ML20009A663

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Forwards Safety Evaluation & Technical Evaluation of SEP Topic VI-4,re Override of Containment Purge Isolation & Other Engineered Safety Feature Actuation Signals.Facility Meets Current Licensing Criteria
ML20009A663
Person / Time
Site: La Crosse File:Dairyland Power Cooperative icon.png
Issue date: 07/02/1981
From: Crutchfield D
Office of Nuclear Reactor Regulation
To: Linder F
DAIRYLAND POWER COOPERATIVE
References
TASK-06-04, TASK-6-4, TASK-RR LSO5-81-07-003, LSO5-81-7-3, NUDOCS 8107130452
Download: ML20009A663 (10)


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Docket No. 50-409 LS05-81-07-003 4

NW'l.Z 0 /SgN Mr. Frank Linder S-W-

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,( l m Lacrosse, Wisconsin 54601

Dear Mr. Linder:

SUBJECT:

SEP TOPIC VI-4, OVERRIDE OF CONTAINMENT PURGE ISOLATION AND OTHER ESF ACTUATION SIGNALS (LACROSSE)

The staff has determined that the scope of review and evaluation performed for multi-plant generic activity B-24 includes the electrical aspects of SEP Topic VI-4. Additional review and evaluation is, therefore, not required.

Enclosed is a copy of our current evaluation of the electrical portion of generic activity B-24 for Lacrosse. This assessment compares your facility, as described in Docket No. 50-409, with the criteria currently used by the regulatory staff for licensing new facilities.

Please inform us if your as-built facility differs from the licensing basis assumed in our assessment within 30 days upon receipt of this letter.

This safe,try evaluation is the staff's position regarding design of your facility 'in the subject area. With regard to the referenced topic, the staff has concluded your facility meets current licensing criteria.

Sincerely.

Dennis M. Crutchfield, Chief Operating Reactors Branch No. 5 Division of Licensing

Enclosure:

As stated cc w/ enclosure:

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.l fir. Frank Linder p

I cc Fritz Schubert,-Esq'uire U. S. Environmental Protection-Staff Attorney Agency Dairyland Power Cooperative Federal Activities Branch 2615. East Avenue South Regior. V Office La Crosse, Wisconsin 54601 ATTN:

EIS C0ORDINATOR 230 South Dearborn Street

0. - S. Heistand, J r.

Esquire Chicago, Illinois 60604 Morgan, Lewis & Bockius 1800 M Street, N. W.

Mr. John H. Buck Washington, D. C.

20036 Atomic Safety and Licensing Appeal Board U. S. Nuclear Regulatory Comission Mr. R. E. Shimshak Washington. D. C.

20555 La Crosse Boiling Water Reactor Dairyland Power Cooperative Dr. Lawrence R. Quarles P. O. Box 135 Kendal at Longwood, Apt. 51 Genoa, Wisconsin 54632 Kenneth Square, Pennsylvania 19348 J

'Ms. Anne K. Morse Charles Bechhoefer, Esq., Chairman l-Coulee Region Energy Coalition Atomic Safety and Licensing Board P. O. Box 1583 U. S. Nuclear Regulatory Comission La Crosse, Wisconsin 54601 Washington, D. C.

20555 La Crosse Public Library Dr. George C. Anderson 800 Main Street De~partment of Oceanography L Crosse, Wisconsin 54601 University of Washington l

Seattle, Washington 98195 U. S. Nuclear Regulatory Comission l

Resident Inspectors Office Mr. Ralph S. Decker l

Rural ' Route #1, Box 225 Route 4, Box 1900 Genoa, Wisconsin 54632 Canbridge. Maryland 21613 Town Chairman Thomas S. Moore Town of Genoa Atomic Saf ety and Licensing Appeal Board l

Route 1 U. S. Nuclear Regulatory Comission l

Genoa, Wisconsin 54632 Washingten, D. C.

20555 Chairman, Public Service Comission i

of Wisconsin j

Hill Farms State Office Buildino Madison, Wisconsin 53702 l

L Alan S. Rosenthal, Esq., Chairman i

Atomic Safety and Licensing Appeal Board U. S. Nuclear Regulatory Comission Washington, D. C.

20555 L

Mr. Frederick Milton Olsen, III 609. North lith Street Lacrosse, Wisconsin i

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EtiCLOSURE SAFETY EVALUATION REPORT LACROSSE OVERRIDE OF CONTAINMENT PURGE ISOLATIO!1 AfiD OTHER-ENGIllEERED SAFETY FEATURE ACTUATION SIGNALS

-i Introdaction

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Instances have been reported at nuclear power plants where the intended automatic closure of the containment ydrge/ ventilation valves during a postulated accident would not have occurred because the safety actuation signals were inadvertently overriden and/or blocked, due to design deficiencies.

These instances were determined to constitute an Abnormal Occurrence (#78-5). As a follow-up action, NRR issued a generic letter requesting each licensee to take certain actions.

