ML20052B748

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Suppls Response to IE Bulletin 80-06, ESF Reset Controls. Safety Evaluations Completed on Identified Category 4 Items. Mods to Be Completed & Tested Prior to Entering Mode 2. Re-evaluation on Unit 1 Will Be Completed by 820530
ML20052B748
Person / Time
Site: Arkansas Nuclear  Entergy icon.png
Issue date: 04/16/1982
From: Cavanaugh W
ARKANSAS POWER & LIGHT CO.
To: Jay Collins
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20052B739 List:
References
REF-SSINS-6820 2CAN048208, 2CAN48208, IEB-80-06, IEB-80-6, NUDOCS 8205030530
Download: ML20052B748 (96)


Text

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ARKANSAS POWER G LIGHT COMPANY FIRST NAT!ONAL BUILDING /P.O. BCX SS1/urTLE ROCK, ARKANSAS 72203/(501) 371-4422 April 15, 1982

.t WILLIAM CAVANAUGH Ill Senior Vice President,

- Energy Supply . . ,

t APR I 91982 L o

2CAN048208 Mr. John T. Collins Regional Administrator U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011

SUBJECT:

Arkansas Nuclear One - Unit 2 Docket No. 50-368 License No. NPF-6 Confirmatory Action Letter on IE Bulletin 80-06 Gentlemen:

On April 9, 1982, in a conversation with you and your staff, AP&L outlined a plan of action for performing a re evaluation of our response to IE Bulletin 80-05. Your letter of April 9, 1982, (0CNA048203) confirmed your concurrence with our plan of action on this matter. As we agreed, we have re-evaluated our response to IE Bulletin 80-06 and have completed actions in the following ~ areas:

A. An engineering review of all AN0-2 electrical schematics to identify all ESFAS components has been conducted and a listing of all safety related components receiving an ESFAS signal compiled.

B. An identification and listing of all ESFAS components which have not been tested as specified in Action Statement 2 of IE Bulletin 80-06 has been completed.

C. An evaluation of the potential safety implications of failing to test /failing to modify all applicable ESFAS components has been completed.

820 50 3 0 no ,

t MEM(iER MICOLE SOUTH UTILITIES SYSTEM J

I Mr. John T. Collins 2 April 16, 1982 D. All ESFAS components requiring modification not previously identified and modified have been identified.

E. Documentation confirming that testing of all previously modified ESFAS components was conducted has been reviewed and verified.

A listing of active ANO-2 components receiving an ESFAS signal to perform a safety function has been compiled and evaluated against the concerns stated in IE Bulletin 80-06. Non-safety components which receive ESFAS signals (e.g., load shedding through interposing relays) were not further evaluated. AN0-2 safety analyses do not take credit for any function performed by these non-safety components. In addition, ANO-2 design criteria preclude the operation / mis-operation / failure of any non-safety component from affecting safety related ESFAS components.

During the review of the safety related ESFAS component schematics, we found the components to comply with the Bulletin in varying degrees.

Accordingly, we divided the components into five categories, depending on their degree of compliance, as follows:

l Safety Flyback , Modification Modification Documented l l Related Feature Required Complete Testing l l l l CATEGORY 1 Yes Yes Yes Yes Yes l 1 l l CATEGORY 2 Yes Yes No No No* l l l l CATEGORY 3 Yes No No No No* l l l l CATEGORY 4 Yes Yes Yes No No* l l l l CATEGORY 5 No NA NA NA Not l l Required l l

  • Existing documentation does not provide reasonable assurance that l l testing was performed. l l l Attachment 1 is a listing of all CATEGORY 1 components. These components were previously modified. Existing documentation provides reasonable assurance that testing has been conducted to verify effective currection.

Many of these components were modified before Bulletin 80-06 due to operational problems identified with flyback.

Attachment 2 is a listing of all CATEGORY 2 components followed by a component by component evaluation / justification for allowing these components to continue to flyback.

Attachment 3 is a listing of all CATEGORY 3 components followed by a component by component evaluation of the potential safety implications of the possible lack of previous testing. Our detailed review of the r_ .

Mr. John T. Collins 3 April 16, 1982 component schematics and system engineering evaluations provide a high degree of assurance that these components will not flyback. During the four years of operation of ANO-2, several various ESFAS actuations have cccurred. No reports of flyback of any of these components have been made by the operators following reset of these signals, thus providing further assurance of the validity of our engineering review and conclusion. is a listing of all CATEGORY 4 components. These components have been determined to flyback and modifications are proposed. We do not believe flyback of any of these components presents a safety concern; however, their modification will increase safety margins. Also included in Attachment 4 is a component by component evaluation of the potential safety implications used to support this conclusion. As requested in the confirmatory action letter, these items were discussed with your Mr. Bill Johnson by our Mr. Jim Levine on April 14, 1982.

CATEGORY 5 components are non-safety components which receive ESFAS signals. As discussed above, these components were identified during this re-review but were not further evaluated or tested within the scope of this re-review as the ANO-2 design precludes them from having adverse effects on safety components and systems. These non-safety components are listed in Attachment 5 with component by component evaluations justifying this conclusion.

We also stated that we would provide a definition of testing and additional modifications necessary as a result of this re-evaluation.

Re-testing of CATEGORY 1 components and testing of CATEGORIES 2, 3 and 4 components will be conducted in accordance with Work Plan No. 2409.14.

As ANO-2 is currently in a Mode 5 cold shutdown, all testing and re-testing will be completed before entering Mode 2 following this current outage.

Safety evaluations have been completed on all CATEGORY 4 items that have been identified as a result of our re-review, and we have concluded that justification for continued operation until the next scheduled refueling exists. However, modifications to the CATEGORY 4 components and to any additional components requiring modification as a result of the above testing will be completed and tested before entering Mode 2 following this current outage provided qualified parts, etc. are available. Those components not modified during this current outage will be modified and tested no later than the next refueling outage. In the interim, instructions will be provided to the operators where appropriate to accommodate potential flybacks. We will keep your Senior Resident Inspector, Mr. Bill Johnson, informed of our progress on the testing and modifications during this outage.

Mr. John T. Collins 4 April 16, 1982 Also, as we indicated, we will complete a re-evaluation of our previous actions on ANO-1 for response to IE Bulletin 80-06 to identify any potential need for additional action as a result of the re-evaluation on ANO-2 by May 30, 1982. You will be informed of the results of that re-evaluation and any corrective actions required as a result, if any.

Very truly_yours

Wv William Cavanaugh III WC
JTE: cmc 1

Attachments j cc: NRC-NRR 4

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ATTACHMENT 1 CATEGORY 1 COMPONENTS COMPONENT DESCRIPTION 2CV-0798-1 EFW Flush Line Isolation Valve 2CV-0714-1 EFW Flush Line Isolation Valve 2SV-5833-1 RCS Sample Containment Isolation 2SV-5878-1 Quench Tank Containment Isolation 2SV-5843-2 Quench Tank Containment Isolation 2SV-5871-2 RCS Containment Isolation 2CV-5628-2 Containment Spray Recirc. Isolation 2CV-5126-1 Safety Injection Recirc.

2CV-5127-1 Safety Injection Recirc.

2CV-5128-1 Safety Injection Recirc.

2CV-5672-1 Containment Spray Recirc. Isolation 2CV-5673-1 Containment Spray Recirc. Isolation 2CV-5123-1* Safety Injection Recirc.

2CV-5124-1* Safety Injection Recirc.

2CV-5649-1 Cont. Spray Recirc. Isolation 2CV-5650-2 Cont. Spray Recirc. Isolation 2SV-5001-1 Safety Injection Tank Drain 2SV-5021-1 Safety Injection Tank Drain 2SV-5041-2 Safety Injection Tank Drain 2SV-5061-2 Safety Injection Tank Drain Main Steam Isolation Valve 2CV-1010 j 2CV-1060 Main Steam Isolation Valve 2SV-5876-2 SI Tank Sample Isolation PAGE 1 of 2

i ATTACHMENT 1 CATEGORY 1 COMP 0NENTS COMPONENT DESCRIPTION

~

-2CV-1024-1 Main Feedwater Isolation Valve 2CV-1074-1 Main Feedwater Isolation Valve 2CV-6207-2 N2 Isolation Valve 2CV-6213-2 N2 Isolation Valve 2SV-8231-2 H2 Purge Sample Isolation Valve 2SV-8261-2 H2 Purge Sample Isolation Valve

! 2SV-8273-1 H2 Purge Sample Isolation Valve 2SV-8265-1 H2 Purge Sample Isolation Valve 2SV-8271-2 H2 Purge Sample Isolation Valve -

2SV-8263-2 H2 Purge Sample Isolation Valve  !

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. ATTACHMENT 2 CATEGORY 2 COMP 0NENTS COMPONENT DESCRIPTION PAGE 2CV-4873-1 VCT Outlet Valve 4 2CV-4903-2 BAMT 2T-6A Recirc. 4 2CV-4915-2 BAMT 2T-68 Recirc. 4 2CV-4916-2 BA Pump Discharge 4 2CV-4920-1 BAMT 2T-6A Outlet 4 2CV-4921-1 BAMT 2T-6B Outlet 4 2CV-4941-2 CVCS Blend Control 4 2CV-5647-1 Containment Sump Isolation 5 2CV-5648-2 Containment Sump Isolation 5 2E-35A Low Flow Alarm 6 2E-35B Low Flow Alarm 6 186-2DG1 2DG1 Lockout Device 7 4 186-2DG2 2DG2 Lockout Device 7 2SV-0740D FW Reg. Valve 8 2SV-0740E FW Reg. Valve 8 2SV-0744 FW Startuo Valve 8 2SV-07480 FW Reg. Valve 8 2SV-0748E FW Reg. Valve 8 2SV-0753 FW Startup Valve 8 2P-36A Charging Pump 9 2P-36B Charging Purcp ' 9 2P-36C Charging Pump 9 2CV-1025-1 EFW Discharge Valve 10 l 2CV-1026-2 EFW Discharge Valve 10 PAGE 1 of 17

ATTACHMENT 2 CATEGORY 2 COMPONENTS COMPONENT DESCRIPTION PAGE 2CV-1036-1 EFW Discharge Valve 10 2CV-1037-2 EFW Discharge Valve 10 2CV-1038-1 EFW Discharge Valve 10 2CV-1039-2 EFW Discharge Valve 10 2CV-1075-1 EFW Discharge Valve 10 2CV-1076-2 EFW Discharge Valve 10 2P-60A LPSI Pump 11 2P-60B LPSI Pump 11 2SV-8476 ECCS Pump Room Ventilation Dampers 12 2SV-8477 ECCS Pump Room Ventilation Dampers 12 2CV-8471-1 ECCS Pump Room Ventilation Dampers 12 2CV-8472-1 ECCS Pump Room Ventilation Dampers 12 2CV-8474-2 ECCS Pump Room Ventilation Dampers 12 2CV-8475-2 ECCS Pump Room Ventilation Dampers 12 2CV-8497-2 ECCS Pump Room Ventilation Dampers 12

.. 2CV-8498-2 ECCS Pump Room Ventilation Dampers 12 2DG1 DG Start Failure Relay 13 2DG2 DG Start Failure Relay 13 2CV-5003 SIT Isolation Valves 14 2CV-5023 SIT Isolation Valves 14 2CV-5043 SIT Isolation Valves 14 2CV-5063 SIT Isolation Valves 14 2CV-5630-1 RWT Outlet 15 2CV-5631-2 RWT Outlet -15 PAGE 2 of 17

ATTACHMENT 2 CATEGORY 2 COMPONENTS COMPONENT DESCRIPTION PAGE 2RE-8231-1 Rad Monitor 16 2RE-8271-2 Rad Monitor 16 2VCC-2A/B Low Flow Alarm 17 -

2VCC-2C/D Low Flow Alarm 17 PAGE 3 of 17

ATTACHMENT 2 r CATEGORY 2 COMPONENTS i

COMPONENTS-

{

2-CV-4873-1 2-CV-4903-2

' 2-CV-4941-2 '2-CV-4915 2-CV-4920-1 2-CV-4916-2 -

2-CV-4921-1 ESFAS: SIAS

COMPONENT FUNCTION i i 2-CV-4873 VCT Outlet Valve (normally open, SIAS to.close)  ;

t 2-CV-4941 CVCS Blend Control (normally closed, SIAS_to open) 2-CV-4920 BAMT 2T6A Outlet (normally closed, SIAS to open) 2-CV-4921 BAMT 2T6B Outlet (normally closed, SIAS to open) ,

2-CV-4903 BAMT 2T6A Recirc. (normally closed, SIAS to open) -l 2-CV-4915 BAMT 2T6B Recirc. (normally closed, SIAS to open) 2-CV-4916 BA Pump Discharge to Charging Pumps (normally closed, SIAS to open) j QF: YES CATEGORY: 2 SAFETY IMPLICATION .

f No credit was taken for the boration function of the charging system in SIAS events. Boration is accomplished from the RWT.

Repositioning of the CVCS and boration system valves on SIAS reset r does not constitute an improper operational event, since the boration  :

function would be terminated following SIAS by operator action as

- required by current procedures because of boron precipitation '

concerns.

