ML19301C692
| ML19301C692 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 02/05/1985 |
| From: | Schwencer A Office of Nuclear Reactor Regulation |
| To: | Leonard J LONG ISLAND LIGHTING CO. |
| References | |
| NUDOCS 8502190120 | |
| Download: ML19301C692 (12) | |
Text
'
y
/* "Wg UNITED STATES
[ \\ p cj[fsh NUCLEAR REGULATORY COMMISSION W ASWNGTON. D. C. M555
- i y,
Docket No. 50-322 FEB 5 1985 Mr. John D. Leonard Vice President - Nuclear Operations Long Island Lighting Co.
Shoreham Nuclear Power Station North Country Road, P.O. Box 618 Wading River, NY 11792
Dear Mr. Leonard:
SUBJECT:
EMERGENCY DIESEL GENERATOR LOADING -
SHOREHAM NUCLEAR POWER STATION As part of its evaluation of the adequacy of the TDI Emergency Diesel Generators (EDGs) at Shoreham, the NRC staff reviewed the possibilities of operator error causing the EDGs to be loaded in excess of 3300KW, the " qualified load."
Based on our review to date, we believe that you have not performed an adequate operational evaluation or analysis of the effectiveness of the procedures to be relied upon, e r of the instrumentation to be used, to limit operator error.
In addition, the training program for this issue had not been developed, much less implemented at the time this review was done (mid-January, 1985). Based on the enclosed concerns, it does not appear that an adequate basis exists for concluding that procedures and training will prevent operators from unnecessarily loading the diesels above 3300KW, as stated in your letter, to H. R. Denton, dated November 19, 1984.
In addition, we feel there are a number of procedure-related problems that may increase, rather than reduce, the likelihood of operator error.
Our specific coacerns on the procedures. training, and instrumentation are enclosed. Acceptable resolution of thest concerns is reovired before we can determine whether or not procedures and tra ining are an adequate substitute for design changes or testing of the EDGs for this issue, Although we received copies of several revised procedures on January 29, 1985, we could not perform a comprehensive review of them in time to file testimony with the ASLB on February 5.
Accordingly, stme of the enclosed concerns may have already been corrected.
If you have any questions, please contact Mr. R. Caruso 301-492-8392.
Sincerely,
/ -
((f'W2ff0&
/-
e5g2Qg@0$00 0
2 A. Schwencer, Chief PD PDR Licensing Branch No. 2 g
Division of Licensing
Enclosure:
As stated
....._m.._~
,..,,,; y g..
x.
SHOREHAM (1)
Lawrence Brenner, Esq.*
Stephen B. Latham, Esq.
Administrative Judge John F. Shea, III, Esq.
Atomic Safety & Licensing Board Twomey, Latham & Shea U. S. Nuclear Regulatory Comission Attorneys at Law Washington, DC 20555 P. O. Box 398 33 West Second Street Dr. George A. Ferguson Riverhead, New York 11901 Administrative Judge School of Engineering Atomic Safety & Licensing Howard University Board Panel
- 2300 6th Street, NW U. S. Nuclear Regulatory Comission Washington, DC 20059 Washington, DC 20555 Dr. Peter A. Morris
- Administrative Judge Atomic Safety & Licensing Appeal
~
Atomic Safety & Licensing Board Board Panel
- U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Comission W,ashington, DC 20555 Washington, DC 20555 Alan S. Rosenthal, Esq., Chairman
- Gary J. Edles, Esq.*
Atomic Safety & Licensing Appeal Board Atomic Safety & Licensing U. S. Nuclear Regulatcry Comission Appeal Board Washington, DC 20555 U. S. Nuclear Regulatory Comission i
Washington, DC 206E5 Howard L. Blau, Esq.
Gerald C. Crotty, Esq.
217 Newbridge Road Ben Wiles, Esq.
Hicksville, New York 11801 Counsel to the Governor Executive Chamber W. Taylor Reveley III, Esq.
State Capitol Hunton & Williams Albany, New York 12224 707 East Main Street P. O. Box 1535 Herbert H. Brown, Esq.
Richmond, Virginia 23212 Lawrence Coe Lanpher, Esq.
