ML19344A332

Second Round Questions Re Environ Qualification of safety- Related Equipment,Response Time Testing & post-accident Monitoring Equipment Requirements

ML19344A332
Person / Time
Site:	Midland
Issue date:	03/20/1979
From:	Office of Nuclear Reactor Regulation
To:
References
NUDOCS 8008120671
Download: ML19344A332 (11)

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. MIDLAND SECOND ROUND QUESTIONS 031.38 The response to Question 031.15 indicates that the pressurizer heater controls may.-.not be qualf.' led as safety related equipment.

However, the response to Question 031.27 states that "The Midland plant design will be revised to include Class 1E redundant

. pressurizer heater controls and pcwer supplies." We require that you resolve this inconsistancy and provide the information requested in Question 031.15.

031.39

.(A) The response to Question 031.19 refers to FSAR Section 7.1.2.5 and Section 7.1.2.5 refers to the response to Regulatory Guide 1.118 listed in Appendix 7A'of;the FSAR.

The response to Regulatory Guide 1.118 appears to be in conflict with the.FSAR response to Regulatory Guide 1.22.

The staff has determined that the FSAR response to Regulatory Guide 1 22 is acceptable, therefore, please show that the recommendations of Regulatory Guide 122 are still satisfied or justify any differences.

(B) ?Also item (b) of the test program, specified in accordance with Regulatory Guide 1.118, states that there will be no periodic response time veritication for some of the sensors.

This is unacceptable:to the staff.

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031.391 Position C.12 of Regulatory Guide 1.118 sca' es:

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" Response timejtesting of all _ safety system equipment per se is not. required-if, in lieu of response time. cesting, the response time of safety system equipment is verified by functional testing and/or calibration checks where it can be demonstrated that changes in response-time be-yond acceptable limits are always accompanied by changes in performance characteristics that are detectable during these routine periodic func-tional tests and/or calibration checks."

This is an acceptable w >. to verify response time when testing cannot-be readily performeu. Therefore, we require that provisions and procedures for response time verification be provided in the Midland design for all safety related systemsincluding the sensors.. Provide this information or justify any differences.

(C) The response to position C14 states that temporary test setups and jumper wires will be used for response time testing.

The staff is concerned that these test methods can lead to unsafe plant conditions.

When systems are modified with jumpers there is a possibility that the jumpers may-not all be removed when the testing is complete. There have been several cases _where jumpers were.

not removed and the action or safety related systems was jeopardized.

We therefore require that a procedure, with necessary drawings,

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bi;provided for each circuit and parameter where jumpers will be used for testing. This procedure.should specify the provisions and i

the steps taken to assure that the system has been returned to the normal _ mode of ope *ation'and that all temporary equipment has been

-removed from the circuit. We also require that each circuit and

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031.39

. parameter requiring jumpers be identified in a list in the FSAR.

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We request a copy of.the procedtres, describing all circuit alterations required toLtest.two parameters. The selected parameters should repre-

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sent those requiring the most extensive modifications.

All other procedures should be made available for-the staff's review during the-:ite' visit.

We also request verification that the approved procedures will be followed'during normal -response time _ testing.

031.'40 The response to Question 031.20(3) is too general to satisfy our 2

concerns. We require that the following qualification information also be provided for each type of isolator used in the Midland design:

2.

Description of the isolator (Relay......etc.)

b.

Manufacturer.

c.

Manufacturer's type number.

d.

Manufacturer's model number.

e.

Test plan.

f. --Test setup.

g.

Test procedures.

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h.. Acceptability goals and requirements.

.i. ' Test results.

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.4 031.41

.The response to Question 031.25 does not satisfy all ~of our. concerns.

The. response states that the control room fresh air intake monitors

= will be environmentally qualified as discussed in FSAR Table 3-11-4, Test 17. ~ Test 17 states that environmental testing is not considered-necessary.

L's rcquire t'.at all safety related equipment, including the fresh air-intake monitors be environmental qualified, even if it is

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not subject-to accident conditions. Provide ~your modified design to satisfy this position.

l Also the ~ response to question 031.25 states that test methods for -

seismic L esting will be provided after March 1979 and the test results t

will not be provided until after September. Wa cannot complete our review until this information has been provided.

