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Category:INTERNAL OR EXTERNAL MEMORANDUM
MONTHYEARML20211K8611999-09-0101 September 1999 Informs That There Has Been Some Confusion Re Recently Issued ODCM Generic Section Rev Which Needs to Be Clarified. Clarifications Are Listed ML20210P1361999-08-0404 August 1999 Notification of 990817 Meeting with Util in Rockville, Maryland to Discuss Status of Licensing Actions Submitted by Comm Ed & Plan for Proposed Licensing Workshop ML20210C7061999-07-16016 July 1999 Forwards Facility Submitted Outline & Initial Exam Submittal for Operator Licensing Exams Administered During Wk of 990607 ML20209H2231999-07-16016 July 1999 Forwards Operator Licensing Exam Repts 50-456/99-301(OL) & 50-457/99-301(OL) of Exam Administered During Wk of 990607 ML20206Q2751999-05-13013 May 1999 Forwards Official Case File for DPO-99-1,request of Review of Concerns Related to TS Setpoints & Allowable Value for Instrumentation Under Formal DPO Procedures,For Disposition in Accordance with Provisions of NRC MD 10.159 ML20206E9331999-05-0303 May 1999 Notification of 990524 Meeting with Commonwealth Edison,Co in Rockville,Md to Discuss Technical Issues Related to Proposed re-rack of SFPs at Braidwood Station & Byron Station ML20206Q3211999-02-19019 February 1999 Responds to e-mail Message Sent on 980202,re Status of Staff Actions on Recipient Dpv.With Regard to Dpv Concerning Dynamic Testing of Instrument Channels at Braidwood,Staff Pursuing Resolution of Issue with Licensee ML20206Q3391999-01-0505 January 1999 Provides Update on Status of Resolution of follow-up Actions from Resolution of Dpv on Dynamic Testing of Instrumentation at Braidwood Station ML20155E7361998-11-0202 November 1998 Forwards NRC Operator Licensing Exam Repts 50-456/98-305 & 50-457/98-305 for Tests Administered on 980914 ML20154G2361998-10-0707 October 1998 Responds to Memo Sent on 981002 Re Resolution of follow-up Actions for NRR Differing Professional View Panel on Dynamic Testing of Instrumentation at Plant ML20196D7921998-10-0202 October 1998 Forwards Comments Related to Staff Responses to follow-up Actions Re Dynamic Testing of Instrument Channels at Braidwood ML20196D7801998-09-21021 September 1998 Informs That Staff Completed Review of follow-up Actions Identified in Memo from Bw Sheron to Ba Boger, on Dymanic Testing of Instrumentation Channels at Braidwood ML20151V2951998-09-0202 September 1998 Informs That Braidwood Station Concurs with Encl Proposed 980904 Util Response to NRC Re IPEEE ML20197C8041998-09-0202 September 1998 Informs That Braidwood Station Concurs with Proposed Encl Response to NRC Re RPV Integrity at Braidwood & Byron Stations ML20197C8301998-09-0101 September 1998 Informs That Rev 2 to Calculation BYR98-109/BRW-98-339-E Has Been Reviewed & Found Acceptable for Transmittal to Nrc. Draft Util Ltr Re Thermo-Lag Ampacity Derating Factor Calculation,Encl ML20237D4331998-08-21021 August 1998 Notification of 980903 & 04 Meetings W/Util in Rockville,Md to Discuss Technical Issues Related to Byron & Braidwood Improved Std TSs Conversion,Including Section 3.3,beyond Scope Issues,Closeout Packages & Amends to Current TSs ML20196D7211998-08-0404 August 1998 Responds to 980720 Memo from Sj Collins to Lj Callan Re When & How Mesac Approved.Licensee Installed Mirco Electronic Surveillance & Calibration (Mesac) Sys Measurement & Test Equipment as Backup Sys to Normal M&TE