ML20211E964
| ML20211E964 | |
| Person / Time | |
|---|---|
| Site: | Indian Point, Wolf Creek, Byron, Braidwood, Callaway, 05000000, Trojan |
| Issue date: | 10/31/1986 |
| From: | Haroldson R, Vanderbeek R EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY |
| To: | NRC |
| Shared Package | |
| ML20209D174 | List: |
| References | |
| CON-FIN-D-6001, CON-FIN-D-6002 EGG-EA-7035, EGG-EA-7035-R03, EGG-EA-7035-R3, GL-83-28, NUDOCS 8610300062 | |
| Download: ML20211E964 (38) | |
Text
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i EGG-EA-7035 l
Revision 3 October 1986 INFORMAL REPORT
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/daho CONFORMANCE TO GENERIC LETTER 83-28 ITEf1S 3.1.3 National AND 3.2.3, BRAIDWOOD, UNITS NOS. 1 AND 2, BYRON STATION, UNIT NOS. 1 AND 2, CALLAWAY PLANT, ng neering UNIT NO. 1, INDIAN POINT, UNIT N0. 3, TROJAN Laboratory NUCLEAR PLANT, AND WOLF CREEK GENERATING STATION Managed by the U.S.
R. VanderBeek Department R. Haroldsen ofEnergy 4
0 Prepared for the
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"*aa U. S. NUCLEAR REGULATORY COMMISSION Work performed under No DE-AC07 761 15 k"N PR!3 mum! NARY i
This document was prepared primarily for preliminary or internal use.
It has not received full review and approval.
Since there may be substantive changes, this document should not be considered final.
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EGG-EA-7035 Revision 3 CONFORMANCE TO GENERIC LETTER 83-28 ITEM 3.1.3 AND 3.2.3 BRAIDWOOD, UNIT NOS., 1 AND 2 BYRON STATION, UNIT NOS. 1 AND 2, CALLAWAY PLANT, UNIT NO. 1 INDIAN POINT, UNIT N0. 3, TROJAN NULCEAR PLANT, WOLF CREEK GENERATING STATION R. VanderBeek R. Haroldsen Published October 1986 EG&G Idaho, Inc.
l Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Under DOE Contract No. DE-AC07-76ID01570 FIN No. D6001 and D6002 j
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4 ABSTRACT This EG&G Idaho, Inc. report provides a review of the submittals for several nuclear plants for conformance to Generic Letter 83-28, Item 3.1.3 and 3.2.3.
The specific plants selected were reviewed as a group because of similarity in type and applicability of the review items.
The group includes the following plants:
Plant Docket Number TAC Numbers Braidwood 1 50-456 Braidwood 2 50-457 Byron 1 50-454 56279,56281 8yron 2 50-455 Callaway 1 50-483 55193,55203 Indian Point 3 50-286 53009,53847 I
Trojan 50-344 53052,53891 Wolf Creek 50-482 57383,57381 FOREWORD This report is supplied 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.
4 The U.S. Nuclear Regulatory Commission funded the work under the authorization, B&R Nos. 20-19-10-11-3 and 20-19-40-41-3, FIN Nos. D6001 and 06002.
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CONTENTS ABSTRACT..............................................................
11 FOREWORD..............................................................
11 1.
INTRODUCTION.....................................................
1 2.
REVIEW REQUIREMENTS..............................................
3 3.
GROUP REVIEW RESULTS.............................................
4 4.
REVIEW RESULTS FOR BRAIDWOOD UNIT NOS. 1 AND 2...................
6 4.1 Evaluation.................................................
6 l
4.2 Conclusion.................................................
6 5.
REVIEW RESULTS FOR BYRON STATION UNIT NOS. 1 AND 2...............
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1 5.1 Evaluation.................................................
7 5.2 Conclusion.................................................
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6.
REVIEW RESULTS FOR CALLAWAY PLANT UNIT NO. 1.....................
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6.1 Evaluation.................................................
8 i
6.2 Conclusion.................................................
8 7.
REVIEW RESULTS FOR INDIAN POINT UNIT NO. 3.......................
9 7.1 Evaluation.................................................
9 7.2 Conclusion.................................................
9 8.
REVIEW RESULTS FOR TROJAN NULCEAR PLANT..........................
10 8.1 Evaluation.................................................
10 2
8.2 Conclusion.................................................
10 9.
REVIEW RESULTS FOR WOLF CREEK GENERATING STATION.................
11 l
9.1 Evaluation.................................................
11 9.2 Conclusion.................................................
11 3
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- 10. GROUP CONCLUSIONS................................................
12 11.
REFERENCES....................................................,...
13 TABLES Table 1...............................................................
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CONFORMANCE TO GENERIC LETTER 83-28 ITEM 3.1.3 AND 3.2.3 BRAIDWOOD. UNIT NOS.