031.42' The response to Question 031.31 does not provide the requested information.

It is our position that all information requested in Question 031.31 must be provided'in1the Midland FSAR for our review.

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This~ includes P&ID's, electrical' schematic diagrams and conformance to all safety requirements such as IEEE-STD-279-1971, IEEE-STD-323,

. IEEE-STD-344-1975,- Regulatory Guides.1.75,11.97,1.118 and Branch

. Technical Position No. 23.

031'.43 Position C4d(2) of Regulatory Guide 1.95 states that "The system response time, which incorporates the detector response time, it -

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value closure time and associated instrument delays, should be i

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equal,to 'or less than the required isolation time."

iThis guide.also recommends that verificationitesting and calibration l'

of the chlorine detector 'and verification testing of the system

-response time should be conducted at six month intervals." -There

!is no response to these recommendations in FSAR Section 3A.

Further, the response to Regulatory Guide 1.118, Section C.12 l

states that no periodic response time verifications will be performed l

an the sensors for the toxic gas analyzers. We do not agree that this is an acceptable approach since operation of the Control Room j

Isolation System (CRIS)-relies on these sensors to maintain a safe-control room atmosphere in the event of inadverted release of toxic-l.

gases.

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We require that the applicant establish a ' method' to be used to 1

periodically demonstrate that the control room isolation system will perform its function within acceptable time limits.

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031.44 From our_ review of FSAR1 Table 3.11-1, we have determined that the

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following Class lE' equipment has not been included for environmental p

.' qualification:

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1. -Service water, motor operated isolation valves, 2101052 and 2M01856. These valves shown on FSAR Finora 0.? ? are " nit 2 dieseligenerator' cooler service water valves.

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Service water, motor. operated isolation valve, 2M01947. Also cont.

there are no qualification tests specified for any of the other i

.~ otor operated valves listed.on Page 18 or FSAR table 3.11-1.

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-These valves are shown on FSAR Figure 9.2-3.

3.

Auxiliary feedwater steam supply valves,1M0-3831, 2M0-3931, 1SCV-3831 and 2SCV-3931. These. valves are.shown on FSAR Figure 10.4-10 and -13.

4 Electro Hydraulic feedwater isolation valves,1XV

3866A1, lXV - 3866B1, 2XV - 3966Al and 2XV - 3966Bl. These valves are.shown of FSAR Figures 10.4-10 and -13.

5.

Instrumentation for automatic switchover of auxiliary feedwater pump suction from the condensate storage tank to the service water system.

6.

Level sensors and transmitters located in the ultimate heat sink pump pit used for protection of the service water. pumps.

7.

Sensors and level transmitters for the component cooling water (CCW) surge tank which are used to isolate the non-seismic portion of the CCW system.

8.

Motor operate valves, IMO -0102-1,1M0-0102-2, 2M0-0202-1 and 2MO-0202-2.. These valves are listed on FSAR Table 3.11-1 Sheet 2 but no qualification test has been specified.

9.

Reactor building pressure transmitters IPT7200 A, B, C and 0 l

shown on FSAR Figure 7.3-2.

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. Describe the. qualification program usedte verify that this equipment will-perform its safety function when required. See

Question 031.13 _for-specific -details required by the staff.

031.45 Describe the instrumentation and controls used for automatic switchover of the auxiliary feedwr

• pump suction from the condensate storage tank to the service water system.

The description should discuss-how this eg'uipment conforms to all safety requirements such as IEEE-279-1971, IEEE-308-1974, IEEE-323-1971 and IEEE-344-1975 The -response should: include all electrical drawings.

l 031.46 The response to-Question 031.36 is not acceptable to the staff.

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The response states "should problems arise which are not antic' pated, administrative action will be taken to curtail the use of such I

equipment in all but the most essential situations in the affected areas."

l Radio frequency interference (RFI) may cause equipment to stop or start i t any time and administrative action may not be sufficient f:

to prevent exceeding safety limits. Therefore, we require that the applicant provide a basis for establishing the areas where two way communication devices may be used in the Midland plants.

