IR 05000266/1990021

Enforcement Conference Repts 50-266/90-21 & 50-301/90-21 on 901004 Re Violation of 10CFR50,App B, Design Control

ML20059N981
Person / Time
Site:	Point Beach
Issue date:	10/11/1990
From:	Ring M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20059N980	List: IR 05000266/1990021 ML20059N979
References
50-266-90-21-EC, 50-301-90-21, NUDOCS 9010240269
Download: ML20059N981 (40)

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ti- REGION 111 C

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Reports N'o, 50-266/90-21(DRS);No.-50-301/90-21(DRS).

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'L 'Y ' Docket'N6s.: .50-266;J50-301 . Licenses No. DPR-~24; DPR-27 O

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Licensee: ' Wisconsin Electric Power Company e .

-231. West Michigan Street;- P379

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.Mileaukee, WI 53201 a: Facility Name: ' Point. Beach Nuclear Power Plant - Units 1 and 2

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Meeting At: Region III Office, Glen,Ellyn, Illinois 60137

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g, ~ Meeting Conducted: October 4, 1990 '

Type of Meeting: Enforcement Conference m

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I Approved By: Ak q Date-

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M. A. Ring, Chief G 9 Engineering' Branch i

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Meeting' Summary 1 y ,

6" Meeting o'n-0ctober 4', 1990 (Reports No.- 50-266/90-21(DRS);-No. 50-301/90-21(DRS))-

.iiMatters Discussed: The apparent yiolation.of 10.CFR 50,' Appendix.B, " Design' [.

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' Control,'.' with the following' examples: ..An inadequate _EDG loading calculation;

e failure to' perform a seismic- analysis for the' racked out position ~of the 4.16kV i

. bus- tie breakers; tso cable separation issues involving both u' nits':CCW pumps : !

Iand the' Unit :2 steam driven:AFW pump; and -inadequate seismic supporting,of 'the

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-EDG fuel tri.nsfer piping ; (InLaddition,. the apparent violation of-10 CFR .50,

Appendix B, !' Quality Assurance Program," which involved the failure to. fully

extend: quality assurance.-controls over the calibration of non-Technical .

-Specification ! safety-related relays; the-apparent violation.of. Technical ]

Specification 15.6.8, " Plant 0perating Procedures,";to include-the calibration:

(- Jof the safety-related inverters undervoltage trip function in a routine c maintenance procedure;;and an apparent deviation of Point Beach FSAR cable fill- m 1

l Trequirements=were discussed.- Information pertinent. to the. causes, safety . .

j fsignificance, and corrective actions to prevent recurrence were discusse '

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'hs 1 Disposition.of;the apparent violations will be presented in subsequent- '

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DETAILS Enforcenient Conference Attendees Wisconsin Electric Power Company (WEPCo)

J. Zach, Senior Manager, Nuclear Engineering R. Newton, Manager, NSEAS G. Krieser, Manager, Quality Assurance G. Frieling, Superintendent, Systems Engineering D. Johnson, Superintendent, Nuclear Regulation R. Seizert, Superintendent Regulatory and Support Services P. Katers, Senior Project Electrical Engineer U. S. Nuclear Regulatory Commission (NRC)

C. Paperiello, Deputy Regional Administrator H. Miller, Director, Division of Reactor Safety (DRS)

T. Martin, Deputy Director, DRS C. Pederson, Director, Enforcement and Investigations Coordination Staff B. Berson, Regional Counsel M. Ring, Chief. Engineering Branch, DRS R. Gardner, Chief, Plant Systems Section, DRS N. Jackiw, Chief. Projects Section 3A Divition of Reactor Projects (DRP)

R. Gramm, Special Inspect' as Branch, Nuclear Reactor Regulation (NRR)

R. Samworth, Project Manager, NRR S. Stein, EDSFI Team Leader, NRR C. Vanderniet, SRI, Point Beach P. Lougheed, Enforcement Specialist D. Butler, Reactor Inspector, DRS J. Monninger, HQS Intern, DRS Erforcement Conference As a result of the apparent violations of NRC requirements, an Enforcement Conference was held at the Region 111 Office in Glen Ellyn, Illinois, on October 4, 1990. The preliminary findings which were the bases for these ap?arent violations of NRC requirements were documented in HRC Inspection 3eports No. 50-266/90-201(NRR);No.50-301/90-201(HRR);

No. 50-266/90018(DRS); and No. E0-301/90018(DRS) and were transmitted to the licensee by letters dated June 1,1990 and September 27, 1990, respectively. The attendees of this enforcement conference are denoted in Paragraph 1 of this repor The purposes of the conference were: (1) to discuss the apparent violations,)the significance, actions;(2 to determine cause, whether andwere there the any licensee's corrective mitigating circumstances; and (3) to obtain other information which would help determine the appropriate enforcement actio >

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L The f(RC representatives identified the apparent violations and those deficiencies contributing to the apparent violations. The licensee did not contest the information presented by the NR The information presented by Wisconsin Electric Power Company is included as r.nclosure 2 to this report, 3. Conclusion The evaluation and disposition of the apparent violations will be presented in subsequent cowiunications,

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EhFORCEMENT COhFERENCE OCTOBER 4,1990 l

j WISCONSIN ELECTRIC ATTENDEES V  ;\

JIM ZACH SENIOR hiANAGER, NUCLEAR ENGINEERING i

l ROGER NEWTON - hiANAGER, NUCLEAR SYSTEhiS ENGINEERING &

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ANALYSIS SECTION GARY KRIESER - hiANAGER, QUALITY ASSURANCE ,

GARRY FRIELING - SUPERINTENDENT, SYSTEhiS ENGINEERING j PAUL KATERS - SENIOR PROJECT ENGINEER DOUG JOHNSON - SUPERIhTENDENT, NUCLEAR REGULATION '

RON SEIZERT - SUPERINTENDENT, REGULATORY SERVICES i

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ENFORCEMENT CONFERENCE OCTOBER 4,1990 AGENDA INTRODUCTION / OPENING REhiARKS (ZACII) DISCUSSION OF APPARENT VIOLATIONS & DEVIATION 1. Design Control a. EDG Leading Calculations (Katers)

b. Racked-Out Tie-Breakers (Katers)

c. Cable Single-Failure Mechanism for 480V Bus Tie Breakers (Katers)  ;

d. Cable Separation and Common Mode Failure of CCW Pumps (Katers) i e. Cable Separation for AFW Valve Auto Open Circuit (Katers) L f. Fuel Oil Transfer Piping Design (Frieling)

2. Quality Assurance Program Criteria (Krieser)

Calibration of Safety-Related Protective Relays 3. Technical Specl0 cation 15.6.8 - Inverter Test Procedure (Katers)

