ML20039B534
| ML20039B534 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 12/21/1981 |
| From: | Knox J Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20039B531 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8112230205 | |
| Download: ML20039B534 (22) | |
Text
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UNITED STATED OF' AMERICA NUCLEAR REGULATORY COMillSSION
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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)
PACIFIC GAS AND ELECTRIC COMPANY
- )
Docket Nos.
50-275 0.L.
)
50-323 0.L.
(Diablo Canyon Nuclear Power
)
Plant, Units Nos.1 and 2)
)
AFFIDAVIT OF JOHN L. KN0X ON CONTENTION 10
- 1. John L. Knox, being duly sworn, state as follows:
1.
I am employed by the U.S. Nuclear Regulatory Commission as a Senior Electrical Engineer in the Division of Systems Integration, Office of Nuclear Reactor Regulation.
2.
I am the Senior Electrical Engineer assigned to review selected aspects of the electrical power systems for the Diablo Canyon Nuclear Power Plant Unit Nos.1 and 2.
3.
Contention 10 states:
Contention 10. The staff recognizes that pressurizer heaters and associated controls are necessary to maintain natural circulation at hot stand-by conditions. Therefore, this equipment should be classified as " components important to safety" and required to meet all applicable safety-grade design criteria, including but not limited to diversity (GDC 22), seismic and environmental qualification (GDC 2 and 4), automatic initiation (GDC 20),
separation and independence (GDC 3 and 22), quality assurance (GDC 1), adequate, reliable on-site power supplies (GDC 17) and the single failure criterion. The Applicant's proposal to connect two out of four of the heater groups to the present on-site
' emergency power supplies does not provide an equivalent or acceptable level of protection.
811223020S 811221 PDR ADOCK 05000275 O
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4.
The _ number of heaters required to be connectable to each of two emergency busses at Diablo Canyon was based on a conservative estimate of 150 kw. Position 1 and clarifications I and 2 of item II.E.3.1 of NUREG-0737 specifically address the number of heaters required. The staff evaluation prepared on this item is in Attachment B.
Although I did not prepare the evaluation myself, I have evaluated the subject Diablo Canyon design, concur with the staff conclusions, and thus adopt the staff evaluation as my own.
The technical bases for the attached safety evaluation are derived from and supported by applicant's submittal titled:
Pacific Gas and Electric Company Response to NUREG-0578: Short Term Lessons Learned Requirements dated April 21, 1980. Section 1.1.1 part A of the submittal addresses the TMI task force position on pressurizer heater power supply (TMI item II.C.3.1) and a copy is in Attachment C to this affidavit.
%s L %y John L. Knox Subscribed and sworn to before me this2/of day ofjQad(1981
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ATTACHMENT A UNITED STATES OF AMERICA NUCLEAR REGULATORY C0;o115510N BEFORE THE ATOMIC SAFETY AND LICkNSING BOARD In the Matter of PACIFIC GAS AND ELECTRIC COMPANY Docket Nos. 50-275 0.L.
50-323 0.L.
(Diablo Canyon Nuclear Power Plant,.
Unit Nos. I and 2)
JOHN L. KNOX PROFESSIONAL QUAI.IFICATIONS Education A.A.
Electrical Technology, 1962 Montgomery College Takoma Park, Maryland Major:
Electrical Power Systems B.S.
Electrical Engineering, 1971 University of Maryland er College Park, Maryland s
Major:
Electronic Systems Engineering Professional Qualifications From 1971-1974, I worked for Potomac Electric Power Company in Washington, i
D. C.
I was assigned to the undergr6und power Transmission Engineering l
l Group and my duties included relocation and restoration of underground power.
i and transmission cables due to the subway construction project.
(Prior to this, I spent four years in the AiqForce working on the F4 aircraft electronic weapons control systems.)
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o 2-From 1974 to the present, I have worked for the Nuclear Regulatory Commission involved in the technical review of electrical systems (onsite and offsite power, instrumentation and control). Through 1976. I was a cember of the Electrical Instrumentation and Control Systems Branch. This-branch was split in January 1977 into an I&C branch and a power branch.
Since this split, I have been a member of the power Systems Branch.
My present title is Senior Reactor Systems Engineer (Electrical).