1 AND 2. BYRON STATION, UNIT NOS. 1 AND 2. CALLAWAY PLANT, UNIT NO. 1.
INDIAN POINT, UNIT NO. 3. TROJAN NULCEAR PLANT.
WOLF CREEK GENERATING STATION 1.
INTRODUCTION On July 8, 1983, Generic letter No. 83-28 was issued by D. G. Eisenhut, Director of the Division of Licenssing, 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 Braidwood, Unit Nos. 1 and 2 Byron Station, Unit Nos. 1, and 2, Callaway Plant, Unit No. 1, Indian Point, Unit No. 3, Trojan Nuclear Plant and Wolf Creek Generating Station, for conformance to items 3.1.3 and 3.2.3 of Generic Letter 83-28.
The submittals from the licensee utilized in these evaluations are referenced in Section 11 of this report.
These review results are applicable to the group of nuclear plants previously identified because of their similarity.
These plants are similar in the following respects.
1.
They are operating Westinghouse-PWR reactors 2.
They utilize the Dry Containment System 3.
They utilize two Class lE Power System Trains 1
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They-are four loop reactors.
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They use the Westinghouse Solid State Protection System r
An item of concern identified for any one of these plants is assumed to be potentially significant for all of the plants in the group, i
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REVIEW REQUIREMENTS Item 3.1.3 (Post-Maintenance Testing Reactor Trip System Components) requires licensees and applicants to identify, if applicable any post-maintenance test requirements for the Reactor Trip System (RTS) in existing technical specifications which can be demonstrated to degrade rather than enhance safety.
Item 3.2.3 extends this same requirement to include all other safety-related components. Any proposed technical specification changes resulting from this action shall receive a pre-implementation review by NRC.
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GROUP REVIEW RESULTS l
I The relevant submittals from each of the named reactor plants were i
reviewed to determine compliance with Items 3.1.3 and 3.2.3 of the Generic Letter.
First, the submittals from each plant were reviewed to determine j
that these two items were specifically addressed.
Second, the submittals l
were checked to determine if any post-maintenance test items specified by j
the technical specifications were identified that were suspected to degrade i
rather than enhance safety.
Last, the submittals were reviewed for 1
1 evidence of special conditions or other significant information relating to the two items of concern. The results of this review are summarized for l
each plant in Table 1.
t The responses from Braidwood, Unit Nos. 1 and 2. Byron Station Unit Nos.1 and 2 and Indian Point, Unit No. 3 indicated that there had been no items identified from the licensees' review of the technical specifications 4
relating to post-maintenance testing that could be demonstrated to degrade j
rather than enhance safety.
However, the licensee gave no insight on the depth of the review conducted on these two items.
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l The licensee's initial responses for Callaway Plant Unit No. 1, Trojan I
Nuclear Plant, and Wolf Creek Generating Station did not address the concerns about pu:t-naintenance test requirements raised by Item 3.1.3 and 3.2.3.
However, later sub.7.ittals corrected this deficiency for the l
Callaway and Wolf Creek Plants.
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TABLE 1.
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i Were Itesm 3.1.3 and 3.2.3 Addressed Responses Plants in the Submittal Licensee Findings Acceptable Comments i
Braidwood 1 Yes No tech spec. items Yes and 2 identified that r
degrade safety Byron 1 and 2 Yes No tech. spec. items Yes identified that degrade safety Callaway 1 Yes No post-maintenance Yes requirements a
identified that degrade safety Indian Point 3 Yes No tech. spec. items Yes identified that 1
degrade safety l
Trojan Yes No Concerns of Items 3.1.3 and 3.2.3 were not addressed..
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Wolf Creek Yes Yes i
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4.
REVIEW RESULTS FOR BRAIDWOOD, UNIT NOS. 1 AND 2 i
4.1 Evaluation Commonwealth Edison, the licensee for Braidwood, Unit Nos. 1 and 2, provided response to Item 3.1.3 and 3.2.3 of Generic Letter 83-28 on November 5, 1983.
At the time of the submittal the Braidwood Technical Specifications were in the developmental phase.
However, the licensee stated in the submittal that they were not aware of any requirements for testing reactor trip systems components or safety-related components in tneir proposed Technical Specification which would degrade safety.
4.2 Conclusion The licensee's statement meets the requirements of Item 3.1.3 and 3.2.3 Generic Letter 83-28 and is acceptable.
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REVIEW RESULTS FOR BYRON, UNIT NOS. 1 AND 2 5.1 Evaluation Commonwealth Edison, the licensee for Byron, Unit Nos. 1 and 2, f*
provided response to Item 3.1.3 and 3.2.3 of Generic Letter 83-28 on 3
November 5, 1983.