4. FSAR Cable Tray Fill Requirements (Katers) DISCUSSION OF NRC ISSUES 1. Classification of Systems (Newton)

2. Full QA Treatment of Safety Related Systems (Krieser)

3. WEPCO Initiated Audits and Corrective Actions (Zach)

4. 79-14 Piping Systems (Frieling)

5. Safety Signlucance, Root Cause, and Corrective Actions 6. Discussion of Design Basis Reconstitution Effort (Newton /Katers)

7. Efforts to Ensure Functionality of Systems (Newton) CONCLUDING REMARKS (Zach) ,

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DISCUSSION OF APPARENT -

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VIOLATIONS AND DEVIATION

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,' APPARENT VIOLATION 1A DIESEL GENERATOR LOADING - CALCULATIONS

• ORIGINAL DIESEL GENERATOR LOADING WAS SHOWN IN FSAR TABLES 8.2.1 (FOR INJECTION PHASE) AND 8.2.2 (FOR RECIRCULATION PHASE),

e SELF INITIATED SSFI CONDUCTED IN EARLY 1988 BY MTSTEC IDENTIFIED THE LACK OF A FORhiAL DIESEL GENERATOR LOADING CALCULATION AS A FINDING. ALSO hiENTIONED WAS THE CAPABILITY TO OVERLOAD TIE DIESEL BY hiANUALLY RESTORING LOADS INAPPROPRIATEL e IN LATE 1988, IhiPELL CORPORATION WAS CONTRACTED TO CREATE A FORhiAL LOADING CALCULATION FOR DIESEL GENERATORS. TlHS CALCULATION WAS TO INCLUDE AN EVAL'UATION OF WIBCH ELECTRICAL LOADS WOULD BE ADDED/REh10VED FROh! THE DIESEL BY OPERATOR ACTION. EOPs WERE TO BE UTILIZED AS AN AID IN TIBS EVALUATIO e REVISION 0 OF THIS CALCULATION WAS ISSUED 3/31/90. TIUS SHOWED A WORST CASE LOADING OF APPROXIhiATELY 99% OF THE DIESEL GENERATOR 200 IlOUR LOAD RATING DURING TIE RECIRCULATION PIIASE. TIIIS DID NOT INCLUDE THE LOAD RESULTING FROh!

OPERATION OF AN ACCIDENT FAN IN THE NON-AFFECTED UNIT. IT DID Il0 WEVER INCLUDE THE hiANUAL ADDITION OF SEVERAL AUXILIARY BUILDING VENTILATION LOADS WIUCH ARE NOT REQUIRED TO hilTIGATE AN ACCIDENT OR SHUTDOWN THE NON-AFFECTED UNI e SUBSEQUENT TO THE EDSFI, TIUS CALCULATION WAS REVISED TO INCLUDE THE LOADING DUE TO AN ACCIDENT FAN OPERATING IN TIIE NON-AFFECTED UNIT. TIIIS REVISION ALSO INCLUDED TIE REh10 VAL OF SEVERAL NONREQUIRED AUXILIARY BUILDING VENTILATION FANS FROM TIIE DIESEL GENERATOR LOADING. THESE CIIANGES RESULTED

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IN A hiAXIhiUM LOADING OF 2918 KW OR 98.5% OF THE 200 HOUR RATING OF 2963 K .

e ALL LOADING CALCULATIONS ARE COMPLETE. FSAR REVISIONS ARE PENDIN _ _ _ . _ _ . _ _ . . _ _ . _ _ . _ _ ._ _ _. . _ . . _ .

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APPARENT VIOLATION 1 A DIESEL GENERATOR LOADING - EOPs (continued)

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I o ORIGINAL POST-Thil EOPs WERE WRITTEN TO COVER A VARIETY OF l

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PLANT OPERATING SCENAIUOS. ORIGINAL VERIFICATION AND 1 VALIDATION DID NOT INCLUDE A REVIEW OF DIESEL GENERATOR

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LOADING. OPERATORS WERE EXPECTED TO hiANAGE DIESEL GENERATOR LOA * IN 1988, TABLES WERE ADDED TO SEVERAL EOPs TO ALLOW OPERATORS  ;

TO BETTER hiANAGE LOADS ON THE DIESEL GENERATORS. THE EDSFI l CONSIDERED THESE NON-CONSERVATIV .

I e DURING EDSFI, WALKDOWNS OF EOPs TO VERIFY ACCElrrABILITY OF RESULTING DG LOADING WERE COhiPLETED. THESE RESULTED IN A DETERMINATION THAT DG WOULD STILL NOT BE OVERLOADE '

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o EOPs LOAD TABLES WERE CORRECTED BY REVISIO e SEVERAL EOPs WERE REVISED TO PROVIDE BETTER GUIDANCE TO OPERATORS FOR CONTROL OF DG LOADIN e TRAINING WAS CONDUCTED FOR ALL LICENSED OPERATORS AND DTAs FOR DG LOAD MANAGEMENT DURING USE OF EOP .

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" l APPARENT VIOLATION 1B 4160 VOLT TIE BREAKERS o ORIGINAL PLANT DESIGN INCLUDED A SINGLE TIE BREAKER BETWEEN THE 4160 VOLT SAFEGUARDS BUSES ON EACII UNIT. TIE CONTROL i i

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CIRCUIT INCLUDED AN INTERLOCK TO PREVENT CONNECTION OF A DIESEL TO EITIER BUS WlEN THE TIE BREAKER WAS CLOSE ,

o IN 1987, WESTINGHOUSE ISSUED A PART 21 CONCERNING THE USE OF SINGLE CELL SWITCH TO PROVIDE THIS INTERLOCK. THIS WAS I

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FOLLOWED BY NRC IN 87-61.

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o WISCONSIN ELECTRIC REh10VED THIS INTERLOCK BY C0hiPLETION OF h10DIFICATION REQUESTS87-205 AND 87-206. tills MODIFICATION ALSO

INCLUDED PLACING TIE TIE BREAKERS IN TIE RACKED OUT POSITION AND TIE CREATION OF ADhilNISTRATIVE CONTROLS FOR THEIR US ,

o TIESE h10DIFICATION REQUESTS DID INCLUDE A FINAL DESIGN VERIFICATION PER QP 3-1. HOWEVER, THIS REVIEW DID NOT INCLUDE AN EVALUATION OF TIE SEISMIC ACCEIFI' ABILITY OF BREAKERS IN TIE RACKED OUT POSITIO O EDSFI INSPECTORS QUESTIONED TIE ACCEPTABILITY OF THIS ARRANGEh1EST, ESPECIALLY THE POTENTIAL FOR DAhiAGE TO RELAYS h10UNTED ON TIE DOOR OF THE BREAKER CUBICLE DURING A SEIShilC EVEN * TIIE TIE BREAKERS WERE REh!OVED FROh! THE CUBICLES AND PLACED IN STORAG e SUIISEQUENT EVALUATION INDICATES TIIAT ONLY G01 DIESEL GENERATOR WOULD BE POTENTIALLY AFFECTED BY RELAY DAhiAGE DURING A SEIShilC EVENT.

