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U. S. ATOMIC ENERGY COMMISSION g
REGION I
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DIVISION OF COMPLIANCE y
7 Report of Inspection M
CO Report No. 219/68-8
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Licensee:
JERSEY CENTRAL PDF7ER & LIGHT COMRANY
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(Oyster Creek 1) y;;
Construction Permit No. CPPR-15
-d Category B q
Dates of Inspections:
October 1, 10 and 15 - 18, 1968 Dates of Previous Inspection:
September 19 and 20, 1968 Inspected by:
ll 16h8 R. T. Carlson, Senior Reactor Inspector Date M t-li 1
68 Reviewed by :
J. G. Keppler, Senidr Reactor Inspection
' Dale i
Specialist i
Proprietary Information:
None
SUMMARY
i Meetings were held with management and technical representatives of Jersey Central Power & Light Company and their principal contrac' tors at the site on October 1 and 10, 1968, as a continuance of CO's inspection and review in the following areas:
plant quality, preoperational testing, integrated systems functional I
testing, initial fuel loading, and start-up testing.
The specific j
topics discussed and the results are given in Sections II and III of the report.
j Measureable progress has been made in resolving outstanding issues i
in the areas of preoperational testing and. initial fuel loading.
l Also, the detailed procedures for the integrated rystems functional test, the scope of which was previously reviewed by UO and found to be adequate, are reported to be nearly ready for 01 review.
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There are no indications at this time that the issues still out-standing in these areas will not be resolved Ln a timely manner.
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The discussions relating to the start-up testing program represented
{g the first significant exchange of views on this subject.
Several r
areas in question to CO were adequately resolved at this time, f
Emphasis was placed by CO on the need to incorporate into the R
transient tests such conditions that could reasonably be expected
'l to result from single failure events.
JC-GE appeared reasonably F
receptive to this premise, and agreed to evaluate the specific examples postulated.
Additional meetings will be held as necessary to followup in'this area of review.
Although some resolution was accomplished on a few of the outstanding issues relating to plant quality during these meetings, most items remained unresolved.
As a result of concern expressed by CO in that regard, GE promised an extra effort towards early resolution of these items.
The results of this latter effort are to be discussed at a meeting scheduled at the site for November 21, 1968.
CO's observa-tions relating to GE's program of construction records, inventory and review, and the scope and results of special audits by GE in the areas of compliance with applicable electrical separations criteria and cable tray loading - three subjects of importance in CO's assessment of plant quality - were also discussed.
The results of these discussions are contained in the body of the report.
At the time of these meetings, CO announced their intention to conduct additional systems inspections as a further effort to assess plant quality.
The systems to be inspected were identified:
the mechanical portions of the isolation condenser systems, and selected aspects of the plant electrical installations.
The reasons for the additional inspections were to evaluate the effectiveness of GE's program of records inventory and review and to assess the effective-
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ness of GE's audit in the electrical area.
The actual inspection of the above-listed systems was performed during October 15 - 18, 1968.
The detailed results, including
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items discussed and comments made at the management interview, are j
given in Section IV of the report.
A summary of the principal observations made follows:
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- 1... Six items of nonconformance with the Application were.
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identified-in the: electrical area of review'.
Several of j.
these items are considered by CO to be of major significance-tL in that they were in areas previously auditedf by GE.
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2.
Several significant deficiencies were identified in the
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mechanical area-of review.
3.
Several additional areas of concern, including apparent over-loading of cable trays and questionable adequacy of. battery room layout and ventilation, were identified.
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.As a result of these findings, CO concluded that additional assurances of plant. quality, with emphasis in the electrical area, l
must be provided by JC-GE before CO can arrive.at a-position that.
i the facility has been built in accordance with the-Application and -
i applicable codes and standards, and that it can be operated safely.
l JC-GE have agreed to this position and reportedly have initiated' appropriately responsive actions.
The agenda for the November 21 meeting'noted earlier includes a discussion of the scope and results of these additional-efforts by JC-GE.
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DETAILS I.
Scope of Visits ki Meetings were held with management and technical representatives
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of Jersey Central Power and Light Company and their principal p
contractors at the site of the Oyster Creek Unit No.1 facility on j
October 1 and 10, 1968.
Lists of meeting attendees are given below.
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The meetings represented a continuance of the construction phase j
inspection program for this facility.
The principal subject areas discussed included the following:
plant quality, including the status of GE and CO efforts in that regard; the preoperational testing program; the integrated systems functional test; initial fuel loading; and the start-up testing program.
At the time of the above meetings CO announced its plans to conduct additional in-depth inspections as a further effort to assess plant quality.
The systems to be inspected were identified:
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isolation condenser systems and selected portions of the plant electrical installations.
These inspections were subsequently con-ducted during October 15 - 18, 1968.
This was a task force effort by Messrs. F. U. Bower (electrical systems) and J. M. Varela (isolation condenser system), Reactor Inspectors (Construction), CO:II, and the writer.
Portions of the report relating to this inspection were contributed to by Messrs. Bower and Varela.
Principal persons contacted during these visits were as follows:
A.
Attendees at October 1, 1968, Meeting AEC-CO J.
P. O'Reilly, Chief, Reactor Inspection & Enforcement Br.
J. G. Keppler, Senior Reactor Inspection Specialist G. W. Reinmuth, Reactor Inspector (Program Standards) l R. T. Carlson, Senior Reactor Inspector Jersey Central Power & Light Company (JC)
G. H. Ritter, Vice President T. J. McCluskey, Plant Superintendent
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Jersey Central Power & Light-Co.
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I..R..Finfrock, Jr., Technical Supervisor-
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D. E. Hetrick, Operations Supervisor f.
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il General Electric Company (GE) a D. K. Willett, Project Manager (San Jose)-
D. Long, Representative of V. Elliot, Manager,
' Quality-Control (San Jose)
L. ' M. Loeb, ' Manager, Materials & Quality Services -
Domestic Turnkey Projects. (San Jose)
N. M. Strand, Construction Site Manager K..W..Hess, Start-up Test Manager C. E. Foreman, Physicist (San Jose)
B.
Attendees at October 10, 1968, Meeting AEC-CO J.
P. O'Reilly, Chief, Reactor Inspection & Enforcement'Br..
J.'G. Keppler, Senior Reactor Inspection Specialist R. T. Carlson', Senior ~ReactorcIrispectore h-F. U. Bowe r<, nSeac t ocr Ins piHt: bor Y4 Cons t ruc tion )
AEC-DRL i
D. F. Sullivan, Instrumentation and-Power Technology'Br.
Jersey Central Power & Light Co.
T. J. McCluskey, Plant Superintendent E. J. Riggle, Instrument Foreman em - m e 1-NS-m*+*
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t General Electric Company D. K. Willett, Project Manager (San Jose)
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R. A. Huggins, Principal Project Engineer (San Jose) i r
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T. J. Pashos, Manager, Balance of Plant Engineering (San Jose)
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M. R. Lane, Systems Electrical Engineer (San Jose)
T. E. Bloom, Plant Engineering (San Jose)
A. G. Mellor, Balance of Plant Engineering (San Jose)
E. Wester, Electrical Construction Engineer Burns & Roe, Inc. (B&R)
G. A. Lari, Plant Engineer (Oradell)
C.
Other Visits Jersey Central Power & Light Company T. J. McCluskey, Plant Superintendent N. M. Nelson, Maintenance Supervisor E. J. Riggle, Instrument Foreman General Electric Company L. M. Loeb, Manager,. Materials & Quality Services -
Domestic Turnkey Projects (San Jose) l N. M. Strand, Construction Site Manager
!l K. W. Hess, Start-up Test Manager W. C. Royce, Construction Coordinator M. R. Lane, Systems Electrical Engineer (San Jose) m h
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General' Electric Company (Cont'd) j u
E. Wester, Electrical Construction Engineer 7
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D. L. Borchers,-Electrical. Construction Engineer q
- h R. M. Haynes, Mechanical Construction Engineer
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11 4 Y J. C. Larrew, Shift Supervisor J
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E. A. Lees, Responsible Engineer
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.II.
Results of Visits October 1, 1968, Meetinq I
The purpose of this. meeting was to discuss the following.
subjects:
the status of CO's review of plant quality, including supplemental efforts by GE; unresolved items relatingLto the pre-
operational testing program; the status of the integrated systems
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functional test and fuel loading. procedures;.and the start-up testing program.
Also, at this t1me, CO announced their plans to conduct 4
additional systems inspections as a further effort to' assess plant j
. quality.
A summary of the principal items. discussed and the related
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results is provided in this section of the report.
The atmosphere j
at the meeting was one of cooperation and cordiality -throughout.
A.
Plant Quality - Task Force Items The status of GE's efforts to resolve the outstanding problems detected during CO's special quality. control inspection was discussed.
An earlier statusJsummary of the overall results of the subject inspection is_ contained.
in CO Report No. 219/68-5.
For purposes of comparison; the pertinent paragraph numbers'in the referenced report j
are given in parenthesis, i
j 1.
Recirculation System Vibration Questions (II.A.4.a.&b.)
J GE has completed their engineering review of the primary system vibration frequency question -
possible resonance considerations.
CO followup on' this question was provided by Mr..R. T. Dodds,
-l Reactor Inspector, Region V, who represented CO during j
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the initial review of this subject at San Jose.
Communications between Mr. Dodds,and the writer prior to this meeting showed that a major effort had been put forth in this area by GE and that the results showed
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that no problem exists.
GE stated thag in any case, they would still observe the system closely in this regard h
during preoperational and operational vibration testing.
k GE confirmed that they are modifying the preoperational i
i vibration test procedure to establish zero loading condi-tions at the sway braces at the temperatures for the f
testing.
CO's original concern regarding the possible resonance considerations is considered to be adequately resolved.
The inspector will verify that the preoperational vibra-tion test procedure is modified as discussed.
2.
Pipe Hangers (II. A 5)
Discussions during this meeting revealed that, contrary to prior understanding, the practice of blocking the re-circulation system pipe hangers is principally for i
construction purposes only, and that the only time it i
would be applicable otherwise would be during a pump motor replacement.
JC said that the proper precautions will be incorporated in the applicable maintenance procedure.
The inspector will verify that this is done.
3.
Main Steam System Piping Material Certification (II.B l.)
Mr. Loeb stated that the engineering disposition relating to the lack of proper material certifications for the 6" piping was essentially complete.and would be available i
for CO's review in the near future.