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ATTACHMENT B II.E.3.1 Enerpency Power Sucply for Pressurizer Heaters
- (
Position -
Consistent with satisfying the reoufrements of General Design Criteria 10,14, r
15,17, and 20 of Appendix A to 10 CFR Part 50 for the event of loss of offsite powe'r, the following positions shall be implemented:
(1)
The pressurizer heater power supply design shall provide the capability to supply, from either the offsite power source or the emergency power source (when offsite pcwer is not available), a predetermined number of pressurizer heaters and associated controls necessary to establish and maintain natural circulation at hot standby conditions.
The required heaters and their controls shall be connected to the emergency buses in a manner that will provide redundant power supply capability.
(2) Procedures and training shall be established to make the operator aware of when and how the required pressurizer heaters shall be connected to the emergency buses.
'[
If required, the procedures shall identify under what conditions selected emergency loads can be shed from the emergency power source to provide sufficient capacity for the connection of the pressurizer heaters.
(3).The time reqyired to accomplish the connection of the preselected pressurizer heater to the emergency buses shall be consistent with the timely initiation and maintenance of natural circulation conditions.
(4) Pressurizer heater active and co.nt,rol power interfaces with the emergency buses shall be accomplished through devices that have been qualified in accordance with safety grade requirements.
Clarification 1
1 (1) Redundant heater capacity must be provided, and each redundant heater or group of heaters should have access to only one Class IE division power supply.
1 Diablo Canyon Full Power SER 2 26
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(2) The number of heaters required to have access to each emergency power s'ource is that number required to maintain natural circulation in the hot '
~
standby conditfori.
r (3) The power sources needed not necessarily have the capacity to provide
' power t'o the heaters concurrently with the loads required for loss-of-cociant accident.
(4) Any changeover of the heaters from normal offiste power to emergency onsite power is to be accomplished manually in the control room.
(5) In establishing procedure to manually load the pressurizer heaters onto the emergency power sources, careful consideration must be given to:
(a) which ESF loads may be appopriately shed for a given situation; (b) reset of the safety injection actuation signal to permit the operation of the heaters; and (c) instrumentation and criteria for operator use to prevent overloading
~,
a diesel generator.
(6) The Class IE interfaces for main power and control pcwer are to be protected by safety grade circuit breakers (see also Regulatory Guide 1.75).
(7) Being non-Class IE loads, the pressurizer heaters must be automatically shed from the emergency power sources upon the occurrence of a safety injection actuation signal (see item 5.b above).
Discuss'en All'four pressurizer heater groups in the Diablo Canyon design can be supplied from the cffsite power sources when they are available, and two of tne four groups can_be transferred to the emergency power sources when the offsite
~
sources are not available. Each of the two selected groups (12 & 13) has access to only one Class IE diesel generator and their controls are likewise supplied from separate safety grade de power supplies.
Each heater group x,,
Diablo Canyon Full Power.SER 2-27
(12 & 13) is comprised of-seven 69 kW heaters (483 kW total).
Therefore, energizing.three of the seven heaters (207 kW) will be more than adequate to fulfill the calculated minimum heater requirement of 150 kW.
This is in
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)
accordance with NRC position 1 and clarification items 1 and 2.
In accordance with position 4 and clarifi' cation 6, the connection of the pressurizer heater elements and controls to the Class IE buses is through safety grade circuit breakers, and the heaters are automatically tripped off cf the emergency buses upon occurrence of a safety infection (SI) signal in.
accordance with clarification 7.
PG&E has developed procedures and implemented the training of their operators to make them aware of when and how the required heaters should be connected to the emergency buses.
The procedures identify under what conditions selected loads can be shed from the emergency bus to prevent overloading the diesel generator when the pressurizer heaters are connected and also include provisions to reset the SI signal to permit the operation of the heaters.
Diesel generator and pressurizer heater loading information is displayed in the control room.
This covers position 2 and clarifications 3 and 5.
In order to align the pressurizer heaters to the emergency power source, an operator must be dispatched to the 100 ft level of the Auxiliary Building, three floors directly below the main control room, and manually throw a transfer switch.
This action in itself does not connect the heaters to the emergency buses but allows sun 2quent operation of the heaters from'the emergency buses using the normal control devices provided on the main control console. Although not in strict accordance with clarification item 4, this is considered an acceptable alternative since the heaters can be supplied with emergency power well within the one hour limit re..ommended by Westinghouse and therefore meets the criteria of position 3.
Conclusion.