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APPARENT VIOLATION IC 480 VOLT TIE BREAKERS

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o ORIGINAL PLANT DESIGN INCLUDED A SINGLE TIE BREAKER BETWEEN

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480 VOLT SAFEGUARDS BUSES. TIE COhTROL CIRCUIT FOR TIUS BREAKER INCLUDED TRIPPING OF TIE BREAKER ON A SAFETY INJECTION SIGNA ,

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o h10DIFICATION REQUESTS85-053 AND 85-054 WERE COhiPLETED TO ADDRESS TIE POTENTIAL FAILURE OF THESE BREAKERS TO OPEN UPON SAFETY INJECTION DUE TO TIE FACT THAT THE TRIP SIGNAL WAS RECEIVED FROh! ONLY ONE TRAIN OF SAFETY INJECTION LOGI O EDSFI INSPECTORS POSTULATED SPURIOUS CLOSURE OF BREAKER DUE TO A FAILURE IN THE CONTROL CIRCUIT.

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o WISCONSIN ELECTRIC HAS PREVENTED SPURIOUS CLOSURE OF EITIER OF TIESE BREAKERS BY REh10VING TIE FUSES IN TIE DC CONTROL POWER SUPPLY TO TIE BREAKERS.

o IN ADDITION, ADhilNISTRATIVE CONTROLS HAVE BEEN ESTABLISIED '

TO CONTROL USE OF THESE BREAKER ,

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APPARENT VIOLATION 1D

, l CABLE SEPARATION - CCW PUhiPS )

o TIIE DESIGN OF TIIE CCW PUhfP CONTROL CIRCUITS IS ORIGINAL PLAhT DESIGN. TIIIS INCLUDES AN AUTOSTART FEATURE WIIICil CAUSES START OF TIIE NON RUNNING PUhiP UPON LOW IEADER PRESSUR o CCW SYSTEh! AT PBNP WAS NOT ORIGINALLY DESIGNATED AS A l

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SAFETY-RELATED SYSTEh l o FAILURE OF TIE CONTROL CIRCUITS FOR BOTII PUhfPS WILL NOT RESULT IN TIIE TRIPPING OF TIE RUNNING PUhfP NOR WILL IT

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PREVENT hiANUAL CLOSING OF TIE SUPPLY BREAKER FOR EITIIER PUhf :

o TIIE SAFETY-RELATED FUNCTION OF TIE CONTROL CIRCUIT IS STRIPPING OF CCW PUMPS FROM TIIE SAFEGUARD BUSES ON LOSS OF AC AND SAFETY INJECTIO O TEhfPORARY h10DIFICATIONS WERE COhiPLETED TO PREVENT I

SIhfULTANEOUS FAILURE OF BOTil PUhiPS.

l 0 PERhiANENT h10DIFICATIONS WILL BE COhfPLETED TO ACCOhfPLISil ADEQUATE CABLE SEPARATION. TIESE h10DIFICATIONS WILL BE i COh!PLETED BY TIIE END OF EACII UNIT'S NEXT REFUELING OUTAGE.

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APPARENT VIOLATION 1E A

_ FW PUhiP - CABLE SEPARATION

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, * INSTALLATION OF REDUNDANT CABLES IN TIE SAhE RACEWAY WAS PART OF ORIGINAL PLANT DESIGN TIESE CABLES ARE PART OF THE ,

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START CIRCUITRY FOR TIE UNIT 2 STEAh! DRIVEN AND THE hf0 TOR I DRIVEN AFW PUbiPS WHICII RESULT IN PUhiP START UPON LOSS OF l

VOLTAGE TO THE NON-SAFETY RELATED 4160 VOLT BUSES WHICH

SUPPLY hiAIN FW PUhfP * FAILURE OF TIIESE CABLES WOULD NOT AFFECT TIE LOW-LOW STEAh!

GENERATOR LEVEL START CIRCUITRY FOR THE UNIT 2 STEAh! DRIVEN  ;

AFW PUh1P NOR WOULD IT AFFECT hiANUAL OPERATIO I

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l e FAILURE OF TIESE CABLES WOULD NOT AFFECT TIE LOW-LOW STEAh!

GENERATOR LEVEL START CIRCUITRY FOR THE hf0 TOR DRIVEN AFW

PUhfPS NOR WOULD IT AFFECT hiANUAL OPERATION OR START UPON SI ACTUATION.

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• THE UNIT WAS PLACED IN AN LCO CONDITION DUE TO A

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DETERhf1 NATION THAT TIE UNIT 2 STEAh! DRIVEN AFW PUhfP WAS NOT OPERABLE. h!ODIFICATION REQUEST 90-111 WAS COhfPLETED ON 4/5/90 l

AND TIE PUh1P RETURNED TO SERVICE. NO FURTHER ACTION IS l PLANNED.

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APPAREST VIOLATION IF DIESEL GENERATOR FUEL OIL SYSTEh!

SEIShilC 1 CLASSIFICATION o ORIGINAL PLANT CONSTRUCTION

- SEISMIC CATEGORY 1 FUEL OIL STORAGE TANK 1

- TRANSFER PIPING APPARENTLY NOT SEIShilCALLY ANALYZED

- LICENSING QUESTIONS / RESPONSES REFER TO BOTH EhERGENCY AhT ABOVE GROUND TANKS AS BEING SOURCE OF FUEL OIL

- ORIGINAL DESIGN / LICENSING BASIS IS NOT CLEAR AND CAhWOT BE ESTABLISIED o CURIENT STATUS )

- DECISION IIAS BEEN hiADE TO UPGRADE SYSTEh! TO SAFETY-RELATED 1

! - TRANSFER PIPING HAS BEEN EVALUATED AND SUPPORTS INSTALLED 1 IN PUhiPHOUSE

, - SEVERAL MINOR SUPPORT ADDITIONS /h10DIFICATIONS WILL BE COhfPLETED DURING THE CURRENT REFUELING OUTAGE >

- PUhfPIlOUSE (EXCEPI' BLOCKWALL PORTION) VERIFIED AS SEIhfSIC CATEGORY 1 l - BLOCKWALLS JUDGED TO BE CAPABLE OF WITHSTANDING SEIShilC EVENT AND WILL BE EVALUATED FURTHER

