ML18052B166

Forwards Response to 861103 Request for Addl Info Re Implementation of ATWS Rule,Including Three Sets of Proprietary drawings.W/11 Oversized Proprietary Drawings. Drawings Withheld (Ref 10CFR2.790)

ML18052B166
Person / Time
Site:	Palisades
Issue date:	06/30/1987
From:	Bordine T CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML18052B167	List: ML18052B166
References
NUDOCS 8707070339
Download: ML18052B166 (16)

Text

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consumers Power POWERIN&

NllCHl&AN'S PRO&RESS General Offices: 1945 West Parnell Road, Jackson, Ml 49201 * (517) 788-0550 June 30, 1987 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -

ANTICIPATED TRANSIENT WITHOUT SCRAM (ATWS) RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION A November 3, 1986 NRC letter requested additional information pertaining to the implementation of the ATWS rule at Palisades. The enclosure to this letter provides the responses to the NRC concerns. Included in the response are three sets of drawings for the proposed. modifications and information from our supplier of relays to be used as electrical isolation devices. The relay supplier, Telemecanique, considers the information proprietary; therefore, as required by 10CFR2.790(b), an Affidavit attesting to the proprietary nature of the Telemecanique report is also enclosed which provides the necessary information to support withholding from public dis.closure.

Although we have chosen to delay installation of the ATWS modifications until the second refueling outage from now, we wish to resolve the NRC concerns within the next few months. We, therefore, request the NRC to apply appropriate priority to thi~ *response consistent with your November 3, 1986 letter which indicated 60_,days as necessary for NRC review.

Thomas C Bordine Staff Licensing Engineer CC Administrator, Region III, NRC NRC Resident Inspector - Palisades Attachments re7o7o7o.339 e7ob3o *.

i . PPD*R ADqCK 05000255.,,

PDR OC0687-0088-NL02 r

ATTACHMENT Consumers Power Company Palisades Plant Docket 50-255 ATWS ENCLOSURE RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION June 30, 1987 6 Pages AT0687-0088-NL04

ATWS ENCLOSURE RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION The following discussion is in response to your request dated November 3, 1986 for additional information regarding diversity, electrical independence and reliability/testability at power. This discussion is supplemented by the attached Table 1 and Figures 1 and 2.

Drawings for the proposed modification are being ~upplied for your review.

Changes for this modification are typically shown with a "balloon" to differentiate from the sections of existing circuits/logic that are not being changed and an 8- is added to the base number to signify that the drawings are part of an active project. A short description of the enclosed drawings and their changes are provided to facilitate your review.

DRAWING DESCRIPTION Logic diagram 8-El7, sheet 21A and schematic diagram 8-E-238, sheet 4 show the changes we are proposing to provide electrical diversity for the AFAS.

Solenoid valve SV-0522B is normally energized from preferred DC bus Dll and blocks the normal and/or backup air supply to control valve CV-0522B. In the event of Dll's failure, SV-0522B will open and provide air to CV-0522B causing the steam driven auxiliary feed pump to start. The Auxiliary Feedwater flow control valves CV-0727 and CV-0749 are air-to-close valves. On loss of power from DC bus DlO (D20) to the flow control circuits or loss of the flow signal, these valves will fail open. A path for auxiliary f eedwater will be maintained on loss of power or instrument signal to the flow control valves.

Schematic diagram 8-E-121, sheet 1 shows the normal turbine trip solenoid 20/AST and its associated initiation devices. 20/AST is powered from DC bus D21. Schematic diagram 8-E-121, sheet lA and logic diagram 8-E17, sheet 9 illustrates the redundant and diverse emergency trip solenoid 20/ET. 20/ET will be energized by ATWS-1 contacts among others and will be powered from DC bus D205. 20/ AST and 20/ET employ different principals of. operation and will be powered from independent DC supplies.