ML20196D7711998-07-22022 July 1998 Discusses Staff Review of Braidwood Mesac System ML20249A2231998-06-12012 June 1998 Notification of 980625-26 Meeting W/Util in Rockville,Md to Discuss Technical Issues Re Byron & Braidwood Improved Std TSs Conversion ML20216B6731998-05-11011 May 1998 Discusses Closure of TAC M94439 for Braidwood,Unit 1,steam Generator Replacement ML20217P0131998-04-29029 April 1998 Forwards NRC Approved Operator Licensing Exam (Facility Outline & Initial Exam Submittal & as-given Operating Exam) for Tests Administered During Wk of 980413 ML20217P0731998-04-29029 April 1998 Forwards NRC Operator Licensing Exam Repts 50-456/98-304(OL) & 50-457/98-304(OL) (Including Completed & Graded Tests) for Tests Administered on 980413-15 ML20217E3881998-04-23023 April 1998 Notification of 980506 & 07 Meetings W/Util in Rockville,Md to Discuss Technical Issues Re Plants Improved STS Conversion ML20216H3401998-03-17017 March 1998 Notification of 980331-0402 Meeting W/Util in Rockville,Md to Discuss Reviewer Comments on Byron & Braidwood Improved Std TS Submittal ML20216H6971998-03-17017 March 1998 Notification of 980326 Meeting W/Commonwealth Edison Co in Lisle,Il to Discuss Comed Request to Consolidate near-site Emergency Operations Facility Into Single Central EOF ML20203G8551998-02-23023 February 1998 Notification of 980305 Meeting W/Util in Rockville,Md to Discuss Status of Byron & Braidwood Licensing Issues ML20198G4921998-01-0707 January 1998 Forwards Facility Submitted Outline,Initial Exam Submittal & as Given Operating Exam for Test Administered During Wk of 971006 at Plant ML20198J6881998-01-0707 January 1998 Forwards NRC Operator Licensing Exam Rept w/as-given Written Exam for Tests Administered During Wk of 971006 at Plant ML20202E5831997-11-25025 November 1997 Notification of 971215 Meeting W/Commonwealth Edison Co in Rockville,Md to Review Schedule for Listed Plants Improved Std TS Conversion & Supplemental Submittals ML20203C3621997-11-25025 November 1997 Revised Notification W/New Starting Time of Meeting W/Ceco on 971215 in Rockville,Maryland to Discuss Review Schedule Byron & Braidwood Improved TS Conversion & Supplemental Submittals ML20202D2221997-11-25025 November 1997 Notification of Meeting W/Ceco on 971211 in Rockville,Md to Discuss Proposed Mod to Methodology for Estimating SG Tube Leakage Attributable to Outer Diameter Stress Corrosion Crack Indications Restricted from Burst for Plant SGs ML20236N5111997-10-22022 October 1997 Fowards Staff Response to 960912 TIA Re Containment Spray Additive Sys Conformance W/Design Basis & Tss.Analysis Concluded That 2,400-2,600 Ppm in RWST Acceptable ML20217K8271997-10-16016 October 1997 Notification of 971024 Meeting W/Util to Discuss Results of Comed Investigation Into Sensitivity of Proposed voltage- Dependent Growth Rates to Binning Strategy for ODSCC Indicators ML20212A1501997-10-15015 October 1997 Forwards Response for NRC RAI Re SG Interim Plugging Criteria 90 Day Rept for Braidwood,Unit 1 Sixth Refuel Outage (A1R06).Station Concurs W/Response as Proposed for CE ML20217D4261997-09-30030 September 1997 Informs of Scheduled Visits W/Nuclear Services at Gpu on Nov 14th & Visit at Commonwealth Edison on Dec 3rd & Would Like to Receive Any Info Available.Supporting Documentation Encl ML20217B3901997-09-23023 September 1997 Forwards Questions Re Ceco Submittal of Revised SG Tube Rupture Analysis for Byron,Unit 1 & Braidwood,Unit 1 ML20149L1901997-07-22022 July 1997 Notification of 970723 Meeting W/Commonwealth Edison Co in Rockville,Md to Discuss Results of Spring 1997,Braidwood,1 SG Tube Eddy Current Insp.Time of Meeting Rescheduled ML20149F2731997-07-0303 July 1997 Notification of 970723 Meeting W/Util in Rockville,Md to Discuss Results of Spring 1997 Plant,Unit 1 SG Tube Eddy Current Insp Including Determination of Impact of Data ML20138D2781997-04-28028 April 1997 Notification of 970430 Meeting W/Util in Rockville,Md to Discuss Results of EC Insps of Plant SGs Conducted During Present Refueling Outage IA-97-178, Forwards Partially Withheld Background Briefing Package in Preparation for 970425 Meeting Between Comed & Commission1997-04-18018 April 1997 Forwards Partially Withheld Background Briefing Package in Preparation for 970425 Meeting Between Comed & Commission ML20217D5461997-04-18018 April 1997 Forwards Partially Withheld Background Briefing Package in Preparation for 970425 Meeting Between Comed & Commission ML20147J2391997-04-0909 April 1997 Notification of Meeting on 970416 W/Util in Rockville,Md to Discuss Overall Response & Present Addl Details Re Performance Indicators Used to Monitor Performance Stations ML20236N0071997-04-0707 April 1997 Responds to Request for TS Interpretation on Containment Vent & Drain Valves at Braidwood ML20138J7671997-02-0505 February 1997 Informs That NRC Plans to Administer Generic Fundamentals Exam Section of Written Operator Licenseing Exam on 970409. Ltr W/Copy to Chief,Operator Licensing Branch Must Be Submitted to Listed Address in Order to Register Personnel ML20149M6901997-01-19019 January 1997 Notification of 970128 Meeting W/Commonwealth Edison Co to Discuss Licensee Proposed Program for Use of Mixed Oxide Fuel ML20133J5811997-01-15015 January 1997 Notification of 970122 Meeting W/Util in Rockville,Md to Discuss Licensee Status of Program for Replacement & Operation of New SG at Byron 1 & Braidwood 1 ML20133J4821997-01-15015 January 1997 Notification of 970123 Meeting W/Licensees in Rockville,Md to Discuss Contents of Plants TS Conversion Submittal, Provide Staff Comments Based on Initial Screening Review & Discuss Review Schedule ML20196D8881997-01-0202 January 1997 Provides Results of Review of Dpv That Was Expressed in 961017 Memo Re Dynamic Testing of Instrumentation Channels at Braidwood ML20196D8011997-01-0202 January 1997 Forwards NRR Ad Hoc Dpv Review of Recipient Differing Professional View Re Dynamic Testing of Instrumentation Channels at Braidwood,Per 961017 Memo ML20196D8671997-01-0202 January 1997 Submits Review of Ad Hoc NRR Dpv Review Panel Re 961017 Memo Dpv on Dynamic Testing of Instrumentation Channels at Braidwood 1999-09-01
[Table view] Category:MEMORANDUMS-CORRESPONDENCE
MONTHYEARML20211K8611999-09-0101 September 1999 Informs That There Has Been Some Confusion Re Recently Issued ODCM Generic Section Rev Which Needs to Be Clarified. Clarifications Are Listed ML20210P1361999-08-0404 August 1999 Notification of 990817 Meeting with Util in Rockville, Maryland to Discuss Status of Licensing Actions Submitted by Comm Ed & Plan for Proposed Licensing Workshop ML20209H2231999-07-16016 July 1999 Forwards Operator Licensing Exam Repts 50-456/99-301(OL) & 50-457/99-301(OL) of Exam Administered During Wk of 990607 ML20210C7061999-07-16016 July 1999 Forwards Facility Submitted Outline & Initial Exam Submittal for Operator Licensing