Karla J. Letsche, Esq.
Howard A. Wilber*
Kirkpatrick, Lockhart, bill, Atomic Safety & Licensing Appeal Board Christopher & Phillips U. S. Nuclear Regulatory Comission 1900 M Street, NW - 8th Floor Washington, DC 20555 Washington, DC 20036 Eleanor L. Frucci, Esq.
Leon Friedman, Esq.
Atomic Safety & Licensing Board Costigan, Hyman & Hyman U. S. Nuclear Regulatory Comission M0 Mineola Boulevard Washington, DC 20555 Mineola, New York 11501
~
SHOREHAM(1) 2-James B. Dougherty, Esq.
Mr. William Steiger 3045 Porter Street, NW Acting Plant Manager Washington, DC 20008 Shoreham Nuclear Power Station P. O. Box 628 Wading River, New York 11792 Fabian G. Palomino, Esq.
Special Counsel to the Governor Executive Chamber - State Capitol MHB Technical Associates Albany, New York 12224 1723 Hamilton Avenue - Suite K
' San Jose, California 95125 Edward M. Barrett, Esq.
General Counsel Hon. Peter Cohalan Long Island Lighting Company Suffolk County Executive 250 Old County Road County Executive / Legislative Bldg.
Mineola, New York 11501 Veteran's Memorial Highway Hauppauge, New York 11788 Mr. Brian McCaff rey Long Island Lighting Company Mr. Jay Dunkleberger Shoreham Nuclear Power Station New York State Energy Office 4
P. O. Box 618 Agency Building 2 North Country Road Empire State Plaza Wading River, New York 11792 Albany, New York 12223 Marc W. Goldsmith Ms. Nora Bredes Energy Research Group, Inc.
Shoreham Opponents Coalition 400-1 Totten Pand Road 195 East Main Street Waltham, Massachusetts 02154 Smithtown, New York 11787 Chris Nolin Martin Bradley Ashare, usq.
New York State Assembly Suf#olk County Attorney Energy Comittee Lee Derinison Building 626 Legislative Office Building 4
feteran's Memorial Highway Albany, New York 12248 houppauge, New York 11788 Ezra I. Bialik, Esq.
Ken Robinson, Esq.
Assistant Attorney General New York State Departnent of Law Environmental Protection Bureau 2 World Trade Center - Room 4615 New York State Department of Law New York, New York 10047 2 World Trade Center New York, New York 10047 Resident Inspector Shoreham NPS, U. S. NRC Post Office Box B Rocky Point, New York 11778
- m..
-m,
RE0 VEST FOR ADDITI0f'AL INFORMATION SHOREHAM NUCLEAR POWER PLANT EMEPGENCY DIESEL GENERATOR LOADING The NRC staff has conducted a review of the applicable Shoreham operating procedures, training program, and instrumentation that relate to operation of the TDI Emergency Diesel Generator (EDGs). The following procedures were evaluated by desk-top review:
Level Control SP29.023.01, Rev. 4 Loss of Offsite. Power SP29.015.01 Loss of Coolant Accident Coincident with a Loss of Offsite Power SP20.015.04, Rev. 0 Emergency Diesel Generators SP23.307.01, Rev. 12 Main Control Room - Conduct of Personnel SP21.004.01, Rev. 7 Loss of Instrument Air SP29.016.01, Rev. 4 Emergency Shutdown SP29.010.01, Rev. 4 An onsite inspection of plant instrumentation and training programs relevant to EDG loading was conducted by representatives of the NRC on January 16 and 17, 1985. The NRC staff will evaluate the responses to the following requested information to detemine if the licensec has perfomed an adequate 3
evaluation or analysis of the acceptability of relevant training and procedures.
In addition, the NRC will evaluat-e the licensee's response to determine the adequacy of the training, procedures and hardware for providing reasonable assurance that the procedures, training and instrumentation will not contribute to, and will serve to minimize, the likelihood of an operator error that would result in an overload of the EDGs.
GENERAL 1.