Schematic diagram 8-E-84, sheet 2 shows the changes made to include _the ATWS trip as part of the pressurizer pressure control and measurement channel instrumentation. Schematic diagram 8-E-84, sheet 2A contains the matrix relays, initiating contacts, and the fuses used to provide electrical isolation between ATWS circuits and Class lE circuits. Schematic diagram 8-E-212, sheet 3 contains the matrix relay contacts in the *2-out-of-4 logic for the ATWS trip. It also contains hand switch HS-0102D contacts that will inhibit the ATWS-1 trip relay to facilitate testing and/or maintenance. The ATWS-1 relay is powered from preferred AC panel Y230A which is powered from DC bus D205 to provide electrical independence. The ATWS-1 relay output contacts AT0687-0088-NL04

2 are used as electrical isolation devices between the ATWS circuitry and the Class lE reactor trip circuitry. The ATWS-1 relay is a Telemecanique 600V Class JlOA industrial control relay. Telemecanique documentation is enclosed with this submittal to justify our use of this relay as a Class lE isolation device.

Schematic diagram 8-E-122, sheet 1 shows the ATWS-1 reactor trip contacts in series with the undervoltage trip circuit breaker, and the existing redundant reactor trip push button #2 in each of two channels. The ATWS-1 turbine trip contact was discussed above. Vendor schematic diagram 8-950Yl8l*MlQ, sheet 1198 is included to expand on 8-E-122, sheet 1 and to assist in showing the required diversity.

Annunciator schematic diagram 8-E-295(Q), sheet 5 illustrates the alarm that will be annunciated and continuously displayed if any of the matrix relays are energized or if the ATWS channel is bypassed by HS-0102D.

ADDITIONAL INFORMATION RESPONSES AFAS, RPS and ATWS all use 2-out-of-4 sensor channel logic to detect an "off normal" condition. AFAS employs a l-out-of-2 channel logic for actuation. The RPS employs a l-out-of-2 taken twice actuation logic. ATWS utilizes a single actuation channel. A point by point response to your required information request follows:

1. Diversity from the Existing Reactor Trip System Table.l lists the components, manufacturer and part number, power supply; power source and design principle as applicable in each case. The table includes components from the sensor to the final actuation device in each of the three systems where diversity is required. Figures 1 and 2 further illustrate that diversity.

Bis tables The bistables for the two existing systems and one proposed system under consideration are made by different manufacturers. All have different principles of operation. All three bistables are powered from the AC vital busses. RPS and AFAS fail to tripped condition on loss of AC. The ATWS design is energized to trip.

Matrix Relays The matrix relays are all made by different manufacturers and all employ different principles of operation. RPS and ATWS systems are powered by the AC vital busses while the AFAS is powered from the DC vital busses.

The RPS system matrix relays fail to tripped condition on loss of power source. The AFAS and ATWS are both energized to trip. Although the AFAS matrix relay is energized to start the AFW pump, an intervening actuation AT0687-0088-NL04

3 device (solenoid valve) is de-energized to start. *Thus, on loss of control power, once of the three AFW pumps will auto start.

Initiation Relays Initiation relays are present in only the AFAS and ATWS systems.

Diversity is not required between these systems.

Actuation Devices Actuation devices in the three systems are all made by different manufacturers. The RPS and ATWS systems are powered from the AC vital buses. The AFAS system is powered by the DC vital bus. The RPS and ATWS systems are de-energized to trip. The AFAS is energized to trip.

2 . . Electrical Independence from the Existing Reactor Trip System (RTS)

ATWS Station battery D204 will provide the preferred power to AC panel Y230A via inverter Y210 (see Palisades P&ID Dwg ES Sh 3). D204 is not used to provide power to the RTS components and, therefore, satisfies the electrical independence requirement.

As discussed in our March 19, 1986 meeting with NRR, the matrix relays for the ATWS system are powered from the preferred AC busses. Each matrix relay is fused inside the respective channel from which it receives power. These fuses are sized to protect the integrity of safety related circuits from failures in the ATWS circuits.

AFAS DC control power for the auxiliary feed pump start circuits is provided from the same source as the RTS circuits. Electrical independence for the AFAS is provided by changing the logic and operation of air supply solenoid valve SV0522B *. Electrical independence is provided by the

• following method: With DC p9wer and associated AC inverter available, all three auxiliary feed pumps will function as designed when the signal for auxiliary feed automatic start is received. When DC power is not available, SV0522B will de-energize opening the normal or backup air supply line to the "air to open" steam supply valve CV522B which provides steam to the auxiliary feedwater pump turbine driver K-8. Thus, with DC power and associated AC inverter available, the auxiliary feed pumps will function as designed to.supply auxiliary feedwater and when DC power becomes unavailable the steam-driven auxiliary feedpump will automatically start due to the loss of the DC power.

