagara Mohawk Power Corp.

P.O. Box 767 300 Erie Boulevard, West One First National Plaza Syracuse, NY 13202 Chicago, IL 6069Q Hr. John Fowler Hr. Dave Foreman Mississippi Power 5 Light,Co. General Electric Co P.O. Box 1640 175 Curtner Avenue Jackson, MS 39205 Hail Drop 682 San Jose, CA 95125 Hr. Roger Boyd Hr. T. E. Tipton KNC, Inc. Atomic Industrial Forum, Inc.

801 18th Street, NW 7101 Wisconsin Avenue Suite 300 Washington, p.C. 20014 Washington, D.C. 20006

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