ML17180A978
| ML17180A978 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 10/21/1994 |
| From: | Darrin Butler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17180A976 | List: |
| References | |
| 50-237-94-16, 50-249-94-16, NUDOCS 9410260108 | |
| Download: ML17180A978 (26) | |
See also: IR 05000237/1994016
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION I II
Reports No. 50-237/94016(DRS); No. 50-249/94016(DRS)
Docket Nos. 50-237; 50-249
Licensee:
Commonwealth Edison Company
Executive Towers West III
1400 Opus Place - Suite 300
Downers Grove, IL 60515
Licenses No. DPR-19; No. DPR-25
Facility Name:
Dresden Nuclear Power Station - Units 2 and 3
Inspection At:
Dresden Nuclear Power Station, Morris, IL
Inspection Conducted:
August 15 through September 16, 1994
Inspection Team:
D. Butler, Team Leader
R. Winter, Assistant Team Leader
NRC Consultants:
P. Eshleman, Parameter, Inc.
J. Leivo, Parameter, Inc.
Approved By:
DavT S. Butler
Approved By: H.GPid,~h~
Plant Systems Section
Inspection Summary
Inspection on August 15 - September 16. 1994 (Reports No. 50-237/94016CDRS):
No. 50-249/94016CDRS))
Areas Inspected: Special announced systems based instrumentation and control
inspection (SBICI) performed in accordance with NRC Inspection Procedure
93807.
Results:
The team considered the design and operation of the instrumentation
and control (I&C) loops reviewed and the I&C engineering and technical support
to be adequate. A summary of strengths and weaknesses in I&C system design
and engineering support are provided in the Executive Summary.
The team
identified one violation with two examples of inadequate post modification
testing (Section 4.2).
In addition, seven inspection followup items were
identified (Sections 3.2.1.b, 3.2.2, 3.3.1.b, 3.3.2.b, 3.4.1, 3.5.1, and
3.7.1.b) .
9410260108 941021
PDR ~-ADOCK 05000237
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TABLE OF CONTENTS
Executive Summary ................................................. .
1.0
2.0
3.0
4.0
5.0
6.0
Introduction ............................................... .
1
1
3
Action on Previously Identified Inspection Items ........... .
Instrument Loops Reviewed .................................. .
3 .1
Setpoint Calculation Methodology.....................
5
3.2
Suppression Pool (Torus) Temperature and Indication..
6
3.3
HPCI Initiation......................................
7
3.4
HPCI Turbine Trips...................................
10
3.5
HPCI Isolation Trips.................................
10
3.6
Condensate Storage Tank Leve 1 . . . . . . . . . . . . . . . . . . . . . . . .
11
3.7
ATWS Recirculation Pump Trip and ARI.................
11
3.8
ATWS Manual Initiation...............................
11
3.9
LPCI Initiation......................................
12
3.10
Reactor Water Level Narrow Range Indication..........
12
3 .11
Standby Gas Treatment Initiation.....................
13
Engineering and Technical Support .......................... .
13
16
16
Inspection Followup Items .................................. .
Exit Meeting . ....... * ....................................... .
Appendix A - Personnel Contacted
Appendix 8 - Requests for Information
. :
~-----------------------
EXECUTIVE SUMMARY
During August 15 through September 16, 1994, a U. S. Nuclear Regulatory
Commission (NRC) inspection team conducted a system based instrumentation and
control inspection (SBICI) at the Dresden Nuclear Power Station, Units 2
and 3.
The inspection focused on the design and configuration of selected
safety related and important to safety instrumentation and control (I&C)
systems and components.
The inspection purpose was to:
(1) determine if
selected instrument setpoints were properly derived such that automatic
actions would occur to prevent safety .limits from being exceeded;
(2) determine if calculations, supporting these setpoints, considered all
appropriate uncertainties; (3) determine if setpoint calculation methods were
technically consistent with accepted standards; and (4) evaluate I&C related
activities, engineering and technical support (E&TS), and self assessment.
Instrument loop selection was based on the predominant accident scenarios
identified in Dresden's individual plant examination (IPE) and updated final
safety analysis report (UFSAR).
The team considered the design and operation of the instrument and control
loops reviewed and I&C engineering technical support to be adequate.
However,
the team identified the following weaknesses:
o
Several instrument setpoint calculations contained various unverified
assumptions, carried inconsistent number precision through the
calculations, or utilized calibration procedure and calculation
tolerances that did not always agree.
o
Several instrument calculations did not identify the setpoint analytical
limit, or the environmental conditions that the I&C loops would
encounter in the event of an accident.
o
Two post modificaLiun tests did not demonstrate that modified systems
would perform satisfactorily in service.
The team concluded that increased management attention was warranted in I&C
design control areas, specifically in setpoint calculations.
The team identified the following positive attributes:
o
The counterpart team was knowledgeable and experienced.
o
The HPCI design basis document was good.
o
The setpoint methodology used was technically sound and reflected
current industry practices.
i
.,
DETAILS
1.0
Introduction
Selected instrumentation and control (I&C) setpoints were examined in detail,
including their design basis requirements, assumptions, calculations, and
component configuration.
In particular, the setpoint methodology
(uncertainties or errors) associated with the selected instrumentation loops
were evaluated to determine if setpoints were correct and adequate safety
margin existed.
Instrument loop selection was based on the predominant accident scenarios
identified in the individual plant examination (IPE) and the updated final
safety analysis report (UFSAR).
The team walked down originally installed and as-modified I&C equipment for
configuration and equipment types, reviewed component qualifications, testing,
and calibration records.
The team also assessed the licensee's engineering
and technical support (E&TS) organization's capability with respect to
personnel qualification and staffing, timely and adequate root cause analyses
for failures and recurring problems, and involvement in design modifications
and operations.
The areas reviewed and the concerns identified are described in Sections 3.0
and 4.0 of this report.
Personnel who attended the exit meeting on
September 16, 1994, are listed in Appendix A.
A complete list of the team's
requests for information are listed in Appendix B.
2.0
Action on Previously Identified Inspection Findings
a.
(Closed) Open Items (237/92028-03; 249/92028-03):
The inspectors
identified during fuse verification walkdowns that several control room
porcelain fuse holders were idenLifieu as "withstand rated 10,000 Amps.
rms.
11
However, the fuses installed were short circuit rated (withstand
capability) to 200,000 amperes.
b.
In response, the licensee provided Calculation No. D-OOSOEF which
identified the maximum available short circuit current as 1,487 amperes.
Other than the porcelain fuse holders discussed in this open item, no
others have been identified with a 10,000 ampere rating.
The licensee
is developing a fuse list. Approximately 80% of the known fuse
population have been walked down.
No other fuse holder discrepancies
have been identified. The fuse list is tentatively scheduled for
completion by December 1995.
The team reviewed Dresden Administrative
Procedure (OAP) No. 11-27, "Control and Maintenance of Fuses and The
Fuse List,
11 and concluded the licensee was adequately controlling fuses.
This item is considered closed.
(Closed) Open Item (237/91038-06):
The EDSFI team was concerned that
the swing (Unit 2/3 EOG) diesel room was excessively hot.
The EOG
generator, exciter and relays are rated for a maximum 122°F temperature.
The swing diesel room was not provided with any forced ventilation when
in the standby mode.
1
.* ..
In response, the licensee now monitors the swing diesel room temperature
once per shift. If the room temperature exceeds 118.4°F, the operator
manually starts the room fan and runs the fan until the room temperature
drops below 114.8°F~ The team reviewed the outdoor afternoon
temperatures recorded at Dresden during June 1994 and compared them to
the swing diesel room temperatures.
The highest outdoor afternoon
temperature was 94.64°F and the room temperature was 98°F.
The team
concluded the licensee adequately addressed the swing diesel temperature
concern.
This item is considered closed.
c.
(Closed) Unresolved Items (237/91038-05; 249/91042-05; 249/92023-05):
The licensee was unable to provide documentation to support that
electrical cables were not thermally overloaded.
In response, the licensee completed a Cable Tray Temperature Measurement
Program at Dresden and Quad Cities Stations.
Eighteen routing point
cable tray temperatures were measured and compared to a computer model.
The measured and computed temperatures agreed very closely. The
licensee intends to change the Sargent and Lundy Interactive Cable
Engineering (SLICE) program to better reflect the actual cable tray
thermal conditions. This program is tentatively scheduled for
completion by June 1995.
The team reviewed preliminary program results.
The cable temperatures were adjusted based on a 40°C ambient
temperature.
No cable routing points exceeded their 90°C cable rating.
The maximum cable temperature identified was~ 62°C.
The team concluded
the licensee was adequately addressing potential cable overloading.
These items are considered closed.
d.
(Closed) Violation (237/92028-02: 249/92028-02):
The licensee failed to
take corrective actions to replace improperly sized fuses used to
protect safety related components and circuits. For example, two 30A
fuses and one 40A fuse were installed in the Unit 2 EDG excitation
cabinet,. where the drawings specified 25A fuses.
e.
In response, the licensee installed the correct fuses.
In addition~ the
licensee strengthened DAP 11-27 to address fuse discrepancies.
The team
reviewed Calculation No. DOOll-EF that concluded the installed fuses
provided adequate protection.
However, the calculation stated that the
fuses specified on the drawings were the correct size. The team
reviewed the fuse discrepancies identified tn the past year and
concluded that all of the discrepancies were adequately dispositioned.
This item is considered closed.
(Closed) Violation (237/92028-01: 249/92028-01):
The station failed to
follow plant procedures to locate, isolate and remove; enter an
administrative LCO; and issue a JCO when appropriate for three
acknowledged DC grounds.
In response, the licensee counseled the Operation's staff involved about
the importance of procedure adherence.
During the tailgate session, the
three Notice of Violation examples were discussed.
The team reviewed
the DC grounds identified in the past 6 months.
The licensee adequately
implemented the ground detection procedure for three identified grounds .
This item is considered closed.
2
~ ..
f.
(Closed) Open Item (237/91016-04: 249/91016-04):
The NRC was concerned
that the original EOG output breaker trip logic design did not include a
LOOP/LOCA trip signal to realign the EOG in the emergency mode when
tested in parallel with offsite power.
The potential existed to
overload or backfeed the redundant bus during testing. This item was
referred to NRR for resolution.
In response, NRR indicated that adding an emergency override feature as
described in Regulatory Guide (RG) No. 1.108, "Periodic Testing of
Diesel Generator Units Used as Onsite Electric Power Systems at Nuclear
Power Plants," position C.l.b.3, would resolve the above concern.
However, the RG 1.108 requirements were implemented for nuclear plants
licensed after August 1977, that is, after Dresden's plants were
licensed. Also, the NRC recognizes that these conditions (EOG in
parallel with the grid for monthly testing) represent a limited window
of vulnerability, and the probability of experiencing the above cited
problems were very low.
Therefore, NRR does not believe backfitting the
EDG designs of these plants with the test override feature is
sufficiently safety significant to warrant backfit. This item is
considered closed.
g.
(Closed) Violation (237/92021-03; 249/92021-03):
The licensee did not
include four safety related SBGT current sensing relays in a calibration
program.
In response, the licensee satisfactorily calibrated the four relays and
added the relays to the calibration program.
During the corrective
action reviews, the licensee identified other relay types that require
calibration, such as time delay relays (TDRs).
The Safety Related
Contact Testing Adequacy ,(SRCTA) program was expanded to include TDRs
and other relay types in the program.
The inspectors reviewed the TDR
program and concluded the licensee had adequately addressed this
concern. This item is considered closed.
3.0
Instrument Loops Reviewed
In assessing I&C capability, the team reviewed the plant's instrumentation and
control system design, configuration and operation.
The team reviewed the
setpoint program, original and recent calculations, installed I&C equipment,
I&C testing and procedures, equipment qualification, and compliance with
regulations, design engineering standards and accepted engineering practices.