For-a postulated Loss of Offsite Power Coincident with a Loss of Coolant Accident (LOOP /LOCA) at least five procedures appear to be used simultaneously. These are Level Control - SP29.023.01, Emergency Shutdown - SP29.010.01, Containment Cnntrol - SP29.023.03, Loss of Offsite Power - SP29.015.01, and Loss of Coolant Accident Coincident with a Loss of Offsite Power - SP29.015.04, a.
Explain how the operators are to physically manage these procedures.
b.
Explain how the operators establish priorities between the various procedures, and between the necessary actions contained in the various procedures.
c.
What evaluations have been performed to determine the operators' capacity to rianage the necessary procedures, including correctly prioritizing procedures and actions?
. ~.,,
I
. 2.
The procedures evaluated call for stopping unspecified loads before starting others to limit the possibility of diesel generator overloads.
What means are provided to allow the operators to determine priority loads, and to keep track of which loads are stopped and which ones are running? For loads which are stopped, what parameters must be monitored to alert operators that loads must be restarted?
3.
Based on the information that was provided by the licensee and the information evaluated during the onsite inspection, it does not appear that an acceptable procedure and training program has been developed to address the EDG loading issue. This has led the staff to question the basis for the licensee's determination that the procedures and training will keep the EDGs from exceeding 3300KW.
At the time of the onsite inspection, the licensee had not started to develop a training program for the issue. There has apparentl in-depth evaluation or analysis (including Job Task Analysis) y been no of the actions necessary to keep EDG load less than 3300KW within the context of the procedures used during execution of the actions.
In addition, there is no evidence that the licensee has developed or conducted an in-depth evaluation of operator or team performance, and of their capability to 4
accomplish the necessary actions without error. This evaluation should have included an operational evaluation under realistic conditions with consideration for the uncertainty and stress that face operators during a LOOP /LOCA event. Therefore, LILC0 must:
a.
Develop a program for training the operators on the concern of maintaining EDG load less than 3300KW during a LOOP /LOCA, including the procedures which address this concern. Provide the staff a description of the training p aogram for control room and auxiliary operators.
b.
Perform an evaluation, including detailed analyses if necessary, to determine if the procedures and training are adequate to keep the EDG loading less than 3300KW during a LOOP /LOCA. Provide the staff a description of the evaluation and its results. The evaluation needs to include real-time evaluation of control room personnel and auxiliary operators.
4 There are etTrently no active means to alert the operators that the EDG load limit is either being approached, or that it has been exceeded.
Describe the means for alerting the operators that the EDG load limit is being approached, and to alert the operators that the EDG load limit has been exceeded.
5.
The best reading accuracy that can be obtained on the installed EDG KW meter is 50KW assuming the operators are at normal reading distance.
Thus, before any load less than 100KW is started, EDG loading, as
-,3
.m
, indicated on the meter, will need to be reduced to at least 3200KW, due to the inability to accurately determine EDG loading. Describe the impact that the readability of this meter has on the actions specified in the relevant procedures.
6.
Describe the means to be used to highlight the EDG c,alified load limit on the EDG KW meters.
7.
There is a general lack of consistency and integration between the procedures to be used during a LOOP or LOOP /LOCA event. This is evidenced in the operation of CRD and RHR/LPSI pumps. The Level Control procedure calls for use of the CRD pumps as one of the primary means of level control; the Loss of Coolant Accident Coincident with a Loss of Offsite Power procedum -awac the CRD pumps to be off if EDG load is found to be above 3300KW; while the ? oss of Offsite Power procedure calls for starting a CRD pump. None of the listed procedures, which are all implemented concurrently on a LOOP /LOCA., identify to the operators that these conflicting requirements exist, nor are any criteria for prioritization identified for the operators. A similar situation exists in the Level Control and Loss of Instrument Air Procedures for LPSI/RHR pumps.
a.
Describe the analyses performed to identify the necessary priorities and the method used for identifying all procedures and conditio:.s for which similar conflicts may exist for a LOOP or LOOP /LOCA.
b.
Describe the means by which the operators are alerted to these conflicts during performance of an individual procedure.
c.
Describe the evaluation or analysis performed to determine that the operators are able to operate the equipment in the specified priority without error.
