ML19320B176

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Denies 790323 Proposed Change 2 to Tech Specs to Alter Safety Features Actuation Sys Containment Radiation Instrumentation Requirement.Forwards Requests for Addl Info Re Bypass Capabilities of Engineered Safety Features
ML19320B176
Person / Time
Site: Davis Besse Cleveland Electric icon.png
Issue date: 06/24/1980
From: Novak T
Office of Nuclear Reactor Regulation
To: Roe L
TOLEDO EDISON CO.
References
NUDOCS 8007100006
Download: ML19320B176 (5)


Text

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UNITED STATES 8

NUCLEAR REGULATORY COMMISSION p,

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E WASHINGTON, D. C. 20555 June 24, 1980 Docket No. 50-346 Mr. Lowell E. Roe Vice President, Facilities Development Toledo Edison Conpany Edison Plaza 300 Madison Avenue Toledo, Ohio 43652

Dear Mr. Roe:

Your letter of March 23, 1979, proposed several changes to the Davis-Besse Nuclear Power Station, Unit No.1 Technical Specifications (TS).

In this submittal, proposed change number 2 would alter the Safety Features Actuation System (SFAS) Containment Radiation Instrumentation Requirements. Currently, your TS require that containment radiation instruments be operable in all modes of plant operation to initiate containment purge isolation and to ini-tiate the emergency ventilation system on a high radiation signal. Your pro-posed change would alter this requirement such that operability would no longer be required except when moving irradiated fuel, ma' King positive reactivity changes, or making core alterations while in Mode 6.

Your justification for the proposed chagge is that this signal is only a backup to the reactor coolant system low pressure and containment high pressure SFAS actuation signals, and that r.one of Final Safety Analysis Report (FSAR) accident analyses identify or take credit for this backup signal.

We have reviewed proposed change number 2 of your March 23, 1979, submittal and find that implementation of this change would be contrary to the staff's Branch Technical Position CSB 6-4, " Containment PurgingsDuring Normal Plant Operations".

In this technical position, one of the acceptanca criteria is that diverse signals should be provided to initiate isolation of the containment purge system. Speci-fically, high containment radiation, as well as safety infection actuttion and containment high pressure, should automatically initiate containment purge iso-lation. Therefore, proposed change number 2 of your March 23, 1979, submittal that would alter the SFAS Cnntainment Radiation Requirements is denied.

In a related matter, the staff is continuing a review of bypass and reset capa-bilities of engineered safety features for Davis-Besse 1.

The enclosure identi-l fies additional information required to comolete this review. You are requested l

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8007100006$

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Mr. Lowell E. Roe to provide a ' response to the items identified in the enclost re within 30 days of receipt of this letter.

Sincere'y, omas M. Novak, Assistant Director for Operating Reactors Division of Licensing i

Enclosure:

Request for Additu. 4 Information l

cc w/ enclosure: See next page l

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. Toledo Edison Company cc w/ enclosure (s):

Mr. Donald H. Hauser, Esq.

[J. S. Nuclear Regulatory rannission gesident Inspector s Office,

The Cleveland Electric

5503 N. State Route 2 379,9 9

inpa y Oak Harbor, Ohio 43449 3

p, 0. Box 0 Cleveland, Ohio 44101 Director, Technical Assessment Division Gerald Charnoff Esq.

Office of Radiation Programs Shaw, Pittman, Potts (AW-459) and Trowbridge U. S. Environmental Protection Agency 1800 M Street, N.W.

Crystal Mall #2 Washington, D.C.

