ML20096H072

Affidavit of Gr Leidich on as-built Status of Standby Liquid Control Sys Initiation.Related Correspondence

ML20096H072
Person / Time
Site:	Perry
Issue date:	09/07/1984
From:	Leidich G CLEVELAND ELECTRIC ILLUMINATING CO.
To:
Shared Package
ML20096H048	List: ML20096H047 ML20096H072 ML20096H108 ML20096H121
References
OL, NUDOCS 8409110250
Download: ML20096H072 (15)

Text

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er n- g UNITED STATES OF AMERICA ~ yy."d NUCLEAR REGULATORY COMMISSION ct BEFORE THE ATOMIC SAFETY AND LICENSING BOARD '64 SEP 10 m :01

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<t In the Matter of '

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THE CLEVELAND ELECTRIC ) Docket Nos. 50-440 0 '

ILLUMINATING COMPANY ) 50-441 N

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(Perry Nuclear Power Plant, )

. i. Units 1 and 2) i )

.s AFFIDAVIT OF GARY R'. LEIDICH ON AS-BUILT STATUS OF SLCS INITIATION

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STATE.0F. OHIO )

ss COUNTY OF LAKE )

Gary R. Leidich, being duly sworn, deposes and says as 3 ,

follcws:

1 J. 'I, Gary R. Leidich, am General Supervising Engineer, Nuclear Construction Engineering Section, of The Cleveland Electric Illuminating Company. My business address is 10 Center Road, Perry, Ohio 44081. In my position, I havo

.recponsibility for all engineering activities to support construction, including the engineering activities to support

/ s construction of the Standby Liquid Control System ("SLCS"). A

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1 summary of my professional qualifications and experience is MO9110250 840907 -

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i attached hereto as Exhibit "A." I have personal knowledge of the matters set forth herein and believe them to be true and correct.

2. In general terms, the SLCS consists of a storage tank for boron solution, a test water tank, two pumps (SLCS Pumps C001A and C001B), two motor operated pump suction valves (Storage Tank Outlet Valves F001A and F001B), two explosive operated injection valves (squib valves F004A and F004B),

associated _ local valves, piping, instrumentation and controls.

Except for the controls, there would be no differences in the configuration of the SLCS whether its initiation mode were manual or automatic. The controls which would be used to manually initate SI.CS are the two key-locked switches, C41A-S01A and C41A-S01B, which are located in Control Panel lH13-P601 (the ECCS benchboard).

3. The controls for an automatically initiated SLCS would be in addition to that for the manually initiated system.

In general terms, automatic initiation would involve bringing the appropriate plant status indications (i.e., temperature, pressure) from the plant to the control system logic and sending appropriate activating signals from the control system logic to the SLCS pumps and valves. The control system logic for automatic initiation was built into the Redundant Reactivity Control System ("RRCS") panels (control room panels 1C22P001 and 1C22P002). The RRCS panels are the standard General Electric ATWS panels and include all Alternate 3A features, including automatic initiation. The automatic initiation capability is provided in a few of the plug-in printed circuit cards and memory chips which are incorporated in the RRCS panels. These panels were installed in the control room in early 1984.

4. The RRCS panels themselves cannot automatically initiate SLCS. To convert to automatic initiation, considerable additional equipment would have to be built into the plant. This includes the following circuits:

From Control Room Panel (lH13P)

Circuit or Motor Control To Control Designation Center (lR24S) Room Panel C22AXX010 1H13P601 1C22P001 C22AXX012 lH13P601 1C22P001 C22AXX014 lH13P601 1C22P001 C22AXX018 1H13P601 1C22P002 C22AXX110 1H13P632 1C22P001 C22AXX111 lH13P632 1C22P001 C22AXX112 lH13P632 1C22P001

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C22AXX113 lH13P632 1C22F001 C22AXX114 lH13P632 1C22P002 C22AXX115 1H13P632 1C22P002 C22AXX116 1H13P642 1C22P001 C22AXX117 lH13P642 1C22P001 C22AXX118 lH13P642 1C22P002 C22AXX119 lH13P642 1C22P002 C22AXX120 lH13P642 1C22P002 C22AXX124 lH13P632 1C22P002 C22AXX125 lH13P632 1C22P002 C22AXX126 lH13P632 1C222002 C41AXX012 lH13P632 lH13P601 C41AXX018 lH13P632 1H13P713E C41AXX019 lH13P642 lH13P710A l

C41AXX021 lH13P601 1H13P702B C41AXX022 lH13P601 1H13P642 C41AXX0231 / lH13P601 lH13P632 1/ This cable had been placed in floor duct prior to issuance of FDDR No. KLI-964 (see para. 6 below), but not termi-nated at either end.