AT0687-0088-NL04

4

3. Reliability and Testability at Power

a. Periodic testing of RPS and AFAS while at power is accomplished by use of the Technical Specification Surveillance Program. New Technical Specification tests will be generated to test the ATWS circuit. The proposal for testing will include provisions to:

(1) check each of four pressure indicators for comparison each shift, (2) test each meter relay by applying a test signal every month, and (3) test each meter relay by applying a test signal to verify sensor to trip device actuation logic each refueling.

b. The existing AFWS actuation circuitry is considered to meet the diversity requirements of the ATWS rule as shown in Table 1 and Figures 1 and 2. Testing at power for the AFWS will continue to be performed without changing the existing testing program which is presently covered by the Palisades Technical Specification Surveillance Testing Program (reference T~S. Section 4.9) *

. c. A hand operated keyswitch will affect the bypass of the turbine/

reactor ATWS trip relay to allow testing/maintenance. This bypass will be automatically annunciated and continually indicated on a main control board annunciator panel.

d. Technical Specifications will be proposed that will require demonstration that the systems and equipment required by the ATWS rule will be adequately maintained and capable of performing thei~ desig~

functions in a reliable manner. The proposal will also include operability requirements which will specify the required operation and availability to ensure the necessary reliability of the equipment is maintained. This will be accomplished by:

( 1) checking each of the four pr'essure indicators for comparison each shift.

(2) testing each meter relay by applying a test signal every month.

(3) testing each meter relay by applying a test signal to verify sensor to trip device actuation logic each refueling.

(4) specifying the availability requirements' for the ATWS equipment.

(5) specifying the operability requirements for the ATWS equipment.

(6) identifying the Limiting Conditions for Operation when availability and operability requirements are not met.

e. The only bypass feature is described in 3c above.

AT0687-0088-NL04

5

f. As described in the paragraphs that follow, good Human Factor Engineering practices (consistent with NUREG-0700 "Guidelines for Control Room Design Reviews," Chapter 6 "Control Room Human Engineering Guidelines") have been incorporated into the design of ATWS prevention/mitigation system components located in the control room.

Control Room Alarm Both the ATWS "Trip" and "Bypass" condition is annl;lnciated on a common window located within the RPS annunciator panel. Sharing a common window is considered desirable since very few spare windows exist on this panel, and entering a bypass condition is a procedurally controlled evolution at the plant ensuring that the operator is informed of the bypass and its associated alarm prior to it being affected.

As indicated, the new alarm will be incorporated into the existing RPS .

annunciator panel which is locat_ed above the RPS controls and displays per NUREG-0700, Section 6.3.3.1. This panel currently features a small number

• of alarm windows sub-*grouped by function for ease of recognition according to the requirements of NUREG-0700, Section 6.3.3.3.d. Utilizing the existing panel ensures that the labeling and color/auditory coding scheme is consistent with.other RPS trip and bypass annunciation.

Control Room Indicators As described in our April 23, 1986 submittal, the four existing pressurizer indicator/alarms will be replaced with four redundant Versatile 9292 indicator/alarms each featuring an additional setpoint to initiate a channel ATWS signal. To maintain operator familiarity with specific indicator location, the new indicator/alarms will be installed at the control panel locations which will be vacated by removal of the existing units.

Each indicator/alarm features a vacuum fluorescent bargra~h display to optimize readability. A specific human factors review of this indicator has been conducted by Consumers Power Company Operations and Engineering personnel. The review consisted of comparing the readability of the Versatile bargraph display to other manufacturers' models featuring both conventional pointer-driven displays and bargraph displays. The review consensus indicated that the Versatile bargraphs provide superior readability in term~ of contrast, character dimensions and viewing angle.

It is concluded that the use of these meters will ensure that the readability requirements of NUREG-0700, Sections 6.1.2.2.e and 6.5.1.3 will be met.

Finally, the four new indicator/alarms will be identical in terms of display features such as bargraph display, fixed scale characterization, color coding and labeling according to the compatibility requirements of NUREG-0700, Section 6.5.1.5.d.

