ML20147G762

Summary of 880210 Meeting W/Util & NUS Co Re Reply to 880205 Request for Addl Info Re Modernization of Reactor Protection Sys.Addl Questions Resulting from Meeting & List of Attendees Encl

ML20147G762
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	03/01/1988
From:	Wang A Office of Nuclear Reactor Regulation
To:	Office of Nuclear Reactor Regulation
References
TAC-66948, NUDOCS 8803080310
Download: ML20147G762 (7)

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March 1,1988 Docket No. 50-713 LICENSEE:

Connecticut Yankee Atomic Power Company FACILITY:

Faddan Neck Plant r

SUMMARY

OF FEBRUARY 10, 1988 MEETING REGARDING MODERNIZATION OF THE REACTOR PROTECTION SYSTEM (TAC NO. 66948)

On February 10, 1988, the NRC met with Connecticut Yankee Atomic Power Company (CYAPCO) to discuss their reply to a February 5,1988 Request for Additional Information (RAI) regarding the Reactor Protection System (RPS). CYAPC0 stated their position that the RPS modifications can be made under the provisions of 10 CFP. 50.59 and do not require prior NRC approval. Additionally, CYAPC0 sees no reasons why the NRC review of their 10 CFR 50.59 report should affect the scheduled plant start-up.

The NRC staff stated that we will be reviewing on a generic basis if RPS modifications fall under the provisions of 10 CFR 50.59. The NRC staff stressed that the thrust of this meeting is our concerns regarding the adequacy of the plant design change record (PDCR) 861, as documented in our February 5,1988 RAI. As a general question the NRC staff asked to what design criteria (current or plant design basis) are nodifications made. CYAPCO replied that modifications made are to current design criteria as limited by the as-built plant design.

CYAPCO then described their responses to the RAT. The following are sore comments regarding CYAPCO's responses and NRC staff requests for additional information made during the meeting.

Question 1

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The NRC stated CYAPC0 should clarify the scope for PDCR 861 as there is r

overlapping of modifications and the NDC wants to limit this review to those modifications perforned in PDCR 861.

Question 2 I

The NRC agreed IEEE 384-1981 is more conservative than 197a, but the plant only needs to meet the 1974 version. CYAPC0 stated while the changes have improved the design, it still does not meet the 1974 criteria. CYAPCO is reviewing the possibility of further modifications which would bring this system into compliance with the 1974 Code.

Question 3 No comments, i

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Ou_estion 4 CYAPC0 stated that because one dedicated pressure level channel out of three is used for control and the protective action is based on 2/3 logic a potential control / protection interaction problem exir.s.

CYAPC0 using a deteministic analysis demonstrated that the consequences of this fault are acceptable.

Additionally, CYAPC0 believes a study has been done that reviewed this issue and fcund it to be acceptable.

The NRC asked for this report to be provided.

1 Ouestion 5 CYAPC0 stated they have verified that the response tire of the new equipment meets the respense times required by Chapter 15 of the UFSAR by at least a factor of two. The NRC requested CYAPC0 to provide a table with the Chapter 15 response times, old (if available) and new equipment response times, current respcnse tire test results for all components within each instrument channel affected by the design change.

Cuestion 6 No comments.

Question 7 The NRC stated we wculd prefer the monthly functional checks in the Technical Specifications.

Question 8 CYAPCO stated that their surveillance testing complies with R.G. 1.22 and 1.118.

Question 9 CYAPC0 stated Foxboro is currently preparing several reports which will address this question. The NRC requested CYAPCO to provide these reports as scen as they are available.

Question 10 The NRC expressed concern over the downgrading of the interlocks for the loop stcp valves from safety grade to control grade. CYAPC0 stated they improved the logic for the interlocks, but in the process could not upgrade the system to meet the single failure criteria.

CYAPCO states this condition is also true of the original design but the existence of the interlocks in cenjunction with administrative procedures and Technical Specifications keep the cen-sequences acceptably low. The NPC requested a copy of the adninistrative procedures for controlling operation of these valves.

In acdition, the staff also reeds CYAPCO to adtfress the enclosed questions, i

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Enclosed is CYAPCO's response to our February E,1988 RAI and the attendance list.

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t Alan B, Wang, Project Manager Project Directorate I-4 Division of Reactor Projects I/II i

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Enclosures:

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Mr. Edward J. Hroczka Connecticut Yankee Atomic Power Conpany Haddam Neck Plant cC' Gerald Garfield, Esquire R. M. Kacich, Manager Day, Eerry and Howard Generation Facilities Licensira Ccurselors at Law City Place Northeast Utilities Service Corpany Post Office Box 270 Hartford, Connecticut 06103-3499 Hartford, Connecticut 06141-C270 W. D. Rorberg, Vice President D. 0. Nordquist Director Nuclear Operations Quality Services Departrent Northeast Utilities Service Company Northeast Utilities Services Ccrpary Post Office Box 270 Post Office Box 270 Hartford, Connecticut 06141-0270 Hartford, Connecticut 06141-0270 Kevin McCarthy, Director Regional Administrator Radiation Control Unit Region I Department of Environmental Protection U. S. Nuclear Regulatory Conrission State Office Building 621 Park Avenue Hartford, Connecticut 06106 King of Prussia, Pennsylvania 19406 Bradford S. Chase, Under Secretary Board of Selectmer.

Energy Divisien Town Hall Office of Policy and Managenent Haddam, Connecticut 06103 80 Washington Street Hartford, Connecticut 06106 J. T. Shedlosky, Resider.t Inspector Haddar Neck Plant D. E. Miller, Station Superintendent Haddam Neck Plant c/o U. S. Nuclear Regulatory Comissier Post Office Box 116 RFD f 1 East Haddam Post Office Post Office Bcx 127E East Haddam, Connecticut 06423 East Hampton, Connecticut 06424 G. H. Bouchard, Unit Superintendent Haddam Neck Plant RFD / 1 Post Office Box 127E East Hampton, Connecticut 06424 i

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FEPPUARY.10, 19t,8 MEETING RPS UPGRArt t

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NAME COMPANY A. Wang NRC S. Newberry NRC J. Knox NRC J. Mauck NRC J. Joyce NRC F. Burrows NRC H. Balukjian NRC W. O'Hara NUSCO T. Shaffer NVSCO i

S. Vick NUSCO J. Kowalchuk NUSCO I

i M. Brothers NUSCO l

D. Ray CYAPC0 t

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ADDITIONAL QUESTIONS AS RESULT OF FEBRUARY 10, 1988 RPS MEETING 1.

Instrumentchannelaccuracy/safetysetpointcalculationsheets(similar to IC-CALC-87-007) for all reactor trip and engineered safety feature actuation functions affected by new instrumentation installed under PDCR 861.

2.

Justification / discussion of the calibration and drift errors utilized in IC-CALC-87-008 for Weed RTD's with a comparison to the values used by the licensee recently for Millstone 3 for an identical /similar RTD.

5.

Tables of response times for transmitters and rack have been provided.

Response time test procedures have also been provided which state that the total channel response time will be the sum of the individual components' response times that make up the channel.

It is not clear at this time whether the rock response times encompass all individual cerponents(excepttransmitters). A breakdown of all individual component res)onse times should be provided if the rack times do not account for tiese.

4.

Technical Specification 3.17.5 requires that indicated T should be d 542'F with a safety analysis limit of 544.1*F. AdisE8}lionof measurement uncertainties accounting for instrumentation uncertainties should be provided if affected by PDCR 861.

5.

During the February 10, 1988 meeting, we stated that a V&V audit would be conducted in the future. The licensee should be reminded that we are currently considering such an audit.

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