This matter is still considered to be an outstanding item.
1 4.
Certification of Bellows Expansion Joints (II.B.3) k Mr. Loeb stated that they were continuing their investiga-tion to determine that the main steam penetrations comply with applicable code requirements.
He said that their review revealed that the problem was also applicable to g
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'the feedwater system penetrations.
He st'ated that an
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engineering disposition on. this _ matter would be provided for CO's review.
This. matter is still considered to be.
i an outstanding item.
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5.
Stress Relief Operations (II.B.5) l
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The only outstanding issue here was.a'. question regarding-1
%N possible damage to the safe-ends on the reactor vessel j
main steam ~ nozzles during field. weld stress relief opera-1 tions.-_The safe-ends in question were determined to be'
- j carbon steel and therefore not. subject to this.particular-1 concern.
This matter is considered to.be resolved.
6.
Protection of' Critical Electrical Equipment (II.B.6.)
GE stated that they had satisfied themselves that_all-of-the critical electrical equipment within the : dry well is adequately protected against the accidentienvironment.
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.In response to a specific _ request by CO, GE agreed to.
make available for review at a future date, ~ a list of the equipment that was looked at, the results of their'observa--
j tions, and their-conclusions.
This matter is still
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considered to'be outstanding, j
7.
Steam Line cold Spring (II.B.7.)
2 As a~ result of further discussion on this _ subject, GE agreed to provide an engineering writeoff on the cold-springing of the particular joint in question, ~as;well-as to determine'the applicability of this problem to'-
j other joints.
This matter is still considered to be unresolved.
I 8.
Questionable Welds in Main Steam Lines (II.B.8.)
4' Mr. Loeb stated that an engineering-disposition was being processed regarding the acceptability of the two internal guard pipe welds on the MS-10 penetration' that had questionable radiographic results.
CO will review the subject documentation when' it becomes available.
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. 3 addition, CO plans to visit the vendor shop, Tubeco, to review all of the radiographs for both main steam g
t-i With respect to the two faulty external welds in the main steam lines, GE stated that they had successfully 4
completed the stress relief and hydrostatic testing y
of these welds.
CO plans to review.the radiographs, stress relief records, and hydrostatic test records during the next visit to the site prior to considering this matter resolved.
9.
Auto-Depressurization System - Adequacy of Exhaust Piping (II.C.l.)
i Mr. Loeb stated that they were still processing the engineering disposition on the subject piping.
This matter is still considered to be unresolved.
10.
Feedwater System Isolation Valves (II.F.1.)
Mr. Loeb stated that B&R were conducting an investigation j
to determine that the subject valves were fully adequate i
for the intended service, and that the results of this effort would be documented for CO's review.
This matter is also considered to remain an outstanding issue.
I In a summary statement regarding the above items, CO pointed out that the majority of them remained outstanding, and the fact that this was true sone 10 months following original i
detection was of concern.
GE acknowledged these points, and stated that every effort would be made to provide CO with evidence of satisfactory resolution of the outstanding issues by early November 1968.
In a subsequent side discussion I
with the CO representatives, Mr. Ritter stated that prior to this meeting he had spoken to GE regarding their slow response
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on these matters and was given assurances that a more timely and responsive attitude would be demonstrated in the future.
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B.
Plant Quality - Supplemental Efforts by GE and Additional Quality Control Inspection by CO f
CO reviewed the results'of their observations to date i
relating to GE's program of inventory and review of construc-
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tion records.
The portion of Inspection Report No. 219/68-5 relating to this subject was read verbatim to those present 4
in order to convey the, fact that CO was favorably impressed by GE's effort in this regard.
At this point, CO reminded GE that we were still expecting to be provided with a summary of the deficiencies identified by them and their resolutions.
Mr. Loeb said that an attempt would be made to make this information available also by early November, 1968.
In response to questions regarding any additional efforts undertaken by GE or JC towards providing additional assurance of plant quality, GE stated that special audits had been undertaken in two areas, compliance with applicable electrical i
separations criteria and cable tray loading.
The former l
effort,although not acknowledged outright by GE, appeared to have been undertaken as a result of the earlier detection of j
deficiencies in this area by Co.*
The latter effort was stated by GE to have been motivated by the fires at San Onofre.
Arrangements were made at this time for a future meeting at the site during which GE would discuss the scope j
and results of these audits.
(See Section III of this report).
CO, at this time, announced their intention to conduct addi-tional systems inspections as a further effort to assess plant quality.
The systems to be inspected were identified - the mechanical portions of the isolation condenser systems, and selected aspects of the plant electrical installations.
The week of October 15 - 18, 1968, was agreed to for this effort.
The reasons for the additional inspections were outlined as follows:
to evaluate the effectiveness of GE's program of i
records inventory and review; and to assess the effectiveness i
l of their own audit in this area (electrical), especially in light of the fact that their records review only covered this area lightly and because of the finding of significant deficiencies in this area during the previously referenced earlier inspection by CO.
- CO Report No. 219/68-7.
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I C.
Precoerational Testino Procram - Unresolved Items p
The results of earlier discussions on these subjects at a E
meeting held at the site on May 15, 1968, are given_in f
Inspection Report No. 219/68-7, Addendum A.
The items j
considered outstanding as of that time were-discussed at.
't this meeting.
The results are summarized below.
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1.
Control Rod Drive System x y i
During a previous visit, GE provided CO with copies ~of a friction test program that they proposed as_a substitute for testing at elevated temperatures (non-nuclear).
The proposed testing calls for monitoring of drive settling time as an indicator of drive malfunction.
This monitoring _
would be performed during all operations involving the drives up to and including tests at full temperature and pressure.
GE rationalized that there have not been any instances to date of rods failing to drive in on scram signal, presumably because of the relatively high' scram forces involved.
Also, it was not likely that any problem could develop during drive operation that would be large enough to offset the scram forces involved and still go undetected by the settling time monitoring program.
CO stated that the program proposed by GE was considered to be acceptable on the following conditions which were agreed to by GE:
1 a.
Should problems develop during the preoperational testing, the adequacy of the test program must be re-evaluated before proceeding.
b.
As many of the rods as possible would be. scram tested once operating temperature and pressure was j
attained, as previously agreed to.
2.
Stand-by Liquid Poison System CO had previously maintained that a full operational test of the system (w/o poison) at operating temperature and pressure. was required to adequately demonstrate the 4
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design-intended performance of this system.
meeting, : GE agreed to revise the test-' procedure. as necessary to accomplish the' test outlined by CO.
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3 inspector will review the _ revised ' test procedure to.
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- verify satisfactory resolution of this issue.
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. 3.
Vibration Measurements - Steam Dryer.
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The subject of vibration measurement'in the dryer was
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were GE's : rational for rejecting this test,, as: presented -
i to'CO at the:May 15 meeting.
The result.of the CO-DRL'
.t discussions were that.not only should the.dryerJbe; included-l in the vibration measurement tests but'also that'the overall tests-should be run at! operational temperature and pressure conditions as well as'at the conditions.
originally proposed-(~ 1500 F).
At the time of this meeting GE considered and then j
rejected the new proposed testing program..-Their -
rational was basically the.same~as that stated at the:-
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May 15' meeting.
A lack of sufficient penetrations for instrumentation leads' together with inherent difficulties.
in maintaining instrumentation. integrity;at elevated temperatures and pressures were cited as additional-reasons in opposition'to the proposal.
At the time of a subsequent ACRS_ subcommittee meeting *,
attended by the inspector, GE indicated that they had reconsidered their earlier position and that they.now planned to include testing at operating conditions.-
.j However, their position. remains the same regarding not
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including the dryer in the tests.
This latter point is-
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being reviewed further by DE and CO.
4.
Auto-Depressurization System
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GE-JC are still considering what can be done to provide l
a meaningful demonstration that the system will' function i
properly under operating conditions.
..one' concern is that'
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- Held at H Street on October 17, 1968.
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an improperly conducted test could result in an undesired.
rapid blowdown of the system..One alternative.being l '
considered is to conduct a manual, pop-type test.
The checkout; of signals and logic circuits' will be done.u'nder ambient conditions.
The. test procedure ultimately l
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. decided upon by GE-JC will be = reviewed by the inspector.
when it becomes available.
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D.
Integrated Systems Functional Test and Core Loading Procedures -
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The results of earlier discussions on these subjects-are given in Inspection Report No. 219/68-7.- Outstanding issues as of that time were discussed' at this -meeting.
The results are summarized in the following paragraphs:
1.
Integrated Systems Functional Test The scope of the integrated systems. functional test proposed by GE was.found to be adequate during the earlier review of this subject by CO.
During this meeting l it was determined that the preparation and review by GE-JC'of the related test procedures is. essentially
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complete.
These procedures will be reviewed by the inspector during a near future-visit.
i 2.
Core Loadino Procedure -' General
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GE-JC stated that the subject procedure had been reviewed-in - light of comments. made earlier by CO, but that it was j
still undergoing review by JC.-
The final revised-procedure will be reviewed by the inspector when it i
becomes available.
3.
Core Loading Procedure - Temporary Control Curtains The principal concern by CO in this area was related
.j to verification of poison content.
This was based on information previously provided by GE to the effect that a missing curtain or one totally _ void of poison could result in fuel damage under the worst case conditions.
During this meeting it became apparent that there had
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been a misunderstanding in that regard, and that
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p contrary:to the previous understanding, no core damage would result under the conditions ' described.
Mr. Foreman 3
-stated that theirzcomputations.showed that the effect of 1
omission of 'a ' curtain (worst case). on the local power factor of'the hottest adjacent; fuel' rod is less than.
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l% in magnitude, and_that the effect on-local core.
- reactivity. is_ less. than ' O.004 d K.
GE presented;addi-tional.information that' indicated to co that, although
. fef no blackness tests of the curtains will' be 'run at the -
/C 7 site, adequate measures had been taken during the'fabrica--
E tion and testing of - the curtains to. provide GE with j
sufficient assurance that -the curtains to be ' installed in ~ oyster creek 1 will have the' design intended worth.
'Also,'GE showed that adequate provisions have been provided in the loading procedure to assure them that all the curtains will be installed properly.
This matter-is considered to be resolved.
E.
Start-up Testing Program This meeting represented the first significant discussion of-CO's observations-relating to the subject program for the Oyster Creek 1 facility.