- ANALYSIS AND ADDITIONAL SUPPORT OF OTIER FUEL OIL AND t

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WATER PIPING IN THE PUh1PIIOUSE WILL BE EVALUATED TO ADDRESS FLOODING CONCERNS

- POWER SUPPLIES TO TIE FUEL OIL TRANSFER PUhiPS JUDGED TO WITIISTAND'SEIShilC EVENT AND WILL BE EVALUATED FURTIER

- REASONABLE ASSURANCE OF SEIShilC CAPABILITY l

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APPARENT VIOLATION #2 CALIBRATION OF SAFETY-RELATED PROTECTIVE RELAYS

• PROTECTIVE RELAY CALIBRATIONS ARE CONTROLLED AS PART OF l

'I REFUELING hiAINTENANCE ACTIVIT RELAY TECHNICIANS PERFORhiING THE WORK ARE FROM THE WE ELECTRICAL TESTING AND hiAIhTENANCE GROU * TIIIS ACTIVITY HAS BEEN SUBJECT TO PAST AUDITING AND VERIFICATION ACTIVITIES. PREVIOUS DEFICIENCIES HAD BEEN IDENTIFIED AND CORRECTE '

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USE OF COhiPONENT INSTRUCTION hiANUALS WHICH WERE NOT

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CONTROLLED PER ESTABLISHED PROCEDURES

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REPLACEMENT PARTS WERE NOT CONTROLLED UNDER THE QA PROGRAM

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USE OF UNCONTROLLED hfULTI-AhiP EQUIPhiENT ,

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o IMMEDIATE ACTIONS TAKEN AS A RESULT OF EDSF1 INSPECTOR CONCERN IMMEDIATE STOPPAGE OF 'VORK ON SAFETY-RELATED AND TEC SPEC. RELAY EXISTING WORK PROCEDURES FOR TECH. SPEC. RELAYS WERE REVIEWE SE1 TINGS FOR SAFETY-RELATED NON-TECH. SPEC. RELAYS WERE DETERMINE CALIBRATION STATUS OF TEST INSTRUMENTATION TO BE USED WAS EVALUATED. ACCEI'I' ABLY CALIBRATED EQUIPMENT WAS IDENTIFIED AND USE EVALUATED PAST USEAGE OF SPARE PARTS FOR RELAY REPAIR WE SYSTEM PROTECTION RELAY SETTINGS FOR UNIT 1 WERE COMPARED TO PBNP SETPOINT DOCUMENT.

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,' APPARENT VIOLATION #2 CALIBRATION OF SAFETY-RELATED PROTECTIVE RELAYS (continued)

o ADDITIONAL ACTIONS IN PROGRESS FOR FUTURE RELAY CALIBRATION FORhiALLY VERIFY UNIT 2 RELAY SETPOINTS AND COh1 PARE TO PBNP SETPOINT DOCUhiEN DEVELOP WORK PROCEDURES FOR SAFETY-RELATED NON-TECH, SPEC. RELAYS,

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QA INDOCTRINATION OF RELAY TECHNICIAN PROCURE RELAY COhiPONENT SPARE PARTS IN ACCORDANCE WITH QA PROCEDURE FORhiALIZE THE CALIBRATION PROGRAh! FOR TEST EQUIPhiES e QA SURVEILLANCE OF RELAY CALIBRATIONS WILL BE PERFORhfED DURING UPCOhilNG UNIT 2 REFUELING OUTAGE AND SUBSEQUENTLY AS DETERhflNED NECESSAR i

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,' APPARENT VIOLATION #3 INVERTER TEST PROCEDURE j l

l o TECHNICAL SPECIFICATION SECTION 15.6.8 REQUIRES THAT THE PLANT WILL BE OPERATED AND hiAINTAINED IN ACCORDANCE WITH l APPROVED PROCEDURES INCLUDING THOSE WHICH INVOLVE SURVEILLANCE AND TESTING OF SAFETY-RELATED EQUIPhiENT.

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o SIX ELGAR INVERTERS WERE INSTALLED IN 1984 TO PROVIDE UPS FOR 3RD AND 4TH INSTRUhfENTATION CHANNELS. THESE INVERTERS HAVE A FEATURE WHEREBY THE INVERTER SHUTS DOWN SHOULD THE DC INPUT VOLTAGE FALL BELOW A PRE-SET LEVEL.

l o STARTUP AND CHECKOUT OF THESE INVERTERS DID NOT INCLUDE CALIBRATION OF THIS FEATUR O RhfP 45 WAS CREATED FOR PERIODIC hiAINTENANCE AND SURVEILLANCE OF THE INVERTERS. THIS DID NOT INCLUDE CALIBRATION OF THIS SHUTDOWN FEATURE.

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.' APPARENT VIOLATION #3 INVERTER TEST PROCEDURE (continued) .

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o EDSFI INSPECTORS QUESTIONED WIETIER SUCH A FEATURE EXISTED ON PBNP INVERTERS AND WIETIER THE SHUTDOWN AT DC VOLTAGES HIGIER TIIAN 105 VOLTS COULD RESULT IN THE INVERTERS SHU1 TING DOWN PRIOR TO TIE 1 IIOUR DESIGN CAPABILITY OF THE STATION BATTERIE O CONVERSATIONS WITH ELGAR INDICATED THAT SUCH A FEATURE WAS i PRESENT ON PBNP INVERTERS AND THAT IT WAS FACTORY PRE-SET AT 105 VDC. IT WAS ALSO DETERhilNED THAT THIS FUNCTION WAS NOT NECESSARY IN AN APPLICATION SUCH AS THAT AT PBN O EACl! OF TIE SIX INVERTERS WAS TESTED TO DETERhiINE THE AS-FOUND SETTING OF THE CUTOFF FEATURES. WITH THE EXCEFI' ION OF

1DYO3, ALL INVERTERS WERE FOUND TO HAVE SETTINGS BELOW 105 VDC.1DY03 WAS FOUND TO HAVE A SE'ITING OF 110.84 VDC. ALL INVERTERS WERE ADJUSTED TO HAVE DC VOLTAGE CUTOFFS OF l APPROXIhiATELY 100 VDC.