.i Following a~ reset of SIAS, the CVCS boration system would return to l

the operating configuration which existed at the time of the SIAS

  • which would return the RCS volume control to either automatic or i operator control as selected by the operator. The CVCS and boration '

. system valves are routinely. automatically operated for makeup functions, and as such changes in CVCS alignment such as VCT makeup, -

i makeup termination and increases and decreases in number of operating *

- charging pumps would be considered no different following SIAS reset

- than in normal automatic' operating mode. -,

'i CONCLUSION ~

No' reduction in the margin of safety as it' relates to the public' health and safety is involved. ,

PAGE 4 0F 17 i

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ATTACHMENT 2 CATEGORY 2 COMPONENTS COMPONENTS 2CV-5647-1, 2CV-5648-2 ESFAS: RAS COMPONENT FUNCTION Containment sump valves (normally open, RAS to open).

QF: Yes CATEGORY: 2 SAFETY IMPLICATION These valves are the inside containment reactor building sump valves ,

which serve as a water suction source for the safety injection and containment spray pumps when a recirculation actuation signal (RAS) is received.

Due to the location of these valves (i.e. in containment and submerged) therefore being completely inaccessable post accident, they are maintained in the open position (ESFAS position) at all times with key locked switches in the Control Room and verified open at least once each shift.

CONCLUSION As these valves are locked open, no flyback upon reset of a RAS can

, occur, thus the margin of safety as it relates to the public health and safety is not reduced.

PAGE 5 0F 17

ATTACHMENT 2 CATEGORY 2 COMPONENTS COMPONENTS 2E-35A - 62/1453-1 2E-35B - 62/1456-2 ESFAS: RAS COMPONENT FilNCTION Contacts close on a RAS to permit a low service water flow alarm on the shutdown cooling heat exchangers to come in if needed.

QF: Yes CATEGORY: 2 SAFETY IMPLICATION These relays are designed to flyback upon reset of the RAS. Service water does not flow through the shutdown cooling heat exchangers except when in the shutdown cooling mode of operation or the RAS mode.

If the relays did not flyback (open), a continuous low flow alarm would come in when service water was not flowing through the coolers.

The only effect of relay flyback failure would be an unnecessary alarm.

CONCLUSION No reduction in the margin of safety as it relates to the public health and safety is involved.

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ATTACHMENT 2 CATEGORY 2 COMPONENTS l l l

COMPONENTS 186-2DG1 - Diesel Generator Lockout Device j 186-2DG2 - Diesel Generator Lockout Device l

ESFAS: SIAS COMP 0NENT FUNCTION Diesel Generator Protective Relaying QF: No CATEGORY: 2 SAFETY IMPLICATION The diesel generator lockout device is provided to prevent damage to the diesel generator in the event of a fault. Upon safety injection actuation, the diesel generators receive a start signal and at the same time the lockout device is bypassed.

I Upon reset of an ESFAS signal, the protective feature is reinstated, however, the diesel generator would continue to operate uninterrupted, provided no fault existed.

l l Reinstatement of the lockout device would not impair operator response l to the initiating event.

CONCLUSION

{ No reduction in the margin of safety as it relates to the public l

health and safety is involved.

l l PAGE 7 0F 17 i .

ATTACHMENT 2 CATEGORY 2 COMPONENTS COMPONENTS 2SV-0744, 2SV-0740 D&E, 2SV-0748 D&E, 2SV-0753 ESFAS: MSIS COMPONENT FUNCTION Actuating solenoid valves for main feedwater regulating valves and startup (bypass), (normally open) also provide feedwater isolation upon MSIS.

QF: Yes CATEGORY: _ 2 S!FETYIMPLICATION Sufficient redundancy is provided for feedwater isolation on MSIS by the addition of the second (redundant) qualified main feedwater isolation valve in each MFW train.

Resetting MSIS would not now result in re-feeding a steam ge .<: cor even if this valve re-opens and one of the redundant MFW isolation valve fails to close.

Since the main feed pumps and heater drain pumps would not restart in the event an actuation signal cleared, the function of these valves is no longer important since isolation would not be necessary without flow.

CONCLUSION No significant reduction of the margin of safety as it relates to the public health and safety is involved.

PAGE 8 0F 17 l

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i l-ATTACHMENT 2 l CATEGORY 2 COMPONENTS

' COMPONENTS 2P36A, 2P36B, 2P36C 1

1 ESFAS: SIAS COMPONENT FUNCTION Reactor. coolant system charging pumps are used for normal RCS inventory makeup and are started upon SIAS.

QF: Yes CATEGORY: 2 SAFETY IMPLICATION The charging pumps control circuits are designed to flyback upon reset of the SIAS unless pressurizer level control and the charging pump suction pressure are sufficient to require the pumps to run, in which case the pumps would not stop. If charging pump header flow fell below 25 GPM, this condition would be alarmed on 2K12.

No credit was taKen for the boration function of the charging system in SIAS events, boration being accomplished from the RWT.

l SIAS reset does not constitute an improper operational event, since I the boration function would be terminated following SIAS by operator l action as required by current-procedures'because of boron precipitation concerns.

CONCLUSION No significant reduction of the margin of safety as it relates to the

.public health and safety is involved.

PAGE 9 0F 17 L

1 ATTACHMENT 2 CATEGORY 2 COMPONENTS COMPONENTS 2-CV-1036-1 2-CV-1025-1 2-CV-1038-1 2-CV-1075-1 2-CV-1037-2 2-CV-1026-2 2-CV-1039-2 2-CV-1076-2 ESFAS: EFAS COMPONENT FUNCTION Emergency Feedwater Discharge Valves QF: Yes CATEGORY: 2 SAFETY IMPLICATION The actuation signals also serve as control signals to these valves.

These valves have the capability to feed only the unaffected steam generator following an MSIS event, and have been designed to modulate EFW feed through auto-resetting the EFW actuation system.

The auto-resetting feature of the EFW system was reviewed during the original licensing process of Unit 2.

Removing the auto-reset feature from the system could result in creating a new class of steam generator over-feed accidents and would require operator action to prevent over-feed following EFW actuation, such action now being automatic until purposefully made manual by operator action.

CONCLUSION Therefore, the margin of safety as it relates to the public health and safety is maintained without modifications.

PAGE 10 0F 17

ATTACHMENT 2 CATEGORY 2 COMPONENTS COMPONENTS 2P60A, 2P608 ESFAS: SIAS, RAS COMPONENT FUNCTION Low Pressure Safety Injection Pumps (SIAS, RAS to start)

QF: Yes CATEGORY: 2 SAFETY IMPLICATION The LPSI pumps receive two ESFAS signals, SIAS and RAS. The SIAS will start the LPSI pumps. Resetting of the SIAS signal will not stop these pumps. This flyback would not de-energize the LPSI pumps.

The RAS signal will stop the low pressure safety injection. Resetting of the RAS signal will not start the LPSI pumps, provided that the SIAS signal is not present.

There is no evidence that the LPSI pumps would revert to a non-actuated status on reset of either SIAS or RAS.

If SIAS and RAS are considered independently, then there is no flyback. Resetting of RAS with an SIAS signal still present would result in re-start of the LPSI pump and re-injection of water into the RCS. Such an event is unlikely since resetting of RAS would occur only after plant recovery, as this requires refill of the RWT.

CONCLUSION No reduction in the margin of safety as it relates to the public health and safety is involved.

PAGE 11 0F 17

ATTACHMENT 2 CATEGORY 2 COMP 0NENTS COMPONENTS 2CV-8475-2 2CV-8471-1 2CV-8497-2 2CV-8472-1 2CV-8498-2 2SV-8476 2SV-8477 2CV-8474-2 ESFAS: .SIAS COMPONENT FUNCTION ECCS Pump Room Ventilation Dampers 2CV-8475-2, 2CV-8497-2, 2CV-8498-2, 2CV-8471-1, 2CV-8472-1, and 2CV-8474-2 normally closed, SIAS to close.

2-SV-8477 and 2SV-8476 normally open, SIAS to close.

QF: Yes CATEGORY: 2 SAFETY IMPLICATION The ECCS pump room ventilation supplied by the penetration room ventilation system was not assumed to function in the ANO-2 accident analysis.

There are no operational concerns with these dampers repositioning, since their repositioning will not, in itself, restore the radwaste ventilation system to an operating mode, and will not terminate penetration room ventilation. The radwaste area exhaust fans must be manually restarted following the resulting interlocking shutdown after SIAS actuation.

CONCLUSION There are no significant safety implications associated with the flyback feature of these valves.

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A ATTACHMENT 2 CATEGORY 2 COMPONENTS i

COMPONENTS i t-Diesel Generator Start Failure Relay  ;

L

, ESFAS: SIAS  :

COMPONENT FUNCTION  ;

Prevent overcrank of the diesel generator.

QF: No CATEGORY: 2  ;

t SAFETY IMPLICATION i ,

The diesel generator start failure relays are provided to prevent overcranking of a diesel generator. Upon safety injection actuation,  !

the' diesel generators receive a start signal and at the same time the start failure protective relays are bypassed.  ;

. t i

Upon reset of an ESFAS signal, the protective features of this relay ,

would be reinstated; however, the diesel generator if running would

~

continue to run uninterrupted and if not running would be protected  !

from overcranking permitting ~a refill of starting air tanks and the potential for additional start attempts if an ESFAS signal is L repeated. t CONCLUSION

, There are no significant safety implications associated with flyback  ;

of this relay.

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ATTACHMENT 2 CATEGORY 2 COMPONENTS COMPONENTS 2CV-5003, 2CV-5023, 2CV-5043, 2CV-5063 ESFAS: SIAS COMPONENT FUNCTION Safety Injection Tank Isolation Valves (Normally Open)

QF: Yes CATEGORY: 2 SAFETY IMPLICATION These valves are the safety injection tank discharge M0V's and serve to isolate the safety injection tanks during shutdown periods when the RCS pressure is below the pre-charge pressure on the safety injection tanks. These valves are interlocked to automatically open any time the RCS pressure is above 700 psia. The open position is the position they assume on receipt of a safety injection signal. The breakers for these valves are de-energized and locked and the valves are verified open during normal operation. Power is restored to the valves only during plant heatup and cooldown evolutions. These manipulations are administrative 1y controlled and breakers are de-energized and locked upon completion of these operations. In addition, these valves are verified to be open periodically per plant procedures.

CONCLUSION As these valves are locked open (with power removed) in their ESFAS position, no flyback is possible. Therefore, the margin of safety as it relates to the public health and safety is not reduced.

I PAGE 14 0F 17

i ATTACHMENT 2 CATEGORY 2 COMPONENTS COMPONENTS [

2CV-5630-1, 2CV-5631-2.  !

l ESFAS:' RAS, SIAS  !

COMPONENT FUNCTION l

RWT outlet valves (normally open), SIAS to open, RAS to close.

i r

QF: Yes CATEGORY: 2 i

! I t

j SAFETY IMPLICATION [

i  :

These' valves receive two signals (SIAS and RAS). Upon receipt of a [

safety injection signal, these valves would open (verified open once '

per shift per Operating procedures) and would allow suction from the RWT for HPSI, LPSI and containment spray pumps, when the refueling 4

water tank level reaches five feet, these valves receive a recirculation actuation signal initiating closure and realignment of the containment spray system to the containment sump. These valves additionally are interlocked with the containment sump valves _

(2CV-5647-1, 2CV-5649-1, 2CV-5648-2 and 2CV-5650-2) to-ensure that a i water source is always available.

Resetting of RAS could only occur after a. refill of the RWT and would -

i be by direct operator action in accordance with Emergency Operating procedures. If upon reset of RAS an SIAS signal' was still present, t this valve would return to its SIAS position, shifting suction source-to the RWT. Flow delivery to the RCS would not be interrupted. .In no  !

known case will the valves flyback to a non-actuated position. It is t extremely ~unlikely that an SIAS signal would still be present since  ;

resetting of RAS would occur only after plant recovery.

i CONCLUSION

As these valves are interlocked in such a-manner to assure a j continuous supply of suction water, flyback cannot interrupt the h supply. Therefore,~the margin to safety as it relates to the public.  ;

L health and. safety is not involved. ,

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ATTACHMENT 2 CATEGORY 2 COMPONENTS COMPONENTS 2RE-8231-1, 2RE-8271-2 ,

ESFAS: CIS COMPONENT FUNCTION Monitor containment radiation during sampling and H2 purge operations.

QF: Yes CATEGORY: 2 SAFETY IMPLICATION The containment atmosphere radiation monitors would be tripped on receipt of a containment isolation signal. Upon reset of containment isolation, the sample pumps would be enabled for start.

No modification 's deemed necessary because the containment isolation ,

valves in the supply and return piping for these monitors (2SV-8231-2, 2SV-8271-1, 2SV-8273-1, 2SV-8261-2, 2SV-8263-2 and 2SV-8265-1) would  !

remain (not flyback) in the closed position isolating the containment. The sample pumps are protected from damage by low flow interlocks.