Factored into CO's position was.the realization that this was the first of the new generation:of BWR's and that precedents would be established for subsequent comparable facilities.
The discussions were centered on areas where co had questions or found the proposed. program to be inadequate.
The items discussed and_ pertinent results are summarized in the following paragraphs:
1.
Low Power Testing with Head Off - Cold Condition
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a.
Measurement of Core Excess Reactivity Provisions for the determination of base point core j.
excess reactivity were not' apparent _in co's ~ review.
y GE stated that it would be.done by. comparing actual rod positions with predicted. ?The measurements as:
proposed are considered by CO to be adequate.
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Measurements for Determination of Core Reactivity'
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Moderator Temperature Coefficient *
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GE does not propose l to include the subject, measure ;
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( i) ments in their programs for.this cut any future plant, the basis being that; measurements were made'at KRB and five to six previous. plants,.and that comparisons-with predicted values were completely adequate.
At KRB'the value was found to be negative from ambient y.'d'
' temperature.on up to operating temperature.. They j
stated further that the Oyster Creek 1 fuel-temperature coefficient was measured in the minimum' critical array-
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tests run at Vallecitos and found to agree with the predicted value.
Based on the above, CO concurred in the position that the subject determinations were not required.
2.
Lower Power Testing with Head On - Hot Condition -
(Power Levels up to 10%)
a.
Calibration of Water Level Instrumentation
- s GE plans to calibrate cold during the preoperational testing.
They stated that they have one electrically operated, pressure corrected instrument that takes 3
into account the density changes in theLwater.
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instrument will be used to compare indications from the other water level instrumentation.
CO indicated a specific interest in instrumentation' performance --
during transient tests.'
GE stated that they do plan to make periodic checks during these tests, and that although their plans were not yet formalized, they-will have procedures to reflect this.
Data taken during the transients will be recorded.
The transient I
test procedures will be reviewed by CO to confirm.
i appropriate provisions for monitoring of water level g
instrumentation performance.
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- Comments on this subject applicable to all. phases of start-up.
testing program.
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Calibration of Off-Gas System I
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were not apparent from CO's ' review.
GE confirmed l
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sampling, and-that a procedure has been. generated.
j The subject procedure is currently under review by CO.-
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Power Ascension Testing:
a.
Measurements for Determination of Reactor Power U
Coefficient GE's proposed program does not include provisions
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for the subject testing.
Their rational is basically' the same as that for the temperature coefficient.
CO maintained that these measurements should be made since certain values of the power coefficient are assumed in their ~ safety evaluation.
GE is re-examining - its position in light of CO's comments.
1 b.
Measurements of Reactor Noise Such measurements were not apparent from CO's review.
GE stated that they will be done and that they have been incorporated in one of the revi' sed test -procedures.
Tne subject procedure will be reviewed further by CO.
c.
Power Ascension Plateaus GE confirmed that the scram set points will be set down to the appropriate power levels during the power j
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ascension program.
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d.
Closure of Main Steam Isolation valves l-GE confirmed that the scheduled tests will include
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demonstration of complete isolation of the system at full power.
Measurements to be made will include closure time, leak tightness and a determination of the. fixed losses from the plant under isolation conditions.
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Tripout and Restart of Feedwater Pumps t
CO emphasized the importance of testing the most E
severe transients that could result from single
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failures.
In that regard, since two of the three g
feedwater pumps are powered from the same bus, Co
.4 questioned if an event could be postulated that
-1 would allow both pumps to be tripped and then immediately returned to service.
GE stated that this would be looked into and that if it was determined' that the suggested event could occur, its safety significance would be reviewed and a test conducted as appropriate.
f.
Opening of Turbine Bypass Valves The subject valves are cammed to open sequencially.
When they do open, the turbine block valves close in order to hold the system pressure constant.
A test to verify the above described valve action is included in the start-up test program.
CO questioned the possibility of a single failure event causing the simultaneous opening of all turbine bypass valves with the resultant severe transient.
GE stated that they felt the system design prohibited such an occurrance; however, they agreed to review this area and to consider inclusion of a transient test of this type should it be indicated.
g.
Response to Loss of Off-Site Power CO questioned whether consideration had been given to demonstrating the ability of the plant to with-stand a complete loss of off-site power.
GE stated l
that they did run such a test at KRB, both scheduled and unscheduled, with the scheduled test being l
conducted at full power.
They said that thay had considered it for Oyster Creek 1 but decided it was too risky, especially if run at full power.
They maintained that they could pick up all needed informa-tion during preoperational testing.
CO stated that recent events, including the northaast blackout and j
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the recent tiotal loss of off-site pwer at connecticut Yankee
- clearly categorize this event
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as."possible",'and that in light of this, such a.
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test should be conducted.
The pwer~ level'for the
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test was left unspecified. - GE will re-examine its M
philosophy.and test program in light of CO's' comments.-
I CO will. follwup in this area.
Throughout-the' discussions'on the atart-up. testing-program, i
CO emphasized the importance placed-on transient tests,
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and especially the need to test conditions-which could result-from single failures.
Additional meetings will be held with GE-JC as necessary to follwup on the outstanding issues'as of this meeting.
III.
Results of Visits - October 10, 1968, Meeting The purpose of this meeting was to discuss the scope and results -
of the special audits by GE and their contractors relating to cable tray loadings and to conformance with applicable redundancy and separations requirements for the engineered safeguards electrical systems.,
In summing up_the inspection procedure to be used by compliance 4
during the subsequent inspection of the isolation. condenser systems
= I-and the electrical system,** Mr. O'Reilly stated that it would 'be a '
review in depth on a sampling basis..This technique had been chosen since'an overall inspection was not possible with the manpower and the time available.
The results.of the inspection would be 1:
extrapolated to the whole plant and would go far in shaping the 1
opinion of Compliance as - to the suitability of the plant for. power
/
operations.
In.this regard, emphasis was-placed on the importance j
of having all deficiencies in the~ subject systems knwn to GE identified to CO prior to the start of the inspection.
GE concurred
.in this position and stated that this would be done.~ The deficiencies in the. electrical area would be identified at this time and those in the isolation condenser system at the start of the actual inspection.
- CO Report No. 213/68-2.
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- Section IV of this report.
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A.
Cable Tray Loading l i GE has undertaken-'an analysis of cable tray loading through-L + Y out the plant.
This analysis is-. analytical'in character and 1
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is'aimod at determining the temperatures!that might.be _
l expected in those trays with high loading factors.
The'.
l stiated purpose of these analyses is to, avoid. incidents similar.
to those that occurred at San onofre wherein appreciable -
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numbers. of' cables were destroyed by fire due to overheating-t of cables in the trays.
GE stated that they. had consulted I
with San onofre personnel in this regard.- The GE analysis l
technique assumes all the conductors in any tray to beuin a j
circular bundle with the highest power cables in the 'conter.
I With this configuration they have applied the Insulated Power Cable Engineer's Association (IPCEA) approach to determining.
l temperature.
In addition, where applicable, the National.
l Electrical Code provisions have been applied.
A 900 C i
conductor temperature limit is being used.
GE reported that their analysis of cable trays throughout i
the plant was not complete; however, they had-early indications l
l that some cables might require relocation to meet the.
1 temperature criteria as established.
They contend that-l
.t their approach is conservative and will produce meaningful l
.l results.
They stated that a similar review was being under-l
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taken at the other domestic turnkey projects and that a l
l similar approach was being employed.
'l When asked what steps would be taken to confirm the accuracy l
q of the analytical approach, GE stated that they had no plans l
in this regard.
During subsequent discussions, both at this l
l meeting and at the time of inspection exit interview on I
october 18, 1968, GE agreed that instrumenting of critical I
cable' trays to monitor actual temperatures was in order and i
said that this would be done.
The actual temperature j
I monitoring program to be employed will be reviewed by the
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inspector during a, future visit after it has been developed.
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i During the discussion, Mr. Huggins, GE Principal Project Engineer, made the observation that cable tray loading was
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probably grossly in excess of what might be considered good engineering practice in many cases.
However, in defense of
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their actions, he further stated that a plant such as Oyster Creek which had been constructed under a back fit or retro-fit approach, made it practically impossible to 1
provide sufficient and satisfactory means for the installa-I tion of cables.
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GE reported that the physical examination of the cables by GE and others had reverled no cables with physical damage.
In response to questions on derating, GE stated that they had looked at this area and that no problems had been identified.
With respect to fusing, GE stated that the plant design differed from that at San Onofre in that it incorporated three-phase circuit breakers as protection against one-phase shorts.
GE plans as of this meeting called for the completion of the physical examination of the trays within one week, and the completion of the analytical review within one month.
The results of these efforts will be reviewed by CO at that time.
B.
Separations of Engineered Safeguards Electrical Systems Over the past few months the GE site staff and their sub-contractors have attempted an analysis of the installed electrical systems as they relate to the engineered safe-guards separation criteria.
This effort appears to have been motivated, at least in part, by the earlier finding of deficiencies in the area by CO.*
The GE review had earlier been announced as being a " Task Force" approach to the problem by the GE program manager.
However, during the meeting i
it became evident that the inspection had be ade principally by the site staff in conjunction with their regular work.
Certain problems with this approach were identified and i
discussed; however, GE felt this approach was adequate and they made their presentation on that basis.
GE pointed out j
that a specific criteria for separation of systems had not j
yet been developed in the industry.
To provide a guide, they i
have developed a Separation Summary based upon their recent i
application to the DRL.
They proposed to follow this guide for any correction they might have to make in circuitry.
A copy of this separation criteria summary, which is a pre-
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liminary draft, was obtained on an informal basis and is included herewith as Attachment A.
- Co Report No. 219/68-7.
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s The Compliance Division response to this approach was that i
the document would be reviewed in detail and compared to the FDSAR. The separation criteria. set forth therein would be used as a guide for the physical inspection of the electrical systens if it met all those provisions set forth in the applica-tion.
5
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A list of the deficiencies identified by GE as having been i
uncovered as a result of their audit of the electrical systems, together with the status of the proposed fixes, are given below:
l' 1.
The redundant 125 volt DC control circuits serving the emergency diesel generators were found to occupy the same cable tray from the power distribution center in the battery room to the point where they entered conduits and continued underground to the e:mergency diesel generator building.
Engineering orders have been released to place one of these circuits in steel from the distribution center to the point of conduit pickup.
It was not possible to confirm that this work had been performed at this time.