The review was based on the following information:
o
setpoint calculations
o
system descriptions
o
o
technical specifications (TSs)
o
system design basis documents
o
probabilistic risk assessment (PRA)
o
manufacturer documents
o
test and operating procedures
o
control logic diagrams
o
elementary and loop schematic diagrams
3
The team conducted I&C equipment walkdowns to verify that the operational,
environmental and seismic criteria had been correctly applied.
For each
instrument loop selected, the team reviewed the process sensing line and
instrument design interface, and the trip device or control room indicator
design.
The following instrumentation and control loops were reviewed:
Unit 3
1. Suppression Pool (torus)
a.
Temperature
b.
Level (indication and HPCI transfer
on high level in the torus)
2.
HPCI Initiation
a.
Low-low reactor water level
b.
High drywell pressure
3.
a.
High reactor water level
b.
High turbine exhaust pressure
c.
Low booster pump suction pressure
4.
HPCI Isolation Trips
a.
High steam line flow
b.
High steam line area temperature
c.
Low reactor pressure
5.
Condensate Storage Tank
a.
Level (high level transfer HPCI to suppression pool)
b.
Level Indication
Unit 2
1.
ATWS Recirculation Pump Trip
a.
High reactor pressure
b.
Luw-luw reactor water level
2.
ATWS Initiation
a.
High torus water average temperature alarm
b.
High reactor dome pressure
c.
Low-low reactor water level alarm
3.
LPCI Initiation
a.
High drywell pressure
b.
Low-low Rx level coincident with low reactor pressure or
c.
Low-low Rx level sustained for 8.5 minutes
4.
LPCI System Protection
a.
Low pressure injection permissive
b.
Keep fill system
5.
Reactor Vessel Level
a.
Level indication (narrow range)
b.
Low reactor water level trip (RPS)
6.
Standby Gas Treatment (secondary containment initiation)
a.
High reactor building air monitor radiation
b.
Group 2 primary containment isolation
o Low reactor water level
o High drywell pressure
o High drywell radiation
4
.
- .
3 .1
3 .1.1
Setpoint Calculation Methodology
Setpoint Calculation and Basis
The team revfewed Engineering Procedure Nos. TID-E/I&C-10, "Analysis of
Instrument Channel Setpoint Error and Instrument Loop Accuracy," and
TID-E/I&C-20, "Basis for Analysis of Instrument Channel Setpoint Error and
Instrument Loop Accuracy." These procedures are used as the method and basis
for instrument channel setpoint calculation preparation, review, approval and
loop accuracy analysis.
The team concluded that the methodology was
technically sound, consistent with current industry practices, such as ISA
67.04-1988, and sufficiently comprehensive for their intended purpose.
The calculations reviewed by the team were consistent with the licensee's
methodology, with the following exceptions:
a.
Several unverified assumptions were referenced in the calculations
reviewed, such as:
b.
c.
o
unissued draft design sketch
o
untraceable design information identified on telecon memos
o
several calculations used instrument seismic or environmental
accuracy data only if it was available or assumed an accuracy
Collectively, the team considered these examples of weak design
calculation controls.
Inconsistent number precision was carried through the calculations. The
number of decimal places used in the calculations did not match the
measurement precision in the calibration procedures.
However, the team
did not identify any instances where this practice resulted in
u11acceptable setpoint margin.
Calculations used manufacturer instrument drift data rather than station
historical drift data.
The licensee indicated that a program was being developed to collect and
analyze historical drift data for setpoint determinations.
This was
acceptable to the team.
d.
Several ca lcul at i ans prepared .by contractors were presented in a study
format rather than an engineering calculation format.
The team noted
that calculations performed by ComEd were more focused from input to the
finished product.
The team did not identify any errors attributable to
calculation format.
The contractors did prepare a useful and auditable
"Master Calculation" for reactor water level (RWL) calculations.
The
master calculation established the general assumptions and bases for
more detailed calculations involving RWL.
The team considered the
"master calculation" a good approach.
5
~---------~--- ------
3.1.2
Environmental and Seismic Effects
The team identified several examples where the licensee identified instrument
seismic or environmental effects in the calculations only if manufacturer
information was available. The calculations did not always clearly state the
environment and accident conditions that the instrument loop must function in.
In some instances, the calculations appeared generally limited to determining
numerical values for loop error based on available data, rather than serving
as the basis for loop performance during a DBA.
While the calculations
appeared correct within this limited scope, they were not always useful for
drawing conclusions about instrument loop performance during all operating
conditions.
However, sufficient margin existed in the calculations that the
team did not identify any operability concerns.
3.2
Suppression Pool (Torus} Temperature and Level
The instruments selected for review included torus bulk temperature
(TR-3-1641-9) and water level (Ll-3-1602-3, narrow range and LI-3-1640-lOA,
wide range).
These indication channels are used to maintain suppression pool
operating limits within technical specification limiting conditions for
operation and are considered RG 1.97, Category 1 instruments.
In addition,
the team reviewed high torus level float switches (LS-2351A/B) located in
float chambers.
These switches are used following an accident for automatic
HPCI suction transfer from the condensate storage tank to the torus.
3.2.1
Setpoint Calculation and Basis
a.
Prior to the l&C inspection, the licensee identified that the torus bulk
temperature procedure operating limits did not allow sufficient margin
for instrument uncertainties. The licensee performed an operability
evaluation for this condition and was implementing corrective actions
during the inspection. The operating limits were changed to allow
additional margin for measurement error. This was acceptable to the
team.
b.
Post accident monitoring channels, torus wide range level (Calculation
No. NED-IEIC-0149) and torus bulk temperature (Calculation No. NED-l-
EIC-0251) did not include environmental terms in the tolerance
calculation. The bulk temperature calculation excluded seismic effects
and the level calculation selectively excluded seismic effects for the
recorders and panel meters.
In addition, temperature, humidity, and
radiation effects were unknown.
This is considered an inspection
followup item (237/94016-0l(DRS); 249/94016-0l(DRS)) pending NRC review
of the licensee's actions to obtain and incorporate this information in
the calculations.
Based on other margins identified in the calculations, the team concluded the
above items would not affect operability. However, these items represent
another example of weak design calculation control.
3.2.2
Moore Industries Isolation Device Qualification
The team was concerned that the Moore Industries isolators' installed
configuration was not bounded by the test configuration that the devices were
qualified to for maximum credible faults (MCF) and surge withstand capability.
6
During a plant tour, the team identified Moore Industries torus temperature
isolator Nos. 943-237, -238, -242A and -2428, and several isolators installed
in computer input cabinet No. 903-68 with their input, output~ and power
wiring bundled together. This field configuration appeared to defeat the
isolation device purpose for separating safety related circuits from nonsafety
circuits.
During the inspection, the licensee was unable to retrieve qualification
documentation to support the installed configuration.
Preliminary
calculations performed by the licensee indicate the installed configuration
was acceptable.
However, this is considered an inspection followup item
(237/94016-02(DRS); 249/94016-02(DRS)) pending NRC review of the licensee's
calculations.
3.3
HPCI Initiation
The HPCI initiation instruments selected for review included low reactor water
level (LIS-3-0263-72A) or high drywell pressure (PS-3-1632A).
The instruments
are used to initiate HPCI for LOCA or MSLB accidents.
3.3.1
Setpoint Calculation and Basis
a.
The team identified several calibration data sheet tolerances and
setpoints that were less conservative than the values used in the
setpoint calculations:
o
Surveillance Procedure (SP) No. DIS 0500-03 (lo-lo RWL) used a +/- 2
INWC as the calibration tolerance while a+/- 1 INWC tolerance was
used in Calculation No. 0349-E-30 (Unit 3 low reactor water level
ECCS initiate).
In response, the licensee issued a Problem
Identification Form (PIF) to initiate corrective actions.
The
team considered the difference between the calibration tolerance
and the calculation to be minor.
o
SP No. DIS 2300-04 high drywell pressure setpoint was set. less
conservative (negative margin) than the setpoint established in
Calculation No. NED-I-EIC-0111 (Unit 3 high drywell pressure ECCS
initiation). However, the surveillance procedure setpoint did not
exceed the TS value.
In response, the licensee issued a PIF to
initiate corrective actions. This was acceptable to the team.
The team reviewed an informal licensee analysis for the above items and
concluded the discrepancies did not affect operability.
However, these
items represent another example of weak design calculation control.
b.
Calculation No. 0349-E-30 (Unit 3 RWL) contained the f6llowing
unverified assumptions or documents:
o
Reference No. 17 identified a draft sketch (NUS SK-0349-M-002A}.
A note on the sketch stated, in part, that it was not required to
be issued because " ... design parameters [are] included and checked
in design calculations." However, the calculation referenced the
informal sketch as the basis for several instrument elevation
datum points.
7
3.3.2
a.
0
Reference No. 24 identified training materials, Reference Nos. 41
and 50 identified two telecons, and Reference No. 28 identified a
calibration procedure that were used to support the RWL analytical
l i mit basis.
The licensee was unable to provide a qualitative basis to the team
for these assumptions and documents.
o
Paragraph No. 5.5.5.6.2 indicated that the RWL analytical limit
(AL) was derived from the technical specification (-59" RWL).
ISA Standard S67.04-1988, "Setpoints for Nuclear Safety-Related
Instrumentation," defines an AL as the "Limit of a measured or
calculated variable established by the safety analysis to ensure
that a safety limit is not exceeded." Although the licensee is
not committed to this Standard, the team was concerned that the
analytical limit for RWL was derived from the TS and not the
safety analysis.
In response, the licensee stated that the RWL setpoint setting was
more conservative than the TS value.
In addition, the licensee
indicated that consideration wou1d be given to establishing the AL
in accordance with ISA Standard S67.04-1988.
This was acceptable
to the team.
o
Attachment 2, page 26, discusses a telecon during which the Yarway
manufacturer identified the level switch repeatability error as+/-
3%.
It was not apparent to the team that the manufacturer's value
was consistent with the reference accuracy value used in the
calculation.
For example, repeatability errors should be
separately identified because such errors are not amenable to
calibration or adjustment.
In response, the licensee indicated that the manufacturer data,
although attached to the calculation and referenced in the
manufacturer's internal QA specification, was not used.
Data in
Calculation No. NED-I-EIC-0100 was used instead; however, this
calculation was not provided to the team in sufficient time to
complete a review.
This is considered an inspection followup item
(237/94016-03(DRS); 249/94016-03(DRS)) pending NRC review of
Calculation No. NED-I-EIC-0100.
Based on other margins identified in the calculation, the team concluded
the above items would not affect operability. However, these items
represent another example of weak design calculation control.
Environmental and Seismic Performance
The team noted that the original equipment Yarway RWL switch setpoint
calculations did not include an environmental error term.
The level
switches are required to mitigate LOCA and HELB (main steam line break
inside containment) accidents .
In response, the licensee stated, in part, that the level switch
protective functions would be performed
11
- prior to environmental
8
changes resulting from the abnormal condition (i.e., less than two
minutes}.
As such they are not required to be qualified per [IEB]
79-0lB." The level switches are located in EQ Zone Nos. 24 and 27.
The
following environmental conditions are postulated in these zones:
Process
Temperature
Pressure
Normal
104°F
14.7 psig
212°F
14.8 psig
104°F
14.7 psig
The high energy line breaks that could occur in the vicinity of the
level switches involved isolation condenser lines, the HPCI steam line,
or a RWCU line (bounding accident}.
However, the level switches are not
required to mitigate accidents that dominate EQ Zone Nos. 24 and 27.
In
addition, a drawing review did not indicate that the above lines could
directly spray on the instrument racks.
The team concluded the Yarways could perform their safety function.
In
addition, ISA S67.04-1988 supports the licensee's basis for not
including environmental effects in the Yarway calculation. Section
4.3.1.4, "Instrument Uncertainties by Design Basis Events,
11 indicated
that only uncertainties specific to the event and required period of
service need be used.
