ML17297A581
| ML17297A581 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 06/18/1981 |
| From: | ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY, ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR, BECHTEL GROUP, INC. |
| To: | |
| Shared Package | |
| ML17297A580 | List: |
| References | |
| NUDOCS 8107230144 | |
| Download: ML17297A581 (272) | |
Text
INDEPENDENT DESIGN REVIEW of the PALO VERDE NUCLEAR GENERATXNG STATION INSTRUMENTATXON AND CONTROL SYSTEMS Before the XNSTRUMENTATXON & CONTROL SYSTEMS REVIEW BOARD VOLUME XI of XXX Pages 215 346 Phoenix, Arizona June 17-18, 1981
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VOLUME II 3 INDEX'0 Open Item Response 216 Compliance With Regulatory Requirements Standard Review Plans 229 General Design Criteria 245 Regulatory Guides 252 IEEE Standards 263 Branch Technical Positions 275 IE Bulletins, Circulars and Information Notices 280 NUREG-0737 299 Open Item Response 12 Additional Items of Concern 13 Instrumentation and Control Systems Branch Concerns (NRC Letter Dated April 16, 1981) 323 Addendum - Open Items 347 15 16 18 19 20 21 22 23'4 25 GRUMLEY REPORTERS Phoenix, Arizona
r 2l6 Phoenix, Arizona June l8, 198l 8:05 a.m.
MR. ALLEN: The first thing. we will start off this morning with is we will ask Bechtel to report on the open items they were able to resolve last night and then we will get into the subject matter. Hopefully, we will be done by noon.
MR. BINGHAM: Dennis, would you go over the open items 10 we want to answer at. this time?
MR. KEITH: Yes. 'The first one that we were asked was the criteria for routin'g of the sensing lines for 13 instruments that were concerned with the high-energy line 14 break. We have done extensive high-energy line break analysi 15 It has been particularly related to piping and large components. We are now in the process, of performing that.
17 analysis as related to instrument lines, condu'it. Those are 18 the two key things, instrument lines and conduit, the things which get routed last. We will be applying the same criteria 20 to the instrument lines and the conduit that we apply to the 21 rest of the analysis, and that is if a system is required to 22 mitigate the accident, then we can not lose redundancy. If
.23 it is required for other safety concerns, then we can lose redundancy, but not lose function. Interpreting that for our 25 instrument lines, since we have four'of them, for those GRUMLEY REPORTERS Phoenix, Arizona
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2l7 lines which are required to mitigate the accident and bring the plant to a safe shutdown, we will allow a loss of one of the four of those instrument lines. Then for the systems that, are safety systems and can't lose redundancy, we will allow the loss of two of the four of those instrument lines.
Those are our criteria.
MR. ALLEN: Any. questions from the Board on the response?
Any questions from the NRC?
10 MR. ROSENTHAL: At some point in the plant, you may have to bring impulse lines fairly close together, in which 12 case I assume that you will put them in raceways of some sort 13 MR. KEITH: We will have to do something to protect 14 them, you know, put things that are considered a barrier in 15 front of them or a guard pipe around the break.
16 MR. ROSENTHAL: Have you reached conclusions about 17 that yet?
18 MR. KEITH: We have not completed that analysis and we 19 have not implemented any design for that.
20 The concern was raised on MSIV testing. We do 21 have a test switch on our main steam isolation valves on 22 the main control boards in the main control room, and going 23 to test, we will stroke the valves 10%, so we can do that 24 at power.
25 MR. ROGERS: That was my question. I had asked that GRUMLEY REPORTERS Phoenix, Arizona
with regard to the main steam isolation system and whether that met the criteria that were listed in 2A1. That also applied to the auxiliary feedwater system and containment isolation system, Dennis. Specifically, Dennis, Figure 2A-1 gives a list of what is called, on that. figure balance of plant systems. Section 2.A.1. does not include discussions several of the systems listed. We were wondering where
- 8 those systems would be discussed criteria-wise and test-wise.
MR. KEITH: We just addressed main steam isolation.
10 MR..ROGERS: Yes, that was one of them, and I used that as*an example because later on, and I have lost the 12 reference for the exhibit, but someplace you have indicated that for the balance of plant systems, you can test them all 14 on line, and I was concerned as to whether the main steam 15 isola'tion system could be tested on line, and I hear your answer. You are saying that you only stroke the valve l0%;
therefore, the test can be conducted on line I assume without lowering, the output mode of the plant or disrupting normal plant operation. I'm also wondering whether that, applies to the auxiliary feedwater system, whether that can be tested or how it is tested on line or off line, and containment isolation. Those may have been addressed at 23 another system review.
24 MR. KEITH: Yes, you have hit it exactly. Containment 25 isolation was hit at the last IDR. Auxiliary feedwater was GRUMLEY REPORTERS Phoenix, Arizona
I hit at an earlier IDR for testing of that. Then containment combustible gas control was discussed at, the last IDR.
MR. ROGERS: Well, you discussed containment combustib e gas control at this IDR and the design criteria and the testing was considered I believe during the discussion of 6 2A MR. KEITH: Well, the logic as I recall. I think so far as the testing of the system itself, that was discussed at the last IDR.
10 MR. ROGERS: Right. What I am saying is where are the logic for these other balance of plant systems considered?
Are they considered in this IDR or are they considered
, someplace else, and the evident one was the main steam 4 isolation. You have answered at least part of the question.
I think you might want to put up Exhibit 2A1-24.
16 MR. KEITH: The sensor checks, the trip bistable test?
17 MR. ROGERS: No, that is not the first paragraph.
Actuation of the ESF systems controlled by the one-out-of-two 19 ESFAS does not disturb normal plant operating conditions.
20 This is all listed under balance of plant Engineered Safety 21 Features Actuation System. I believe we are talking about 22 the systems listed under BOP over on the right-hand side.
23 MRS. MORETON: We are talking about. the first bullet.
24 MR. ROGERS: The first bullet there, but not the rest of them.
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'1 220 MR. KEITH: That's correct.
MR. ROGERS: Where are the rest of them covered?
3 MR. KEXTH: Carter, what has been listed here and 4 what is really discussed at this XDR is the actuation system, this first bullet,, as Mary just pointed out. These others are balance of plant. ESF systems and testing of those is part. of a separate subject. I think that is what 9'eally
'8 has confused me for a minute here. In the case .of contain-ment isolation, auxiliary feedwater, and containment combustible gas control, those systems have all been discussed at previous IDR's. I think, let's see, containment purge isolation was also discussed at the last IDR. The other items we do not have scheduled to discuss at an IDR, 14 but they will be reviewed at, least in terms of the NRC in 15 terms of a working meeting or however. Those are the systems 16 themselves, and in this review, from here down (indicating),
17 we are, talking about the ESF systems r
themselves, but this 18 review is really to cover the actuation systems. I,think 19 that is where the confusion has arisen.
20 MR. KOPCHINSKI: Xs that closed?
4 21 MR. ROGERS: Let's continue on. I want to think about 22 that a little bit. If I have a problem with that, I will 23 get back to you.
24 MR. BESSETTE: Maybe I can shed a little light on this. The MSIS, the aux feedwater, containment isolation GRUMLEY REPORTERS Phoenix, Arizona
221
,signal, the logic for that is developed in the RPS and it is tested and was discussed at the last IDR about the RPS testing scheme. I think, Carter, if I understand, your question is once you get past the actuation relay where we provide you with a contact closure of MSIV, can you test during operation'he.,circuitry.:from the.'.point, of actuation relay downstream to the motor controllers, valve operators, whatever, downstream of the actuation relays in the reactor protection system. If you say you have a manual switch on 10 the MSIV's for 10% stroke, then is that. switch that goes into the motor controller an actual portion of the circuitry 12 or does that in fact have some input signals downstream so 13 that I have a complete test. of the actuated device circuitry?
14 I think that is the scope of your question.
15 MR. ROGERS: Bernie, you are getting at what I am 16 concerned about. and presenting it in a much better way than 17 I can ask. I think that we ought to proceed o'n that particul 18 line.
19 MR. HELLMAN: You mentioned a test. switch. Does this 20 test. switch go'nto the specific logic of the MSIS or does .
21 the test switch go into the specific logic of the motor 22 control center for the valve?
23 MRS. MORETON: The exercise switch on the main control board for the main steam isolation valves goes into the 25 main steam isolation valve logic, but it does not simulate, h
an GRUMLEY REPORTERS Phoenix, Arizona
222 MSIS. It is simply an exercise to lift the valve off its seat and close 10%.
MR. HELMAN: Is this typical of the other ESFAS 4 testing devices?
MRS. MORETON: No, that is unique for the MSIV's.
MR. HELMAN: ,So in the other devices that are tested during their specific ESFAS channel, they are tested during the time the ESFAS channel is tested,,which'is manually simulated by pressing a test button.
10 MR. KEITH: If we can talk about, say, the LPSI pump, you do channel checks, you do logic checks, which you do 12 without ever starting the component. I think I will defer 13 to APS Operations as far as when they line up the system.
14 You have to open the bypass valve, since you are not actually h
15 going to be injecting into the reactor coolant system when 16 you test the pump. When they do that, whether they actually 17 press a button to simulate an SIAS, I don't know just what, 18 is done as far as the testing on those pumps, but there is 19 a required frequency of testing the, pumps and the valves that 20 is all supplied in ASME Section ll and really part of a 21 separate review, but if you want to get into that here 22 MR. HELMAN: No, I understand. The question is based 23 on do you test the continuity, shall we say, between the
,24 ESFAS actuated relay that Combustion provides and the 25 .actuated device?
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223 MR. KEITH: I guess it would be our understanding that, would be how it. would be tested. In order to get that part of the circuit when you are testing the pump, you should simulate an SIAS and, therefore, check that part of the circuit.
, MRS. MORETON:. On the NSSS ESFAS cabinet, which is where these signals are coming from that actuate, even though 8 they are BOP ESF systems, they are actuated by NSSS ESFAS, there are test relays and you can individually test by 10 dropping out contacts on an individual relay to test a pump or a valve or a collective group of valves.
12 MR. HELMAN: Simultaneously when you test the ESFAS 13 channel?
14 MRS. MORETON: The testing of the NSSS ESFAS, which 15 was discussed at the CESSAR IDR, is an overlapping piece-wise test. It is up to Operations if it is simultaneous or not.
17 MR. ALLEN: Does the Board feel that Bechtel should 18'9 take an open item to dwell a little bit more deeply into the testing of these systems or reference where they are discusse ?,
20 MR. MINNICKS: I think so, John. I,don't know that 21 Carter's question has ever been adequately answered whether 1
22 these systems are designed to be tested at power.,- I think 23 that was Carter's question. In other words, CE has designed 24 a system to test the logic up to the actuating relay. Now 25 we are concerned with from the actuating relay contact out GRUMLEY REPORTERS Phoenix, Arizona
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224 to the device itself, is that portion of the system designed to be tested at power as our criterion says it is?
MRS. MORETON: The criterion you are reading is for the one-out-'of-two ESFAS that controls selected- balance of plant ESF systems. The fuel building essential ventilation, control room essential ventilation, containment purge isolation, and containment combustible gas control (manual),
that criterion is met.
MR. HELMAN: But you also stated interface criteria, 10 that the ESFAS systems meet the CESSAR design criteria as an interface. Was that one of the ones that was in';the 12 first few exhibits?
13 MRS. MORETON: Yes, we meet the CESSAR interface 14 test.
15 MR. ROGERS John, I think it is appropriate that we 16 take an open item here and just. list as the open item where 17 the complete system criteria are discussed. '
am not 18 particularly hung up in the idea that you have to test all 19 of these systems at power, but I think it is important. that 20 we know when each system can be tested completely, and 21 especially those systems that are partly Combustion and 22 partly designed by Bechtel, that we are sure of the interface 23 and we are sure that we can test that interface at an appropriate time. I would like to see the list on the 25 figure, just a listing next to that, as to where the testing GRUMLEY REPORTERS Phoenix, Arizona
225 requirements are discussed in an IDR or in the FSAR. I think you are covered, but I am still a little unclear as to how to draw the complete line on the steam line isolation signal, how that complete line is tested. Am I clear, Dennis?
MR. KEITH: I guess I can relate it a little bit better if we 'relate it to Norm's concern, mainly that for the balance of plant ESF systems, which are primarily the ventilation systems, those we can test at power.
10 MR. ROGERS: Yes, there is no problem there.
MR. HELMAN: What I am more concerned about is the 12 NSSS systems that are actuated by the NSSS ESFAS and how 13 do we get from the actuation relay to the device in the 14 MSIV area, also?
15 MR. KEITH: That falls into that, yes.
16 MR. HELMAN: I understand from you that you have a 17 test switch on the Combustion-supplied ESFAS box, module, 18 whatever, that will provide a contact that goes directly to 19 the specific actuated device for closing or opening or 20 starting or stopping in the test mode. Is that what I heard 21 you say?
22 MRS. MORETON: That is correct.
MR. HELMAN: But in the balance of plant, this is not 24 so. Is that what I am hearing?
25 MRS. MORETON: In the balance of plant, test'ing is GRUMLEY REPORTERS Phoenix, Arizona
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226 done by complete system actuation unlike the NSSS ESFAS where testing is done in an overlapping piece-wise test.
MR. HELMAN: But it is unique to test the MSIV's?
MRS. MORETON: The MSIV's are unique, yes.
MR. HELMAN: With this little pushbutton that doesn' test continuity of the circuit.
MRS. MORETON: Right.
MR. STERLING: In the CESSAR IDR, they went through an extensive review of the testing features on their correc-10 tion system and the ESFAS, and so forth, and when you are running at power, you test your actuation systems and you 12 are in bypass, since you don'0 actuate your final piece of 13 equipment. When you are in shutdown, periodically you do 14 go in and you test the complete circuit. I think m'aybe it 15 should be tempered with that. Your response should be tempered by that facility in that requirement" that CE places.
MR. KEITH: That is what we basically s'tated was done 1
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18 about 10 or 15 minutes ago, but guess, Carter, now the 19 question is to just tie the two together on where this is 20 all covered.
21 MR. ROGERS: Yes. On Exhibit 2A1-27, you start with 22 a list of actuated systems and those systems are wt least 23 part of the listing of systems on Figure 2A-1. Just to 24 restate what I said a few times, where are the missing system covered?
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227 MR. BESSETTE: May I add a little more clarity to it? I think the piece that is missing in this discussion 3 is the function of the auxiliar'y relay cabinet, and the group relay assignments of components to certain actuated relays.
What I am not familiar with is the actual testing scheme, and I think we need to leave this open just to prove this out. There are components assigned certain actuated relays
.f so that you can actuate valves without pumps running and actuate pumps without valves open by the nature of the 10 assignment of components to these actuation relays, and this I believe can be done at power. But, again, I think that 12 we ought to just verify that, which I think will answer'our 13 question. We go from our actuation relay to the ECF actuatio 14 relay cabinet where the components are assigned to group 15 relays and then that does permit the actuation of components and starting pumps without completely actuating the train 1
17 by a partial actuation. Then there is overlap'here.
18 MR. HELMAN: So during the channel test, you are 19 actually not energizing the group relay?
20 MR. BESSETTE: No.
21 MR. HELMAN: You are just bypassing at that point and 22 testing the upstream portion, is that correct?
23 MR. BESSETTE: I believe that's correct. I think 24 the balance of that is a manual test for the group relay 25 test., but we should verify that.
GRUMLEY REPORTERS Phoenix, Arizona
J 228 MR. ALLEN: Do you understand the open item now?
NR. KEITH: Yes.
MR. ALLEN: Do you have another one you want to close out?
MR. KEITH: . The next concern that was brought up was missile protection of the control room outside air intake, the concern being specifically the sensors that we have in the control room air intake. We have two intakes for the control ventilation system. They are located on either 10 side of the control. buildi'ng and these intakes join together.
The air comes in horizontally and then the intakes join 12 together into a vertical chase and then all the instruments 13 are located in the vertial chase, so it is highly unlikely 14 that a missile could affect the instruments, since they are in a vertical chase and there is a long h'orizontal run before 16 we get to the vertical chase.
17 MR. BARNOSKI: Does that mean you are providing line-18 of-sight protection?
19 MR. KEITH: Yes.
20 MR. ALLEN: That was my question. I am satisfied on 21 that."'R.
22 KEITH: A question was brought up whether the 23 safety injection tank interlocks receive 'a signal from the 24 same sensors as the Class IE alarm system which we discussed 25 yesterday, and they do.
GRUMLEY REPORTERS Phoenix, Arizona
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229 That's all we have to close out.
MR. ALLEN: Are there'any further questions on these open items?
If not, Bill, why don'0 you go ahead with your presentation?
MR. BINGHAM: Let's continue then with Section 3.A, Compliance With Regulatory Requirements, the SRP's.
MRS. MORETON: Figure 3-1 provides a summary of the regulatory requirements that will be discussed, regulatory 10 requirements that. come from Standard Review Plans 7.1 through 7.7, Rev. 1, through General Design Criteria, 12 Regulatory Guides, IEEE Standards, and Branch Technical 13 Positions defined per SRP Table 7-1, which defines the 14 applicable criteria, guides, standards, and positions for 15 the subsystems discussed in 7.2 through 7.7. We will also be addressing the IGE Bulletins, Circulars, and Information 17 Notices and compliance with NUREG-0737.
18 Starti'ng with Standard Review Plans, Figure 3A-l, 19 Standard Review Plan 7.1 does provide a Compliance Table 20 7-1, which defines the applicable criteria for the Engineered 21 Safety Features Systems as defined in SRP 7.3, safe shutdown 22 systems as defined in SRP 7.4, safety-related display 23 instrumentation as defined in SRP 7.5, and all other safety-24 related instrumentation per SRP 7.6, and the nonsafety-25 related control systems per SRP 7.7. We will be discussing GRUMLEY REPORTERS Phoenix, Arizona
230 compliance with the NSSS requirements per SRP 7.2 as well as all the other sections and compliance as applicable to the balance of plant systems.
Exhibit 3A-l. SRP Section 7.3, SRP Acceptance Criteria. The requirement is to meet the General Design Criteria and IEEE 279. In compliance.
Exhibit 3A-2, SRP Section 7.4, redundancy required per GDC 26, 33, and 34 and IEEE Standard 279. In compliance.
Conformance with the single failure criterion as defined in IEEE 279, 379, and Reg. Guide 1.53. In compliance Exhibit 3A-3, identification of cables, cable 12 trays, and instrument panels as defined in Reg. Guide 1.75.
13 In compliance.
14 Vital supporting systems required for safe shutdown should meet, the same acceptance criteria as for the systems they support. In compliance.
17 Exhibit 3A-4, continuing with the SRP 7.4 criteria.
System testing, quality assurance, and surveillance in accordance with GDC 1 and 21, IEEE Standard 279, 336, and Reg. Guides 1.22, 1.47, and 1.68. In compliance.
21 Exhibit 3A-5, SRP Section'.5. The safety-related display instrumentation should cover appropriate 'variables consistent with the assumptions for accident analyses and 24 with the information needs of the operator and shall meet 25 Reg. Guide 1.97. In compliance.
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231 All monitoring channels should be redundant to assure that wrong indication due to device malfunction will not cause false'ction. In compliance.
Exhibit 3A-6, continuing with SRP 7.5. Requirement Redundant channels of safety-related display instrumentation should be isolated physically and electrically to comply with single failure criteria. In compliance.
Exhibit 3A-7, continuing with SRP 7.5 criteria.
Capability should be provided for checking. In compliance.
10 Exhibit 3A-S, SRP 7.5 continued. An indication system should be provided to cover bypass or deliberately 12 inoperable conditions per Reg. Guide 1.47 and Branch 13 Technical Position ICSB 21. In compliance.
14 Cables, cable trays, components, modules, and 15 interconnecting wiring shall be identified per Reg. Guide 16 1.75. In compliance.
Components and modules shall'be of a'uality 18 consistent. with reliability r'equirements for safety-related systems. In compliance.
20 Exhibit 3A-9, continuing with SRP 7. 5 criteria.
21 In order to assure that the requirements of GDC 1 are met, 22 the quality assurance program must satisfy the requirements 23 of IEEE 336 and Reg. Guide 1.30. In compliance.
24 Exhibit 3A-10, SRP requirement as stated in 7.6, system redundancy shall meet General Design Criteria 26 and GRUMLEY REPORTERS Phoenix, Arizona
232 33 and IEEE Standard 279. In compliance.
