ML20238E604

Forwards Ltrs to Utils Documenting NRC Position Presented at 780802 Meeting & Requesting That STS Allowing Limited Reactor Protection Sys Channel Bypass Be Proposed

ML20238E604
Person / Time
Site:	Millstone, Calvert Cliffs, Palisades, Saint Lucie, Maine Yankee, Fort Calhoun, 05000000
Issue date:	09/15/1978
From:	Stello V Office of Nuclear Reactor Regulation
To:	Eisenhut D, Grimes B Office of Nuclear Reactor Regulation
Shared Package
ML20238E606	List: ML20238E604 ML20238E644 ML20238E652 ML20238E697 ML20238E702
References
TAC-7089, NUDOCS 8709150094
Download: ML20238E604 (4)

Text

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1. • % UNITED STATES g- . 4, NUCLEAR REGULATORY COMMISSION c:Q

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/6< 6e L MEMORANDUM FOR: Brian K. Grimes, Assistant Director for Engineering &

Projects, D0R Darrell G. Eisenhut, Assistant Director for Systems &

Projects, D0R FROM: Victor Stello, Jr. , Director, Division of Operating Reactors, NRR

SUBJECT:

GENERIC REVIEW 0F COMBUSTION ENGINEERING REACTOR

) PROTECTION SYSTEM (RPS) CHANNEL INOPERABILITY We have been in extended discussion with licensees utilizing the CE design in regards to the RPS channel inoperability. CE and the licensees consider their RPS design to be a "two-out-of-three" channel system with an installed spare channel. This is contrary to their FSAR's and our past licensing reviews which found the RPS acceptable as a "twor out-of-fot)r" channel system with limited channel bypass. '

At the present time, three of the CE facilities, Calvert Cliffs 1 and 2 and St. Lucie 1, have STS that authorize bypassing one RPS channel for the purpose of testing or maintenance. The TS for the other CE facili-ties, Ft. Calhoun, Maine Yankee, Millstone 2 and Palisades, specifies no limit on the length of time one channel can be bypassed. Near the end of 1977, letters were sent to these four licensees requesting that they propose the limited bypass STS or request a specific site review to determine if adequate channel separation exists at the facility to justify a "two-out-of-three" channel RPS. All four licenseer requested the specific review and Millstone has requested a TS change to the

" two-out-of-three" logic.

The enclosed letter to the four licensees invnived is to document our position presented at a meeting on August 2,1978 and again request that the STS allowing limited RPS channel bypass be proposed. The option to request a specific site review remains open.

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. v Memo to B. Grimes &

D. Eisenhut It is estimated that the review and issuance of any resultant amend-ments will require approximately 0.13 man year per facility if a specific site review is required and 0.07 man year per facility if the licensee proposes the 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> channel bypass TS.

The 0.25 to 0.5 man years of effort will be primarily in the Plant Systems Branch and will displace lower priority work.

This generic item (E-7) has been assigned to E. Conner (0RB#4) lead engineer and J. Burdoin (PSB) as lead reviewer.

Victor Stello,Jr. , Director Division of Operating Reactors Office of Nuclear Reactor Regulation

Enclosure:

Letter to Licensees Utilizing CE design RE: RPS Channel In-operability cc: D. Vassallo R. Denise H. Gearin J. McGough B. Grier K. Seyfrit

to UNITED STATES l' I,f NUCLEAR REGULATORY COMMISSION h, $ WASHING TON, D. C. 20555 u***

Docket No.: 50-Addressee Gentlemen:

On August 2,1978, representatives from utilities using Combustion Engineering (CE) USSS and from CE met in Bethesda, Maryland to discuss the action requirements in the event of Reactor Protection System (RPS) channel inoperability. Enclosure 1 is the minutes of this meeting. The meeting was held to clarify our position on this subject as presented in our letter dated and to gain an understanding of your position as indicated in your re-sponse dated . This same subject had been discus-sed previously on liarch 16, 1976.

In our previous correspondence, we requested that you submit an appli-cation for license amendment to change the Technical Specifications (TS)Section VI to require inoperable RPS channels to be placed in the " tripped" status within one hour after being declared inoperable. We further stated that you could request that we undertake a specific facility review of your RPS to determine the suitability of operating the RPS in a two-out-of-three logic.

Your response requested such a specific facility RPS review and we propose that the RPS review be scheduled for the month of 1978. The exact date will be coordinated through your Operating Reactor Branch Project Manager (ORPM). Enclosure 2 is the RPS review items that will be of interest to our review team.