Restart of these radiation monitors would not impair operator response I to the incident. l CONCLUSION No reduction in the margin of safety as it relates to the public health and safety is involved.

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ATTACHMENT 2 CATEGORY 2 COMPONENTS COMPONENTS Auxiliary Relay - 62/1521 2VCC-2A/B Containment Coolers Auxiliary Relay - 62/1514 2VCC-2C/D ESFAS: CCAS, MSIS COMPONENT FUNCTION Relay contacts close on ESFAS to permit low flow alarms to come in if needed.

QF: Yes CATEGORY: 2 SAFETY IMPLICATION These relays are designed to flyback upon reset of the CCAS and MSIS.

Service water does not flow through the coolers in normal operation.

If the relays did not flyback (open), a continuous low flow alarm would come in when service water was not flowing through the coolers.

The only effect of relay flyback failure would be an unnecessary alarm.

CONCLUSION No reduction in the margin of safety as it relates to the public health and safety is involved.

PAGE 17 0F 17

ATTACHMENT 3 CATEGORY 3 COMPONENTS COMPONENT DESCRIPTION PAGE

. 2A-301 285 Feeder Breaker 6 2A-401 286 Feeder Breaker 6 28-512 2B5 Main Breaker 7 2B-612 286 Main Breaker 7 2CV-0340-2 EFW Turbine Steam Inlet Valve 8 2CV-0716-1 EFW SW Suction Valve 9 2CV-0789-1 EFW Condensate Suction 9 2CV-0711-2 EFW SW Suction Valve 10 2CV-0795-2 EFW Condensate Suction 10 2CV-1023-2 MFW Isolation Valves 11 2CV-1073-2 MFW Isolation Valves 11 2CV-1425-1 S W Inlet to ACW 12 2CV-1427-2 S W Inlet to ACW 12 2CV-1453-1 S W Inlet to SDC Heat Exchange 13 2CV-1456-2 S W Inlet to SDC Heat Exchange 13 2CV-1511-1 S W Supply to Containment Cooling Units 14 2CV-1519-1 S W Return from Containment Cooling Units 14 2CV-1510-2 S W Supply to Containment Cooling Units 15 2CV-1513-2 S W Return from Containment Cooling Units 15 2CV-1525-1 S W Supply to SFP Heat Exchanger 16 2CV-1526-2 S W Supply to SFP Heat Exchanger 16 2CV-2201-2 Reactor Drain Tank Isolation Valve 17 2CV-2202-1 Reactor Drain Tank Isolation Valve 17 2CV-3200-2 Containment Fire Water Isolation Valve 18 PAGE 1 of 50

t ATTACHMENT 3 CATEGORY 3 COMPONENTS COMPONENT DESCRIPTION PAGE 2CV-4690-2 Quench Tank Makeup Isolation Valve 19 .

2CV-4821-1 Letdown Isolation Valves 20 2CV-4823-2 Letdown Containment Isolation Valve 20 2CV-4846-1 RCP Bleed-off Isolation 21 2CV-4847-2 RCP Bleed-off Isolation 21 -

2CV-5016-2 HPSI Discharge Valve - 22

' 2CV-5015-1 HPSI Discharge Valve 22 2CV-5035-1 HPSI Discharge Valve 22  ;

HPSI Discharge Valve

~

2CV-5036-2 22 2CV-5055-1 HPSI Discharge Valve 22 2CV-5056-2 HPSI Discharge Valve 22 2CV-5075-1 HPSI Discharge Valve 22 2CV-5076-2 HPSI Discharge Valve 22 2CV-5236-1 Component Cooling Water Isolation Valve 23 ,

2CV-5254-2 Component Cooling Water Isolation Valve 24 2CV-5255-1 Component Cooling Water Isolation Valve 24 2CV-5657-1 NaOH Pump Suction 25 2CV-5667-2 Na0H Pump Suction 25 2DG1 DG Auto Start Relay 26 2DG2 DG Auto Start Relay 26 4

2P-4A Service Water Pumps 27 2P-4B Service Water Pumps 27 2P-4C Service Water Pumps 27 2P-78 Emergency Feedwater Pump Breaker 28 PAGE 2 of 50

r ATTACHMENT 3 CATEGORY 3 COMPONENTS COMPONENT DESCRIPTION PAGE 2P-35A Containment Spray Pump 29 2P-35B Containment Spray Pump 29 2P-39A Boric Acid Makeup Pump 30 2P-398 Boric Acid Makeup Pump 30 2P-89A HPSI Pump 31 2P-89B HPSI Pump 31 2P-89C HPSI Pump 31 2P-136A Na0H Addition Pump 32 2P-136B Na0H Addition Pump 32 2SV-0317-2 EFW Turbine Seal Water Supply Solenoid 33 2VCDM-8203-1 Containment Cooler Bypass Damper 34 2UCDM-8209-1 Containment Cooler Bypass Damper 34 2UCDM-8216-2 Containment Cooler Bypass Damper 34 2UCDM-8222-2 Containment Cooler Bypass Damper 34 2UCDM-8851-1 Pent. Room Inlet Ventilation Damper 35 20CDM-8852-2 Pent. Room Inlet Ventilation Damper 35 2UCDM-8853-1 Pent. Room Inlet Ventilation Damper 35 2UCDM-8854-2 Pent. Room Inlet Ventilation Damper 35 2UCDM-8863-1 Pent. Room Inlet Ventilation Damper 35 2VCDM-8864-2 Pent. Room Inlet Ventilation Damper 35 20CDM-8865-1 Pent. Room Inlet Ventilation Damper 35 20CDM-8866-2 Pent. Room Inlet Ventilation Damper 35 2VEF-25A-1 Intake Structure Exhaust Fans 36 2VEF-25B-2 Intake Structure Exhaust Fans 36 PAGE 3 of 50 u

ATTACHMENT 3 CATEGORY 3 COMP 0NENTS COMPONENT DESCRIPTION PAGE 2VEF-38A-1 Pent. Room Exhaust Fan 37 2VEF-38B-2 Pent. Room Exhaust Fan 37 2VUC-2A-2 SWGR Unit Cooler 38 2VUC-28-2 SWGR Unit Cooler Standby 38 2VUC-2C-1 SWGR Unit Cooler 38 2VUC-2D-1 SWGR Unit Cooler Standby 38 2VUC-19A-1 Electrical Equipment Room Unit Cooler 39 2VUC-198-1 Electrical Equipment Room Unit Cooler 39 2VUC-20A-2 Electrical Equipment Room Unit Cooler 39 2VUC-20B-2 Electrical Equipment Room Unit Cooler 39 2CV-8283-1 Containment Purge Air Valve 40 2CV-8284-2 Containment Purge Air Valve 40 2CV-8285-1 Containment Purge Air Valve 40 2CV-8286-2 Containment Purge Air Valve 40 2CV-8289-1 Containment Purge Valve 40 2CV-8291-1 Containment Purge Valve 40 2CV-3850-2 Containment Chill Water Isolation 41 2CV-3851-1 Chill Water Containment Isolation Valve 41 2CV-3852-1 Chill Water Containment Isolation Valve 41 2CV-5852-2 Steam Generator Sample Valve 42 2CV-5859-2 Steam Generator Sample Valve 42 2CV-1530-1 Service Water Inlet to CCW 43 2CV-1531-2 Service Water Inlet to CCW 43 2CV-1541-1 Service Water to ECP 43 PAGE 4 of 50

J ATTACHMENT 3 c , .

CATEGORY 3 COMPONENTS COMPONENT DESCRIPTION PAGE 2CV-1542-2 Service Water from HDR #2 43

- 2CV-1543-1 Service Water Outlet from CCW 43 2CV-1560-2 Service Water Discharge to ECP 43 2CV-2400-2 Containment Vent Header. Valve 44 2CV-2401-1 Containment Vent Header Valve 44 2CV-2060-1 Containment Sump Drain Valve 45 2CV-2051-2 Containment Sump Drain Valve 45 2CV-1400-1 SW Inlet to ESF Pump Room Coolers 46 2CV-1406-2 SW Inlet to ESF Pump Coolers 46 2VSF-1A Containment Cooling Fan 47

'2VSF-1B Containment Cooling Fan 47 2VSF-1C Containment Cooling Fan 47 2VSF-10 Containment Cooling Fan 47 2CV-5017-1 LPSI Discharge Valve 48 2CV-5037-1 .LPSI Discharge Valve 48 2CV-5057-2 LPSI Discharge Valve 48 2CV-5077-2 LPSI Discharge Valve 48 ,

2CV-8233-1 Containment Air Sample Valve 49 2CV-8259-1 Containment Air Sample Valve 49 2A-308 2DG1 A.C.B. 50 2A-408 2DG2 A.C.B. 50 PAGE 5 of 50 .

l ATTACHMENT 3 CATEGORY 3 COMPONENTS i

COMPONENTS Breaker 2A301, 2 ado 1 ,

t i

ESFAS: __SIAS ,

COMPONENT FUNCTION  !

285 and 286 480V load center transformer feeders, normally closed, SIAS to I close, j i

QF: Yes CATEGORY: 3  !

SAFETY IMPLICATION These breakers are not designed to flyback upon reset of the SIAS. As these  :

breakers are normally in their ESFAS position, no change of position would i occur on a SIAS, thus no flyback. However, should they open, the control i i room operators would be immediately aware by the myriad alarms and/or loss  !

i of indication on the 480 and 120V systems. Position indication and manual

  • control is provided in the control room. A diesel generator auto start [

would occur within 8 seconds due to the degraded voltage protection relay on 3 i the 480V bus.

CONCLUSION l l

No reduction in the margin of safety as it relates to the public health and  :

safety is involved. ,

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ATTACHMENT 3 ,

CATEGORY 3 COMPONENTS COMPONENTS 2B512, 28612 i

ESFAS: SIAS COMPONENT FUNCTION 285 and 286 load center main, normally closed, SIAS to close breakers.

QF: Yes CATEGORY: 3 i SAFETY IMPLICATION These breakers are not designed to flyback upon reset of the SIAS. As these breakers are normally in their ESFAS position, no change of position would occur on a SIAS, thus no flyback, llowever, should they open, the control room operators would be immediately aware by the myriad alarms and/or loss of indication on the 480 and 120V systems. Position indication and manual control is provided in the control room. A diesel generator auto start would occur within 3 seconds due to the degraded voltage protection relay on the 480V bus.

4 l CONCLUSION No reduction in the margin of safety as it relates to the public health and safety is involved.

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PAGE 7 0F 50 m._ ._

ATTACHMENT 3 CATEGORY 3 COMPONENTS  !

COMPONENTS 2CV-0340-2 ESFAS: EFAS i

COMPONENT FUNCTION l Steam inlet valve to EFW turbine driver. V>1ve normally closed. EFAS to open.

QF: Yes CATEGORY: 3 SAFETY IMPLICATION I 2CV-0340-2 is not designed to flyback following reset of the EFAS. Should ,

the valve flyback to its normally closed position, the turbine driver would l shut down due to low steam flow. If actual plant conditions continued to require EFW, an automatic reinitiation of the EFAS would occur reopening the t valve. The operator could manually reopen the valve and restart the pump.

Such a flyback would not affect the redundant motor-driven EFW pump and system. I 2CV-0340-2 has been frequently actuated since ANO-2 startup and has never  :

exhibited flyback characteristics. There are no known cases of the EFW pump '

i shutting down due to 2CV-0340-2 closing by any means other than manual 1 action. ,

CONCLUSION No reduction in the margin of safety as it relates to the public health and safety is involved. .

i PAGE 8 0F 50 ,

ATTACHMENT 3 CATEGORY 3 COMPONENTS j

COMPONENTS  !

l 2CV-0716-1, 2CV-0789-1 ESFAS: EFAS  :

t i

COMPONENT FUNCTION  !

2CV-0716-1 supplies service water suction to the motor-driven EFW pump  !

(normally closed). i j_ 2CV-0789-1 supplies condensate suction to the motor-driven EFW pump  ;

j (normally open).  !

QF
Yes CATEGORY: 3 j l

SAFETY IMPLICATION  !

These valves are not designed to flyback following reset of an EFAS. These  :

valves are interlocked such that one is always open and the other closed.

The EFAS signals applied to these valves provide auto-enabling .

(interlocking) functions only and do not actuate these valves.

i CONCLUSION [

1 r

! A reduction in the margin of safety as it relates to the public health and l safety is not involved. '

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PAGE 9 0F 50  ;

t ATTACHMENT 3

, CATEGORY 3 COMPONENTS i

COMPONENTS I 2CV-0795-2, 2CV-0711-2 t

ESFAS: EFAS, EFAS COMPONENT FUNCTION 2CV-0795-2 is condensate suction to EFW pump turbine (normally open).

2CV-0711-2 SW suction to EFW pump turbine (normally closed).

Both normally in ESFAS position.

QF: Yes CATEGORY: 3 SAFETY IMPLICATION j These valves are not designed to flyback following reset of an EFAS. These valves are interlocked such that one is always open and the other closed.

] The EFAS signals applied to these valves provide auto-enabling functions only and do not, in themselves, actuate those valves.