, Level Control - SP29.023.01 1.
Page 2, Step 3.2 - This step lists the systems to be used to restore and maintain RPV water level. The second system listed (Step 3.2.2) is the CRD system which, if operated under LOOP /LOCA conditions and assuming automatic EDG loading as listed on FSAR Table 8.3.1-1, would cause the EDGs to be overloaded. The procedure needs to address reducing EDG loads to allow sufficient mergin for running the CRD pumps before the CRD pumps are started. Any such modification needs to address the specific safety loads (or the criteria to be used in selecting the safety loads) to be stopped to allow the CRD pumps to be started. The parameters which must be monitored during the period of time and the conditions which require restart of these loads need to be identified to the operators.
2.
Pace 3, Step 3.9 - Since this is the last step in the procedure, no following step exists in this procedure which would call for operating non-safety-related loads. The purpose of this step is unclear and should be deleted, moved, or its application explained.
- ~,
^
- 4.-
~
toss of Coolant Accident Coincident with a Loss of Offsite Power -
SP29.015.04 1.
The purpose and operational effectiveness of having a separate procedure to deal with this specific combination of events is not clear. The actions taken in this procedure deal exclusively with verifying that all equipment that does not automatically connect to the diesel generators for a LOOP /LOCA is in fact not operating. Explain the analysis or evaluation performed to investigate and justify the impact on other competing operator responsibilities, and on the operators' ability to execute all necessary concurrent procedures.
2.
Page 2, Step 4.1 -
a.
A number of the listed loads have no indication available in the control room, and the sortrols for these and a number of other listed
'oads are outside the control room. This adds significant concerns regarding completion of the step in a timely manner, accessibility of the necessary controls, adequacy of available lighting under the event conditions, and the impact of these actions on the watch engineers' attention to plant safety p.arameters. Describe any existing or planned provisions to address these concerns and the
+
evaluation performed to determine whether or not the necessary actions can reasonably be accomplished.
b.
This step, and the procedure in general, does not addrass the action to be taken if the listed loads are not running, and the diesel generator loading is still in excess of 3300KW. Specific actions to deal with this condition are needed.
3.
Page 2, Note before Step 4.1.1 -
a.
This note contains an action step. The note should be reworded to not require an action, or be incorporated into an action step.
b.
The need for checking the size of the load in this step is unclear, since the instruction is to stop the equipment regardless of its load. Explain what is intended by the action in the note, and why it is necessary.
4 Pace 2, Substeps of Step 4.1 -
a.
The entire nunber should be shown for each substep to be consistent with the numbering scheme in other procedures.
b.
A place-keeping aid needs to be provided for each load to allow the operators to mark off each load as it is checked or de-energized.
. 5.
Page 2 Step 4.1.1 - The terminology used in this step, "RBCLCW Pump," is inconsistent with the teminology used in SP29.015.01, "RBCLCW Circ.
Pump." The two procedures need to be made consistent.
6.
Page 4. Steps 4.2 and 4.3, and Caution - The sequence of these steps appears incorrect. The operators need to be warned, and need to detemine that adequate load margin exists before irstructing the watch engineer that loads may be added.
7.
Page 4 Caution before Step 4.3 - This caution is formatted differently than the caution in SP29.015.01.
In addition, there is insufficient contrast between the formatting of notes and cautions throughout the procedures. The cautions need to be refomatted, and a means needs to be used to highlight cautions to the operator which contrasts cautions fom
~
notes and from the steps.
8.
The overall femat of this procedure is inconsistent with the format of Level Control SP29.023.01. The procedures should have a consistent format, or the reason for the difference needs to be acceptably justified.
2 9.
The femat of conditional statements (e.g., IF... THEN) are inconsistent
+
between this procedure and Level Control SP21T 023.01. The procedures should use a consistent fomat, or the reason for the difference needs to be acceptably justified.
Loss of Offsite Power - SP29.015.01 1.
Pages 1 and 2, Note before Step 4.1 - This note is split between two pages, which may cause a portion of the note to be missed or misinterpreted. The note, and notes and cautions in general, needs to be wholly contained on one page, and be on the same page as the step to which they apply.
