ML20212G947
| ML20212G947 | |
| Person / Time | |
|---|---|
| Issue date: | 11/04/1997 |
| From: | Beckner W NRC (Affiliation Not Assigned) |
| To: | Jennifer Davis NUCLEAR ENERGY INSTITUTE (FORMERLY NUCLEAR MGMT & |
| References | |
| NUDOCS 9711070225 | |
| Download: ML20212G947 (5) | |
Text
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November 4, 1997 Mr. James Davis Nuclear Energy Institute 1776 Eye Strcst, N. W.
Suite 300 Washington, DC 20006 2496
Dear Mr. Davis:
This is to inform you that disposition has been made on three pro 90 sed changes to the Standard Technical Specification NUREGs made by the NEl Te,:hnical Specification Task ,
Force (TSTF). Disposition for TSTF-037, Rev.1, is to modify; TSTF 088 was withdrawn by I the NEl TSTF; and TSTF 091, Rev.1, is rejected). The disposition summary for TSTF 037, Rev.1 and TSTF-091, Rev.1 is enclosed.
With regard to the first paragraph of the summary for traveler TSTF 091, Rev.1, relative to undervoltage relays being set too high, we note that the Westinghouse ISTS section 3.3.5 does not have upper limits on tl4e loss of voltage and degraded voltage relay set: .. This surveillance is not consistent with the other owner's group ISTSs and does not ensure operabilit/ of the offsite and onsite power sources in accordance with the req,irements of 10 CFR 50.36(c)(3). Without an upper limit on the voltage setpoints of the uMervoltage relays, the relays could separate the offsite system from the safety equipment 'endering it inoperable when it is still capable of performing its safety function. Without an upper limit on the time delay setpoints of the undervoltage relays, the ralays can fail to separate safety equipment from the offsite power source before the equipment is lost or damaged. This effectively renders the offsite an f onsite power sources inoperable. Wo therefore request that a line item improvement be issued to Westinehouse'ISTS section 3.3.5 to add upper limits to the voltage and time delay setpoints of the loss of voltage and degraded voltage relays.
Please contact me at (301) 415-1161 or e-mail wdb@nrc. gov if you have any questions or need further information on these dispositions.
Sinceruly, Orl2i nal Signed By William D. Beckner, Chief
, Technical Specifications Branch 9711070225 971104 Associate Director for Projects REVGP ER C Office of Nuclear Reactor Regulation PDR
Enclosure:
As stated cc: see next page
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NUCLEAR REGULATORY COMMISSION 4E WASHINGTON. 9 C. 3066H001 November 4, 1997 Mr. James Davis Nuclear Energy Institute 1776 Eye Street, N. W.
Suite 300 Washington, DC 20006 2496
Dear Mr. Davis:
This is to inform you that disposition has been made on three proposed changes to the Standard Technical Specification NUREGs made by the NEl Technical Specification Task Force (TSTF). Disposition for TSTF-037, Rev.1, is to modify; TSTF-088 was withdrawn by the NEl TSTF; and TSTF-091, Rev.1, is rejected). The disposition summary for TSTF 037, Rev.1 and TSTF-091, Rev.1 is enclor,ad.
With regard to the first paragraph of the summary for trav:'er TSTF-091, Rev.1, relative to undervoltage relays being set too high, we note that the Westinghoure ISTS section 3.3.5 does not have upper limits on the loss of voltage and degraded voltage relay setpoints. This surveillance is not consistent with the other owner's group ISTSs and t.oes not ensure operabili+y of the offsite and onsite power sources in accordance with the requirements of 10 CFR 50.36(c)(3). Without an upper limit on the voltage setpoints of the undervoltage relays, the relays could separate the offsite system from the safety equipment rendering it inoperable when it is still capable of performing its safety fonction Without an upper limit on the time delay setpoints of the undervoltage relays, the ralays can fail to separate safety equipment from the offsite power source before the equir, ment is lost or damaged. This effectively renders the offsite and onsite power sources inoperable. We therefore request that a line item improvement be issued to Westinghouse Brid section 3.3.5 to add upper limits to the voltage and time delay setpoints of the loss of voltage and degraded voltage relays.
Please contact me at (301) 415-1161 or e mail wdb@nrc. gov if you have any questions or need further information on thase dispositions.