Exhibit 3A-ll, conformance with the single failure criterion shall meet IEEE Standard 279, 379, and Reg. Guide t
1.53. In compliance.
Identification of cables and raceways per Reg.
Guide 1.75. In compliance.
Exhibit 3A-12, continuing with SRP 7.6. Requiremen for vital supporting systems. In compliance.
Testing, quality assurance, and system availability surveillance per GDC 1 and 21, IEEE standards 279, 336, and 338, and Regulatory Guides 1.22, 1.47, 1.68, and 1.118.
12 In compliance.
13 Exhibit 3A-13 provides the SRP requirement stated in Section 7.7, conformance with GDC 13 for instrumentation 15 and control systems. In compliance.
16 Conformance with GDC 24 for separation of control systems from protection systems. In compliance.
18 Exhibit 3A-14, SRP Section 7.7 continued.
19 Conformance to IEEE Standard 279, Section 4.7, for control and protection system interaction. In compliance.
21 Exhibit 3A-15 provides a key to the acceptance criteria. We will be going through. all of Table 7-1 for compliance. The tables have been annotated to identify the 24 applicable sections as defined in 7.1. If they are not applicable in 7.1, they are keyed in the table as not GRUMLEY REPORTERS Phoenix, Arizona
)II 233 applicable. In compliance, with clarification or without clarification, is noted by a C. If the item is totally within CESSAR scope, it is noted by NSSS. If it is a CESSAR interface requirement, if PVNGS is in compliance, it is 5, noted with .an I. If it is both a CESSAR interface require-ment for NSSS scope and we are in compliance for BOP scope, r
7 it is noted with anI/C.
To cover very briefly the first criterion identifie in SRP 7-1 on Exhibit 3A-16, requirement provided: in 10 10CFR50.34, Contents of Application. In compliance.
10CFR50.36, requirement for Technical Specifica-12 tions. In compliance.
10CFR50.55A, Codes and Standards. In compliance.
14 Compliance with IEEE 279. In compliance.
15 MR. BINGHAtl: Are there any questions from the Board?
16 MR. MINNICKS: I'e got one on Exhibit 3A-5, the 17 requirement there on the SRDI, the accuracy and range of 18 indicating instrumentation should be consistent with the 19 assumptions of the accident analyses. I am curious as to 20 where those accuracy and range values are stated.
21 MRS. MORETON: The range values we 'covered when we 22 covered post-accident monitoring yesterday. Accuracy will 23 be provided when it is available.
24 MR. MINNICKS: But in a permanent documentation, 25 where would that be found? In the instrument index?
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234 MRS. MQRETQN: Data sheets.
MR. MINNXCKS: Xt is my understanding that, the data sheets were just a procurement document and weren'5 part of the formal package. Instrument data sheets you-are talking
'about?
MR. BINGHAM: . You will have instrument data sheets as part of the permanent records.
MR. MINNICKS: So then each data sheet that identifies an instrument should have an accuracy on that data sheet?
10 MR. B INGHAM: Yes.
MR. MINNICKS: That should be an open item, then, 12 because there are many data sheets that do not have accuracie 13 for instrumentation items identified on them.
14 MR. BXNGHAM: If I might, John, I think it would be 15 inappropriate to have an open item with the Board here.
That is just completion of tlute engineering information.
17 There will be sheets on modifications yet to 1
c'ome that, will 18 be, all'pulled together at'the final conference.
19 MR. ALLEN: I guess it should be an open item to the E
20 effect to indicate to the Board where the accuracies can be 21 found, whether it be on data sheets or another document.
22 MR. MINNICKS: Xt gets a little more complicated, 23 because some of these are in CE's scope of supply.
24 MR. STERLING: In the CE IDR, Combustion did provide 25 some documents that showed where, they provide these GRUMLEY REPORTERS Phoenix, Arizona
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235 I accuracies, and that will appear in their transcript. What 2 I would suggest is that we take some sample data sheets 3 and show where these things will appear and add them as part 4 of this transcript so we would have a complete picture of where this information is going to be found.
MR. BINGHAM: May I clarify what I think you are after again? There are many accuracies.
I When a system designer generates his accuracies related in the NSSS scope, what we call a measurement channel requirement, that is 10 converted to an instrument specification, sheet for procurement 11 as you referred to. Are you looking for that description 12 of the accuracy or are you looking at. what the final vendor's 13 product accuracy is and where that is specified? That may 14 be, for example, a technical manual.
15 MR. MINNICKS: I am looking for the formals. In 16 other words, the requirement here is that the accuracy has 17 to be consistent with the assumptions in the accident 18 analyses, so that should be the accuracy that we are concerned 19 with. The vendor may supply something that is better than 20 that, but we have to know what was assumed in the accident 21 analyses.
22 MR. BINGHAM: Let me see if I understand. You want 23 to know what was assumed in the accident analyses, and I can 24 25 GRUMLEY REPORTERS Phoenix, Arizona
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236 understand that, from CE. You may have an instrument. that is more accurate, and I believe you also want to know that, do you not?
MR. NINNXCKS: True.
MR. BINGHAI41: What piece of information is it that you want as part of .the transcript?
MR. ALLEN: I think Ed said to make.
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it consistent with Combustion Engineering XDR, and that was to provide samples of .documentation and reference to documents where 10 they could find the accuracy of the instrumentation.
MR. STERLXNG: Combustion provided,'orrect me if I 12 am wrong, the intex'face documents, the detailed interface 13 documents that they send to us that we design our support 14 systems'o, which had all the detailed information about 15 their requirements, and they also went through how they take the accuracies of the equipment and define setpoints and 17 that sort of thing, erx'ors.
18 In response to Jim's question, we maybe could have 19 sample o'f those documents that provide the accuracies that 20 we use.
21 MR. BXNGHAM: I guess what is confusing me, Ed, is 22 the fact that all of the interface information does come from CE, comes to us, becomes part of the permanent record, 24 as, well as information developed for balance of plant.
25 That is all one stash of information that you will have for GRUMLEY REPORTERS Phoenix, Arizona t
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237-the particular plant when you get ready to start it up.
Certainly we can provide all of those examples.
3 MR. STERLING: Couldn'. you just provide a sample of a data sheet and show us where the accuracy is'?
MR. BINGHAM: Sure. Here is a sample of a data sheet here. Is that what .you. had in mind' MR..MINNICKS: I guess the question would be what assurance do you. have that -- I am familiar with the data sheet. Nhat assurance do you have that every instrument has 10 an accuracy value in these data sheets?
MR. BINGHAM: That's a different question.'ust one 12 moment.
13 Regarding the question of how do we assure that 14 those data sheets that require accuracies have been, that 15 is done by review by Bechtel,,particularly by the controls 16 discipline in looking at each data sheet to assure that 17 that information is available, 18 MR. MINNICKS: I guess to expand that, Bill, would 19 that accuracy be the value assumed in the accident analyses 20 or would that value be what the vendor supplied?
21 MR. BINGHAM: I would assume that that would be what 22 the vendor supplies.
23 MR. MARSH: Can I interject something here? I think 1
24 there are two different questions tha't we need to address.
One is how do we know that the instrum'ent, is performing its GRUMLEY REPORTERS Phoenix, Arizona
238 function within its design limits, and the second question is how do we know that the design is adequate in terms of the accident analyses. The question of the design accuracy really goes to the system design consideration. It is a 5 lot more than just an instrument. It has to do with the tolerance that is built into the analyses as well as the instrument accuracy and other system factors that the instrument itself interconnects with. It,is my understanding that that system consideration is documented on a separate 10 data sheet separate from the procurement data sheet that you are speaking of and that that data sheet is completed for 12 every safety-related functional instrument, and I suspect 13 that many of those documents haven'0 yet been completed for 14 this project. Maybe Mary or Dino can indicate to us whether they have been completed for this project.
16 MR. BINGHAM: Fred, were you discussing with the 17 Board on a generic basis of how these things a'e handled or were you trying to be plant specific?
19 MR. IRRSH: On the basis of what I have seen before, 20 that's correct.
21 MR. BINGHAM: Not all the work is complete and, as 22 you know, we talked about the instruments. As a result of Reg, Guide 1.97, we have two that, we are 'still in the process 24 of developing and purchasing, so they would not be there.
The other point I wanted to mention to the Board is that we GRUMLEY REPORTERS Phoenix, Arizona
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239 do rely on Combustion Engineering to specify the requirements properly and we go and procure instruments to meet those 3 requirements. We 'do send that information back to them for them to verify. So when it comes to assumptions for accident analyses, Chapter 15 work, we would, of course, rely on Combustion Engineering to specify right and we would buy
'E right. P I1 MR.'INNICKS:, 'hat:leads me to two questions. One, Mr. Marsh identified a very exact method of determining where 10 the accuracies are acceptable to the accident analyses. I don't know that I heard a response whether that was what 12 Bechtel was using on this project or not. I am looking for 13 .that. Is that the method that Bechtel is using on this project', a separate data sheet. other than the procurement 15 data sheet?
16 MR'. BINGHAM: Excuse me, maybe Mr. Marsh would clarify 17 that. Did you talk about two data sheets?
18 MR. MARSH: That's correct.,
19 MR. BINGHAM: I don'0 believe we have a document of 20 that type you described on Palo Verde. We will check and 21 see and confirm.
22 MR. PHELPS: Maybe I can clarify what .I predict will 23'4 happen on Palo Verde based on what has ha'ppened on San Onofre The setpoints that they use in the safety analyses in the 25 FSAR are called analysis setpoints. The way you get from GRUMLEY REPORTERS Phoenix, Arizona
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240 that, analysis setpoint back to an instrument setpoint is through a specific document, which usually Combustion Engineering creates and they would factor in the instrument accuracies that have been specified on the data sheets along with all the other accuracies that combine in that particular protection channel,,so in that way, you are assured that the instrumentation that you have procurred is set with a setpoin that is consistent with the. accident analysis, and Palo Verde should eventually get the'ame document.
10 MR. BINGHAM: That's correct. We have a commitment, from CE for'a setpoint document. I wasn't aware that that 1
I I 12 was where the Board was headed with the question. i I
13 MR. STERLING: At the CE XDR, they went through a 14 very detailed explanation of how they got those setpoints.
15 What I understand the question to be is how do we handle our 16 portion, the BOP.
17 MR. BINGHAM: So the question is how do we determine 18 the setpoints? Is that the question?
19 MR. STERLING: You could expand it to that.
20 MR. BINGHAM: What is the question?
21 MR. MINNXCKS; We kind of mixed apples and oranges 22 here. Setpoints and accuracy are 'two very distinct differenc s 23 pnd they have been handled differently both by. CE and 24 Bechtel with setpoint indexes. The question I had was 25 'elative to accuracy, 1 how does Bechtel document that the GRUMLEY REPORTERS Phoenix, Arizona
0 241 accuracies assumed in the accident analyses are carried through the procurement system through sensor to signal converter to indicator the indicator is what is discussed t
in this requirement -- and that that total loop accuracy is within what, was assumed in the accident analyses. Mr. Marsh 7
6 descxibed a method that he had seen at other plants, but 7 what you responded is that is not used here, so I am wonderin what is used for Palo Verde.
MR. BINGHAM: Ne will caucus at the break and come 10 back and tell you.
MR. ALLEN:'hat then is an open item?
12 MR. BINGHAM: Yes.
13 MR. ALLEN: Norm, have you got a further comment?
14 MR. HELMAN: No, I have another question whenever you 15 close that out on something different.
- 16. MR. STERLING: I think then we should carry that on to how we de'termine our setpoints in our porti'on of the 18 instrumentation, also.
19 MR. ALLEN: Just expand it to include both accuracy 20 and setpoints.
21 MR. BINGHAM: All right.
22 MR. ALLEN: Norm, have you got'another question?
23 MR. HELMAN: I had a question on Exhibit 3A-4, SRP 24 7.4. SRP 7.4.11 requires that a specific interlock for 25 bypassing of Channel A or Cha'nnel B ESPAS instrumentation be GRUMLEY REPORTERS Phoenix, Arizona
242 provided. It appears on an earlier drawing that we covered yesterday, Figure 2A1-6, this interlock is provided. They also require that with the failure of this interlock that there is no capability for bypassing both channels at one time. Could you clarify that for me, please?
. MRS. MORETON: BOP ESFAS interlocks are isolated such that if the logic senses that both channels are-in interlock, they both revert back to a non-bypass mode, and it does meet the single failure criterion. Ne really need a logic 10 diagram. This is Figure 2A1-6 on the CPIAS. If this interlock (indicating) fails and the operator attempts to 12 put this in bypass, this interlock (indicating) will J
13 immediately throw that. one out of bypass.
MR.'ELMAN: I see.
15 MR. ALLEN: Further questions? Carter.
16 MR. ROGERS: On Figure 3A-12, this pertains to 17 Standard Review Plan 7.6.. Review of that Standard Review 18 Plan indicates that there are six accep'tance criteria. The 19 last one, the number six one, which. does not appear here, 20 pertains to the fire protection system. I believe that the 21 fire protection system requirements are covered elsewhere, 22 but I 'think if that's true that there sho'uld be a nate to 23 that so that it doesn't confuse 'other readers of this transcript. Is that correct?
25 MRS. MQRETQN: For clarification, ther'e was g note GRUMLEY AEPORTERS Phoenix, Arizona
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243 on the introduction slide, the Other Systems Required for Safety slide, that excluded fire protection. A note can be added here.
MR. ROGERS: I missed that before, but. if it is already there, then nothing needs to'be changed.
MR. ALLEN: Any further questions from the Board?
MR. STERLING: Exhibit 3A-13, Item 1). I will ask the same question I asked at the CE IDR. Is this a case that all .the instrumentation that is provided currently for Palo Verde is designed to be on range throughout the anticipa ec normal and abnormal plant occurrences?
12 MRS. MORETON: All instrumentation?
13 MR. STERLING: Yes. You say there you are in 14 compliance.
15 MRS. MORETON: Instrumentation is provided to cover all anticipated occurrences per Reg. Guide 1.97. It does not cover all anticipated ranges. There are overl'apping instrumentation to cover all anticipated ranges per Reg.
Guide 1.97, Rev. 2.
20 MR. STERLING: Prior to Reg. Guide 1.97, Rev. 2, did we have cases where instrument ranges were designed to fall short of anticipated'rends?
23 MR. BINGHAM: May I ask why'e are going bpck into 24 the 'history? We have been asked by APS to upgrade the 25 system to respond to Reg. Guide 1,97, Rev. 2. John, if you GRUMLEY REPORTERS Phoenix, Asizona
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r want, we can go back and research the answer.
MR. ALLEN: Well, I think you know the answer.
MR. BINGHAM: We'l 'see if we can't r
answer that properly.
MR. -KEITH: Prior to 1.97, Rev. 2, we we'e still designed such that all our instruments covered the anticipate r
ranges. Since 1.97, Rev. 2, came out, some of the anticipate ranges changed, and that is why we axe changing some instruments.
10 MR. ALLEN: Any other questions of the Board?
MR. SIMKO: I'e got one. On Exhibitr3A-ll, on 12 Number 2, you talked about single failure criterion for 13 electrically operated valves. Does that cover the contain-14 ment purge butterfly valves, the isolation valves?
15 MRS. MORETON: ICSB 18? No. ICSB 18 applies to the 16 'safety injection tank isolation valves and other valves where only one valve is provided r in the field 'house to meet 18 the single failure cxiterion. The containment purge isolatio 19 valves are two valves in series.
20 MR. SIMKO: Is there a single failure criterion for 21 isolation valves? One is on Train A and one is on Train B, r
22" ,I believe. What I am driving at is on the'ontainment 23 purge system, is it 3 credible rto have both."of those isolation 24 4
valves Ir fail open and you could bl'ow out,the'ilter train 25 going to the plant vent. I guess the question is is the GRUMLEY REPORTERS Phoenix, Arizona
245 plant vent designed for a Delta P of about 50 psig?
MR. KEITH: As you stated, we have one valve o'ff 3 Train A, one valve off Train B, and that is designed to that.
4 We have that designed so that we don't have to design for full containment pressure out. beyond those valves and we have not designed that..purge ducting for the'0 psi.
MR. ALLEN: Anybody else on the Board?
Does, NRC have any questions?
MISS KERRIGAN: I just have a comment that the NRC audit, of the assertions will not be made until our drawing review, the assertions about compliance with different Reg. Guides and other NRC criteria.
MR. BINGHAM: As you recall, about the second IDR 14 we had, we decided that it was appropriate for us to go througn and give a first cut, if you would, at how we stack up against:the SRP's as a convenience for the licensing process.
18 Are there any other questions, John?
19 MR. ALLEN: Go ahe'ad.
20 MR. BINGHAM: The next section we would like to cover is 3Br Compliance With Regulatory Requirements, General Desi,gn Criteria.
23 MRS. MORETON: Throughaut SR/. Table 7 l, we will be 24 using the compliance statements as stated on Exhibit '3A-15.
t 25 On Exhibit 3B-l, we start with the General Design GRUMLEY REPORTERS Phoenix, Arizona
'1 Criteria as defined in SRP Table 7-3..
GDC 1, Quality Standards and Records. In compliance.
GDC 2, Design Bases for Protection Against Natural Phenomena. In- compliance.
6 Exhibit 3B-2, GDC 3, Fire Protection. In M
compliance.
GDC 4, Environmental and Missile Design Bases.
In compliance.
10 Exhibit 3B-3. GDC 5, Sharing of Structures, Systems and Components.'n compliance.
12 GDC 10, Reactor Design, NSSS scope.
13 Exhibit 3B-4, GDC 12, Suppression of Reactor 14 Power Oscillations, NSSS scope.
15 Exhibit 3B-5, GDC 13, Instrumentation and Control.
In compliance.
17.
Exhibit 3B-6, GDC 15, Reactor Coolan't System Design t
18 NSSS scope.
19 GDC 19, Control Room. In compliance.
20 Exhibit 3B-7. GDC 20, Protection System Functions.
21 In compliance with a clarification that the containment 22 combustible gas control system is manually initiated.
23 Exhibit 3B-8. GDC 21, Protecton System Reliability I
24 and Testability. In compliance with a clarification about 25 the one-out-of-two ESFAS. They do not meet the single failur GRUMLEY REPORTERS Phoenix, Arizona
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247 criterion during channel bypass, but. the bypass time interval
- I as discussed before, is a very short, interval and is for maintenance only.
Exhibit 3B-9. GDC 22, Protection System Xndependence. Tn compliance.
GDC 25, Protection System Failure Modes. Xn compliance.
Exhibit 3B-10. GDC 24, Separation of Protection and Control Systems. ln compliance.
10 Exhibit 3B-11. GDC 25, Protection System Requirement for Reactivity Control Malfunctions, NSSS scope.
12 GDC 26, Reactivity Control System Redundancy and 13 Capability, NSSS scope.
14 Exhibit 3B-12. GDC 27, Combined Reactivity 15 Control Systems Capability, NSSS scope.
16 GDC 28, Reactivity Limits, NSSS scope.
Exhibit 3B-13. GDC 29, Protection Against 18 Anticipated Operational Changes. Xn compliance.
19 GDC 33, Reactor Coolant Makeup, NSSS scope.
20 Exhibit 3B-14. GDC 34, Residual Heat Removal.
21 Xn compliance.
22 Exhibit 3B-15. GDC 35, Emergency Core Cooling, 23 NSSS scope.
24 GDC 37, Testing of Emergency Core Cooling System, 25 NSSS scope.
GRUQLEY REPORTERS Phoenix, Arizona
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248 Exhibit 3B-16. GDC 38, Containment Heat Removal, NSSS scope.
GDC 40, Testing of the Containment Heat, Removal System, NSSS scope.
Exhibit 3B-17. GDC 41, Containment Atmosphere Cleanup. In compliance.
Exhibit, 3B-18. GDC 43, Testing of Containment Atmosphere Cleanup Systems. In compliance.
GDC 44, Cooling Water. In compliance.
10 Exhibit 3B-19. GDC.46, Testing of Cooling Water System. In compliance.
12 GDC 50, Containment Design Bases. In compliance.
13 Exhibit 3B-20. GDC 54, Piping Systems Penetrating 14 Containment. In compliance.
15 GDC 55, Reactor Coolant Pressure Boundary Penetrating Containment. In compliance.
17 Exhibit 3B-21. GDC 56, Primary Containment.
18 Isolation. In compliance.
19 GDC 57, Closed System Isolation Valves. In 20 compliance.
21 MR. BINGHAM: Are 'there any questions from the 'Board?
22 STERLING: On Exhibit 3B-2, what does the little 23'4 I under 7.2 mean?
f MR. BINGHAM: Excuse me, your ques'tion was what does 25 nIn mean? It is "on.'xhibit 3A 15r Ed.