This note contains an action and is independent of other adjacent steps.
The note needs to be rewritten as a note without requiring an action, or else the action portion needs to be rewritten as an a."_ ion step.
2.
Page 2, Step 4.1 - This step calls for observation of parameters, but does not provide instructions to correct any honormal conditions that are found. This step needs to address correction of any abnomal voltage or frequency observed.
3.
Page 2, Caution before Step 4.2 -
a.
This caution is formatted differently than the caution in Loss of Coolant Accident Coincident with a Loss of Offsite Power SP29.015.04.
A consistent format for cautions needs to be used in all emergency procedures.
, b.
The caution contains an action step that calls for removal of other eouipment from service prior to adding non-safety loads. With the current projected loading of all three diesel generators, safety loads will need to be removed before any load can be manually added.
The procedure needs to provide acceptable guidance on how the operators are to determine which safety loads are to be removed before non-safety loads are added.
Provide the analyses or evaluation performed to determine which safety loads can be removed r
under what conditions to allow which expected non-safety loads to be added.
In addition, the portion of this caution requiring action to be taken needs to be rewritten as an action step.
4 Page 2 Step 4.2 - As currently worded, this step requires no definitive
~
action. The step should be reworded in the imperative mode.
5.
Page 2, Step 4.4 -
For a LOOP /LOCA,(with the listed loads running in addition to the a.
automatic loads assume none are de-energized), provide the actual (or if not available, the calculated) loading on all three diesel generators.
b.
This step addresses action for three diesel generators running. What is the expected action if only two, or one, diesel generator is running? The procedure needs to be modified to address the appropriate conditions, c.
The operators are instructed to check Appendix 12.1 for load levels of individual components:
(1) For Step 4.4, why are the load levels not provided in the procedure itself since specific components are designated for operation? This would reduce the procedure transitions, and reduce the complexity of actions and likelihood for error.
(2) The power supply and load level for the following loads are not listed in Appendix 12.1 - Main Turbine Emergency Bearing Oil Pump, RFPT Standby Lube Oil Pump, RFPT Emergency 011 Pump, Reactor Recirculation MG Set Lube Oil Pump, Reactor Recirculation MG Set Emergency Lube Oil Pumps.
If Step 4.2 is followed, these loads will nee r be started. The power source for these loads need to be spec lfied, EDG loading (if uppropriate, since these appear to be DC power loeds) for these loads need to be listed, and/or the step needs to be modified to have these loads running when necessary.
(3) Step 4.4.2 addresses " Bearing Lift Pumps," while Appendix 12.2 lists ' Main Turbine Bearing Lift Pumps." If these two listings are in fact the same, they should be labeled consistently with each other and with the control room label designation.
m m
., d.
This step includes label alpha-numerics.
If this information is importar', Appendix 12.1 needs to be modified to include these designations.
e.
The phrase "as a minimum" implies that any other equipment in the plant that may be operating is a satisfactory situation. Reword to cla rify.
6.
Page 2, Step 4.4.4 - This step contains a confusing combination of the logic tems "and" and "or."
As written, the D Service Water Pump could ie the only pump running and the logic step would technically be satisfied.
In addition, Step 4.4 calls for the listed equipment "as a minimum." If this is true, having all four service water pumps running
~
would be an acceptable condition and the logic terms are unnecessary.
State what is intended, and clarify the existing wording.
7.
Page 3 Step 4.4.5 - This step addresses "RBCLCW Pumps," while Appendix 12.2 lists "RBCLCW Circ. Pumps."
If these two listings are for the same equipment, they need to be labeled consistently.
8.
Page 3 Step 4.4.5 and 4.4.6 - These steps do not list the alpha-numeric control room label designation as is used'in Steps 4.4.1 through 4.4.4.
+
The procedure needs to consistently address all equipment.
9.
Page 3, Note after Step 4.4.5 -
a.
This note requires an action based on a condition, and needs to be incorporated into an action step.
b.
The note needs to be clarified to state which pumps are being referenced.
c.
Notes need to be placed before the step to which they apply.