Sincerely, g .: b. & W William D. Beckner, Chief Technical Specifications Branch Associate Director for Projects Sifice of Nuclear Reactor Regulation
Enclosure:
As stated cc: see next page 1 l
t Mr. James Davis . 2-November 4, 1997 cc: D. Hoffman, EXCEL L. Bush, WOG J. Volkoff. CEOG -
B. Ford, BWROG C. Szabo, BWOG D. Wuokko, BWOG i s
4 -
t
DISPOSITION
SUMMARY
TSTF-037. R.1: Modifv The change is acceptable in concept. However, some modifications are required. The modifications are as follows:
(1) The justification addresses GL 94 01. This GL providad an incentive to implement the Maintenance Rule prior to 7/96. The incentive was the allowance to delete EDG accelerated testing and reporting requirements. However, the mandatory date for implementatior of the Maintenance Rule has passed, and incentives for early implementation are moot. Therefore, GL 94-01 is also Moot.
The justification for this generic change should address why accelerated tetting is not required in stand alone terms, and not GL 94-01. The justification specifics should include, as applicable, RG 1.9 Rev. 3, the Maintenance Rule, RG 1.160, NUMARC 93-01, etc. The justification should be adequate for use by alllicensees in justifying deletion of accelerated testing.
(2) The Bases should be revised similar to what follows:
BWOG. SR 3.8.1.2 and SR 3.8.1.7 (conMr' $
"The 31 day frequency for (SR 3.8.1.2] and 184 day frequency for (SR 3.8.1.71 are e
consistent with Positions C.2.3.2, C.2.3.2.1, and C.2.3.2.2 of R.gulatory Guide 1.9, Rev. 3, dated July 1993. These frequencies provide adequate assurance of EDG OPERABILITY while minimizing degradation from testing. In the event of an EDG
- failure, additional activities necessary to reestablish OPERABILITY (or reliability),
including testing, will be covered by ths EDG maintenance program developed and implemented in accoroance with 10 CFN 50.65 and associated documents."
and BWOG. SR 3.8.1.3 "The 31 day 'equency for [SR 3.8.1.3) is consistent with Positions C.2.3.2 and C.2.3.2.1 of Regulatory Guide 1.9, Rev. 3, dated July 1993. This frequency provides adequate assurance of EDG OPERABILITY while minimizing degradation from testing. In the event of an DG failure, additional activities necessary to reestablish OPERABILITY (or reliability), including testing, will be covered by the EDG maintenance program developed and implemented in accordance with 10 CFR 50.65 and associated documents."
b 2
TRTF.91. R.1
- mpe=A An offsite and onsite power system are required by GDC 17, and they meet the criteria of Criterion 3 in 10 CFR 50.36(c)(2)(ii) to be included in the Technical Specifications. Properly set loss of voltage and degraded voltage relays are necessary to maintain operability of these power systems. During normal operation the ofisite power system functions as essentially a single power source to all plant safety loads. Loss or degradation of this power source without properly set loss of voltage or degraded voltage relay setpoints cou3 result in the inability to automatically disconnect the offsite power system and transfer the safety loads to the onsite prwer system before loss er damage of redundant safety loads occurs. This effectively mr.kes both the offsite and onsite power sources ur$available to safety equipment. Loss of voltage or degraded voltago relays that are set too high could result in separation of redundant safety equipment from the 'ffsite power system, even though it is capable of performing its safety function of powering the safety loads. This renders the offsite system inoperable. Properly set relays are therefore required to ensure the operability of the offsite and onsite power sources, and as such the relays and their
, setpoints must be included in the technical specifications as required by 10 CFR 50.36(c)W to ensure the powei cource LCOs are met.
It is noted that the degraded voltsge relays are also required to be included in technical specifications under the requirements of Criterion 4 of 10 CFR 50.36(c)(2)(ii) on the basis of oparating experience. As the result of events that occurred at Millstone Nuclear Power Station the staff issued a generic letter to all LWR licensees in June,1977, as part of multiplant action MPA 23, stating its position that all licensee facilities must have degraded i voltage relays. That letter also' required that certsin technical specifications, which included the degraded voltage relays and their setpoints, be incorporated into all the facility-operating licenses. This is consistent with the position that the relay setpoints are necessary to ensure that the relay LCO, and thereby the offsite and onsite power LCOs, are met under the esquirements of 10 CFR 50.36(c)(3).
Our experience with these relay setpoints does not provide confidence that licensees will-maintain adequate setpoint values if they are removed from their ter,hnical spe::ifications.
Even under the current program requiring theae setpoints be included in technical specifications, plant inspections have identified numerous instances of inadequate .setpoint values. Several plants continue to operate under interim procedures while they attempt to -
address these deficiencies. The most recent information notices issued on these problems I include IN 95 37, IN 93 99, IN 91-29, and IN 9129 supplement 1.
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