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0 hil 17.3.1 WILL BE ISSUED AND RhiP 45 WILL BE REVISED. THIS hiAINTENANCE INSTRUCTION WILL INCLUDE CALIBRATION OF THE LOW l VOLTAGE CUTOFF FEATUR _

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, APPARENT DEVIATION

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CABLE TRAY FILL

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I o ALLOWABLE CABLE TRAY FILL IS ADDRESSED IN TWO DIFFERENT SECTIONS OF TIE FSAR. SECTION 7 LIhilTS CABLE TRAY FILL TO 30%

FOR POWER AND CONTROL CABLES. SECTION 8 ALLOWS 40% FIL BOTII SECTIONS REFERENCE hETHODS FOR DERATING OF CABLES BASED NOT ON PERCENTAGE FILL, BUT ON NUhfBER OF CABLE '

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0 ORIGINAL BECHTEL DESIGN CRITERIA BASED CABLE SIZE SELECTION ON A hiAXIhiUhi OF 24 CONDUCTORS IN A TRAY WIUCH RESULTED IN A DERATING FACTOR OF 0.7.

l o WISCONSIN ELECTRIC COMPLETED A DATA BASE SEARCH AND IDENTIFIED 210 CABLE TRAYS WITII FILL GREATER THAN 30%.

O CABLES LARGER THAN 250 KChilL ARE INSTALLED IN TRAYS WITH hiAINTAINED SPACING.

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o hiANY OF THE INSTALLATIONS WIUCII EXCEED 30% FILL ARE ORIGINAL PLANT AND ALSO DO NOT CONFORhi TO BECHTEL CRITERIA OF A hiAXIhiUh! OF 24 CABLES.

l l 0 WISCONSIN ELECTRIC ISSUED INTERIh1 GUIDANCE TO ALL DESIGN . ENGINEERS TO LIhilT CABLE TRAY FILLS TO 30%.

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o WILL EVALUATE EACH OF THE 210 EXISTING CASES OF FILL GREATER TIIAN 30%. I o- WILL ISSUE FORhiAL GUIDANCE ON ALLOWABLE CABLE TRAY FIL FSAR WILL BE REVISED TO RESOLVE INCONSISTENCY.

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DISCUSSION OF NRCISSUES

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ISSUE #1 CLASSIFICATION OF PLANT SYSTEhiS AND COhfPONENTS I

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o SYSTEhtS AND COhfPONENTS MTRE ORIGINALLY CLASSIFIED IN ACCORDANCE WITH PLANT DESIGN BASIS, DESIGN STANDARDS, AND ACCEITED DEFINITION OF SAFETY-RELATED AS LICENSED IN 197 I o APPENDIX B WORK COhiPLETED IN EARLY 1970s. THE SCOPE OF SAFETY-  !

RELATED WAS USED TO DEFINE QA SCOP I o SYSTEh!S THAT IIAVE SINCE BEEN RECLASSIFIED AS SAFETY-RELATED INCLUDE:

- SPENT FUEL POOL COOLING SYSTEh! I

- IN-CORE THERh!OCOUPLES l

0 SYSTEh1S THAT ARE IN THE PROCESS OF BEING UPGRADED TO SAFETY-RELATED INCLUDE:

l - COhfPONENT COOLING WATER SYSTEh!

- EDG FUEL OIL SYSTEM o SYSTEh1S WIIICH HAVE BEEN EVALUATED TO VERIFY APPROPRIATE l SAFETY CLASSIFICATION:

- INSTRUMENT AIR SYSTEh!

- LIQUID AND GASEOUS RADWASTE SYSTEMS

- AUXILIARY FEEDWATER SYSTEMS

- CONTAINMENT ISOLATION COMPONENTS

- EDG SUPPORT SYSTEMS AIR STARTING SYSTEM EDG DC SUPPLY EDG ROOM VENTILATION EDG COOLING SYSTEMS

- RADIATION MONITOR: '3 SYSTEM

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- SERVICE WATER

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ISSUE #1

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CLASSIFICATION OF PLANT SYSTEhiS AND COMPONENTS (continued) ,

o SYSTEMS WE EXPECT TO EVALUATE FOR PROPER CLASSIFICATION IN -

TIIE NEAR FUTURE:

- CONTROL ROOM AND AUXILIARY BUILDING HVAC

- PLANT CABLING o DETAILED REVIEW OF Q LIST HAS RAISED A QUESTION REGARDING .

SAFETY-RELATED SCOPING OF A FEW COMPONENT * SAFETY SIGNIFICANCE

- NO SIGNIFICANT SAFETY CONCERNS

- PRIOR, CURREhT, AND PLANNED WORK ENHANCES SAFETY BEYOhT t ORIGINAL LICENSED BASI TIIOSE SYSTEMS BEING RESCOPED llAVE BEEN WELL MAINTAINE UPGRADING IIAS IIAD NOMINAL IMPACT ON WORK CONTROL * ROOT CAUSES

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TIIE ROOT CAUSE OF TIIE ISSUE IS THE DIFFERENCES BETWEEN AS-BUILT PLANT AND TODAY'S STANDARD * CORRECTIVE ACTIONS

- PRIOR, CURRENT, AND PLANNED SYSTEM REVIEW l u

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r .,- ISSUE #2 QA SCOPING OF SAFETY-RELATED COhfPONENTS AND SYSTEhiS o COhiPONENTS AND SYSTEhiS CURRENTLY CLASSIFIED AS SAFETY-RELATED ARE QA-SCOP O THE Q-LIST COhTAINED WITIHN CHAhiPS IDENTIFIES THE SAFETY-RELATED AND QA-SCOPE STATUS OF COh1PONENT o ACTIVITIES ASSOCIATED WITH SAFETY-RELATED SYSTEhiS AND COhfPONESTS ARE CONTROLLED UNDER THE QUALITY ASSURANCE PROGRAh!.

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.. ISSUE #3

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WEPCO INITIATED OR PROPOSED CORRECTIVE ACTIONS

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l 0 WE CONCERNS WITH ADEQUACY OF DESIGN INFORhiATION FOR ELECTRICAL SYSTEht .

O IhiPELL ANALYSIS AND DATABASE DEVELOPhfEN .

O SSFI CONDUCTED ON EMERGENCY DIESEL GENERATOR O DESIGN BASIS DEVELOPhiENT ACTIVITIES. INITIAL EhiPHASIS ON ELECTRICAL SYSTEh1 O UPGRADING OF EXISTING DATABASES AND SOFTWARE (CARDS).

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l ISSUE #3 WEPCQ_ INITIATED OR PROPOSED CORRECTIVE ACTIONS (continued)

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o CARDS UPDATES / REVIEWS WOULD BE EXPECTED TO IDENTIFY THE ;

MAJORITY OF THE EDSFI SEPARATION ISSUE O DESIGN BASIS DEVELOPAEhT, IMPELL ANALYSIS, AND AS-BUILT ACTIVITIES WOULD BE EXPECTED TO IDENTIFY TIE hiAJORITY OF THE i EDSFI INADEQUATE DESIGN CONTROL ISSUE O WESTEC SSFI AND OTHER WEPCO AUDITS IDENTIFIED SEVERAL OF THE SAME ISSUE .