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249 MR. STERLING: All right. On Criterions 3 and 4 for the Engineered Safety Features System, which is Column 7.3, Combustion also provided interface requirements.
You don't indicate that. I think you should have an I/C under 7.3 if that is the case.
MRS. MORETON:. An I/C can be added to all the sections MR. ALLEN: Any further questions from the Board?
I'e got one, Mary. Do we have any third of a kind type instrumentation in our scope like off the charging 10 pumps or anything like that that may not meet the same requirements as the rest of our ESFAS systems in regard to 12 marking, maybe?
MRS. MORETON: The third charging pump receives power 14 from Train A and,from Train B, but the control circuit for 15 that is redundant instrumentation.
MR. ALLEN: Completely redundant?
17 MRS. MORETON: The pressure switch instrumentation 18 for the charging pumps is redundant. A Train A pressure 19 switch, controls the Train A switchgear and B controls the 20 Train B switchgear.
21 MR, STERLING: Exhibit 3B-6. Combustion Engineering 22 in their XDR indicated Criteria 17 and 1.8, which are the 23 electrical power requirements, they provided us qn interface 24 requirement.
l I think it would be appropriate, I believe that 25 was covezed in the XDR's for the power system electrical, GRUMLEY REPORTERS Phoenix, Arizona
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250 that reference should be made to that IDR to close that loop.
MR. BINGHAM: I guess 'the point here is that, since it isn'0 in 7 in the table, we didn', put it on the chart.
MR. STERLING: In the CE IDR, they provided an interface requirement, but there is nothing to tie that interface requirement to something.
MR. BINGHAM: I understand. Let me try to explain again. What we did was take what is in 'the SRP's, reproduce it to the best of our ability, and respond to it. If there 10 is other information, for example, that CE said that wasn' in the SRP, you .wouldn't find it on these charts. We could 12 annotate the charts or add some information as clarifica'tion 13 in, addition, but the purpose of thi's review was to take the 14 SRP as it is written and respond to it.
15 MR. STERLING: I guess just for the record that will 16 be found in the power XDR's, the AC and the DC XDR's.
17 MR. BXNGHAM: Yes, that's correct. The'DC responses 18 are in there.
19 MR. ALLEN: Any further questions from the Board?
20 NRC?
Yes,'lease. Exhibit 3B-15. I just I
21 NR. ROSENTHAL:
22 want a clarification of the scope of supply. I understand 23 that HPSX's are within CE's scope of supply. Are the LPSI's 24 and the containment heat removal system Bechtel or CE?
25 MR. BINGHAM: Combustion Engineering's scope.
GRUMLEY REPORTERS Phoenix, Arizona
h' MR. ROSENTHAL: On 3B-16, to what extent is the containment spray system downstream of CSAS Bechtel or 3 Combustion?
MR. BXNGHAM: . The pumps are provided by Combustion Engineering. The supports for the pumps are provided as balance of plant. It includes piping.
MR. ROSENTHAL: Piping, spray headers?
,8 MR. BINGHAM: Yes.
MR. ROSENTHAL: And the electrical connections 10 between the power and between the auxiliary relay cabinet,
, the ESF auxiliary relay cabinet and--
12 MR. BINGHAM: The hard wires, yes.
13 MR. ROSENTHAL: The wires to start those?
14, MR. BXNGHAM: That's correct.
15 MR. KEITH: Jack, I think we should clarify it is the 16 same scope as to the containment spray pump as it is on the 17 HPSX and LPSX. There is no difference between the Bechtel 18 and CE scope.'R.
19 ROSENTHAL: But you also have tanks to take 20 hydrogen.
22 MR. ROSENTHAL: Those pumps and the tanks are yours?
MRS. MORETON: No.
25 MRS. MORETON: Yes, Combustion Engineering scope.
GRUMLEY REPORTERS Phoenix, Arizona
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252 MR. KEITH: The system will be designed by CE. There 2 may be some individual components, but. the containment spray system is completely within the CESSAR scope. When we get to the next slide, which is containment atmosphere cleanup, the iodine .removal system, although provided by- CE, is not covered in CESSAR, it. is covered in our FSAR, so that is why you see a difference. We don'0 say NSSS scope here even though as a point of fact as far as components provided, it is the same as the containment spray system and the 10 HPSI and LPSI.
MR. ALLEN: Any further questions?
12 MR. ROSENTHAL: Thank you.
13 MR. ALLEN: Go ahead, Bill.
14 MR. BINGHAM: Let ' move on to 3C, Compliance With 15 Regulatory Guides.
MRS. MORETON: Continuing on with SRP Table 7-1, 17 Acceptance Criteria for Regulatory Guides.
18 Exhibit 3C-1. Reg. Guide 1.6 requiring an 19 acceptable degree of independence between the redundant 20 standby power sources and their distribution systems. In 21 compliance.
22 Reg. Guide 1.7 requiring a containment combustible 23 gas control system. In compliance.
Exhibit 3C-2. Reg. Guide 1.11 regarding instrument 25 lines penetrating containment. In compliance with the GRUMLEY REPORTERS Phoenix, Arizona
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253 clarification that there are four instrument lines that are
'2 a part of the containment pressure boundary and part of the protection system and are provided with isolation facilities that meet the requirements for redundancy, independence,- and testability of that redundant system.
Exhibit. 3C-3, Reg. Guide 1.12, Instrumentation for Earthquakes. In compliance with -the clarification that the strong. motion accelerometers are used inside, containment 9 rather than the peak recording accelerographs required by 10 Reg. Guide 1.12. Time-history strong motion accelerometers provide data for response spectra analysis rather than 12 response spectrum recorders. Thirty-minute battery power 13 is provided for continuous operation in the event of a loss 14 of external power. Seismic monitoring instrumentation has 15 a response essentially flat, or equivalently correctible by 16 computational techniques over the range of 1 to 30 Hertz.
17 Damping values are applicable to the overall s'trong motion 18 accelerometer. Seismic triggers are adjustable over a minim 19 range of 0.01 Co 0.03 G on the base slab.
20 Exhibit 3C-4. Reg. Guide 1.22, Periodic Testing 21 of Protection System Actuation Functions. In compliance.
22 Reg. Guide 1.29 requiring a seismic design classifi 23 cation. In compliance.
24 Exhibit 3C-5. Reg. Guide 1.30, Quality Assurance 25 Requirements. In compliance.
GRUMLEY REPORTERS Phoenix, Arizona
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254 Reg. Guide 1.32, Criteria for Safety-Related Power Systems. In compliance.
Exhibit 3C-6. Reg. Guide 1.45 addressing reactor coolant pressure boundary leakage detection. In compliance.
Reg. Guide 1.47 identifying, the requirements for bypassed and inoperable status indication. In compliance.
Exhibit 3C-7. Reg. Guide 1.53 addressing the single failure criterion. In compliance.
Reg. Guide 1.62 requiring manual initiation of 10 protective actions.. In compliance.
Exhibit 3C-8. Reg. Guide 1.63 addressing 12 electrical penetrations. In compliance.
13 Reg. Guide 1.67 addressing overpressure protection 14 devices. In compliance.
15 Exhibit 3C-9. Reg. Guide 1.68 on the initial test program. In compliance.
Reg. Guide 1.70 on the standard format and content 18 of the Safety Analysis Report. In compliance.
19 Exhibit 3C-10. Reg. Guide 1.75 addressing physical 20 independence of electric systems. In compliance.
21 Reg. Guide 1.78 addressing control room habitabilit 22 In corn'pliance.
Exhibit 3C-ll. Reg. Guide 1.80 addressing pro-op.
24 testing of instrument air. In compliance.
25 Reg. Guide 1.89, Qualification of Class IE Equipmen GRUMLEY REPORTERS Phoenix, Arizona
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255 In compliance.
Exhibit 3C-12. Reg. Guide 1.95, Protection Against 3 Chlorine Release. In compliance.
Reg. Guide 1.97, which we have addressed earlier, the Rev; 2 .will be in compliance..
Exhibit 3C,-13. Reg. Guide 1.100, Seismic Qualification of'lectrical Equipment. In compliance.
8 Reg. Guide 1.105 on instrument setpoints. In compliance.
10 Exhibit 3C-14. Reg. Guide 1.118 addressing requirements for periodic testing. In compliance.
12 Reg. Guide 1.120 on fire protection. This subject 13 was covered in the fire protection IDR.
14 MR. BINGHAM: Any questions from the Board?
15 MR. BARNOSKI: I just have one request. I think it 16 would be appropriate that in the transcript you identify 17 what revisions of these you are using as a. bas'is for saying 18 you are in compliance. There is a number. of these where I have questions on which revision you are using. I believe 20 that, needs to be added for completeness.
21 MR; ALLEN: That ' a good idea.
22 MR. BINGHAM: We will 'add it.
23 MR. PHELPS: Exhibit 3C-10, Protection of the Control Room From Toxic Gases. I know you addressed the chlorike 25 monitors. Do you have monitors for any other toxic gases to GRUMLEY REPORTERS Phoenix, Arizona
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256 isolate the control room?
MR. BINGHAM: Not to my knowledge.
3 MR. MARSH: Is there a threat to the control room from release of any other toxic gases?
MR. BINGHAM No.
MR. ALLEN: Jim, did you have a question?
MR. MINNICKS: On 3C-13, Reg. Guide l.l05, this kind
)
of falls into what we were talking about before on the accuracy and setpoints. The requirement says instrument setpoints in systems important to safety initially are within and remain within the specified limits. The same question, 12 I guess. The specified limits are documented where?
13 MR. BINGHAM: It is in the setpoint index or list.
14 MR.'INNICKS: So in the setpoint index, is that setpoint required to meet the accident analyses? That is the setpoint. that is in the index.
17 MR. BINGHAM: At least that much, yes.
18 MR. MINNICKS: Well, is it that or is it some conservative number thrown in there with it?
20 MR. BINGHAM: Excuse me, I confused you. .What I meant 21 was there will be other setpoints other than those related 22 to accident analyses in the list.
23 MR. MINNICKS: In this setpoint document, which is out in Rev. 0, will the CE setpoints be included in that or will we have a separate setpoint document for CE setpoints?
GRUMLEY REPORTERS Phoenix, Arizona
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MR. BINGHAM: I believe we will start with two
,setpoint lists, one from CE and. one for the balance of plant, and eventually they will be combined.
MR. JOHNSON: On Exhibit 3C-7 on Reg. Guide 1.53, can you briefly explain to me how the Failure Modes and Effects Analysis for the balance of plant system are properly dovetailed into the Failure Modes and Effects Analysis performed by Combustion Engineering on the plant protection system to ensure that you meet the regulatory requirements 10 of 1.53 to meld those Failure Modes and Effects Analyses together?
12 MR. BINGHAM: Maybe you could help us a little bit 13 and indicate what Failure Modes and Effects Analysis CE 14 has done.
15 MR. JOHNSON: If you will read the FSAR, it is about an inch thick in CESSAR. There are assumptions, made in 17 there on the balance of plant. A Failure Modes and Effects 18 Analysis is required by the SRP's to be performed in the 19 balance of pla'nt area, also. Reg. Guide 1.53 is highlighting 20 that they ."should not be done completely independent, they 21 should be melded together to assure a uniform analysis.
22 MR. BINGHAM: Let me see if we can get to responding 23 to the issue, Larry. When Combustion Engineering does their Failure Modes and Effects Analysis, they look at what happens 25 outside their systems and they document any requirements in GRUMLEY REPORTERS Phoenix, Arizona
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25 the interface information that they send to Bechtel for designing the balance of plant. I believe that is the way 3 that the two are integrated.
MR. JOHNSON: The Section 7..2 Failure Modes and Effect Analysis summary tables are quite extensive. Do you have similar tables for the balance of plant portion?
MR. KEITH: CE looks at the detailed component level failures, we look more at the system level failures, so ours are not in the same level of detail as Combustion Engineering s.
10 MR. JOHNSON:- Do you provide a summary table of those failures?
12 MR. KEITH: We provide a table showing what we looked 13 at in our analysis.
14 MR; JOHNSON: In Section 7?
15 MR. KEITH: Yes.
16 MR. STERLING: Just for reference, it is Table 7.3-14.
17 MR. JOHNSON: I notice them in Section 7.3. I don' 18 notice them in Section 7.4 where you will find the systems 19 that are really supporting a lot of the CE other than 20 ventilation systems, which are in 7.3.
21 MR. BINGHAM: Give us just a minute, John. We will 22 try to find it.
23 (Thereupon a brief off-the-record discussion ensued, 24 after which proceedings were resumed as follows: )
25 MR. BINGHAM: Could I ask that Larry Johnson restate GRUMLEY REPORTERS Phoenix Arizona
l' 259 the question to make sure we have the proper response?
MR. JOHNSON: How do you demonstrate that you have summarized your Failure Modes and Effects Analysis in the support systems for the CE plant protection system?
MR. BINGHAM: Thank you.
MR. ALLEN: Any further Board questions on this?
I have one, just a clarification. On Exhibit 3C-3 where we talk about the seismic trigger range, .Ol to .03 or..01 to .3 G, which one?
10 MRS. MORETON,: The slide is correct.
MR. ALLEN: Further questions from -the Board ar the 12 NRC? Jack.
13 MR. ROSENTHAL: Yes. You stop at Reg. Guide 1.105.
14 Will you make comments about conformance "to Reg. Guide 1.06 15 and Reg. Guide 1.118? Okay, 1.106. What is the thermal overload protection for electric motors on motor-operated valves?
18 MRS. MORETON: We will take it as an open item, but 19 for information today, thermal overloads are bypassed by 20 the ESFAS signals on motor-operated valves.
21 MR. ROSENTHAL: Let me get back to Reg. Guide 1.118, 22 and I, will need your help on this. 1.118, which was issued 23 after the date of your CP, endorses IEEE 338-1977, which was also issued after your CP. I believe that you are telling lt 24 25 me that you are in conformance with 338-77 by listing GRUMLEY REPORTERS Phoenix, Arizona
260 Reg. Guide 1.118, and, if so, that's terrific.
MR. KEITH': Well, there are different versions of 1.118, also. I believe one of the references is 338-75.
MISS KERRIGAN: I,believe one of your open items was to provide a table of which revision you are meeting for, all these.
MR. KEITH: Yes, that would be part of that. We will tell you what revision and confirm that. we are in compliance.
MR. ROSENTHAL: 'ow, just the last part. I believe 10 that the CE scope of supply is in conformance with IEEE 338-1971. Should the Bechtel scope of supply be in conformance with 338-75 or 338-77, then does this represent an interface problem? I would like to explore that. Is 14 there conflict?
15 MR. KEITH: Would it matter if one part of the plant were tested to one version and one part to another?
17 MR. ROSENTHAL: You can always do more,'nd that' 18 fantastic. I -am not clear that unless there is careful review that conflicts don'0 necessarily come up and I am I
19 not clear on what the conflicts would be.
21 MR. BINGHAM: Let's see if we can understand. As Gerry, Kopchinski said, in the SAR, we are talking about 23 Rev. 1 to Reg. Guide 1.118, which I believe is the one you r
24 were referring,to.
25 MR. ROSENTHAL: Well, for instance, Rev. 1 I believe GRUMLEY REPORTERS Phoenix, Arizona
261 endorses the 1975 version of 338 which requires, as an example, periodic testing, and 338-71 did not. I am asking if the interfaces have been satisfied between the BOP and the kl CE scope of supply such that you can in fact conform to 338-1975 given that the CE system was built to 338-71. I would like you to identify where there are conflicts between trying to conform to standards which have been. revised.
MR. BINGHAM: We will take that as an open item for this Reg. Guide 1.118.
10 MR. ALLEN: Further questions?
MR. ROSENTHAL: There are regulations which were in force as of the date of your CP or were backfit. There are many other regulations or revisions of those regulations 14 which are post your CP date and to which you need not conform latter situations, I think like to N
15 but for those we would understand where you conform to the Reg. Guide that is in force by, virtue of the date of the CP, but not with the new requirements.
19 MISS KERRIGAN: I think I would like to kind of expand his question. Would you confirm that there are,,first of all, for all the Reg. Guides, regulations, SRP-'s that you are discussing here, confirm either that. CE and balance of 23 plant are using the same revision and, if they are not, confirm that there are no interface problems caused by using different revisions of the SRP or Reg. Guide or all the NRC GRUMLEY REPORTERS Phoenix, Arizona
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262 A
1 requirements in this area?
2 MR. BINGHAM: All right. I think we can handle that, Janis. I also wanted to indicate that there was an amendment 4'o the PSAR, Amendment 4, I believe, that did clarify some to II later updates on requirements of the revision numbers Reg. Guide and General Design Criteria.
MISS KERRIGAN: Did you say PSAR?
MR. BINGHAM: Yes.-
MR. KEITH: That is all now reflected in the FSAR.
10 MR. BINGHAM:. It is now in the FSAR.
MR. BESSETTE: For clarification on this item, you can refer to CESSAR Appendix A for the revisions of the Regulatory Ggides and standards that CE complies with, and 14 then for project specific cases where we may actually exceed what is in CESSAR, you can refer to your System 80 and Palo Verde project specific specifications and interface 17 documents, and you have to look through all th'ose references 18 in order to identify where there is some nonequality in the regulations that were used.
20 MR. KEITH: That is the open item.
21 MISS KERRIGAN: Yes. We just. want you to confirm that 22 no interface problems resulted from perhaps using different.
23 revisions.
24 MR. ALLEN: Any further questions before we move along 25 Okay, Bill.
GRUMLEY REPORTERS Phoenix, Arizona
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P MR. BINGHAM: The next section is 3.D., Compliance With Regulatory 'Requirements, IEEE Standards.
3 MRS. MORETON: Continuing on with SRP Table 7-1 Acceptance Criteria.
Exhibit 3D-l. IEEE Standard 279 identifies .
criteria for protection systems for nuclear power generating stations. The criteria in Section 4 will be addressed,.
Section 4.1, General Functional Requirements. In compliance with a clarification that the containment combustible gas control system is to be a manually initiated system. i 12 Exhibit 3D-2, continuing on with IEEE Standard 279. Section 4.2 on the single failure criterion. In compliance with the clarification that has been stated earlier about single failure in the BOP ESFAS will defeat more than one of the two protective channels. A single 17 failure may cause spurious actuation. However, this I
18 spurious actuation is allowable, since it does not create 19 plant conditions requiring protective action nor does it 20 interfere with normal reactor operations.
21 Exhibit 3D-3, continuing with IEEE Standard 279.
Section 4.3 on quality of components and modules. In 23 compliance.
24 Section 4.4 on equipment qualification. In 25 compliance.
GRUMLEY REPORTERS Phoenix, Arizona
IP 264 Section 4.5 on channel integrity. In compliance.
Exhibit 3D-4, continuing with IEEE Standard 279.
3 Section 4.6, Channel Independence. In compliance.
4 Exhibit 3D-5. Section 4.7, Control and Protection System Interaction. In compliance.
Subsections 4.7.1 on Classification of Equipment,,
II 4.7.2 on Isolation Devices. 4.7.3 shown on Exhibit 3D-6 on the Single Random Failures, Section 4.7.4 on Multiple Failures Resulting From a'redible Single Event, shown on 10 Exhibit 3D-7.
Continuing on with IEEE 279. Secti'on 4.8 on 12 Exhibit 3D-S, Derivation of System Inputs. In compliance.
13 4.9, Capability for Sensor Checks. In:compliance.
14 Exhibit 3D-9. Section 4.10 requiring capability 15 for test, and calibration. In compliance.
16 Exhibit 3D-10. IEEE Standard 279, Section 4.11 D requiring channel bypass or removal from operation. In 18 compliance. ,The one-out-of-two systems, however, do violate 19 the single failure criterion during channel bypass for main-20 tenance.
21 Exhibit 3D-ll. Section '4.11 continued at the top 22 of this. Testing of the ESFAS is done by channel actuation.
23 Either one of the two channels may be calibrated or repaired without detrimental, effects on the system. Individual trip 25 channels may be bypassed to effect a single channel logic GRUMLEY REPORTERS Phoenix, Arizona
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265 during maintenance mode.
