ML20027E172
| ML20027E172 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 11/04/1982 |
| From: | Schwencer A Office of Nuclear Reactor Regulation |
| To: | Davidson D CLEVELAND ELECTRIC ILLUMINATING CO. |
| References | |
| NUDOCS 8211120191 | |
| Download: ML20027E172 (6) | |
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DISTRIBUTION:
NOV 4 1982 C Document Controlf(50-440)1 NRC PDR L PDR NSIC PRC "9
Docket Nos.: 50-440/441 ton JStefano Cutchin OELD ACRS (16)
Mr. Dalwyn R. Davidson ELJordan, DEQA:IE Vice President, Engineering JMTaylor, DRP:IE The Cleveland Electric Illuminating Company Region III P. O. Box 5000 FRosa JHauck l
Cleveland, Ohio 44101 ERossi TDunning hsenhal
Dear Mr. Davidson:
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Subject:
Request for Additional Infomation Required to Resolve the Perry Nuclear Power Plant SER Outstanding Issue (12), " Manual Initiation /
i Termination of ESF Systems" During its review of the Perry ESF Systems, the NRC staff found that the logic for manual initiation of several ESF Systems is interlocked with permissive logic from various sensors. In some cases, it appeared that the permissive logic was dependent upon the same sensors as those used for automatic initiations. This leadsthe staff to question whether the Perry design meets the requirement of IEEE-279, Section 4.17.
In my letter to you dated March 2,1982, Question 421.73 was forwarded to CEI addressing the staff's findings and concerns relative to tha Perry design for manual initiation / termination of ESF Systems. Your letter to me dated July 20,1982 responded to that question. The NRC staff has reviewed this response and finds that it specifically describes the normal operation of ESF Systems rather than the effect of failure of interlocks. Your July 20, 1982 response is therefore considered to be insufficient for resolving SER Out-standing Issue (12).
Accordingly, Question 421.73 has been clarified to identify the specific additional information needed by the staff for resolving this issue, which is enclosed. Please advise the project manager when the additional information may be expected within five (5) days after receipt of this letter. Your expeditious attention to this request will be most appreciated and is urged.
Sincerely.
Original signed by:
8211120191 821104 PDR ADOCK 05000440 E
PDR A. Schwencer, Chief Licensing Branch No. 2
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4 ENCLOSURE 1
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Clarification of Question 421.73 Manual Initiation / Termination of ESF Systems Q421.73 During the NRC staff's review, it Lacame apparent that the logic for.
manual initiation for several Engineered Safety Feature (ES F) systems is interlocled with permissive logic from various it ' appeared 'that the permissive logic sensors.
In some eises, is dependent upon tie same sensors as those used for automatic initiation of the system.
The staff questions whether this design meets the intent of IEEE 279, S e c t i on 4.17. and requires the applicant to revise the design to provide the cape bility to manuially initiate each safety system independent of any permissive logic dependent upon sensors or circuitry used for automatic initiation.or submit justification for interlocks for each ESF system in which the applicant proposes to retain the intertocks.
1 Further Clarification:
The response should definitively address the following systems:
HPCS, LPCS, LPCI, ADS, CRVICS, Suppression Pool Cooling Mode of RHR, Containment Spray Mode of RHR.
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The capability to manually initiate systems is desired to:
(1) permit manual initiation of systems should the automatic initiation circuitry fail, and (2) permit manual initiation to enable the operator to cope with event sequences which do not proceed in the precise manner postulated in the safety analysis.
Manual initiation is required at the systems level in paragraph 4.17, "M a nua l Initiation," of IEEE 279.
Manual initiation of actuated devices is provided in th.e control room in accordance with GDC 13 and 19e " Appendix A-General Design Criteria for Nuclear Power Plants," 10 CFR 50.
_Furthermores paragraph 4.17 of IEEE 279 stytes that:
" Manual initiation should depend upon the operation of a minimum of equipment."
The initiation circuitry may be divided into two portionse that which crecedes a logical "0R" consisting of the automatic and manual initiation circuitry, and that which follows the~"0R."
Cleartyr that equipment which follows the "0R" is common.to automatic and manual initiation.
This equipment should be kept to a m'inimum (see paragraph 4.17, IEEE 279).
That equipment which precedes t h e " 0 R ')
automatic initiation circuitry and manual initiation circuitry,should be separate and distincts in order to meet the design goals enumerated abover i.e.,
manual initia-tion as a backup to automatic initiation.
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, e The same sensors and circuitry should not be used in the auto-matic initiation circuitry and in the permissive circuitry for manual actuation.
Furthermore, in order for the staff to deter-mine conformance with GDC 13 and 19, and confirm that manual initiation depends "upon the operation of a minimum of equip-ment," the f ollowing inf ormation should be provided for the ESF systems identified above:
(1)
Provide a list of interlocks which perform a safety related function and whose failure would prevent manual initiation at the systems level from the control room.
Provide a list of t)e affected systems.
(2)
Provide a list of interlocks which perform a safety related function, and whose failure would prevent manual initia-tion at the actuated device level from the control room.
Provide a list of affected actuated devices.
(3)
Provide a list of interlocks which perform an equipment protection function, and whose failure would prevent manual initiation at the actuated device level from the control room.
Provide a list of affected actuated devices.
(4)
For the affected motor operated valves, identify which valves may or may not be operated using handwheels.
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(5)
Local manual control at the motor control centers may, in principler be used to actuate devices should equipment in the control room fail.
Indicate if local control at the motor control centers has been provided.
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c Perry Mr. Dalwyn R. Davidson Vice President, Engineering The Cleveland Electric Illuminating Company P. O. Box 5000 Cleveland, Ohio 44101 cc:
Jay Silberg, Esq.
Shaw, Pittman, Potts & Trowbridge 1800 M Street, N. W.
Washington, D. C. 20006 Donald H. Hauser, Esq.
The Cleveland Electric Illuminating Company P. O. Box 5000 Cleveland, Ohio 44101 Resident Inspector's Office U.S. Nuclear Regulatory Commission Parmly at Center Road Perry, Ohio 44081 Donald T. Ezzone, Esq.
Assistant Prosecuting Attorney
.,[05 Main Street Lake County Administration Center
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Painesville, Ohio 44077 Daniel D. Wilt, Esq.
P. O. Box 08159 C1.eveland, Ohio 44108 Ms. Sue Hiatt OCRE Interim Representative 8275 Munson Mentor, Ohio 44060 Terry Lodge, Esq.
915 Spitzer Building l
Toledo, Ohio 43604 John G. Cardinal, Esq.*
Prosecuting Attorney Ashtabula County Courthouse Jefferson, Ohio 44047
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