Evaluation The enclosed report " Electrical, Instrumentation, and Control Aspects of the Overriden of Containment Purge Valve Isolation" (0386J) was prepared for us by EG&G, Idaho, as part of our technical assistance contract program.

The report provides their technical evaluation of the design compliance with URC-provided criteria.

It identifies one area where the ventilation valves do not satisfy our criteria.

The area of concern is that the containment is not isolated autcmatically when the core spray system is initiated manually.

However, the plant does g g vgt g g g g vel manual initiation of core spray, therefore the present The question raised by the contractor regarding GDC-56 will be covered by i

the me.:hanical system review being performed under SEP Topic VI-4.,

Conclusion j

The staff finds the present design for the electrical overrides and bypasses

,to be acceptable.

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7 SEP TECHNICAL EVALUATION TODIC VI-4 ELECTRICA!., INSTRUIENTATION, AND CONTROL ASPECTS OF THE OVFRRIDE OF CONTAIlNENT PURGE VALVE ISOLATION LA CROSSE BOILING WATER REACTOR 9

Docket No. 50-409 tiay 1981 Reli.ility ena stat 1s' tics Branch i

Engineering Analysis Division EG&G Idaho, Inc.

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CONTENTS

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. l.0 I NTR O D UC TIO N.............. -.............. 1 2.0 TVALUATION OF THE LA CROSSE BOILINC k'ATER REACTOR 2

2.1. Revi ew Gui del i nes.....................

2 2.2 Containmefit Veitilation Isolation. Circuits Design 3

Descri ption..

2.3 Containment W..tilation Isclation System Design!

' Ev al u a ti o n................... /........

3 Other..Related Engineered Safety-@'ature System Circuits 4

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. 3.0

SUMMARY

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4.0 REFERENCES

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SEP. TECHNICAL EVALUATION TOPIC VI-4 ELECTRICAL, INSTRUMENTATION, AND CONTROL ASPECTS OF THE OVERRRIDE OF CONTAINMENT PURGE VALVE ISOLATION

. LA CROSSE BOILING WATER REACTOR l.0 INTRODUCTION Based on the infomation supplied by the Dairyland Power Cooperative (DPC), this report addresses the electrical, instrumentation, and control systems design aspects of the Containment Ventilation Isolation (CVI) system and other related Engineered Safety Feature (ESF) functions for Millstone Unit 1.

Several ins'tances have been repcrted where the automatic closure of the containment ventilation or purge isolation valves would not have occur-red because the safety actuation signals were manually overridden or bi;

.ed during nomal plant operations..

Lack of proper management con-trols, procedural inadequacies, anc circuit design deficiencies contributed to these instance s.

Tnese events also brought into question the mechanical operacility of the valves themselves.

These events were detemined by the Mxiear Regulatory Ccamission (NRC) to be an A5nomal Occurrence (=78,')5) and accordingly, were reported to Congress.

Tne NRC is now reviewing the electrical override aspects of containment purging and venting for all operating reactors.

On November 28,1978, the NRC issued a letter, " Containment Purging During Nomal Plant Operation"I to all Boiling Water Reactor and Pressuri::ed Water Reactor licensees.

Tni s

.equired a review of these systems by the licensee.

OPC responded on 2

3 February 1,1979.

On February 20. 1981, DPC provided additional information requested by the NRC.

The Final Safety Analysis Report (FSAR) l and a letter of January 14,_1980,4 also contain design information reviewed for this report.

1 L

F 2.0 EVALUATION OF THE LA' CROSSE BOILING WATER REACTOR i-2.1 Review Guise. ines.

The intent of this " evaluation -is to detemine if the actuating signals for the ESF equipment meet the following NRC requirements:

1.

Guideline No.1--In keeping with the requiremsn'ts of General Design Criteria 55 and,56, the over '

a ride..of one type of safety acttration signal (e.g., radiation) shoul d not cause the blocking of any other type of safety attuation signal (e.g.,

pressure) for those valves that have no function besides containment isolatior).

s 2.

Guideline No. 2--Sufficient physical features (e.g.,

key lock switches) are.to be provided to facilitate adequate administrative control s.

3.

Guideline No. 3--A system level annunciation of the overridden status should be provided for every saft ty system impacted when any override is active.

'kiditionally, this review uses th'e following NRC design guidelines:

1.

Guideline No. 4--Diverse signals should be provided to initiate isolation of the containment ventilation system. Specifically, containment high raciatien, safety injection actuation, and containment nigh pres-sure (where containment high pressure is not a portion i

of safety injection actuation) shoui d autcmatically initiate CVI.

2.

Guideline No. 5--Tne instrumentation and control systems provided to initiate the ESF should be designed and qualified as safety grade equipment.

'3.

Guideline No. 6--the overriding or resettingb of the ESF actuation signal should not cause any valve or damper to change position.

a.