The use of different uncertainty components for
the same process equipment for different events is permitted.
b.
The team noted that original equipment SOR drywell pressure switches and
Yarway RWL *switches were classified as "commercial grade".
Information
provided in the calculations did not address their seismic
qualification.
In response, the licensee provided the "commercial grade" dedication
packages, however, the packages did not address the instruments' seismic
capability. This is considered an inspection followup item
(237/94016-04(DRS}; 249/94016-04(DRS pending NRC review of the seismic documentation for these instruments. Based on other margins identified in the calculation, the team concluded the above items would not affect operability. However, these items represent another example of weak design calculation control. 3.3.3 Condensate/Particulate Traps in Drywell Pressure Impulse Lines and Methods for Ensuring the Lines Are Unrestricted The team noted that the drywell pressure calibration procedures did not verify if the instrument impulse lines were blocked or restricted. The lines must be open and unrestricted to insure the pressure instruments will respond to a DBA. In addition, installation drawings did not identify any provisions for protecting the impulse line opening inside the drywell or provisions to drain impulse line low points. In response, the licensee walked down the lines and identified several low points (traps} that require further review. A PIF was issued to evaluate this item. This was acceptable to the team . 9
3.4 HPCI Turbine Trips The HPCI turbine instruments selected for review included high reactor water level (LIS-3-0263-72A), high HPC1 turbine exhaust pressure (PS-3-2368A) and low HPCI pum~ suction pressure (PS-3-2360). The setpoints must be set with adequate margin for equipment protection and must have adequate margin to prevent spurious HPCI trips during a DBA. 3.4.1 Setpoint Calculation and Basis a. Calculation No. NED-I-EIC-096 (HPCI turbine high exhaust pressure trip and suction pressure trip) did not evaluate Mercoid pressure switch seismic effects. b. Calculation No. NED-I-EIC-096 identified the Mercoid pressure switch temperature limit as 180°F, but the identified accident temperature was 230°F. c. The calculation did not identify any setpoint margin for the HPCI low suction pressure trip. The licensee was unable to retrieve information on the above items during the inspection. This is considered an inspection followup item (237/94016-05(DRS); 249/94016-05(DRS)) pending NRC review of the licensee's actions to address the above. Based on other margins identified in the calculation, the team concluded the above items would not affect operability. However, these items represent another example of weak design calculation control . 3.5 HPCI Isolation Trips The HPCI isolation instruments selected for review included high steamline flow (DPIS-3-2391-3), high steamline area temperature (TS-3-2370-A) and low reactor pressure (PIS-3-2391-lA). 3.5.1 Setpoint Calculation and Basis a. Calculation No. NED-I-EIC-108 (HPCI turbine/pump trip on high area temperature) did not evaluate temperature switch seismic effects. b. Calculation No. NED-I-EIC-108 stated, in part, that 11 *** post-accident radiation induced errors are assumed to be small .... 11 No basis was provided in the calculation to support this assumption. The licensee was unable to retrieve information on the above items during the inspection. This is considered an information followup item (237/94016- 06(DRS); 249/94016-06(DRS)) pending NRC review of the licensee's actions to address the above. Based on other margins identified in the calculation, the team concluded the above items would not affect operability. However, these items represent another example of weak design calculation control. 10
3.6 Condensate Storage Tank Level The instrument selected for low condensate storage tank level (LS-3-2350A) review initiates automatic HPCI suction transfer from the condensate storage tank to the suppression pool (torus). 3.6.l Setpoint Calculation and Basis The team noted that a setpoint calculation was not available and that the level switch (LS) was only functionally tested. In response, the licensee developed an informal analysis and walked down the LS (mechanical float assembly) installation. The LS is located in a float chamber and has a limited mechanical operating range. The switch was not designed to be calibrated. The team reviewed the informal analysis and concluded the LS would initiate HPCI suction transfer with adequate margin before losing HPCI pump NPSH. In addition 9 the team concluded a functional test was acceptable for this application. 3.7 ATWS Recirculation Pump Trip and Alternate Rod Insertion {ARI) The anticipated transient without scram system was installed as a backup to the reactor protection system. The instruments selected for recirculation pump trip (ATWS RPT) and ARI review included high reactor pressure (PT-2-0263- 208) and lo-lo RWL (LT-2-0263-23B). 3.7.1 Setpoint Calculation and Basis a. Calculation No. 0349-E-10 (Unit 2 RWL) did not conform to ISA S67.04-1988 (see Section 3.3.1.b, 3rd Bullet). b. Calculation No. 0349-E-10 (0349-E-30) did not include instrument drift data, calibration tolerances and environmental effects in the setpoint determination. The setpoint was determined from a scaling calculation. This is considered an inspection followup item (237/94016-07(DRS); 249/94016-07(DRS)) pending NRC review of the licensee's actions to obtain and incorporate this information in the calculation. Based on other margins identified in the calculation, the team concluded the above items would not affect operability. However, these items represent another example of weak design calculation control. 3.8 ATWS Manual Initiation Manual initiation was based on channel indication or alarms. The instruments selected for review included high torus water average temperature (TR-2-1641- 2008), high drywell pressure (PS-2-16328), and low RWL (LT-2-0263-578 or LS-2- 0263-1438). The calculations associated with these instruments are identical to those previously discussed in Section Nos. 3.2.1.b, 3.3.1.a and 3.7.1.b, respectively, and the findings identified in those Sections are applicable to these instruments. 11
3.9 LPCI Initiation The LPCI initiation instruments selected for review included high drywell pressure (PS-2-1632B) or lo-lo RWL coincident with low reactor pressure (LIS-2-0263-72B and PS-2-0263-52B). In addition, LPCI Loop II keep fill system (PS-2-1557B) and low reactor pressure permissive (PS-2-0263-52B) instruments were reviewed. 3.9.l Setpoint Calculation and Basis a. A calculation did not exist for the keep fill system. In response, the licensee indicated that the keep fill setpoint was an original design setting based on operating experience. The licensee provided the team a schedule for completion of setpoint calculations with priority based on design basis relevance. Categories of the setpoints included in the schedule were safety related, control system, regulatory related, reliability related, and nonsafey related setpoints. ESF/ECCS/RPS trip actuation or permissive signals, emergency operating procedures (EOPs), and RG 1.97 indication channel calculations receive the highest priority. Calculations for the remaining TS instruments, such as the keep fill system, are to follow. This was acceptable to the team. b. Calculation No. 0349-E-10 (Unit 2 lo-lo RWL ECCS initiation) identified negative setpoint margin. Although negative setpoint margin indicates the potential for the combined setpoint uncertainties to exceed the TS allowable value, the actual surveillance procedure setpoint did not exceed the TS value. Calculation No. NED-I-EIC-091 (Unit 2 high drywell pressure ECCS initiation) identified negative setpoint margin. However, the actual surveillance procedure setpoint did not exceed the TS value. Based on other margins identified in the calculations discussed in b. and c. above, the team concluded these items would not affect operability. However, the above items represent another example of weak design calculation control. 3.10 Reactor Water Level Narrow Range Indication The feedwater RWL instruments selected for review included the reactor level indication (LT-6468, Ll-640-298, and L/FR-640-26) and alarms for feedwater control. 3.10.l Setpoint Calculation and Basis The team noted that a loop error calculation was not available. In response, the licensee indicated that the loop settings were based on original equipment operating experience. The licensee provided the available design information. Subsequent team review did not identify any discrepancies and the team concluded the instruments were operating within their design limits. The licensee indicated that the performance of a loop error calculation was being considered. This was acceptable to the team. 12
3.11 Standby Gas Treatment (SBGT) Initiation The SBGT initiation instruments selected for review included the reactor building radiation monitor (RIS-2-1705-88), lo-lo RWL (LT-2-0263-578), high drywell press.ure (PS-2-16218) and high drywell radiation (RE-2-24188). 3.11.l Setpoint Calculation and Basis The team noted that formal calculations did not exist for the reactor building ventilation trip and the high drywell radiation monitor. In response, the licensee indicated that the ventilation trip was an original equipment setting and the high drywell radiation monitor settings were based upon NUREG 0737 analyses or offsite dose calculations. The team reviewed supporting documentation and concluded the setpoints were reasonable. 4.0 Engineering and Technical Support The team evaluated Dresden's I&C engineering and technical support (E&TS) capability by reviewing the licensee's programs for modifications, engineering interfaces, document and drawing control, discrepancy management, safety evaluations (10 CFR 50.59), test development and control, setpoint methodology, calibration procedures, QA and maintenance. In addition, the team reviewed training programs for I&C engineers and interviewed design,. construction and system I&C engineers. Overall, the team concluded Dresden was receiving adequate I&C engineering and technical support and that I&C engineering expertise was available; however, efforts toward developing an integrated engineering approach appeared minimal. Ownership for the design, calculations and systems was difficult to identify because weak linkages existed between design, construction and system engineering. One consequence observed was slow progression of engineering initiatives from program conception to implementation. For example, engineering was slow in identifying and correcting performance problems with the Yarway level switches. It appeared to the team that ComEd's control of external design engineering activities was weaker than internal design activities. The team noted that I&C setpoint calculations performed by ComEd were more focused with a clear path from calculation input to the finished product. Several contractor I&C calculations appeared to jump around from instrument loop to instrument loop and appeared to be in a study format rather than an engineering calculation format. Although the setpoint calculation review did not identify any operability concerns, numerous design calculation control weaknesses were identified. This area may require additional management attention to ensure the setpoint methodology program is implemented consistently. The licensee informed the team that they were adding additional design engineers to the site. Engineering's goal was to perform~ 80% of Dresden's design activities in-house. The team identified several positive attributes. The Dresden counterpart I&C team was knowledgeable and experienced. In addition, recent setpoint methodology used was technically sound and reflected current industry practices. Finally, the HPCI design basis document (DBD) was good. 13
4.1 Engineering Staff Training The team reviewed selected I&C engineers' training programs, training records and work experience. In addition, the team conducted interviews and technical discussions with selected I&C engineers. The I&C engineers interviewed were experienced and had a positive attitude. The team concluded that training was not focused on specific I&C skills and it appeared that l&C engineers were not completely trained on existing instrumentation system designs. It appeared to the team that the emerging I&C engineering group and their involvement with setpoint methodology may require additional training to ensure consistent implementation. The team was informed that in October 1993, 22 modification and technical staff engineers received training on post modification testing as an effort to resolve previously identified weaknesses in that area. This training was provided after post modification test (PMT) No. SP 93-10-90 was approved for use in Modification No. Pl2-3-93-614 (see Section 4.2.a). 4.2 Design Control and Modifications The team concluded that Dresden was adequately controlling station modifications. Safety evaluations were thorough and well documented. Eight permanent and three temporary modifications were reviewed. Two permanent and the three temporary modifications were walked down. The walkdowns reviewed the modifications against the design drawings and concluded the installations reflected the as-built configuration . The team reviewed the PMTs for the modifications. Inadequate PMTs were identified in two permanent modifications. a. Modification Pl2-3-93-614: Reroute Torus Bulk Temperature Monitoring System conduits to lessen Unit 3 flooding and/or corrosion concerns (completed July 1994). This modification replaced existing thermocouple cables and conduits for the post accident monitoring suppression pool temperature indication channels. The team identified there was no basis for the +/- 6°F acceptance criteria specified in Special Procedure (SP) No. 93-10-90, "Modification Test for Torus Temperature Monitoring Conduit Relocation Minor Design Change Pl2- 3-93-614." In response, the licensee used design Calculation No. NED-I-EIC-0251, "Suppression Pool Temperature Loop Accuracy Calculation," and determined the acceptance criteria to be+/- 4.6°F. Based on indicator readability; the acceptance criteria specified in the PMT procedure should have been +/- 5°F. Although the actual temperature values recorded during performance of the SP were~ 5°F. The failure to include acceptance limits contained in applicable design documents is a violation (237/94016-0Ba; 249/94016-0Ba(DRS)) of 10 CFR 50, Appendix B, Criterion XI, Test Control. The team noted that the Unit 2 special procedure recorded temperature values showed no variances from the desired input values. Unit 3 recorded temperature values varied between -4°F and +5°F. The team was concerned as to why the PMT results were different between units. 14
b. 4.3 In response, the licensee indicated they would investigate the Unit 3 temperature variances and retest the modification. This was acceptable to the team. Modification M12-0-90-025: Modify Standby Gas Treatment System (SBGT) logic so an isolation in either Unit will isolate both Units' Reactor Building Ventilation Systems (completed February 1991). Four relays were added to automatically close both Units' reactor building isolation dampers and trip their respective building ventilation and exhaust fans. The team identified that new SBGT Train A relay (30K5 and 30K24) contacts (Drawing No. 12E-2400C, sh.1) and Train B relay (30K21 and 30K25) contacts (Drawing No. 12E-2400C, sh.2) were inadequately tested. Special Procedure Nos. SP 91-2-29, "Standby Gas Treatment Train A Logic Modification Test," and SP 91-1-12, "Standby Gas Treatment Train B Logic Modification Test," verified the isolation dampers automatically closed and that all reaGtor building fans tripped. However, the post modification tests did not identify that original construction relays CR-2 and CR-3 (Drawing Nos. 12E-2399C and 12E-33998) would, in parallel, trip the reactor building fans upon isolation damper closure.
