ML20033B024

Informs That Review & Evaluation Has Determined That multi- Plant Generic Activity B-24 Includes Electrical Aspects of SEP Topic VI-4.Safety Evaluation Encl

ML20033B024
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	11/24/1981
From:	Crutchfield D Office of Nuclear Reactor Regulation
To:	Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
References
REF-GTECI-B-24, REF-GTECI-EL, REF-GTECI-ES, TASK-06-04, TASK-6-4, TASK-B-24, TASK-OR, TASK-RR LSO5-81-11-051, LSO5-81-11-51, NUDOCS 8111300292
Download: ML20033B024 (14)

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November 24, 1981 LS05-81-ll-051 g

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Mr. David P. Hoffman O

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Consumers Power Company 1945 W Parnall Road 4

Jackson, Michigan 49201

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SUBJECT:

SEP TOPIC VI-4, CONTAINMENT ISOLATION SYSTEM (ELECTRICAL) - BIG ROCK POINT 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 Big Rock Point. This assessment compares your facility, as described in Docket No. 50-155, 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.

As a result of our review, we find that your facility satisfies our electrical requirements and is, therefore, acceptable.

This safety evaluation will be a basic input to the integrated safety assessment for your facility unless you identify changes needed to reflect the as-built conditions at your facility. This assessment may be revised in the future if your facility design is changed or if NRC criteria re-lating to this subject are modified before the integrated assessment is completed.

In future correspondence regarding this topic, please refer to the topic number in your cover letter.

Sincerely, S.

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PDR ADOCK 05000155 Dennis M. Crutchfield, Chief GL igas P

PDR ll/W/81 Operating Reactors Branch No. 5 _

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UNITED STATES EY j

NUCLEAR REGULATORY COMMISSION p *E WASHINGTON D. C. 20555 November 24, 1981

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Docket No. 50-155 LS05-81 11-051 Mr. David P. Hoffman Nuclear Licensing Administrator Consumers Power Company 1945 W Parnall Road Jackson, Michigan 49201

SUBJECT:

SEP TOPIC VI-4, CONTAINMENT ISOLATION SYSTEM (ELECTRICAL) - BIG ROCK POINT 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~ Big Rock Point.

This assessment compares your facility, as described in Docket No. 50-155, 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, As a result of our review, we find that your facility satisfies our electrical requirements and is, therefore, acceptable.

This safety evaluation will be. a basic input to the integrated safety assessment for your facility unless you identify changes needed to reflect the as-built conditions at your facility.

This assessment may be revised in the future if your facility design is changed or if NRC criteria re-lating to this subject are modified before the integrated assessment is completed.

In future correspondence regarding this topic, please refer to the topic number in your cover letter, Sincerely, dW&$

4 ennis M, Crutchfield, Chief D

Operating Reactors Branch No. 5 Division of Licensing Enc ~1osure: As stated cc w/ enclosure:

See next page

L Mr. David P. Hoffman cc Mr. Paul A. Perry, Secretary U. S. Environmental Protection Consumers Power Company Agency 212 West Michigan Avenue Federal Activities Branch Jackson, Michigan 49201 Region V Office -

ATTN: Regional Radiation Representative Judd L. Bacon, Esquire 230 South Dearborn Street.

Consumers Power Company Chicago, Illinois 60604 212 West Michigan Avenue Jackson, Michigan 49201 Herbert Grossman, Esq., Chairman Atomic Safety and Licensing Board Joseph Gallo, _ Esquire U. S. Nuclear Regulatory Comission Isham, Lincoln & Beale Washington, D. C.

20555 1120 Connecticut Avenue Room 325 Dr. Oscar H. Paris Washington, D. C.

20036 Atomic Safety and Licensing Board U. S. Nuclear Regulatory Comission Peter W. Steketee, Esquire,

Washington, D..C.

20555' 505 Peoples Building Grand Rapids, Michigan 49503 Mr. Frederick J. Shon Atomic Safety and Licensing Board Alan S. Rosenthal, Esq., Chairman U. S. Nuclear Regulatory Comission Atomic Safety &-Licensing Appeal Board Washington, D. C.

20555 U. S. Nuclear Regulatory Comission Washington, D. C.

20555 Big Rock Point Nuclear Power Plant ATTN: Mr. C. J. Hartman Mr. John O'Neill, II Plant Superintendent Route 2, Box'44 Charlevoix, Michigan 49720 Maple City, Michigan 49664 Christa-Maria Charlevoix Public Library Route 2, Box 108C 107 Clinton Street Charlevoix, Michigan 49720 Charlevoix, Michigan William J. Scanlon, Esquire Chairman 2034 Pauline Boulevard County Board of Supervisors Ann Arbor, Michigan 48103

.Charlevoix County Charlevoix, Michigai. 49720 Resident Inspector Big Rock Point Plant Office of the Governor (2) c/o U.S. NRC Room 1 - Capitol Building RR #3, Box 600 Lansing, Michigan 48913 Charlevoix, Michigan 49720 Ferbert Semel Mr. Jim E. Mills Counsel for Christa Maria, et al.