Tne follcwing definitions are given for clarity of use in this evaluation:

Overri de:

the signal is still present, and it is blocked in order to perfom a function contrary to the signal.

Reset:

the signal has come and gone, and the circuit is 'eing cleared in order to return it to the nomal condition.

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Guideline 6 in this revicw applies primarily to other related ESF

~ systems because implementation of this guideline for containment isolation will be reviewed by the Lessons t. earned Task Force, based on the recommen-dations in NUREG-0578, Section 2.1.4.

'inen containment isolation is not involved, consideration on a case-by-case basis of automatic valve reposi-tioning upon reset may be considered acceptable.

Rceptability would be d.ependent upon system function, design intent, and suitable operating procedures.

I 2.2 Containment Ventilation Isolation Circuits Design Description.

The containment purge and vent isolation valves use solenoid-operated air pilot valves.

Loss of power or air will cause the isolation valves to

'cl o se.

Automatic closure of the containment purge inlet and outlet 3

iso.lation valves will occur on any of the following conditions 1.

High reactor containment building pressure (5 psig).

2.

High primary system pressure (1325 psig).

3.

Low reactor water level.

4.

High Radiation.

Tne four inch vent header valves will close on the above signals, except for high radiation.

During cperation, Sese valves are closed.

DPC 3

has indicated, that these signals are cerived from safety grade equipment.. SEP Tcpic III-12, "Envircnmental Qualification," will. verify that they are.

Tne high primary system pressure signal can' be bypassed, one channel at a ' time, for calibration, by a key operated switch.2 Both channels cannot be bypassed at the same time, and this bypass does not affect any other signal s.

The use of the key-operated bypass switch is annunciated.

2.3 Containment Ventilation Isolation System Design Evaluation.

Guideline 1 requires that no signal override can prevent another safety a.tuation signal from functioning.

The La Crosse Station complies with this guideline.

3 1

Guideline 2 requir'es that resst and overrida switches have physical

. provisions to aid in the administrative control of these switches.

The key-locked bypass switch, previously mentioned, complies wi di this guide-n

.line.

DPC will install locked covers over 'the radiation reset switches.

Guideline 3 requires system level annunciation whenever an override affects the performance of a safety system.

The use of the override is annunciated in conformance with this guidelin,e.

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Guideline 4 requires that isolation of the CVI valves be actuated by se several' diverse signals.

This requirement is met.

However, the normally closed four inch vent header isolation valves do not close on a high radia-tion signal.

Since they are closed during operation (when an accident would occur) this is not viewed as a deficiency.

Manual actuation of either the high pressure. core spray or the alternate core spray systems will not actuate closure of the CVI valves.

Guideline 5 requires that isolation actuation signals be derived from safety grade equipment.

CPC indicates' that the isolation actuation signals are qualified to operate in their normal environment.

Should isolation be necessary, it would be acccmplished prior to any significant exposure to radiation, temperature or pressure.

SEP Tcpic III-12 will further examine the enviernmental qualifications of this equipment.

Guideline 6 requires that no reset of isolation logic will *automati-call apen the isolation valves.

DPC indicates that no valve or damper will change cosition when a containment isolation signal is overridden or reset.

2.4 Other Related Engineered Safety Feature System Circuits.

A review of other related ESF circuits was also made.

No other manual overrides lave been identified in the review of the material submitted for this audit.

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SUMMARY

The NRC issued a letter, " Containment Purging During Normal Plant Operation," whic:i requested DPC to review purging requirements, controls, and-procedures for purging at the L3 Crosse station.

t The electrical, instrumentation, and control design aspects of the containment ventilation isolation valves for La Crosse Unit 1 were evaluated using the design gudelines stated in Section 2.1 of this report.

These guidelines are satisfied.

However, automatic isolation will not occur for manual operation of the high pressure core spray or the alternate core spray systems.

The NRC should determine if this is acceptable.

Both redundant CVI 20-inch valves are located inside containment.

This is not presently acceptable per General Design Criteria 56 which requires one valve to be inside containment and the other valve outside containment.

The NRC should determine the continued acceptability of this exemption to.Olis General Design Criteria.

4.0 REFERENCES

1.

NRC/ DOR letter ( A. Schwencer) to DPC and all BWR and PWR licensees,

" Con ainment Purging During Normal Plant Operation," dated !bvember 28, 1978.

2.

DPC letter, F. Linder to the Director of Nuclear Reactor Reculation, NRC, "Centainment Purging During Normal Plant C eration," February 1, 1979, LAC-6104.

3.

DPC letter, F. Linder to the Director of Nuclear Reactor Regulation, NRC, " Bypass and Raset of Engineered Safety Features," February 20, 1981, LAC-7379.

4.

DPC letter, F. Linder to the Director of Nuclear Reactor Regulation, NRC, "IE Bulletin No. 79-08.

Additional Information-Events Relevant to BWR's Identified During Three Mile Island Incident," January 14, 1980, LAC-6732.

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