Exams Administered During Wk of 990607 ML20206Q2751999-05-13013 May 1999 Forwards Official Case File for DPO-99-1,request of Review of Concerns Related to TS Setpoints & Allowable Value for Instrumentation Under Formal DPO Procedures,For Disposition in Accordance with Provisions of NRC MD 10.159 ML20206E9331999-05-0303 May 1999 Notification of 990524 Meeting with Commonwealth Edison,Co in Rockville,Md to Discuss Technical Issues Related to Proposed re-rack of SFPs at Braidwood Station & Byron Station ML20206Q3211999-02-19019 February 1999 Responds to e-mail Message Sent on 980202,re Status of Staff Actions on Recipient Dpv.With Regard to Dpv Concerning Dynamic Testing of Instrument Channels at Braidwood,Staff Pursuing Resolution of Issue with Licensee ML20206Q3391999-01-0505 January 1999 Provides Update on Status of Resolution of follow-up Actions from Resolution of Dpv on Dynamic Testing of Instrumentation at Braidwood Station ML20155E7361998-11-0202 November 1998 Forwards NRC Operator Licensing Exam Repts 50-456/98-305 & 50-457/98-305 for Tests Administered on 980914 ML20154G2361998-10-0707 October 1998 Responds to Memo Sent on 981002 Re Resolution of follow-up Actions for NRR Differing Professional View Panel on Dynamic Testing of Instrumentation at Plant ML20196D7921998-10-0202 October 1998 Forwards Comments Related to Staff Responses to follow-up Actions Re Dynamic Testing of Instrument Channels at Braidwood ML20196D7801998-09-21021 September 1998 Informs That Staff Completed Review of follow-up Actions Identified in Memo from Bw Sheron to Ba Boger, on Dymanic Testing of Instrumentation Channels at Braidwood ML20197C8041998-09-0202 September 1998 Informs That Braidwood Station Concurs with Proposed Encl Response to NRC Re RPV Integrity at Braidwood & Byron Stations ML20151V2951998-09-0202 September 1998 Informs That Braidwood Station Concurs with Encl Proposed 980904 Util Response to NRC Re IPEEE ML20197C8301998-09-0101 September 1998 Informs That Rev 2 to Calculation BYR98-109/BRW-98-339-E Has Been Reviewed & Found Acceptable for Transmittal to Nrc. Draft Util Ltr Re Thermo-Lag Ampacity Derating Factor Calculation,Encl ML20237D4331998-08-21021 August 1998 Notification of 980903 & 04 Meetings W/Util in Rockville,Md to Discuss Technical Issues Related to Byron & Braidwood Improved Std TSs Conversion,Including Section 3.3,beyond Scope Issues,Closeout Packages & Amends to Current TSs ML20196D7211998-08-0404 August 1998 Responds to 980720 Memo from Sj Collins to Lj Callan Re When & How Mesac Approved.Licensee Installed Mirco Electronic Surveillance & Calibration (Mesac) Sys Measurement & Test Equipment as Backup Sys to Normal M&TE ML20196D7711998-07-22022 July 1998 Discusses Staff Review of Braidwood Mesac System ML20249A2231998-06-12012 June 1998 Notification of 980625-26 Meeting W/Util in Rockville,Md to Discuss Technical Issues Re Byron & Braidwood Improved Std TSs Conversion ML20216B6731998-05-11011 May 1998 Discusses Closure of TAC M94439 for Braidwood,Unit 1,steam Generator Replacement ML20217P0731998-04-29029 April 1998 Forwards NRC Operator Licensing Exam Repts 50-456/98-304(OL) & 50-457/98-304(OL) (Including Completed & Graded Tests) for Tests Administered on 980413-15 ML20217P0131998-04-29029 April 1998 Forwards NRC Approved Operator Licensing Exam (Facility Outline & Initial Exam Submittal & as-given Operating Exam) for Tests Administered During Wk of 980413 