2.
The redundant 125 volt DC control circuits serving the 4160 volt vital busses (1 C and 1 D) were found to occupy the same cable tray from the distribution center in the battery room to the 4160 volt distribution center located in the turbine building.
Corrective action in the form of placing one circuit in steel conduit, thus physically separating them, has been initiated by engineering action.
The status of the physical installation was undetermined.
3.
At the time of this meeting, GE stated that their review revealed that the power cables to the auto-depressurization valves (four valves, three of which must function) were routed through only two penetrations.
Howevdr, during the october 15 - 18, 1968 inspection by CO, it was determined that actually four penetrations were employed, one per valve.
GE later verified' the error in their original finding.
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The power ~ cables'to the parallel redundant.' pairs of-isolation valves -in the two core spray systems (valve f
.Nos. V-20-15,.-21, -40 and -41 ' located outside j}
containment)- were alls found to have been ' routed via a common tray.for at least part of the distance.from the'
,y valves to their respective motor control centers.
GE stated that the ' fix decided upon was to use separate "i
routings.for the cables'to one of the valves in eachfof 9
the two systems.
This left the cabling-to-the: remaining two valves, one in each system,;still in a common tray.
j Mr. Sullivan, DRL, stated that the proposed fix. appeared unacceptable in that one might postulate a single failure one.taking out the common tray - that might cause an e
electrical feedback to the subject. motor control centers resulting in a loss of all four valves and thus possibly-negating both core spray systems.
GE agreed to re-evaluate the modified installation in light of the comments made.
A discussion of circuit' redundancy for certain isolation" valves such as those for the sumps, ventilation, auto-depressurization system, nitrogen purge and pressurization.
system indicates that the separation criteria was not met.
GE felt that they had met the single. failure criteria require-
. ment even though separation'of circuits was not met.
Their attitude regarding these situations.'.was based =onLthe characteristics of the various systems which meant, in most cases, that the valves -in question closed on failure, thus maintaining the integrity of the system..Since the scope of this particular meeting.was intended to be limited, it was felt that this type discussion would best -be reserved
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for another meeting.
GE stated that they were ready to defend their position before the reviewing board..
In concluding the presentation of the results of their audit, f
GE management representatives present stated that it was their-q-
opinion that they had reported all identified discrepant items and had or would take corrective action.
The end result would be a plant constructed essentially as set forth in'their application.
The status of the discrepancies detected earlier by Co in the reactor pressure and drywell pressure reactor protection
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GE stated that engineering action
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had:been initiated to change the routing of the reactor-j
' pressure impulse lines to conform with the description in the Application.
With respect to~the drywell. pressure system, l
they stated that ' the routing of electrical conduits -from the '
sensors had been changed to conform with the minimum -25' l
separation. between redundant systems specified in the field.
c 3.f drawings.
However, no changes were ' planned with respect to
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the routing and location of the impulse lines and sensors.
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Their rational was that this installation was reviewed by them fn:n l J-the viewpoint of possible single failures negating. redundant i
systems and found to be acceptable.
GE-JC were reminded by i
CO that since the as-installed system was not as described in
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the Application (FDSAR, Amendment No.11, page V-6-1), 'it would either have to be changed or the Application -amended
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accordingly.
GE-JC stated that this issue would be resolved l
accordingly.-
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.l The outstanding issues discussed in this section of the. report-l will be followed up on by the inspector-during future visits.
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IV.
Results of Visits - Site Inspection, October 15' - 18, 1968-j j
A.
Preparatory Meetinar October 14, 1968 l
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A meeting amongst CO representatives was held at the Region I i
office ~on October 14,-1968, preparatory to the scheduled site
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3' inspection.
Those in attendance included Messrs. O'Reilly, -
Keppler, Carlson, Bower, and Varela. 'The purposes of the j
meeting were to acquaint the participating-inspectors with con (',tions at the job site,.to highlight the significance of thiw particular inspection, and to set forth the lines of-i 1
authority and coordination for the :hspection effort.
The
_j general purpose and detailed approach for the inspection were outlined.
,)
It was agreed that in addition to the isolation condenser system, two electrical systems would be reviewed in-depth.
These systems were the 125-volt DC control power system.and the core spray electrical system.
Other investigations were'
- CO Report No. 219/68-7.
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-f to be performed if; time" permitted.
Basic ' outlines prepared by Messrs. Bower' and Varela-for making the proposed -inspec-tions were discussed and agreed upon at this' time.-
J B.
Inspection' Results - Electrical Systems
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125 Volt DC Distribution System - Battery Room-j L
- i The battery room is considered;to be a vulnerabl'e area:
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by the inspectors.
Most'all of the primary equipment,
_f distribution panels and cables associated with the 125 volt DC control system are located in this. room.
The equipment consists of two motor generator sets, two banks of batteries (lead-acid type), a. two unit static
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charger, two main distribution panels, and one sub-
-l distribution panel.
All of this equipment is located' within a radius of 10 feet.
The two bauary banks are separated by a two-hour roll-up fire door which provides i
missile and. arc protection.
However, the space over(the j
door and at one end is open and would not prevent fire propagation to other regions in the room.
l Amendment No. 20, Page II-4-1, Paragraph II.4. states:
~
"The 125 volt DC batteries A~and B located in the battery room in the office building are to be i
separated by the installation of a. fire wall.
The fire wall will be -of Class I' construction capable of withstanding designed seismic loads and will be '
a two-hour or greater rating.
The wall will be i
movable'to allow for maintenance of the batteries."
1 I,.
The fire wall as installed meets the movable requirement; j
however, it does not meet the fire wall classification as described in the foregoing paragraph.*
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With respect to the lead-acid type batteries occupying.
the same room with the other DC equipment, it was noted that except.for the fire door, special~ provisions have not been made to provide separation or a controlled i
- Reference made to following standards due to lack of more I
descriptive reference in Application:
Uniform Building Code, Volume I, 1967 Edition, Section 42-43, Fire Resistance Standards for Fire Protection.
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The GE engineer was questioned about the ventilation of the batteries to eliminate any hazard due to hydrogen generation.
He stated that Burns and Roe had conducted an evaluation of the ventilation system and had issued a report stating that the ventilation system was adequate and no hydrogen hazard was present.
A copy of this report was requested for review; however, after a search it proved that no copy was available at the site.
GE stated their willingness to make a copy of both the engineering evaluation and the summary of the evaluation available to CO for review and evaluation at the time of the next visit.
i 1
It was noted that all sub-Deeders from the two fr.ain DC i
distribution panels enter the same cable tray and leave j
the battery room via a tunnel to other points of distribu-
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tion.
This includes those redundant circuits described in the safeguards summary as well as those considered non-essential to the safety of the plant.
The results of GE's audit of the 125 volt DC control system is discussed j
I in Paragraph III.B. of this report.
Specific deficiencies identified by them in the battery room are summarized in Paragraphs III.B.1 and 2.
It was noted during this visit that the proposed corrective actions for these items had not yet been implemented.
During CO's independent inspection of the area discussed above, the inspector noted that, in addition to the two items previously identified by GE, the 125 volt DC control circuits for the redundant 460 volt vital busses lA2 and 1B2 wera also located in the subject tray.
This installa-tion is considered to be in nonconformance with the
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applicable separations criteria explicit or implicit in t
the Application
- when one postulates a fire or other single failure event that could take out the subject tray.
- FDSAR, Volume I, Page VII-7-2, Paragraph 7.2.1.4, Circuit Isolation; Amendment No. 11, Page V-6-1; Amendment No. 18, Page 5-1, Paragraph 3.
Also, the separation criteria implicit in DRL Report No. 4 to the AC RS, dated 10/14/68.
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In addition to the 125 volt DC circuit cables leaving the battery. room via the common tray, many additional
, cables from other portions of the plant come through j
the battery room and, in many cases, mingle with the y
IX: circuit cables.
The subject transient cables include j
p those from the recirculation system variable flow control equipment.
A four-high rack of' cable trays i
form the main path through the tunnel (tunnel dimensions -
~4' x 4 ' x 25 ').to the control room and other distribution points located in other sections of the plant.
The cable population in these four trays is very dense.
One tray, J
that containing the 125 volt DC cables was measured to be I
7 inches deep with cables in a tray designed with-sides 4 inches high.
A count of the cables in the trays was j
impossible; however, they number in the hundreds, perhaps thousands.
1 2.
Continuous Power Unit While reviewing the equipment layout in the battery room, it was noted that the continuous power unit and the panel served (Instrument panel No. 3) were in the same room and j
in the same general location.
This equipment, as a matter of fact, falls into the 10-foot radius previously described for the DC equipment.
At the time of inspection, it was considered that this equipment was essential and a part of that equipment falling under the general heading of vital g
equipment.
During later conversations, GE* maintained'that this system did not fall under the category of vital equipment nor was it included in the safeguard summary as such.
It should be pointed out, however, that considerable effort has been expended in both design and l
installation to provide this instrument panel with reliable i
and continuous power.
This condition can best be viewed i
by review of the FDSAR, Volume II, Figure VIII-2-3.
A question regarding the transfer switch in the panel power supply circuitry elicited the response that the diagram was wrong.
The switch should be shown to furnish power to the panel from the continuous power unit as the primary source with vital motor control center lA2 as the i
secondary or back-up source.
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j A; close check of the cabling ' entering the instrument
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panel as well' as ' the power andLinter-ties to. the motor.
1 generator, set and the vital. motor control center revealedI i
that all cablea for ' the entire system. enter the same -
cable tray used for'the DC distribution. system.
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A list ' of the equipment supplied by this. panel is as.
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'follows:
I i
a.
Radiation Monitoring _ Recorders l
l b.
Event Recorder Drive c.
Feedwater Control d.
Control Rod Position Monitor u.
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Electro-hydraulic Pressure f.
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Process Radiation Monitors h.
Recirculation-Control 3.
Core Spray System A review of theLcontrol diagrams-with members of the,GE j:
site staff revealed that sensing', control and operation of the core spray system is as'follows in general:
A' low low water level ovent in the reactor vessel is sensed by redundant instruments which cause relays to close in logic panels ER18 A and B.
The relay closing in the I
logic panel causes'the auction side valves-and the~ core spray pumps to be energized.
The core spray booster pumps.
start when a pressure-sensitive switch located in the -
suction lines are closed', indicating'that water is in.the line from the core spray pumps.