Route 2, Box 108C Urban Law Institute Charlevoix, Michigan 49720 Antioch School of Law 263316th Street, NW Washington, D. C.

20460

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Mr. David P. Hoffman

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i cc Dr. John H. Buck Atomic Safety and Licensing Appeal Board U. S. Nuclear Regulatory Comission Washington, D. C.

20555 Ms. JoAnn Bier 204 Clinton Street Charlevoix, Michigan 49720 Thomas S. Moore Atomic Safety and Licensing Appeal Board U. S. Nuclear Regulatory Comission Washington, D. C.

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a ENCLOSURE av SAFETY EVALUATION REPORT i

BIG ROCK POINT OVERRIDE 0F CONTAINMENT PURGE ISOLATION Introduction Instances have been reported at nuclear power plants where the intended automatic closure of the containment purge / ventilation valves during a postulated accident would not have occurred because the safety actuation signals were inadvertantly overriden and/or blocked, due to design deficiencies.

These instancec 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 Override of Containment Purge Valve Isolation," (0575J) was prepared for us by EG&G, Idaho as part of our technical assistance contract program. The report provides their technical evaluation of the desi'gn compliance with NRC provided 4

criteria.

Conclusion Based upon our review of the contractor's technical report, we conclude that the electrical portion of this topic is satisfactory in this plant.

SEP Topic III-12 will address the environmental qualifications of the radiation monitors used to isolate the containment.

The mechanical operability of the containment purge valves is being analy:ed separately.

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SYSTEMATIC EVALUATION PROGRAM

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TOPIC VT-4 ELECTRICAL, INSTRUMENTATION,' AND CONTROL ASPECTS OF THE OVERRIDE OF CONTAINMENT PURGE VALVE ISOLATION BIG ROCK POINT PLANT Docket No. 50-155 4

October 1981 j

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Reliability and Statistics Branch Engineering Analysis Division EG&G Idaho, I.nc.

i Draft 10-23-81

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r CONTENTS

1.0 INTRODUCTION

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1 2.0 EVALUATION OF THE BIG ROCK POINT PLANT..........................

2 2.1 Review Guidelines.........................................

2 2.2 Containment Ventilation Isolation Circuits Design Description...............................................

4 2.3 Containment Ventilation Isolation System Design Ev a l u ati o n................................................

4 2.4 Other-Related Engineered Safety Feature System Circuits..................................................

6 3.0 SUM %RY.........................................................

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4.0 REFERENCES

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p SYSTEMATIC EVALUATION PROGRAM,

TOPIC VI-4 ELECTRICAL, INSTRUMENTATION, AND CONTROL ASPECTS OF THE OVERRIDE OF CONTAINMENT PURGE VALVE ISOLATION BIG ROCK POINT PLANT s

1.0 INTRODUCTION

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Based on the infonnation supplied by the CoEsumers Power Company (CPCo), 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 the,

Big Rock Point Plant.

Several instances have been reported 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 blocked during normal plant cperations. Lack of precer management controls, pro-

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cedural inadequacies, and circuit design deficiencies contributed to these instances. These events also brought into question the mechanical oper-ability of the valves.themselves. These events were determined by the Nuclear Regulatory Commission (NRC) to be an Abnormal Occurrence (#78-05) and, accordingly, were reported to Congress.

The NRC is now reviewing the electrical override aspects of containment purging and venting for all operating reactors. On November 28, 1978,.the 1

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NRC issued a letter, " Containment Purging During Normal Plant Operation"I to all Soiling Water Reactor and Pressurized Water Reactor licensees. This

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required a review of these systems by the licensee. CPCo responded on 2

December 29, 1978 stating that the review was in process. On Septem-ber 11, 1979 and March 14, 1980,# CPCo suppliea 2nalysis and circuit 3

details for-this review. CPCo supplied additional information for this review on Septenber 24,1981.5 2.0 EVALUATION OF THE BIG ROCK POINT PLANT 2.1 Review Guidelines. The intent of this evaluation is to determine if the actuating signals for the ESF equipment meet the following NRC criteria:

1.

Guideline No. T--In keeping with the requirements of General Design Criteria 55 and 56, the over-

' l rice of one type of safety actuatien signal (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.

2.

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

key lock switches) are to be provided to f acilitate adequata administrative controls.-

The following definition is 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.

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Guideline No. 3--A system level annunciation of the ove. ridden status should be provided for every safety system impacted when any override is active.

Additionally, this review uses the following NRC design guidelines:

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Guideline No. 4--Diverse signals should be provided to-s initiate isolation of the containment ventilation systent. Specifically, containment high radiation, safety injection actuation, and containment high pres-sura (where. containment high pressure _is_not a portion of safety injectToT aci:uati6n) should automatically

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I initiate CVI.

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2.