- 10. Page 3, Step 4.4.6 - To reduce the possibility of confusion, or of not considering a particular load, when calculating total diesel generator load, this step needs to list the specific equipment in each train.
- 11. Page 3 Notes after Step 4.4.7 -
a.
Notes need to be placed before the step to which they apply.
b.
The first note requires an action and needs to be incorporated into the procedure as an action step.
., c.
The first note, in conjunction with Step 4.4.6, is inconsistent with Step 4.4, which states that the listed equipment "as a minimum" be operating, which would allow operation of two filter trains and four RBSYS/CRAC chilled water systems. Provide the allowable and intended (if different from allowable) equipment conditions, and clarify the step (with the first note a step, if still required).
2 d.
The second note is inconsister.t with the instruction provided in Step 4.2, SP29.015.04, which requires Watch Engineer direction before energizing any additional emergency powered equipment. The reason for imbedding the addition of equipment loads to the diesel generators is not clear and it is not clear what the relationship of this note is to adjacent notes or action steps. Therefore, (1) provide definitive direction regarding adding additional emergency powered equipment, including appropriate personnel for authorizing the addition; (2) place the action in a location in the procedure appropriate for the action; and (3) provide criteria in the procedure for deciding what is needed and what is not needed.
- 12. Page 3, Step 4.5 - The Level Control procedure calls for possible use of these pumps, while SP29.015.04 calls for these pumps to be off, and now they arc beiro turned back on again. The conditiens under which the CRD pumps are to be operated, including priorities over other safety equipment, need to be determined, and the actions in these three procedures that govern use of the CRD pumps need to be coordinated to meet the priorities. Provide the evaluation or analysis performed to establish acceptable priorities and conditions for CRD pump operation, including priorities for diesel generator loading. Modify the appropriate procedural steps in the appropriate procedures to address the priorities and conditions.
- 13. Page 3. Step 4.6 -
a.
This step states that RPS MG sets are to be restarted "when practical." The need for adequate load margin on the diesel generators is a consideration that needs to be explicitly factored into this step.
b.
This step abbreviates "RPS," while Appendix 12.1 does not.
Nomenclature needs to be made consistent.
Id. Page 4, Step 4.10.7 - This step omits the word " spent" as used in Appendix 12.1.
Be consistent.
- 15. Pages 6 and 7 (Appendix 12.1) - The equipment listing for "TSC Air Cooled Condenser" is split between two pages.
Listings shuld be co..ipleted on a page, and not split in this manner.
'b
, 16. Appendix 12.1 - The format of the tabulated values makes it very difficult to associate the specific numeric loading values with their respective loads. The table needs to be acceptably reformatted to make the values easily relatable to the proper equipment.
Emeroency Diesel Generator Procedure - SP23.307.01 1.
Page ll, Step 8.1.4.5, and Page 13, Step 8. 1.5.4 - These steps provide two different instructions on when to close the EDG breaker during paralleling operations, and are inconsistent in providing instructions regarding checking that load is picked up by the EDG.
Explain the reason or justification for the difference in closing position used in the two steps, or make the steps consistent, and. ovide justification for the I
method used. Modify the step (s) to provide consistent instructions on what to observe when the breaker is shut.
2.
Sections 8.1.4 and 8.1.5 need to be modified to appropriately infom the operators of the EDG qualified load limit.
3.
Page 13 Step 8.1.5.3 and 8.1.5.4 - These steps instruct the operators to parallel the EDGs and pick up load on the EDGs. During an emergency condition (e.g., a LOOP /LOCA) with speed droop set at zero, the EDGs may pick up loads significantly above 3300KW. Describe the likelihood and consequences of this action given the current procedures, and modify the procedure, if necessary, to ensure a controlled load transfer during this paralleling operation.
4.
Appendix 12.4, Operational Surveillance Log Sheets, has readings that are to be taken every half hour while the EDGs are in service. The log sheets need to be modified to include the operational ranges for the various readings contained in Steps 8.1.2.7 and 8.1.3.4 of the procedure.
5.
The EDG procedure needs to be modified to provide consistent instructions for use of the installed synchronizino lamps, which are to be used in the case of synchroscope malfunction.
.. -. _ _