ML18153A955
| ML18153A955 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 05/24/1994 |
| From: | Ohanlon J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 94-265, NUDOCS 9405260093 | |
| Download: ML18153A955 (14) | |
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e VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 May 24, 1994 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 Serial No.
NL&P/CGL-MDK Docket Nos.
License Nos.
CONTROL ROOM DESIGN REVIEW REASSESSMENT -
RESPONSE TO SAFETY EVALUATION OPEN ITEM AND IDENTIFICATION OF DESIGN CHANGE DISCREPANCIES93-265 R4" 50-280 50-281 DPR-32 DPR-37 Our July 29, 1992 letter (Serial No. 92-131A) transmitted the Surry Control Room Design Review (CRDR) Reassessment. The NRC issued a Safety Evaluation (SE) on April 21, 1993. The SE concurred with the CRDR Reassessment with the exception of one item. The one remaining open item is related to safety system indicator lights with single filament bulbs that are not normally illuminated. Attachment 1 discusses our proposed resolution of this remaining item. Attachment 2 identifies the control room indicator lights that are affected. Attachment 3 identifies alternate indication for the affected control room indicator lights.
Upon receipt of the NRC's SE, we developed the design change package for the outage-related reassessment items, which were implemented during the recent Unit 1 refueling outage and will be implemented during the next Unit 2 refueling outage.
Because the reassessment effort did not include detailed design considerations, two discrepancies were identified during the detailed design change package development. These discrepancies are discussed in Attachment 4. It is anticipated that the resolution of these discrepancies will not impact the NRC's SE.
Development of the design change package for the remaining reassessment items to be completed as non-outage activities has been initiated. Due to the nature of the remaining activities, it is not expected that there will be any additional discrepancies identified.
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As previously indicated in our July 29, 1992 letter, it was our intention to complete the required CRDR modifications by the end of 1994 consistent with the schedule for completion of the CRDR Program. As noted in that letter, we were planning installation of required modifications during the Units 1 and 2 refueling outages then scheduled for 1994. However, the next Unit 2 refueling outage has been rescheduled to begin on January 21, 1995 and end on March 28, 1995. Therefore, the Unit 2 outage-related CRDR modifications will be completed by the end of the next refueling outage.
If you have questions or require additional information, please contact us.
Very truly yours, q-;?c!J/~
J. P. O'Hanlon Vice President - Nuclear Operations Attachments: 1. Planned Resolution of Concern Related to Safety System Indicator Lights with Single Filament Bulbs that are not Normally Illuminated
- 2. Safety System Indicator Lights with Single Filament Bulbs that are not Normally Illuminated
- 3. Alternate Indication for Safety System Indicator Lights with Single Filament Bulbs that are not Normally Illuminated
- 4. Discrepancies between CRDR Reassessment and Outage-related Design Change Package cc:
U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, N. W.
Suite 2900 Atlanta, Georgia 30323 Mr. M. W. Branch NRC Senior Resident Inspector Surry Power Station
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ATTACHMENT 1 PLANNED RESOLUTION OF CONCERN RELATED TO SAFETY SYSTEM INDICATOR LIGHTS WITH SINGLE FILAMENT BULBS THAT ARE NOT NORMALLY ILLUMINATED SE Conclusion Regarding CA39E:
Selectively investigate for lamp test ca*pability, any safety systems with legend lights that have single bulbs and that are not normally illuminated.
The staff does not agree with the licensee's determination that no further action is required to effectively resolve this issue. The staff's experience has shown that safety-related single bulb (single filament) indicator lights which are normally off cannot be adequately monitored through administrative controls such as surveillance
- tests, calibration procedures, operating instructions and routine checks.
In previous DCRDR reviews, the NRC has found the following methods acceptable for resolving this issue:
(1) dual-filament bulbs, (2) long-life bulbs, (3) integral test feature, including a commitment to test at least once per shift, or (4) redundant indication.
The licensee is requested to submit a list identifying which safety-related indicator lights for which systems are affected, and its proposed corrective actions for each of the identified lights.
RESPONSE
The safety system indicator lights with single filament bulbs that are not normally illuminated and are applicable relative to this item are listed in Attachment 2. It is our understanding that the indicator lights of interest relative to the NRC's concern are those associated with a safety system component and not normally illuminated during any mode of plant operation.
