ML19263C153
| ML19263C153 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 12/22/1978 |
| From: | Counsil W NORTHEAST NUCLEAR ENERGY CO. |
| To: | Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19263C152 | List: |
| References | |
| NUDOCS 7902080069 | |
| Download: ML19263C153 (2) | |
Text
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December 22, 1978 Eldon J. Brunner, Chief Reactor Operations and Nuclear Support Branch United States Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Penn.
19406 Gentlemen:
This is in response to your letter of October 23, 1978 which transmitted to us Inspection Reports 50-245/78-29 and 50-336/78-24.
With regard to your review of LER 50-336/78-16 concerning override of a containment purge valve isolation signal, you identified an area of concern on procedure preparation and an apparent deviation from the Unit 2 FSAR.
Details of your report and our corresponding responses are listed below.
A.
Concern on Procedures "Specifically, we are concerned that your procedure preparation, review, and issuing process could result in a procedure which fails to include consideration of the design of your containment purging control system in conjunction with a number of Limiting Cenditions for Operation contained in your Technical Specifica-tions, and thereby result in your unknowingly entering into Limiting Conditions for Operation Action Statements. While your containment purging procedure now appears to have been revised to include proper consideration of Limiting Conditions for Operation, please respond to this letter describing in detail the actions which you have taken or plan to take to assure that similar inadequacies do not exist in other procedures."
Response
7902080067 E We have reviewed our technicaT opecifications to identify similarly confusing areas of operability requirements, and none were identified.
In addition the specific area of signal overrides was reviewed and a standard precaution entered in all system procedures whose equipment responds to an accident signal.
This precaution prohibits overriding an equipment accident signal except for protection of equipment or personnel, compliance with operating procedures or if the equipment is not required for the mode.
No other action is considered necessary since in general the technical specifications are self explanatory, all procedures reference the applicable specifications, and the operators have been trained to reference the technical specifications during abnormal circumstances.
7N2Wd00
", hidsn J. Brunner, Chief (letter)
Page 2 B.
Apparent Deviation from FSAR.
"Another matter of concern is the design of the Engineered Safety Features Actuation System which does not appear to be in accordance with IEEE 279-1971, " Criteria for Nuclear Generating Station Protection Systems." This appears to be a deviation from Article 7.3.1.2.1, Section 7, Amendment 39 of the Unit 2 Final Safety Analysis Report."
Response
Individual Engineered Safety Feature (ESF) component (pump, valve, fan) bypass status is available in the Control Room through the indication of ESAS actuation alarm status and the individual component status on the Engineered Safety Equipment Status Panel, C0lX.
The only initiating condicion to permit bypass by override of ESF component, is an actual ESAS actuation signal, which actuation signal is annunciated on the main control board.
Once this condition exists, the individual ESF component control scheme has been provided with the capability to allow manual operation of the component to a condition other than :ts accident mode condition.
If tF 1mponent is placed, at this time, in other than its accident position, that condition is denoted on C0lX by extinguishment of a blue light for each affected ESF component.
Hence, a combination of an actuation signal (annunciated) and lack of the blue light for the respective actuated component is a positive indication the component has been bypassed with respect to the accident signal.
Where specific components have the capability to respond to two actuation signals (example, High Rad & CIAS), override or bypass when in receipt of one actuation signal will also result in bypass or override for the second condition.
Plant alarm identification information enables the operator to be fully aware of the additional actuation signals which have been bypassed in this event.
In order to increase the ada.inistrative controls associated with this indication, a shift surveillance procedure will be implemented by January 1,1979 to document ESF component bypass status and log any specific Technical Specification LC0's involved.
Since receipt of your letter, NNECo has received a letter from Robert W.
Reid, Chief, Operating Reactor Branch #4, DOR, dated November 29, 1978 with the subject " Containment Purging During Normal Plant Operation".
This letter requires a 30 day response end is to contain a discussion of NNECo's plans on purging during operation, results of a review of override circuitry and a schedule for development of any design or procedural changes imposed or planned.
We will forwara a copy of our response to that letter to you to be reviewed along with this letter.
Very truly yours, Northeast Nuclear Energy Company W. G. Counsil By:
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Vice President W. F. Fee Vice President
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