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ISSUE #3 WEPCO INITI ATED OR PROPOSED CORRECTIVE ACTIONS (continued)

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0 WE CONCERNS NOT LIhilTED TO ELECTRICAL SYSTEht l o DESIGN BASIS DEVELOPhiENT IS DIRECTED TO IMPORTANT hiECIIANICAL, ELECTRICAL, AND STRUCTURAL SYhTEhi I O hfETilODICAL EVALUATION OF SYSTEhiS FOR UPGRADING TO QA AND/OR SAFETY-RELATED.

. 1 o RESPONSE TO INDUSTRY OPERATING EXPERIENCE (h10VS, ETC.).

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O EXPANDED SCOPE OF NCR PROCES >

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l' ISSUE #4 IEB 79-14 PROGRAh_f SCOPE ,

o ALL SAFETY RELATED PIPING SYSTEhtS 2-1/2" AND GREATER IN )

DIAhiETER AND OTIER PIPING, REGARDLESS OF SIZE, WHICH WAS

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COhiPUTER ANALYZE O TIE IEB 79-14 PROGRAh! FOR POINT BEACH WAS BASED UPON THIS

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. SCOPE AND A THOROUGH SEARCII OF PLANT RECORDS.

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O IN ADDITION TO SAFETY-RELATED PIPING, PORTIONS OF STEAhi, FEEDWATER, CVCS AND RADIOACTIVE WASTE SYSTEhiS, THE l

COhiPONENT COOLING WATER SYSTEhi, AND THE SPENT FUEL POOL

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COOLING SYSTEh! WERE INCLUDED.

0 FUEL OIL PIPING WAS EXCLUDED BECAUSE IT WAS DESIGNATED NON-SAFETY RELATED, WAS LESS THAN 2-1/2" IN DIAhfETER, AND HAD NOT BEEN COhiPUTER ANALYZED.

. o WE BELIEVE IT IS UNLIKELY THAT OTIER SYSTEhtS EXIST WHICH WOULD IIAVE hiET TIIE SCOPING CRITERIA FOR IEB 79-14.

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" ? ISSUE #4 IEB 7914 PROGRAhi SCOPE (continued)

o WE BELIEVE TIERE IS NO SAFETY SIGNIFICANCE REGARDING TIIE IEB 79-14 PROGRAh! SCOPE.

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O TIE ROOT CAUSE OF NOT INCLUDING FUEL OIL PIPING WAS TWOFOLD: '

- NON-SAFETY RELATED DESIGNATION AND <21/2" IN DIAhETER

- ORIGINAL LICENSING BASIS FOR THIS SYSTEM WAS NOT WELL DOCUhiENTED I

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l 0 CORRECTIVE ACTIONS WIUCII IIAVE BEEN OR ARE BEING TAKEN: l

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FUEL OIL SYSTEM UPGRADE EVALUATION ACTION REQUEST WAS ISSUED IN 1989 AND COhiPLETED IN JULY 1990 i

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DECISION TO UPGRADE SYSTEh! J

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PIPING ANALYZED AND SUPPORT SYSTEh! UPGRADED IN 1990 l

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FURTIIER EVALUATIONS OF STRUCTURES AND POWER SUPPLIES IIAVE BEEN SCIEDULED IN ACCORDANCE WITH OUR kESPONSE TO-TIE NRCs EDSFI l

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.- .,- ISSUE #6 DBD PROGRAM STATUS PLANNING PIIASE ACTIVITIES o NEEDS & USES ANALYSIS - COMPLETED 5/18/90 0 INFORhiATION SYSTEMS ASSESShiENT - COMPLETED 6/15/90 0 CONFIGURATION hiANAGEhiENT SYSTEM RECOMhENDATIONS -

COMPLETED 8/29/90

• DBD WRITER'S GUIDE -IN FINAL REVIEW

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• PROGRAM SCOPE & DEVELOPMENT SEQUENCE RECOMMENDATIONS -

REVIEW IN PROGRESS i i

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DBD PROGRAM STATUS l kontinued} l l

PROGRAh! ACTIVITIES i l 0 TWO-LOOP E PLANT - JOINT DBD DEVELOPhiEST - STARTED 8/90 l 0 DBD DEVELOPhfENT BID SPECIFICATION - REVIEW IN PROGRESS

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O PROGRAh! IMPLEhiENTATION PROCEDURES - DRAFT IN PROGRESS o CONFIGURATION MANAGEMENT SYSTEh! IMPLEMENTATION - 1990/1991 o DEVELOP & EXECUTE PILOT PROGRAM - 1990/1991 0 DBD PRODUCTION - 1991 THROUGH 1997 l

0 DESIGN BASIS VALIDATION - 1991 THROUGH 1997 o DBD LIFE-CYCLE MAINTENANCE - 1991 AhT BEYOhT l-l  ;

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ISSUE #6 ELECTRICAL SYSTEM ANALYSIS PURPOSE

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e TO COLLECT THE DATA REQUIRED TO SUPPORT EVALUATION OF THE ADEQUACY OF THE ELECTRICAL DISTRIBUTION SYSTEMS AT POINT BEACH NUCLEAR PLAN * TO CREATE A COMPUTERIZED DATA BASE TO RETAIN THE INFORMATION COLLECTED. THIS DATA BASE TO BE MADE AVAILABLE TO ALL NECESSARY PERSONNEL. . TIES PROMOTES CONSISTENT EVALUATIONS THROUGH USE OF A COMMON DATA BAS e TO OBTAIN SOFTWARE CAPABLE OF PERFORhBNG ELECTRICAL DISTRIBUTION SYSTEM ANALYSIS'USING THE DATA RETAINED IN THE COMPUTERIZED DATA BASE. USE OF THIS SOFTWARE WILL PROMOTE'

CONSISTENT METHODOLOGY IN SYSTEM EVALUATION e TO COMPLETE INITIAL EVALUATIONS OF THE ADEQUACY OF ELECTRICAL DISTRIBUTION SYSTEMS AT PBN * TO DEVELOP THOSE ADMINISTRATIVE CONTROLS NECESSARY TO ASSURE ADEQUATE MAINTENANCE OF THE DATA BASE AND TO ASSURE CONSISTENT AND PROPER USE IN THE EVALUATION OF EXISTING PLANT

. CONFIGURATION, THE ACCEI'I' ABILITY OF PLANT MODIFICATIONS, OR CHANGES IN PLANT OPERATIO .