Guideline No. 5--The 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 resetting" of the ESF actuation signal snould not cause any valve or damper to change position.

Guideline 6 in this review applies primarily to other related ESF f

systems because implementation of this guiceline for containment isolation i

will be reviewed by the Lessons Learned Task Force,. based on the reconnen-dations in NUREG-0578, Section 2.1.4.

When containment isolation is not; involved, consideration on a case-by-case basis of automatic valve reposi-tioning upon reset may be considered acceptable. Acceptability would be l

The following definition is given for clarity of use in this ' evaluation:

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- Reset:

the signal has come and gone, and thrcircuit is being cleared in order to return it to_the normal condition.

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p' dependent upon system funct' ion, design intent, and su.itable operating pro-cedures.

2.2 Containment Ventilation Isolation Circuits Design Descriotion.

The containment purge and vent isolation valves use solenoid-operated pilot valves for actuation. l.oss of power or instrument air pressure will cause the isolation valves to close. Automatic closure of the isolation valves will occur on any of the following signals:. reactor scram, containment high pressure, lo reactor water level (the same setpoint used for core spray), containment high radiation and loss of. power.5 The purge and vent isolation valves are also used for containment vacuum relief. The control system will not. adversely affect both series valves concurrently on a single random f ailure. However, the system will override any signal that closes the containment ventilation isolation valves. It is not expected that a vaccum condition will exist concurre'nt with a design basis accident. Even in long ter= cooling, shoul_d the vacuum relief system operate, the air flow would be into containment. Therefore, no radiation would escape wnile tne vacuum is befng relieved. The valves reclose, due to tne same signal, when tne vacuum-has can relieved.

2.3 Containment Ventilation Isolation System Design Evaluation.

Guideline 1 requires that no signal override can prevent..,other safety actuation signal from functioning. The Big Rock Point Plant has no manual override of the isolation signal for the containment ventilation isolation valves. This guideline is satisfied.

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Guideline 2 requires that reset and override switches have physical With no provisions to aid in.the administrative control of tnese switches.

override possible for the containment ventilation isolation valves, this guideline.is not applicable.

Guideline -3 requires system level annunciation whenever an override affects the performance of a safety system. This guideline is also not applicable to the containment ventilation isolation valves.

Guideline 4 requires that isolation of the CVI valves be actuated'by several diverse signals. This guideline is met in that:

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Reactor scram, 2.

Containment high pressure, 3.

Low reactor water level (this also actuates the core spray system),

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Containment nign radiation ano 5.

Loss of power all will cause the containment ventilation isolation valves to close.

Guideline 5 requires tnat isolation actuation signals be derived from

. safety grade equipment. CPCo indicates that all are derived from fully qualified safety-grade equipment.' The radiation monitors, when described, were,"not class lE" equipment.5 SEP Topic III-12 will further examine the environmental qualifications of the radiation monitors.

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Guideline 6 requires t' hat no reset of isolation logic will automatic-ally open the isolation valves. CPCo indicates that after the initating.

isolation signal is cleared, that no isolation valve will automatically reopen. This guideline is satisfied.

2. 4-Other Related Engineered Safety Feature System Circuits. A review-of ot.her related ESF circuits was also made. Control switches that. are pull to overrida, are used for the functions.a) reactor emergency cooling back-up spray valves, b) reactor building emergency spray valve, c) reactor emer-gency cooling spray valves and d) emergency condenser outlet valves.3 These circuits have been modified to provide annunication upon an override 5

condition and now comply with the applicable guidelines.

No other manual overrides,in existing circuits have been identified in the review of the material submitted for this audit.

3.0

SUMMARY

The NRC issued a letter, " Containment Purging During Normal Plant Operation," which requested CPCo to review purging requirements, controls, and procecures for purging at the Big Rock Point Plant.

The electrical, instrumentation, and control design aspects of the containment ventilation isolation valves for the Big Rock Point Plant were o

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evaluated using the design guidelines stated in Section 2.1 of this report.

Except for non-class lE radiation monitors, thasa guidelines are satisfied.

SEP Topic III-12 will examine the environmental qualifications of the radi-ation monitors.

4.0 REFERENCES

1.

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

" Containment Purging During Normal Plant Operation," dated, November 28,

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1978.

2.

CPCo letter, D. A. Bixel to Director, Nuclear Reactor Regulation, NRC,

" Containment Purging During Normal Plant Operation," December 29, 1978.

3.

CPCo letter, D. A. Bixel tc Director, Nuclear Reactor Regulation, NRC,'

t "Results of Review of Safety Circuit Overrides," September 11, 1979.

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CPCo letter, D. P. Hoffman to Director, Nuclear Reactor Regulation, NRC, " Containment Purge System, Single Failures," March 14, 1980.

5.

CPCo letter, R. A. Vincent to Director, Nuclear Reactor Regulation, I

NRC, "SEP Tcpic VI 4, Containment Isolation System," Septenber 24, 1981.

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