We have reviewed the previously accepted methods for resolving this issue and offer the following comments regarding the applicability of each method to our specific case. It should be noted that it is our intention to use the same method of resolution for all of the affected indicator lights.
Dual Filament Bulbs The control room lamp types listed in Attachment 2 and evaluated are 24X and 1835.
Based on telephone conversations with numerous vendors, dual filament bulbs are not manufactured as replacement lamps for these lamp types. The smallest dual filament incandescent bulb, which allows sufficient space on the lamp base for the necessary contacts, is approximately 1" in diameter. The 24X and 1835 lamps have a 3/16" and 1 /4" diameter, respectively. There is insufficient space on the control room boards to install sockets to accommodate a 1" bulb.
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In addition, circuitry would have to be installed to enable the backup filament to illuminate after the primary filament has failed. This additional circuitry would be necessary because, if both filaments are illuminated, the manufacturer has indicated that in most cases both filaments would fail simultaneously.
Therefore, we have concluded dual filament bulbs are not an acceptable alternative for our specific application.
Long Life Bulbs (LEDs)
Approximately 60% of the affected lights listed in Attachment 2 are either amber or white. The majority of the amber and white lights are located on light colored control room (CR) boards. The LED industry has not yet manufactured a white light. The nearest LED to white that is manufactured is a mixed red/green LED, which provides a pale yellow light. The mixed red/green LED was found to be unacceptable due to its low intensity during an in situ control room test using both white and clear lens caps.
Also the mixed red/green LEDs could not be seen at all on the light colored backgrounds of the CR boards. Amber LEDs on the light colored CR boards were marginally acceptable. We also investigated whether or not the color of the lights could be changed to an LED color with known brighter intensity. However, because the colors specifically represent certain functions and the available LED colors are limited, the light color can not be changed without significant impact on human factors considerations.
In addition to the low intensity of the LEDs, another concern became evident with the LEDs during in situ control room testing. The angle of light emitted from an LED is approximately 130° as opposed to 180° for an incandescent bulb, which makes viewing from a distance or at an angle considerably more difficult.
Therefore, we concluded that use of LEDs is not an acceptable alternative for our specific application.
Integral Test Feature or Redundant Indication The Surry CRDR Reassessment considered installation of a lamp test feature and concluded that "the benefit of any hardware modification would not be commensurate with the high cost of the modification." This conclusion applies to plant modification for installation of either a lamp test feature or redundant indication. There is insufficient space on the CR boards to install either a pushbutton adjacent to each of the affected lights for lamp testing or a second light adjacent to each of the affected lights for redundant indication.
Therefore, we concluded that installation of an integral test feature or redundant indication is not an acceptable alternative for our specific application.
Proposed Resolution We have concluded that a practical alternative to the NRG-identified methods for resolution is implementation of administrative controls for periodic lamp replacement Page 2 of 3
e of the identified indicator lights in the control room. Specifically, this program will institute administrative controls for replacement of the identified.indicator lights with pre-service tested bulbs during each refueling outage. The program will also include post-service testing of the removed bulbs.
The post-service test results will be evaluated to allow replacement interval adjustments, if required. provides the following information:
- the function of the affected control room indicator lights listed in Attachment 2, identification of alternate indication for the affected control room indicator lights, and identification of where the alternate indication is referenced in the Surry emergency procedures.
This information is being provided in response to an NRC request made during a March 14, 1994 conference call to discuss our proposed resolution of the lamp test issue.
In addition to the indicators listed in Attachment 2, the Surry Units 1 and 2 control rooms each have forty-nine (49) safety system indicator lights with single filament bulbs that are not normally illuminated because the associated equipment (24 components) is normally de-energized.
When the associated equipment is energized, one of the indicator lights showing either valve position or breaker status illuminates. Therefore, the lamp test issue is not applicable to these indicator lights.
