ML20054L752

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Forwards Notes from 820623 & 24 Meetings W/Nrc Re Emergency Feedwater Safe Shutdown.Notes Provided to Assist in Preparation of Ser,Highlighting Open Issues,Resolved Issues & Commitments Tendered
ML20054L752
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 07/02/1982
From: Devincentis J
PUBLIC SERVICE CO. OF NEW HAMPSHIRE, YANKEE ATOMIC ELECTRIC CO.
To: Miraglia F
Office of Nuclear Reactor Regulation
References
SBN-288, NUDOCS 8207080435
Download: ML20054L752 (9)


Text

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AutSUC SERVICE SMOOK STATION 1.i.2 5.,, Om Companyof New Hempehre 1671 Worcester Road Framingham. Massachusetts 01701 (617) - 872-8100 July 2, 1982 SBN-288 T.F. B 7.1.2 United States Nuclear Regulatory Commission Washington, D. C. 20555 Attention:

Mr. Frank J. Miraglia, Chief Licensing Branch No. 3 Division of Licensing

References:

(a) Construction Permit CPPR-135 and CPPR-136, Docket Nos. 50-443 and 50-444 s

Subject:

Meeting Notes; Seabrook Emergency Feedwater System and Safe Shutdown

Dear Sir:

We have attached notes from the June 23 and 24, 1982 meeting with the NRC Auxiliary Systems Branch, Reactor Systems Branch, and Instrumentation and Controls Systems Branch, conducted at your offices in Bethesda.

These notes are provided to assist you in the preparation of the Safety Evaluation Report, as they highlight open issues, resolved issues, and commitments which have been tendered.

Very truly yours, YANKEE ATOMIC ELECTRIC COMPANY l

J. DeVincentis y

Project Manage Attachment yo\\

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NOTES OF MEETING EMERGENCY FEEDWATER, SAFE SHUTDOWN June 23-24, 1982 - Bethesda, Maryland Attendance - Attachment 1 1.

General Discussion of Emergency Feedwater System (EFW) Including How Startup Feedpump Interfaces, Remote / Local Operation and Atmospheric Steam Relief Valves Peter Anderson gave a detailed presentation of the operation of the Emergency Feedwater System including how the Startup Feedpump interfaces with emphasis on changes we have made to meet NRC requirements. The following are the significant items discussed.

EFW motor operated flow control valves must be incorporated in the a.

RG 1.47 inop status alarms.

b.

NRC requested a tabulation of all valves associated with the EFW system including actuator type, availability of status monitoring lights and applicability to R. G. 1.47 (see Attachment 2).

NRC questioned the operation of the steam driven EFW pump steam c.

supply valves. They are air operated, fail open valves.

Loss of air supply would prevent closure and require operator action to stop the EFW pump. Their concern was with the release of radioactive steam from the turbine exhaust for a steam generator tube rupture accident. We stated that our analysis considers all secondary side radioactivity is being released to the atmosphere through the safety valves. Any release via the turbine exhaust would be minor and would not affect our accident analysis.

d.

NRC questioned us about the lack of IE indication on the Condensate Storage Tank (CST). We explained our design, and they appeared satisfied.

e.

Briefly discussed CST heating system. No apparent NRC concerns.

f.

In response to NRC concern with terry turbine generated missiles, we explained the manufacturer's QC and testing procedures, emphasizing the one piece rotor design. We committed to provide a revised response to RAI 410.8 confirming details of this design.

g.

NRC wants a copy of the Westinghouse EFW analysis prior to July site visit.

h.

We stated that by the July site visit we would have a listing of all RAI's affected by EFW changes and at least marked-up copies of our re-written responses.

i.

Atmospheric relief valves will fail shut.

j.

In response to the NRC concern with loss of power following modulation of EFW flow control valves, we stated that operator action would be required but modulation would not occur until well into the accident and plenty of time is available to manually open the modulated valves and regain flow control with the redundant valves. We agreed to arrange the valves and controls so that the primary valves used for control will be divided between the two safety trains. With two valves on each train, a power failure will result in only two valves failing in a modulated position.

k.

Design should insure that the instrumentation and control which detects and isolates flow to the faulted steam generator will not isolate all feed flow.

1.

Turbine-driven EFW steam supply valves control switches have a maintained close position which inputs to the R. G.1.47 alarms.

NRC agreed with this design change which allows EFW pump to be stopped from the control room.

m.

Following further discussion, the NRC agreed with our position as provided in RAI 410.48 relative to consideration of High Energy Line Break (HELE) and Moderate Energy Line Break (MELB) in design of steam supply to P-37A.

2.

General Discussion on Reliability Study of the Emergency Feedwater System Anthony Toce of Wood, Leaver and Associates (WLA) gave a brief presentation on the reliability study. The only significant comment by the NRC was with the use of modified reliability data. WLA modified NUREG-0611 data using more current and applicable information so they could perform a time dependent study. The NRC stated that it may be two months before they complete the review of the study. We requested they have preliminary comments for the July site visit.

3.

Safe Cold Shutdown - Discussion of RSB 5-1 Peter Anderson presented our position on safe cold shutdown.

The following exceptions were discussed with no indication from the NRC that they were unacceptable.

Operator action required to rack in breakers to Residual Heat a.

Remova (RHR) suction valves.

(Normally de-energized to prevent interfacing LOCA caused by fire.)

b.