Exhibit 3D-12, continuing with IEEE Standard 279, 3 Section 4.11 at the top of the slide.
4.12 on Operating Bypasses. The BOP has no operating bypasses.,
Exhibit 3D;13, IEEE Standard 279. Section 4.13 on Indication of Bypasses. Xn compliance.
Section 4.14, Access to Means for Bypassing. In compliance.
10 Exhibit 3D-14, IEEE 279. Section 4.15 on Multiple
, Setpoints. Xn compliance.
12 Exhibit,3D-15 continuing with IEEE Standard 279.
13 Section 4.16, Completion of Protective Action Once It Xs 14 Initiated. In compliance.
15 Section 4.17 addressing manual initiation. In 16 compliance.
17 Exhibit 3D-16 continuing with IEEE Standard 279.
Section 4.18 addressing access to setpoint adjustments, calibration, and test points. In'compliance.
20 Section 4.19 require,ng identification of protective 21 actions. In compliance.
22 Exhibit 3D-17 continuing with IEEE Standard 279.
23 Section 4.20, Information Read Out. In compliance.
24 Exhibit 3D-18 continuing IEEE Standard 279. Sectio 25 4.22 on Xdentification. Xn compliance.
GRUMLEY REPORTERS Phoenix, Arizona
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266 Exhibit 3D-19. IEEE Standard 308, Criteria for Class IE Power Systems. Requirement is for power systems to meet the functional requirements. In compliance.
IEEE Standard 317 on Electrical Penetrating Assemblies .in Containment Structures. In compliance.
Exhibit 3D-20. IEEE Standard 336 on Installation, Inspection, and Testing Requirements for Instrumentation and Electric Equipment During Construction. In compliance.
IEEE Standard 338, Criteria for Periodic Testing.
10 In compliance.
Exhibit 3D-21. IEEE Standard 344 addressing 12 seismic qualification of Class IE equipment. In compliance.,
13 IEEE Standard 379 addressing the application of single failure criteria. In compliance.
15 Exhibit 3D-22. IEEE Standard 384, Criteria for Separation of Class IE Equipment and Circuits. In compliance 17 per Reg. Guide 1.75.
MR. BINGHAM: Are there any questions?
MR. STERLING: On Exhibit. 3D-16, Section 4.18, the 20 control access, was it designed in the controls? Is that a 21 key lock or are you depending upon administrative procedures, 22 or what?
23 MRS. MORETON: ESPAS setpoints are controlled by key 24 lock. Other setpoints are adjustable in the control room and they are controlled by administrative procedures.
GRUMLEY REPORTERS Phoenix, Arizona
267 MR. HELMAN: Exhibit 3D-ll, Section 4.1l. In your clarification, you are talking about a short time interval with maintenance and calibration of the bypass panel. Can you shed some more light on that, please?
MR. BINGHAM: Excuse me just a minute. Was that an open item we had from yesterday?
MR. ALLEN: It seems like it was.
MR. BINGHAM: Maybe Gerry or Terry could help us on that point.
10 MR. KOPCHINSKI: There was a question on time allowed for bypass.
12 MR. ALLEN: It was Jack's question. I think it was 13 how can you justify a short interval, what justifies it.
14 MR. BINGHAM: Is that the same question?
15 MR. HELMAN: Yes.
16 MR. BINGHAM: All right. Do you have any other 17 questions?
18 MR. HELMAN: No.
19 MR. BINGHAM: I think Ralph's got one.
20 MR. PHELPS: It is a followup on the question that 21 was just asked and you might take it into consideration when 22 you come up with your justification that when you look at 23 that, time interval, you might have to look at it not only on a per event observance, but on an integrated time out of 25 service to make your argument. You might want to look at GRUMLEY REPORTERS Phoenix, Arizona
268 that very carefully, because it. might prove to be restrictive and would have to go in the Tech. Specs.
3 MR. ALLEN: I'e got. a question on 3D-2. On the clarification, it says spurious actuation is allowable since it does not create plant conditions requiring protective action nor does it, interfere with .normal reactor operations.
I was trying .to figure out in my own mind how we could say that a spurious actuation of the sequencer full power is not going to interfere with normal reactor operation.
10 MRS. MORETON: The sequencer is designed to only actuate pumps and does not control any valves. The pumps 12 would go on recirc and no injection would be initiated.
13 MR. ALLEN: So in no way would it. interfere with 14 normal reactor operations?
15 MR. BINGHAM: .Could you define normal reactor operations to us?
17 MR. ALLEN: Operating the system at all, just continue 18 on if you were operating at 75% power.
19 MR. BINGHAM: Xt shouldn't perturbate the system.
1 20 am sure the operators will be busy putting the safety systems 21 back in order.
22 , MR. ALLEN: Along the same line, I guess, I was 23 wondering how we justified making that statement. Was there 24 an analysis done?
MR. BINGHAM: John, in order to make sure we respond GRUMLEY REPORTERS Phoenix, Arizona
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269 correctly, we will caucus at break time and pick this up right after.
MR. KONDIC: Just to add to Mr. Allen's question, is there an event tree analysis to confirm this statement which, we are discussing now?
MR. BINGHAM: Event tree like fault .tree?
MR. KONDIC: Event tree analysis.
MR. BINGHAM: Fault tree analysis?
MR. KONDIC: Well, event tree is slightly different, 10 but this will really be able to confirm such a statement, an event tree analysis.
12 MR. ALLEN: It is just an addition to the question.
13 MR. BINGHAM: Yes. Are there any further questions?
14 MR. MINNICKS: On 3D-9, I would like some clarificatio 15 In the last sentence there, you talk about less than normal time interval between generating station shutdowns. I 17 would like to know what that is defined as. I's that a 18 refueling outage, or what is the intent of that generating 19 station shutdown?
20 MR. ALLEN: That probably should be clarified, because 21 generating station shutdowns. could be anything from spurious 22 trips- to whatever.
23 MR. BINGHAM: We will clarify it.
24 MR. MINNICKS: To go on with that, when you clarify, that should be whether that is l2 months, 18 months, what you GRUMLEY REPORTERS Phoenix, Arizona
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270 are talking about.
Above that, there is a statement "Where the required, interval between testing; " and I'm curious as to where that is documented, where those required intervals between testing are. Are we talking about surveillance .
requirements there?
MRS. MORETON: The shutdown is required by the Tech.
Spec. at periodic testing intervals.
MR. MINNICKS: So that is the Tech. Spec. surveillance requirements. Those are the required intervals between testing as defined in this statement?
12 MRS. MORETON: Yes.
13 MR. ROSENTHAL: r Deciding on what a proper, periodic 4 test interval is is the applicant's responsibility and, having decided what are appropriate test intervals, the NRC staff may put them'nto the Technical Specifications of a plant, but it is your responsibility based on your knowledge of equipment reliability to decide what would be a proper test interval.
20 MR. MINNICKS: I guess using that, we have heard 21 discussions that, for some of these systems or some of these I k
22 instrumentations that have been post-TMI, requirements aren' 23 designed yet, so I am curious as to how you can say that 24 you are complying with these requirements when the instru-25 mentation isn't designed. Therefore, the required interval GRUMLEY REPORTERS Phoenix, Arizona
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271 for testing can't be defined, either.
MR. BINGHAM: John, we may be getting tangled up in what compliance means. At, the other IDR's, we have indicated if, t
that we have not yet procurred an instrument, for example, that it would be our intent.to comply once we have procurred it and determined the parameters that were appropriate for testing. While we say we are in compliance, we really have that one exception.
MR. MINNICKS: So that is compliance with systems as designed as of the writing of this document.
MR. BINGHAM: Yes.
12 MR. KEITH: And the systems which are yet to be designed, we intend them to be in compliance.
14 MR. ROSENTHAL: IEEE 338-l977, Section 6.5, talks about test intervals and defines initial test interval frequency and changes of test interval lengths, and I believe it would be appropriate for you to consider these stipulation or criteria in the selection of test intervals for equipment,,
especially those that are new.
20 MR. ALLEN: Any further questions?
21 Is this a good time 'to break?
22 MR. BINGHAM: Yes.
23 MR. ALLEN: Why don't we take about a 15-minute 24 break.
25 (Thereupon a brief recess was taken, after which GRUMLEY REPORTERS Phoenix, Arizona
272 proceedings were resumed as follows: )
MR. ALLEN: Jack, I believe you had a question before we recessed.
MR..ROSENTHAL: Yes. Exhibit 3D-8, Section 4.9 of IEEE 279, do you employ pressure or temperature switches as well as analog devices for bistables?
MRS. MORETON: We have no pressure switches in safety-related systems. We would have to check on temperatur systems for the HVAC system.
10 MR. ROSENTHAL: Exhibit 3D-5, Xsolation Devices.
I would appreciate on a programmatic basis a statement of 12 the criteria that you use in the selection of isolation 13 devices and link that with your cable routing criteria downstream of those isolation devices.
15 MR. BXNGHAM: We will take that as an open item.
MR. ALLEN: You touched on that yesterday.
17 MR. KEITH: I was going to ask how that'as different, 18 from what we stated yesterday, Jack.
19 MR. ROSENTHAL: We have before us a set of statements 20 by Bechtel and I was hoping to appropriately insert in the 21 transcript some programmatic statements which would. serve 22 as confirmation of your statements.
I 23 MR. ALLEN: Do you want to take that as an open item 24 or do you want to address it now?
25 MXSS KERRIGAN: Maybe we can help the Board if Jack GAUMLEY REPORTERS Phoenix, Arizona
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273 can kind of tell you the type of statements that he is looking for.
MR. BINGHAM: All right.
MR. ROSENTHAL: I would hope that you had purchased all your isolation devices for at least, let's say, 480 volts AC and some DC voltage, applied it to that terminal, and that, having done that, you ensure that all cables downstream of isolation buffers are run in cable trays where you don' have 2,160 volts. Some general statement of that sort I 10 think would clear it up. Zf you'e got a mix-and-match situation, it may be more difficult.
12 MR. BINGHAM: I think that was the same area that. we
\
13 discussed yesterday.
MR. ROSENTHAL: Can you make a definitive statement.
15 MR. BINGHAM: Let's see if we can do that.
16 MRS. MORETON: All analog isolation devices are bought 17 at 600 volts AC isolation capability. Digital'solation 18 devices are bought at 1,500 volts DC isolation capability.
19 All downstream cables are routed per the EE580 program in 20 cable trays at, voltage levels much lower than those rated 21 isolation voltage levels.
22 MR. BINGHAM: Is that the statement you were looking 23 for?
24 MR. ROSENTHAL: Thank you.
25 MR. ALLEN: Does that close that item, then? It GRUMLEY REPORTERS Phoenix, Arizona
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274 closes the item.
Any further questions?
Go ahead, Bill.
MR. BINGHAM: The next section we will do is 3.E.,
Compliance, With Regulatory Requirements, Branch Technical Positions.
MRS. MORETON: Continuing on with SRP Acceptance Criteria Table 7-1 on the Branch Technical Positions starting on Exhibit 3E-l. Branch Technical Position ICSB 1 requiring instrumentation and, electric equipment essential to safety to function in an accident environment, requiring protection 12 circuits 'to meet single failure criterion, and that DC power 13 be provided for single failure criterion, in compliance.
14 ICSB l is continued on Exhibit 3E-2 requiring 15 redundant sources of onsite AC power. Also in compliance.
1 16 Exhibit 3E-3. Branch Technical Position ICSB 3 17 requiring the design of interfaces between low pressure 18 systems and high pressure systems. In compliance.
19 Exhibit 3E-4, continuing with Branch Technical Position 3 at the top of the slide.
21 At the bottom of the slide, Branch Technical Position ICSB 4 requiring that features be incorporated in 23 the design of MOI valve systems to meet the intent of IEEE
.Standard 279. In compliance.
25 Exhibit 3E-5 provides more specific information on GRUMLEY REPORTERS Phoenix, Arizona
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275 Branch Technical Position 4.
Branch Technical Position 4 is continued again Exhibit 3E-6.
Also identified is Branch Technical Position ICSB 5 5 requiring control rod drive trip breakers be tested monthly which is in NSSS scope.
Exhibit 3E-7 continues with Branch Technical Position ICSB 9 requiring daily adjustment to fulfillthe requirements of calibration procedures to remain as a daily 10 requirement, but be. deleted from the channel calibration category in the Technical Specifications. In compliance.
12 Branch Technical Position ICSB 12 requiring a 13 change to the more restrictive setpoints be accomplished automatically when required. In compliance.
15 Exhibit 3E-S, continuing with Branch Technical 16 Position 12 at the top of the slide.
17 Branch Technical Position ICSB 13 on the auxiliary 23'nfeedwater 18 system. In compliance.
19 Exhibit 3E-9, Branch Technical Position ICSB 14, 20 requirement to demonstrate compliance with the requirements 21 af GDC 20 to 25 with regard to spurious withdrawal of single 22 control rods. NSSS scope.
Exhibit 3E-10. Branch Technical Position ICSB 16.
24 Interlocks are considered safety-related and should meet 25 the requirements of IEEE 279 for the shutdown CEA's and more GRUMLEY REPORTERS Phoenix, Arizona
276 than two groups of CEA's. All these are in the NSSS scope.
Exhibit 3E-ll. ICSB 18. Where a single failure in an electrical system can result in loss of capability to perform a safety function, the effect on the plant safety must be evaluated. In compliance.
Branch Technical Position ICSB 20. A manual initiation of the transfer to the recirculation mode. In compliance.
Exhibit 3E-12 continues with Branch Technical 10 Position 20 and is also directed to Branch Technical Position ICSB 21 on bypass indicators. In compliance.
12 On Exhibit 3E-13, Branch Technical Position 21 r
13 is continued, and on Exhibit 3E-14.
r 14 Exhibit. 3E-15. Branch Technical Position ICSB 22 15 on testing of the protection systems. In compliance.
16 Branch Technical Position ICSB 25 requires complian 17 with GDC 37. In compliance.
18 Branch Technical Position ICSB 26 on reactor trips 19 is NSSS scope.
r 20 MR. BINGHAM: Are there any questions from the Board?
21 MR. PHELPS: I have a question on Exhibit 3E-4. On 22 Branch Technical Position ICSB 4, the first statement is 23 automatic opening of the valves. Would you just explain 24 your clarification to that position for me, please, the 25 clarification on 3E-6, and how it relates to Item No. l.
GRUMLEY REPORTERS Phoenix, Arizona
277 MR. BINGHAM: I'm sorry, I didn'. hear the last part of that question.
I MR. PHELPS: I would like to just have you explain to me how your clarification relates to Item l. Do the valves automatically open when the reactor coolant pressure reaches a certain value and then the operator manually locks them open? Is that what you mean to say?
MRS. MORETON: That's correct. That was discussed in the CESSAR IDR, the interlocks on the safety injection tank 10 isolation valves. The valve motor centers are also opened and locked.
12 MR. STERLING: On that same Exhibit 3E-4, the indica-13 'tions for the safety injection tanks on the main board are h
14 safety-related. Why is not 7.5 applicable in this case?
15 MRS. MORETON: The nonapplicable identified in this 16 table would" be because it was not checked in SRP Table 7-l, 17 but your statement is correct. They are, identified on the 18 main control board'.
19 . MR. STERLING: It is the case that the safety-related 20 displays for the safety injection systems do meet. the 21 requirements of a safety-related display system that would 22 have been set down if they were J
inapplicable under 7.5?
23 MRS. MORETON: Yes.
24 MR. ALLEN: Further questions from the Board? Ned.
25 MR. KONDIC: A formal question. On Exhibit 3E-7 under GRUMLEY REPORTERS Phoenix, Arizona
0 278 1, you said setpoints. It is written trip points. Xs it a typo or is it setpoints or trip points?
3 MRS. MORETON: it I think is the same thing.
MR. KONDIC: You have setpoints without any trip.
MRS.. MORETON: The only requirement is on the reactor trip system as an 'interface.
MR. KONDIC: Then it is trip points?
MRS. MORETON: Xt is trip points.
MR. KONDIC: Thank you.
10 MR. ALLEN: Further questions?
MR. MECH: On Exhibit 3E-11, I have a specific 12 question in this case on the shutdown cooling system inter-13 locks and the safety injection tank interlocks. Xf I under-14 stand it properly, the system design is such that a'll the 15 power can be lost on all the interlocks at one time on a loss of power incident.. Are the interlocks such that. they
'17 will change state under a loss of power or suffer a common 18 mode failure on more than one interlock' 19 MRS. MORETON: Would. you clarify that on loss of power Loss of power to more than one channel?
MR. MECH: Yes.
22 MRS. MORETON: More than one channel?
23 MR. MECH: Right.
24 MR. BINGHAM:, I believe we are still just a little confused on the question.
GRUMLEY REPORTERS Phoenix, Arizona
279 MR. ROSENTHAL: Are the interlocks supplied by vital power?
MR. BINGHAM: Yes, they are.
MR. MECH: Well, that conflicts with my understanding of the FSAR, .then.
MRS. MORETON:. The interlocks are addressed in CESSAR Section 7.6.
MR. MECH: They are also addressed in Palo Verde, too.
Maybe it. is a question of the wording or the accuracy of the 10 writing.
MRS. MORETON: The Class IE alarms are addressed A
in 12 the Palo Verde FSAR.
13 MR. BINGHAM: Perhaps, John, if the Board or NRC could provide us,with a reference, we could look at that and 15 clarify the..issue.
16 MR. ALLEN: Do you have a reference we could look at?
MISS KERRIGAN: Why don'0 you give us a'ouple minutes I
18 If you could give him Section 7 of the Palo Verde FSAR, a 19 copy of that, so that he can find the reference, we will go 20 on while he is looking at that.
21 MR. BINGHAM: We can do that.
22 MR. ALLEN: We will come back to it, then.
23 MR. ROSENTHAL: I would like to insert into the transcript at this 'point that implementation of Branch, 25 Technical Position Reactor Safety Branch 5.1 with respect to GRUMLEY REPORTERS Phoenix, Arizona ~
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280 the ability to perform a cold shutdown from the control room may require interpretation of Branch Technical Positions ICSB 4 and 18, interpretations that are different from those that, are now employed.
I MISS KERRIGAN: That was an open item from yesterday.
I just wanted to draw your attention again to that.
MR. ALLEN: Do you have any further questions? Do 8 you have your reference yet?
MR. BINGHAM: Would it be appropriate to continue 10 while they are looking for the reference?
MR. ALLEN: I think we can continue.
12 MR. BINGHAM: The next section is 3.F., Compliance 13 With Regulatory Requirements, IE Bulletins, Circulars, and 14 Information Notices.
15 MRS. MORETON: Referring. back to Figure '3-1. We have completed the Standard Review Plans and will now address the IE Bulletins, Circulars, and Information Notic'es.
18 Exhibit 3F-1 starts off with IE Bulletins beginning 19 with 78-01 on Flammable Contact-Arm Retainers in GE CR120A 20 Relays. These are not used in the PVNGS design.
21 78-02 on Terminal Block Qualification has been covered on another Review Board is per IEEE 323 and NUREG-23 0588.
24 78-04 on Environmental Qualification of Certain 25 Stem-Mounted Limit Switches Inside Reactor Containment, will GRUMLEY REPORTERS Phoenix, Arizona
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28l also be qualified per NUREG-0588 to meet the requirements of Reg. Guide l.97. This slide will be corrected.
78-05, Malfunctioning of Circuit Breaker Auxiliary Contact Mechanism General Electric Model CR105X. This is not used in the PVNGS design.
78-06, Defective Cutler-Hammer Type M Relays With DC Coils. Not used in the PVNGS design.
Exhibit 3F-2, continuation with Bulletins. 79-05, 05A, 05B, 05C, 06, 06A, 06B, and 06C are all addressed as 10 part of NUREG-0737..
79-09 on Failures of GE Type AK-2 Circuit Breaker 12 in Safety-Related Systems, we will follow manufacturer's 13 service advice in preventive maintenance.
79-ll, Faulty Overcurrent Trip Device in Circuit 15 Breakers for Engineered Safety Systems. Westinghouse DB-50's 16 are not used in the PUNGS design.
17 Exhibit 3F-3, continuing with IE Bul'letins. 79-25, 18 Failure of Westinghouse BFD Relays in Safety-Related Systems.
Not used in the PVNGS design.