When the core spray:
booster pumps start, pump pressure of 285 psi is applied against the isolation valves.
Water is returned through.
i a:2-inch bypass line to the torus section, while the-pumps are pumping-against the main isolation valves'.
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This circulation provides cooling and prevents overheating the pumps.: The isolation valves remain closed until a low pressure event is sensed by the low pressure instrument system.
This event occurs when the reactor vessel pressure 3
has been relieved from the operating pressure to 285 psi.
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The signal from thi6 byent is transmitted over the sensor
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lines from the low pressure transducer to the logic panels
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ERU3 A and B,l where relays are closed which cause the isolation valves to open.
This permits water from the core spray system to enter the reactor vessel.
The system is both mechanically and electrically complex and contains many refinements not described.
Many of these refinements-are known to be important to the successful operation of this system, however, time was just not available to investigate analytically or physically many of these systems.
As a consequence, the remarks set forth here are limited in scope to the primary circuitry.*
Each of the core spray systems is equipped with redundant components consisting of two core spray pumps, two core spray booster pumps, and tWo isolation valves.
The sensor transducers for control of the. redundant equipment are supported on racks (RKOl and RKO2) located approxi-mately 1800 apart around the perimeter and outside of the containment vessel.
Each rack has transducers for low low water sensors for systems 1 and 2 and low pressure sensors l
for systems 1 and 2.
The leads from these transducers enter a common, locally-mounted terminal panel and exit via steel to a common tray located directly above the panel.
The bundles of four cables each from each rack follow their separate routes in tray to a point of common
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meeting at the NW corner of the reactor building at floor 4
elevation 51 feet.
At this point, all cables from all eight sensors enter a common tray (No. 14) and proceed to the f
460 volt distribution room, a distance of approximately 50 to 60 feet.
At this point, the cables diverge to enter
- For detailed information of the mechanical and electrical control systems, reference is made to General Electric drawings, Piping and Instrumentation Drawing 885D781 and. Electrical Control Diagram 718E644, sheets 1 and 2.
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The' routing of.the cables
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to be in nonconformance with:the applicable separations
.l 3-criteria.*when one c'onsiders the single > failure event 7
postulated earlier (Paragraph ; IV.B.l. ). -
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The isolation valves are~ installed in~ parallel' redundant'.
N u pairs.
They are motor-operated.ElectroMatic valves
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~ equipped with torque and limit switches.~as well as position 1-indicator switches.
The torqueLand limit switches ~are'in-i the system control circuitry and the position indicator-switches are read out on the contzol panel? in L.the control room..
The valves are located in close proximity.to the point' where the core spray pipe lines enter the containment vessel.
One pair is located-in the NW section at the 51-foot level'.
The other pair is located approximately.
1600 i
- 1700 around the perimeter of the vessel and at-floor elevation of.75 feet.
The valves at the NW corner, elevation 51 feet, are identified as V-20-15 which'is in.
i parallel with valve.V-20-40. 'The power cables and feed back information cables from valve V-20-15 and the-feed back-information cable from valve V-20-40, enter the tray located directly;above the valves.
This is the'same tray.
with the transducers for the.same. system.
This tray isl identified at the site as No. 14 and extends from this general location to the 460. volt distribution room, a distance of 50 - 60 feet.
The power cables'fok the motor operator V-20-40 enter-their own donduit which goes by a different route to the 460 volt distribution
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The two valves located at the opposite side of the contain-ment vessel and at the 75 foot elevation are identified as V-20-21 and V-20-41.
The power.and feed back cables from
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V-20-21 and the feed back cables from V-20-41, enter the;
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tray directly above the valves and continue; via horizontal' tray No. 43 to the " east side of the building where 'it
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enters a vertical tray V-22 which drops the cables to the l 51 foot elevation.
There they enter tray No. -14 and continue to the 460 volt distribution. room with the cables from the redundant system valves.
Here again, the power cables fcr the motor operator on valve V-20-41 enter.
an individual conduit and follow' a different route to the
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1 460 volt distribution room.
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- Same ae those referenced in Paragraph IV.B.l.
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discussed having found the pwer cables 1for-the.
-g isolation valves in these redundantisystems; occupying l
the same tray. 'As noted above, the fix stated by them-
- L l' to be in effect at that time (the adequacy. of which has.
i tyy been questioned by DRL as indicatedLin the referenced q
paragraph) was confirmed by the-inspector during;this 4
inspection as having been implemented.- However, not identified.to CO by GE at the time of the October 10 meeting, was the situation described above regarding the control cables for the subject valves including their relationship (ir. routing) with certain of the. power' cables.
This situation, elements of the power and control systems for the valves in these redundant systems occupying a common tray, is considered to be~1n non-conformance with the applicable separations criteria I,
(previously referenced) for the reasons given previously..
When the situation described above was brought to the attention of.GE during the inspection, they produced.a job request (Attachment B) which they maintained was-intended to correct the entire situation.
However, based.
on the. observations by CO, and comments made by GE.at the-October 10 meeting and during. this : inspection, it.is not clear to CO that the total fix would indeed have been-implemented.
l' 4.
Auto-Depressurization System The operation of the core spray system is dependent-in-some ways upon the auto-depressurization' system. - Under certain~ conditions of leakage, the core spray system will not function until the auto-depressurization system l
has reduced the reactor pressure from the 1,000: psi r operating pressure down to '285 psi where the core. spray pumps function.
To reach this condition of pressure, the auto-depressurization system opens:the relief valves when
- a. low low low water level is experienced.
Present' design requirements dictate that three of the four relief valves must open.
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An inspection of the physical installation revealed that k
two valves are installed on each of the two steam headers as required.
Each of the pair of valves are controlled j
by redundant systems.
The power leads leave each of the t
valves inside the containment vessel by divergent routes and proceed to individual penetration openings.
After the power leads leave the penetrations, outside the s
containment vessel, the routing is such that the cables 4
for the four valves are paired in two trays for approx-imately 100' en route to the logic panels in the 460 volt distribution (ER18 A and B).
The above described installation, paired routing of cables, does not meet the applicable separations criteria
- when one considers the previously postulated single failure event.
(Paragraph IV.B.l.)
Due to time limitations, and problems of access, it could not be precisely determined that the low low low water event sensor cables for the auto-depressurization system control do not enter the same wire ways with the low pressure and low low water sensors of the core spray system.
A cursory examination at the time indicated this condition could exist.
This item will be investigated further by CO during the next inspection visit.
5.
Nuclear Instrumentation The cabling leaving the containment vessel penetrations for the Linear Power Range Monitors (LPRM) and the Average Power Range Monitors (APRM) were inspected at the request of Mr. D. Sullivan, DRL to determine the position of the redundant systems, and their vulnerability I
j to credible incidents such as fires, missiles, etc.
As described by the GE site representatives, the system consists of 124 cables which penetrate the containment vessel at opposite ends of the same quadrant.
Sixty-two (62) cables are in one system and come through the i
containment vessel in seven penetrations.
Cables from the seven penetrations are extended through conduit and enter a common terminal cabinet.
The other 62 cables are
- Same as those referenced in Paragraph IV.B.l.
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handled in a similar fashion.
Each set of 62 cables leave "E
its respective terminal box in a single 3-inch conduit.
The 3-inch conduits separate until they reach the west.
wall of the reactor building.
At this wall they converge j/
to within approximately 12 inches of each other to exit g; kf from the reactor building through an opening in the wall.
F_
At the other side of the reactor building wall, the conduits diverge until 25' apart and continue by different routes to the reactor control room.
To summarize the above, the subject nuclear instrument systems cables are encased in conduit over their entire length and separated in space by a minimum distance of-25' with the exception of the point where they exit the reactor building and in the control room complex.
With the exception of the exiting from the reactor building, a
the as-installed system appears adequately; protected against the incidents considered.
With respect to the point of exception, it is noted that even here the installation meets GE's own separation criteria in that both sets of cables are in conduit.
(Attachment A, Paragraph III.C.)
In addition, through discussions with GE and DRL, it was determined that the only failure of concern is one that would sever both conduits and all cables therein without causing even a single short.
This in.GE's judgement is incredible.
The inspector concurs.
Based on the above, the subject installation is considered-by the inspector to be adequate.
6.
Quality Control and Testing Program 4
i Discussions with the responsible GE Electrical Construc-tion Engineer, Mr. E. Wester, regarding their on-site quality control and testing program indicated that they had followed a guide set down early in the construction of the plant.
This guide was written by Mr. Wester and is entitled, " Report on Electrical Quality Assurance for Oyster Creek Nuclear Power Plant."*
The concepts of inspection and quality testing as set forth in this guide are basic and considered adequate as far as they went.
- Copy available for review in Region I files.
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- executed, failed-i to record the data in a manner-that.would be recoverable 4
in any logical way.
A contributing 1 factor was the basic j
provisions of the electrical subc ontract.. The -electrical' f
a ubcontractor was charged with the responsibility-of j
g field routing and marking. of all of ~ the ' cables.
As a' f
result, the-qual-testing program-index was. keyed to ;the i
1 electrical sub-contractor's pulling schedules and cable l
identif'ication schedules. ' As the cables were ' installed, i
they were inspected and tested and. the data recorded; thus,.
l they accumulated a chronological file rather than one related to a family or a numbered index syst'em.
The electrical subcontractor, Hatzel, Buehler/ Beach Electric, performed the quality testing under the o
jurisdiction of the Burns &. Roe inspectors.
The data l
'I was recorded by the subcontractor and attested.to by a j
signature of the Burns & Roe inspectors.
The GE staff made periodic' sample reviews of the data to confirm compliance with the program.
Some of the tests and calibration data was reviewed, however, it could not be determined whether the' program was' effectual or not, due to the method of recording the' data.. GE personnel were not capable of producing a single specific item of record that was requested.-
At the-time of inspection, the entire quality record consisted of documents that would fill approximately 1/5 of a standard file drawerLcabinet.
1 1
i Amendment No. 11 to the FDSAR, Page V-6-1, contains the following statement under the paragraph entitled ~" Testing":
" Sensor cables conductor insulation integrity will be verified by meggering between wires and ground and between subchannels during installation."
Discussions with Mr. Wester revealed that the required meggering had not been performed.
The reason given was that the referenced statement was not in the same context as'that given in their quality testing program.
The failure to conduct the meggering as specified is
' l considered an item of nonconformance.