Therefore, positive identification that the new relays had performed their intended function was not verified. In response, the licensee indicated they would verify by test that the relay contacts could perform their intended functions. The failure to demonstrate that systems and components will perform satisfactorily in service and assure test requirements have been satisfied is a violation (237/94016-0Bb; 249/94016-0Bb(DRS)) of 10 CFR 50, Appendix B, Criterion XI, Test Control. Review of Licensee Self-Assessment Program in the I&C Area The team reviewed I&C related audits and surveillances performed during the last three years. Recent self-assessments appeared to be more self critical than earlier audits that had few technical findings. For example, the current instrument trending program was found m~rginal since only as-found values outside specified surveillance tolerances were trended (marginal instrument drift patterns may not be noted). The team concluded that recent licensee I&C self-assessments were acceptable. 4.4 Measuring and Test Equipment {MTE) The inspectors noted that recent improvements in the licensee's MTE control practices were, in part, driven by self~assessment findings. To address the findings and other MTE problems, an Instrument Compliance Manager position was created. Increased management direction at several levels has lowered the MTE work request backlog, created a MTE problem list and involved the instrument mechanics (IMs) in solving MTE problems. The team concluded that MTE issue controls, such as storage, calibration interval and damaged or out of tolerance MTE instruments were acceptable. 4.5 Instrument Calibration and Testing The team reviewed calibration and functional surveillance tests, logic functional tests and response time tests associated with the instrument loops 15
' I! selected. The team concluded the procedures were user friendly and of good quality. However, as discussed in previous Sections of this report, several calculated setpoints used different tolerances than identified on surveillance procedure data sheets. It was unclear to the team how Dresden would tie the calculation and procedure together to ensure changes made to either document, such as MTE, would not invalidate the calculation. Though problems were noted, the surveillance procedures did incorporate the correct technical specification (TS) setpoint values and the setpoints were conservatively set below the allowable TS limits. The team concluded the instrument testing program was acceptable. 5.0 Inspection Followup Items Inspection followup items are matters that have been discussed with the licensee, which will be reviewed further by the team, which involve some action on the part of NRC or licensee or both. Followup items disclosed during the inspection are discussed in Sections 3.2.1.b, 3.2.2, 3.3.1.b, 3.3.2.b, 3.4.1, 3.5.1, and 3.7.1.b of this report. 6.0 Exit Meeting The team met with licensee representatives (denoted in Appendix A) after the inspection on September 16, 1994, to discuss the scope and findings of the inspection. During the exit meeting, the team.discussed the likely informational content of the inspection report about documents or processes reviewed by the team during the inspection. Licensee representatives did not identify any such documents or processes as proprietary. 16
APPENDIX A Dresden SBICI Exit Meeting September 16, 1994 1.0 Common~ealth Edison Company
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E. Eenigenburg, Unit 2 Station Manager H. Massin, Site Engineering & Construction Manager H. Drumhiller, Station Engineering Department Superintendent D. Barrett, Acting Quality Control Supervisor J. Phelan, CECo l&C Team Leader G. Wagner, Acting Chief E/Instrument & Control Engineer P. Wicyk, Electrical - Instr*ument and Control Supervisor D. Pritchard,Work Control Superintendent J. Grzemski, ISEG Supervisor J. Williams, Dresden Construction Superintendent C. McDonough, Regulatory Assurance NRC Coordinator R. Ralph, System Engineering Team Leader D. Ambler, SVP Executive Assistant G. Tietz, Operations Manager M. Pacilio, Unit 3 Maintenance Superintendent R. Mason, Instrumentation and Control Engineer J. McHale, Instrumentation and Control Engineer K. Robbins, Instrument Maintenance Supervising coordinator S. Stiller, Instrument Department Superintendent L. McCalip, Instrument Compliance Manager J. Zeszutek, Regulatory Assurance Engineer S. Koenig, Regulatory Performance Administrator D. Rahn, Signals & Safeguards Inc. R. Ellman, Signals & Safeguards Inc. W. Barasa, S&L U. S. Nuclear Regulatory Commission
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M. Leach, Senior Resident Inspector G. Wright, Chief, Engineering branch DRS C. Settles, IONS Resident Inspector Denotes those present at the exit meeting on September 16, 1994.
001 002 003 004 005 006 007 008 009 010 011 012 013 014 015 016 017 018 019 020 021 022 023 024 025 026 027 028 029 030 031 032 033 034 035 036 037 038 039 040 041 042 043 044 045 APPENDIX B DRESDEN SBICI REQUESTS FOR INFORMATION PROVIDE 3 COPIES OF SETPOINT METHODOLOGY PROVIDE INFORMATION ON MT&E PROGRAM PROVIDE INFORMATION ON HOW THE MT&E PROGRAM IS IMPLEMENTED IN THE CALCULATION METHODOLOGY PLEASE PROVIDE QA SURVEILLANCES OR AUDITS OF I&C ENGINEERING . PROVIDE PROCEDURES THAT DEAL WITH SUPPRESSION POOL TEMPERATURE PROVIDE PROCEDURES THAT DEAL WITH SUPPRESSION POOL LEVEL (INDICATION AND HPCI TRANSFER AND HIGH LEVEL) PROVIDE PROCEDURES THAT DEAL WITH HPCI INITIATION ON RX LO LO WATER LEVEL PROVIDE PROCEDURES THAT DEAL WITH HPCI INITIATION ON HI DRYWELL PRESSURE PROVIDE PROCEDURES THAT DEAL WITH HPCI PROTECTIVE TRIP ON HIGH FLOW (PIPING) PROVIDE PROCEDURES THAT DEAL WITH HPCI PROTECTIVE TRIP ON HI TEMPERATURE IN HPCI PIPING PROVIDE PROCEDURES THAT DEAL WITH THE HPCI KEEP FILL SYSTEM PROVIDE PROCEDURES THAT DEAL WITH HPCI ISOLATION TRIPS ON STEAM LINE HIGH FLOW PROVIDE PROCEDURES THAT DEAL WITH HPCI ISOLATION TRIPS ON STEAM LINE AREA HIGH TEMPERATURE PROVIDE PROCEDURES THAT DEAL WITH HPCI ISOLATION TRIPS ON LO RX PRESSURE PROVIDE PROCEDURES THAT DEAL WITH CST LEVEL (LO LEVEL TRANSFER HPCI TO SUPPRESSION POOL) PROVIDE PROCEDURES THAT DEAL WITH ATWS RECIRCULATION PUMP TRIP ON REACTOR HIGH PRESSURE PROVIDE PROCEDURES THAT DEAL WITH ATWS RECIRCULATION PUMP TRIP ON REACTOR LOW-LOW LEVEL PROVIDE PROCEDURES THAT DEAL WITH ATWS MANUAL INITIATION ON HIGH TORUS WATER AVERAGE TEMPERATURE ALARM PROVIDE PROCEDURES THAT DEAL WITH ATWS MANUAL INITIATION ON REACTOR HIGH DOME PRESSURE HIGH ALARM PROVIDE PROCEDURES THAT DEAL WITH ATWS MANUAL INITIATION ON REACTOR LOW LOW WATER LEVEL ALARM PROVIDE PROCEDURES THAT DEAL WITH LPCI INITIATION ON HIGH DRYWELL PRESSURE PROVIDE PROCEDURES THAT DEAL WITH LPCI INITIATION ON LOW LOW RX LEVEL COINCIDENT WITH LOW REACTOR PRESSURE PROVIDE PROCEDURES THAT DEAL WITH LPCI INITIATION ON LOW LOW RX LEVEL SUSTAINED FOR 8.5 MINUTES PROVIDE PROCEDURES THAT DEAL WITH LPCI INITIATION ON LOW PRESSURE INJECTION PERMISSIVE PROVIDE PROCEDURES THAT DEAL WITH LPCI KEEP FILL SYSTEM PROVIDE PROCEDURES THAT DEAL WITH REACTOR VESSEL LEVEL (INDICATION - NARROW RANGE) PROVIDE PROCEDURES THAT DEAL WITH REACTOR VESSEL RPS LEVEL 3 TRIP PROVIDE PROCEDURES THAT DEAL WITH STANDBY GAS TREATMENT INITIATION UPON SECONDARY CONTAINMENT INITIATION FOLLOWING RX BUILDING AIR MONITOR