20 79-27, Loss of Non-Class IE Instrumentation and 21 Control Power Bus During Operation. The PVNGS design does 22 provide for two ungrounded non-IE instrument distribution 23 panels and four ungrounded vital panels. All Non-IE 24 instrumentation has a IE counterpart to provide continuous control room readout of shutdown parameters even with a
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GRUMLEY AEPORTERS Phoenix, Arizona
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282 total loss of all non-IE instrumentation. This Bulletin is addressed further in Section 4 later today.
79-28, Malfunction of NAMCO Limit Switches. NAMCO has corrected the problem by the use of a suitable gasket material. Action has been taken to ensure that all NAMCO switches on PVNGS will be installed with suitable gasket material.
Exhibit 3F-4, continuing with IE Bulletins. 80-06, Engineered Safety Features Rest Controls. PVNGS ESF actuated devices remain in emergency mode on reset of an ESF actuation signal with the following clarifications: Actuated devices 12 with different safety modes in response to different ESF 13 actuation signals by design may actuate to a different safety 14 mode on reset of an ESF actuation signal. Ne will discuss this in a little more detail with specifics in Item 4 later this morning. The auxiliary feedwater valves by design 17 cycle closed on automatic AFAS,reset. Again, 'that will be
'discussed in detail later in Item 4.
19 80-l2, Decay Heat Removal System Operability.
20 PVNGS design incorporates four independent power channels 21 for ESFAS initiation and two full capacity, independent shutdown cooling trains. The series of events resulting in loss of decay heat, removal are not possible 'in the PVNGS 24 design.
Exhibit 3F-5, continuing with IE Bulletins. 80-16, GRUMLEY REPORTERS Phoenix, Arizona
283 Misapplication of Rosemount Pressure Transmitters. PVNGS use of the subject Rosemount pressure transmitters has been V
reviewed and their use in safety-related applications are 4 within the calibrated range of the transmitter.
80-20, Failure of Westinghouse W-2 Type Spring Switches. West'.'nghouse Type W-2 control switches are not used in the PVNGS design.
80-23, Failures of Solenoid Valves Manufactured by Valcor Engineering Corporation. No Valcor solenoid valves are used in safety-related service in the PVNGS design.
We will now go on with IE Circulars on Ehxibit 3F-6 I
12 78-08, Environmental Qualification of Safety-Related 13 Electrical Equipment at Nuclear Power Plants. Qualification, 14 ,,as stated before, will be per IEEE 323 and NUREG-0588.
15 78-19, Manual Override or Bypass of Safety Systems 16 Actuation Signals. Override of an ESF actuation signal in the component'ogic places the component under'anual" control 18 blocking any subsequent ESF actuation. Override is auto-19 matically removed on reset of the ESF actuation signal. Once in the override mode, the SESS alarms at the system level every system impacted when the component is returned to 'its 22 normal non-ESF position. The only exception is the contain-23 ment purge isolation valves do have separate override logic 24 for the CPIAS and the'IAS.
25 Exhibit 3F-7, continuing with IE Circulars.
GAUMLEY AEPORTERS Phoenix, Arizona
284 80-01, Service Advise for GE Induction Disc Relays. Field inspection is in progress to identify affected relays in j
work.
80-12, Valve Shaft-to;Actuator Key May Fall Out, of Place When Mounted Below Horizontal Axis. On PVNGS, Loctite adhesive is used in addition to the press fit key connection.
80-16, Operational Deficiencies in Rosemount Model A
510DU Trip Units and Model 1152 Transmitters. Neither of 10 these are used in the PVNGS design.
81-01, Design Problems Involving Indicating 12 Pushbutton Switches Manufactured by Honewell Incorporated.
13 Review of this circular is still under way.
14 Exhibit 3F-8 proceeds with Information Notices.
15 Information Notice 79-22 on Qualification of Control Systems.
16 Analysis of high energy line break effects on control systems 17 resulting in, complicating failures is in process. We will 18 cover this more in Item 4 today.
19 79-29, Loss of Nonsafety-Related Reactor Coolant 20 System Instrumentation During Operation. The design does 21 provide for two ungrounded non-IE instrument panels and four 22 ungrounded vital Class IE panels to provide continuous contro 23 room readout of shutdown parameters even with a total loss 24 j
of all non-IE instrumentation. 4 25 79-30, Reporting of Defects and Noncompliance GRUMLEY REPORTERS Phoenix, Arizona
285 With 10CFR21. We are in compliance..
80-08, The States Company Sliding Link Electrical Terminal Blocks. These are not used in the PVNGS design.
80-10, Partial Loss of Non-Nuclear Instrument System Power Supply During Operation. Instrumentation provided is Class IE. and would not cause the operator to be instrument blind.
Continuing with ZE Information Notices on Exhibit 3F-9. 80-13, GE Type SBM Control Switches with Defective 10 Cam Followers. All SBM switches used on PVNGS are post-1976 manufacture and not subject to defective cam follow'ers.
12 80-20', Loss of Decay Heat Removal at Davis Besse 13 Unit No. 1 While in Refueling Mode. This was discussed 14 earlier in the Bulletins. Tpe series of events resulting in 15 the loss of decay heat removal are not possible in the PVNGS 16 design, which uses four independent, sources of instrument 17 power and has two independent full-capacity tr'ains for lt 18 shutdown cooling which do not isolate on spurious ESF 19 actuation signals.
20 80-31, Maloperation of Gould-Brown Boveri Type 480 21 Volt K600S,and K-Don 600S Circuit Breakers. Not applicable 22 to PVNGS supplied breakers,- which were supplied after 1977.
23 Exhibit 3F-10, continuing with the Information Notices. 80-40, Excessive Nitrogen Supply Pressure Actuates 25 SRV Operation,to Cause Reactor Depressurization. PVNGS GRUMLEY REPORTERS Phoenix, Arizona
0, 286 design uses spring-loaded relief valves. The atmospheric dump valves have redundant solenoid valves in pneumatic 3 supply to isolate overpressure source. Leakage through solenoid valves would be to atmosphere.
81-01, Possible Failure of General Electric Type HFA Relays. Field inspection is in process to identify affected relays.
81-05, Degraded DC System at Palisades. PVNGS 9 design incorporates breaker alarms on the DC system annunciat 10 on the SESS.
81-06, Failure of ITE Model K-600 Circuit Breaker.
12 This information notice is'n process'f review.
4
-13 MR. ALLEN: Any questions from the Board?
14 MR. STERLING: Exhibit 3F-6.1 In your statement on 15 the right.-hand side for 78-19, the first two sentences seem 16 to be in conflict with each other. You state in the first 17 one that when you override that. you are blocking any 18 subsequent ESF actuation, and in the second one, you say the 19 override is automatically removed.
20 'et me withdraw the question. Let me ask another 21 question. If one signal comes in and another signal comes 22 in, normally would it cancel? In other words, can one 23 signal remain and another come in or is it normal that when 24 another comes in, it cancels the first one?
25 MRS. MORETON: For a device which has a single ESFAS GRUMLEY REPORTERS Phoenix, Arizona
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287 signal actuating that device, the override is very simple, as we discussed earlier. on the override circuitry. For devices which are actuated by more than one ESF signal, once the first signal has come'n and the, operator has armed the F
override, that effectively, blocks any future 'signals from performing their function with the exception of the contain-ment purge isolation valves, which were specifically addresse by the IE Circular, and th'e design has been modified to provide independent override circuitry.
10 MR. STERLING.: Is there a case where the operator puts r
an item into override and the ESF actuation signal disappears at that point and fails to reset it, then another action in 13 the plant causes .another signal to come in which would have E
14 required this valve to go to whatever its safe position was 15 and" it failed to do so because the other was not reset?
MRS. MORETON: If the operator failed to reset the li 16 first ESF actuation signal when the initiating'ircuitry returned to normal?
19 MR. STERLING: Yes.
20 MRS. MORETON: It is still annunciated on, the SESS.
21 Can you clarify your question?
22 MRS. STERLING: Well, I was trying to think of an 23 example, but say, for example, you'e got containment 24 isolation and then you put some valves in override to open 25 up some lines for whatever you are going to do and then GRUMLEY REPORTERS Phoenix, Arizona
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288 the signal goes away.
MRS. MORETON: The containment isolation signal goes 3 away or high containment pressure signal goes away?
MR. STERLING: The containment isolation signal goes away.
MRS. MORETON:, Then'he override is reset automaticall It is automatically removed.
MR. STERLING: Your second statement is that the reset is not an operator action then. That. is an automatic 10 reset?
MRS. MORETON: Reset of the override is automatic.
12 When you use the word "reset," that can also be construed 13 to mean the reset of the CIAS signal,-which is manual after 14 the initiating conditions have cleared.
15 MR.,PHELPS: On Exhibit 3P-S, with reference to 79-29 16 and 80-10, do you have some sort of alarm or indication in 17 the control room that specifically alerts the operator to 18 the loss of a non-IE instrument bus?
MRS. MORETON: 79-29 was addressed in the AC Review 20 Board in a great deal of detail to, close out an action item 21 and it is provided in Section 4. To answer your question 22 specifically, alarms are provided, and we. can get into that 23 in detail when we get to Section 4.
24 MR. MINNICKS: I'e got one on 3P-2, 79-09, you say you will follow manufacturer's service advice in preventive GRUMLEY REPORTERS Phoenix, Arizona
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maintenance. Could you elaborate on that a little bit more?
, MRS. MORETON: The information provided by GE was that they would provide service advice to prevent the problems that were experienced with the Type AK-2 circuit breakers and .that service a'dvice will. be available to you.
We don't know what it is at this time.
MR. MINNICKS: GE is going to provide it to Bechtel or to APS?
'9 MR. BINGHAM: Yes, both.
10 MR. MINNICKS: On Exhibit 3F-3, 79028, and this also is the same question I'e got kind of generic to two others.
12 One is 'a Bulletin and one is a Circular, 80-l3 and 80-31.
13 has to do with spare parts. Bechtel is procurring some l't 14 spare parts on purchase orders. The NAMCO limit switch, 15 79-28, for instance, says that actions have been taken to assure that PVNGS will only get gasket material that is 17 suitable and these other two identify equipmen't that was 18 manufactured after a certain date, that, that is the only equipment that we are receiving. I am curious as to what 20 assurance we have that spare parts that are also procurred 21 by Bechtel will meet that same. criterion.
22 MR. BINGHAM: The Bechtel Engineering Group would be 23 assuring through review that the spare parts are purchased 24 to the proper requirements through review of the purchase 25 documentation.
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290 MR. MINNICKS: I think the last one I have was on 3F-5 on 80-16. You are very. specific there about the fact 3 that Rosemount transmitters that are used in safety-related applications are within the calibrated range. Has there been an investigation made to assure that Rosemount trans-mitters in applications that could confuse or cause adverse indications to the operator have also been checked to assure they are within the calibrated range of the transmitters I'hat 4
In other words, these particular Rosemount transmitters have 10 been found to do funny things when they are overpressurized.
MR. BINGHAM: Well, let me see if I understand the problem. You are talking about transmitters in harsh environments or transmitters in harsh and non-harsh environ-1 14 ments?
15 MR. MINNICKS: I guess it could be'ither.
16 MR. BINGHAM: Well, it makes a difference to answer the question. In harsh environments, I am not'ure that we have any Rosemount transmitters on Palo Verde. I believe that's correct.
20 MR. MINNICKS: We do have some inside the containment.
I 21 MR. ALLEN: In Combustion's scope, diversity, they 22 have diverse transmitters from Rosemount.
23 MR. BINGHAM: There are six diverse ones in 24 Combustion's scope for the plant inside -and Combustion would have to answer to that particular question, but I am sure GRUMLEY REPORTERS Phoenix, Arizona
291 they are looking at the qualifications.
2 MR. MINNICKS: How about the non-harsh environment?
MR. BINGHAM: In the non-harsh environment, I suppose 4 that they might give a false reading due to high pressures.
In the non-harsh environment, of course, we don't expect high pressures.'ll of the instruments are qualified for the environments that they will see, radiation, humidity.
MR. ALLEN: I think I can clarify that. Jim is talking about with high process pressure.
10 MR. MINNICKS: That's right. This Bulletin applies to overranging those particular transmitters, not environmental.
12 MR. BINGHAM: I am sorry, I missed the question.
13 John, there seems to be some confusion on our part.
14 Is it the nonsafety-related transmitters you are referring to or the safety related?
MR. MINNXCKS: The nonsafety related. You made a very definitive statement relative to the safe'ty related.
18 What. I,am concerned about is those identified as nonsafety related but still could have a very confusing effect. upon 20 the operator., 4
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21 MR. BINGHAM: We have not looked into the detail of the nonsafety-related transmitters. To answer your question, 23 we have not looked into that, same depth of detail.
24 MR'. ALLEN: I guess to carry that on a little further, 25 do you intend to?
GRUMLEY REPORTERS Phoenix, Arizona
IJ 292 MR. BINGHAM: No.
MR. MINNICKS: I have a feeling it would be wise if that were done, because pretty much of the balance of plant instrumentation in the area of transmitters are Rosemount's.
Just about everything that the operator is seeing on his Foxboro 270 is being supplied by a Rosemount transmitter.
MR. BINGHAM:. John, perhaps we should have a conversa-tion with APS outside the meeting since we are. talking about nonsafety-related transmitters and come to agreement on what should be done for the project.
Q MR. ALLEN: I can see Jim's point. If you don't look 12 at, them, there is a possibility that this type of transmitter if overranged would cause false readings to make the operator 14 take inappropriate action, so I think it is an issue that should be kept open and resolved.
16 MR.: BINGHAM: I don't know how to resolve it for this 17 forum. If the agreement is to go ahead and lo'ok at it, 18 certainly we can look at them.
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19 MR. ALLEN: Without going back and looking at, the answer you provided us when this Bulletin came out; I would think it wouldn't be a real overwhelming task to apply the 22 same criteria on the other ones.
23 MR. BINGHAM: We will look at them.
24 MR. MINNICKS: I just had one other question on 3F-7.
80-12 says on PVNGS, Loctite adhesive is used in addition GRUMLEY REPORTERS Phoenix, Arizona
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A to press fit. Xs that Loctite adhesive supplied by the vendor, or'hat, is going Co be done by whom?
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MRS. MORETON: We have a letter from Pratt stating that that will be done by Pratt. It was done before the valves were shipped.
MR. MXNNXCKS:, The same engineering review relative to spare parts would account for that, also?
MR. BXNGHAM: Yes.
MR. ROGERS: Exhibit 3F-9, Bulletin 80-20. Would you clarify what you mean in the response there about full-capacity trains for shutdown cooling? Are those indeed full-capacity trains? What does that mean?
13 MR. KEITH: Each train is capable by itself without 14 the other one operating of bringing the reactor to a cold shutdown condition.
16 MR. ROGERS: However, the temperatures may be somewhat, 17 different depending on whether you are using o'e train or two trains, is that. not correct?
MR. KEITH: Yes, and, of course, the speed at which 20 you come down to that, also.
21 MR. ROGERS: Fine. Very good.
22 MR. ALLEN: Any further questions from the Board?
23 I'e got, one kind of a generic question on this whole issue'f XaE Bulletin review. We have exhibits that indi.cate that such and such an item is not used in the GAUMLEY REPORTERS Phoenix, Arizona
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294 Palo Verde design. My question is how do we assure that when the initial investigation was done, maybe Engineer A checked it, and we order TMI-related equipment tomorrow and Engineer B does that work; how does he ensure that he is not procurrin some of the stuff that we said. we did not use in the Palo
'I Verde design?
MR. BINGHAM: There are several levels that we have of assurance. First of all, when the Bulletin comes in, we send letters to all of the potential manufacturers and ask 10 them to research their supply. This would include the NSSS vendor. They will come back and say yes or no regarding 12 whether the equipment is applicable to the bulletin. We then make that information known P
to APS through a letter and to our procurement people, and there are separate quality bulletins that are sent out to all of our people in the procurement area and the inspection area. We have had-occasion where vendors with their subsuppliers have not been 18 thorough. Through the industry, we have found out about 19 those. We factor that information back into our system.
20 Now regarding your specific question on TMI items, 21 the designer still is under a .supervisor that has that information and we rely on. the designer and the supervisor to make sure that any of these requirements are incorporated 24 in the design. There are fall-back positions, because the 25 procurement group will also have the information- and have CRUMLEY REPORTERS Phoenix, Arizona
0' 295 been trained to be aware of the fact that there is a
.deficiency and that they should not order material from a 3"
supplier even if it is specified by the engineer. If that fails, there is another fall-back position, and that is that all of. our procurement documents and purchase orders are reviewed and approved by Arizona Public Service, who are also aware of the deficiencies. The final fall-back position I
would come with the inspection on 'the part of our procurement department where <hose people have been trained to look for 10 particular deficiencies, and I guess a final fall-back position comes from the QA audits of suppliers both by 12 Bechtel and APS and other utilities on the supply of material 13 MR. ALLEN: Just one clarification. Do you publish 14 maybe a defective component. list or "don't use",list like 15 don'0 use Type M relays?
16 MR. BXNGHAM: There are two things. One, the chief 17 engineers put out a problem alert that goes to'he designers 18 to make sure that, they don't use that particular component.
19 There =is also what we call the QA bulletin that goes to all 20 members of the proj'ect; in other words, procurement, J
21 engineering, management, QA. So we have a wide distribution 22 of the particular problem in house.
23, MR. ALLEN: Any further questions from the Board?
24 NRC?
25 MR. ROSENTHAL: Yes. On this general issue, circulars GRUMLEY REPORTERS Phoenix, Arizona
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296 or notices coming from the NRC staff or manufacturers recognize that an isolated problem which may have. been reported as an LER in fact had generic implications, but that doesn't meant that, these lists are complete. Because l
this is a design review meeting rather than a compliance with NRC criteria meeting in part, is your'ystem more extensive than the ISE Notices, Bulletins and Circulars, and
}i information you may have gained from INPO or reading LER's?
9 What other efforts do you do?
10 MR. BINGHAM:. Well, are you asking the utility or Bechtel? Let me, John, take. just, a moment. Generally', we know about most of these issues before the bulletin comes out through either information from the utilities thiough their 14 contacts or through our inspection findings and we will be 15 looking at our projects far in advance of these documents-16 coming in. We generally also look at if there are other 17 implications that would be peculiar to a parti'cular project
'18 that may have been overlooked in other reviews. So in our 19 corporation, at least in Bechtel, we have separate indepen-20 dent projects and each project will be looking at this 21 particular 'issue as it applies to that project and generally there is a cross-fertilization of the information. Then we have with a major system the chiefs that are also looking 24 at 'the implications from a technical viewpoint and how it might apply generically across all of our projects. That is GRUMLEY REPORTERS Phoenix, Arizona
297 what is- done in Bechtel. The utilties have their own different ways of approaching the issue and maybe John or someone from APS might want to describe that program.
MR. ALLEN: APS at least on the nuclear side, we have procedures in effect where we look at all these bulletins and procedures. We the same as you have cross-fertilization between us and the fossil side. In several instances, problems have come up on some of the fossil units which are directly applicable to the nuclear side, so we 10 identify problems from that end.
Go ahead, Carter.
12 MR. ROGERS:, I will expand a little bit.
Il We not only 13 look at, the NRC bulletins in a formal manner, but we also I
14 look at the INPO'OER's in a formal manner in the engineering 15 office, and it is my understanding that, our Operations is doing a review of the SOER's from their side,,also. We take 17 part in a number of industry-related groups th'at share 18 information. This includes an active participation in the 19 Edison Electric Institute and EPRI groups, so we follow 20 those. We get information bulletins from Combustion 21 Engineering related to plant operations. We periodically discuss with Combustion. Engineering problems which we ask about as being related to our plant and.how Combustion 24 Engineering will ensure us that we won't have a similar kind 25 of a problem with our plant. So we do quite a bit of industr GRUMLEY REPORTERS Phoenix, Aritona
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298 review outside of that, that is specifically NRC and that is applied to the design as we have it and are designing and procurring.
MR. SIMKO: On the Operations side, we are gearing up for an operational review program in which I believe the shift technical advisors are going to review INPO studies, LER's, operational reviews from other utilities, and that program is being developed right now. It is not implemented, because we are not operating it, but we are goi'ng to have 10 a total review program.
MR. BINGHAM: John, might I ask, does that deal with 12 the question?
13 MR. ROSENTHAL: Thank you.
14 MR. ROGERS: Just one other thought was that we are 15 also members of Notepad and are regularly involved with the 16 Notepad network, which communicates with INPO and INSAC.