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to workmanship, line and grade, and eye appeal can be
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' considered quite satisfactory.
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7.
General Observations and Comments
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+bi By observation during the physical inspection and from
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comments supplied by the GE site staff and the JC site 1-staff members,. it is obvious that the number of cables and the amount.of equipment has increased quite drastically from that originally designed for the plant.
It ' was informally reported by members of the site' staff that cable population has-increased from the time ~of the original electrical subcontract award from approximate 1y'-
4900 cables to the present cable codnt of approximately 7500 cables.
This proliferation of cables evidently has occurred with little or no increase in ' cable tray capacity.
4 The natural consequence of this set of conditions. has :been the general. overloading of-cable trays.
Whether this condition will. produce. unfavorable. results is atill unknown and will remain unknown until' the results of GE's -
c analytical investigation of cable trays is~ complete or.
until. operations begin and actual temperature measurements are made.
Some of the tray, systems are lightly or-nominally loaded, however, there'are regions of extreme congestion.
These regions include the. battery room,-the o
battery room tunnel, the room-at the end of the tunnel ~,
the 460 volt distribution room, and the' vertical risers at the NW corner of the reactor building.
The 460 volt distribution room is an area where. a change
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in concept is evident.
The separation' walls designed.to
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separate the two vital systems located therein are j
obviously an afterthought and consist of 2-inch transite installed between the building columns... These' walls'are j
only continuous in the region where the equipment is located.
At the area where the' trays pass between the equipment,..there is no wall of any kind.
This will
]
provide flash protection and missile protection of a sort, however, it will not stop the propagation of a fire.
The tray system in this room is extremely congested and loaded and is quite extensive.
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'C.-
Deficiencies Identified by GE - Isolation Condenser Systems
~1 The following ' list' of deficiencies was presented to the.
l inspectors by Mr. Loeb at the start of this inspection as-N i
previously arranged.
According to Mr. Loeb, these' items
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represented all' the deficiencies identified by GE in their.
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II inventory and review of the construction records relating to the isolation condenser systems.
Mr. Loeb stated that the j
y records review for this system had been completed; however, the resolution of the deficiencies was not complete at this j
time.
The status of this latter action at the time of the.
i visit is included below:
l 1.
One could not conclude from examination of the field j
weld inspection records that a meaningful inspection j
of the welds had been performed by the supervisory' i
representative of the piping contractor,LAlmirall-Doyle.
.l The subject records were typed, apparently from the j
original records which were no longer available.
Many of the records were signed on'the same date, months j
~ -
following the actual welding.
This situation was.
i represented as being. fairly typical for all process systems with~the possible exception-of the recirculation l
system.
GE subsequently examined the radiographs and.related j
records for all of the subject' welds..'According to.~
]
.i Mr. Loeb, the dates noted thereon provided GE with an-adequate degree of credibility. that the ~ welds were indeed
-l inspected properly.
Mr. Loeb showed the inspector
]
evidence.that steps had'been taken to avoid this. problem i
in the future.*
2.
Records for the field welds 'in the condenser shell. side exhaust piping are missing.
A total of 24 welds
(#9701-9724) are involved.
GE has requested Almirall-Doyle to supply the missing records; however, they are not optimistic in this regard.
- Document entitled, " Guide for the Preparation of a Construction Site QC Plan, Domestic Turnkey Projects, GE Co.",
March 28, 1968.
Copies subsequently distributed to CO regional offices.
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- I GB rationalized that these records would only be for historical purposest that this is non-critical equip- -
ment in that'the piping exhausts to the. atmosphere.
The
'l inspector concurs.
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The weld information for. all shop welds in the subject ~
piping is either not available or is. incomplete.
Some y
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28 welds are-involved.
Included was one weld in the guard pipe that extends the containment vessel to the l
body of the first of the special double isolation valves i
(outside containment) -in the inlet line to each 'of the two condensers (weld Nos. SW NE-5-6-1 and SW NE-5-3-1).
A general problem in this area had been identified earlier
- during CO's inspection of the main steam piping, supplied.
j by the same vendor - Tubeco, Inc.
As a result o.f the.
earlier problem,.GE and B&R conducted a special review j
at Tubeco of weld radiographs for all piping supplied by
)
Tubeco, including that in the isolation condenser' system.
Mr. Loeb stated that a check by him of the~related trip.
~
reports -had provided him with: adequate assurance that the.
welds in the isolation condenser system had been included l
in the earlier review and found acceptable.
With. respect
.i to the two guard pipe welds,. additional assurance of their j
~
adequacy was provided.by records available at the site --
radiography reports showing satisfactory results.
4.
Limited documentation was available at the site relating to i
the vendor fabrication and testing of the special double-isolation valves,in the inlet lines to the condensers.
These valves, because of their special safety significance,-
reportedly had received special quality control attention.**
l Included amongst the missing information was all the data l
relative to:
dye penetrant ~ checks of the valve bodies, welds, radiography, and hydrostatic testing.
The only I
document available attesting to the satisfactory completion of these checks was a letter from the vendor certifying in general terms to the meeting of c'ontract
- CO Report No. 219/68-1, Addendum I, Attachment B, Paragraph 9.
- Amendment No. 32, Page 5-1.
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specifications.
The subject ' valves.were fabricated j
by Anchor valve company on a-purchase order from B&R.
Advance Heliweld did'the welding,for" Anchor Valve and-.
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.X-Ray Engineering. Company did the radiography for j
Advance Heliweld..All three firms are located in I
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Mr. Loeb stated that a request has gone,to Anchor Valve,
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via B&R to provide the missing' documentation.
In addition,'GE was planning on reviewing the radiographs.
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Neither of these actions had been completed at the time
.l of this visit.
The QC on these valves is discussed further.
in Paragraph IV.D.3.
l i
' 5.
Except for a general certification statement similar to l
that referenced.in paragraph 4 above, no evidence exists j
to confirm that the remaining four isolation valves in-i the return-lines had'been. dye penetrant tested as specified (B&R Specification S-2299-61).
GE is also
!j pursuing this documentation.
j 6.
The shop weld -records for the guard pipes on the return
'l line containment penetrations can be interpreted'to-f
-indicate that the same type electrode and the same weld l
procedure was used for s/s to s/s, s/s to carbon steel,_
l and carbon steel to carbon steel welds.
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Mr. Loeb stated that they visually checked the subject welds, including using a magnet,.to confirm that they j
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were adequate.
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D.
Inspection Results - Isolation Condenser Systems i
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The inspector found the isolation condensers and associated
?
piping completed including full insulation.
Because of.'
the insulation, most. welds and related piping could not 1
be visually examined.
Consequently, the inspection was limited to visual observations of the-exposed portions of the systems, and examination of site records.
Pertinent observations are summarized in the following paragraphs.
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Isolation Condenser supports since the supports for vessels of the proportions and 1
temperature gradients such as the isolation condensers
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must provide for expansion and contraction, the steel-
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h old down pads of the supports were examined to determine
,i if the holes were slotted. - The nuts and washers concealed-
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the bolt holes making' inspection impossible.. Mr. Loeb requested the removal of a representative number of nuts
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and washers.
Inspection after removal disclosed that a
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3/8 '? slot was provided for the calculated.220" maximum
- j expansion.
-1 1
During the examination of the supports, the inspector.
noted that the 5/8" thick vertical member of the support-n to-vessel saddle and base plate was attached to the. base plate with a fillet weld, and no provision was made for the movement of'the base plate on the-concrete footing
-other than the slotted holes.
Messrs. Loeb and Royce were with the inspector, and both agreed-that the. fillet weld appeared inadequate.
Mr. Royce added that "a lubra' plate should have been used for ease in movement."
(See Attachment C),
GE was unable to produce a detailed drawing of this installation at the time of the visit; however, a-
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drawing was subsequently made; available to the Region -I l'
office together with a - statemert from Mr. Loeb that their s
review showed the installation to be in accordance with f'
design.
The adequacy of the subject supports is being reviewed further by CO in light of this new information.
2.
system suspension i
1 i
While' studying the system suspension, the inspector noted j
that the welding of all of the brackets and associated hanger supports was not completed and was discrepant-as follows:
(a) None of the welding slag had been removed I
from any of the above welding, which indicates that no one, including the welder, inspected the work; (2) Some
'of the welding lacked continuity; (c) There was deep
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l undercut on some of the welding.- The above work had been accomplished several weeks before,-and the responsible contractor was no longer at the site.
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t GE had little comment regarding the existence of the above described condition other than to state that it 3
would have been detected during their punch list inspec-tion, which they claimed had just been started on this-system.
Mr. Loeb stated that the specific condition will be evaluated and the appropriate corrective action taken.
In visually comparing the supply and return systems, it j
was noted that the inlet valves (double valve assemblies) were each supported from the valve yoke with a spring hanger, while the 2000 lb. outlet valves (Nos. V-14-34 and i
V-14-35) were unsupported at the yo'ke.
(See Attachment D).
Initially, GE claimed that supports were not required.
However, Mr. Loeb later stated that supports were j
required, that they had previously determined this, and that installation of the supports was scheduled.
3.
Isolation Valves The six isolation valves that are outside containment are located approximately 12 feet above the floor of the 75 foot level.
On both the supply and return valves, the j
insulation had been removed from the valves and to approx-imately two feet beyond the flued head of the guard pipes.
The inspector found that the system had been tested as evidenced by the warning tags which were attached to the valve manual operators and by the attached JC tags which indicated that the systems had been turned over to the-j owner (joint occupancy).
l The inspector observed four ground out areas at the field 1
weld (No. FW-5564) joining the double inlet isolation valve assembly in system A (valve Nos. V-14-30 and V-14-31),
at the flued head attached to the upstream valve (No. V-14-30), to the 18 inch guard pipe.
(See Attachment l
I D).
The worst grind mark, 1/16 inch deep and 3/16 inch m
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wide, appears not to have been accidentally made.
The inspector has not drawn any conclusions regarding this latter observation.
GE stated that they had not been j
aware of the grind marks but thought that here t o.o i =t h e y' would have been detected during their g'
punch list inspection.
Mr. Loeb said that the condition would be evaluated and the appropriate corrective action implemented.
Comparing the two outlet isolation valves V-14-34 (system A) and V-14-35 (system B), the inspector noted that the field weld (No. FW 5541A) joining the body of valve V-14-35 to the flued head attached to the guard pipe.had been extensively ground out while the similar field weld (No. FW 5513) on the companion valve was not ground out.