HIGH PROVIDE PROCEDURES THAT DEAL WITH STANDBY GAS TREATMENT INITIATION UPON SECONDARY CONTAINMENT INITIATION FOLLOWING GROUP 2 PRIMARY CONTAINMENT ISOLATION ON: A) RX LO LEVEL B) HI DRYWELL PRESS C) DRYWELL HI RADIATION PROVIDE ROUND SHEETS FOR LOOPS INDICATED ON ATTACHED LIST PROVIDE DRAWINGS ASSOCIATED WITH SELECTED LOOPS PROVIDE CABLE ROUTING FOR SUPPRESSION POOL A) TEMPERATURE B) LEVEL (INDICATION AND HPCI TRANSFER ON HIGH LEVEL IN THE TORUS) PROVIDE CABLE ROUTING FOR HPCI INITIATION ON: A) REACTOR LOW LOW WATER LEVEL B) HIGH DRYWELL PRESSURE PROVIDE CABLE ROUTING FOR HPCI PROTECTIVE TRIPS ON: A) HIGH FLOW HPCI PIPING B) HIGH TEMPERATURE HPCI PIPING C} HPCI FILL SYSTEM PROVIDE CABLE ROUTING FOR HPCI ISOLATION TRIPS ON: A) STEAM LINE HIGH FLOW B) STEAM LINE AREA HIGH TEMPERATURE C) LOW REACTOR PRESSURE PROVIDE CABLE ROUTING FOR CONDENSATE STORAGE TANK A) LEVEL (LOW LEVEL TRANSFER HPCI TO SUPPRESSION POOL) PROVIDE CABLE ROUTING FOR ATWS RECIRC PUMP TRIP A) REACTOR HIGH PRESSURE B) REACTOR LOW LOW WATER LEVEL PROVIDE CABLE ROUTING FOR ATWS MANUAL INITIATION ON: A) HIGH TORUS WATER AVERAGE TEMPERATURE ALARM B) REACTOR HIGH DOME PRESSURE HIGH ALARM C) RX LO LO WATER LEVEL ALARM PROVIDE CABLE ROUTING FOR LPCI INITIATION ON: A) HI OW PRESSURE B) LO LO RX LEVEL COINCIDENT IN LO RX PRESS C) LO LO RX LEVEL SUSTAINED FOR 8.5 MINUTES D) LO PRESS INJECTION PERMISSIVE E) KEEP FILL SYSTEM PROVIDE CABLE ROUTING FOR RX VESSEL A) LEVEL (INDICATION - NARROW RANGE) B) RPS LEVEL 3 TRIP PROVIDE CABLE ROUTING FOR STANDBY GAS TREATMENT A) INITIATION UPON SECONDARY CONTAINMENT INITIATION FOLLOWING: PROVIDE A) B) PROVIDE A) B) PROVIDE A) B) C) PROVIDE A) B) C) (1) RX BLDG AIR MONITOR HIGH (2) GRP 2 PRIMARY CONTAINMENT ISOLATION ON: A) RX LO LVL B) HI OW PRESS C) OW HI RAD CALCULATIONS FOR SUPPRESSION POOL TEMPERATURE LEVEL (INDICATION AND HPCI TRANSFER ON HI LEVELS IN THE TORUS) CALCULATIONS FOR HPCI INITIATION ON: RX LO LO WATER LEVEL HI DRYWELL PRESSURE CALCULATIONS FOR HPCI PROTECTIVE TRIPS ON: HI FLOW HPCI PIPING HI TEMPERATURE HPCI PIPING KEEP FILL SYSTEM CALCULATIONS FOR HPCI ISOLATION TRIPS STEAM LINE HIGH FLOW STEAM LINE AREA HIGH TEMPERATURE LOW RX PRESSURE
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046 047 048 049 050 051 052 053 054 055 056 057 058 059 060 061 062 063 064 065 066 067 068 069 070 071 072 07~ 074 075 076 077 078 079 080 PROVIDE PROVIDE A) B) PROVIDE A) B) C) PROVIDE A) B) C) D) E) PROVIDE A) B) PROVIDE A) CALCULATIONS FOR CST LEVEL {LO LEVEL TRANSFER HPCI TO SUPPRESSION POOL) CALCULATIONS FOR ATWS RECIRC PUMP TRIP ON: RX HI PRESSURE RX LO LO WATER LEVEL CALCULATIONS FOR ATWS MANUAL INITIATION HI TORUS WATER AVERAGE TEMP ALARM RX HI DOME PRESSURE HIGH ALARM RX LO LO WATER ALARM CALCULATIONS FOR LPCI INITIATION ON: HI DRYWELL PRESSURE LO LO RX LEVEL COINCIDENT WITH LO RX PRESS LO LO RX LEVEL SUSTAINED FOR 8.5 MINUTES LO PRESS INJECTION PERMISSIVE KEEP FILL SYSTEM CALCULATIONS FOR REACTOR VESSEL: LEVEL {INDICATION - NARROW RANGE) RPS LEVEL 3 TRIP CALCULATIONS FOR STANDBY GAS TREATMENT: INITIATION UPON SECONDARY CONTAINMENT INITIATION FOLLOWING: (1) RX BLOG AIR MONITOR HIGH (2) GROUP 2 PRIMARY CONTAINMENT ISOLATION A) RX LO LEVEL B) HI DRYWELL PRESS C) DRYWELL HI RADIATION PROVIDE CLOSURE PACKAGES FOR: 237/249/91016-04, 237/91038-05, 237/91038-06, 237/249/92028-03, 237/249/92021-03, 249/92023-05, 237/249/92028-01, AND 237/249/92028-02. PROVIDE LIST OF I&C MODIFICATIONS/EC'S PERFORMED OVER LAST 5 YEARS. PROVIDE LIST OF LER'S, DR'S, ETC. THAT DEAL WITH INSTRUMENTS OVER LAST 5 YEARS. PROVIDE A DISCUSSION AND AVAILABLE INFO REGARDING OLD FSAR VS. UFSAR SECTION TRANSLATION. PROVIDE HPCI TURBINE HI RX LEVEL TRIP SETPOINT CALCULATION AND LOOP CALIBRATION PROCEDURE. PROVIDE HPCI TURBINE HI TURBINE EXHAUST PRESSURE TRIP SETPOINT CALCULATION AND LOOP CALIBRATION PROCEDURE. PROVIDE HPCI TURBINE LOW BOOSTER PUMP SUCTION PRESSURE TRIP SETPOINT CALCULATION AND CALIBRATION PROCEDURE. PROVIDE A LIST (OR LISTS) OF INDUSTRY INITIATIVES (INs, VENDOR TECHNICAL BULLETINS, GENERIC LETTERS, SI Ls, ETC.) (LAST 5 YEARS) DEALING WITll I&C. PROVIDE ATWS SER FOR UNIT 2. PROVIDE PIR 12-2-93-106, CAR 12-93-040, AND DVR 12-2-92-026. INCLUDE ANY SUPPORTING INFORMATION. PROVIDE LERS 3-91-03, 3-92-19, 3-93-1 PLUS SUPPLEMENT, AND 3-94-8. INCLUDE SUPPORTING INFORMATION. 1989 TO 92 TIME FRAME - I COUNTED APPROX 20 UNIT 2 & 3 DVRs DEALING WITH ECCS LVL INST DRIFT. WHAT HAS BEEN DONE TO CORRECT THIS? PROVIDE ALL SUPPORTING INFORMATION. PROVIDE DVRs: 12-2-90-022, 12-2-90-025, 12-2-90-116, 12-2-90-160, 12-2-91-148, 12-2-92-111 AND 12-2-92-152. (INCLUDE SUPPORTING INFORMATION) PROVIDE DVRs: 12-3-90-068, 12-3-91-036, 12-3-91-063, 12-3-92-014, 12-3-92-021, 12~3-92-038, 12-3-92-075. (INCLUDE SUPPORTING INFORMATION) PROVIDE MODS: Ml2-0-90-025, Ml2-2-91-022, Pl2-3-93-614, Pl2-2-93-601, Pl2-2-92-748, Ml2-3-89-024, Pl2-3-94-224 AND Pl2-3-93-208. PROVIDE MOD PROCEDURE, TEMPORARY MOD PROCEDURE AND LIST OF TEMPORARY MODS FOR BOTH UNITS. PROVIDE DRESDEN'S RESPONSE TO BULLETIN/LETTER FROM NRC THAT ADDRESSES CONDENSATE POT DEGASSING AND IT'S AFFECT ON LEVEL MEASUREMENT. RUFSAR 6.3.3.1.3.2.1. PGS. 6.3-29, (1) WHAT IS THE HI DP STEAM LINE ISOLATION OF HPCI TURBINE IN 50 SEC? (2) ARE THEIR ANY SETPOINT CALCS AND CALIBRATION PROCEDURES? (3) DWG. fl'S. PROVIDE DRESDEN'S CONTROL OF M&TE PROCEDURES (WE HAVE A COPY OF TID-C/I&C-26). PROVIDE PROCEDURES QE 16, QE 16.1, QE 72, QE 80, QE 80.1, TID-E/I&C-11 AND 12 AND ANY DRESDEN PROCEDURES THAT CONTROL SETPOINTS. (NOTE: TID-E/I&C-21 CORRECTS TYPOGRAPHICAL ERROR OF REQUESTED TD- E/I&C-12) URI 237/91038-05; 249/91042-05. SEE ATTACHED. TORUS HI LVL HPCI TRANSFER: (1) PROVIDE LS CALIBRATION PROCEDURE (FUNCTIONAL TEST WAS PROVIDED). (2) PROVIDE FT3 VALUE FOR THE SETPOINT. (3) PROVIDE THE ANALYTICAL LIMIT FOR THIS SETPOINT. CST LVL INDICATION: (1) DOES THIS INST. LOOP HAVE ANY ALARM/CONTROL FUNCTIONS? (2) USING EOPS/ABNORMAL OPERATING PROCEDURES, DOES OPERATION'S USE THIS INST. LOOP TO MAKE ACCIDENT MITIGATION TYPE DECISIONS? IF YES, (3) WHAT ARE THE LEVELS AND WHAT ARE THEIR ANALYTICAL LIMITS? U3 TORUS: (1) PROVIDE NARROW RANGE LVL XMITTER INSTALLATION DRAWING. (2) PROVIDE XMITTER PIPING CONNECTION TO THE TORUS (TAP HEIGHT LOCATION). (3) PROVIDE XMITTER VENDOR MANUAL AND OTHER LOOP COMPONENTS (INCLUDE VENDOR MANUALS). XMITTER ENVIRONMENTAL CONDITIONS, SUCH AS HELB ENVIRONMENT. (4) PROVIDE U3 TORUS HI LVL: (1) PROVIDE LVL SWITCH VENDOR MANUAL. (2) PROVIDE TORUS INSIDE DIMENSIONS (DRAWING IF AVAILABLE). (3) PROVIDE ACCIDENT ENVIRONMENT FOR LS AND ANY EQ INFORMATION. (4) PROVIDE TORUS LEVEL CURVE FT3 VS. LEVEL. (1) PROVIDE COPY CST LEVEL SWITCH VENDOR MANUAL. (2) PROVIDE CST LS INSTALLATION DRAWING (WE HAVE M-310 SH 62) (3) PROVIDE CST LS PIPING CONNECTION TO CST DRAWING (TOP LOCATION) (4) PROVIDE CST LS ENVIRONMENTAL OPERATING CONDITIONS, SUCH AS TEMP. U3 TORUS NARROW RANGE LEVEL: (1) DOES THIS INST. LOOP HAVE ANY ALARM/CONTROL FUNCTIONS? (2) USING EOPS/ABNORMAL OPERATING PROCEDURES, DOES OPERATION'S USE THIS INST. LOOP TO MAKE (3) (1) (2) (3) (1) ACCIDENT MITIGATION TYPE DECISIONS? IF YES, WHAT ARE THE LEVELS AND WHAT ARE THEIR ANALYTICAL LIMITS? PROVIDE HPCI CST NPSH CALCULATION PROVIDE CST TANK DIMENSIONAL (INSTALLATION/DESIGN) DRAWING. PROVIDE CST TANK CURVE, SUCH AS GALLONS VS LEVEL. IS THERE A CST LEVEL INDICATION LOOP CALCULATION, IF SO, PLEASE PROVIDE. 2