CONCLUSION A reduction in the margin of safety as it relates to the public health and safety is not involved.

E e

PAGE 10 0F 50

ATTACHMENT 3 CATEGORY 3 COMPONENTS COMPONENTS 2CV-1023-2, 2CV-1073-2 ESFAS: MSIS #1 COMPONENT FUNCTION Main feedwater isolation valves (normally open) (MSIS to close).

QF: Yes CATEGORY: 3 SAFETY IMPLICATION These valves are not designed to flyback following reset of a MSIS.

Redundant valves 2CV-1023-2 and 2CV-1073-2 have recently been installed and likewise are designed to not flyback on reset of a MSIS. Feedwater line ruptures outside containment are mitigated by MFW check valve closure even if both MFW isolation MOVs were to flyback to an open position. The safety significance of flyback of isolation valves due to re-feeding a ruptured steam generator is considered minimal due to the extremely low probability of simultaneous occurrence of all of the following:

1. Both MFW isolation valves having an undetected flyback feature after multiple reviews indicating none exists, and one set of isolation valves having been tested to prove freedom from flyback responses.
2. Resetting MSIS on a ruptured steam generator when PPS design would not allow MSIS to be reset if actuated and steam generator is depressurized.
3. A condensate pump, MFW pump or heater drain pump being re-started or auto-started concurrent with MSIS reset, when design and operating history show this to be extremely unlikely.

CONCLUSION The margin of safety as it relates tc the public health and safety is not significantly degraded.

PAGE 11 0F 50

ATTACHMENT 3 CATEGORY 3 COMPONENTS COMPONENTS 2CV-1427-2, 2CV-1425-1 ESFAS: SIAS, MSIS ,

COMPONENT FUNCTION I

Service water inlet to auxiliary cooling system (normally open) (SIAS, MSIS to close).

QF: Yes CATEGORY: 3 ,

SAFETY IMPLICATION These valves are not designed to flyback following a reset of the SIAS and/or MSIS. The SIAS/MSIS closes these valves to isolate the non-safety <

. auxiliary cooling water (ACW) system. Should these valves flyback to their normally open position, service water would be restored to the auxiliary cooling system heat exchangers. Restoration of service water flow to this system would cause a flow reduction in one of the two service loops (whichever was aligned to supply ACW). Both SW loops would not be affected, and the loop with reduced flow would only cause a performance reduction in one loop which would be detected by indications provided to the control room operators.

CONCLUSION No reduction in the margin of safety as it relates to the public health and safety is involved.

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J PAGE 12 0F 50 G

i ATTACHMENT 3 '

CATEGORY 3 COMPONENTS COMPONENTS 2CV-1453-1; 2CV-1456-2 ESFAS: RAS COMPONENT FUNCTION Service water inlet valves tc shutdown cooling heat exchangers (normally closed, RAS to open).

QF: Yes CATEGORY: 3 1

SAFETY IMPLICATION i

These valves are not designed to flyback upon reset of a RAS. Should they 4 flyback to their closed position, service water to the heat exchangers would

! be terminated. Emergency Operating procedures specify that RAS not be reset 4

unless RAS cooling of the RCS was no longer necessary. Operating procedures for the desired means of long-term RCS cooling would be used which would specify system alignments and activities. Adequate time exists to allow these valves to be manually aligned as instructed in operating procedures.

CONCLUSION I No significant reduction in the margin of safety as it relates to the public health and safety is involved.

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PAGE 13 0F 50-

ATTACHMENT 3 i

CATEGORY 3 COMP 0NENTS COMPONENTS 2CV-1511-1, 2CV-1519-1 ESFAS: CCAS, MSIS COMPONENT FUNCTION 2CV-1511-1 service water supply to containment coolers 2VCC-2A/B (normally open in ESFAS position).

2CV-1519-1 SW return from containment coolers 2VCC-2A/B (normally closed, Opens on CCAS or MSIS).

QF: Yes CATEGORY: 3 SAFETY IMPLICATION These valves are not designed to flyback upon reset of a CCAS and/or MSIS.

As 2CV-1511-1 is normally in its ESFAS position, no change of position upon CCAS/MSIS or reset of CCAS/MSIS would occur. Should 2CV-1519-1 flyback to its closed position upon reset of CCAS/MSIS, flow would be stopped through the coolers. As the purpose of the coolers is long term heat removal and containment pressure reduction, a CCAS and/or MSIS would be automatically reinitiated if the coolers were required. In addition, ANO-2 safety analyses demonstrate that no containment coolers are necessary to mitigate any accident if two trains of containment spray are available.

CONCLUSION No reduction in the margin of safety as it relates to the public health and safety is involved.

FAGE 14 0F 50

ATTACHMENT 3 CATEGORY 3 COMPONENTS COMPONENTS 2CV-1513-2, 2CV-1510-2 ESFAS: CCAS COMPONENT FUNCTION 2CV-1513-2 SW return from 2VCC-2C/D header number 2 (normally closed).

2CV-1510-2 inlet isolation valve for 2VCC-2C/D (normally open).

QF: Yes CATEGORY: 3 SAFETY IMPLICATION These valves are not designed to flyback upon reset of a CCAS and/or MSIS. .

As 2CV-1510-1 is normally aligned in its ESFAS position, no change of r position upon CCAS/MSIS or reset of CCAS/MSIS would occur. Should 2CV-1513-1 flyback to its closed position upon reset of CCAS/MSIS, flow would be stopped through the coolers. As the purpose of the coolers is long term heat removal and containment pressure reduction, a CCAS and/or MSIS would be automatically reinitiated if the coolers were required. In addition, ANO-2 safety analyses demonstrate that no containment coolers are necessary to mitigate any accident if two trains oT containment spray are available.

CONCLUSION No reduction in the margin of safety as it relates to the public health and safety is involved.

PAGE 15 0F 50

ATTALHMENT 3 CATEGORY 3 COMPONENTS COMPONENTS 2CV-1525-1, 2CV-1526-2 ESFAS: MSIS, SIAS COMPONENT FUNCTION Service water to spent fuel heat exchanger. (2CV-1525-1 normally open, MSIS or SIAS to close). (2CV-1526-2 normally closed, MSIS or SIAS to close.)

QF: Yes CATEGORY: 3 SAFETY IMPLICATION These valves are not designed to flyback upon reset of a MSIS and/or SIAS.

One valve of the pair is normally in its ESFAS position. Therefore, a MSIS or SIAS would not cause a change of position negating a flyback. Should the other valve (normally open) flyback upon reset of a MSIS and/or SIAS, service water cooling to the spent fuel pool heat exchanger would be restored reducing the affected SW supply header pressure. Low SW header pressure is annunciated and header pressure is displayed in the control room. Operators have sufficient time to detect and alleviate the reduced header pressure condition before safeguards components degrade from high temperature.

CONLLUSION No significant reduction in the margin of safety as it relates to the public health and safety is involved.

PAGE 16 0F 50

ATTACHMENT 3 CATEGORY 3 COMPONENTS i

COMPONENTS l l.

2CV-2202-1, 2CV-2201-2 l

[

ESFAS: SIAS, CIAS i COMPONENT FUNCTION I

Reactor drain tank isolation valve (normally closed, SIAS or CIAS to close).

QF: Yes CATEGORY: 3  ;

t SAFETY IMPLICATION These valves are not designed to flyback following reset of a SIAS and/or

  • CIAS. These valves are interlocked with the reactor drain tank pumps such that the pumps trip if the valves close. These valves are very infrequently  ;

opened and then only for very short periods of time. Thus the probability  ;

of any flyback to an open position occurring is very low. j i

CONCLUSION  !

The margin of safety as it relates to the public health and safety is not significantly degraded.  ;

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ATTACHMENT 3 CATEGORY 3 COMPONENTS  !

c

+

COMPONENTS l'

2CV-3200-2 ESFAS: CIAS, SIAS I

COMPONENT FUNCTION i i

Fire water containment isolation valve (normally open, CIAS or SIAS to close).  ;

QF: Yes CATEGORY: 3 l

SAFETY IMPLICATION This valve is not designed to flyback upon reset of the CIAS and/or SIAS. i Should the valve flyback, containment integrity would be maintained as a  ;

check valve is provided inside containment for the second level of isolation. The fire water supply system provides water to hose reels and normally closed sprinkler systems, t

CONCLUSION Containment integrity is maintained regardless of the position of this valve. Therefore, no reduction in the margin of safety as it relates to the public health and safety is involved.  :

i PAGE 18 0F 50 t

I I

ATTACHMENT 3 CATEGORY 3 COMPONENTS COMPONENTS 2CV-4690-2 i ESFAS: SIAS, CIAS COMPONENT FUNCTION Reactor makeup water to the quench tank containment isolation valve.

Normally closed; SIAS, CIAS to close.

QF: Yes CATEGORY: 3 SAFETY IMPLICATION This valve is not designed to flyback following reset of the SIAS and/or CIAS. As this valve is normally closed and receives a SIAS/CIAS to close, no change of position would occur upon reset of ESFAS. In addition, a check valve and a normally closed non-ESFAS motor-operated valve (botn inside

{. containment) provide redundant isolation should the valve unexpectedly open

upon ESFAS reset.

CONCLUSION i

No significant reduction in the margin of safety as it relates to the public health and safety is invovled.

l t

PAGE 19 0F 50

ATTACHMENT 3 CATEGORY 3 COMPONENTS COMPONENTS 2CV-4821-1, 2CV-4823-2 ESFAS: SIAS and CIAS COMPONENT FUNCTION ,

Letdown isolation valves (SIAS and CIAS to close) normally open.

QF: Yes CATEGORY: 3 SAFETY IMPLICATION I

These valves are not designed to flyback following reset of the SIAS and/or '

CIAS. For those accidents where letdown isolation is necessary to assist in mitigation of an accident, emergency operating procedures require closing the valve by placing the hand switch in the control room in the closed position. This is a positive close signal which precludes flyback. In other scenarios not procedurally addressed, flyback should not result in negative consequences. Operator instructions with regard to use and positioning of these valves are provided in recovery and shutdown procedures.

Additionally, there is no operator recollection of any flyback characteristics of these valves upon reset following actual and inadvertent SIAS actuation events which have occurred at ANO.

CONCLUSION No reduction in the margin of safety as it relates to the public health and i safety is involved.

PAGE 20 0F 50

ATTACHMENT 3 CATEGORY 3 COMPONENTS COMPONENTS 2CV-4847-2, 2CV-4846-1 ESFAS: CIAS, SIAS COMPONENT FUNCTION Containment isolation (normally open, SIAS or CIAS to close). RCP bleed-off.

2 QF: Yes CATEGORY: 3 SAFETY IMPLICATION These valves are not designed to flyback following reset of a CIAS and/or SIAS actuation. In the unlikely event both valves exhibited undetected flyback features, only a small, controlled and metered quantity of coolant

(< 5 gpm total from full RCS pressure) is bled to the volume control tank.

The VCT and its piping is designed to accept primary coolant; further failures must occur before a radioactive release would occur. The loss of primary inventory is not considered significant due to the low flow rates involved.

CONCLUSION No significant reduction in the margin of safety as it relates to the public health and safety is involved.

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ATTACHMENT 3 CATEGORY 3 COMPONENTS COMPONENTS 2CV-5035-1, 2CV-5036-2, 2CV-5056-2, 2CV-5076-2, 2CV-5055-1, 2CV-5016-2, 2CV-5075-1, 2CV-5015-1 ESFAS: SIAS COMPONENT FUNCTION High pressure safety injection discharge valves (normally closed, SIAS to open).

QF: Yes CATEGORY: 3 SAFETY IMPLICATION These valves are not designed to flyback following reset of the SIAS. If plant conditions exist which require high pressure safety injection, the SIAS would not reset. If conditions do not warrant high pressure safety injection, (i.e., RCS pressure restored), HPSI flow would already have dropped to zero due to RCS pressures being greater than HPSI pump head.

Under such conditions, resetting SIAS and subsequent postulated HPSI MOV flyback would have no safety impact.

CONCLUSION No significant reduction in the margin of safety as it relates to the public health and safety is involved.

PAGE 22 0F 50

ATTACHMENT 3 CATEGORY 3 COMPONENTS l

COMPONENTS 2CV-5236-1 ESFAS: CIAS l

COMPONENT FUNCTION  !

Component cooling water isolation valve (normally open, CIAS to close).

QF: Yes CATEGORY: 3 i F

SAFETY IMPLICATION This valve is not designed to flyback following reset of the CIAS. Redun-dant containment isolation is provided by a check valve inside containment. +

The CCW system is an isolated closed loop system. Operating procedures require re-establishing CCW to the RCP seals following a CIAS within a relatively short time frame or reactor coolant pump trip. Therefore, it is probable that this valve would be returned manually to its normally open position prior to a CIAS reset.

i CONCLUSION No reduction in the margin of safety as it relates to the public health and safety is involved. i b

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PAGE 23 0F 50

ATTACHMENT 3 CATEGORY 3 COMPONENTS COMPONENTS 2CV-5254-2, 2CV-5255-1 ,

ESFAS: CIAS COMPONENT FUNCTION Component cooling water isolation (outlet, normally open, CIAS to close).