In order to better compare the two welds, the inspector measured the minor circumference of both welds and found i
that the ground out weld was 3/8 inches smaller, indicating j
1/16 inch less metal on FW 5541A.
From the appearance of j
the grinding and the geometry of the transition, it appeared to be a fairing operation; however, the geometry lacked uniformity in some areas.
GE stated that the grinding on valve V-14-35 was performed' as part of the program to correct the previously identified problem of improper transition radii of welds.* However, they were not prepared at this time to attest to the l
adequacy of the " fixed" weld.
Mr. Loeb indicated that j
this would be investigated and the results made known to the inspector.
t j
The inspector checked the ferrite content of stainless steel fillings, weldments and valve bodies, using a Severn ferrite indicator.
The flued head and stainless weldments j
were 5 to 7% ferrite.
The valve bodies were in excess i
of 15% (upper limit of instruments).
The only ferrite I
requirement specified for the system was that specified for the filler metal:
" Acceptance shall be based on 5%
i ferrite minimum."
It is noted, however, that relatively high values of ferrite content are not uncommon for stainless steel castings of this type.
- CO Report No. 219/68-5, Paragraph II.A.l.
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- While inspecting for.. ferrite content,~the inspector.
found that:the stainless steel flued heads;on the inlet-a isolation valves had been field welded'to the carbon:
steel guard pipes.
B&R Specification'S.-2299-60C states:'
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"The end of the stainless steel-flued fitting'that-
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I connects to the. carbon steel ~ penetration sleeve' "
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must'have a matching carbon. steel end, since'-
dissimilar metal joint welds are not permitted'
-j to-be made in the field."
Subsequent discussion with GE produced 'a ' B&R engineering _
l disposition that allowed the above work to be performed -
j in the field. ~ The welding was accomplished. by, first '
~
buttering the carbon steel pipe (A106-GR B-SCH 80). with '
l type 309 s/s and completing' with an overlay of 316-s/s.
This preparatory work was performed by' the vendor, Tubeco.
8 The inspectior reviewed the available records relating to.
the fabrication of the double inlet isolation valve assemblies - those requiring special quality control-efforts as per Amendment No. 32, page.5-l'.' The review 1 confirmed the incompleteness of records' previously 1
reported-by GE as discussed in Paragraph'IV.C.
consequently, it was impossible to conclude'at-this-time that these valves.were-indeed fabricated per the applicable requirements.
The subject documentation will be reviewed by CO when it becomes available.
In 4
addition, ~ arrangements are -being made-for CO' to visit l
the vendor ' shops to review fabrication procedures and the results of required nondestructive tests.
e 4.
Radiographic Results The inspector viewed the radiographs for all the field' welds in the system..All radiographs'and welds were noted to be acceptable with the exception of two, those for the welds joined the flued heads on the double inlet isolation valve' assemblies to the 18 inch guard pipes, weld Nos. W 5558 and W 5564.
Here the negatives were blank.
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' Mr. Loeb explained' to - the inspector that it ~ was not possible_to radiograph these welds due to the geometry:
R involved (see Attachment D) andithat dye penetrant -
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- inspection was' performed in place of radiography.
In-f response to further questioning, he maintained that the fff method of testing employees'was acceptable per.the B&PV-Le Code Section VII.
Conformance with applicable code requirements will be t:onfirmed by the inspector.
5.
Inspection with Magnifier Exposed critical portions of the system were. inspected, on a sampling basis, with 4X to lOOX magnification..No apparent weaknesses were observed.
E.
Management Interview The results of the inspection were discussed with the following representatives of JC-GE on October 18,n1968, at the conclusion of the visit:*
?C T. M. McCluskey, Plant Superintendent i
E. J. Riggle, Instrument Foreman 91 ii L. M. Loeb, Manager, Materials & Quality Services -
Domestic Turnkey Projects (San Jose)
M. R. Lane, Systems Electrical' Engineer (San Jose) i.
-l 1
K. W. Hess, Start-up Test Manager W. C. Royce, Construction Coordinator E. Wester, El&ctrical Construction Engineer s.
R. M. Haynes, Mechanical Construction Engineer I
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- Senior management representatives of JC-GE had been informed in advance of the significance of this inspection, and advised accordingly to have appropriate representation at this interview.
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- y The. interview was conductec} by the writer with the assistance-
- off Messrs. Bower and Varela.
The observations. pertaining to-
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the' isolation condenser-systems were discussed first followed by those relating to the electrical systems.
The.
l 4'
items highlighted together with pertinent comments by JC-GE j
follow:
l 1.
Isolation condenser Systems i
a.
Condenser Tank Supports (Paragraph IV.D.1)
- l Messrs. Loeb and Royce agreed with the inspectors _
l that the support welds appeared to be' insufficient-for the purpose intended.
Both apologized for:the unavailability of pertinent field drawings.
Mr. Loeb stated that the adequacy of the. subject installation would be reviewed by GE and the results made known to Co.
As is noted in the body of the report, this-action by GE reportedly has been completed to the point of determining that the' installation is according to design.
This matter is currently under review by CO and is still considered an outstanding issue at this time.
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b.
System Suspension (Paragraph IV.D.2)'
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I-The status of the suspension system welds, i.e.
poor workmanship, incomplete work and apparent
.i lack of inspection, was categorized by the inspectors as being unfavoral:1y reflective on the. quality control i
system.
GE had little comment regarding the' situation' other than'to state that it would have been detected' during their punch list inspection.
Mr. Loeb stated that the specific condition will be appropriately-evaluated and corrected..
The lack of supports for the outlet isolation valves was discussed..As noted earlier,'GE eventually agreed that supports were required and said that their installation was already scheduled.
The
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the valves unsupported even during the interim-i a
because of the possibility of experiencing
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undesirable stresses.in the system..Mr..Loeb indicated that this observation would :be taken into -
'F consideration.
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c.
Isolation Valves (Paracraph IV.D.3) t 1;
When discussing the grinding gouges across the weld at the flued head on the A system double' isolation j
valves, GE again stated that although they were not aware of -this particular condition, they felt j
i confident that it would have-been detected during l
their punch list inspection.
The inspectors.
suggested that because of its apparent severity,
~
this particular instance be examined closely.. LMr.Loeb..
concurred and indicated. that-the results will-be j
made known to CO.
The effect on the system's integrity.of the-grinding on the field weld. joining isolation valve V-14-35 to.
j the adjacent flued head was questioned.
Mr. Loeb
}.
indicated that 'this condition would also' be investigated and the results made known to Co.-
4 I
Emphasis was placed on the significance of the incompleteness of the fabrication and testing records for the double isolation valves; especially in light t
of their particular safety significance.
The r
inspectors requested that the results of GE's own followup in this area be made available for review L
by Co when completed. ' The -intent of Co to visit the
~
vendor shops was announced at this time.
d.
Nonradioaraphable Welds (Paragraph IV.D.4) y J
The inspectors informed GE that.the adequacy of the nondestructive testing employed on the field
~
welds joining the flued heads on the double inlet j
isolation valves with their related guard pipes; would require further review by Co.
This issue is
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still outstanding at this time.
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1 frequently during both the As exampled above, i
inspection and this interview GE made reference.to i
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punch listing.
However, little evidence of a'meaningfuli j
' ' ~4 punch list program was noted by the inspectors. - The inspector emphasized the importance ' of such a : program --
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and indicated that this' subject would be reviewed U-further during future visits.
l 2.
Electrical Systems a.
Core Spray System (Paragraph IV.B.3) 4 The-results of the inspection of the core spray' i
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system circuitry was discussed in some. detail.
t The failure to meet the separations criteria for-j the sensor cables and the isolation valve cables-i was pointed out specifically.
The points of i
common location were detailed.
Prior to this inspection the GE site staff had J
thought they had the sensor cables completely separated.
Consequently, this was a new item to l
them.
They,did not know off-hand what their fix would be; however, they were going to study the installation and report back:at-a later date.
The-location of the isolation valve' control wires and' power wires had. been known to the GE site staff and they had issued a job request to correct this.
l situation.(Attachment B)... A review of their job request as issued, indicated that it would' correct the condition -if the work was completed in accordance with the instruction contained therein.
However,:
it was pointed out - that the' job request-was dated in August and the work had not been completed except in part.
Their response was that they would invest'igate the situation and complete the work as '
required.
They also indicated that the aspects of the circuitry questioned by DRL during the October 10, 1968, meeting at the site were still being reviewed.
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Auto-Depressurization System (Paragraph IV.B.4)
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- ..j It was pointed out to the GE' representatives that I
the circuitry for the auto-depressurization. valves did not meet the single failure. criteria since the W
j cables from each pair'of valves entered the'same tray and follw ed the same general path to the-point of control.
They accepted this statement as being fact and said that they.were aware of it but they pointed out that this particular system.was not a redundant system and was outside that grouping intended to meet the separations. criteria even.though it was recognized that it was an. essential system for.
many postulated incidents.
c.-
125 V DC Control System (Paragraph IV.B.1)
The results of the' inspection in this area were discussed.
The failure to meet the separations criteria for the. circuitry to the redundant 460 volt vital buses was pointed out specifically.. Emphasis l
was placed on the fact that their w n audit had failed to detect'this item.
GE acknwledged the discrepancy and indicated that a.fix comparable;to-that scheduled for the other redundant DC control systems would be employed.
I d.
Testing of sensor cable conductor Insulation-(Paragraph IV.B.6)
-The failure to perform the subject tests was cited -
as an item of nonconformance with the Application.
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The GE representatives claimed that their. site' installation procedures exempted these particular.
circuits from. meggering; hwever, they stated that -
they would either complete the specified tests or submit'an amendment.
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(Paragraph IV.B.1)
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N The separation of the'125 volt DC battery systems
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was discussed with the ' emphasis placed on the FDSAR j
description of the 2-hour fire wall,to be built-between the two battery systems.
It.was pointed l
out to' the GE representatives that the fire wall as described had not been built and would not meet.the '
criteria.they~themselves had established.- Their-4 response to this statement was that the Lfire wall' as such was intended only as a flash and missile.
protection device.
The words ~ set. forth -in..the ~'
amendment were unfortunate. in their point of view,.