Within the responses, the licensee states that a review in conjunction with the NRC review of the current revision of the technical specifications for Unit Nos. I and 2 has not identified any I
requirements that will degrade rather than enhance safety.
5.2 Conclusion Based on the licensee's statement that they have reviewed their l
technical specification requirements to identify any post maintenance testing which could be demonstrated to degrade rather than enhance safety and found none that degraded safety, we find the licensae's responses acceptable.
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6.
REVIEW RESULTS FOR CALLAWAY PLANT, UNIT NOS 1 AND 2 4
6.1 Evaluation i
j Union Electric Company, the licensee for Callaway Plant, Unit Nos. 1 and 2, provided responses to Item 3.1.3 and 3.2.3 of Generic Letter 83-28 4
t on November 18, 1983.
Within the response, the licensee states that an i
NRC Task Force on Plant Technical Specification Surveillance Requirements has been recently chartered and represents the appropriate forum for 1
i addressing these sections.
The SNUPPS utilities are also actively involved in a Technical Specification Optimization Program (TOP).
This involvement and interface with the NRC task force will ensure that changes to the Technical Specifications are adequately addressed.
This response did not address the concerns about post-maintenance test requirements raised by j
these two items.
Following discussions with the NRC staff, the licensee submitted an additional response dated August 12, 1986.5 In this later response the licensee states that a review of the Technical Specification j
had not identified any post-maintenance test requirements that could degrade safety.
l 6.2 Conclusion j
Based on the licensee's submittals, we find that the licensee's j
response meets the requirements of Items 3.1.3 and 3.2.3 of Generic Letter 83-28 and is acceptable.
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REVIEW RESULTS FOR INDIAN POINT, UNIT N0. 3 7.1 Evaluation New York Power Authority, the licensee for Indian Point, Unit No. 3 provided responses to Item 3.1.3 and 3.2.3 of Generic Letter 83-28 on j
May 17, 1985.
For Item 3.1.3, the licensee states that to date no post-maintenance testing which would degrade safety has been identified.
Currently, the Authority is reviewing, for plant specific applicability, the NRC SER on WCAP-10271, Supplement 1, " Evaluation of Surveillance Frequencies and Out of Service Times for the Reactor Protection Instrumentation Systems."
For Item 3.2.3, the licensee states that the Authority found none and will continue to review and propose changes related to post-maintenance testing requirements when and if identified.
7.2 Conclusion i
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Based on results of review of test and maintenance programs which did
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not identify any post-maintenance testing that may degrade rather than enhance safety, we find the licensee's responses acceptable.
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REVIEW RESULTS FOR TROJAN NUCLEAR PLANT 2
8.1 Evaluation Portland General Electric (PGE) Company, the licensee for the Trojan Nuclear Plant, provided responses for Items 3.1.3 and 3.2.3 of Generic 4, 1983.7 Within the responses, the licensee Letter 83-28 on November states that no changes to Technical Specifications are being proposed at this time.
Portland General Electric (PGE) Company is participating in the l
Westinghouse Owners Group (WOG) program for reevaluation of Technical Specifications using the methodology in WCAP-10271, which was submitted to i
the NRC on February 3, 1983 and October 4, 1983.
PGE may request changes to the Trojan Technical Specifications based on the results of this i
program.
PGE supports the review of Technical Specifications initiated by the NRC Task Force.
The licensee states that there may be Technical l
Specification surveillance requirements which degrade rather than enhance j
safety, they have not qualified such effects at this time.
This response does not address the concerns about post-maintenance test requirements raided by these two items.
8.2 Conclusion i
The licensee shall review the post-maintenance testing requirements contained in the technical specifications for the reactor trip system and other safety related components and determine whether any such current post-maintenance requirements may degrade rather than enhance safety.
If any such current post-maintenance testing requirements are found, the licensee shall identify them and propose corrective Technical specification changes.
If no requirements are found to exist, then a statement to that effect should be submitted.
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REVIEW RESULTS FOR WOLF CREEK GENERATING STATION 9.1 Evaluation Kansas Gas and Electric Company (KG&E), the licensee for Wolf Creek Generating Station, provided an initial response for Items 3.1.3 and 3.2.3 of Generic Letter 83-28 in a submitted dated November 15, 1983.
The submittal stated that an NRC Task Force on Plant Technical Specifications Surveillance Requirements had been chartered and would provide the appropriate forum for addressing these items.
KG&E is also actively involved in the Westinghouse Owners' Group (WOG) Technical Specification 9
Optimization Program (TOP).
A later response dated October 3, 1986 stated that the licensee had reviewed the Wolf Creek Technical i
Specification concerning post-maintenance test requirements. One item (post-maintenance testing of the emergency desired generators) was identified which may be excessive and cause a reduction in the overall reliability of the systems.
