ML20080N927

Forwards Revised Historical Earthquake Data Implementation Schedule,Per Section 18.2 of SER Open Item 18, Control Room Design Review. Implementation of Identified Historical Earthquake Data Solutions Acceptable

ML20080N927
Person / Time
Site:	Catawba
Issue date:	02/20/1984
From:	Tucker H DUKE POWER CO.
To:	Adensam E, Harold Denton Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737 NUDOCS 8402220385
Download: ML20080N927 (8)

Text

. .

DUKE POWER GOMPANY

>>.o. n o x a a:B o CIIAltLo1TE. N.C. 28242 IIAL II. TUCKER retsenown E "C- **"

. february 20, 1984 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Ms. E. G. Adensam, Chief Licensing Branch No. 4 Re: Catawba Nuclear Station Docket Nos. 50-413 and 50-414

Dear Mr. Denton:

Section 18.2 of the Catawba Safety Evaluation Report discusses Open Item 18, Control Room Design Review. My letter of February 7, 1984 provided a proposed schedule for implementation of the HED solutions.

After review of the HED solutions scheduled for completion between fuel load and the end of the first refueling outage, it was concluded that some improve-ments could be made in the HED implementation schedule. Attached is a discus-sion of the revised schedule. Since none of the identified HEDs were judged to have an adverse impact on the health and safety of the public, implementation of the identified HED solutions after fuel loadings is deemed acceptable.

Very truly yours, 4 v Hal B. Tucker ROS/php Attachment cc: Mr. James P. O'Reilly, Regional Administrator U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30303 l

I NRC Resident Inspector Catawba Nuclear Station Mr. Robert Guild, Esq.

Attorney-at-Law P. O. Box 12097 Charleston, South Carolina 29412 ,

8402220385 840220 p d PDR ADOCK 05000413 E PDR 'IL

-Mr. Harold R. Denton, Director February 20, 1984 Page 2 cc: Painetto Alliance 21351 Devine Street Columbia, South Carolina 29205 Mr. Jesse L. Riley Carolina Environmental Study Group 854 Henley Place Charlotte, North Carolina 28207

CATAWBA NUCLEAR STATION Revised HED Implementation Schedule To reiterate, the schedule was developed after an extensive review of the HED solutions recommer.ded for implementation. Following the requirements of Supplement I to NUREG-0737, this review carefully considered the significance of each HED, including the contribution of the HED solution to the reduction of risk and enhancement in the safety of operation, the difficulty of installing the HED solutions, the need for rewriting operating procedure; and for retraining, and the coordination of HED solution changes with changes resulting from other improvement programs such as the SPDS, operator training, new instrumentation (Reg. Guide 1.97, Rev. 2), and upgraded emergency procedures.

The integration of the changes resulting from each of the NUREG-0737, Supplement 1 improvement efforts, as well as, the scheduling and coordination of individual HED solution changes is a complex and demanding scheduling effort which requires cognizance of the inter-relationships between each of the improvement areas, operator training requirements, and the plant status required for the implementation of each change.

The Duke Control Room Review Team, comprised of engineering personnel and operators from each of the three Duke nuclear stations, care-fully assessed each HED and its solution during the scheduling effort.

This assessment as stated considered the significance of HED, the difficulty of installing the solution, the coordination necessary with the installation of other HEDs and with changes from other review efforts, operator training requirements, and the need for procedure changes.

The schedule was developed folicwing a policy of scheduling the

, completion of the more significant HEDs first. consistent with the practical constraints of installation such as design / installation time, material procurement, and the coordination with training and procedures. An arbitrary policy of completing minor changes with little significance before fuel load was not followed; rather, emphasis was placed on completing the more significant changes before fuel load. The remaining changes were scheduled to be completed between fuel load and the end of the first refueling outage. This scheduling method avoided impacting the completion of the more important items by those with small consequences.

An example of this philosophy is demonstrated in the scheduling before fuel load of the rearrangement of the steam generator controls on Control Board MC2. This change was considered by the Review Team to provide a significant improvement in the operation of this panel . The change required the welding and cutting of approximately 44 cutouts, the rearrangement and rewiring of 163 meters, switches, and controllers, and the rearrangement of the associated nameplates. In addition, several functions were added to this panel necessitating the pulling of several field cables; and the extensiveness of the changes required both a seismic review of the panel and a complete reworking of the separation barriers behind the panel.

Other changes scheduled for this period include changes such as the rearrangement of portions of the safety injection controls, ESF initiation switches, nuclear sampling system controls and auxiliary feedwater controls.

To facilitate the scheduling of HED solution changes, two classes of HED solutions were identified: (1) HED solutions which require physical changes and (2) HED solutinns that can be accomplished with surface enhancements.

Most physical change solutions involve the rewiring, relocation, or addition of control and/or instrumentation components. The effective disablement of these components and of large sections of the Control Board during modifications, as well as the attendant cutting and welding needed, preclude the completion of most of this work while the systems involved are energized, such as during unit operation or testing. In addition, many physical solutions impact operator training and/or procedures, and require careful coordination in these areas.

Surface enhancement solutions generally do not involve the addition, rewiring, or relocation of control or instrumentation components.

Some of the changes in this category include changes commonly referred to as " paint, tape, and label" or "PTL" changes. These "PTL" changes involve items such as the application of demarcation lines or the changing of nameplate engravings. These changes do not disturb instrumentation or control components and can, with proper safe-guards, be installed while the systems involved are energized.