20036 Arlington, Virginia 20460 U. S. Environmental Protection Agency r,

en y, r, and Hodge Federal Activities Branch 300 Madison Avenue Region V Office Toledo' Ohio 43604 ATTN:

EIS COORDINATOR 230 South Dearborn 3treet Mr. Robert B. Borsum Babcock & Wilcox Chicago, Illinois 60604 Nuclear Power Generation Division l

Suite 420, 7735 Old Georgetown Road Bethesda, Maryland 20014 Ohio Department of Health ATTN: Director of Health Ida Rupp Public Library 310 Madison Street 450 East Town Street Columbus-, Ohio 43216 Port Clinton,0hio 43452 President, Board of County Consnissioners of Ottawa County Port Clinton, Ohio 43452 Attorney General Cepartment of Attorney General 30 East Broad Street Columbus, Ohio 43215 Harold Kahn, Staff Scientist Power Siting Commission 361 East Broad Street g

Columbus, Ohio 43216 i

Mr Rick Jagger '

Industrfal Conunission State of Ohio 2323 West 5th Avenue Columbus, Ohio 43216

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i Mr, Ted Myers Ltcensing Engineer

' Toledo Edison Company Edison Plaza 300 Madison Avenue Toledo, Ohio' 43652

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REOUEST FOR ADDITIONAL'INFORMATION FOR BYPASS AN'd RESET OF ENGINEERED SAFETY FEATURES FOR DAVIS-BESSE 1 DOCKET NO. 50-346 1.

The information presented in your FSAR and your letters of December 13, 1978 and January 18, 1980, is not sufficient to deiermine i'f the following requirements are met for the safety signals to all Engineered Safety Features (ESF) equipment. Therefore, identify and. justify' all exceptions to the following:

Criterion 1 - In keeping with the requirements of General Design Criteria 55 and 56, the overridinga of one type of safety actuation s,ignal (e.g., radiation) should not cause the blocking.of any other.

type of safety actuation signal (e.g., pressure) for those valves that have no function besides containment isolation.

Criterion 2 - Sufficient physical features (e.g., key lock switches) are to be provided to facilitate adequate administrative controls.

Criterion 3 - A system level annunciation of the overridden status should be provided for every safety system inpacted when any override is active.

(See R.G. 1.47).

Criterion 4 - Diverse signals should be provided to initiate isolation

.of the containment ventilation system.

Specifically, containment high radi4 tion, cafety injection actuation, and containment high pressure (where containment high pressure is not a portion of safety in,jection actuation) should automatically initiate CVI.

Criterion 5 - The instrumentation and control systems provided to initiate the ESF should be designed and qualified as safety grade equipment, j

Criterion 6 - The overriding or resettingb of the ESF actuation signal should not cause any valve or damper to change position.

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In addition to responding to the general queation above, please provide the following specific information:

The following definitinns ars given for clarity of use in this evaluation:

a - Override: the signal is still present, and it is blocked in order to perform a function contrary to the signal.

b - Reset:

the signal has come and gone, and the circuit is being cleared in order to return it to the normal condi*. ion.

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2-(1)

Provide an "as built" tabulation of all Engineered Safety Features (ESF)/ Auxiliary Supporting Features (ASF) valves and dampers required to be operated automatically following an accidsnt.

This tabulation shouli include the following:

a.

Component designation b.

System served.

c.

Safety function (e.g., containment isolation, spray initiation) d.

Actuation signal sources e.

Reference to control circuitry (see 2.(3) below) f.

Indication whether or not the component safety function indicated in 2.(1) above can be defeated.through the use~

of a. manual override or bypass in ef ther the control' system or actuation signal system circuitry.

(2) For each marual bypass or override feature identified in 2(1) above, provide a description of the physical feature (s) provided to prevent inadvertant operation and to satisfy the requirements of IEEE Std. 279-1971, Section 4.14.

(3)

For each actuation signal system'and component actuation system identified in 2(1)d and 2(1)e above, incorporating a manual reset, override or bypass feature, provide a complete circuit description, including detailed pictorial information (i.e., as built circuit diagram, schematics, logics), sufficient to allow a thorough understanding of the operation of'such circuitry including the fundtion and effect of all control devices (e.g., relays, contacts, switches, diodes,etc.).

(4)

For each actuation signal identified in 2(1) above, identify the design standards, quality assurance requirements, and component qualification standards involved to ensure that the systems will perform their designated safety function upon demand.

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