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i require that:the procedures, the results of tests or a description of I

other means used to demonstrate that safety related systems will not

be compromised by RFI, be included in be FSAR. -Provide this informa-i ti on. -

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- '031;47-FSAR 'Section 3.11.5, Section 6.1, Table. 3.ll-2 and Table 3.ll-3 indicate that pH is the only chemicalEparameter of concern for -

environmental' qualification of safety related equipment. Provide justification that this is the only chemical parameter which may

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-Class -lE equipment. ' This justification should. include environments both inside and outside of - the containment following all DBA (Design basis accidents).

If other chemical parameters are identi-fied then-we require that they be included in the environmental qualification program.

Describe how the all chemical effects have been implemented in the Midland environmental qualification program.

031.48' Question 031.13 identified groups of Class lE equipment for which

specific environmenta: qualification information was requested.

.Please add the following equipment to this list,'

(a) connectors

.(b) = terminal - blocks and (c). fans k

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031.49-

'Some types of safety related instrumentation' and control equipment

. rely on a hermetic - sealj for: protection against moisture.. Moisture-can enter the compo'nent through a defective hermetic. seal when the component is subjected to a highly humid environment. These seals are subject to. damage during installation and maintenance e ation.

We ~ require -that the Midland design -include a monitoring program to assure that all safety related components, protected by hermetic seals will continue to function throughout the life of the plant and during all accident conditions. Provide a description of this monitoring program.

031.50 The' response to Question 031.30 is not acceptable for the following reasons:

(a) it is'a staff position that all recorders required for post accident monitoring must.be qualified to operate within acceptable limits before and-after a seismic event. -This is a' requirement to-satisfy IEEE Standard 279-1971 specified in Branch Technical Position No. 23 listed in Appendix 7A of the Standard Review Plan.

Provide a commitment to this position.

.(b)' Listed below are key parameters which should be included for post accident monitoring:

(1) Condensate storage tank level (2) High pressure injection -flow i

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-031.50 (3) Low prassure in,jection flow-

(4)_ Pressurtur pressure

'(5) Pressurizer level (6) : Reactor coolant temperature

.(7) Reactor _ building emergency sump level

'(8) The' enabling alarm and the transient pressure alarm for the overpressure protection system for low temperature operations indication (9)- Post-LOCA " Dump-to Sump" flow (10) Reactor building temperature

-(11) Reactor building emergency sump water temperature

-(12) Fan cooler flow rate and associated cooling water flow rate; and' (13)' Valve position for all power operated containment isolation valves (See FSAR Table 6.2-28).

It is the' staff's position that these parameters be included for post accident monitoring. Provide this information.

If parameters have been excluded, provide the basis for not ' including them.

031.51

.The response to Question 031.23 states' that ultrasonic flow transmitters will be used in the' reverse feedwater flow monitoring system.

The use' of ultrasonic flow transmitters to initiate actuation of safety related systems is unique. We therefore require that the applicant prov'ide a complete description and justification for use of this method' of flow detection.

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.!r-,T Th'e description should include vendors literature, specifications, 031.51 and information used to establish the adequacy.of _ these devices.

l-The description should_ completely describe the principles of.

operation.

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We also require that-the applicable _ revisions cf all_ referenced l

standards and regulatory guide be-specified, in the description.

031.52 The response to Question 031.17'is unacceptable. We require the Midland plant satisfy items B1 and 84 of Branch Technical position ICSB No. 4.

Provide your modified design to satisfy this position.

'031.53 A recent 0IE Circular (No 78-19) identified a concern about a manual F-overide (By Pass) feature, incorporated in the design of safety L

related system circuits. We request that the applicant review all safety related circuits in the Midland design and identify all

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circuits that incorporate a manual override feature.

For each case identified, we-request that the results an analysis be provioed L

to 'emonstrate that the override feature does not cause the bypass d

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of any other safety actuation signal and a description identifying how the design satisfies the requirements of IEEE 279-1971. We also request a description of the alarm system used to notify-the operator j

l of the bypass status and a-description of the procedures and adminis-trative controls required by the operator to maintain the plant in a j

safe condition.

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