081 082 083 084 085 086 087 088 089 090 091 092 093 094 095 096 097 098 099 100 101 102 103 104 105 106 107 108 109 110 111 112 113 114 115 (2) PROVIDE CALIBRATION PROCEDURES AND VENDOR MANUALS FOR CST LI LOOP. OPN ITEM 237/91038-06 (1) PROVIDE UNIT 2/3 DIESEL GENERATOR ROUND BOOK PG 22 (D/G ROOM TEMP) (2) PROVIDE UNIT 2/3 DIESEL GENERATOR ROOM TEMPERATURES FOR JUNE 1994. OPN ITEM 237/91038-06 NEED TO DISCUSS UNIT 2/3 DIESEL GENERATOR ROOM TEMPERATURES WITH SYSTEM ENGINEER. PLEASE PROVIDE OR MAKE AVAILABLE FOR REVIEW CLOSURE PACKAGES ASSOCIATED WITH INDUSTRY INITIATIVES; N92-06 & N92-06Sl (IN), N90-28 (IN), N82-16 (IN), GL-92-04, N90-22 (IN), SIL 470 & SIL 470Sl {GE TECH REP), N93-27 (IN). OPEN ITEM 237/249/92028-03: HAVE OTHER PORCELAIN FUSE HOLDERS AND/OR OTHER FUSE HOLDER TYPES BEEN VERIFIED THAT THE AVAILABLE FAULT CURRENT IS LESS THAN THE HOLDER 'WITHSTAND' RATING? OPN ITEM 237/249/92028-03: (1) IS THERE A PROGRAM TO ADDRESS NON-LIKE-FOR-LIKE FUSE DISCREPANCIES, PROVIDE INFORMATION? (2) HAVE INSTALLED FUSES AT DRESDEN BEEN WALKED DOWN AND VERIFIED AGAINST DESIGN DRAWINGS? OPN ITEM 237/249/92028-03: (1) PROVIDE COORDINATION CURVE FOR BUSS NON 3 FUSE AND GE TYPE TEF 15A CIRCUIT BKR. (2) PROVIDE MAX FAULT CURRENT FOR CIRCUITS FUl THROUGH FU16 IN PANEL 2/3-5400-105 (CR HVAC), REF. CALC 8772-14-19-19. OPN ITEM 237/249/92028-03: S&L DISCREPANCY #D-92-150 IDENTIFIED THAT COORDINATION DID NOT EXIST BETWEEN THE FUSES AND UPSTREAM CIRCUIT BKRS. THESE CIRCUITS ARE SAFETY RELATED. COULD THE OPENING OF A SINGLE UPSTREAM BKR FAIL THE CR HVAC AND OTHER SAFETY RELATED EQUIPMENT? FOR FUl THROUGH FU16. OPN ITEM 237/91038-06: (1) PROVIDE HIGHEST AFTERNOON DRESDEN OUTDOOR TEMPERATURE FOR EACH WEEK DURING JUNE 1994, INCLUDE DATE. (2) WERE THE RX UNITS OPERATING DURING JUNE, 1994. VlO 237/249/92021-03: (1) PROVIDE COPY OF PROCEDURES OADMP-1 AND OADMP-lA. (2) PROVIDE LAST CALIBRATION RECORD FOR THE FOUR SBGT HEATER CURRENT SENSING RELAYS. (3) PROVIDE RELAY VENDOR MANUAL. PROVIDE NRC INSP. REPORT NOS. THAT REVIEWED DRESDENS ATWS C0""'1ITMENTS. VlO 237/249/92028-01 (1) PROVIDE DOP 6900-07 AND OAP 07-05 (2) FOR THE PAST 6 MONTHS, PROVIDE A LIST OF ALL U2 AND U3 125 voe GROUNDS THAT INITIATED ENTRY INTO DOP 6900-07, INCLUDE DATE AND POTENTIAL. (3) PROVIDE CORRECTIVE ACTIONS FOR THE LIST AND DATE WHEN GROUND WAS REMOVED. OPN ITEM 237/91038-068: EOG (2/3) ELECTRICAL RELAYS AND EXCITER ARE RATED FOR A MAXIMUM TEMP OF 122.F) (1) IS THIS TEMPERATURE EXTERNAL TO THE EQUIPMENT CABINETS OR AN INTERNAL CABINET TEMPERATURE. (2) WHAT IS A TYPICAL INTERNAL CABINET TEMP IN THE 2/3 EOG ROOM? VlO 237/249/92028-02: (1) PROVIDE FUSE DISCREPANCY TPRs LIST BACK ONE YEAR. (2) PROVIDE PROCEDURE OAP 11-27 VlO 237/249/92028-02: (1) PROVIDE WR AND OCR PACKAGE THAT CHANGED OUT THE DG EXCITER CABINET 40A FUSE TO A 30A FUSE. (2) WHY IS THE 30A FUSE ACCEPTABLE VS VENDOR SPECIFIED 25A FUSE (REF. TPRs DF-0147 & 0186)? PROVIDE (2) COPIES OF DRESDEN ENVIRONMENTAL ZONE MAPS AND NOTES (DRESDEN UFSAR SECTION 3.11) PROVIDE TORUS FT3 VS LEVEL CURVE NOT SUPPLIED ON T-076. PROVIDE COPIES OF IR DROP CALCULATIONS. CALC 349-E-10 REV. 6 INDICATES TECHNICAL SPEC VALUES AS ANALYTICAL LIMITS. PROVIDE SOURCE OF THE QUANTITATIVE BASIS FOR ANALYTICAL LIMITS AND THEIR MARGINS. CALC NO. 349-E-10 REV. 6 SEC. 5.5.1.18 INDICATES A TRIP UNIT CHANGE TO G.E. VENDOR DATA ATTACHED IS FOR A ROSEMONT TRIP UNIT. PLEASE CLARIFY. CALC NO. 349-E-10 REV. 6 SEC. 5.5.12.1 IDENTIFIES A "HEAD CORRECTION". PROVIDE SOURCE OF THIS NUMBER AND HOW DETERMINED. (WALKDOWN - INSTALLATION DWGS?) . (CALC 0349-E-30) PROVIDE REFS. 24,28,41,50 AND APPROPRIATE DESIGN BASIS DOCUMENTATION THAT SUPPORTS THE BASIS FOR THE ANALYTICAL LIMITS FOR RV LEVEL SETPOINTS. (CALC 0349-E-30) PROVIDE INSTALLATION DETAILS OF RECORD; THESE APPEAR TO BE RF.F. 7,8,17. INSTALLATION DETAILS FOR LEVEL INSTRUMENTS SHOULD IDENTIFY LOCATION, ARRANGEMENT, LINK ROUTING/SLOPES, INSTALLATION TOLERANCES, AND ELEVATIONS TRACEABLE TO TOP OF FUEL. (CALC 0349-E-30) PROVIDE THE ANALYSIS SUPPORTING THE SIZING OF THE CONDENSING CHAMBERS THAT DEMONSTRATES THE CHAMBERS WILL ACCQl.loKJDATE THE TOTAL VOLUME DISPLACEMENT OF CONNECTED INSTRUMENTS. (CALC 0349-E-30) PARA 5.5.1.12, 5.5.5 APPEARS TO INDICATE THAT RV LEVEL INSTRUMENTS ARE NOT REQUIRED TO PERFORM IN A HARSH ENVIRONMENT. WHY AREN'T THE ENVIRONMENTAL EFFECTS OF INITIATING EVENTS SUCH AS LOCAS OR HELB - INCLUDED (EG FLASHING OF THE REFERENCE LEG) (FSAR 9.2.6.5) WHY ISN'T THE AUTO TRANSFER OF HPCI SUCTION FROM THE CST (ON LOW CST LEVEL) TO THE SUPPRESSION POOL IDENTIFIED IN THIS FSAR SECTION? PROVIDE PROCEDURE ENC-QE-69 PROCEDURE TID-E/I&C -10, PG 5, DEFINITION AST. IS THIS THE DIFFERENCE BETWEEN THE PROCESS OPERATIONAL LIMIT TRANSIENT AND THE POSITIVE SETPOINT TOLERANCE FOR A DECREASING TRIP AND NEGATIVE SETPOINT TOLERANCE FOR AN INCREASING TRIP? PROVIDE AN ANALYSIS DEMONSTRATING THAT SUFFICIENT MARGIN FOR UNCERTAINTIES IN THE SUPPRESSION POOL HIGH LEVEL SETPOINT VALUE IS PROVIDED. IDENTIFY THE INSTALLATION TOLERANCES AND OTHER UNCERTAINTIES. PROVIDE THE BASIS FOR THE ANALYTICAL LIMIT (ACCIDENT ANALYSIS, VOLUME/LEVEL CALCULATIONS, ETC). PROVIDE FOLLOWING REFERENCES IN CALC 349-E-10 REV. 6, ITEM 7: M-4023 SH. 1 & 2; ITEM 8: M-310 SHTS 28 & 38; ITEM 11: 257HA350AM REV. 10; ITEM 18: NUS SKETCH SK-0349-M-001 REV. B. HOW IS THE TRENDING DATA FOR INSTRUMENTS CURRENTLY APPLIED TO THE SETPOINT CALCULATIONS. SCHEM. 12E-3430 SH. 1 REV. AP IDENTIFIES A CROSS REF. TO 12E-3769A FOR DEPICTION OF LIS 263-72A, BUT 12E-3769A REV. S DOES NOT SHOW THE DEVICE. WHAT MAKE/MODEL NO. IS THE DEVICE, AND WHERE IS THIS INFO. DEPICTED? PROVIDE ACCESS TO EQ PACKAGE (COPY NOT NECESSARY) FOR REACTOR LOW WATER LEVEL INSTRUMENTATION. SBGT Ml2-0-90-025: (1) WHY WAS THE DESIGN CHANGED TO TRIP ALL RX. BLDG. VENT & EXHAUST FANS, INCLUDING THE UNAFFECTED UNITS, IN CASE AN INITIATION SIGNAL IN THE OPPOSITE UNIT? (2) IS THIS BECAUSE THE ISOLATION DAMPER CLOSURE CAUSED THE UNAFFECTED UNIT RX BLDG FANS TO LOSE SUCTION SOURCE? SBGT Ml2-0-90-025: WHAT VENTILATION SOURCE WILL PROVIDE RX BLDG VENTILATION IN THE NON-ACCIDENT UNIT, IF ALL THE RX BLDG FANS ARE TRIPPED? CALC 0349-E-30 SUPPORTS A "NEW SETPOINT" (P. 85) OF 85.83 + 1 DEC AND 155.22 + 1 INC; HOWEVER, THE CALIBRATION DATA SHEET, P.68 OF DIS 0500-03 REV. 13, ALLOWS A GREATER TOLERANCE (85.8 + 2 AND 155.2 + 2). ALSO, "85.83 :!. l" IS NOT STATISTICALLY MEANINGFUL. PLEASE EXPLAIN. - - 3