As you know, our staff has conducted the RPS review at the Calvert Cliffs and St. Lucie units. A copy of the resultant Safety Evaluation for St. Lucie, presenting the finding of the RPS review (pages 3 to 5),

is provided for your information as Enclosure 3. Our conclusion was

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that allowing indefinite bypass of one of the four RPS is not a justified, but since the four channel CE system does have some independence, bypassing for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> during testing or maintenance of one RPS channel is justified.

As an alternative to the onsite NRC review of your RPS, we will consider issuance of the Calvert Cliffs and St. Lucie type TS

. of your RPS if you provide an application including documentation of your RPS similarity to those of Calvert Cliffs and St. Lucie. Any such application should be submitted within 45 days of the date of this letter.

Si ncerely, Robert W. Reid, Chief Operating Reactors Branch #4 e Division of Operating Reactors ~,

Enlosures:

l. Meeting Summary

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2. Review Item

3. Safety Evaluation cc w/ enclosures: See next page 4

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DZiemann I ItEMORANDUM FOR: Brian K. Grimes.. Assistant _ Director for Engineering. & . . _,. .

Projects.,D08

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Darrell G. Eisenhut, Assistant. Director. fp.r. Systems., &,._.. .

._j Projects,;p0R , ,

! FROM: Victon Stello, Jr., Director, Division,0f Operating. . .,,9

{ Reactors JRR _ .. .. . 4 l  !

SUBJECT:

GENERIC REVIEll.0F.00MBUSTION_ ENGINEERING.. REACTOR _ _ _ . ... ; -

PROTECTION SYSTEM (RPS) CHANNELIN0PERABII.!TY, ,. . ... s j .

We have been in extended discussion.with. licensees utilizing the.CE , . ,_ .;

design in regards to the RPS channel,jnoperability...CE.and. the licensees, , .

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consider their RPS design to,pe a. "two-out-of-three'Lchannel . system . . j with an installed srare channel. .This is, contrary,to their,FSAR,'s.ani .. . , ,!

- our past licensing reviews wbjch.found the. RPS; acceptable _as.a "two . ..

out-of-four" channel system with lfmiteri, channel bypass., _ . _ . _ . . ,

q l . At the present time, three oTthe,CE. facilities,.Calvert Cliffs 1.and,R. . _ q l and St. Lucie 1 have STS that autborire, bypassing one.RPS channel for . . . . _

the purpose of testing or ma10tenance. The TS.for the other_ CE.facili-ties, Ft. Calhoun, Maine Yankee,,Nillstone 2 and Palisades, specifies.

no limit on the length of time,one channetcan..be bypassed , Near the . . ,

j end of 1977, letters were sen).to these, four, licensees: requesting that, . 1

! they propose the limited bypass,STS.or, request a specific site review ,

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t3 determine-if adequate channel separation. exists at the facility,to_.. .. . .

justify a "two-out-of-three" channel, RPS,_, All four licensees requested ,L the specific review and Millstone.has, requested a TS_ change.to the s , _ . .

"two-out-of-three" logic.

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' The enclosed letter to the f5r. licensees. involved.is to doctnent.our 1. . ), ., [

position presented at a meeting on. August 2,,1978.and 'h;5ff1Trequeste. .u. . {

that the STS allowing limited.RPS. channel., bypass be proposed...The-. ,(.. ,

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option" to request a specific, site review remains.open._ . . .

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l It is estimated that the review.and.. issuance of any. resultant amend . . . . i ments will require approximately.0,13 man. year per facility if a. .. . . .

specific site review is required.and.D.07 man year per facility if.

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the licensee proposes the 48.bour channel bypass TS.- ,_ (

I The 0.25 to 0.5 man years of. pffort.will be,.primarily,in the Plant ,

Systems Branch and will disp 1ppe lower priority wort 1 .

! Th'is generic item (E-7) has b9en assigned to;E, Conner.(ORBf4) lead,_ _ . ..i-

! engineer and J. Burdoin (PSB),as, lead reviewer. . .. _...... ,

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. 'Vittor. Stet 1,o, Jr. , Director , , . . . . _ . . . , .

Division of Operating Reactors. . .

Office of Huclear Reactor Regulation

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Enclosure:

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Letter to Licensees ... -. ,

Utilizing CE design ... , . , . ,

RE: RPS Channel In- _ .

operability '

l1 i cc: D Vassallo

} R. Denise _. ._.

3 H. Gearin . . , , .. ..

J. McGough .. . - , . , ..

B. Grier , .. , . , .

K. Seyfrit .. ~_

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