17 MR. ALLEN: Any further questions from 'the Board befor 18 we move on?
19 MR. MECH: Can I go back to that previous one?
20 MR. ALLEN: Sure, go ahead.
21 MR. MECH: I apologize for not having distinguished 22 in my notes between CESSAR notes and Palo Verde notes, but.
23 the statement in CESSAR is not refuted in Palo Verde,'o let 24 me read the statement in reference to interlocks. "... if 25 there should be a loss of all AC power. The interlocks are GRUMLEY REPORTERS Phoenix, Arizona
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299 automatically connected to the emergency buses. This is to assure that the interlocks and valves will be able to operate under all operating conditions." This is in Paragraph 7.6.l of CESSAR. That implies to me now that you can lose all 5 power through these interlocks.
I think it implies that you cannot lose tt 6 MR. KEITH:
all power, because in the event of a loss of all offsite AC power and the diesels, you still, have these things connected
'.to the batteries, four, independent batteries for the four
'V channels that feed these interlocks, so it is very unlikely that you will lose any of them let alone all four of the channels which provide input to the interlocks.
13 MR. MECH: You are saying then that the system is not as described here? It is not interruptible?
15 MR. KEITH: I don't know that that really implies 16 that it is interruptible. I don't know if CE would like to 17 comment on that. Ours is not interruptible.
18 MR, MECH: Very good.
19 MR. ALLEN: Further questions? Go ahead, Bill.
20 MR. BINGHAM: The next section we would like to cover is 3.G., Compliance With Regulatory Requirements, NUREG-0737.
22 MRS. MORETON: Referring back to Figure '3-l on 23 regulatory requirements, we will now address requirements 24 applicable to instrumentation and controls as defined ia 25 NUREG"0737-GRUMLEY REPORTERS, Phoenix, Arizona
300 Exhibit 3G-1. Item 1.D.l, Control Room Design 3'eviews. APS has formed a Control Room Design Review Management Team and is performing a preliminary assessment of the PVNGS control room. The early part of this effort was divided into three phases. Phase I of the study develope the guidelines to be used while conducting the control room design review. Phase II consisted of the detailed data-taking effort and the identification of human factors deficiencies. The three task areas addressed were human 10 factors, systems factors, and operator preparedness factors.
The deficiencies identified were anlyzed for proper resolutio 12 and assigned priorities to assist in determining a schedule 13 for implementation.
14 Continuing on on Exhibit 3G-2, Phase III, which is 15 currently in progress, includes preparati9n and publication 16 of a preliminary report. The review has resulted in APS 17 initiating implementation to date of color dern'arcation, 18 instrument relocation, alarm prioritization, and additional 19 instrumentation. When the control room design review is 20 completed, a final report will be submitted to the NRC.
21 The submittal date is targeted for December, 1981.
22 Exhibit 3G-3, Item 1.D.2 on Plant Safety 23 Parameter Display Console. We are in compliance with the 24 requirements as set forth in NUREG-0660. An SPDS is being 25 developed to display to operating personnel a minimum set of GRUMLEY REPORTERS Phoenix, Arizona
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301 parameters which define the safety status of the plant. The SPDS will provide continuous indication of direct and derived variables. The requirements of NUREG-0696 will be uitilized in development and installation of the SPDS.
Exhibit 3G-4, Item XX.B.3 on Post-Accident Sampling Post-accident sampling is in compliance with the requirements 7 of Item XI.B.3 and Reg. Guide l.97, as we discussed when we presented post-accident monitoring.
Exhibit 3G-5, Item XX.D.3, Direct Indication of 10 Relief and Safety Valve Position. PVNGS will comply. The design does not utilize power-operated relief valves. The 12 PVNGS primary code safety valves, located at the top of the 13 pressurizer, are headered into the reactor drain tank inside containment. Upstream of the common header, each code safety 15 valve is monitored for seal leakage by an in-line RTD.
16 Indirect indication of code safety valve leakage is provided 17 by an increase of RTD pressure and a decrease 'of pressurizer 18 pressure and pressurizer level, which is monitored by safety grade instrumentation. Positive indication of safety valve I
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position will be provided in the control room. The instru-1 20 21 mentation will be environmentally qualified. A plant 22 annunciator alarm will be provided to alarm valve opening, 23 Exhibit 3G-6, Item XI.E.1.2, Subpart 2, on the 24 Auxiliary Peedwater System Plow Rate 'Xndication. Plow rate 25 indication is provided. It is Class IE. Xt is monitored GRUMLEY REPORTERS Phoenix, Arizona
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302 flow to both steam generators. The flow indicator channels are displayed on the main control boards. In addition, there are Class IE pressure indicators located upstream of the manual block valves and Class IE steam generator level indicators are also provided. All of these indicators are powered from Class IE buses.
Exhibit 3G-7, Item II.E.3.1 on Emergency Power for Pressurizer Heaters. Pressurizer heaters are covered by k
the NSSS'esign. CE interface requirements. for the pressuriz 10 heaters are incorporated in the PVNGS design.
Exhibit 3G-8 identifies the number of heaters and 12 the power provided to the heaters.
13 Exhibit 3G-9, Item II.E.4.2 on Containment 14 Isolation Dependability. Item 1, in compliance. A contain-15 ment isolation signal is diversely generated by either a high containment pressure signal or a lower pressurizer 17 pressure signal. The power access purge and r'efueling 18 purge are additionally isolated by high containment purge 19 radioactivity by the containment purge isolation signal.
20 Exhibit 3G-10, continuing with Item II.E.4.2.
21 Item 4, we are in compliance. Override of a CIAS signal 22 is ava'ilable for each containment isolation valve via the 23 control switch for that valve. Resetting of a CIAS does not 24 result in the automatic opening of containment isolation 25 valves. Reopening does require opeiator action for each GRUMLEY REPORTERS Phoenix, Arizona
303 valve and does not compromise the containment isolation signal.
Item 5. 's identified before, the containment isolation setpoint on high containment pressure is 5 psig.
Calculations are in progress confirming that the trip setpoint represents .the minimum value compatible with normal operating conditions.
Exhibit 3G-ll, continuing with Item XX.E.4.2.
Both the power access purge and the refueling purge do 10 isolate on high containment purge radioactivity as provided by the CPIAS logic.
12 Exhibit 3G-12, proceeding with Xtem IX.F.1,,
Additional Accident, Monitoring Instrumentation. Monitoring 14 instrumentation is in compliance, as discussed earlier in 15 post-accident monitoring. Requirements continue on Exhibit 3G-13. There P is a clarification on a subsequent letter 17 sent on October 30, 1979, on the containment radiation 18 levels. We are in compliance with that letter.
Exhibit 3G-14, continuing the post,-accident 20 monitoring. Again, in compliance.
21 Exhibit 3G-15 continues with post.-accident 22 monitoring related to containment water level. Xn compliance 23 Exhibit 3G-16, continuing with post-accident 24 monitoring as related to the 'containment hydrogen concentra-25 tion monitors. We are in compliance. Continuous indication GRUMLEY REPORTERS Phoenix, Arizona
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304 of containment atmosphere hydrogen concentration is available in the control room within 30 minutes after the initiation 3 of safety injection.
Exhibit 3G-17, Item II.F.l, Instrumentation for Detection of Inadequate Core Cooling.- PVNGS will comply.
Control room indicators of the following parameters will be provided as indication of ICC: core exit thermocouples, subcooled margin monitor, and heated junction thermocouples.
Exhibit 3G-18, Item II.G.1, Power- Supplies for Pressurizer Relief Valves, Block Valves, and Level Indicators PVNGS is in compliance. This is continued on Exhibit. 3G-19.
12 Exhibit 3G-20, Item III.A.1.2, Upgrade Emergency 13 Support Facilities. PVNGS will comply. Display of data 14 at the TSC and EOF will be in accordance with NUREG-0696.
15 Exhibit 3G-21 continues with the requirements 16 for the operational support center and the emergency operating facility.
18 MR. ALLEN: Questions from the Board? Fred.
HR. HARSH: On Exhibit. 3G-9 regarding the containment 20 isolation system, could you briefly describe the extent of 21 redundancy in the measurement figures there for containment 22 pressure and pressurizer pressure?
23 MRS. MORETON: Containment pressure is measured by fOur independent sensors as required by the NSSS ESFAS.
25 Pressurizer pressure is also measured by four independent GRUMLEY REPORTERS Phoenix, Arizona
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305 sensors as required by the NSSS ESFAS.
MR. MARSH: Actuation is then the two-out-of-four logic?
MRS. MORETON: Yes.
MR. ALIEN: Further questions?
MR. ROGERS: A clarification of Exhibit 36-18. This discusses power operated relief valves and block valves. I think the record should show that we do not have either PORV's or block valves.
10 MR. BINGHAM:. We will make that correction.
MR. STERLING: On Exhibit 3G-S, I just wanted to 12 confirm that the 150 kw capacity from either group is .
13 sufficient. for natural t circulation.
14 MR. BINGHAM: I'm sorry, would you repeat the question 15 again?
16 MR. STERLING: The 150 kw capacity from either of the 17 three element groups is sufficient, there is 1'00% redundancy?
18 MR. BARNOSKI: I can only offer a speculation. I 19 think that's correct. I'm not .positive.
20 MR. ROSENTHAL: The pressurizer heaters are not 21 grade, we have merely asked that they put on a 'afety 22 safety grade bus, so I think that 'one must be able to show 23 that one can operate the reactor witho'ut the heaters, 24 including in a natural circulation mode. The reason for 25 adding the 'heaters was that it would be easier for the GRUMLEY REPORTERS Phoenix, Arizona
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306 operator to maintain pressure. Otherwise, the pressure would be constantly decreasing. I think it, should be 3 confirmed that you shouldn'0 need those heaters in order to be in natural circulation. The reason for putting the heaters on .the emergency bus is to provide pressure, control to 'help the operator. That is an important distinction to your design.
MR. STERLING: It is an alternative method from the required method. My question is if we are going to do that 10 and you needed to pick the heaters necessary to fulfill that requirement or that need for help, then it should be 100%-
12 redundant between Train A and Train B.
13 MR. ROSENTHAL: You have to look at your post 14 accident emergency procedures, decide whether those emergency 15 procedures -- you will have to tell me the answer to this 16 instruct the. operator to maintain the plant at pressure or 17 how to depressurize: the plant and what is the'mergency 18 procedure planned rate of depressurization. Having studied 19 the emergency procedures to decide what you are going to do, 20 you should then link it to the heater capacity. I think 21 that that .is the order that things should be done. Now, tell me, t
22 can you do you need'those? Do your emergency 23 procedures require or instruct. the operator to use those?
24 MR. STERLING: The emergency procedures are not 25 written yet. The guidelines on which 'they will be based are GRUMLEY REPORTERS Phoenix, Arizona
307 being formulated by the CE Owners Gxoup activity. CE I would say would provide that interface as to whether to use heaters in that pr'ocedure, what size they would be, or what size you would need, so I assume that is where you got, that figure.
MR. KEITH: This's the CE interface, Ed, that we provide power'to these heater groups, so we are meeting the CE interface requirements.
MR. STERLING: The final procedures, however I have 10 not see the guideline for that, so I don't know how the Owners Group guideline intends to operate 'natural circulation 12 MR. ROSENTHAL: It will be unclear to me two months 13 from now reading the transcript. if the heaters were deemed 14 to be require'd for safety or were considered to be of 15 convenience to the operator such that. he could keep the plant 16 in pressure in a mode that he was used to operating in, and 17 that distinction is now important to resolve ih my mind.
18 MR. STERLING: My understanding of it is they are a 19 convenience. What I can'5 tell you is where that convenience 20 shows in those guidelines. I have not seen .the 'guidelines.
21 Maybe Mike would be able to -- you haven't seen them yet?
22 MR. BARNOSKI: No.
MR. ALLEN: Further questions from the Board' I would like to have an open item. Maybe, Mike, 25 you could call back during lunch and ask your people back GRUMLEY REPORTERS Phoenix, Arizona
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308 there whether they are required or not. required.
MR. BARNOSKX: What I will do is try to find out what conclusions the Owners Group has come up with. As far as I know, there has been no work -- .I am not sure that there is no. work to directly correlate that with this particular CE plant,. but I'l find out as much as I can.
MR. ALLEN: Further questions? Jack?
MR. ROSENTHAL: Yes, please. We had a bulletin, circular, or notice on errors in steam generator level or 10 pressure indication. due to a high-energy line break perhaps you can refresh me due to a high-energy line 12 break inside of containment .. Combustion ' design results 13 in an error in the indicated reading of the steam generator 14 level or pressure and provides also a correction table to be used by the operator. From an opexation's standpoint, does that hardware meet the intent of the guidance that we have attempted to, put out post-TMI providing the op'erator with reliable information .and not encumbering the operator need-lessly?
20 MRS. MORETON: Excuse me, Jack, for clarification, we need some assistance in understanding what CE has committed to, what the errors CE repoxts ther'e will be, and then would .you please restate your question?
24 MR. BESSETTE: May I add some clarification *to this?
25 Bulletin 79-21 addressed this concern. In the IDR we. had pn GRUMLEY REPORTERS Phoenix, Arizona
J 309 Chapter 7 for CESSAR, we did address this and we did take an open item on it, which was subsequently closed. It was Item No. 48. We did discuss an analysis that was performed that showed that the error was in the conservative direction.
I am not. aware of any remaining concern on that.
MR. KONDIC: ,To brief and summarize, the whole thing is because of the reference leg density depending on the containment temperature, there is this error which i' tabulated, so what. Jack is now pointing out is the operator 10 has to perform the following steps: to look into the history of the recent containment temperature, to" choose the highest, 12 to look into the corrections, and then to correct the 13 setpoint fox that error which was tabulated. We know about the -error, maximum 24%. All these tests he has to undertake 15 in order to properly correct the setpoint. This is a 16 cumbersome operation.
17 MR. BESSETTE: The action the operator 'takes is not 18 a setpoint adjustment per se. He would take manual control 19 of his emergency feed. The analysis that was done showed 20 that. if left in automatic that the system would sti'll 21 function.to maintain the generator at the same level. Should the operator take manual control, the correlation that, he 23 would be looking at for a corrective type table would be for 24 his knowledge of actual level versus indicated level, and 25 he then refers to containment temperature 'to obtain the GRUMLEY REPORTERS Phoenix, Arizona
3l0 reference to the correction.
MR. KONDIC: I see no contradiction. There is a correction necessary to be undertaken. That is what we are both pointing out.
MR. BESSETTE: Yes.
MR. BINGHAM: What is the question for this group, John?
MR. ALLEN: I guess what I understood is is there additional information that needs to be given to APS from 10 Combustion with a correction table?
MR. ROSENTHAL: Given the hardware design that was 12 previously reviewed, given that hardware plus a correction 13 table which will be provided to the operator, recognizing 14 that the operator is burdened by an additional task in the 15 course of running his auxiliary feedwater system in a manual 16 mode, my "question is not a hardware-related question, but 17 rather an operator-related question, and that 'is do you
'I 18 consider this a sufficient, reliable, correct indication to 19 the operator within the context of the guidance that the 20 NRC has attempted to provide post-TMI about providing the 21 operator with reliable information and not encumbering hi' 22 with unnecessary tasks.
23 MR. KEITH: I just heard Combustion Engineering say 24 that the operator could leave the auxiliary feedwater system 25 in automatic'nd still maintain th'e plant 'in a safe condition GRUMLEY REPORTERS Phoenix, Arizona
I MR. ROSENTHAL: That's true.
MR. KEXTH: I think the operating procedures would reflect that and you would not have the operator until he 4 had completed other priority items worry about going into manual and .looking at his correction table.
MR. ROSENTHAL: But it is planned that the operator will in fact 'take manual control of- that system--
MR. KEXTH: At some time.
MR. ROSENTHAL: at some time and he will go into a modulating mode rather than a bang-bang control scheme.
MR. KEXTH: Yes.
12 MR. ROSENTHAL: So my question is not a hardware one, 13 but a human one. Is that scheme, including the manual use 14 of correction tables, consistent with today's thoughts about what we expect of operators?
MR. ALLEN: I think no one is ready to make that decision until we have seen the operating proc'edures and 18 somebody has made a judgment. Maybe that should go into the 19 later part of the human factors study or something like that.
20 I don't think we could sit here today and say yes or no. I 21 don't think anybody here has read the procedures and could
-22 truly say.
23 MR. BINGHAM: If I understand, John,,where Jack is 24 heading is should we be looking at the 'design in order to preclude this from being a consideration. Xs that the point GRUMLEY REPORTERS Phoenix, Arizona
312 you are getting at?
MR. ROSENTHAL: Yes. From an instrumentation stand-point, one could choose to take the CE scope of supply and then the owner could modify, that information, for instance, l
5 by using a simple microprocessor to provide a direct indication to the operator for which he wouldn't have to use the correction tables, and in that context, it would then become a classical instrumentation control issue.
MR. ALLEN: Through automatic compensation.
10 MR. ROSENTHAL: Yes. I am not suggesting that that, is necessary. I am asking p /
if you have thought it out and what are your views on whether that should be necessary or not.
13 MR. MARSH: Did I understand Combustion Engineering to 14 say that if this correction is not made that the errors are in a conservative direction and would not interfere wi,th ~ .
16 the function of the steam generators? Did I understand that 17 correctly?
18 MR. BESSETTE: That's correct.
MR. MARSH: So from a plant operations standpoint, if the operator does not make this correction at 'all, is he 21 in any way endangering the function manually or automatically 22 and, i,n fact, couldn't this correction be made or not made and not affect the proper function of the" steam generators?
MR. ROSENTHAL: The operator will cho'ose .to ta3ce 25 manual control of the system, adjust his emer'gency feedwater GRUMLEY REPORTERS Phoenix, Arizona
0' 313 V
flow rate, and monitor, the steam generator level such that he has a controlled cooldown rate in that steam generator.
It is not a question of what goes on the first three minutes, but what goes on over the next two hours, and I don'0 know if an, automatic system'is necessary or if the procedures are okay or "if he could ignore it throughout the evolution.
MR. ALLEN: Having heard what. CE, said about being conservative and it can be done without this automatic compensation> it appears to me, maybe someone else would care 10 to comment on it, that this might just be a betterment type of an item that somebody would want to look into. It 12 doesn't seem like a safety item.
13 MR. BINGHAM: The thought that crossed my mind is if 14 it is in the conservative direction, why is CE providing a table for the operator?
16 MR. BESSETTE: My response to that would be in 17 response,to Bulletin 79-2l.
18 MR. KONDIC: We are entering into the philosophy of the setpoint., There is a maximum error of 24%. We do know 20 that a Delta P measurement has seven or more real causes 21 of error, so we may be adding to that maximum 24% or red'ucing 22 it. Now the question is sha'll we stick to the established 23 setpoint, or just let it float for plus or minus. That is 24 why they do have the correction.
25 MR. ALLEN: Let us take it. as an @pen item and get GRUMLEY REPORTERS Phoenix, Arizona
C 314 with Combustion Engineering and see if there is any guideline or procedures written yet and take a look at it with the Operating Department and then come to some conclusion. I don'0 think we can resolve it here today.
MR..BINGHAM: I guess my concern, John, is that you have set a time frame at the beginning of the session in order to respond and some of these issues are going to fall outside that. time frame.
MR. ALLEN: That has been the case in the past.
10 MR. BINGHAM:. Certainly this one I think falls in that category. If it, is acceptable to do that or to have a 12 preliminary response or interim response, that would be 13 satisfactory. The reason I was being hesitant is I am not sure that we could gather, the facts to close or resolve this 15 particular issue that was brought up. Further, it sounds 16 like the NRC representatives aren'0 totally enamored with 17 the results of the CE analysis. Xs that correct?
r 18 MR. ROSENTHAL: I think. we understand the Combustion C
19 system that is being provided and the analysis is fine and 20 the hardware does what it is stated to perfo'rm. I would like 21 to link that aspect with what, is going to be 'done at the 22 plant.'e have considered sugges'ting or perhaps automatic compensation rather tha'n manual cpmpensa-
-even'equiring 23 24 tion,,and I was asking for your tho'ughts on the matter.
25 MISS KERRIGAN: Let me make one statement. I don 't GRUMLEY REPORTERS Phoenix, Arizona
315 know if it has'o be an open item for the Board or not and the NRC would not be that concerned about the schedule that 3 you are trying to "keep for the Board. We would like the question addressed either within the Board or outside the Board. The NRC will pursue it.. You can handle it in what-ever way you want or on whatever schedule you want, but we will be looking into it, MR. ALLEN: Take it as an open item, Bill, Any further questions? Comments?