AT0687-0088-NL04

• 6 Control Room Controls The key-operated control switch, which will be used to: 1) bypass the ATWS initiating trip circuit:s-for maintenance or testing, and 2) reset the ATWS trip signal, will be located near the aforementioned Versatile indicators and within clear sight of the aforementioned trip/bypass alarm according to the requirements of NUREG-0700, Sections 6.9.1.1 and 6.9.1.2.

The switch design (ie, handle shape and relative locations of individual switch positions such as "reset" and "bypass") is similar to other switches already installed in the control room for similar purposes according to the requirements of NUREG-0700, Section 6.4.2.2.a, c and d. The key is removable only in the "normal" position in accordance with NUREG-0700, Section 6.4.4.3.e.

AT0687-0088-NL04

RPS TABLE 1

• AFAS PALISADES NUCLEAR POWER PLANT DIVERSITY TABLE FOR ATWS RULE ATWS (Existing) (Existing) (Proposed)

SENSOR TYPE High Pressurizer Low S.G. Level High Pressurizer Pressure Pressure MANUFACTURER Rosemount Rosemount Rosemount PART NO. 1153GD9 1153DD5 1153GD9 POWER SUPPLY Foxboro Lambda Foxboro POWER SOURCE AC Vital Bus AC Vital Bus AC Vital Bus BI STABLES MANUFACTURER Gulf Vitro Versatile PART NO. NT-4 2717-1076 9292 POWER SUPPLY Dynage Lambda/CEA N/A POWER SOURCE AC Vital Bus AC Vital Bus AC Vital Bus DESIGN PRINCIPLE Mercury Relay A to D Voltage Indicating Comparator Voltage Switch MATRIX RELAYS MANUFACTURER Ad lake Vitro Telemecanique PART NO. MW2600 2717-1081 J-10 A4012 POWER SUPPLY Dynage CEA N/A POWER SOURCE AC Vital Bus DC Vital Bus AC Vital Bus DESIGN PRINCIPLE Mercury Relay Solid State Logic Electromechanical Module Relay INITIATION RELAYS MANUFACTURER N/A Agastat Telemecanique PART NO. GPD-N-R J-10 A4012 POWER SOURCE DC Vital Bus Y-230A DESIGN PRINCIPLE Electromechanical Electromechanical Relay Relay ACTUATION DEVICE MANUFACTURER Allen-Bradley Agastat Westinghouse PART NO. 702-DAD94 E-7012-PC D-JA-2200.

w/UV Trip POWER SOURCE AC Vital Bus DC Vital Bus AC Vital Bus DESIGN PRINCIPLE Electromechanical Electromechanical U.V. Circuit Con tac tor Relay Interruptor With the exception of the sensors which are exempted from the ATWS rule, diversity of the RPS, ATWS and AFAS is shown in the above table and the attached block diagrams. All of the components in each system are from different manufacturers and, in several cases, use power from different sources.

AT0687-0088-NL04

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Drawing Sheet Revision Title 8-El7 9 2 Logic Diagram, Turbine Gene-rator Trips and Fast Transfer 8-El .. *- 21A 1 Logic* Diagram, Auxiliary* Feed-water Pump PS~ Control 8-E84 2 2 Schematic Diagram, Pressurizer Pressure Control & Measurement Channel Instrumentation 8-E-84 2A 2 Schematic Diagram, Pressurizer Pressure ATWS 8-E-121 1 2 Schematic Diagram, Turbine Control 8-E-121 lA 2 Schematic Diagram, Turbine Control 8-E;...212 1 0 Schematic Diagram, Turbine Control 8-E-212 3 2 Schematic Diagram, Pressurizer Pressure ATWS 8-E-238 4 1 Schematic Diagram, Auxiliary Feedwater System 8-E-295 5 0 Schematic Diagram, Annunciator Reactor Protective Panel 8-950yl8l*MI-Q 1198 1 Reactor Protective System Schematic DWG0687-0088-NL02

I*

ATTACHMENT Consumers Power Company Palisades Plant Docket 50-255 TELEMECANIQUE RELAY INFORMATION CONTAINS PROPRIETARY INFORMATION June 30, 1987 52 Pages ATT0687-0088-NL02

A .F F J D A V I T STATE OF MARYLAND *.* ~)

) - SS. **

COUNTY OF CARROLL )

I, R~ W. Jones,* being duly s~orn, h~r~by say and depose:

1. I am Dfrect.C:ir -of. Operations for Telemec:_anique **Irie.~ *~

Westminster, MD*, :*here after. known as TE, and. ani authorized to exec.ute this Affidavit. ' ..