The licensee has plans for proposing changes in the technical specification regarding this items through the normal licensing amendment process.
No other post-neintenance test requirements were identified in the technical specifications that were perceived to degrade safety.
9.2 Conclusion Based on our review of the licensee submittals we find that the licensee has reviewed the Wolf Creek technical specification and except for the emergency diesel generators has found no post-maintenance test requirements that are perceived to degrade safety.
The concern for post-maintenance testing of the emergency diesel generators will be considered under the guidance of Generic Letter 84-15 and consequently excluded from this review.
We, therefore find that the licensee's submittals meet the requirements of items 3.1.3 and 3.2.3 of Generic Letter 83-28 and are acceptable.
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GROUP CONCLUSION The licensee responses for Braidwood, Unit Nos., 1 and 2, Byron Station, Units No. I and 2, Callaway Indian Point, Unit No. 3 and Wolf Creek were found acceptable by the staff.
However, the staff found the licensee response for the Trojan Nuclear Plant unacceptable, i
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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 Implications of 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.
Commonwealth Edison letter to NRC, P. L. Barnes to H. R.
- iton, Director, Office of Nuclear Reactor Regulation, NRC, "Dr aen Station Units 2 and 3, Quad Cities Station Units 1 and 2, Zion Station Units 1 and 2, Lasalle County Station Units 1'and 2, Byron Station Units 1 and 2, Response to Generic Letter No. 83-28, NRC Docket Hos. 50-237/249, 50-254/265, 50-295/304, 50-374/374, 50-454/455,nand 50-456/457," November 5, 1983.
g 4.
Union Electric Company letter to NRC, D. F. Schnell to H. R. Denton, Director of Nuclear Reactor Regulation, NRC, " Docket No. 50-483, Union Electric Company, Callaway Plant Unit 1, Response to Generic Letter 83-28," November 18, 1983.
5.
Union Electric Company letter to NRC, D. F. Schnell to H. R. Denton, Director of Nuclear Reactor Regulation, NRC " Docket Number 50-483 Union Electric Company, Callaway Plant Generic Letter 83-28, Required Actions Based on Generic implications of Salem ATWS Events"
/
August 12, 1986.
6.
New York Power Authority letter to NRC, J. C. Brons to S. A. Varga, Chief, Operating Reactor Branch No. 1, Division of Licensing, NRC "
Indian Point 3 Nuclear Power Plant, Dctket No. 50-296, Additional Information Regarding Generic Letter 83-28, Required Actions Based on Generic Implications of the Salem ATWS Events," May 17, 1985, IPN-85-26.
7.
Portland General Electric letter to NRC, B. D. Withers to D. G. Eisenhut, Director, Division of Licensing, NRO, " Required actions Based on Generic Implications of Salem ATWS Ivents,(Generic Letter 83-28)," November 4, 1983.
8.
Kansas Gas and Electric Company letter to NRC, G. L. Koester to H. R. Denton, Director, Office of Nuclear Reactor Regulation, NRC,
" Response to Generic Letter 83-28," November 15, 1983.
9.
Kansas Gas and Electric Company Letter to NRC, G. L. Koester to H. R. Denton, Director of Nuclear Reactor Regulation, NRC, " Required Actions Based on Generic Implications of Salem ATWS Events,"
October 3, 1986.
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BIBUOGRAPHIC DATA SHEET EGG-EA-7035 Revision 3 ses i=stavetic=s c* e-e asvesse 3"^*""**
r.<u A~o ive"'" Conformance to Generic Letter 83-28 Items 3.1.3, and 3.2.3, Braiducod, Unit flos.1 and 2, Byron Station, Unit f!os. 1 and 2, Callawa Plant, Unit flo.1,
'*^"""'c**""o Indf an Point, Unit flo. 3, Trojan flu lear plant, and
'/o15 Creek Generatina Station l
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Idaho Falls, ID 83415 1 f. TV.S G8 8tPCRT
,10 SPONSQR*NG CMGami2 ATsCN Newt AND WAeLING AQOmtES umega.e te Case #
Division of Systems Integration Preliminary Technical Office of fluclear Reactor Regulation Evaluation Report U. S. fluclear Regulatory Conmission
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liashington, DC 20555 i
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,.. r..a,m This EG&G Idaho, Inc. report provides a review of the submittals for Braidwood Unit Nos. I and 2, Byron Station, Unit Nos. I and 2, Callaway Plant, Unit flo.1, Indian Point, Unit flo. 3, Trojan fluclear Plant, and Wolf Creek Generating Station for conformance to Generic Letter 83-28 Items 3.1.3 and 3.2.3.
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