ML20217E3881998-04-23023 April 1998 Notification of 980506 & 07 Meetings W/Util in Rockville,Md to Discuss Technical Issues Re Plants Improved STS Conversion ML20216H3401998-03-17017 March 1998 Notification of 980331-0402 Meeting W/Util in Rockville,Md to Discuss Reviewer Comments on Byron & Braidwood Improved Std TS Submittal ML20216H6971998-03-17017 March 1998 Notification of 980326 Meeting W/Commonwealth Edison Co in Lisle,Il to Discuss Comed Request to Consolidate near-site Emergency Operations Facility Into Single Central EOF ML20203G8551998-02-23023 February 1998 Notification of 980305 Meeting W/Util in Rockville,Md to Discuss Status of Byron & Braidwood Licensing Issues ML20198J6881998-01-0707 January 1998 Forwards NRC Operator Licensing Exam Rept w/as-given Written Exam for Tests Administered During Wk of 971006 at Plant ML20198G4921998-01-0707 January 1998 Forwards Facility Submitted Outline,Initial Exam Submittal & as Given Operating Exam for Test Administered During Wk of 971006 at Plant ML20202D2221997-11-25025 November 1997 Notification of Meeting W/Ceco on 971211 in Rockville,Md to Discuss Proposed Mod to Methodology for Estimating SG Tube Leakage Attributable to Outer Diameter Stress Corrosion Crack Indications Restricted from Burst for Plant SGs ML20202E5831997-11-25025 November 1997 Notification of 971215 Meeting W/Commonwealth Edison Co in Rockville,Md to Review Schedule for Listed Plants Improved Std TS Conversion & Supplemental Submittals ML20203C3621997-11-25025 November 1997 Revised Notification W/New Starting Time of Meeting W/Ceco on 971215 in Rockville,Maryland to Discuss Review Schedule Byron & Braidwood Improved TS Conversion & Supplemental Submittals ML20236N5111997-10-22022 October 1997 Fowards Staff Response to 960912 TIA Re Containment Spray Additive Sys Conformance W/Design Basis & Tss.Analysis Concluded That 2,400-2,600 Ppm in RWST Acceptable ML20217K8271997-10-16016 October 1997 Notification of 971024 Meeting W/Util to Discuss Results of Comed Investigation Into Sensitivity of Proposed voltage- Dependent Growth Rates to Binning Strategy for ODSCC Indicators ML20212A1501997-10-15015 October 1997 Forwards Response for NRC RAI Re SG Interim Plugging Criteria 90 Day Rept for Braidwood,Unit 1 Sixth Refuel Outage (A1R06).Station Concurs W/Response as Proposed for CE ML20217D4261997-09-30030 September 1997 Informs of Scheduled Visits W/Nuclear Services at Gpu on Nov 14th & Visit at Commonwealth Edison on Dec 3rd & Would Like to Receive Any Info Available.Supporting Documentation Encl ML20217B3901997-09-23023 September 1997 Forwards Questions Re Ceco Submittal of Revised SG Tube Rupture Analysis for Byron,Unit 1 & Braidwood,Unit 1 ML20149L1901997-07-22022 July 1997 Notification of 970723 Meeting W/Commonwealth Edison Co in Rockville,Md to Discuss Results of Spring 1997,Braidwood,1 SG Tube Eddy Current Insp.Time of Meeting Rescheduled ML20149F2731997-07-0303 July 1997 Notification of 970723 Meeting W/Util in Rockville,Md to Discuss Results of Spring 1997 Plant,Unit 1 SG Tube Eddy Current Insp Including Determination of Impact of Data ML20138D2781997-04-28028 April 1997 Notification of 970430 Meeting W/Util in Rockville,Md to Discuss Results of EC Insps of Plant SGs Conducted During Present Refueling Outage ML20217D5461997-04-18018 April 1997 Forwards Partially Withheld Background Briefing Package in Preparation for 970425 Meeting Between Comed & Commission