Other surface enhancements, however, whi,le not requiring the rewiring, relocation, or addition of control or instrumentation components, do disturb these components. For example, the changing of a meter scale or meter legend plate requires the unwiring, removal, and dismantling of the meter to access the scale plate. Once the change is completed,' a recalibration of the meter is required.

Obviously, this type of surface enhancement must be treated similar to a physical change, since the involved components cannot be

-energized or in use during the change.

The classification of the type of change, i.e. physical or surface enhancement, gives a rough approximation to the difficulty involved in the installation of the HED solution. However, the number of changes involved in the HED solution, the coordination of these changes with other changes being made, the impact on the completion of other changes, the coordination with operator training and procedures, and the benefit derived from the changes are important considerations that must be considered in the scheduling of HED solutions.

After review of the HED solutions scheduled for completion between fuel load and the end of the first refueling outage, we propose the following changes to Section II of Appendix D of our Control Room Review, Supplement to Final Report, Catawba Nuclear Station, Unit 1, dated, May 6,1983:

1. Physical Changes A. HED solutions to be completed prior to fuel loading 9 64 424B 437(P)*

30 68 429C 42 416 584

• The portion of this HED which involves the application of warning tape B. HED solutions to be completed before exceeding 5% power 437(P)*

• The portion of this HED involving the capping of floor sleeve penetrations.

C. HED solutions to be completed by the end of the first refueling outage.

The following HED solutions require the rewiring or relocation of components and will be completed on a continuing basis as outage schedules permit during this period.

6 88 254 354 - 422H 505 8 89 273 355 424C 51 2 10 92 274 357 424F 526 14 102 283A 358 424G 532 19 1 04 283E 359 424H 43 105 3 01 366 426 d5 108 324 371A 429B 48 113 332 392 430 52 124 343 422A 437(P) 58 125 344 422B 457 59 202 345 422D 468 60 250 350 422E 469 72 2 51 352 422F 470B 79 253 353 422G 490

.II. Surface Enhancement Solutions A. HED solutions to be completed prior to fuel loading 41 463 594 11 9 482 446 509 B. HED solutions to be completed prior to exceeding 5% power These changes generally involve minor revisions to name-plates and labels for consist'ency in abbreviations and wording, m!nor improvements in demarcation and coding; and general " housekeeping" normally encountered in moving from the construction stage to the operational stage of a unit.

46 255 405(P) 522 80 378 411 5 34 207 390 413 235 3 91 41 5

, 238 400(P) 417 241 403 i 495 C. HED solutions to be completed by the end of the first refueling outage.

These HEDs involve component modifications to complete the surface enhancement changes as previously described.

Several HEDs require the unwiring, removal, and disassembly of meters to complete meter scale changes. Other HEDs require the physical modification or change-out of a significant number of switches to complete the desired change. 'These changes will be completed on a continuing basis as outage schedules permit during this period.

32 361(P) 387 84 363 395(P) 117 367(P) 402 204 368 406 211 369 423 282 374 467(P) 338 379 .

341 381 348 382 These HEDs involve nameplates on the Aux Shutdown Fanels.

However, these panels are being rearranged under other HEDs (273 and 371). HEDs 206 and 208 should be performed in conjunction with the control rearrangement.

206 208

These HEDs involve the changing of recorder scales. However, a large scale rearrangement of recorder pens and scales is being done under HED 219 which involves the physical rewiring of a significant number of recorders. All of these HEDs should be performed in conjunction with 219. A careful coordination of these changes is required due to the work involved and the impact on operator training.

214 21 5 21 9 525 These HEDs add instrument channel identification tags for the benefit of maintenance personnel . Channels are currently shown on meters but will be changed from Roman numerals to arabic. These changes will be coordinated with individual meter scale / legend changes.

256 408 (P)

The above schedule reflects the revisions transmitted to the NRC staff on January 30, 1984. The following discussion describes those revisions (please refer to the letter from H. B. Tucker to H. R. Denton dated January 30, 1984):

(a) Section I (Physical Changes) - Delete HED 6,14, 52 HED 6 requires procurement of a transmitter and square root extractor with lead times preventing implementation before fuel load.

HEDs 14 and 52 require modifications to vendor supplied equipment and must be coordinated through the vendor requiring a longer lead time than the fuel loading schedule permits.

These three HEDs have been rescheduled to be impl emented by the end of first refueling (see (c) below).

(b) Section I (Surface Enhancements) - Add (P) for partial implementation to HEDs 367, 400, 405, 408.

During the NRC audit in August,1983, the auditors noted that several HED modifications recommended for implementation were not included in the implementation schedule. In resolving this omission, it was also noted that the HEDs listed above did not include the partial indication as originally planned for grouping the work on a control board basis.

HEDs 400(P) and 405(P) are scheduled to be completed prior toHEDs above. exceeding)5%

367(P andpower 408(P)as explained are in to scheduled Section be II.B l completed by the end of first refueling outage as I explained in Section II.C. above. l l

(c)Section II (Physical Changes) - Delete HED 429A (this HED is listed under Appendix C, HEDs not corrected)

- Add HED 457 These two changes corrected an error in the listing of 429A and the omission of 457 Note: HEDs 6,14, and 52 should have been added to (c) but were inadvertently omitted in the January 30, 1984 letter.

(d)Section II ( Surface Enhancements)

- Delete HED 242 (this HED is covered by HED 80)

- Correct HED 238 between HEDs 341 and 361 to be HED 348

- Add HEDs 3G7(P), 400(P), 405(P), and 408(P)

These changes corrected a duplication of one HED solution and a typographical error. In addition, the portion of HEDs 367, 400, 405, and 408 moved from Section I were added (see (b) above).