Based on our review, we conclude that the design for providing emergency power to the pressurizer heaters at Diablo Canyon Nuclear Generating Station Units 1 and 2 is consistent with the NRC positions and clarifications in NUREG-0737 and is acceptable.
N.
Diablo Canyon Full Power SER 2-28
ATTACHMENT C S:ction 2.1.1 - Emergency Powrer Supply Requirements for the Pressurizer Heaters Power-Operated Relief Valves and Block Valves, and Pressurizer Level Indicators in PWR's Task [orce Position (TTP) on Pressurizer Heater Power Supply A.
Task Terce Position 1 The pressurizer heater power supply design shall provide the capability to supply, from either the offsite power source or the emergency power source (when offsite power is not available), a predetermined nu=ber of pressurizer heaters and associated controls necessary to establish and maintain natural circulation at hot standby conditions.
The required heaters and their controls shall be connected to the emergency buses in a manner that will provide redundant power supply capability.
J (Category A:
Implementation shall be completed prior to OL, or January 1,1980, whichever is later.)
Task Force Position 2 Procedures and training shall be established to make the operator aware of when and how the required pressurizer heaters shall be connected to the emergency buses.
If required, the procedures shall identify under what conditions selected emergency loads can be shed from the emergency power source to provide sufficient capabili*y for the connection of the pressurizer heaters.
(Category A: Imple=entation shall be ce=pleted
~
prior to OL, or January 1, 1980, whichever is later.)
o Revision 0 III-B-1 2/29/80
Section 2.1.1. (Continued) 9 Task Force Position 4
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The time required to accomplish the connection of the preselected pressurizer heater to the emergency bu'ses sha*11 be consistent with the timely initiation and maintenance of natural circulation conditions (Category A:
Implementation shall be empleted prior to OL, or January 1, 1980, whichever is later.)
Task Force Position 4 Pressurizer heater motive and control power interfaces with the emergency
~ buses shall be accomplished through devices that have been qualified in accordance with safety grade requirements. (Category A: Implementation shall be completed prior to OL, or January 1, 1980, whichever is later.)
Clarification 1.
In order not to compromise independence between the sources of emergency power and still provide redundant capability to provide emergency power to the pressurizer heaters, each redundant heater or i
)
group of heaters should have access to only one Class 1E division power supply.
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t III-B-2 Revision 0 2/29/80
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Sectio,n 2.1.1 (Continu d) 2.
The nu=ber of heaters required to have access to each e=ergency power source is that number required to maintain natural circulation in the hot standby condition.
3.
The power sources need not necessarily have the capacity to provide power to the heater concurrent with the loads required for LOCA.
4.
Any change-over of the heaters from normal offsite power to emergency onsite power is to be acco=plished manually in the control room.
5.
In establishing procedures to manually reload the pressurizer heaters onto the emergsney power sources, careful consideration must be given to:
Which ESF loads may" be apprepriattly shed for a given situation.
a.
b.
Reset of the ' afety Injection Actuation Signal to per=it the operation of the heaters.
Instrumentation and criteria for operator use to prevent over-c.
leading a diesel generator.
III-B-3 Revision 0 2/29/60 c
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Section 2.1.1 (Continued)
- 6. "The Class IE interfaces for main power and control power are to be protected by safety grade circuit breakers.
(See also Regulatory Guide 1.75.)
7.
Being non-Class IE loads, the pressurizer heaters must be automatically shed from the emergency power sources upon the occurrence of a safety injecti'on actuation signal.
(See Item 5.b.
above.)
PG&E Response and Status for TFP 1
~
All of the four pressurizer heater groups can be supplied with power from the offsite power sources when they are available.
In addition, 4
provisions will be made to provide power to two out of four heater groups from the emergency power source through the Engineered Safety Features (ESF) buses when offsite power is not available~(see Figure 2.1.1-2).
Sufficient power is available from the EST buses to energize enough heaters to establish and maintain natural e.freulation at hot ste:.dby conditions. Redundancy is provided by supplying each of the two groups of heaters from a different ESF bus.
~
The minimum capacity and time requirements of the emergency power supply for t,he pressurizer heaters have been specified. These requirements are well within current design. It is recommended that one bank of backur Revision 1 111-B-4 3/14/80
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.Section 2.1.1 (Continued) i
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heaters be available to each emergency power train within 60 minutes I-af ter' a blackout.
A review of several pressurizer heat loss calculations.
has resulted in the minimum heater requirements without offsite power of 150 Kw.