IA-97-178, Forwards Partially Withheld Background Briefing Package in Preparation for 970425 Meeting Between Comed & Commission1997-04-18018 April 1997 Forwards Partially Withheld Background Briefing Package in Preparation for 970425 Meeting Between Comed & Commission ML20147J2391997-04-0909 April 1997 Notification of Meeting on 970416 W/Util in Rockville,Md to Discuss Overall Response & Present Addl Details Re Performance Indicators Used to Monitor Performance Stations ML20236N0071997-04-0707 April 1997 Responds to Request for TS Interpretation on Containment Vent & Drain Valves at Braidwood ML20138J7671997-02-0505 February 1997 Informs That NRC Plans to Administer Generic Fundamentals Exam Section of Written Operator Licenseing Exam on 970409. Ltr W/Copy to Chief,Operator Licensing Branch Must Be Submitted to Listed Address in Order to Register Personnel ML20149M6901997-01-19019 January 1997 Notification of 970128 Meeting W/Commonwealth Edison Co to Discuss Licensee Proposed Program for Use of Mixed Oxide Fuel ML20133J4821997-01-15015 January 1997 Notification of 970123 Meeting W/Licensees in Rockville,Md to Discuss Contents of Plants TS Conversion Submittal, Provide Staff Comments Based on Initial Screening Review & Discuss Review Schedule ML20133J5811997-01-15015 January 1997 Notification of 970122 Meeting W/Util in Rockville,Md to Discuss Licensee Status of Program for Replacement & Operation of New SG at Byron 1 & Braidwood 1 ML20196D8671997-01-0202 January 1997 Submits Review of Ad Hoc NRR Dpv Review Panel Re 961017 Memo Dpv on Dynamic Testing of Instrumentation Channels at Braidwood ML20196D8011997-01-0202 January 1997 Forwards NRR Ad Hoc Dpv Review of Recipient Differing Professional View Re Dynamic Testing of Instrumentation Channels at Braidwood,Per 961017 Memo ML20196D8881997-01-0202 January 1997 Provides Results of Review of Dpv That Was Expressed in 961017 Memo Re Dynamic Testing of Instrumentation Channels at Braidwood 1999-09-01
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Text
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- J p' UNITED STATES I g, j NUCLEAR REGULATORY COMMISSION l
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l October 2, 1998 ,
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l MEMORANDUM TO: Samuel J. Collins, Director ..
Office of Nuclear Reactor Regulation 98 tel 18 f00 M FROM: Frederick H. Burrows, Electrical Engineer,
! Electrical Engineering Branch qg >
Division of Engineering -
j Office of Nuclear Reactor Regulation j
SUBJECT:
CONCERNS RELATED TO DYNAMIC TESTING OF INSTRUMENT CHANNELS AT BRAIDWOOD in a niemorandum dated October 17,1996, I expressed a Differing Professional View l (DPV) concerning the dynamic testing of instrumentation channels at Braidwood.
Specifically, I expressed my view that dynamic testing of safety-related instrument l
channels was outside the plant's licensing basis and represented an unreviewed safety question. In a January 2,1997, memorandum, Frank Miraglia, Acting Director, NRR, provided the ad hoc DPV panel's recommendations for this issue. A follow-up action memorandum was sent to Brian Sheron, Acting Associate Director for Technical Review, NRR, on the same day with subsequent forwarding to Bruce A. Boger, Director, Division of l Reactor Contrals and Human Factors, NRR. In .*. September 21,1998, memorandum, you have now pim.ded the results of the staff's review of the follow-up actions.
