ML20215A782

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Sser Re Util Response to Generic Ltr 83-28,Item 4.3, Reactor Trip Breaker Automatic Shunt Trip. Licensee Should Submit Proposed Tech Specs Consistent W/Generic Ltr 85-09 Guidance for NRC Review.Salp Input Also Encl
ML20215A782
Person / Time
Site: Indian Point, Vogtle, 05000000
Issue date: 05/08/1986
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20213E629 List:
References
GL-83-28, GL-85-09, GL-85-9, NUDOCS 8612110397
Download: ML20215A782 (5)
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  • SUPPLEMENTAL SAFETY EVALUATION REPORT DOCKET NO. 50-247 INDIAN POINT UNIT 2 GENERIC LETTER 8E-28, ITEM 4.3 REACTOR TRIP BREAKER AUTOMATIC SHUNT TRIP INTRODUCTION AND

SUMMARY

Generic Letter 83-28 was issued by NRC on July 8[ 1983,' indicating actions to

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be taken by licensees b'ased on the generic implication of the Salem ATWS events.

Item 4.3 of the generic letter requires that modifications be made to improve the reliability of the reactor trip system by implementation of an automatic actuation of the shunt trip attachment on the reactor trip breakers. By letters dated November 4,1983, March 15,1984, April 2,1984 and June 22, 1984, the licensee,-Consolidated Edison of New York, Inc., provided responses to the plant specific questions identified by the staff in its August 10, 1983, Safety Evaluation Report on the generic proposed Westinghouse design. Subsequent to the review of the licensee's submittals, the staff issued a safety evaluation report on June 22, 1984 indicating the acceptable and unacceptable aspects of the licensee's responses and requested the licensee to further respond. By l 1etter dated February 14, 1986, the licensee submitted further responses re-garding the Technical Specifications and seismic qualification of the automatic

. shunt trip. We find the response to the seismic qualification issue to be ac-ceptable, but are unable to accept the responses to the Technical Specification issues.

EVALUATION The staff identified the following concerns in its safety evaluation report (SER) of June 22, 1984 and our evaluation of each is presented below.

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a)

The seismic qualification of: the shunt trip attachment is being conducted by the Westinghouse Owners Group (WOG). The licensee should confirm that'the shunt trip is seismically qualified when the results of the WOG qualification program are completed.

By letter of February 14, 1986, the licensee advised us that the seismic quali-fication of the reactor trip breaker shunt trip attachment (model 08-50) had been completed by Westinghouse, that the Indian Point 2 plant specific seismic parameters were enveloped by the Westinghouse test results, and that 10 CFR 50.49 does not apply because the equipment is located in a mild environment.

We find this acceptable.

b)

Following the implementation of the shunt trip modifications, the licensee should submit proposed technical specifications which are responsive to the staff requirements noted in the enclosed SER.

Subsequently, the staff issued Generic Letter 85-09 providing guidance for the Technical Specifications.

The licensee has declined to implement this guidance in the following respects M.

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1.

The bypass breaker testing would not be included in the Technical Specifications.

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y. Letter from John D. O'Toole to Mr. Steven A. Varga, February 14, 1986.

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. 2. The remaining surveillance test requirements would be administra-

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tively controlled on an interim basis without Technical Specifi-cation changes until the requirements can be optimally determined.

The above approach is unacceptable to the NRC staff. When a reactor trip breaker is tested, the reactor trip bypass breaker is put into service as a backup. The Generic Letter 85-09 Technical Specifications Guidance requires a manual test of the bypass breaker prior to putting it into service. This test-ing is a simple procedure and it is prudent to do this test before relying on .

this breaker as a backup to the remaining reactor trip breaker. The licensee states that probabilistic risk analyses (PRAs) show that testing of the break-er has an insignificant effect on the overall reliability. No claim is made that the reliability is decreased or that the bypas's breaker is not safety related. Therefore, we believe that this test should be made as specified in Generic Letter 85-09.

Secondly, the licensee does not plan to amend its Technical Specificatinns until the requirements can be optimally determined. No schedule is given for such a determination. This is unacceptable to the NRC staff. The licensee should amend its Technical Specifications consistent with the guidance and re-quirements of Generic Letters 83-28 and 85-09. If further changes are then required in the interest of optimizing safety, the staff will consider further amendment requests.

CONCLUSION Based on the above review, we find th'at the seismic qualification issue has been satisfactorily resolved. The licensee's position with respect to the Technical Specification issue is not acceptable. The licensee should submit proposed Technical Specifications consistent with Generic Letter 85-09 guidance for staff review.

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ENCLUbUMt 4

PLANT: Indian Point, Unit 2

SUBJECT:

Review of Additional Information on G.L. 83-28, Items 4.3 and 4.3 (T.

PERFORip.NCE BASIS EVALUATION CATEGORY CRITERIA .

N. A. No basis for assessment.

i no e ent . . .

The The response for Item 4.3 (seismic qualification) was canplete and l . Approach to 2

information provided in response to Item 4.3 (T.S.) (technical spe i Resolution of. responsive to the requirements of G.L. 85-09 and is unacceptable.

Technical issues i.

Responsiveness Licensee's infonnation on seismic qualification issue was respon 3

acceptable.

Infonnation on Technical specifications was not responsive to the requirenents of G.L. 85-09 which gave guidance on the issue and is he unaccontable hv the staff.

l. Enforcement N. A. No basis for assessment. .

llistory

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5. Reportable Events No basis for assessment.

N. A.

T' .

6. Staffing N. A. No basis for assessment.

N. A. No basis for assessment.

7. Training j ,
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