These capacities will conservatively cover heat losses from the-:
pressurizer at or below normal operating pressure with no allowance for continuous spray. With continuous spray, loss of subcooling would occur between five and six hours. Heater input at any time of 150 Kw as specified above would more than offs'et the heat loss and allow system pressure to be stabilized at any desired value. Ability to supply emergency power to the heaters within four hours will prevent loss of subcooling in the primary following s loss of offsite power.
J All of the equipment associated with pressurizer heater power supply described in this response will be seismically qualified fer the Hosgri event except for those devices specifically noted as non-safety grade.
Circuit breakers 52-1G-72 and 52-1H-74 will be added to 480 volt ESF buses 1G and IH, respectively (see Figure 2.1.1-1).
These breakers will be seismically qualified and installed to meet safety grade requirements.
The seismic qualification is based on PG&E's vast testing experience which has previously demonstrated that electromechanical equipment can 1
withstand numerous seismic tests cimulating high seismic events without damage and that the equipment will be available to perform its safety i
function when called upon af ter the seismic event.
Revision 2 III-B-5 3/31/80
Section 2.1.1 (Continued)
Emergency power is generated by the onsite emergency diesel ger.arators and supplied directly to the 4.16 kV EST buses. Power is then fed through a step-down transformer to the 480 volt ESF buses.
The heater banks will be automatically tripped off of the ESF buses upon occurrence of a safety injection (SI) actuation signal. This feature satisfies Clarification 7.
PG&E Response and Status for TFP 2 PG&E will d elop the required procedures and implement the proper s
training of the operators. Procedures and training will be completed to make the operator aware of when and how the required pressurizer heaters should be connected to the emergency buses. Loading of each ESF bus can be accomplished from the main control board (see TTP3 below). Procedures will identify under what conditions and which selected loads can be shed from the ESF bus to prevent overloading when the pressurizer heaters are connected. The procedures will include provisions to ensure that the heaters are transferred to the ESF power source as described in TFP3 below. The time required to transfer the power supplies will be less than 10 minutes and will expose the operator to no more than 10 mrem.
~
The. procedures will be written and approved, and the operators trained, by May 1, 1980.
~-
Revision 1 III-B-6 3/14/80
Section 2.1.1 (Continued)
PG&E Response and Status for TFP 3 The proposed design modifications will provide for simple and rapid transfer of the heater groups to the EST power source. Within 2 minutes after loss of offsite power, the onsite emergency diesel generators will have started and been connee:4d to any required ESF loads.
- When it is determined that the pressurizer heaters are required, the Shift Foreman needs on?y to dispatch an operator to the 100 foot elevation in the Auxiliary Building, which is just three f1cors directly below the main control room (two separate stairwells are available). Once in the area, the operator simply verifies that the source breakers (52-1H-74, 52-13D-6, 52-13E-2, 52-1G-72) are open, white " Power on" lights indicate if either source is energized, and manually throws the deenergized transfer switches.
This action in itself will not connect the pressurizer heaters onto the ESF buses.
Only when the Shift Foreman is informed that the transfers have been made, will the heaters again be controlled using the normal cor*.rol devices provided on the r.ain control conscle (see Figure 2.1.1-2).
This control room function is intended to meet the requirements of Clarification 4.
Even with manual transfer, there is no problem in meeting the Westinghouse estimated time requirement of providing pressurizer heaters on emergency power within one hour after the accident. PG&E will provide control room indication of actual wattage being supplied to each heater group that has been transferred to the emergency power sources. Diesel generator loading parameters are also displayed in the control room.
Revision 1 III-B-7 3/14/60
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Should the operator inadvertently transfer power while energized, neither the transfer switch nor the diesel generator would be adversely affected.
I The operating and emergency procedures will be changed to reflect these requirements and changes by May 1, 1980.
PG&E Response and Status for TFP_s The seismic qualification mentioned in PG&E status for position 1 above will qualify to safety grade requirements the interface between the pressurizer heater motive power and the emergency bus.
B.
Task Force Position on Power Supply for Pressurizer Relief and Block Valves and Pressurizer Level Indicators Task Force Position 1 Motive and control components of the power-operated relief valves (PORV's) shall be capaale of being supplied from either the offsite power source or the emergency power source when the offsite power is not available.
(Category A: Implementation shall be completed prior to OL, or January 1, 1980, whichever is later.)
III-B-8
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