10 How long is the next section'p MR. BINGHAM: I think maybe it would be appropriate 12 to break at this time, John.
13 MR. ALLEN: Why don'0 we break for lunch. now. Try 14 to be back here in one hour.
15 (Thereupon the meeting was at recess.)
17 June 3:8, 1981 1:05 p.m.
18 19 MR, ALLEN: Dennis Keith indicated he'. gOt a few 20 answers to some open items,'e can just as well address 21 those now and close them out, 22 Go ahead, Dennis."
23 MR. KEITH: A concern was raised on the fuel'uj,lding 24 essential ventilation actuation signal,,and we discussed 25 this somewhat alrea'dy yesterday, that 'if we 'took one channel GRUMLEY REPORTERS Phoenix, Arizona
e
316 out of service, should we take special precautions because the other channel is out. of service. The thing we have done since then, we looked at the SAR 'and the analysis in there does consider a fuel handling accident with no ventilation I and the dose theory is less than 10$ of Part 100, just to provide you what the analysis showed. We do feel that this is sufficient such that it would not be necessary to Tech.
Spec. if you had a channel out of service to operate the system.
10 MR. ALLEN: Any comment on that?
MISS KERRIGANz Thank you for the position.
12 MR. KEITH: A concern was raised this morning on spurious action of some of our BOP ESF system or ESFAS 14 system, and specifically the concern raised was and whether a failure of that was a concern.
the'equencer Then the question was also raised on whether we did a fault tree analysis. We have looked at the sequencer and possible 18 failure modes in great detail. We have not done any formal 19 fault tree analysis, but,. as I said, we have looked at it a great deal. I was reminded that at the'C IDR,, a question was'raised as to what if we lost a bus 'and the sequencers 22 actuated during power operation, and we responded to that tha 23 some equipment would come on, but tha't i.t would not adversely 24 affect reactor operation. We feel that that previous respons real.ly addresses the concern on spurious act'ion. There are GRUMLEY REPORTERS Phoenix, Arizona
3l7 a number of different things you could postulate, but we feel, particularly because none of the valves operate on the sequencer, that we aren'0 going to do anything which is going to cause an upset as far as the reactor operation.
The other item we have to address is .the question raised on what Failure Modes and Effects Analyses were
\
conducted for support systems. The support systems to the CE ESF systems are covered in Chapter 9 and l0 of the FSAR.
i The analyses performed there really just give one item saying 10 electrical failure,. and, because'f the redundancy that we have in those'systems, it shows that. we are all right. We.
do, of course, design all the instrumentation for those support systems with redundancy and then everything is routed 14 to meet Reg. Guide 1.75 so that the cabling and all is adequately separated. We feel this is adequate as far as looking at the support systems, 17 MR, ALLEN: Any comments on that?
18 MR. KEITH: All right, Then we will get into 19 Section 4.
20 MR. ALLEN: There is, I believe, an open item that we 21 had asked Combustion Engineering to, look into over lunch.
and I think Mike has some information on that.
23 MR. BARNOSKI: With regard to the pressurizer heaters, 24 in the CESSAR PSAR, they" wer'e shown as being not required fox safety.. That was when we were looking at our normal Cl GRUMLEY REPORTERS Phoenix, Arizona
318 cold shutdown scenario without natural circulation, so as of that time, they were not required for safety. However, CESSAR P did have an interface requirement for 150 kilowatts per train to be established on each diesel generator. That was based on a conservative estimate of the ambient heat, losses from the pressurizer. That was the basis for the l50. Since TMI came along and.the concern about natural circulation cooldown, we have done analyses to show that pressurizer heaters are not required to do that. They 10 certainly though are desirable, .and the emergency guidelines that are being put out shortly by the CE Owners Group will 12 note that fact. They are very desirable to use for control 13 in natural circulation just as in the normal scenario of safe shutdown to cold condition, 15 MR. KEITH: Just a point of clarification. The k
response I gave on the fuel building essential ventilation 17 actuation signal and how we are not concerned 'about having 18 one channel out that any parti'cular precaution need be taken, 19 that really addresses, I believe, an open item which was 20 concerned with whit a short t'ime'nterval meant as far as 21 how long you have a ch'onnel out of operation. We don' 22 really feel there is any additional analysi,s that needs tg 23 be done as far as that for .the. systems we are talking about,
. MR, ALLEN: You are saying then that. that syst'm 25 function or time interval out, the 'same logi,c could be 'used GRUMLEY REPORTERS Phoenix, Arizona
,e 319 for the rest of the systems?
MR. KEITH: Yes.
MR. ALLEN: I guess since they have different function 4 I have a little trouble correlating or buying that. Who raised that question?
MR. HELMAN: I did. I would have that same problem, especially like MSIS as 'compared to fuel building ventilation MR. KEITH: MSIS is not part of this.
MR. HELMAN: That's true, but still, if you want to look at it on a function-by-function basis, I would think rather than trying to draw the corollary that says hey, so what? If the thing is out, we don'0 care, because we. are still less than Part 100 releases on the fuel building.
14 MR. KEITH: Well, if we look at. the others, the control room essential filtration actuation signal, all that equipment is also actuated by an SIAS and that is really when you have that concern as fax as needing to have that 18 system. What the CREPAS does -for 'you is Chere is a radiation monitor on the control room air intake, but; if we have an PI 19 SIAS, that is all going to start automatically anyho'w- without 21 that radiation monitor working, so that one is taken'are of.
22 If you want to go through. them point: by point--
23 MR. ALLEN: Most of the'm are Ventilation-related 24 systems?
MR. KEITH: Yes.
GRUMLEY REPORTERS Phoenix, Arizona
320 MR. ALLEN: Any comments from anyone else?
MR. MINNICKS: I guess we will probably see something in the balance of plant ESFAS Tech. Specs. relative to time out of service. We have a rather undefinitive statement in your presentation here of short time. We don'0 know what that is. We don't know what that assumption is, whether a short time to you is two hours or whether a short time is two days.
MR. KEITH: I short time would be two hours. We are 10 just talking about .the time to perform routine maintenance on that channel.
12 MR. HELMAN: But a total integrated time over a year 13 testing the ESFAS on a weekly basis tends to add a fair amoun of time on that particular channel out of service, and then 15 based on the MTTR of that particular system, you would tend 16 to wonder if you would be exceeding a possible Tech. gpec.
l7 limit for a channel out of service. I think t'.hat is your 18 concern, isn't it, Jim?
19 MR. MINNICKS: That, and that becomes a maintainabilit 20 criterion then, because if in fact we go past this Tech.
21 Spec. that we are talking about whichis presumed to be 22 two hours, if we go past tha't,'.then I would think the action 23 requirement would be to =trip possibly the other remains.ng channel, and now we have actuated a safety system when x'cally theie is no need to do that, and the whole process goes back GRUMLEY REPORTERS Phoenix, Arizona
321 to what the definition of short time interval is. The system is designed around that one-out-of-two versus two-out-of-four. I think 'that short time is a very critical item.
MR. KEITH: Right now there is a Tech. Spec. on if you have a,train out of service, for example, one of the essential filtration trains out of service, then you do trip the other one and operate it. J MR. MINNICKS: Then this time limit no doubt will be imposed of two hours, let's say, so I would then assume 10 that after this two, hours, the action statement would then require that other channel to be tripped, so now we have 12 both channels of the safety system in operation, which is 13 certainly safe, but we are taxing that safety system, so 14 to speak.'R.
15 KEITH: Well, you would only operate one train.
If you had a Tech. Spec. on a channel being out of serVice, 17 the most the action requirements would have you do would be 18 to operate one train of the system.
19 MR. MINNICKS: I thought your exception to the single 20 failure criterion was based'n that short time 'that .the 21 other channel could be out of service for maintenance.
22 MR. KEITH: I am not understanding your concern, I 23 guess.
MR. MINNICKS: In the'ingle failuxe criterion, you 25 drew an exception to that and the clarification issue was GRUMLEY REPORTERS Phoenix, Arizona
f 322 that the only time that would become a problem was if you had a channel out. for maintenance, and if that were the
/
case, you assume that to be, from what I hear now, two hours.
MR. KEITH: That two hours is just a ballpark. There has been no. analysis to look at the integrated, time over a year or anything else to try and define probability, of you having a failure in the other channel and that, giving you a problem. Like I said, with,the system that we have talked about, the fuel building ventilation system, there is no 10 problem there based. on the accident analyses. The control room essential filtration, there is no problem there because 12 you have the SIAS which could actuate that, which is where 13 you have the most concern for that system operating. The 14 control room ventilation isolation actuation signal gets 15 signals from the chlorine monitors and we have talked about 16 how we really aren't expecting much. there, since the only I
17 possibility of a chlorine accident is an offsite occurrence.
e 18 Containment purge, we have the containment .isolation actuatio 19 signal as a backup there. So I feel we are adequately backed 20 up, 21 I don't know where you want to go from here, John.
22 MR. ALLEN: Jim, do you believe 'that you need sage 23 further justification for it or do you want to let't xide with the Tech. Specs. to. set the 'limit on outa'ge t'ime?
25 MR. MINNICKS: What I would like to do now. is I will GRUMLEY REPORTERS Phoenix, Arizona
t I
323 take a look at what is written in the Tech. Specs. at this time. I think Dennis made a valid point before saying that if one channel was out of service for maintenance, the 4 statement in the Tech. Spec. now was to trip the other channel. Is that correct?
MR. KEITH: I want. to clarify. That is if the other train is out, of service. I mean we'e got the two channels, and if one of the two channels actuates, it actuates both trains of equipment,. The only Tech. Spec. we have right now 10 is if one train of equipment is out of servi,ce, then you must actuate the other train. We don't have anything 12 related to the channels in the Tech.. Specs. right now.
13 MR. MINNICKS: Why don'. you go ahead'? I want to 14 take a look.
15 MR. ALLEN: Let's proceed. We will get back. to this 16 in a minute.
17 MR. BINGHAM: Letls moVe on then tO Item No. 4 on 18 the agenda, Additional Items of Concern.
MRS. MORETON: NRC sent BPS a letter on April 16, 1981 20 identifying four ICSB items of concern. Xn Section 4,. we 21 have repeated these concernsand provided whexe we have .
b 22 provided the design feature addxessing these concex'ns.
23 Exhibit 4-1, ICSB .Concern 222.01, Loss of 24 Non-Class IE Instrumentation and Contxol Power Syst'm Bus 25 During Power Operation as requi;red by IE Bulletin 79-27,
~ GRUMLEY REPORTERS Phoenix, Arizona 0
O.
324 The concern is that the IE Bulletin be addressed and covered in the FSAR. XE Bulletin 79-27 was covered as an open item on the AC Review Board. The information is provided in Section 5. If the Board wishes, we can go through that.
information. It is available. The response will be included in an FSAR amendment., To answer the specific concern brought up earlier about annunciation, alarms are provided and you will see the list of alarms in Section 5.
Exhibit 4-2 continues with the ICSB Concern 222.01.,
10 MR. ROSENTHAL: Will you consider discussing each one of these one at a time?
12 MR. BINGHAM: Yes, we will, 13 MR. ALLEN: Would you like to discuss, them after they la finish?
15 MR. BINGHAM: May I make a comment, John> I forgot.
to mention that Dennis had an urgent 'call. What we ha'd 17 planned to do was to have 'Mary go through. the material and 18 Dennis and I were, going to come back and review the issues'9 and open the discussion and handle it in that fashion. I'm 20 sorry I forgot to mention that at the'eginning.
21 MRS. MORETON: Continuing on with Zxhi'bit 4-3, 22 ICSB Concern 222.02, Engineered Safety Features Reset, 23 Controls addressed in IE Bulletin 80-06. Xf safety eguipmen does not remain in its emergency mode upon reset of an 25 Engineered Safeguards Actuation Signal, system modification, GRUMLEY REPORTERS Phoenix, Arizona
H 0
I 0
II
325 design change or other protective action of the affected equipment is not compromised once the associated actuation signal is reset. 'This issue was addressed in IE Bulletin 80-06. For facilities with operating licenses as of March 13, 1980, IE Bulletin 80-06 required that systems reviews be conducted by the licensees to determine which, if any, safety functions might be unavailable after reset and what changes could be implemented to correct the problem. For facilities with a construction permit including OL applicants Bulletin 80-06 was issued for information only.
Continuing on Exhibit 4-4, the NRC staff has determined that all CP holders, 'as a part of the OL review process, are to be requested to address this issue.
14 Accordingly, you are requested to take the actions called for in Bulletin 80-06 Actions 1 through 4 under "Actions to 16 be Taken by Licensees." Within the response time called for 17 in the attached transmittal letter, complete the review 18 . verifications and descriptions of corrective actions taken or planned as stated in Action 1 through 3 and submit the report called for in Actions Item 4. The report, should be 21 submitted to the NRC Office of Nuclear Regulation as a 22 licensing submittal in the form of an FASR amendment.
23 Exhibit, 4-5 through the next few exhibits provide 24 a detailed response to the Concern. The Engineered Safety 25 Features Actuation Signals incorporated in the PVNGS design GRUMLEY REPORTERS Phoenix, Arizona
IE 326 include, as we have discussed earlier, the NSSS ESFAS including the containment isolation actuation signal, the containment spray 'actuation signal, the main steam isolation signal, the safety injection isolation signal, the recircula-5 tion actuation signal, and the auxiliary feedwater actuation signals. The BOP ESFAS signals include the fuel building essential ventilation actuation signal, the containment purge isolation actuation signal, the control room ventilation isolation actuation signal, and the control. room essential 10 filtration actuation signal. On Exhibit 4-6, reset switches are located at the plant protection syst: em cabinet, ESFAS auxiliary relay cabinet supplied by CE, and at the BOP ESFAS cabinet. PVNGS equipment which may change position from the 14 safety or emergency state on reset of an ESF actuation signal is identified in Table 1. These devices can be categorized as follows (Exhibit 4-7): Certain actuated devices require 17 a maintained, ESF signal through completion of 'their safety 18 function. If an ESF actuation signal is reset prior to 19 completion of-valve stroke or completion of ESF load sequenc-20 ing, the valve, as an example, would stop in travel or the 21 sequencer, as another example, would not complete sequencing.
Since completion of these actions takes no more than 60 23 seconds, ESF actuation signal reset is not considered. ESF 24 actuation followed by clearing of the initiating signals with the requirement of manual reset at the appropriate cabinet GRUMLEY REPORTERS Phoenix, Arizona
e, S
0
327
'll occurring within a 'short time period on the order of one, minute is not credible under true accident conditions.
No modification to these equipment control circuits is required.
Another category is shown on Exhibit, 4-8. A safety. injection actuation signal is employed in some instanc to trip non-ESP equipment off the IE buses. On reset of 8 SIAS, this equipment will return to an automatic mode unless the control switch has been put into the pull-to-lock 10 position. On return to the automatic mode, the. equipment may start due to process demand. Since SIAS reset may only be 12 accomplished after clearing of both initiating process 13 conditions, low pressurizer pressure or high containment 14 pressure, return of this equipment to automatic control does 15 not defeat required ESF system functions. No modification 16 is required to these equipment control circuits. However, 17 administrative procedures should address placi'ng the control 18 switches in the pull-to-lock position to avoid bus overload 19 on SIAS reset.
20 Continuing on with another category on. Exhibit 4-9, 21 certain actuated devices have different safety modes in 22 response to different ESF actuation signals. In the eveat 23 that ESP actuation signals requiring both safety modes occur, 24 one safety mode by design will have priority. We address 25 of these I'ome on the BOP ESPAS, and examples are the fuel GRUMLEY REPORTERS Phoenix, Arizona
ll 0
328 building essential ventilation system where we have SIAS and FBEVAS actuating the, equipment. SIAS does have priority.
On reset. of that particular ESF actuation signal, the actuated device will change position to the safety mode required by. the remaining ESF actuation signal. This means of control does not defeat required ESP system function and no modification is required to these equipment control circuits.
The fourth category includes the APAS 1 and AFAS 2 10 signals to the auxiliary feedwater valve. These cycles are designed to cycle based on steam generator level. This automatic resetting of the AFAS 1 and APAS 2 does not,affect the AFAS 1 and AFAS 2 signals to other actuated equipment.
The valve cycling represents the desired ESF system and no modification is required.
The tables provided on Exhibits 4-10, 4-11, and, 17 4-12 provide the specifics. No modification i:s deemed to 18 be required to meet the IE Bulletin. We feel we are in 19 compliance with the intent of the bulletin.
Continuing on to ICSB Concern 222.03 on Exhibit.
21 4-13 concerning Qualification of Control Systems, this 22 is identified in IE Information Notice 79-22. Operating 23 reactor licensees were informed by IE Information Notice 79-22 issued September 19, 1979, that certain nonsafety 25 grade or control equipment, if subjected to the adverse GRUMLEY REPORTERS Phoenix, Arizona
329 environment of a high-energy line break, could impact the safety analyses and the adequacy of the protection functions performed by the safety grade equipment. A copy of IF.
Information Notice 79-. 22 was enclosed and reprinted copies of an August 20, 1979, Westinghouse letter and a September 10,.
1979, Public Service Electric and Gas Company letter which address this matter were provided. Operating reactor licensees conducted reviews to determine whether such problems could exist at operating facilities.
10 Continuing on with the Concern on Exhibit 4-14, we are concerned that a similar potential may exist at light water facilities now under construction. You are, 13 therefore, requested to perform a review to determine what, 14 if any, design changes or operator actions would be necessary to assure that high-energy line breaks will not cause system failures. to complicate the event beyond your FSAR analysis.
Provide the results of your reviews including all identified problems'nd the manner in which they are resolved.
The specific scenarios discussed in the referenced Westinghouse letter are to be considered as examples of the kind of interactions which might occur. Your review should include those scenarios where applicable, but should not necessarily be limited to them. Applicants with other light 24 water reactor designs should consider analogous interactions V
25 as relevant to their designs.
ORUMLEY REPORTERS Phoenix, Arizona
0 330 Concern 222.03, as identified on the slide, is under review. A little bit more discussion will be provided on that in a few minutes.
Exhibit 4-15, ICSB Concern 222.04 on Control System Failures. The analyses reported in Chapter 15 of the FSAR are intended to demonstrate the adequacy of safety systems in mitigating anticipated operational occurrences and accidents. Based on the conservative assumptions made in defining these design bases events and the detailed review 10 of the analyses by the staff, it is, likely that they adequately bound the consequences of single control system failures. To provide assurance that the design basis event 1
12 i
13 analyses adequately bound other more fundamental credible 14 . failures, you are requested to provide the following 15 information: Identify those control systems whose failure 16 or malfunction could seriously impact plant safety.
17 Continuing on Exhibit 4-16, indicate which, if any, 18 of the control systems identified receive power from common 19 power sources.'he power sources considered should include 20 all power sources whose failure or malfunction could lead to 21 failure or malfunction of more than one control system and 22 should extend to the effects of cascading power losses due to 23 the failure of higher level distribution panels and load 24 centers.
25 Indicate which, if any, of the control systems GRUMLEY AEPORTEAS Phoenix, Arizona
~I 331 identified receive input signals from common sensors. The sensors considered should include, but should not necessarily be limited to, common hydraulic headers or impulse lines 4 feeding pressure, temperature, level or other signals to two or more control systems.
Continuing on Exhibit 4-l7, provide justification that any simultaneous malfunctions of the control systems identified resulting from failures or malfunctions of the applicable common power source or sensor are bounded by the 10 analyses in Chapter l5 and would not require action or response beyond the capability of operators or safety systems.
12 This item is also in review.
13 MR. B INGHAM: Thank you, Mary.
14 I thank what we will do now I John is go through them one by one. We will put them back up and entertain questions and add some response on those items that are in review. I will ask the Board if there are any questions on this particular one.
19 MR. ALLEN: Any questions from the Board?
20 That was answered 'as part of the AC System Review Board.
22 MR. BINGHAM: So it is satisfactory. All right.
Let's go to the next one.
24 MR. PHELPS:
k I have one general question on your 25 approach to this issu e. Did you go through a systematic GRUMLEY REPORTERS Phoenix, Arizona
k 332 evaluation of all the possible interactions of non-IE equipment with the IE equipment, in particular for those 1
systems that have dual functions, for example, charging 4 pumps or pressurizer heater elementary controls, considering all possible rpodes of operation, loss of offsite power, manual or automatic?