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ISSUE #6 ELECTRICAL SYSTEM ANALYSIS ANALYSIS AREAS Lo EVALUATION OF THE EFFECTS OF A LOSS OF ONE OF THE PLANT DC SYSTEhiS OR OF A PART THEREO e EVALUATION OF TIE ELECTRICAL LOADING ON PLANT ELECTRICAL DISTRIBUTION COhiPONENTS UNDER SPECIFED PLANT CONDITION e DETERhflNATION OF THE ELECTRICAL LOAD CARRYING CAPABILITY OF ELECTRICAL DISTRIBUTION SYSTEM EQUIPhENT, INCLUDING DOCUhfENTATION OFTHE BASIS FOR SUCH RATING * EVALUATION OF THE VOLTAGE LEVELS AVAILABLE AT VARIOUS LOCATIONS ON TIE ELECTRICAL DISTRIBUTION SYSTEMS UNDER SPECIFIED PLANT LOADING CONDITIONS AND CONFIGURATION e DETERMINATION OF TIE AVAILABLE SHORT CIRCUIT CURRENTS FOR VARIOUS TYPES OF FAULTS AT SPECIFED LOCATIONS ON THE DISTRIBUTION SYSTEM e EVALUATION OF THE ADEQUACY OF ELECTRICAL PROTECTION OF EQUIPMENT AND TIE SELECTIVE COORDINATION OF PROTECTIVE DEVICE * TIIESE ANALYSES WILL INCLUDE IMPORTANT PLANT DISTRIBUTION SYSTEMS WITII TIE EXCEPTION OF TIE LOSS OF DC EVALUATIO . . .__ . _ _ . . . . _ _ _ . _

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ISSUE #6 ,

ELECTRICAL SYSTEh! ANALYSI DATABASE ,

o DATABASE INFORhiATION WILL BE OBTAINED FROh! EXISTING CONTROLLED PLANT INFORhiATION SOURCES. WHERE h10RE THAN ONE SOURCE EXISTS, CROSS-CHECKING WILL BE INCLUDE * DATABASE WILL INCLUDE PROVISIONS FOR DOCUhiENTATION OF THE ,

SOURCES OF INFORh1ATIO :

• DATABASE WILL BE CONSIDERED CONTROLLED INFORhiATION AND !

APPROPRIATE ADMINISTRATIVE CONTROLS WILL BE ESTABLISHED.- .

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ELECTRICAL SYSTEM ANALYSIS ,

STATUS AND SCHEDULE I

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l 0 A CONTRACT WAS AWARDED TO IhfPELL CORPORATION IN NOVEMBER L OF 1988 TO COhiPLETE TIUS WOR l

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o LOSS OF DC STUDY - DATA COLLECTION WILL BE COMPLETED IN i

NOVEMBER 1990. DATA ENTRY AND COMPLETION OF EVALUATIONS WILL BE COMPLETED BY MAY OF 199 ]

o ELECTRICAL LOADING EVALUATIONS - DATA GATIERING NECESSARY

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TO SUPPORT A DIESEL GENERATOR LOADING CALCULATION AND i l- CREATION OF TIE CALCULATION WAS COMPLETED IN APRIL 199 !

DATA GATIERING AND ENTRY NECESSARY-TO SUPPORT ANALYSIS OF LIMITED PORTION OF THE 480 VOLT AND HIGHER VOLTAGE SYSTEMS l WILL BE COMPLETED BY FEBRUARY 1991. DATA GATHERING FOR i

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REMAINING AC SYSTEMS AND DC SYSTEhiS WILL BE COMPLETED BY '

THE END OF 199 o DETERMINATION OF THE ELECTRICAL CAPACITY OF DISTRIBUTION SYSTEM EQUIPMENT WILL BE COMPLETED BY SEPTEMBER 1991.

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o VOLTAGE LEVEL, AND SHORT CIRCUIT CURRENT ANALYSIS WILL BE COMPLETED FOR THE LIMITED 480 VOLT AND ABOVE SYSTEMS BY APRIL OF 1991, ANALYSIS FOR REMAINING SYSTEMS WILL BE'

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COMPLETED BY APRIL OF 1992.

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.. ISSUE #6 ELECTRICAL SYSTEh! ANALYSIS STATUS AND SCIEDULE (continued)  !

I o h1OST OF THE DATA NECESSARY TO SUPPORT TIE EVALUATION OF PROTECTION AND SELECTIVE COORDINATION HAS BEEN COLLECTE EVALUATIONS WILL BE COhfPLETED BY JULY 199 .

O IT IS AhTICIPATED THAT TIE DATA BASE WILL BE AVAILABLE FOR USE'

BY WISCONSIN ELECTRIC EARLY IN 1991. INITIALLY, THIS WILL CONTAIN ONLY LIhilTED INFORhiATION.

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l o DEVELOPhfENT OF TIE DATA BASE, ENTRY OF DATA, AND ,

DEVELOPhfENT OF THE EXECUTIVE CONTROL PROGRAh! WILL BE COhfPLETED AS NECESSARY TO SUPPORT TIE ABOVE SCIEDUL >

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ISSUE #6 ELECTRICAL SYSTEM ANALYSIS FINDINGS 0 FINDINGS DISCOVERED AS A RESULT OF EVALUATIONS OF THE ADEQUACY OF TIE ELECTRICAL DISTRIBUTION SYSTEMS WILL BE FORWARDED TO WISCONSIN ELECTRIC IN WRITING AND WILL BE RESOLVED IN ACCORDANCE WITH APPROPRIATE WISCONSIN ELECTRIC QA PRACTICE O TO DATE, FINDINGS GENERATED AS A RESULT OF THIS EFFORT HAVE CONSISTED OF DOCUMENT / DRAWING DISCREPANCIE .