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and they proposed to solve:the. problem administra
s tively.
i It was noted that the number and size of the-
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batteries presently located in the battery room probably constituted enough capacity to require a.
separate room if.the provisions of the Uniform'
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Building Code were applicable.. Such a room would j
require its own ventilation system designed to
.I exhaust hydrogen gas safely.
Their response seemed' to indicate that they had not. investigated it from.
l that particular point of view.
However, they were concerned enough that they had investigated the ventilation system through their architect engirteering;
- l firm.
A report of this investigation allegedly
-h states that the ventilation system is adequate even though no special provisions.have. been made to vent i
the room other than the H & C system' common'to all~
areas.
f.
Continuous Power Unit A review of the circuitry shown on the block diagram for the continuous power unit and the panel it serves, Panel No. 3, led the inspectors to believe that this was a vital system.
As a result,
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- 1 an inspection was made' of the ' system as ' it' was physically installed.. It was found that all. AC
- and DC' conductors l entering and. leaving Panel No. 3
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M @S went' into the same tray with the general distribu-1 i
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. tion cables from the 125 volt DC. control power
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system.
This was considered to be a nonconformance item and was-brought.to the attenti6n of the GE
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personnel at the meeting. - Their response was that this was not a vital system and should-never have 1
been referenced as such in the documents.
They had
-l gone-to great efforts to remove any connotation
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that this was a vital system;'however, they were still confronted with this particular system.and the manner in which it' was installed.. They attempted?
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' to assure CO that. it did not fall under the category-
-l-of one of the safeguard _ systems.
The inspectors
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stated that the matter would be reviewed further with DRL.
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Cable Tray Loading The subject of cable tray overloading and attendant.
1 heating problem was discussed extensively.
The j
conclusion was that the investigation presently
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underway by GE to determine the heating character-istics.through an - analytical approach would be j
continued and the results made available-to CO.
The j
inspector noted that'this could be one of the more
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serious problems observed during-the inspection.
'ii j
In summary, the inspector stated that several' of the 1
observations noted 'during this inspection were considered I
to be gross, especially'since their detection followed.
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audits by GE in the specific areas covered.
Because of..this, further reflection was necessary in order to determine their significance with respect to a Co. position. regarding. the '
'l overall quality of the plant.
The inspector indicated that the results of this additional consideration would be made known to JC-GE at an early date.
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. 3 The observations made by Co during this inspection were subsequently discussed at the ACRS. full committee meeting with ' JC-GE on November 1,1968, and during several 4
subsequent formal and informal meetings and_ telephone
- le--j communications between the Regulatory and JC-GE management.
p ;9 In brief, CO concluded that because of these and earlier I
'I
^j observations, additional assurances of, plant quality, with j
- [
emphasis in.the electrical area, must be provided by JC-GE before CO can arrive.at a position that the facility has been.
l built in accordance with the Application, including applicable codes and standards, and that it can be operated safely..
JC-GE.have agreed to this position and reportedly have initiated j
appropriately responsive actions.
In this regard, a meeting has been scheduled with JC-GE management and technical representatives, at the site on November 21, 1968, to discuss j
~
the scope and results of these additional efforts.
The resolution by GE of all-outstanding issues relating to
~
i plant quality that pre-date the october 18, 1968, inspection
~
will~ also be discussed at this time as previously arranged.
The results of this meeting will be documented in the next 4
inspection report.
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JERSEY CENTRAL POWER & LIGHT COMPANY
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(CO REPORT NO. 219/68-8) 3
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CYSTER CREEK SAFECUARDS SEPARATION
SUMMARY
3 idi -
. I.
GENERAL-j The following is a su=ary of Separation Recomme., dations and Instructions for n
the Reactor Protection Systc=, Core and Containment Cooling Systems and Pri-mary Containment Isolation System for the Oyster Creek Nuclear Power Plant, y
i made up from various pertinent documentation available in our files.
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I II.
03JECTIVE l
e The electrical wiring and sensory equipment for the Oyster Creek plant safe-guards (Reactor Protection System (RPS), Core and Containment Cooling Systems
(,C&CCS), and the Primary Containment Isolation Syst'em (PCIS)), have been 1'n-stalled in accordance with criteria designed to make the functions performed
'by these systc=s' invulnerable to single active component fai~ure.
[
i s
III. REACTOR PROTECTION SYSTEM A.
The protection system which is responsible for shutting down (scramming) the reactor and thus limiting further heat generation in the event of off j
c limit conditions is' designed to tolerate the following accidental events S}
without failure to scram although some of the items' failure can cause a l
4i
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ascrib:
4 l
1.
Single sensor failure in any mode.
l 4-2.
Single short circuit in wiring between any two points in one panel
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or cabinet.
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j 3.
Crounds single or multiple.
7-4.
Single relay failure in any mode.
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5.
Any number of open circuits.
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6.
Power failure, single.or multiple.
~
C 7.
Mechanical damage to any single conduit.
l 8.
Local fires outside of main control room panels of sufficient magni-tude to burn cable insulation within a single tray. '.
ph sical separation of wiring for the R?S is in accordance with the '
3.
Th2
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following general rules:
1.
Wiring for the reactor protection systems outside the main coprrol t
p room protection system panels should b'e run in conduits used for no-other wiring and shall be conspicuously identified at all junction i
or pull boxes. Annunciator and event recorder wiring are not con-sidered part of the RPS wiring.
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V' ring to duplicate sensors from a common process tap should be run 2
, in separate conduits.
3.
Wiring for sensors of more than one variable in the same protection 7
'f, system logic subchannel may be run in the same conduit.
e 4.
Wire from two protection scram contactors in the same' protection logic channel shall be run in se.'parate conduits (i.e., a single conduit i
t
. hall not contain wires to scram solenoids in more than one group of s
a scram solenoids of both protection channels. (wiring for two solenoids, f;
.on the same control rod, may be run in the same conduit).
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S.
Separation between conduits for the RPS channels is ~not required be-cause the system trips on deenergization and all wiring is enclosed in steci conduit to prevent inadvertent energization by crossups.with
" hot" wires.
C.
The neutron monitoring system trip relay contacts are considered as pro-tection system sensors for purposes of applying the above rules. The Co-ax cables for neutron monitors input signals are grouped by channel l
ibtstead of by sub-channels and each channel has a single conduit for all LPRM cables associated with it.
I An exception to Item 2 above has been allowed on the r.ain condenser low vacuum switches, which are not actually required for reactor protection.
The general rules listed above are illustrated in the attached sketches SDIRL 31766 and 32166.
The backup scram function operates on a two-out-of-two logic without
{-
specific separation requirements, since it is not required for a safe scram.
{.
4 D.
The physical separation'for sensing lines and equipment in the RPS'is in
.ccordance with the following general rule.
Sensing lines and sensors providing redundant protection syst em funct. ions essential to reactor safety are physically separated such that no event i
i.
considered reasonable by use of good engineering judgment could disabic both' sensors.
j In general this requires a separation of several feet between redundant j
functions but no specific distance is required.
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(C[CCS gL IV.
Or,1 CERED SAyEGUARDS~
which include the core spray, A.
The core and containment, cooling systems 4 T
auto. blowdown and containment spray subsystems, are energized to operate and are designed to tolerate single failut-or single accidental events
-}
without causing failure to fulfill the required cooling function. The d
individual core and containment spray subsyste=s are not required to Y
.f.,
tolerate single failure but the auto blowdown subsystem is required to t '
tolerate. failure of any single active component.
3.
Single failures and events designed against are:
j 1.
Single sensor failure in any mode.
~
2.
$1ngle short circuit in wiring between any two points in a single
/
panel or cabinet.
/
Any single ground or multinle grounds within any one subsystem.
3.
~
4 Any single subsystem failure.
/
5.
Any single power supply failure.
]V 6.
Machanical damage to any single conduit or cable tray.that could short
.1 Wobreak wires in the tray or conduit.
S 7.
Any single device or circuit failure in a relay panel or control panel I
but not to include an extensive fire or mechanical damage shorting more than one circuit in a main control room, control panel.
P j
C.
The physical separation of wiring for theiC and CCS should'be in accor-dance with the following general rules:
e
- 1. ' Wiring to duplicate sensors from a co::imon process tap for a single sub-system nay run in the same conduit.
i 2.
Wiring for sensors of more than one variable for a given C&CCS sub-system may share a common conduit or tray.
!I 3.
Wiring for C&CCS including control and power wiring sliould be separated t
by systems by either a distance of at least three feet between trays or by a steci barrier equivalent to a rigid steel conduit wall and
[
separated sufficiently that no single. event is reasonably likely to
.1 I
disable both syste=s. This requirement is considered satisfied by having at least one of the two systems in rigid conduit.
Thpmaincontrolroompa'nelshavenotbeenrequiredtohavespecial 4.
wiring or equipment separation but must demonstrate freedom from
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IV.
C.
(cont'd)
,obycetionable heating, during steady sta'te operation that could be con-g sidered a potential fire hazard.
j, 5.
Opening in floor under control room pancis are closed to provide " fire stop".
F D.
Physical separation of sensing lines and equipment separation is to follow the same rules set forth in III D. above.
1 i
V.-
PRD:ARY CONTA1XMZST ISOLATION SYSTEM A.
The primary contain=ent isolation system has features of both the RPS and CSCCS.
Sensors are deenergized-to-operate and employ a 1 out of 2 twice logic and are in some cases shared with the RPS. Wiring for these sensors is separated in the same way as that for the RPS (see above).
Valves are redundant and thus operate on a one-out-of-two logic (like the C&CCS).
Wiring for redundant valves is run in separate trays or conduits.
Out-side of the main control room separation is to be at least three feet in h
open trays, or at least one of a pair is to be in rigid conduit, b.
For the solenoid pilots on solenoid operated isolation valves (including the main steam isolation valves), one valve on each line has its wiring i
enclosed in conduit. (Generally the outboard valve because'of difficulty s'.
in~cartying conduit through the drywell penetrations).
C.
Valve position lights and signals to the event recorder are not required to be in conduit.
l D.
No separation of wireways is required within the individual control room panels nor in the conduits dnterconnecting control room panels but inboard and outboard valves control circuits are to be in separate jacketed cables.
The =ain steam line excess flow trips are all' owed to operate from a single pair of flow' nozzle caps on each of the two main steam lines becaus'e these
" steam leak" signals are bakeup to the steam tunnel temperature switches t
which are much more sensitive.' The excess flow switches may be mounted on a single locci rack but are to be wired out through independent conduits.
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