ML17258A727

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Requests Written Notification Re Steps Taken to Meet NRC Requirements Re Override Capability of Engineered Safety Features Sys Actuation Signals for Containment Purge Valve Isolation.Response Requested in 45 Days
ML17258A727
Person / Time
Site: Ginna Constellation icon.png
Issue date: 01/12/1981
From: Crutchfield D
Office of Nuclear Reactor Regulation
To: Maier J
ROCHESTER GAS & ELECTRIC CORP.
Shared Package
ML17258A728 List:
References
TASK-06-04, TASK-6-4, TASK-RR LSO5-81-01-008, LSO5-81-1-8, NUDOCS 8101280414
Download: ML17258A727 (11)


Text

Docket No. 50-244 LS05"81-1-008'ANUARY 1 3 198l Nr. John E. Maier Vice P res ident Electric and Steam Production Rochester Gas 5 Electric Corporation 89 East Avenue South Rochester, New York 14649

Dear Mr. Ma.ihe:

D ISTRI BUTION:

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SUBJECT:

ELECTRICAL, INSTRUMENTATION AND CONTROL ASPECTS OF TH 88I8 OVERRIDE OF CONTAINYZNT PURGE VALVE ISOLATION (INCLUDI RESOLUTION OF SEP TOP,ICOSI CONTAINMENT ISOLATION)-

GINNA As a result of our generic review of electrical override of engineered safety features, we have identified an area of concern at Ginna.

As discussed with your staff in telephone conferences on September 10,

1980, September 11,,1980, and September 22, 1980, the NRC staff has confirmed that the override of an automatic Engineered S'afety Feature (ESF)

, actuation signal at Ginna will incapacitate the system-level manual actuation features.

Further, this blocking of, the manual ac'tuation buttons is not annunciated to reactor operations personnel.

This condition applies to the Containment Ventilation Isolation, Containment Isolation and Containment Spray Systems.

The NRC staff position provides that the design est be such that the overriding of one type of safety actuation signal does not cause.'the bypassing (i.e., blocking) of any other type of safety actuation signal.

Further, the Use of any manual override provision rust be annunciated at the system level for every system'impacted.

In the earlier telephone conversations, your staff agreed to notify all reactor operators of the potential problem and the actions that need to be taken by the operators to mitigate thi's concern.

In the conversation of September 22, we were informed that this notification was issued on September 19, 1980.

However, in all three conversations it was your position that the designs do not violate the standards in effect in

1965, when the plant was designed, and therefore that the designs are acceptable.

Based on staff review of your design and procedures, we have concluded that it is unacceptable to have system-level manual actuation buttons (for safety-related systems) that could be disabled by an ESF override si gnal.

OFFICE $

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Mr. John E. Maier w 2 w

JANUARY 1 2 tIIi We concur with you that the training of operators is an acceptable short-term solution; however, it is not a satisfactory long-term solution.

We will

~ require, during your forthcoming (April-May 1981) refueling outage, that the following steps be taken:

1.

The override capability for individual containment isolation valves be modified such that:

Manual isolation is never bypassed.

b.

Only high containment radiation or safety injection signal, but not both, are bypassed by a single operator action of a switch.

2.

An annunciation be activated when a bypass condition is established.

As you are aware, we coamenced a similar generic study of ESF actuation

.signals as a result of Abnormal Occurrence 78>>5.

As a result of that study, the following additional requirements at Ginna are necessary:

3.

The feedwater isolation valve control system must be mdified to prevent valve motion when the isolation logic is reset or overridden; and 4.

You rmst coranit to replace the containment radiation channels that initiate containment isolation when Regulatory Guide

1. 141 is approved by the NRC.

The staff's safety evaluation related to abnormal occurrence 78-5 and SEP Topic VI-4 is enclosed.

You are requested to provide written coranitment to accomplish items 1,

2 and 3 during the April-May 1981 refueling outage and item 4 when Regulatory Guide 1-141 is approved by the Cottmission.

Your letter of coomitment should be dated within 45 days of-receipt of this letter.

Sincerely, original signed by Dennis M. Crutchfield Dennis M. Crutchfield, Chief Operating Reactors Branch 85 Division of Licensing

Enclosure:

Safety Evaluation

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Mr. John E. Maier We concur with you that the training of operators is an acceptable short-term solution; however, it is not a'.satisfactory long-term solution.

He will require, during your forthcoming (April-May 1981) refueling outage, that the following steps be taken:

1.

The override capability for individual containment isolation valves be modified such that:

a.

Manual isolation is never bypassed.

b.

Only high containment radiation or safety injection signal,, but not

both, are bypassed by a single operator action of a switch.

2.

An annunciation be activated when a bypass condition is established.

As you are aware, we comenced a similar generic study of ESF actuation signals as a result of Abnormal Occurrence 78-5.

As a result of that study, the following additional requirements at Ginna are necessary:

3.

The fee4cater isolation valve control system rest be modified to prevent valve motion when the isolation logic is reset

.or overridden; and 4.

You must coomit to replace the containment radiation channels. that initiate containment isolation when Regulatory Guide 1.141 is approved by the NRC.

The staff's safety evaluation related to 78-5 is enclosed.

You are requested to provide written commitment to accomplish items 1, 2 and 3 during the April-May 1981.refueling outage and item 4 when Regulatory Guide 1.141 is approved by the Comoission.