116 117 118 119 120 121 122 123 124 126 127 128 129 130 131 132 133 134 135 136 137 138 139 140 141 142 143 144 145 146 147 SEE ATTACHED: M12-0-90-025 SBGT POST MOD PROCEDURES SP-91-2-29 SP-91-1-12 PLEASE MAKE AVAILABLE FOR REVIEW THE LATEST NPRDS/CFAR REPORTS (LOCATION, CONTACT PERSON, TIME ETC.) PAST 3 YEARS. P.LEASE MAKE AVAILABLE FOR REVIEW DESIGN BASIS DOCUMENTATION (FOR HPCI LPCI, ETC - PROVIDE A LISTING OF AVAILABLE DBDs UNDER RECONSTITUTION PROGRAM). MOD Ml2-2-91-22: PROVIDE DOCUMENTATION TO SUPPORT SEISMIC INSTALLATION OF RELAY CV 902-30/Al INSTALLATION DWG M310 SH 310 (HPCI VALVE M02-230l-10 INTERPOSING RELAY) MOD M12-2-9l-22: NEED TO WALKDOWN RELAY CVAl INSTALLATION (HPCI VALVE M02-2301-l0 INTERPOSING RELAY). PROVIDE METHOD TO ENSURE THAT CHANGES TO SURVEILLANCE PROCEDURES, SUCH AS MT&E AND SETTING TOLERANCES, WILL BE CONTROLLED AND REVIEWED AGAINST APPLICABLE CALCULATIONS SO THAT THE SETPOINT CALCULATION IS NOT INVALIDATED. PROVIDE ANALYTICAL LIMITS/ACCIDENT ANALYSIS LIMITS USED IN SAFETY ANALYSIS FOR TORUS - LO AND HI LEVEL AND BULK TEMPERATURE; HPCI/LPCI INITIATION - LO-LO (L2) LEVEL AND HI DRYWELL PRESS; AND RPS TRIP - L3, INCLUDE THE BASIS AND CALCULATION WHICH SUPPORTS THESE LIMITS. PROVIDE A COPY OF THE OPERABILITY ASSESSMENT PERFORMED FOR THE YARWAY LEVEL SWITCH DRIFT ISSUE. MOD Pl2-3-93-614: (1) IS IT COM'lON PRACTICE TO GROUND THERMOCOUPLES? (2) DURING AN ACCIDENT AND IF THE THERMOCOUPLES BECAME SUBMERGED, COULD GROUND CURRENTS (COMMON MODE CURRENTS) FLOW AND CAUSE FALSE INDICATION? (3) HAVE GROUND CURRENTS BETWEEN TC AND RECORDER SYSTEM GROUND EVER CAUSED A PROBLEM? MOD P12-3-93-614: (1) PROVIDE COMPLETED COPY OF DIS 1600-18 PERFORMED ON OR AROUND MARCH 8, 94; (2) WAS THIS SURVEILLANCE PERFORMED PRIOR TO COMPLETING THE CABLE/CONDUIT CHANGES? (3) ARE RECORDERS 1641-200 A/B CONSIDERED CLASS lE? DIS 1600-18 SUPPRESSION POOL TEMP. CAL: (1) WHO COMPARES I.20.C.' PG 69, WITH I.5.C(2)' PG 56, TO DETERMINE EACH TC INPUT IS FUNCTIONING SATISFACTORILY, FOLLOWING RESTORATION? SUPPRESSION POOL BULK TEMP: (1) SINCE THIS TEMP. IS TAKEN ONCE PER SHIFT, HOW WOULD AN OPEN/SHORTED TC INPUT AFFECT THE READING; (2) WOULD THE CHANNEL CHECK READILY DETECT THE MALFUNCTION AND/OR WOULD THE ALARM? SUPPRESSION POOL TEMP. TC: (1) HAS DRESDEN HAD ANY PROBLEMS WITH TC DEGRADATION DUE TO MATERIAL ENVIRONMENT IN THE TORUS? (2) IF SO, WOULD THE CHANNEL BULK TEMP. CHECK BE ABLE TO DISTINGUISH lHlS DEGRADATION (CHANNEL CHECK SENSITIVITY)? PROVIDE ACCESS TO EQ BINDERS FOR FOLLOWING INSTRUMENTS LIS-003-0263-72A (RX LEVEL-YARWAY), LIS-003-1626-10 (TORUS), PS-003-1632-A (DRYWELL), PS-003-2360 (HPCI PUMP SUCTION), PS-003-2368-A (HPCI TURBINE EXH.); DPT 003-2352 (HPCI STM LINE FLOW) TS-003-2370-A (HPCI STEAM LEAK) PT-003-2389-A (LOW RX. PRESS/HPCI ISOL) PLEASE PROVIDE MISSING PAGES 27 AND 91 TO CALC NO 0349-E-10. MOD Pl2-2-93-601: (1) PROVIDE JUSTIFICATION FOR ROTATING THE WATER SENSING LINE TEST TAP FLANGE BY go*; (2) PROVIDE JUSTIFICATION THAT DETAIL 'B', DWG M310, SH 207, IS SEISMICALLY QUALIFIED; (3) PROVIDE TRANSMITTER (1153 DDS RG) VENDOR MANUAL (V-205) DIS 1600-17, REV. 7, PG. 9, NOTE FOLLOWING STEP 8: DO IMs KNOW THEY ARE TO RECORD ROSEMOUNT XMIT. CALIB. MEASUREMENTS TO THREE DECIMAL PLACES? DATA SHEET 1 PG 24 (Pl2-2-92-601, 3/18/93) MEASURED TO TWO PLACES. WHAT OTHER PROCEDURES HAVE THE SAME NOTE? PROVIDE 0349-E-OO, REV. 1, CECO RVWLIS MASTER CALC. (IF NOT TO LARGE, INCLUDE TWO COPIES) (FOLLOW UP ON RESPONSE TO JL-11 [N-105] OF 8/26/94) (1) THE CECO RESPONSE SAYS FUNCTION OF LIS-003-0263-.72A, ET AL, IS TO "PROTECT AGAINST AN ACCIDENT CONDITION." HOWEVER, IT APPEARS THAT THESE INSTRUMENTS ARE REQUIRED TO INITIATE MITIGATION OF ACCIDENTS AFTER THEY HAVE OCCURRED. PLEASE CLARIFY THE ORIGINAL RESPONSE. (REF. A) B) SEE ATTACHED. M-310 SH 102 REV. 2) IS THERE A DRAWING SHOWING THE IMPULSE LINE ROUTING FOR THE DRYWELL PRESSURE INSTRUMENTS? PROVIDE ASSURANCE THAT THE LINES ARE PROPERLY SLOPED TO AVOID TRAPS OR LOOP SEALS. C) HOW IS THE DRYWELL END OF THE IMPULSE LINE PROTECTED FROM BLOCKAGE, ETC? D) HOW LONG IS THE IMPULSE LINE (LONGEST LINE) AND WHAT DIAMETER? PROVIDE INSTALLATION DETAILS FOR: PS-003-2360 (HPCI P. SUCTION); PS-003-2368-A (HPCI TURBINE EXH); DPT-003-2352 (HPCI STEAMLINE FLOW); TS-003-2370-A (HPCI STEAM LEAK DET.); PT-003-2389-A (HPCI STEAMLINE LOW RX PRESS); LS-003-2350-A (CST LEVEL). SHOULD SHOW PROCESS (PIPING, ETC.) INTERFACE AND INSTR. INSTALLATION. WHAT ARE APPROACH CONDITIONS TO FOLLOW INSTRUMENTS? (ARE FLOW ELEMENTS IN ALL UNINSTRUCTED STRAIGHT RUN OF PIPE.) (PROVIDE BASIS FOR TRIP SETTINGS FOR TOPIC ITEMS BE, 9A, 10.l AND 10.2C, WHICH DO NOT HAVE REFERENCED CALCULATIONS) WHEN WILL THESE CALCULATIONS BE PERFORMED (TENTATIVE SCHEDULE)? SEE ATTACHED. (1) PROVIDE TRAINING PLAN (QUALIFICATIONS) FOR I&C ENGINEERS BOTH SITE AND CORPORATE. (09-02-94) (2) MAKE AVAILABLE FOR REVIEW THE TRAINING RECORDS FOR I&C ENGINEERS. (COULD BE THE WEEK OF SEPT 12) PROVIDE INSTALLATION DETAILS FOR LT-002-0646 B, AND PS-002-1621B. DIS 1600-7 PERFORMED (05/01/94) DURING Pl2-3-93-614 (TORUS TEMP CONDUCTS): WHY DID SOMEONE CHANGE UNSAT TO SAT FOR TC 1641-205, TC 1641-208, TC 1641-213 AND TC 1641-214? BELIEVE UNSAT FOLLOWS THE PROCEDURE AND.CORRECTIVE ACTIONS WERE ADEQUATELY ANNOTATED. Ml2-3-89-24: PROVIDE CALIBRATION PROCEDURE/PM FOR TEMP INDICATOR 3-5741-19. DIS 0260-06 TABLE 1, PG. Il7, LT-3-263-23B (ATWS LO LO LVL) PROVIDE THE SPAN SHIFT BIAS ADJUSTMENT SCALING USED TO ADJUST THE ZERO & SPAN CALIBRATION POINTS (ACTUAL SCALING DETERMINATION). IN RESPONSE TO Nl32 (DB-41): PROVIDE COPY OF PIF AND AN IDEA AS TO WHAT CORRECTIVE ACTIONS ARE GOING TO BE CONSIDERED AND WHEN TO COMPLETE THEM. WE UNDERSTAND ANALOG INSTRUMENTATION ASSOCIATED WITH TR 2-1641-200B FAILED WHEN POWER WAS TRANSFERRED FROM MAINTENANCE POWER TO NORMAL (UPS) POWER. A W.R. WAS WRITTEN 8-26-94, AND WE UNDERSTAND A PIF IS BEING DISPOSITIONED. PLEASE PROVIDE STATUS OF THE PIF OR OTHER ACTIONS BEING TAKEN. SERVICE WATER AND OTHER PIPING (e.g., RBCCW LINES) ARE ROUTED IN THE AREA OF THE "CAGED" SAFETY RELATED INSTRUMENTS ON ELEV. 545'. WHAT ARE THE CONSEQUENCES OF A SINGLE PIPE BREAK IN THESE AREAS? WHAT ARE THE CONSEQUENCES OF A BREAK IN THE HEATING STEAM LINE(S) OVER CLASS IE PANELS 2203-73A (DIV. I) AND 2203-73B (DIV II) THAT ARE LOCATED IN U2? ARE THE LINES SEISMICALLY SUPPORTED? THE MOORE INDUSTRIES ISOLATION DEVICES IN THE CONTROL BOARD (FOR EXAMPLE, TORUS TEMP ISOL 943-237, - 238, -242A, -242B). AND ELSEWHERE, DO NOT PROVIDE SEPARATION OF CONNECTED INPUT, OUTPUT, AND EXCITATION 4
148 149 150 151 152 153 154 155 156 157 158 159 160 161 162 163 164 165 166 167 168 169 170 171 172 173 174 175 176 177 178 179 180 181 182 183 184 WIRING. HOW DOES THIS CONFORM TO DRESDEN SEPARATION CRITERIA? WHAT IS THE QUALIFICATION BASIS FOR THE ISOLATION DEVICES? PROVIDE A GUIDED PLANT TOUR. CALC. 0349-E-30 DOES NOT APPEAR TO ADDRESS THE EFFECTS OF THE "BACKFILL MOD" (TO ADDRESS NON- CONDENSABLE GASES IN REF .. LEG) ON THE COLD REFERENCE LEG CONFIGURATION, WITH RESPECT TO EFFECTS ON ACCURACY. WHERE ARE THESE POTENTIAL EFFECTS EVALUATED AND ANALYZED? PROVIDE REF. 21 OF CALC. 0349-E-30: CALC 0349-M-13 (RVWLIS REF LEG TEMP DISTRIBUTION) SEE ATTACHED CONCERN #1 RE: POST MODIFICATION TESTING. PLEASE PROVIDE THE FOLLOWING DOCUMENTS DIS 1600-18, NED-I-EIC-0251, NED-I-EIC-0089, NED-I-EIC-0090. CECO/NUS DWG M-4025 SH 1, 2 (PIPING ISO FOR RV LEVEL INSTR) APC 6-30-93: PROVIDE BASIS/DISPOSITION OF "HOLD" STATUS AND DOCUMENTATION OF FIELD VERIFICATION; FOLLOW-UP ONT103 RESPONSE RE COND CHAMBER. [SPECIFIC QUESTIONS (A) THRU (D) ATTACHED] THE RESPONSE TO N-112 APPEARS TO INDICATE THAT THERE IS NO SEISMIC OR ENVIRONMENTAL QUALIFICATION FOR THE YARWAY INSTRUMENTS. IF SO, HOW IS THIS ACCEPTABLE. THE TRAINING MATERIAL PROVIDED IN RESPONSE TO N-101 REFLECTS A YARWAY CONDENSING CHAMBER AND IS AN OBSOLETE CONFIGURATION WHAT IS THE TRAINING DOCUMENTATION OF RECORD FOR THE NEW (COLD REFERENCE LEG) INSTALLATION? [FOLLOW-UP ON RESPONSE TO T-103] THE RESPONSE TO T-103 (RVWLIS CONDENSING CHAMBERS, ETC.) INCLUDED CONTRACTOR (NUS) RESPONSES TO VENDOR (GE) COMMENTS PROVIDE DOCUMENTATION OF THE RESOLUTION OF THESE RESPONSES; I.E. WAS G.E. AGREEABLE TO THE RESPONSES. CALC NED-I-EIC-90 IN SECT 10 SUGGEST CHANGING THE SETPT OF PS 1621-B FLOW 53 IN