QF: Yes CATEGORY: 3 SAFETY IMPLICATION These valves are not designed to flyback following reset of the CIAS. The CCW inlet is isolated on a CIAS. The CCW system is an isolated closed loop system. Operating procedures require re-establishing CCW to the RCP seals following a CIAS within a relatively short time frame or reactor coolant pump trip. Therefore, it is probable that these valves would be returned manually to their normally open position prior to a CIAS reset.

CONCLUSION l

No reduction in the margin of safety as it relates to the public health and safety is involved.

PAGE 24 0F 50 i

l ATTACHMENT 3 CATEGORY 3 COMPONENTS COMPONENTS 2CV-5657-1, 2CV-5667-2 ESFAS: CSAS COMPONENT FUNCTION Supply for 2P-136A&B (Na0H supply pumps) (normally closed, CSAS to open).

QF: Yes CATEGORY: 3 SAFETY IMPLICATION These valves are not designed to flyback following reset of the CSAS.

Should plant conditions require containment spray following reset of the CSAS, a CSAS signal would be automatically reinitiated. If a CSAS is not required and containment spray therefore not required, termination of Na0H to the containment spray water would have no adverse affect on plant conditions outside those previously analyzed.

CONCLUSION No significant reduction in the margin of safety as it relates to the public health and safety is involved.

PAGE 25 0F 50 e

I' ATTACHMENT 3 CATEGORY 3 COMPONENTS COMPONENTS 2DG1 Start Relays 2DG2 Start Relays ESFAS: SIAS

' COMPONENT FUNCTION 1

Provide start signal to diesel generators to supply emergency power.

QF: Yes CATEGORY: 3 SAFETY IMPLICATION The emergency diesels do not change modes due to resetting the SIAS actuated start relays.

I CONCLUSION Since diesel generator operation is not affected by the resetting feature of

, the SIAS start relays there is no reduction in the margin of safety as it 2

relates to tne public health and safety.

4

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PAGE 26 0F 50  :

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ATTACHMENT 3 CATEGORY 3 COMPONENTS COMPONENTS 2P-4A, 2P-4B, 2P-4C ESFAS: SIAS, MSIS, EFAS-A, EFAS-B COMPONENT FUNCTION These pumps provide service water which is the safety-related heat sink for plant cooldown following an accident and is the heat sink for non-safety related aux-iliary cooling water and component cooling water systems.

QF: Yes CATEGORY: 3 SAFETY IMPLICATION The service water pumps are designed not to trip upon ESFAS reset. If 2P-4A, 2P-4B or 2P-4C were to trip upon resetting of the actuation signal, the following indication is provided:

1. Tripping of the pumps that were running prior to the actuation would be annunciated.
2. Service water loop low pressure is annunciated with the annunciator corrective action procedure, 2203.12, directing the operator to the loss of service water procedure if service water pressure approaches 0 psig.
3. If the condition that initiated the ESFAS returned after the operator reset the ESFAS, the pumps would automatically restart.
4. Red / green indicating lights on 2C-16 and 2C-17.
5. Miscellaneous temperature switches initiate room cooler high temperature alarms such as 2K04-F4. The annunciator corrective action procedure, 2203.12, will direct the operator to verify service water flow.
6. No SW pump " auto-stop" event has ever been acknowledged through any safeguards functional testing conducted since ANO-2 startup.

CONCLUSION Because of the many diverse indications of loss of service water flow, no significant reduction in the margin of safety as it relates to the public health and safety is involved.

PAGE 27 0F 50

ATTACHMENT 3 CATEGORY 3 COMPONENTS COMPONENTS 2P-7B Breaker ESFAS: SIAS COMPONENT FUNCTION Breaker to start 2P-78 motor-driven emergency feedwater pump.

QF: Yes CATEGORY: 3 SAFETY IMPLICATION This breaker is not designed to flyback following reset of the EFAS. Should the breaker flyback to its normally open position, the pump would trip. If actual plant conditions continued to require EFW, an automatic reinitiation of the EFAS would occur, starting the system. Should this not occur, the operators would be aware of the trip by indication in the control room, EFW flow rate indication, EFW low flow alarm and low steam generator level. The operator could manually restart the pump and follow specific procedural steps for operation. Such a flyback would not affect the redundant turbine-driven EFW pump and system. EFW operation has automatically actuated many times on ANO-2; in no event has 2P-7B " auto-stopped" on EFAS auto reset.

CONCLUSION No reduction in the margin of safety as it relates to the public health and safety is involved.

1 PAGE 28 0F 50

l ATTACHMENT 3 -

CATEGORY 3 COMPONENTS COMPONENTS 2P35A and 2P35B (Containment Spray Pumps) j ESFAS: CSAS l

COMPONENT FUNCTION Start on containment spray actuation signal. Spray pumps are in operation i during containment sump recirculation for long-term sump cooling. '

QF: Yes CATEGORY: 3 SAFETY IMPLICATION The containment spray pumps are not designed to flyback following reset of CSAS. Close observation and maintenance of specified spray header flow is addressed in emergency operating procedures. Should the pumps flyback after CSAS is reset, automatic re-initiation would occur when setpoint was reached. If the setpcint for automatic initiation was not reached subsequent to resetting of the CSAS, containment sump recirculation would still be accomplished by starting the pumps manually and performing Section ,

I, Step 3.8 of Emergency Operating Procedure 2202.06, " loss of Coolant."

CONCLUSION No significant reduction in margin of safety as it relates to the public ,

health and safety is involved.

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ATTACHMENT 3 CATEGORY 3 COMPONENTS o

COMPONENTS 2P39A and 2P39B (Boric Acid Addition Pumps)

ESFAS: SIAS COMPONENT FUNCTION Boric acid addition pumps start on SIAS to supply concentrated boric acid to charging pumps suction.

QF: Yes CATEGORY: 3 SAFETY IMPLICATION The boric acid addition pumps are not designed to flyback on reset of SIAS.

Should the pumps stop on reset of SIAS, a redundant supply of boric acid to charging pumps suction is available through two separate gravity drain lines from the boric acid storage tanks. However, since no credit was taken for the boration function of the charging system in SIAS events, boration being accomplished from the RWT. Further, stopping boration would not constitute i an improper operational event, since the boration function would be terminated following SIAS by operator action as required by AN0 procedures because of boron precipitation concerns.

CONCLUSION No significant reduction in the margin of safety as it relates to the public health and safety is involved. ,

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PAGE 30 0F 50 l

-ATTACHMENT 3 CATEGORY 3 COMPONENTS COMPONENTS 2P-89A, 2P-89B, 2P-89C ESFAS: SIAS COMPONENT FUNCTION Provide high pressure safety injection flow (SIAS to start).

QF: Yes CATEGORY: 3 SAFETY IMPLICATION Pumps will start upon receipt of SIAS and are not designed to trip on reset.

In the event this system did revert to the non ESFAS condition on reset of the SIAS and conditions still warranted, a reinitiation of pump operations would occur. If conditions do not warrant HPSI, i.e., RCS pressures are restored to normal values and allowing SIAS reset, no flow delivery via the HPSI system could occur due to the relatively low discharge head of the HPSI pumps. Since no flow conditions exist, stopping or starting HPSI pumps does not alter any actual conditions.

CONCLUSION No significant reduction in the margin of safety as it relates to the public health and safety is involved.

PAGE 31 0F 50

ATTACHMENT 3 CATEGORY 3 COMPONENTS COMPONENTS 2P-136A, 2P-136B L

i ESFAS: CSAS l

COMPONENT FUNCTION ,

r NaOH pumps start on CSAS to inject Na0H into spray header during containment l spray actuation.

QF: Yes CATEGORY: 3 SAFETY IMPLICATION The NaOH pumps are not designed to trip upon reset of CSAS. The Na0H addition pumps will start automatically and inject NaOH to the containment spray header if the containment spray pumps are running and a CSAS is received. If NaOH addition pumps were terminated when the CSAS was reset, ,

the pumps would restart if the CSAS was reinitiated. If a CSAS is not required and containment spray therefore not required, termination of NaOH to the containment spray water would have no affect on plant conditions -

outside those previously analyzed. 4 CONCLUSION No reduction in the margin of safety as it relates to the public health and safety is involved. '

PAGE 32 0F 50

ATTACHMENT 3 CATEGORY 3 COMPONENTS COMPONENTS 2SV-0317-2 ESFAS: EFAS COMPONENT FUNCTION Seal water solenoid valve to EFW turbine (normally closed, EFAS enabled to open).

QF: Yes CATEGORY: 3 SAFETY IMPLICATION This valve is not designed to flyback following reset of an EFAS. Should the valve flyback to its normal closed position, seal water to the EFW turbine driver would be lost. 2SV-0317-2 is interlocked with 2CV-0340-2 (steam inlet valve to the turbine driver) such that both valves must be either open or closed. Therefore, closure of 2SV-0317-2 would require closure of 2CV-0340-2 resulting in a turbine shutdown. The two valves are controlled by a single handswitch.

CONCLUSION Due to the interlocking design, it is not possible to damage the turbine driver if a flyback did occur. The margin of safety as it relates to the public health and safety is not reduced.

PAGE 33 0F 50

ATTACHMENT 3 ,

CATEGORY 3 COMPONENTS COMPONENTS 2UCDM-8216-2, 2UCDM-8203-1, 2UCDM-8222-2, 2UCDM-8209-1 ESFAS: CCAS COMPONENT FUNCTION Containment cooling unit bypass dampers (normally closed, CCAS to open).

QF: Yes CATEGORY: 3 SAFETY IMPLICATION These dampers are not designed to flyback following reset of a CCAS. The CCAS signal is provided to the bypass damper motors which by turning a

. retaining lug allow the bypass dampers to physically drop in place by gravity. Manual reset and lifting into place of the dampers is required to reclose the bypass. Therefore, no physical means exists to reclose the bypass should the bypass damper motors flyback.

CONCLUSION No reduction in C' margin of safety as it relates to the public health and s a n.s exists.

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i PAGE 34 0F 50-l i

r ATTACHMENT 3 CATEGORY 3 COMPONENTS COMPONENTS 2UCDM-8863-1, 2UCDM-8866-2, 2VCDM-8865-1, 2UCDM-8864-2, 2VCDM-8851-1, 2VCDM-8852-2, 20CDM-8853-1, 2VCDM-8854-2 ESFAS: CIAS COMPONENT FUNCTION Penetration room inlet ventilation dampers.

QF: Yes CATEGORY: 3 SAFETY IMPLICATION These dampers are not designed to flyback following reset of the CIAS. Upon CIAS, the penetration room ventilation system actuates drawing suction from the penetration rooms and discharging the air after filtering through charcoal and HEPA filters. These dampers provide air into the penetration rooms. Should they flyback upon CIAS reset, an additional amount of air would be pulled into the penetration room and filtered before discharge.

ANO-2 safety analyses do not take credit for the DF of the penetration room ventilation system. Therefore, failure of the entire system wotld not ~

result in off-site releases outside the bounds of current safety analyses.

CONCLUSION No reduction in the margin of safety as it relates to the public health and safety is involved.

o PAGE 35 0F 50

ATTACHMENT 3 CATEGORY 3 COMPONENTS COMPONENTS 2VEF-25A-1, 2VEF-25B-2

.ESFAS: MSIS, SIAS COMPONENT FUNCTION Intake structure exhaust fans.

QF: Yes CATEGORY: 3 SAFETY IMPLICATION These fans are not designed to flyback following reset. The fat; are normally controlled by a QF room temperature controller. Therefore, they may be either on or off at the time of the ESFAS. The fans will start and/or continue to run upon the ESFAS. Should they flyback to a stopped position following reset, the normal temperature controller would resume fan

control and reactuate the fans when necessary.

CONCLUSION No reduction in the margin of safety as it relates to the public health and safety is involved.

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PAGE 36 0F 50

ATTACHMENT 3 CATEGORY 3 COMP 0NENTS COMPONENTS 2VEF-38A-1, 2VEF-38B-2 ESFAS: CIAS COMPONENT FUNCTION Penetration room exhaust fans normally tripped. CIAS to start.

QF: Yes CATEGORY: 3 SAFETY IMPLICATION These fans are not designed to f!3 back following reset of the CIAS. Upon CIAS, the fans auto start drawing air from the penetration rooms and discharging it through charcoal and HEPA' filters. Should the fans flyback to the shutdown condition, no air would be removed from the penetration rooms. ANO-2 safety analyses do not take credit for the DF of the penetration room ventilatien system. Therefore, failure of the entice system would not result in off-site releases outside the bounds of current safety analyses.

CONCLUSION Na reduction in the margin of safety as it relates to the public health and safety is involved.

l PAGE 37 0F 50

,. ATTACHMENT 3 CATEGORY 3 COMPONENTS COMPONENTS 2VUC-2A, 2VUC-2C, 2VUC-2B, 2VUC-2D ESFAS: SIAS COMPONENT FUNCTION Unit coolers for switchgear rooms. (SIAS to start coolers.)