. 2. I am .fami-li.ar with TE's Corporate Procedures for preparatiOn*

arid c6ntrol of desi~~ documentat~pn:

• 3 .. I am- f_amiliiir'-~ith* TE *Report SC-683, "IEEE 344-1974 Sei.smic*

Certification for *saf_ety Related JlO Relays" and TE Report*CC-14-386, "IEEE 323-1974 Certification for Safety Related JlO Relays", here after referred to as* "Documents~*. I.nformat.ion. contained .i_n these D9cuments ,have been classified as proprietary in. ac.cordance . .

with-- the procedures

. . .*... es ta bl fshed _by TE for the control and pr_otection of information;

4. The Documents contain *informatiori of a proprietary_ and corifidential *nature which is n6t available in public sources. Based on

. my experience, I ani**aware that other companies regard information o*f the kind contained in the Documents as p_ropri_~~ary and ~onfiden_ti_al_...

• 5.

• The information c'ontained in.the Documents* are consider.ed by TE:to be proprietary because* it reveals Ge~tain distingui5hing aspects of TE's JlO relay product l.i-ne_, here after -referred* to as relay, and*test procedures *whhh secur~ competitive advantage to TE for safety re 1ated TELEMECANIQUE INC., 2002 BETHEL ROAD, WESH*~INSTER, MD 21157, (301.) 876-2214

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c I electrical control circuits. The Documents also include information which affords TE an opportunity to obtain a tomp~titive advantage over those who do not or may not know or use the- information contained in the Doe1,1ments.

6. The Documents provide information which reveals strategic data for TE equipment qualification programs* develope*d over ~he :-past several y~ars_. TE_ has i nvest~d over one hundred thousand dollars and _many inan hours of effort in developing the Relay Qualification.

__ 7: The Documents cbntai n information which is vital as a competitive advantage to TE and woul~ be helpful *~o competiiors of TE. The di s*cl osure'i'0f the prop.rietary i nformati o~ contained in the Do~uments to a cqmpetjt_on would permit the competitor. to reduce its expenditure of money and*manpower and to impro~e its competitive.position by giving ~t valuable insights into the TE Qualificatfon,_Program.

• lt*would also result in substanti.al harm to the competitive P.Osi.ti on of TE.

8-. *Based o~_*my'_experi'ence, *~-do not_believe that the* background, data,.-and inc;entives of TE 1 s competitors.are suf'.iciently similar to the .

corre~ponding backgro~nd_,' data, and incehtiv*~*s of TE to reasonably expect such coinp~ti.tors to be in' a position to dupLicate TE 1 s proP,rietary informati on 1

contained-in the Documents without similar investments.

9. In accordanG_e with TE s policies_governing the protection 1

and control of information, -proprietary Tr:iform~tion contained in the Documents has been made ~vailable, on a_li~it~d basis, to other~ outside Tt only as required and under suitable agreement providing for noh-disclosure

-and 1imited use of the information.

TELEMECANIQUE INC., 2002 BETHEL ROAD, WE$TMINSTER, MD 21157; (301) 876-2214

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. lO.' -The Documents have been made avai.lable to the*u:s~* N-uclear*

Reguiat.ory Commiss{on in confidence, with the stipulation that the information contain-ed in the. Documents not be duplicated or djsclosed, in whole or in ;part, witho~t th~ ~xpress wrftten con~~nt of-telemeca~i~~e Inc~ -

• THAT the stateme~ts made hereinabove are, to the best-of.my

- knowledge, inforriiatfon., and belief, *truthful and complete ..

R.

• W. Jo DirectQ of.Operation~

.. Telemecanique Inc:

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SWORN TO AND SUBSCRIBED before me this a&~da~ of

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"r.{oJARY* .PUBLIC My Commiss 1ori Expires: *

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• TELEMECANIQUE INC., 2002 BETHEL ROAD, WESTMINSTER, MD 21157, (301) 876-2214