ML17258A276

Forwards Safety Evaluation Re SEP Topic VI-7.B ESF Switchover from Injection to Recirculation Mode,Automatic ECCS Realignment. Second Refueling Water Storage Tank Level Sys & Second Set of Alarms Should Be Installed

ML17258A276
Person / Time
Site:	Ginna
Issue date:	10/26/1981
From:	Crutchfield D Office of Nuclear Reactor Regulation
To:	Maier J ROCHESTER GAS & ELECTRIC CORP.
References
TASK-06-07.B, TASK-6-7.B, TASK-RR LSO5-81-10-049, LSO5-81-10-49, NUDOCS 8110290533
Download: ML17258A276 (6)

Text

October 26, 1981 Docket No.

50-244'S05 10-049 Mr. John E. Maier Vice President Electric and Steam Production Rochester Gas 5 Electric Corporation 89 East Avenue Rochester, New York 14649

Dear Mr. Haier:

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SUBJECT:

SEP TOPIC VI-7.B:

ESF (ENGINEERED SAFETY FEATURES)

SWITCHOVER FROM INJECTION TO RECIRCULATION MODE, AUTOMATIC ECCS REALIGNMENT, GINNA The enclosed staff safety evaluation report is based on the additional informationzjrovided by your telephone call of October 1, 1981.

This evaluatiog~revises the staff's position regarding design of your facility in the subject area.

With regard to the reference topic, the staff has concluded that, as a result of the nest information. your facility does not-

.- -meet current licensing criteria.

To correct this situation, the staff pro-

~poses that a second refueling water storage tank level indication system and a second set of alarms be installed.

The need to actually implement these changes will be determined during the integrated safety assessment.

This topic assessment may be revised in the future ifyour facility design is changed or if NRC criteria relating to this topic are modified before the integrated assessment is completed.

Sincer ely,

Enclosure:

As stated cc w/enclosure:

See next page el Dennis M. Crutchfield, Chief Operattng Reactors Branch No.

B III Division of Licensing

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Mr. John E. Maier CC Harry H. V.oigt, Esquire

LeBoeuf, Lamb, Leiby and MacRae 1333 New Hampshire

Avenue, N.

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Suite 1100 Washington, D.,C.

20036 Mr. Michael Slade 12 Trailwood Circle Rochester,'ew York 14618 Ezra Bialik Assistant Attorney General Environmental Protection Bureau New York State Department of Law 2 World Trade Center New York, New York 10047 Jeffrey Cohen New York State Energy Office Swan Street Building Core 1, Second Floor Empire State Plaza

'Albany, New York 12223

Director, Bureau of Nuclear Operations State of New York Energy Office Agency Building 2 Empire State Plaza

Albany, New York 12223 Rochester Public Library 115 South Avenue Rochester, New York 14604

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Supervisor of the Town of Ontario 107 Ridge Road West

Ontario, New York 14519 Resident Inspector R. E.'inna Plant c/o U. S.

NRC 1503 Lake Road

Ontario, New York 14519 Mr. Thomas B. Cochran Natural Resources Defense Council, Inc.

1725 I Street, N.

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Suite 600 Washington, D. C.

20006 U. S. Environmental Protection Agency Region II Office ATTN:

E IS COORDINATOR 26 Federal Plaza New York, New York 10007 Herbert Grossman, Esq.,

Chairman Atomic Safety and Licensing Board U. S. Nuclear Regulatory Coranission Washington, D. C.

20555 Dr.'ichard F. Cole Atomic'Safety and Licensing Boar'd U. S. Nuclear Regulatory Commission Washington, D. C.

20555 Dr. Emmeth,A.

Luebke Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington,.D. C.

20555

TOPIC VI-7.B:

ESF ENGINEERED SAFETY FEATURES SMITCHOYER FROH INJECTION TO RECIRCULATION 'tlODE AUTOMATIC ECCS REAL GHflENT INTRODUCTION h/ost Pressurized 1,'ater Reactors (PiJRs) require operator action to re-align the ECCS for the recirculation mode following a LOCA.

The NRC staff has been requiring, on a case-by-case

basis, some automatic feat-ures to assist in the realignment of the ECCS from the injection to the recirc'ulation mode of operation.

The safety objective of this require-ment is. to increase the reliability of long-term cooling by reduci.ng the number of operator actions required to change system realignment to the recirculation mode.

The scope of this topic requires a review of the ECCS control system and the operator action required to realign the ECCS from injection to re-.,

circulation mode following a LOCA.