QF: Yes CATEGORY: 3 SAFETY IMPLICATION The electrical equipment room unit coolers are not designed to stop when SIAS is reset. (SIAS starts cooler.) If flyback could occur, stop indication on 2C-16 and 2C-17 is available. A trouble alarm on low flow is provided in the control room. High air temoerature at the cooler discharge will also alarm in the control room. Sufficient time is available for operator action prior to component degradation.

CONCLUSION

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No significant reduction in the margin of safety as it relates to the pub 1ic health and safety is involved. ,

PAGE 38 0F SO

ATTACHMENT 3 CATEGORY 3 COMPONENTS COMPONENTS 2VUC-19A-1, 2VUC-19B-1, 2VUC-20A-2, 2VUC-208-2 ESFAS: SIAS COMPONENT FUNCTION Electrical equipment room unit coolers.

QF: Yes CATEGORY: 3 SAFETY IMPLICATION The electrical equipment room unit coolers are not designed to flyback upon SIAS reset (i.e. a SIAS starts the coolers). Should flyback occur, stop indication is provided to the operators in the Control Room on panels 2C-16 and 2C-17. A trouble alarm on low flow is also provided in the control room and available to the operators as well as a high air temperature alarm.

Sufficient time is available to allow operator action to restore cooling unit operation prior to component degradation.

CONCLUSION No significant reduction in the margin of safety as it relates to the pu,blic health and safety is involved.

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ATTACHMENT 3 CATEGORY 3 COMPONENTS l

COMPONENTS 2CV-8283-1, 2CV-8289-1, 2CV-8284-2, 2CV-8285-1, 2CV-8291-1, 2CV-8286-2 ESFAS: SIAS, CIAS COMPONENT FUNCTION Containment purge air in and out (normally closed, SIAS, CIAS to close).

QF: Yes CATEGORY: 3 '

SAFETY IMPLICATION ,

These valves are not designed to flyback following reset of a SIAS and/or  :

CIAS. These valves are normally closed and receive a SIAS/CIAS to close.

Therefore, no change of position would occur and likewise no flyback would occur. The valves can be closed from the control room. These valves are required closed whenever RCS temperature is above 200 F by the Technical Specifications.

CONCLUSION No significant reduction in the margin of safety as it relates to the public health and safety is involved.

I PAGE 40 0F 50

ATTACHMENT 3 CATEGORY 3 COMPONENTS COMPONENTS 2CV-3850-2, 2CV-3851-1, 2CV-3852-1 ESFAS: CIAS COMPONENT FUNCTION Chilled water isolation valves (normally open, CIAS to close).

QF: __Yes CATEGORY: 3 SAFETY IMPLICATION These valves are not designed to flyback following reset of CIAS. Should these valves flyback to an open state, they would open to a closed loop which would provide no path for communication of the containment atmosphere with the environment. A simultaneous rupture of the chilled water system both inside and outside of containment would have to occur to allow leakage out of the containment. This possibility is considered to be extremely unlikely.

CONCLUSION The margin of safety as it relates to the public health and safety would not be significantly degraded.

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! PAGE 41 0F 50

ATTACHMENT 3 CATEGORY 3 COMPONENTS COMPONEN1S' 2CV-5852-2, 2CV-5859-2 ESFAS: SIAS, CIAS COMPONENT FUNCTION Steam generator sample valves (normally open, SIAS, CIAS to close).

QF: Yes CATEGORY: 3 SAFETY IMPLICATION These valves are not designed to flyback following reset of a SIAS and/or CIAS. These lines are normally flowing during operation to allow on-line chemistry monitoring. If an unexpected flyback of the valves were to occur, the consequences are not significant due to the small flow rate involved (3/8" lines). Sample liquid flows through radiation monitors with control room indication and an alarm. Consequently, if flyback occurred and a primary / secondary leak existed, identification and corrective action would be rapid.

CONCLUSION The margin of safety as it relates to the public health and safety is not significantly degraded, i

PAGE 42 0F 50

ATTACHMENT 3 CATEGORY 3 COMP 0NENTS COMPONENTS 2CV-1530-1, 2CV-1531-2, 2CV-1543-1, 2CV-1542-2, 2CV-1541-1, 2CV-1560-2 ESFAS: SIAS, MSIS COMPONENT FUNCTION 2CV-1530 SW inlet to CCW heat exchanger (SIAS, normally open) 2CV-1531 SW inlet to CCW heat exchanger (SIAS, MSIS, normally closed) 2CV-1543 SW outlet from CCW heat exchanger (MSIS, normaily open) 2CV-1542 SW from hdr #2 (MSIS, SIAS, normally open) 2CV-1541 SW to emergency pond (SIAS, normally closed) .

2CV-1560 SW discharge to emergency pond (SIAS, normally closed)

QF: Yes CATEGORY: 3 SAFETY IMPLICATION These valves are not designed to flyback following reset of a SIAS and/or MSIS. The SIAS/MSIS closes the valves to isolate the non-safety component cooling water system. Should these CCW valves flyback to their normally open position, service water would be restored to the CCW heat exchangers.

Restoration of service water flow to this system would have no impact on other safety systems. However, a small reduction of one or both service water system flow rates to ESFAS components would be anticipated. This should not cause any significant degradation of the performance of SW cooled ESFAS components. 2CV-1541-1 and 2CV-1560-2 discharge valves to the ECP are normally closed and receive a SIAS/MSIS signal to open.

CONCLUSION No significant reduction in the margin of safety as it relates to the public health and safety is involved.

PAGE 43 0F 50

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ATTACHMENT 3 CATEGORY 3 COMP 0NENTS

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COMPONENTS 2CV-2400-2, 2CV-2401-1 ESFAS: SIAS and CIAS COMPONENT FUNCTION Containment vent header isolation valves. Normally closed. SIAS and CIAS to close.

QF: Yes CATEGORY: 3 SAFETY IMPLICATION These valves were not designed to flyback following reset of a SIAS and/or CIAS. Since these valves are normally closed, even if flyback did occur, no change in position would be expected. However, these valves are very infrequently opened for RDT or quench tank venting. Should these valves-flyback upon ESFAS reset, it would be necessary for vented gases to pass through a holding tank 2T17, a stopped pump 2C9A or 2C98 and through normally closed manual valves before any discharge to the environs could occur. Radiation monitoring is provided to detect radioactive gases and provide shutdown on high radiation.

CONCLUSION The margin of safety as it relates to the public health and safety is not significantly degraded.  !

PAGE 44 0F 50

ATTACHMENT 3 CATEGORY 3 COMPONENTS COMPONENTS 2CV-2061-2, 2CV-2060-1 ESFAS: CIAS, SIAS COMPONENT FUNCTION Containment building sump drain valve (normally closed, CIAS and SIAS to close). ,

QF: Yes CATEGORY: 3 ,__

SAFETY IMPLICATION These valves are not designed to flyback following reset of a CIAS and/or SIAS. The normal and ESFAS positions of these valves are the same - closed.

The valves are infrequently opened only for short periods of time under operator cognizance. The normal closed position is verified and logged as a part of routine logging at least once/ shift, asssuring freedom from flyback to an open position. Should they fly open upon a reset and allow gravity flow of containment sump water to the auxiliary building sump, this would be indicated to tne operators in the control room by: auxiliary building sump level indication, auxiliary building sump level alarm and area radiation monitors. The isolation valves could be isolated by a hand switch in the control room and the auxiliary building sump contents transferred to a holding tank selected by operators.

CONCLUSION As these valves are normally in their ESFAS position, a flyback would not result in a change of position. Therefore, the margin of safety as it relates to the public health and safety is not significantly degraded.

I PAGE 45 0F 50

ATTACHMENT 3 CATEGORY 3 COMPONENTS 3

COMPONENTS 2CV-1400-1, 2CV-1406-2 ESFAS: SIAS COMP 0NENT FUNCTION Service water inlet valves to the ESF pump room coolers, shutdown cooling heat exchangers and ESF pump coolers.

QF: Yes CATEGORY: 3 SAFETY IMPLICATION These valves are not designed to flyback upon a SIAS reset. Should the valves flyback closed upon SIAS reset, service water to the coolers would be terminated. If the ESF pumps continued to run, the room temperature would

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begin to increase until a high temperature alarm on toe room cooler (s) air outlet would be received in the control room and differential pressure alarms on ESF pump coolers would alarm in the control room. . Sufficient time would be available for the operators to re-establish the service water flow.

Service water flow to shutdown cooling heat exchangers would not be required in a condition in which the SIAS reset could occur (RCS pressure recovered above the low pressurizer pressure trip setpoint). The valves can be opened by handswitches in the control room.

CONCLUSION A reduction in the margin of safety as it relates to the public health and safety is not involved.

i PAGE 46 0F 50

ATTACHMENT 3 CATEGORY 3 COMPONENTS COMPONENTS 2VSF-1A, 2VSF-1B, 2VSF-1C, 2VSF-10 ESFAS: MSIS, CCAS COMPONENT FUNCTION [

Containment cooling fans (normally running, MSIS, CCAS to start).

QF: Yes CATEGORY: 3 SAFETY IMPLICATION These fans are not designed to flyback upon reset of CCAS and/or MSIS. If these components were stopped by flyback due to incorrect implementation or any other reason, no serious safety concerns result. Inadvertent stopping would cause containment cooling via the containment cooling units to be ineffective. However, since the purpose of the coolers is long-term heat removal and containment pressure reduction, a CCAS and/or MSIS would be automatically reinitiated if the coolers were required. In addition, ANO-2 safety analyses demonstrate that no containment coolers are necessary to mitigate any accident if two trains of containment spray are available.

Unit cooler trouble alarms annunciated in the control room would indicate low air flow if the fans were to stop when signal was reset.

CONCLUSION No significant reduction in the margin of safety as it relates to the public health and safety is involved.

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PAGE 47 0F 50

ATTACHMENT 3 CATEGORY 3 COMP 0NENTS COMPONENTS 2CV-5037-1, 2CV-5017-1, 2CV-5057-2, 2CV-5077-2 ESFAS: SIAS COMPONENT FUNCTION Low pressure safety injection discharge valves (normally closed) SIAS to open.

QF: Yes CATEGORY: 3 SAFETY IMPLICATION These valves are not designed to flyback following reset of the SIAS. If plant conditions exist which require low pressur; safety injection, the SIAS would automatically reinitiate following reset reopening the valves. The PPS does not allow SIAS reset if RCS pressures are reduced to the point where LPSI is capable of actually injecting water. Therefore, if the SIAS is being reset (i.e., RCS pressure above actuation setpoint) the LPSI injection H0V's repositioning will not alter any actual system function, since no flow would occur with the valves open or closed. If conditions do not warrant low pressure safety injection, the operators would proceed with plant recovery and shut down following appropriate procedures which give specific instructions with regard to manually aligning systems and starting equipment. Therefore, flyback of these valves would have no impact on plant recovery.

CONCLUSION No reduction in the margin of safety as it relates to the public health and safety is involved.

PAGE 48 0F 50 -

ATTACHMENT 3 CATEGORY 3 COMPONENTS COMPONENTS 2CV-8233-1, 2CV-8259-1 ESFAS: SIAS, CIAS COMPONENT FUNCTION Containment air sample isolation valves (normally open, SIAS or MSIS to close).

QF: Yes CATEGORY: 3 SAFETY IMPLICATION These valves are not designed to flyback following reset of a SIAS and/or CIAS. Manual operation of the valves can be accomplished from the control room. This system is a closed loop, and all sample air flow returns to the containment after passing through radiation monitors which indicate in the control room.

CONCLUSION No reduction in the margin of safety as it relates to the public heatlh and safety is involved.

PAGE 49 0F 50

ATTACHMENT 3 CATEGORY 3 COMPONENTS COMPONENTS 2A-308, 2A-408 ESFAS: SIAS COMPONENT FUNCTION 2A-308 and 2A-408 are the diesel generator output breakers to the 4160 busses. SIAS commands tripping of the diesel generator output breaker if the diesel generator is in test and output breakers 2A-308, 2A-309, 2A-408 and 2A-409 are closed.

QF: Yes CATEGORY: 3 SAFETY IMPLICATION These breakers are not designed to flyback. If the breakers are closed due to diesel generator testing with the off-site breakers closed (2A-309 and 2A-409) to the safety bus and a SIAS signal is received, the diesel generator breakers (2A-308 and 2A-408) will be tripped and the ESFAS bus is left on off site power (preferred power). Flyback of the SIAS signal will have no effect since both 2A-308/2A-408 and 2A-309/2A-409 have to be closed to satisfy the logic to open the 2A-308/2A-408 breakers.