RHR flow control valves are air operated. If normal air Is lost, l

local control is required at RHR vault. NFC asked us to compare our design to Byron Braidwood. Similar design may have already been approved.

Need analysis to show how voids are handled if we take credit for c.

cooling down at a rate faster than allowed for a T cold plant.

. d.

}[ needs to provide us the Diablo Canyon natural circulation test data and its applicability to Seabrook.

4.

Remote Safe Shutdown a.

NRC clarified their position of the April 22, 1982 letter.

It was meant to insure that there are no auto signals that could prohibit the control of equipment from Remote Safe Shutdown (RSS) locations.

We stated that when in the " Local" position, all auto controls are removed from the circuits.

b.

Although we have flow control for all four steam generators at each RSS panel, we have only two flow indicators at each panel. NRC accepted this design.

c.

NRC requires lE instrumentation for reuote shutdown purposes. Our position is that the requirement for IE instruments came from R. G.

1.97, Post-Accident Monitoring. Since we do not have to consider an accident and control room evacuation, there is no requirement to provide lE indication.

The second day the NRC modified its position and stated the instrumentation needs to be seismically qualified only. This modified position helps us very little and we will probably appeal this issue.

d.

We take exception to ICSB position 3 on Femote Shutdown Capability.

Since our RSS locations do not constitute a second control room, we feel it is necessary to inhibit Engineered Safety Feature (ESF) actuations which could reposition equipment which is not controlled from the RSS panels. NRC agreed it may be necessary for the fire but questioned disabling ESF signals for other control room evacuations. We feel this conflict would degrade operator performance by requiring different procedures for the same scenario (control room evacuation).

e.

We confirmed that pressurizer level indication is on the RSS panels.

Documentation will be re-written to reflect this instrumentation.

f.

Source range instrumentation will be required on RSS panels.

g.

We committed to provide a description of the location of the RSS locations and accessability.

h.

We committed to provide a general description of security, system for the areas containing RSS controls.

f.

NRC questioned the failure mode of instrumentation that auto closes RHR suction valves. Loss of power supply will result in valve closure. }[ needs to provide response. This item is addressed in FSAR Section 5.4.7.2.

s J.

NRC's Chu-Yu Liang stated that we must consider seismic and an accident for safe shutdown. We disagreed with this position and the NRC agreed to discuss it further and get back to us.

(On July 1, 1982, Chu-Yu Liang indicated in a telecon that we need not consider a seismic event and accident.)

_ 5.

We provided a walk-through of the actions necessary to realign safety systems to the containment sump. NRC questioned how we would test all the interlocks associated with the manual actions.

6.

Following the detailed discussions, we summarized our response to items a through k of NRC letter, dated April 22, 1982, from Frank Miraglia, NRC to William Tallman, PSh1 and committed to provide written responses.

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ATTACHMENT 2 EFW VALVE POSITION INDICATION INDICATION VALVE TAG SERVICE OPERATOR MCB CP108A CP108B RG 1.47 FW-P-37A MS-V127 A S/G Supply A

ZL ZL Full Open UL MS-V128 B S/G Supply A

ZL ZL Full Open UL MS-V95 Maintenance i

MS-V129 Trip Valve Spring ZL UL not full open CO-V154 CST Suction CO-V156 Pump Suction-FW-V67 Recire X

FW-V69 Recirc Iso.

(Common)

FW-V65 Discharge X

i F'l-P37 B i

Co-V158 CST Suction CO-V159 Pump Suction FW-V73 Recire X

l FW-V71 Discharge X

FW-P-113 t

CO-V140 Hotwell 4

l Suction I

CO-V141 CST Suction CO-V143 CST Suction CO-V342 Clean-up Suction i

...,,,, __~.,,,,-,,,--,-----.. _ - - - - - -., -

ATTACllMENT 2 (Continu:d)

INDICATION VALVE TAG SERVICE OPERATOR MCB CP108A CP108B RG 1.47 CD-V344 Clean-up Suction CO-V152 Pump Suction FW-V100 Disch. to MFWP 21.

FW-V156 Disch. to CP415 EFW TM EFW

  • = Present Valve / + = Not Full Open FW-V125 Sectional-izing FW-V126 Sectional-izing FW-V127 Sectional-izing FW-V75 A S/G M

ZL ZL X

Control (B)

UL +

FW-FV4214*

A S/G M

ZL ZL X

Control (A)

UL +

FW-V83 A S/G Stop Check Isolation FW-V81 B S/G M

ZL ZL X

Control (B)

UL +

FW-FV4224*

B S/G M

ZL ZL X

Control (A)

UL +

FW-V82 B S/C Stop Check Isolation l

FW-V93 C S/G M

ZL ZL X

Control (B)

UL +

FW-FV4234*

C S/G M

ZL ZL X

Control (A)

UL +

FW-V88 C S/G Stop Check Isolation...

ATTACHMENT 2 (Continusd) i INDICATION 1

VALVE TAG SERVICE OPERATOR MCB CP108A CP108B RG 1.47 ZL X

FW-V87 D S/G H

ZL Control (B)

UL +

j FW-FV4244*

D S/G M

ZL ZL X

Control (A)

UL +

FW-V94 D S/G Stop Check Isolation NOTES:

ZL = Red + Green Position Lights UL = Status Panel, Engraved Window, Backlighted A = Air M = Motor i

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