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[ .- . ISSUE #6 CABLE AND RACEWAY SYSTEhi l

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o A COMPUTERIZED CABLE AND RACEWAY DATA SYSTEM WAS PUFCHASED FROM EPM CORPORATION IN 1986.

o ORIGINAL DATA INPUT INCLUDED ORIGINAL PLANT DATA OBTAINED FROM BECHTE ' o INFORMATION HAS BEEN UPDATED TO INCLUDE THE EFFECTS OF MODIFICATIONS COMPLETED SINCE 198 ' o IN LATE 1989, WE CONTRACTED WITH EPM TO PROVIDE AN UPGRADED REVISION OF THE CARDS SOFTWAR "

e THIS UPGRADE INCLUDES IMPLEMENTATION OF THE PROGAM CAPABILITIES TO AUTOMATICALLY EVALUATE THE ADEQUACY OF ELECTRICAL CABLE SEPARATIO * DELIVERY -AND INSTALLATION OF THE UPDATED SOFTWARE IS ANTICIPATED IN EARLY 199 A

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.: ISSUE #6 l CABLE AND RACEWAY SYSTEM l (continued)

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I o A SEPARATE PROJECT HAS BEEN INITIATED WITH IhiPELL TO DETERhiINE AND ENTER INTO THE DATA BASE THAT ADDITIONAL CABLE AND RACEWAY INFORhiATION WHICH hiAY NOT HAVE BEEN INCLUDED IN THE ORIGINAL PLANT DATA PROVIDED BY BECHTEL OR IS 1 DUE TO MODIFICATION OF THE PLANT PRIOR TO PURCHASE OF THE l SOrrWAR ;

i o AN ADDITIONAL PROJECT IS BEING INITIATED TO VERIFY THE L ACCURACY OF THE EXISTING DATA IN THE CARDS DATA BASE WHICH IS

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UTILIZED TO DEh10NSTRATE ADEQUATE PHYSICAL SEPARATION. IT IS ANTICIPATED THAT THIS EFFORT WILL BE COhiPLETED DURING 1991.

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o IN GENERAL, FINDINGS OF INACCURACIES IN THE CARDS SYSTEhi DATA HAVE BEEN INVESTIGATED AND CORRECTED TO CORRESPOND TO THE L

AS-BUILT PLANT CONDITIONS. SEVERAL SITUATIONS WHERE IT r APPEARS THAT CABLES HAVE BEEN hiISCLASSIFIED AS NON-SAFETY RELATED ARE BEING ADDRESSED PER THE NCR PROCESS. IN ADDITION, AN ACTION REQUEST HAS BEEN INITIATED TO EVALUATE TH t ADEQUAC?l OF SAI<ETY-RELATED CABLE CLASSIFICATION AS ..

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CONTAINED IN THE CARDS DATA BAS '

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o IILcTORY OF WORE WIIICH EXAMINED SYSTEM FUNCTIONALITY o 79-14 REVIEWED ALL SAFETY-RELATED PIPING SYSTEMS 2-1/2" IN DIAMETER AND GREATER. ALL SYSTEMS OPERABL l e REVIEWED THE AVAILABILITY OF DESIGN INFORMATION FOR MECHANICAL, ELECTRICAL, AND STRUCTURAL SYSTEM i

• FROM THIS REVIEW OF AVAILABLE DESIGN INFORMATION, IT WAS DETERMINED THAT THE ELECTRICAL SYSTEMS HAD LESS DESIGN AND DESIGN BASIS INFORMATION AVAILABLE THAN OTHER SYSTEM *.THE CCW AND SERVICE WATER SYSTEMS WERE REVIEWED AND EVALUATED IN RESPONSE TO WE INTERNAL REVIEW * STARTED ELECTRICAL SYSTEMS ANALYSIS WORK WITH IMPELL.IN-NOVEMBER 198 * COMPLETED CCW SYSTEM REVIEW IN 198 ,

• COMPLETED SERVICE WATER SYSTEM REVIEW IN 199 * FOUR SSFIs COMPLETED OR IN PROGRES l

-- EMERGENCY DIESEL GENERATOR (1988)

- RESIDUAL HEAT REMOVAL (1988)

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- CONTAINMEN'I' SYSTEMS (1989)

- AbXILIARY FEEDWATER SYSTEM (1990) - STILL IN PROGRESS-

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, - FUNCTIONALITY OF SYSTEMS [

(continued)

o EMERGENCY DIESEL GENERATORS I

-- PERFORMED BY WESTEC SUPPLEMENTED WITII WE PERSONNEL '

- EXAMPLES OF ITEMS IDENTIFIED:

• DG LOADING 3

• 50.59 EVALUATIONS '

• BATTERY SIZING AND CAPACITY

• DC BREAKER SHORT CIRCUIT RATING

• DESIGN ENGINEERING INFORMATION i'

o RESIDUAL IEAT REMOVAL SYSTEM

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PERFORMED BY WE QA SECTION, SUPPLEMENTED BY CONTRACTOR . ,

AND WE PLANT PERSONNE ;

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EXAMPLES OF ITEMS IDENTIFIED:

L * EMERGENCY OPERATING PROCEDURES .

• SURVEILLANCE TESTING

• DECAY IIEAT. RATE CALCULATIONS

• SYSTEM ISOLATION FROM CONTAINMENT

• EQ-SCOPING OF EQUIPMENT h

• CCW IIEAT EXCHANGER FLOW

> o CONTAINMENT SYSTEMS

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PERFORMED BY WE QA SECTION, SUPPLEMENTED BY NPD

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ENGINEERING PERSONhT EXAMPLES OF ITEMS IDENTIFIED:

e . CONTAINMENT TRUSSES-

• CONTAINMENT ISOLATION ISSUES i p, *- SPRAY ADDITIVE FLOW RATE y

• SPRAY RING HEADER ANALYSIS i l'

o AUXILIARY FEEDWATER SYSTEM  !

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- IN PROGRESS

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WW ISSUE #7 i FUNCTIONALITY OF SYSTEMS (continuedt i e DBDs WILL LOOK AT ALL IhfPORTANT SYSTEMS

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• RESPONSE TO INDUSTRY ISSUES AND RESPONSE TO NON-CONFORhiANCE !

AND AUDIT FINDINGS CONTRIBUTE TO VERIFICATION OF SYSTEM I ~

FUNCTIONALITY. EXAhiPLES INCLUDE:

- AUXILIARY FEEDWATER (ThfI)

. REACTOR PROTECTION SYSTEM (SALEM - GL 83-28)

L - CHECK VALVES (SAN ONOFRE - INPO SOER)

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- ECCS (NRC IN 87-63 & 88-74)

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- MOVs (GL 88-10) ,

i e CONCLUSION CONCERNING SYSTEM FUNCTIONALITY

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L * PAST EXPERIENCE FROM NUMEROUS REVIEWS, INCLUDING THE EDSFI, HAVE DEMONSTRATED SYSTEM FUNCTIONALIT !

t e PROCESSES ARE IN PLACE TO ENSURE SYSTEM FUNCTIONALITY WILL.BE-REVIEWED IN THE FUTURE IF ISSUES ARE IDENTIFIE l J

• DBD PROGRAM WILL PROVIDE A SYSTEMATIC PROCESS WHICH WILL-. .

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ESTABLISH AND VERIFY SYSTEM DESIGN BASES. SYSTEM FUNCTIONALITY WILL BE PART OF THIS PROCES t w

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