CONCLUSION No reduction in the margin of safety as it relates to the public health and safety is involved due-to inherent protection in the system design.

l PAGE 50 0F 50

ATTACHMENT 4 CATEGO Y 4 COMP 0NENTS DESCRIPTION COMPONENT PAGE 2CV-1001 Main Steam Atmospheric Dump Valves 2 2CV-1051 Main Steam Atmospheric Dump Valves 2 2CV-1016-1 Steam Generator Blowdown Isolation Valve 3 2CV-1066-1 Steam Generator Blowdown Isolation Valve 3 2CV-4820-2 Letdown Line Stop Valve 4 2CV-5123-1 LPSI Recirc 5 l- 2CV-5124-1 LPSI Recirc 5 2CV-5612-1 Spray Header Isol 6 2CV-5613-2 Spray Header Isol 6 l 2SV-5633-1 PASS Cont Isol Valve 7 2SV-5633-2 PASS Cont Isol Valve 7 2SV-5634-1 PASS Cont Isol Valve 7 2SV-5634-2 PASS Cont Isol Valve 7 PAGE 1 of 7

ATTACHMENT 4 CATEGORY 4 COMPONENTS COMPONENTS 2CV-1001, 2CV-1051

.ESFAS: MSIS l COMPONENT FUNCTION Main steam atmospheric dump valves.

QF: Yes CATEGORY: 4 SAFETY IMPLICATION-i These valves have not been operated in the " auto" mode and were caution carded since February 20, 1980 to be left in the off position. Therefore, flyback would not have occurred.

CONCLUSION A reduction in the margin of safety as it relates to the public health and safety is not involved.  ;

i PAGE 2 0F 7

ATTACHMENT 4 CATEGORY 4 COMPONENTS COMPONENTS 2CV-1016-1, 2CV-1066-1 1

ESFAS: MSIS COMPONENT FUNCTION i

Steam generator blowdown isolation valves.

QF: Yes CATEGORY: 4 SAFETY IMPLICATION These valves are designed to isolate in the event of the following accident conditions: (1) Steam generator tube rupture (SGTR), (2) MSLB upstream of MSIVs, (3) MSLB downstream of MSIVs and (4) steam generator blowdown line rupture.

(1) In the case of SGTR, Emergency Procedure 2202.34, Rev. 4, requires the operator to secure blowdown on both steam generators. MSIS would not normally be expected to occur on a SGTR. Even if MSIS did occur, subsequent reset and flyback occurred, the operator action is unchanged and override capability is provided.

(2) In the case of MSLB upstream of the MSIVs, MSIS will not reset and therefore, flyback will not occur.

(3) In the case of MSLB downstream of the MSIVs, MSIV closure will terminate the event. When steam generator pressure recovers to the point where MSIS reset is possible, restart of blowdown due to possible flyback would not result in a safety problem. The valves can be reclosed if needed.

(4) In the case of a blowdown line break, the break would be within the bounds of break spectrum already analyzed and deemed not to proceed to MSIS actuation.

CONCLUSION The margin of safety as it relates to the public health and safety is not reduced.

PAGE 3 0F 7

ATTACHMENT 4 CATEGORY 4 COMP 0NENTS COMPONENTS 2CV-4820-2, Letdown Isolation Valve ESFAS: SIAS COMPONENT FUNCTION Isolation of letdown, one of two valves inside containment and one of three valves which isolate letdown.

QF: Yes CATEGORY: 4 SAFETY IMPLICATION Since there are two other letdown isolation valves, neither of which are designed such that flyback will occur, flyback of 2CV-4820-2 would only be of concern if a line failure were to occur between 2CV-4820-2 and 2CV-4821-1. In this event, an actuation of SIAS would isolate the affected -

line and flyback would re-open the initiating fault. However, this event would not result in radiation releases outside of containment since the i fault which would be re-opened only upstream of a closed valve inside of containment re-opening the line break would again result in SIAS, thus reclosing the valve.

CONCLUSION The margin of safety as it relates to the public health and safety is not  !

involved.

l PAGE 4 0F 7 i,

ATTACHMENT 4 CATEGORY 4 COMP 0NENTS COMPONENTS 2CV-5123-1, 2CV-5124-1 ESFAS: RAS COMPONENT FUNCTION 2CV-5123 2P-60A LPSI recirc. valve 2CV-5124 2P-60B LPSI recirc. valve QF: Yes CATEGORY: 4 SAFETY IMPLICATION These valves were modified by DCP 80-2102 to prevent flyback. However, our review reveals that the modification is only functional if the local handswitch at the MCC is in the remote position. If the MCC handswitch is in the remote position, the valve will not flyback regardless of control room handswitch positon. " Remote" is the specified position for the control room handswitch and " local" would be selected very infrequently during test or maintenance.

If the MCC handswitch is placed in any position other than remote, an annunciator is provided to alert the plant operators in the control room of this abnormal condition. Further flyback would only occur if RAS was reset prior to resetting SIAS. RAS reset requires RWT refill and is not a condition that would be anticipated during a situation which requires safety injection.

Repositioning of this valve would not result in a reinitiation of the initiating event nor would it impair operator evaluation of the event or impair ultimate plant recovery.

CONCLUSION No reduction in the margin of safety as it relates to the public health and safety is involved.

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r ATTACHMENT 4 CATEGORY 4 COMPONENTS COMPONENTS 2CV-S612-1, 2CV-5613-2 ESFAS: CSAS COMPONENT FUNCTION Reactor building spray header (normally closed, CSAS to open).

QF: Yer CATEGORY: 4 SAFETY IMPLICATION ,

These valves are designed to flyback upon reset of CSAS. However, Emergency '

Operating procedures contain specific instructions against securing containment spray so as to not interrupt long-term cooling of the containment sump. (The containment spray pumps discharge through the shutdown cooling heat exchangers to provide this cooling.)

CONCLUSION The margin of safety as it relates to the public health and safety is not significantly degraded due to the fact that specific operator guidance is provided to preclude premature CSAS reset.

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ATTACHMENT 4 CATEGORY 4 COMPONENTS COMPONENTS 2SV-5633-1, 2SV-5633-2, 2SV-5634-1, 2SV-5634-2 ESFAS: SIAS or CIAS COMPONENT FUNCTION PASS containment sump sample and sample return to the containment sump.

QF: Yes CATEGORY: 4 SAFETY IMPLICATION These valves are normally closed and are opened only for PASS sampling per Procedure 1617.009. These valves would close upon ESFAS actuation if sampling was in progress at the time of the actuation. The valves would then re-open upon reset of SIAS and CIAS. This system is designed for post accident sampling including necessary shielding, etc. Consequently, opening of the valves in a post CIAS reset would pose no safety hazard.

CONCLUSION These valves present no reduction in the margin of safety with respect to the public health and safety since the system is designed to be operated in a post accident situation without hazard to the public.

PAGE 7 0F 7 l

ATTACHMENT 5 CATEGORY 5 COMP 0NENTS COMPONENT DESCRIPTION PAGE 2SV-0388-2 FWP A Reset 7 2SV-0387-1 FWP B Reset 7 2SV-0389-2 FWP B Trip Solenoid 8 2SV-0390-1 FWP A Trip Solenoid 8 2P-2A Condensate Pump 9 2P-2B Condensate Pump 9 2P-2C Condensate Pump 9 2P-2D Condensate Pump 9 2P-3A Cirt,lating Water Pump 9 2P-3B Circulating Water Pump 9 2P-8A Heater Drain Pump 9 2P-8B Heater Drain Pump 9 2VCH-1A Main Chiller 9 2VCH-1B Main Chiller 9 2KM6 Main Turbine Turning Gear Motor 10 2KM7A FW Pump Turbine Turning Gear Motor 10 2KM78 FW Pump Turbine Turning Gear Motor 10 2PM-90A Turbine Bearing Oil Lift Pump 11 2PM-908 Turbine Bearing 011 Lift Pump 11 2PM-90C Turbine Bearing Oil Lift Pump 11 2PM-900 Turbine Bearing Oil Lift Pump 11 2PM-90E Turbine Bearing Oil Lift Pump 11 2PM-90F Turbine Bearing Oil Lift Pump 11 2P-26 MFW Pump Turbine Auxiliary L0 Pump 11 PAGE 1 of 16

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ATTACHMENT 5 CATEGORY 5 COMPONENTS COMPONENT DESCRIPTION PAGE 2P-27 MFW Pump Turbine Main L0 Pump 11 2P-63A1&A2 2P-32A RCP Oil Lift Pump 11 2P-63Bl&B2 2P-328 RCP Oil Lift Pump 11 2P-63C1&C2 2P-32C RCP Oil Lift Pump 11 2P-63D1&D2 2P-320 RCP Oil Lift Pump 11 2M-43A Boric Acid Makeup Tank Heater 12 2M-43B Boric Acid Makeup Tank Heater 12 2M-43C Boric Acid Makeup Tank Heater 12 2M-43D Boric Acid Makeup Tank Heater 12 4

2A-111 Load Shed 13 2A-112 Trip Unit Auxiliary Breaker 13 2A-113 Load Shed 13 2A-211 Load Shed 13 2A-212 Trip Unit Auxiliary Breaker 13 i

2A-213 Load Shed 13 281,2,3,8,9,10 Load Center 13 2H-13 Load Shed 13 2H-15 Load Shed 13 2H-23 Load Shed 13 2H-25 Load Shed 13 2C-329 Boric Acid Heat Trace Circuits 14 2C-330 Boric Acid Heat Trace Circuits 14 2C-331 Boric Acid Heat Trace Circuits 14 2C-332 Boric Acid Heat Trace Circuits 14

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ATTACHMENT 5 CATEGORY 5 COMPONENTS COMPONENT DESCRIPTION PAGE 2C-333 Boric Acid Heat Trace Circuits 14 2C-334 Boric Acid Heat Trace Circuits 14 2CV-0711-2 OL EFW SW to EFW Pump 2P7A - TOL 15 2CV-0716-1 OL SW to EFW 2P-7A - TOL 15 2CV-0789-1 OL EFW Pump Suction 2P TOL 15 2CV-0795-2 OL EFW 2P-7A Suction - TOL 15 2CV-1024-1 OL SG E24A Isolation Valve - TOL 15 2CV-1026-2 OL EFW 2P-7A to 2E-24A - TOL 15

- 2CV-1074-1 OL SG B Isolation Valve - TOL 15 2CV-1076-2 OL SG EFW 2P-7A to SG - TOL 15 2CV-1400-1 OL SW Header 1 to ESFAS - TOL 15 2CV-1406-2 OL SW Header 2 to ESS - TOL 15 i

2CV-1425-1 OL SW to Auxiliary Cooling System - TOL 15 -

2CV-1427-2 OL SW to Auxiliary Cooling System - TOL 15 2CV-1453-1 OL SW to SDCHE 2E-35A - TOL 15 2CV-1456-2 OL SW to SDCHE - TOL 15 2CV-1510-2 OL SW to 2VCC-2C,0 - TOL 15 2CV-1511-1 OL 20CC-2A,B Inlet Valve - TOL 15 2CV-1513-2 OL SW from 2VCC-2C,0 to Header 2 - TOL 15 2CV-1519-1 OL SW from 2VCC-2A,B - TOL 15 2CV-1525-1 OL SW to Fuel Pool Heat Exchanger - TOL 15 2CV-1526-2 OL SW t- Fuel Pool Exchangsr 2E-27A - TOL 15 2CV-1530-1 OL SW to CCW 2E-28A,B,C 10L .15 2CV-1531-2 OL SW Component Cooling Water 2E-27A -TOL 15 PAGE 3 of 16

ATTACHMENT 5 CATEGORY 5 COMPONENTS COMPONENT DESCRIPTION PAGE 2CV-1541-1 OL SW to ECP Control Valve - TOL 15 2CV-1542 OL SW from RT Header 2 - TOL 15 2CV-1543-1 OL SW from Return Header 1 - TOL 15 2CV-1560-2 OL SW Disc to ECP - TOL 15 2CV-2060-1 OL RB Sump Isolation Valve - TOL 15 2CV-2202-1 OL RDT 2T-68 Discharge Isolation Valve - TOL 15 2CV-2401-1 OL Containment Vent Isolation Valve - TOL 15 2CV-3200-2 OL Containment Fire Water Isolation Valve - TOL 15 PCV-3850-2 OL CWCAT Containment Isolation - TOL 15 2CV-4690 OL RCS Demineralizer Water to Containment - TOL 15 2CV-4820-2 OL CVCS RCS Letdown to 2E TOL 15 2CV-4821-1 OL CVCS Containment Isolation - TOL 15 2CV-4846-1 OL RCP Seal Water Isolation Valve - TOL 15 2CV-4873-1 OL CVCS Disc Valve - TOL 15 2CV-4916-2 OL CVCS Makeup Bypass Valve - TOL 15 2CV-4920-1 OL CVCS Boric Acid Tank Shutoff Valve - TOL 15 2CV-4921-1 OL CVCS Boric Tank 2 Isolation Valve - TOL 15 2CV-5003-1 OL SIS 2T-2A Isolation Valve - TOL 15 2CV-5015-1 OL HPSI 1 Shutoff Valve - TOL 15 2CV-5016-2 OL SIS HP Header 2 Shutoff Valve - TOL 15 2CV-5017-1 OL SIS Low Header Shutoff Valve - TOL 15 2CV-5023-1 OL SIS 2T-2B Isolation Valve - TOL 15 2CV-5035-1 OL SIS Shutoff Valve - TOL 15 2CV-5036-2 OL SIS HP Header 2 Shutoff Valve - TOL 15 PAGE 4 of 16