I have reviewed the staff's response contained in the September 21 memo and conclude l that those fc!!ow-up action efforts fall short of completely addressing my concerns. To spare myself furthes frustration and to limit the detrimental effects resulting from the j DPV/DPO process, I will not at this time pursue further formal staff review (via the DPO }
i process) of the issues associated with dynamic testing of in ament channels at Braidwood and adjustment of the time constants in reacte- otection instrument channels f in Westinghouse plants.
l In an effort to bring some closure for my concerns, I have attached hereto my comments l related to the staff's responses to the follow-up actions. My hope is that you will consider
! my comments and take whatever action you deem appropriate.
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Also, I now request that the DPV and this letter (if appropriate) be made public, elong with the release of my name, per NRC Handbook 10.159.
f\
I CONTACT: Frederick H. Burrows, EELB/DE/NRR 415-2901
Attachment:
As stated 1 -
9812O20326 981002 PDR ADOCK 05000456 p PDR .
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l COMMENTS ON THE STAFF'S RESOLUTION
_OF FOLLOW-UP ACTIONS TO DYNAMIC TESTING OF BRAIDWOOD INSTRUMENTATION l
- 1. The staff concludes in the September 21,1998, memorandum from R. Lee Spessard to Brian Sheron that the dynamic testing (MESAC) is consistent with the Westinghouse setpoint methodology and the Braidwood Technical Specifications (TS) and equivalent to channel operational or functional tests performed at other plants. I disagree; as I have stated before the periodic required channel functional tests for Westinghouse plants are based on a static test method. That is, the input test signal is slowly changed (manually, not a ramped input from a signal generator) with the dynamic components bypassed until the associated bistable (or comparator) changes state. The value of the input signal at which the bistable trips is written down and verified to be within the setpoint (or allowable value) limits contained in the TS. At Braidwood (and possibly Vogtle) a ramp input signalis used and the dynamic components are not bypassed. The time of the bistable trip is determined and the value of the input signal at the time the trip occurred is read off the input signal, recorded and compared to the TS setpoint limit. Obviously the Braidwooo trip value is affected by the dynamic component uncertainties. Since the Braidwood TS are the same as Byron TS and their setpoint limits contained therein are based on typical Westinghouse setpoint methodology which does not account for dynamic component uncertainties, Braidwood's method of satisfying the TS channel operational test requirements (based on a literal interpretation) remain questionable and not completely evaluated by the staff in my opinion. Although the licensee's evaluation of the channel's static string tolerance does provide some usefulinformation (especially if the comparator/ bistable is included in the string), it does not satisfy (in my opinion) the requirements of a channel functional or operational test (once again based on a literal interpretation).
- 2. The staff concludes in the September 21,1998, memorandum from R. Lee Spessard to Brian Sheron that although the " margins of safety" were decreased in the sensitivity analyses, the Braidwood accident analyses bound the effects of time constants nonconservatively offset by 10 percent. I disagree that the Braidwood accident analyses bound the time constant tolerances--The Westinghouse sensitivity studies do. While it is true that the safety limit used in the Braidwood Chapter 15 is bounding, the individual analyses contained therein do not bound since they currently do not account for the time constant adjustment uncertainties. It is my belief that the most conservative assumptions and conditions should be utilized in FSAR Chapter 15 analyses.
l l Since the licensee plans to continue to use dynamic testing, I believe that the current Chapter 15 analyses should be updated to reflect the results of the Westinghouse sensitivity studies. If they are not updated, it is my opinion that they are then not t
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bounding and the validity of future Chapter 15 type sensitivity studies may be questionable due to lack of formal documentation associated with the impact of time constant uncertainties.
- 3. The staff concluded that the "mergin to safety"in selected Braidwood FSAR safety analyses will be reduced due to offsetting some of the time constants by 10%.