Similarly, the auxiliary shutdown panel (ASP) is normally de-energized. When the auxiliary shutdown panel (ASP) is required to be energized, one of the indicator lights for each component illuminates. The abnormal procedure associated with main control room inaccessibility requires transfer of control from the main control room to the ASP following reactor and turbine trips and based on equipment status as documented in operator logs. The operator will have full cognizance of the status of equipment as control functions are transferred. In addition, surveillance tests are performed at every refueling to 1verify the ability to transfer control power from the control room to the ASP. This transfer of control power is verified by the illumination of indicator lights. Therefore, we conclude that the lamp test issue is not applicable to the ASP indicator lights.
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ATTACHMENT 2 SAFETY SYSTEM INDICATOR LIGHTS WITH SINGLE FILAMENT BULBS THAT ARE NOT NORMALLY ILLUMINATED Unit 1 Main Control Board Indicators Safety Injection System (Benchboard 1-1)
Recirculation Mode Transfer Status Lights Phase 1 - Train A (white) and Train B (white)
Phase 2 - Train A (amber) and Train B (amber)
Ventilation System (Auxiliary Ventilation Panel)
Damper Air Supply Reset 1-SOV-VS-101A (amber) 1-SOV-VS-101 B (amber)
Emergency Diesel Generator (EOG #1 Panel)
EOG #1 Fast Start Reset (red)
Emergency Diesel Generator (EOG #3 Panel)
EOG #3 Fast Start Reset (red)
EOG #3 Auxiliary Trip Relay (amber)
Switch yard Bus D Load Shed (red) (Switchyard Status Panel)
Bus E Load Shed (red) (Switchyard Status Panel)
Bus F Load Shed (red) (Switchyard Status Panel)
Unit 1 Reserve Station Service Transformer Time Delay Reset (white)
(Benchboard 1-2)
Unit 2 Reserve Station Service Transformer Time Delay Reset (white)
(Benchboard 1-2)
Recirculation Spray System (Bench board 1-1)
Inside Recirculation Spray Pump Rotation 1-RS-P-1A (blue) 1-RS-P-1 B (blue)
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ATTACHMENT 2 (continued)
Unit 2 Main Control Board Indicators Safety Injection System (Benchboard 2-1)
Recirculation Mode Transfer Status Lights Phase 1 - Train A (white) and Train B (white)
Phase 2 - Train A (amber) and Train B (amber)
Ventilation System (Auxiliary Ventilation Panel)
Damper Air Supply Reset 2-SOV-VS-201 A (amber) 2-SOV-VS-201 B (amber)
Emergency Diesel Generator (EDG #2 Panel)
EDG #2 Fast Start Reset (red)
Emergency Diesel Generator (EDG #3 Panel)
EDG #3 Fast Start Reset (red)
EDG #3 Auxiliary Trip Relay (amber)
Recirculation Spray System (Benchboard 2-1)
Inside Recirculation Spray Pump Rotation 2-RS-P-1 A (blue) 2-RS-P-1 B (blue)
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SYSTEM SAFETY INJECTION SYSTEM RMT PHASE 1 SAFETY INJECTION SYSTEM RMTPHASE2 e
ATTACHMENT 3 ALTERNATE INDICATION FOR SAFETY SYSTEM INDICATOR LIGHTS WITH SINGLE FILAMENT BULBS THAT ARE NOT NORMALLY ILLUMINATED BULB FUNCTION ALTERNATE INDICATION CAI)