MR. BINGHAM: When you say all possible modes, you mean all modes applicable to this issue?
MR. PHELPS:
V All possible normal operating modes.
10 MRS. MORETON: When IE Bulletin 79-27 was addressed, the review consisted of ensuring that adequate information was available to the operator to allow him to perform a safe shutdown and that information was available to the 14 , operator to allow him to know he had had a loss of a non-IE 15 instrument. bus. The level of detail you are talking about on interactions was not included in that, review.
17 MR. PHELPS: Was it included in one of your reviews 18 as part of'he normal design?
MR. BINGHAM: I don'. believe it was.
20 MR. PHELPS: Do you intend to?
21 MR. BINGHAM: I suspect with the new issues that are 22 coming up that we will in some manner look at those, yes.
23 MR. PHELPS: "
I recommend that you ensure that you do 24 do it, because in response to this issue when it first came up on San Onofre, we did that type of review and we discovered GRUMLEY REPORTERS Phoenix, Arizona
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333 a few areas where we had to make some design changes.
MR. BINGHAM: Fine. Thank you.
MR. ALLEN: Additional comments?
MR. ROSENTHAL: Yes. The orientation of the review of 79-27 has been procedural and has focused on safe shutdown and you are addressing this issue. '
see also Exhibit 5.2, the response to Bulletin 79-27 seems hardware oriented. The question is has the loop been closed vis-a-vis emergency procedures?
10 MR. ALLEN: Over in the attachement, I believe it addresses that, Enclosure B, which is a letter to me from Operations indicating that emergency procedures would be 13 developed and used.
14 MR. ROSENTHAL: Thank you.
MR. BINGHAM: Shall we move to the next item?
16 MR. ALLEN: Jack, do you have any other comments on this?
18 MR. ROSENTHAL: No.
19 MR. BINGHAM: Questions, John?
20 MR. PHELPS: Are you restricting the questions to the page you have displayed there or do you just want questions in general on that response?
23 MR. BINGHAM: No, to the item.
24 MR. PHELPS: On Exhibit 4-8, the approach that you are using, namely, the safety injection actuation signal to GRUMLEY REPORTERS Phoenix, Arizona
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334 isolate non-IE equipment in the event that there is an emergency, you do that I think because you don't want to risk having unqualified equipment in some way degrade the power supplies that are operating the IE equipment. To have it automatically reclose when the signal clears I think is a violation of your criteria it seems to me unless you have a justification for it.
MRS. MORETON: Two things that, are important to consider are that the SIAS has to be manually reset, so procedures should be developed to caution the ope'rator before resetting that. Procedures would have to be developed'o 12 make sure that the bus is not overloaded when the SIAS is 13 reset. If those control switches are left throughout the 14 excursion of the SIAS in the automatic position, the examples 15 we are talking about are the CEDM fans, containment normal fans, and the normal chiller, which are four shutdown loads available on the ESF buses that are tripped on an SIAS.
18 MR. PHELPS: You have pressurizer meters, too.
19 Let me pursue this. You are talking about resetting the SIAS 20 at the system level before you can reconnect. Is that what the permissive is?
22 MRS. MORETON: Excuse me?
23 MR. PHELPS: You have to reset the SIAS at, the system 24 level in order to allow you to reconnect the non-IE loads.
25 MRS. MORETON: No, they can be overridden, like most GRUMLEY REPORTERS Phoenix, Arizona
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335 loads can. SIAS can be overridden and the loads can be connected to the ESF bus.
MR. PHELPS: I guess what I am concerned about. is when I read this paragraph, it appears that when you clear SIAS, whether it. is a manual reset or what, the non-IE loads automatically get reloaded back on the IE buses.
MRS. MORETON: If there is an automatic demand signal, they may in fact get reloaded on the ESF bus.
MR. PHELPS: It seems to me like that, is an undesirable design. You should always want to manually load them back on.
12 MR. BINGHAM: Are you looking for a response of why this is under review?
14 MR. PHELPS: I haven't heard a justification yet why it is okay to automatically load them back on.
MR. BINGHAM: Ralph, we are not exactly sure what part of the criteria you believe is being violated.
18 MR. PHELPS: Let me give you a scenario that I can picture. You enter into some type of event that initates a safety injection actuation signal and you shed your non-IE loads and you shed them for the purpose of maintaining the qualified electrical system to support your safety actions.
Right? That's why you'e got this feature. At some period 24 into the event when your control channels still may be operable, in conditions of harsh environment, they still might GRUMLEY REPORTERS Phoenix, Arizona
0 336 be operable, you decide that it is desirable to manually reset SIAS to allow you to bring the nonessential systems back into service, so when you do that, you automatically dump these unqualified loads back on the IE buses. It seems like you run the risk of degrading whatever actions you might have to take after that point in time.
MR. BINGHAM: If I hear what you are saying, it is they come back on automatically and they may overload the bus.
10 MR. PHELPS: Yes, or something may have happened inside containment to one of these unqualified systems so 12 that when you load it back on, it might propagate back into 13 the IE buses.
14 MRS. MORETON: There. is a very high probability that 15 the operator may have already started the equipment we are 16 talking about anyway, because the reason for making them 17 available to be put on the ESF bus is because there are 18 operational concerns to provide IE power to these devices.
19 MR. PHELPS: Yes, but what I am concerned about is 20 he providing that capability, and he's got. to have some 21 criteria before he elects to load them back on the IE system.
22 He's got to have made some assessment of whether that's okay 23 or not, and I associate that type of assessment with a manual 24 action, not an automatic action.
25 MR. KEITH: Presumably, before'he reset SIAS, which, he GRUMLEY REPORTERS Phoenix, Arizona
337 has to do manually, the situation, whatever it was that caused it, has been corrected.
MR. PHELPS: Well, are you saying there is never a case where he might want to reset SIAS without loading these loads back on the IE buses?
MR. ALLEN: I think, also, Dennis, if I understand Ralph correctly, let's say you'e got all these loads sitting there which need to applied on the bus and the concern is
'egrading the voltage on tha't bus down to a point where you 10 could have some of your other motors drop out. I don't know what it was he said yesterday. At 75 or some percent 12 voltage, your motors will drop out on you again.
13 MR. PHELPS: That is part of my concern.
14 MR. BINGHAM: John, I don'0 recall us having us a criterion that specifically says that is not allowed, but 16 let us take it as an item and give the justification why it 17 is the way it is.
18 MR. ALLEN: Maybe with the bus voltage and the extra 19 capacity you have on that bus, you can hit. them all back on 20 at once and it will'not degrade your voltage. Who knows.'R.
21 BINGHAM: That may be th0 case.
22 MR. ALLEN: If that is the case, it is not a big 23 problem.
24 MR. BINGHAM: We also have the case, as you know, 25 where we are putting the aux feedwater system on the other GRUMLEY REPORTERS Phoenix, Arizona
1 338 diesel, so let us take a look and see if we can provide the proper rationale.
MR. ALLEN: Further comments? Jack.
MR. ROSENTHAL: Yes. I would like to explore this just a little bit,more so that perhaps we can avoid rounds of questions. A follow-on to the question that was asked is we imagine that there were situations in which a valid SIAS had been generated, ESF equipment had worked as designed so that it was possible to reset SIAS, for instance, a 10 pressurizer pressure has come down, been restored, but you really are in an emergency situation if you have an event that, 12 the operator might want to reset SIAS on a system level.
13 Because he is concerned about other equipment, he wants to 14 realign the plant in a preplanned or non-preplanned manner, 15 and when he does that, he should be able to do that to a component level without having to worry about other equipment, 17 coming back on that he might not want.
18 MR. BINGHAM: Well, there is a corollary to that, and 19 that is, since this is equipment that possibly will need to 20 be on, he may forget to turn it on.
21 - MR. ROSENTHAL: Well, I think one has to decide whether 22 you need the containment normal cooling system, and if you 23 really need it there, then it should be an ESF system, and 24 if you don't need it, then you don'0 have to turn it back 25 on.
QRUMLEY REPORTERS Phoenix, Arizona
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339 MR. BINGHAM: The issue is whether you put it on the emergency bus or the normal bus, and if you really don' need it, for emergency, then I would suspect you would put it on the normal bus. That isn'0 the way things have worked out.
MR. ROSENTHAL: Let me give some further examples.
On the control room emergency ventilation system, where you have a real accident going on with a real radiation hazard, a safety injection actuation signal which eventually clears and the operator wants to clear on the system level because 10 he wants to perform some planned or unplanned task, should he have to worry that when he resets on the system level that 12 those dampers are going to change state and hope that the 13 control room CREFAS is working? Should he be burdened with.
14 ,. those things, or wouldn'0 it be better to have him reset 15 by component? We have seen other systems such as containment 16 hydrogen monitoring which was isolated and then automatically 17 reset, and we have approved those figures because it was felt 18 that the information gained was more important than the 19 potential risk that was run. I for one would like to see 20 a point-by-point engineering justification of each of the 21 items.
22 MR, BXNGHAM: I believe that is. what we offered to do, 23 Jack, as the open item. We said we would go back and take 24 a look at the advisability of leaving the system the way it 25 is or whether. there should be a modification, and we will do GRUMLEY REPORTERS Phoenix, Arizona
340 MR. ALLEN: Further comments?
I guess you can go to the next one, Bill.
MR. BINGHAM:, Are there no other questions?
5 MR. ALLEN: No.
MR. KEITH: As we mentioned earlier in talking about the separation criteria for the instrument lines, there are some portions of our high-energy line break review which are really just beginning, and this falls into that area. In fact, we are just beginning to develop a plan with Combustion Engineering. Obviously, this is a joint effort in this .
12 particular case, since the concern is that failures of some 13 non-IE control systems can affect the accident analysis and f'
14 hence can affect safety, so we will be working with them.
The first step of the process will- be to identify those control systems which are of concern, which is largely Combustion Engineering's scope, and then we, Bechtel, will be looking at those control systems to determine if any of the line breaks which have been postulated could take out those control systems. Then Combustion Engineering, since 21 most of the control systems of concern will be in their scope, 22 will be looking at possible failure modes of those control 23 systems and what that could do to them. From that, we will 24 determine whether we have to protect those control systems 25 or not. So that is how we conceive of the program going righ.
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341 now, and, as I said, we are just in the planning stage.
MR. ALLEN: Do you have any comments?
MR. BINGHAM: I think there is one item that has come to our concern, John, and I just wanted to bring it up for the Board's information, and that is that there is an August lith date on submittal of this information to NRC.
I suspect that, although I don't know, this letter has gone out to all of the near-term operating license applicants with the same date, and perhaps we can get some clarification on 10 that point, but I suspect that the timing will be such that it is going to have to be a plan of what is intended rather a 12 than all the details. Perhaps Janis or you can give us some 13 clarification on that point.
MISS KERRIGAN: Yes. It would be part of our licensing review and any items for which you have made commitments but have not completed the work would be left as an open item in the FSAR in the response to any outstand-ing items. Xt would then be NRC management's position as to whether the total number of open items is too large to proceed through, for example, a CRS or some other thing.
So it would be treated as an open item. You should give us as much information as possible to support the SER issuance 23 date, keep the number of open items to a minimum.
24 MR. BXNGHAM: There was one other clarification I believe J
I asked was whether this letter has gone out to all GRUMLEY REPORTERS Phoenix, Arizona
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near-term applicants.
MISS KERRIGAN: I believe it, has.
MR. BINGHAM: You believe it has?
MISS KERRIGAN: Yes.
MR. BINGHAM. With the same date.
MXSS KERRIGAN: With a licensing date. You received these concerns in a letter. You did not receive it as a bulletin. That letter was supposed to have been sent to all applicants containing these four concerns. I believe it 10 has been sent formally to all applicants.
MR. BINGHAM: And the question was the same response 12 date to all near-term applicants?
13 MISS KERRIGAN: lt was my understanding that the 14 letter went out, and the response date was geared to the SER 15 issuance date of the particular facility.
16 MR. BINGHAM: Thank you'.
17 For the Board's information, that is about where 18 we stand on the issue. We are just in the very pxeliminary 19 stages with the Combustion plan.
20 MR. ALLEN: Was there an additional item? Is this 21 the last one?
22 MR. KEITH: One more.
23 MR. BINGHAM: There is one more item: Were there any 24 more questions on this item?
25 Let's go to the last. item.,
GRUMLEY REPORTERS Phoenix,'Arizona
343 MR. KEITH: On the last item, we are in a similar stage as we are with the previous one, the concern here being common sensor lines plus common power supplies. Once again it will be a joint Combustion Engineering/Bechtel effort with Combustion Engineering once again identifying those control systems which could affect their-accident.
analyses and then Becthel looking at. the power supplies, sensor locations, although some of those are provided by CE. Then with those potential failures, .CE will be evaluating 10 how those affect their accident analyses and whether they are outside the bounds, and then, if we have to, make any 12 changes in order to take care of the problems. That is P
13 'once again the conceptual plan for this one.
MR. ALLEN: Any comments on that?
15 MR. BINGHAM: That concludes our presentation to the 16 Board, John.
17 MR. ALLEN: Are there any additional comments or 18 questions from the Board at this time?
19 We will go off the record for a brief off-the-record discussion ensued, minute.'Thereupon 20 a 21 after which proceedings were resumed as follows:)
22 MISS KERRIGAN: First, we would like to thank the 23 Board for letting us sit. in as observers. It has added to our understanding of the balance of plant side of the system.
I heard the same comments from the CE IDR, also,,that it GRUMLEY REPORTERS Phoenix, Arizona
344 aided in NRC's understanding of the instrumentation and control systems.
I would like to talk a little about what NRC needs to do to complete SER's for both CESSAR and Palo Verde.
After we get the transcript from this meeting and the CE meeting, we will be sitting I
down and going through the transcripts making sure that there are no additional questions that NRC has. We would at that time be prepared to take positions on the material presented, positions that would be 10 reflected. in the SER. Some of those positions may be in conflict with the positions that were taken by CE or APS, 12 and we would be willing to meet with you to discuss that and 13 give you an opportunity to change our minds on our positions.
14 The second thing that we expect to come out of a 15 review of the transcript is some additional questions on particularly the interfacing between the CESSAR standard 17 system and the Palo Verde balance of plant system.
18 We would like to go back and talk to some of our 19 colleagues at NRC, but right now we feel that..the most 20 fruitful way to complete our review and wrap this up is to 21 hold a meeting in Washington the week of July 27th with 22 both APS and Bechtel and see at the same time, understanding 23 that CE's participation in the meeting would be from a 24 CESSAR scope and not from a Palo Verde scope. We hope in 25 that meeting, which we expect would take two to three days, GRUMLEY REPORTERS Phoenix, Arizona
t 345 to resolve all open issues, and any additional questions that we had at the conclusion of the meeting the staff would be prepared to write draft SER's for both CESSAR and Palo 4 Verde. What we would anticipate doing, also, is sometime prior to this meeting, we would hope no later than the week of July 13th, we would be sending you the positions that we feel may be in conflict with your positions and the additional questions that we would have in a draft form so that you could prepare for the meeting and everybody is up to speed 10 and we could clean up the rest of the open issues. If there is a change to what I have just outlined, we will be contacting you.
13 MR. ALLEN: Janis, I have one question. Before July 14 27th, do you plan to have a draft SER?
15 MISS KERRIGAN: Well, it, would be in the form of any place where we feel that we would be taking a position in the SER that would be in conflict with the position that either APS or CE has taken, you would receive those positions.
19 MR. ALLEN: I would like to ask, also, if you haVe any 20 more comments, like has been done with some of the other branches, just to give us a call and we will resolve them over the phone.
23 MISS KERRIGAN: That would be no problem.
24 MR. ALLEN: Are there any other comments or questions before we adjourn?
GAUMLEY AEPOATEAS Phoenix, Arizona
I 346 I would like to thank all the Board members and the NRC and especially Bechtel for doing a good job of presenting a lot of material.
If there is nothing else, I will declare the meeting adjourned.
10 I HEREBY CERTIFY that I was present at the meeting 12 before the Balance of Plant Instrumentation and Control Systems Review Board; that I made a shorthand record of all
. proceedings had and adduced before said Review Board at said meeting; that the foregoing 346 typewritten pages constitute a full, true and accurate transcript of said record, all to the best of my skill and ability.
18 19 HA K M. MLEY 20 Court Reporter 21 22 23 24 25 GAUMLEY REPORTERS Phoenix, Arizona
ADDENDUM - OPEN ITEMS Provide a drawing showing the routing and separation of reactor protection system and supplementary protection system circuits. (p. 20)
- 2. Address the BOP items in the list of 27 items of concern on Arkansas Nuclear One, Unit 2, relative to core protection calculators. '.(p. 21) 3 ~" Provide a detailed list of differences between PVNGS
,project j.nterface documents and the System 80 interface documents. (For discussionat the NRC follow-up meeting.) (p. 26) 4 ~ Exhibit 2A1-6,-8. Describe the degree to which systems 10 designed in accordance with IEEE'338-71 differ from XEEE-338-1975 or 338-1977 (to be included in follow-up meeting.) (p. 50) 12 Exhibit 2A1-19, Item B. What is the basis for the assertion that the bypass time will be short? (p. 78) 13 Include time per event out-of-service and'integrated time .out-of-service. (p. 267)
- 6. Confirm that a) the plant can be taken to cold shutdown 15 within the 'control room using emergency procedures (p. 123) and b) that PVNGS meets ICSB/PSB BTP 18.
16 (p. 123) 17 7. Confirm that in the event of a single failure at the remote shutdown panel, the operator's procedures and 18 training are such that he would take parallel actions to those required should the single failure occur in 19 the control room. (p. 136) 20 8. Provide the basis for any exceptions to Reg. Guide 1.97, Revision 2. (p. 189) 21
- 9. Provide a strong commitment to the schedule specified 22 in Reg. Guide 1.97, Revision.2, including-what is in;j1ow and what will be installed in the future. (p. 189) 23
- 10. Exhibits 2C3-15 and 16. .What are the design values of 24 the auxiliary feedwater and essential cooling water system flows? (p. 193) 25 ll. Describe the quality assurance and protection of the GRUMLEY REPORTERS Phoenix, Ar)zona
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348 COLSS software package. (p. 214)
- 12. Discuss the quality assurance of the reactor power cutback system computer software. (p. 214)
- 13. Describe how accuracies and setpoints assumed in accident analyses are carried through procurement, senso signal converter to indicator such that loop accuracy is within what was assumed in the accident analysis.
,(p. 241)
- 14. Exhibit 38-2. Add I/C to all sections of the exhibit.
(p. 249)
- 15. Identify on the exhibits which Reg. Guide revisions and IEEE dates are being used" by PVNGS. (p. 255)
- 16. Add a discussion of Reg. Guide 1.106 to Section 3C.
10 (p. 259)
- 17. Identi fy and discuss any areas o f con flict that may ex].st as a result of CE conforming to IEEE 338-1971 12 and BOP conforming to IEEE 338-1975. (p. 261)
- 18. Confirm'hat CE and BOP are using the same revisions of Reg. Guides, regulations and SRPs, and if they are 13 not, confirm that no interface problems result. (p. 261) 15 19. Exhibit 3D-9. Provide a clarification of "less than normal time interval between generating station 16 shutdowns", including the effect of 12 or 18 month refueling outages. (p. 269) 17
- 20. Exhibit 3D-8, Section 4.9 of IEEE-279. Does PVNGS emplo 18 temperature switches for the HVAC system'? (p. 272) 19 21. Exhibit 3P-S, Bulletin 80-16. ,Provide assurance that Rosemount transmitters used on non-safety systems Chat 20 could cause confusing or adverse indications to the operator have been checked to assure.,that they are 21 within their calibrated range. (p. 290) 22 22 Exhibit 3G-'18. Amend the exhibit to indicate that ne'ither poweroperated relief valves nor block valves are 23 used in the PVNGS design.
'3.
24 Discuss the acceptability of the operator using correction tables to adjust steam generator level/
pressure indication post-HELB. (p. 308)
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- 24. Exhibit. 4-8. Non-ESF equipment is automatically loaded after a SIAS clears. Is this a violation of PVNGS criteria, i.e., should non-ESF equipment be manually loaded after cessation of a SIAS? {p. 334) 10 12 13 14 15 16 17 18 19 20 21 22 23 24 25 GRUMLEY REPORTERS Phoenix, Arizona
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