WC + l TO 49 IN W.C. + 1.5 INCREASING. TECH SPEC L.C.O. IS 55.046657 IN W.C. (WITH HEADCORR) DIS 1600-02,-REV. #6 IDENTIFIES TRIPSET AS 53 IN WCil PLEASE CLARIFY CALC SECT 10. SEE ATTACHED CONCERN #2, RE: SETPOINT TOLERANCES AND INCONSISTENCIES. SEE ATTACHED CONCERN H3, RE: LACK OF ENGINEERING RIGOR. HOW IS THE CALC. INFORMATION TO BE INCORPORATED INTO THE CALIBRATION PROC. FOR THE CHANGED SET PTS? NO REFERENCE TO CALCS IS NOTED IN ANY CALIBRATION PROCEDURE OR DATA SHEETS! (ENGINEERING CALC. INTERFACE TO CALIB. PROCEDURE) AND VICE VERSA. PROVIDE LAST U3 RESPONSE TIME TEST OF THE RPS INSTRUMENTS IN TABLE 3.1.l OF TECH SPECS. ATTACHMENT 3 TO CALC. NED-I-EIC-91, REV. l (4-16-93) IDENTIFIES THAT SOR CONSIDERS DRYWELL PRESSURE SWITCHES PS-2(3)-1632A-D, ET AL. AS COMMERCIAL GRADE. ALSO, GEN ASSUMPTION 2 OF CALC. STATES THAT SEISMIC QUALIF. IS NOT REQUIRED. THESE INSTRUMENTS PERFORM SAFETY FUNCTIONS. PROVIDE THE DOCUMENTATION SUPPORTING THEIR USE FOR SAFETY FUNCTIONS. REVIEW OF SEVERAL CALCS REVEALS ONLY ASSUMED (VENDOR) DRAFT DATA WHEN ACTUAL DATA FROM MAINTENANCE - OOS SHOULD PROVIDE SPECIFICS. (1) WILL CALCS BE UPDATED TO REFLECT ACTUAL INSTRUMENT (DRIFT DATA) EXPERIENCE? (2) WILL SOMEONE VERIFY THAT VENDOR DRIFT INFO IS CONSERVATIVE TO ACTUAL DRIFT DATA? SEE ATTACHED CONCERN #4, RE: ANALYTICAL LIMIT RETRIEVABILITY. SEE ATTACHED CONCERN #5, RE: APPLICATION OF INSTRUMENT ISOLATORS. SEE ATTACHED FOR MOD Pl2-3-93-614. THE PROCESS USED TO "NORMALIZE" A VENDOR ACCURACY SPEC SEEMS QUESTIONABLE. REF. l STATES VENDOR'S 30 VALUE CAN BE DIVIDED BY 3 TO "NORMALIZE" IT TO A 10 VALUE. REF. 2(CALC) PARA TO INCORRECTLY APPLY AN ASSUMPTION (ASSUMPTION 9) TO THE PROCESS INSTRUMENT, NOT THE MTE, INCORRECTLY IMPROVE ACCURACY BY A FACTOR OF 2. THAT A 7 .1.2 APPEARS AND CALC 0349-E-30 REV. 3 (RVWLIS): ANSWER ATTACHED QUESTIONS (A) THRU (N) REGARDING BASIS FOR OATUM POINTS AND OTHER ASSUMPTIONS/VALUES USED IN THE CALCULATION. (1) PROVIDE RESULTS OF DRESDEN'S CONTACT TESTING PROGRAM. (2) HAVE ALL CONTACTS BEEN IDENTIFIED AND TESTED? CALC 0349-E-30 OR E-10 FOR PT-263-20 A, B, C, D: (1) WHY WASN'T DRIFT, CAL ACCURACY AND MTE ACCURACY FIGURED IN THE SETPOINT DETERMINATION? (2) PROCEDURE DIS 0260-06 USES AN MTE OF 0 TO 1500 OR 0 TO 2000 PSIG HEISE GAUGE, HOW IS THE ACCURACY OF THE MTE (+ PSIG) MAINTAINED? Pl2-3-93-208: - (1) HAVE ATWS SETPOINT CALCS BEEN UPDATED TO REFLECT THE USE OF THE G.E. TRIP UNITS? (2) HAVE GE TRIP UNITS BEEN INSTALLED IN BOTH UNITS AND ARE THEY CONSIDERED OPERABLE AT THIS TIME? SEE ATTACHED CONCERN 16, RE: APPARENT LACK OF MARGIN BTWN DEOPs AND TECH SPEC. [REF RESPONSES TO T-108, N-096, T-073, ET AL] THE RESPONSE TO T-108 IS NOT CLEAR. THERE ARE 3 ANALYTICAL LIMITS OF INTEREST: (1) THE AL SUPPORTING THE TS TRIP LEVEL SETTING OF <5" (HI LEVEL); (2) THE AL SUPPORTING THE MAX/MIN LCO FOR WATER VOLUME. (3) THE AL SUPPORTING THE LCO FOR MAX/MIN DOWNCOMER SUBMERGENCE. (CONTINUED ON ATTACHED SHEET). SEE ATTACHED CONCERN #7, RE: NO CALIBRATION PROCEDURES FOR CST & TORUS LEVEL SWITCHES. FSAR 7.5.1.l IDENTIFIES SUPPRESSION POOL LEVEL AND TEMP AS RG 1.97 CAT l TYPE A VARIABLES. THE TEMP ACCY. CALC [l] EXCLUDES SEISMIC EFFECTS AND THE LEVEL ACCY. CALC. [2] SELECTIVELY SEISMIC EFFECTS FOR CERTAIN INSTRUMENTS (E.G., RECORDER). THIS DOES NOT APPEAR TO CONFORM C0"'"1ITMENTS? ATWS DWG 12E-7582C: SEE ATTACHED. DIS 0260-06 (REV. 1) HOWEVER, INCLUDES 40 RG 1.97 (1) SHOULD ANN WINDOW 146, "ATWS LEVEL/PRESSURE ABNORMAL", BE VERIFIED IN THIS PROCEDURE OR IS IT VERIFIED SOMEWHERE ELSE? (2) STOP 40, 66, 121, TRAIN A CHECKLIST, SHOULD A NOTE BE ADDED THAT THE BKRS TRIPS IN 9 SECONDS? PROVIDE A DISCUSSION OF THE ROLES & DUTIES OF THE STATION M&TE COORDINATOR. PROVIDE LAST THREE CALIBRATIONS FOR TDRs; 2-2330-102B-l AND 2-2330-102A-l; 2-595-117A, B, C, D; AND 3-150-105, 133, 182, 282. REFERENCE DVR 12- 2-90-160; 12-2-92-111; AND 12-3-92-014 RESPECTIVELY. PROVIDE PM THAT CHANGES OUT ENERGIZED AND DE-ENERGIZED AGASTAT GP RELAYS REFERENCE DVR 12-3-91-63 (249- 200-91-06301) PLEASE PROVIDE LAST 2 SURVEILLANCES FOR TORUS WR LEVEL (LT(3}-1641-5A/B) DRYWELL PRESSURE (PS-2-1632A, B) DRYWELL HIGH PRESS (PS-2-1621-B) SUPPRESS POOL TEMP (TT-003-1641-222A, TY-3-1641-225A) RX LOW LVL (PS-2-263-52B) DEOP 200-1 APPEAR TO PROVIDE FOR A 0.5 IN MARGIN FOR INSTRUMENT ACCURACY FOR TORUS HI/LOW OPERATING LIMITS (TS VALUES APPEAR TO BE EQUIVALENT TO -1.0 IN AND -SIN, AND TS VALUES* AL VALUES) [1,2]. THERE IS NO CALC FOR THE N.R. TORUS LEVEL INSTRUMENT. HOW IS IT KNOWN THAT THE ACCY. IS ADEQUATE? CALC NED-I-EIC-096 IDENTIFIES TEMPERATURE LIMITS OF 180.F ON THE MERCOID PS, BUT SHOWS AN ACCIDENT TEMP OF 230*F MAX AND l HR RAD ENV OF 5.4.E5. 15.l.3.2 STATES THAT THIS IS NOT A PROBLEM BASED ON DATA IN 11.1. PLEASE CLARIFY. REFERENCE THE EQ FOR THE DEVICE. NED-I-EIC-096 DOES NOT IDENTIFY OR EVALUATE SEISMIC EFFECTS. A) ARE THE MERCOID SWITCHES SEISMICALLY QUALIFIED? B) IS THERE SUFFICIENT MARGIN TO PRECLUDE SPURIOUS TRIP DUE TO SEISMIC EVENT AND WHAT IS BASIS FOR MARGIN? 5
.* t' 185 186 187 188 189 190 191 192 193 194 195 196 197 NED-I-EIC-096 CONCLUSIONS (P. 39) DO NOT APPEAR TO IDENTIFY MARGIN TO SPURIOUS TRIP OF THE HPCI PUMP. WHAT IS THE DESIGN BASIS RANGE OF HPCI PUMP TURB. EXH PRESSURE AND HPCI PUMP SUCTION PRESSURE DURING ACCIDENT/EVENT CONDITIONS? WHAT IS MARGIN TO SPURIOUS TRIPS? PLEASE PROVIDE THE TOP 50 TECHNICAL ISSUE LIST (WITH RESPONSIBLE PERSON ON EACH ITEM AND ACTIVE DUE DATE). [NED-I-EIC-108] GEN ASSUMPTION 2m A.) WHY ARE SEISMIC EFFECTS IGNORED? WHAT ABOUT AVOIDANCE OF SPURIOUS TRIP DURING SEISMIC EVENT? B) ARE THE INSTALLED DEVICES SEISMICALLY QUALIFIED? [NED-I-EIC-108, DIS 2300-06]: WHERE TEMP. SWITCHES ARE USED TO DETECT AND RESPOND TO STEAM BREAKS (THIS IS ONE EXAMPLE), WHAT ARE THE RESPONSE TIME REQUIREMENTS AND HOW IS IT ASSURED THEY WILL BE SATISFIED FOR OBA CONDITIONS? THE CALC AND TEST PROCEDURES DO NOT ADDRESS THIS PERFORMANCE. [NED-I-EIC-108] GEN ASSUMPTION #11: HOW CAN POST ACCIDENT RADIATION INDUCED ERRORS BE "ASSUMED TO BE SMALL"? DIS 2300-1, REV. 12, 2-24-94, DATA SHEET 3 IDENTIFIES A SETPOINT LESS CONSERVATIVE (NEGATIVE MARGIN) THEN IDENTIFIED IN CALC NED-l-E!C-0111, REV. 2, 7/12/94. (THIS IS ANOTHER EXAMPLE FOR CONCERN #2) [CALC NED-I-EIC-0111] (1) P. 5, PARAGRAPH SA - WHAT IS BASIS FOR DIVIDING CAL TOLERANCE BY 3? (2) P. 5, PARAGRAPH SB- ARE TEMPERATURE AND SEISMIC ERRORS CONSIDERED RANDOM? IF SO, HOW JUSTIFIED? LER 249/92-019: PROVIDE RESPONSE/ACTIONS TO ADDRESS TRACK #249-180-92-12801 AND 249-180-92-12802. LER 249/91-003: PROVIDE RESPONSE/ACTIONS TO ADDRESS TRACKING #249-200-91-03603 AND 249-200-91-03604. LER 249/94-008: PROVIDE POLICY STATEMENT #12 NEED TO WALKDOWN TEMP ALTs. UNIT 2, 34-92 (DEGRADED VOLTAGE RELAY & AGASTAT TIMER) UNIT 2, 37-93 {CHART RECORDER FOR RX LEVEL 'A' NORMAL RANGE) UNIT 2, 50-93 (MONITOR AIR COMPRESSOR 2B lAC PERFORMANCE) LER 249/94008: CORRECTIVE ACTIONS INCLUDED CHANGING DAP 02-15, REV. 4, THE STATION MANAGER OR DES!GNEE TO APPROVE CHANGING AN !RP LEVEL l OR 2 DOES FLOW CHART F.2., PG 6, IMPLEMENT THE ABOVE? I DON'T SEE HOW A LVL PG 3, POLICY E.3, TO REQUIRE EVENT SCOPE & SCHEQULE, HOW 1 & 2 WILL GET TO THE PLANT MANAGER. RESPONSE (1) TO (JL-20) T-134, WHAT IS THE BASIS, OPERATE IN? CALC OR WHAT EVER FOR THE 2 MINUTE ENVIRONMENT THAT THE YARWAY HAS TO (2) WILL THE YARWAY BE ABLE TO PERFORM IT'S FUNCTION WITH OUT BEING QUALIFIED? 6 }}