THE PHASE 1 A PHASE 1 LIGHT ILLUMINATES RECIRCULATION WHEN RWST LEVEL <18% IN A 2 MODE TRANSFER OUT OF 4 LOGIC. WHEN RWST STATUS LIGHT LEVEL DROPS TO 22%,
IDENTIFIES TO THE OPERATOR IS DIRECTED TO OPERATOR THAT ES-1.3. VALVE POSITION REALIGNMENT INDICATION IDENTIFIED IN EOP FROM LOW HEAD ES-1.3 STEP 4 TO HIGH HEAD IS COMMENCING TO ANNUNCIATORS A-A2, A-82, A-C2 &
ISOLATE THE RWST A-D2 ALARM "RMT CHAN (1,2,3 &4)
AND ALLOW TRIP BYPASS" SUCTION FROM THE SUMP PHASE 2 PHASE 2 LIGHT ILLUMINATES RECIRCULATION AFTER A ONE MINUTE DELAY MODE TRANSFER FROM PHASE 1 TO ALLOW STATUS LIGHTS ISOLATION OF RECIRC AND VALVE IDENTIFIES TO THE REALIGNMENT. VALVE POSITION OPERATOR THAT INDICATION SHOWING THE NEW LINEUP IS REALIGNMENT TO SUCTION FROM IN PROGRESS THE SUMP IDENTIFIED IN ES-1.3 STEP4 Al = RWST LEVEL INDICATION AND ANNUNCIATORS / VALVE POSITION INDICATION Page 1 of 5 PROCEDURES ES-1.3 STEP 4 ANNUNCIATOR
RESPONSE
PROCEDURES FOR A-A2, A-82, A-C2 &
A-D2 & A-A7 "RWST TNK LO LVL" ES-1.3 STEP 4
SYSTEM VENTILATION SYSTEM SOV-VS-101A SOV-VS-101 B SOV-VS-201A SOV-VS-201 B e
e ATTACHMENT 3 ALTERNATE INDICATION FOR SAFETY SYSTEM INDICATOR LIGHTS WITH SINGLE FILAMENT BULBS THAT ARE NOT NORMALLY ILLUMINATED BULB FUNCTION ALTERNATE INDICATION CAI)
DAMPER AIR ANNUNCIATOR VSP-C2 ALARMS SUPPLY RESET "AUX VENT SYS SFTY MODE INIT' LIGHT ILLUMINATES IN RESPONSE TO AN SI. THE SOV TO INDICATE TO LIGHTS COME ON AT THIS TIME THE OPERATOR INDICATING'THAT THE SYSTEM IS THAT THE COMMENCING TO REALIGN FROM AUXILIARY THE NORMAL TO THE SI VENTILATION ALIGNMENT. THE RED/GREEN SYSTEM IS DAMPER POSITION INDICATING REALIGNING FROM LIGHTS ARE SWAPPING POSITION THE NORMAL TO THE SAFETY Al = ANNUNCIATORS AND INJECTION DAMPER POSITION ALIGNMENT INDICATION Page 2 of 5 PROCEDURES E-0 STEP 18 VERIFIES AUX VENTILATION SYSTEM REALIGNMENT.
THE ALIGNMENT IS VERIFIED IN ACCORDANCE WITH E-0 ATTACHMENT 2
SYSTEM EMERGENCY DIESEL GENERATOR
- 1, #2 & #3 FAST START RESET EMERGENCY DIESEL GENERATOR AUXILIARY TRIP RELAY e
e ATTACHMENT 3 ALTERNATE INDICATION FOR SAFETY SYSTEM INDICATOR LIGHTS WITH SINGLE FILAMENT BULBS THAT ARE NOT NORMALLY ILLUMINATED BULB FUNCTION BULB CORRESPONDS TO PUSHBUTTON ALLOWING OPERATOR TO TAKE MANUAL CONTROL OF DIESEL SPEED IDENTIFIES TO THE OPERATOR THAT THE AUXILIARY TRIP RELAY ACTUATED AND THE AUTO STARTON#3 DIESEL IS DISABLED ALTERNATE INDICATION CAI)
WHEN THE OPERATOR DEPRESSES THE PUSHBUTTON, THE LIGHT COMES ON Al = OPERATOR'S ABILITY TO MANUALLY CONTROL EDG SPEED ANNUNCIATOR VSP-CS ALARMS "EMERG DIESEL 3 AUTO START DISABLED" O-AP-17.05 - EDG #3 FAILS TO AUTO START OR FAILS TO ACCEPT EMERGENCY BUS LOADS. STEP 4, HAS THE OPERATOR VERIFY THAT THE LIGHT IS NOT LIT. IF EDG NOT RUNNING, THE OPERATOR IS DIRECTED TO O-AP-17.05 ATTACHMENT 1 TO RESET THE AUXILIARY TRIP RELAY REGARDLESS OF THE STATUS OF THE LIGHT Al = ANNUNCIATOR AND DIESEL STATUS (E.G., SPEED INDICATION)