Your letter of comnitment should

,be dated within 45 days of receipt of this letter.

Sincerely.

Enclosure:

Safety Evaluation cc w/enclosure:

See next page Dennis M. Crutchfield, Chief Operating Reactors Branch P5 Division of Licensing OFFICE P SURNAME DATE$

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UNITEDSTATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 January 12, 1981 Docket No. 50-244 LS05"81-1-008 Mr. John E. Maier Vice President Electric and Steam Production Rochester Gas 5 Electric Corporation 89 East Avenue South Rochester, New York 14649 Dear Mr. Maier'.

SUBJECT:

ELECTRICAL, INSTRUMENTATION AND CONTROL ASPECTS OF THE OVERRIDE OF CONTAINMENT PURGE VALVE ISOLATION (INCLUDING RESOLUTION OF SEP TOPIC VI CONTAINMENT ISOLATION)-

GINNA As a result of our generic review of electrical override of engineered safety features, we have identified an area of concern at Ginna.

As discussed with your staff in telephone conferences on September 10, 1980, September 11,

1980, and September 22, 1980, the NRC staff has confirmed that the override of an automatic Engineered Safety Feature (ESF) actuation signal at Ginna will incapacitate the system-level manual actuation features.

Further, this blocking of the manual actuation buttons is not annunciated to reactor operations personnel.

This condition applies to.the Containment Ventilation Isolation, Containment Isolation and Containment Spray Systems.

The NRC staff position provides that the design ImIst be such that the overriding of one type of safety actuation signal does not cause the bypassing (i.e., blocking) of any other type of safety actuation signal.

Further, the use of any manual override provision IIUst be annunciated at the system level for every system impacted.

In the earlier telephone conversations, your. staff agreed to notify all reactor operators of the potential problem and the actions that need to be taken by the operators to mitigate this concern.

'In the conversation of September 22, we were informed that this notification was issued on September 19, 1980.

However, in all three conversations it was your position that the designs do not violate the standards in effect in.

1965, when the plant was designed, and therefore that the designs are acceptable.

Based on staff review of your design and procedures, we have concluded that it is unacceptable to have system-level manual actuation buttons (for safety-related systems) that 'could be disabled by an ESF override si gnal.

Mr. John E. Maier January 12, 1981 We concur with you that the training of operators is an acceptable short-term solution; however, it is not a satisfactory long-term solution.

We will

require, during your forthcoming (April-May 1981) refueling outage, that the following steps be taken:

1.

The override capability for individual containment isolation valves be modified such that:

a.

Manual isolation is never bypassed.

b.

Only high containment radiation or safety injection signal, but not

both, are bypassed by a single operator action of a switch.

2.

An annunciation be activated when a bypass condition is established.

As you are

aware, we commenced a similar generic stuQ of ESF actuation signals as a result of Abnormal Occurrence 78-5.

As a result of that study, the following additional requirements at Ginna are necessary:

3.

The feedwater isolation valve control system must be modified to prevent valve motion when the isolation logic is reset or overridden; and 4.

You must coranit to replace the containment radiation channels that initiate containment isolation when Regulatory Guide l. 141 is approved by the NRC.

The staff's safety evaluation related to abnormal occurrence 78-5 and SEP Topic VI-4 is enclosed.

You are requested to provide written comnitment to accomplish items 1,

2 and 3 during the April-May 1981 refueling outage and item 4 when Regulatory Guide 1.141 is approved by the Coranission.

Your letter of commitment should be dated within 45 days of receipt of this letter.

Sincerely, Dennis M. Crutchfseld, ief Operating Reactors Branch 45 Division of Licensing

Enclosure:

Safety Evaluation

Mr. John E. Maier January 12, 1981 cc w/enclosure:

Harry H. Voigt, Esquire LeBoeuf, Lamb, Leiby and MacRae 1333 New Hampshire Avenue, N.

W.

Suite 1100 Washington, D. C.

20036 Mr. Michael Slade 12 Trailwood Circle Rochester, New York 14618 Rochester Coranittee for Scientific Information Robert E. Lee, P h.D.

P. 0.

Box 5236 River Canpus Station Rochester, New York 14627 Jeffrey Cohen New York State Energy Office Swan Street Building Core 1, Second Floor Empire State Plaza

Albany, New York 12223 Director, Techni cal Development Programs 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 Supervisor of the Town of Ontari o 107 Ri dge Road West Ontari o, New York 1451 9 Resident Inspector R. E. Ginna Plant c/o U. S.

NRC 1503 Lake Road Ontari o, New York 1451 9 Ezra I. Bialik Assistant Attorney General Environmental Protection Bureau New York State Department of Law 2 World Trade Center New York, New York 10047 Director, Criteria and Standards Division 0ffice of Radi at ion P rograms (ANR-460)

U. S. Environmental Protection Agency Washington, D. C.

20460 U. S. Environmental Protection Agency Re gi on II Office ATTN:

EIS 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. Richard F. Cole Atomic Safety and Licensing Board U. S. Nuclear Regulatory Coranission Washington, D. C.

20555 Dr.

Emmeth A. Luebke Atomic Safety and Licensing Board U. S. Nuclear Regulatory Coomission Washington, D. C.

20555 Mr. Thomas B. Cochran Natural Resources Defense Council, Inc.

1725 I Street, N.

W.

Suite 600 Washington, D. C.

20006