The sequence'f events from initia-tion of the injection mode to completion of the recirculation mode, the

. systems/components and instrumentation/controls utilized in the injection to recirculation process, and.the automatic and/or manual process requir-ed to complete the switchover. process are to be reviewed:

The object>>

ive of this review is to determine if automatic switchover is necessmy to protect public health and safety.

--'EYIBl CRITERIA The current licensing criteria which govern'he safety issue are identi-.:~.-.

fied in Table 7-1 of the Standard Review Plan.

The most, significant of, these criteria are:

1.

Branch Thchnical Position 1CSB 20, 2.

IEEE.Std. 279-1971, and 3.

Regulatory Guide 1.62.

RELATED SAFETY TOPICS AND INTERFACES

'he scope of review or this topic was limited to avoid duplication of

'ffort since some aspects of the review were performed under related topics.

The related topics and the subject matter are identified below.

Each of the related topic reports contain the acceptance criteria and review guidance for its subject matter.

III-6 Seismic Design Considerations III-10.A Thermal-overload protection for motor operated valves

'II-11 Component Integrity III-12 Environmental guali ficafion IV-1.A Operationwith less than all reactor coolant loops in service Y-10.B RHR Reliability Y-11 High Pressure/Low Pressure Interface VI-7.A.3 ECCS Actuation'Syste'm YI-7.C.1 Independence of Onsite Power YI-lO.A Testing of ESF System VI-10.B Shared Systems 3

VIII-2 Onsite Emergency Power Systems VIII-3 Emergency dc Systems VIII-4 Containment Penetrations The following topics are dependent on the present topic information for completion.

VI;4 Containment Isolation System VI-7.C.2 ECCS Single Failure Criterion IY.

REVIEW GUIDELINES ICSB 20 states that automatic transfer to the recirculation mode is preferable to manual transfer and should be provided for standard plant designs submitted for review on a generic basis under the Commission's standardization policy.

ICSB 20 also states that a design that provides manual initiation at the system level of'he transfer to the recirculation mode, while not ideal, is sufficient and satisfies the intent of IEEE Std. 279 provided that adequate instrumentation and information display are available to the operator so that"'he can make the correct decision at the correct time.

Furthermore, it'should be shown that, in case

'of operator error, there are sufficient time and information avail-

.able so that the operator can correct the error, and the consequences of such an error are acceptable.

V.'VALUATION Redundant and '.ndependent Refueling Water Storage Tank (RWST) level instrumentation.is used to alert the operator when he must initiate a manual change over from the injection mode to the recirculation mode of emergency core cooling.

The instrumentation is qualified for the design basis environmental and seismic conditions at their location.

(The RWST is located in the auxiliary building).

Each instrument channel is powered from a separate Class lE bus.

These

. buses are evaluated in SEP Topic VI-7 AC.l.

One channel provides level indication, the other channel provides the low level alarm function..

'he maximum tank drawdown rate occurs for a large LOCA in which all engineered safety features operate.

This rate is 8880 gpm (1650 gpm

HPSI, 4000 gpm LPSI, and 3230 gpm for containment spray).

By procedure, one train is to be stopped at 31'WST level if both trains are operating,

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If the operator should. ignore this alarm (and his indicator from the other channel) he has 71,925 gallons or approximately 8 minutes until he reaches the 105 RWST level.

Changeover normally occurs at 10Ã,

but 34,250 gallons or 3 minutes additional injection on both trains is possible.

Redundant valves are used to close minimum flow lines

( that may contain highly radioactive water) that return flow to the refueling water storage tank.

However, two of these valves are in series and share, the same motive power (air) and fail closed on loss of air.

The staff's review of valve failures does not indicate a history of failures in air operated valves at the Ginna plant.

VI'.

CONCLUSION As a result of our review, the staff concludes that:

1.

Branch Technical Position ISCB 20 has not been satisfied because of the short time (11 minutes) that is available for the operator to detect and correct a failure to follow procedures and his reliance on a single alarm to-alert him to'uch an error.

2.

A recirculation path to the r'efueling water storage tank relies upon two air operated valves that share an air supply.

Although these valves are not entirely independent, plant operating exper-ience has demonstrated the acceptability of this design; and 3.

Beyond the failures identified in Topic VI-7.C.l, there are no si~gle failures within either ECCS train that could result in a simultaneous.

loss of both ECCS trai n nor in asignificant release of fission products as a result of the changeover from the injec-tion to the recirculation mode of ECCS at Ginna.

l The staff proposes that a second refueling water storage tank level indication system and a second set of alarms be installed.