Page 3 of 5 PROCEDURES O-AP-17.05 ADDRESSES FAILURE OF EDG TO AUTOSTART OR ACCEPT EMERGENCY BUS LOADS. STEPS 18
& 19 DIRECT THE OPERATOR TO TAKE MANUAL ACTION BY DEPRESSING THE FAST START RESET PUSHBUTTON AND VERIFYING LIGHT LIT. IF LIGHT DOES NOT ILLUMINATE, OPERATOR WILL ATTEMPT TO ADJUST SPEED IF NECESSARY VSP-CS O-AP-17.05
SYSTEM SWITCHVARD BUSES D, E,& FLOAD SHED SWITCHVARD RESERVE STATION SERVICE TRANSFORMER TIME DELAY RESET ATTACHMENT 3 ALTERNATE INDICATION FOR SAFETY SYSTEM INDICATOR LIGHTS WITH SINGLE FILAMENT BULBS THAT ARE NOT NORMALLY ILLUMINATED BULB FUNCTION IDENTIFIES TO THE OPERATOR THAT CONDITIONS REQUIRE LOAD SHED ON THAT TRANSFER BUS RESERVE STATION SERVICE TRANSFORMER TIME DELAY RESET IDENTIFIES TO THE OPERATOR THAT THE 1ST LOAD TAP CHANGER TIME DELAY (30 SEC)
HAS BEEN BYPASSED TO A (5 SEC) TIME DELAY ALLOWING THE LOAD TAPS TO RESPOND PROMPTLY TO THE INCREASE IN LOAD ON THE EMERGENCY BUSES.
ASSOCIATED WITH AN SI/HI-HI CLS ALTERNATE INDICATION CAil THE CONDITION WILL EXIST IF BOTH UNITS ARE ON RESERVE STATION SERVICE, E.G., U1 OUTAGE, U2TRIP. IF U1 STATION SERV RES SUP BKR (ACB-15A1) IS CLOSED AND U2 STATION SERV RES SUP BKR (ACB-25A1)
CLOSES, THEN BUS D LOAD SHED LIGHT ILLUMINATES. THE SAME FOR B BKRS AND E LOAD SHED LIGHT AND C BKRS FOR F LOAD SHED LIGHT Al = BREAKER POSITION INDICATION IFTHE LIGHT DID NOT ILLUMINATE INDICATING BYPASS OF THE 1ST LOAD TAP CHANGE, THEN THE H &
J BUS UNDERVOL TAGE ANNUNCIATORS (K-H2 & 3) OR THE H & J BUS OVERVOL TAGE ANNUNCIATORS (K-G2 & 3) WILL ALARM INDICATING EMERGENCY BUS VOLTAGE IS NOT BEING MAINTAINED BY RSS TRANSFORMER TAP CHANGERS AS INDICATED ON H & J EMERGENCY BUSES Al = OVERVOLTAGE AND UNDERVOLTAGE ANNUNCIATORS AND H & J BUS INDICATION Page 4 of 5 PROCEDURES IN E-0 STEPS 19 e, f
&gOPERATOR CHECKS IF UNIT 2 SUPPLIED BY RSS AND CHECKS IF UNIT2 RCPS RUNNING. IF YES, THEN LOAD SHED INITIATED IS VERIFIED; IF NO, THEN GOES TO O-AP-10.10.
O-AP-10.10 LOSS OF LOAD SHED STEP 1c VERIFIES THAT LIGHT IS LIT ANNUNCIATOR
RESPONSE
PROCEDURE K-H2 FOR UNDERVOLTAGE AT 90%, 3744V AP-10.10 ATTACHMENT 1 STEP 3 &
E-0 STEP 19
SYSTEM RECIRCULATION SPRAY SYSTEM RS-P-1A&B ROTATION ATTACHMENT 3 ALTERNATE INDICATION FOR SAFETY SYSTEM INDICATOR LIGHTS WITH SINGLE FILAMENT BULBS THAT ARE NOT NORMALLY ILLUMINATED BULB FUNCTION LIGHT INDICATES THAT THE INSIDE RECIRCULATION SPRAY PUMPS ARE ROTATING> 100 RPM PER SPEED SWITCH ESK 6BA AL TERNAJE INDICATION CAil AMP METERS INDICATING MOTOR CURRENT MARK NOS ISRS PUMP AM PS RS-P1 A&B DISCHARGE PRESSURE INDICATORS RS-Pl-252A&B THE GREEN TO RED PUMP INDICATOR LIGHTS WILL SWAP INDICATINGTHATTHE PUMPS HAVE STARTED Al = PUMP BREAKER INDICATION, DISCHARGE PRESSURE INDICATION, AND AMP METER INDICATION Page 5 of 5 PROCEDURES E-0 STEP 12e &
ES-1.3 STEP 2c REQUIRE VERIFICATION THAT THE PUMPS ARE RUNNING NOTE THAT BLUE LIGHTS ARE NOT RELIED UPON DURING OPERATION. THEY WERE ORIGINALLY INSTALLED TO VERIFY PUMP ROTATION WHEN DRY BUMP TESTING WAS PERFORMED ON THE PUMPS.