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ATTACHMENT 5 CATEGORY 5 COMPONENTS COMPONENT DESCRIPTION PAGE 2CV-5037-1 OL SIS LP Shutoff Valve - TOL 15 2CV-5043-2 OL SIS Tank 2T-2C Isolation Valve - TOL 15 2CV-5055-1 OL SIS Shutoff Valve - TOL 15 2CV-5056-2 OL SIS Header 2 Shutoff Valve - TOL 15 2CV-5057-2 OL SIS Low Pressure Header Shutoff Valve - 15 2CV-5063-2 OL SIST 2T-2D Isolation Valve - TOL 15 2CV-5075-1 OL SIS HP Shutoff Valve - TOL 15 2CV-5076-2 OL SIS HP Header 2 Shutoff Valve - TOL 15 2CV-5077-2 OL SIS Shutoff Valve - TOL 15 2CV-5123-1 OL 2P-60A Recire. - TOL 15 2CV-5124-1 OL SIS 2P-60B Recire. Valve - TOL 15 2CV-5126-1 OL 2P-89A Recire. - TOL 15 2CV-5127-1 OL SIS 2P-89C Recirc. Valve - TOL 15 2CV-5128-1 OL SIS 2P-898 Recirc. Valve - TOL 15 2CV-5236-1 OL CCS to RCP Coolers - TOL 15 2CV-5254-2 OL CCW Return from RCP Heat Exchanger - T6!. 15 2CV-5255-1 OL CCW Return from RCP Heat Exchanger - TOL 15 2CV-5612-1 OL CSS B Containment Isolation - TOL 15 2CV-5613-2 OL CSS System B Containment Isol. Valve - TOL 15 2CV-5628-2 OL CSS Injection Pump Recirc. Isol. Valve - TOL 15 2CV-5630-1 OL CSS RWT Disc to System A - TOL 15 2CV-5631-2 OL CSS RWT2TB Disc to System B - TOL 15 2CV-5647-1 OL CSS Recirc. Isolation Valve - TOL 15 2CV-5648-2 OL CSS B Recirc. Header Isol. Valve - TOL 15 PAGE 5 of 16 L .._m

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, CATEGORY 5 COMPONENTS a

COMPONENT DESCRIPTION PAGE i 2CV-5649-1 OL CSS A Recirc. Header Isol. Valve - TOL 15

{

t 2CV-5650-2 OL CSS B Recirc. Header Isol. Valve - TOL 15  ;

2CV-5657-1 OL CSS NaOH Addition Tank Disc Valve - TOL 15

, 2CV-5667-2 OL CSS NaOH Addition Tank Disc Valve - TOL 15 2CV-5672-1 OL Na0H 2T-10 Addition Valve - TOL 15 ,

2CV-5673-1 OL CSS P-35A Recirc. Isolation Valve - TOL 15  :

! 2CV-5852-2 OL Sample Containment Isolation Line - TOL 15 i

2CV-5859-2 OL Sample Containment Isolation Valve - TOL 15 2CV-8289-1 OL Containment Purge Isolation Valve - TOL 15 l 2CV-8291-1 OL Containment Purge Isolation Valve - TOL 15 20CDM-8203-10L 2VSF-1A Bypass Damper - TOL 15 2UCOM-8209-10L 2VSF-1A Bypass Damper - TOL 15 2VCDM-8216-20L , 2VSF-1C Bypass Damper - TOL 15 2VCDM-8222-20L 2VSF-10 Bypass Damper - TOL 15 l

52-64J2 2PM76 Overload Bypass 16 l

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ATTACHMENT 5 CATEGORY 5 COMPONENTS

. COMPONENTS 2SV-0388-2, 2SV-0387-1 ESFAS: MSIS COMPONENT FUNCTION 2SV-0388 FWP A reset 2SV-0387 FWP B reset QF: No CATEGORY: 5 SAFETY IMPLICATION These valves are not designed to flyback upon reset of the MSIS. Should they flyback upon MSIS reset, Restoring the valves to their normal positio,no change n will allow will pump take place.with deliberate restart operator action.

CONCLUSION No reduction in the margin of safety as it relates to the public health and safety is involved.

Routine operation of the MFWP turbines has consistently demonstrated the

" lockout" function of any MFWP turbine trips; any trip requires manual trip system resetting.

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ATTACHMENT 5 ,

CATEGORY 5 COMPONENTS COMPONENTS 2SV-0389-2, 2SV-0390-1 ESFAS: MSIS COMPONENT FUNCTION 2SV-0389 Trip solenoid for FWP B (normally energized, MSIS -

de energize) 2SV-0390 Trip solenoid for FWP A (normally energized, MSIS -

de-energize)

QF: No CATEGORY: 5 SAFETY IMPLICATION These valves are not designed to flyback upon reset of the MSIS. Should they flyback upon MSIS reset, no change will take place. Restoring the valves to their normal position will allow pump restart with deliberate operator action.

Routine operation of the MFWP turbines has consistently demonstrated the

" lockout" function of any MFWP turbine trips; any trip requires manual trip system resetting.

CONCLUSION No reduction in the margin of safety as it relates to the public health and safety is involved.

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ATTACHMENT 5 CATEGORY 5 COMPONENTS COMPONENTS 2VCH-1A, 2VCH-18, Main Chillers 2P-2A, 2P-28, 2P-2C, 2P-2D Condensate Pumps 2P-8A, 2P-8B Heater Drain Pumps; 2P-3A, 2P-3B Circulating Water Pumps (Load Shed Relays)

ESFAS: SIAS COMPONENT FUNCTION 152Y Relays are actuated by SIAS to load shed selected loads to provide higher integrity of off-site power sources for feeding safeguards busses.

QF: No CATEGORY: __ 5 SAFETY IMPLICATION Flyback of the 152Y relays (or auto reset) allows the loads shed to be re-applied by operator action. Critical loads would have already sequenced onto the ESFAS busses at the time of SIAS reset, and reapplication of loads to off-site power sources are under direct operator control after situation assessment.

CONCLUSION Since no loads previously shed on SIAS will be automatically re-applied on SIAS reset, no reduction in the margin of safety as it relates to the public health and safety is involved.

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ATTACHMENT 5 CATEGORY 5 COMPONENTS COMPONENTS 2KM-6, 2KM-7A, 2KM Load Shed Relays ESFAS: SIAS COMPONENT FUNCTION Load shed of main turbine and main feedwater pump turbine turning gear motors.

4 QF: No CATEGORY: 5 1

! SAFETY IMPLICATION Flyback will occur upon SIAS reset and the turning gear motors will restart if the turbine speed is low enough to accept the load. Application of these ,

loads at the time of SIAS reset poses no safety hazard since at this time i either actuation had been determined to be spurious and reload is of no '

concern or SIAS is reset following valid actuation and plant conditions are restored to normal where electrical loads would be at nominal values. Thus, reapplication of these minimal loads would cause no concern.

CONCLUSION There is no decrease in the margin of safety as related to the public health and safety.

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1 ATTACHMENT 5 CATEGORY 5 COMP 0NENTS COMPONENTS 2PM-90A,B,C,D,E&F (MTG lif t pumps), 2P-26 and 2P-27 (MFP auxiliary L0 pp's) and 2P-63A,B,C&D (1 and 2) RCP oil lift pump interposing relays ESFAS: SIAS COMPONENT FUNCTION The interposing relays serve on SIAS to cause non-class 1E loads to be shed from the class 1E busses to provide a higher degree of integrity of the ESFAS busses during ESFAS actuation.

QF: No CATEGORY: 5 SAFETY IMPLICATION Resetting of the interposing relays on SIAS reset and subsequent automatic reapplication of the loads previously shed is not safety significant in that all safeguard loads would have already been sequenced onto the ESFAS busses,

, their starting currents no longer of concern. The surge applied to the ESFAS busses, even if all non-class 1E loads were simultaneously applied, is lower than the surge induced from starting any of the several large ESFAS motors.

CONCLUSION Since the reapplication of these loads serve to protect plant equipment (main turbine, MFP turbines and RCPs), and the reapplication does not result in ESFAS bus overload, no reduction in the margin of safety as it relates to the public health and safety is irvolved.

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l ATTACHMENT 5 CATEGORY 5 COMPONENTS COMP 0NENTS 2M-43A, 2M-438, 2M-43C, 2M-43D - Load Shed Relays ESFAS: SIAS COMPONENT FUNCTION Load shed of boric acid makeup tank heaters.

QF: No CATEGORY: 5 SAFETY IMPLICATION Upon reset of SIAS signal, auto control circuit will be reinstated to control the boric acid makeup tank heaters by design.

These heaters are not class 1E and are not safety significant. No credit has been taken for them in the safety analysis.

Upon clearing of the SIAS actuation, and resetting, the reinstatement of auto control is desirable to prevent crystallization of boric acid in the makeup tanks 2T-6A and 2T-68. Resetting will not impair the ability of the operator to evaluate and cope with the initiating event.

CONCLUSION It would be undesirable for these heaters not to flyback since they provide assurance that boric acid crystallization in the BAMTs will not occur. No reduction in the margin of safety as it relates to the public health and safety is involved.

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E ATTACHMENT 5 CATEGORY 5 COMPONENTS COMPONENTS 2A-111, 2A-112, 2A-113, 2A-211, 2A-212, 2A-213, 2H-13, 2H-15, 2H-23, 2H-25, 28-1, 28-2, 28-3, 28-8, 28-9, and 28 Load Shed Relays ESFAS: SIAS COMPONENT FUNCTION These relays provide logic to the breakers for selective load shed on SIAS in order to assure a high degree of integrity of offsite power sources to serve safeguards busses.

QF: No CATEGORY: 5 SAFETY IMPLICATION Autoreset of the SIAS actuated relays in the nonclass 1E breaker schemes on SIAS reset does not result in automatic reapplication of the loads removed. Loads would be re-applied as necessary by direct operator action.

Such manual reapplication of non ESFAS loads would follow any ESFAS bus load sequencing and therefore not result in ESFAS bus voltage degradation.

CONCLUSION Since no actual loads are reapplied following a SIAS reset from load shed relay flyback, no reduction in the margin of safety as it relates to the public health and safety is involved.

PAGE 13 0F 16-

r ATTACHMENT 5 CATEGORY 5 COMPONENTS COMPONENTS 2C-329, 2C-330, 2C-331, 2C-332, 2C-333, 2C-334 - Load Shed Relays ESFAS: SIAS COMPONENT FUNCTION Load shedding of boric heat trace circuitry.

QF: No CATEGORY: 5 SAFETY IMPLICATION Boric acid heat trace circuitry is de-energized on SIAS to remove non-class 1E circuitry from class IE power supplies to meet the requirements of Regulatory Guide 1.75. The reinstatement of heat trace circuitry following reset of SIAS will occur but would not impair the operators ability to evaluate and cope with accidents nor will the load added be sufficient to require undervoltage relay actuation.

CONCLUSION -

It is desirable to restore the boric acid heat trace circuitry upon SIAS reset to assure that boric acid crystallization does not occur. No reduction in the margin of safety as it relates to the public health and safety is involved.

PAGE 14 0F 16

r-ATTACHMENT 5 CATEGORY 5 COMPONENTS COMPONENTS ,

Control Valves (Thermal Overload .nterlocks)

ESFAS: SIAS, CIAS, RAS, CSAS, CCAS, EFAS, MSIS

  • COMPONENT FUNCTION Interposing relays for thermal overload bypass of control valves.

QF: Yes CATEGORY: 5*

SAFETY IMPLICATION On an ESFAS actuation, the control valve overic.ds will be bypassed to insure that the valves will continue to their ESFAS position even though the i valve overloads might open.

Once the ESFAS actuation has cleared and has been reset, the bypass of valve overloads will be removed, but no valves will move by this action. Placing the overload protection back in service assures motor protection for non-safeguards operations, insuring availability for safeguards events.

CONCLUSION

Since no valve motion would occur upon removal of the overload bypass, no reduction in the margin of safety as it relates-to the public health and safety is involved.

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! E i *Although these thermal overload interlocks are safety related, they are not within the areas of concern for Bulletin 80-06; consequently, these components have been classified as Category 5.

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ATTACHMENT 5 CATEGORY 5 COMPONENTS COMPONENTS ,

Relay 52-64J2 in 2PM-76 control scheme.

ESFAS: SIAS COMPONENT FUNCTION f

Relay 52-64J2 interlocks 2P-76 off when SIAS is actuated to separate >

non class lE loads from the ESFAS busses to assure a high degree of ESFAS bus power integrity.

QF: No CATEGORY: 5 SAFETY IMPLICATION ,

Relay 52-64J2 will reset on SIAS reset, allowing 2P-76 to autostart (If required by plant conditions). 2P-76 autostart, following SIAS reset, would follow the ESFAS component sequencing on the ESFAS busses, and would not result in overloading any class 1E busses. Restart of 2P-76 is desireable to prevent damage to the main turbine and generator.

CONCLUSION Flyback of the relay 52-64J does not result in any significant degradation of the margin of safety as it relates to the public health and safety.

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