The staff also assumed that MESAC had been installed under 10 CFR 50.59 although the licenses could not readily verify this. It is my position (based on discussions with Eileen McKenna) that the use of the MESAC system and the associated dynamic testing of instrument channels represented an unreviewed safety question (because l the " margin to safety" was reduced) when it replaced the static testing method l approved by the staff as part of the Byron /Braidwood initiallicense activity. Instead l of addressing the safety impact of adopting dynamic testing when it was implemented, it $ pears that the licensee, with some reluctance, only recently ask l Westinghouse to perform sensitivity studies. Also, during the staff's review of the DPV, the licensee appeared unwilling to address some of the staff's questions. In lieu of addressing the licensee's apparent failure to follow 10 CFR 50.59 and the un7sponsiveness, the staff sent a September 21,1998, letter of appreciation to the l licensee for the technical support provided during the review of this DPV issue. l l
believe this sent an inappropriate message to the licensee.
- 4. As noted above the staff concluded that the " margin to safety"in selected Braidwood FSAR safety analyses will be reduced due to offsetting some of the time constants by i10%. Based on licensee analyses that show that the safety limits will not be exceeded in any Braidwood Chapter 15 accident analyses, the staff further concludes that the public health and safety is not affected by 10% time constant uncertainties in other Westinghouse plants. I disagree with this far reaching conclusion. I believe each Westinghouse plant has its own et of Chapter 15 accident analyses with accompanying assumptions, etc. that change over the life of the plant. Based on this, how can one conclude that sensitivity studies performed for Braidwood answer the unreviewed safety question for other plants? Without performing the individual sensitivity studies for the other Westinghouse plants, how can orie conclude that their safety limits are not exceeded? That is, how can one conclude that there was, is, and will be margin available in other plant's Chapter 15 analyses based solely on recent Braidwood sensitivity studies?
- 5. The staff has repeatedly stated that Braidwood's dynamic testing is in accordance with the Westinghouse setpoint methodology and the plant's Technical Specifications (TS). The staff also concluded that 110% tolerance for industry time constant calibration procedures is acceptable and that the Westinghouse Standard Technical Specifications (STS) already implement this recommendation. I do not understand these conclusions. The current Westinghouse STS require the lead / lag j time constants to be set s or a to specified values for OTAT and OPAT. Braidwood l TS require those time constants to be set equal to specific values. How can the l *10% satisfy a s requirement? How can the 110% satisfy a = requirement? Are TS to be interpreted literally? I believe they should be.
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Also it should be noted that the Westinghouse STS and the Braidwood TS do not l specify value:t for time constants in all channels that have dynamic corr ponents. ,
That is only the setpoints and allowable values for OTAT and OPAT protective l functions explicitly contain values for dynamic components; other channels such as I l pressurizer pressure low do not. How does the Westinghouse STS implement the staff's 10% recommendation if they do not even specify any values?
- 6. The' staff stated that the MESAC system had received a " tacit approval" as discussed in an August 4,1998, memorandum. The August 4 memo states that I
since the licensee did not exclude the use of MESAC from an amendment request that was granted on April 13,1993, and it was installed at that time, the staff granted " tacit approval" for its use. The staff's use of " tacit"in the case of MESAC l and in other licensing issues concerns me. One can conclude, for example (based on j l the staff's use and interpretation of " tacit approval"), that just about any inspection !
finding encompassing a plant equipment shortcoming involves a backfit since most i
equipment was installed in the power plant when it was originally licensed and therefore received " tacit approval."
l l
A quick review of the staff's safety evaluation associated with the April 13,1993, I amendment approval indicates the word MESAC or the words, dynamic testing, are i l not found therein. This indicates that the licensee probably did indeed not exclude '
l the use of MESAC from the amendment request: but the licensee did not explicit
! state that he was using MESAC and seeking its approval either. Using my Random
( House College Dictionary, tacit approval means " understood without being openly expressed; implied." I am not an NRC icwyer, but " tacit approval" has always meant to me that I at least had a little knowledge of the thing I was " tacitly approving."
Can the staff say that about the Braidwood MESAC " tacit approval?" ,
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I l