SUBSEQUENTLY A MODIFICATION HAS BEEN INSTALLED TO ALLOW FULL FLOWRECIRC TESTING
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ATTACHMENT 4 DISCREPANCIES BETWEEN CRDR REASSESSMENT AND OUTAGE-RELATED DESIGN CHANGE PACKAGE As noted in the cover letter, the CRDR reassessment effort did not include detailed design activity. When the detailed design package was developed, two discrepancies were identified.
These discrepancies, which are presented in the following paragraphs, were also discussed during the March 14, 1994 conference call between our staffs.
CA10E - SILENCE FEATURE ON ANNUNCIATOR ALARMS Reassessment Issue:
Operators are unable to silence the audible alarm during transients.
The inability to silence the alarms may cause delays and/or errors in an operator's responses due to high levels of noise.
Reassessment
Conclusion:
The existing annunciator system will be modified to install a silence feature using hardware (audible driver card, speakers, etc.) available from the original equipment manufacturer which is compatible with the operation/function of the existing annunciator system.
DESIGN CHANGE PACKAGE DETERMINATION During the CRDR reassessment, the original equipment manufacturer (OEM) of the annunciator system was contacted and we were led to believe that modifications to only the alarm circuitry would be required to implement a silence feature. During the actual design work associated with the design change package preparation, the OEM participated in a walkdown and discovered that the existing Surry system does not operate on a voltage pulse mode to the speaker bus as do the OEM's current systems.
Therefore, extensive modifications or even replacement of the system would be required to accomplish a change such as that considered as part of the reassessment effort. The benefits of implementing a silence feature is not commensurate with the cost associated with either extensive modifications or annunciator system replacement.
The original HED that identified this issue was one of a set of issues addressing noise in the control room. Although installation of a silence feature would assist in reducing noise from spurious alarms, it was demonstrated by a recent sound level survey that the overall noise level in the control room continues to be within the guidelines established by NUREG-0700. Therefore, the previously planned installation of a silence feature will not be implemented. It is anticipated that the final resolution of this item will not affect the previous conclusion of the NRC's SE.
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I IJ CA17E - CHARGING LINE FLOW INDICATORS Reassessment Issue:
The range requirements of the charging line flow indicator was evaluated.
It was determined that a range of O - 200 g pm is required.
Reassessment
Conclusion:
The charging line flow indicator scales will be replaced with scales having a range of o - 200 gpm.
DESIGN CHANGE PACKAGE DETERMINATION Subsequent to transmittal of the CRDR reassessment, testing was separately conducted to determine the maximum flow rate through valve FCV-1122 with the RCS at normal operating pressure. Test data showed that the maximum flow rate of reactor coolant to pass through the charging flow control valve for normal operation (i.e., one pump running) was 138 gpm. Therefore, it has been concluded that it is not necessary to increase the charging line flow range from O - 150 gpm to O - 200 gpm to verify normal operating readings. It should also be noted that expansion of the square root
, scale range would increase the inaccuracies on the low end of the scale.
In addition, safety injection is manually initiated when RCS leakage reaches 150 gpm in accordance with the abnormal procedure addressing excessive RCS leakage. The operator can identify the maximum flow rate and, therefore, it is not necessary for the operator to have an expanded scale.
Finally, the scale will be modified to reflect minimum and maximum graduations in accordance with our labeling standard. The revised scale will show 40 gpm as a major graduation mark enabling the operator to clearly identify the 40 gpm minimum flow requirement.
Therefore, it is anticipated that this determination will not affect the previous conclusion of the NRC's SE.
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