C41AXX026 1H13P601 1H13P702E C41AXX029 1H13P601 1H13P702E 1C22B7A 1R24S018 1H13P713E 1C22B8B 1R24S023 lH13P720A 1C22C54A2 / 1R24S018 lH13P713E 1C22C55A 1R24S018 lH13P713E 1C22C58B2 / 1R24S023 1H13P710A 1C22C59B 1R24S023 lH13P710A Additional relays would also be required:

Designation Location (Control Room Panels)

C41A-K3A lH13P632 C41A-K4A lH13P632 C41A-K5A lH13P632 C41A-K6A lH13P632 C41A-K3B lH13P642 C41A-K4B lH13P642 C41A-K5B lH13P642 C41A-K6B lH13P642 Pump switches C41A-S01A and C41A-S01B which now have an 8 contact configuration would have to be replaced by a 10 contact size. Except for the cables mentioned in footnotes 1-2, none of these additions or replacements were ever installed at Perry.

5. As noted above, the installed RRCS panels included automatic initiation capability. This was in accordance with the statement in a letter from CEI to GE (H.L. Hrenda and H.A.

Putre~to R.C. Mitchell, dated August 9, 1982, Exhibit "B" hereto) that'the manual initiation feature "should not be incorporated on the [RRCS] panels prior to delivery," but that 2/ These. cables were pulled from the motor control center to the control room and terminated at both locations. They were never connected to the appropriate control panel.

They are now identified as spares.

4 GE'should perform its work so that the change to manual initiation "can be made after equipment delivery." This was done to avoid delays in delivery which could impact construction and fuel load schedules.

6. Because GE had not yet revised the electrical l

elementary drawings to reflect manual initiation, CEI on July 22, 1983 directed GE to issue the appropriate documentation to assure that equipment needed for automatic initiation was not installed in Perry. Exhibit "C" hereto.

GE's Field Disposition Disposal Request ("FDDR") No. KLI-964, originated October 20, 19p3, was issued as a result. Exhibit "D" hereto. Except for the circuits identified in footnotes l l-2, which were installed before FDDR No. KLI-964 was issued, and the RRCS panels, none of the SLCS automatic initiation equipment was ever installed.3/

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3/ The statement in an internal CEI memorandum dated September-28, 1983 that GE had been requested to prepare an FDDR "to remove the cables that were involved with au-tomatic initiation" (Exhibit "E" hereto), meant that the cables should be removed from the drawings and did not in-

-dicate that the cables had already been physically in-stalled.

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7. As of the date on which the final ATWS rule was issued (June 26, 1984), the SLCS installation was essentially complete. Installation of the manual initiation resture is at least 90% completes all circuits are installed and only a few circuits have not been terminated. On August 27, 1984, SLCS-subsystem CA:.A was turned over by Construction to Nuclear Testing. On July 31, 1984 SLCS subsystem C418 was turned over.

This permits manual testing or the SLCS from the motor cont'ol r centers. Thus, as of the date the ATWS rule was issued, the Perry SLCS was already being built as a manually initiated system.

8. Based on the facts set forth in this affidavit, the SLCS cannot be considered to have been built to include automatic initiation.

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Gary. R. L idich Subscribed and sworn to before me on this 7_ day or September, 19.84.

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Notary Public My Commission Expires PATRICIA G. OEDEK, Notary PutNic STATE OF CH!O l'Jhe County)

My Commies!on Expires April 16.1985

l RESUME OF GARY R. LEIDICH EDUCATION AND TRAINING: - Bachelor of Science, Electrical' Engineering, University of Toledo, 1972

- Master of Science Degree in Engineering Sciences, University of Toledo, 1974 EXPERIENCE:

1974-Present - The Cleveland Electric Illuminating Company Joined CEI in 1974 as an Associate Engineer in various fossil plant electrical engineering responsibilities in Plant and Substation Engineering Department. Responsible Engineer for precipitator retrofit.

In 1975, was assigned to the Perry Project and was Responsible Engineer for procurement of plant electrical equipment. Also responsible for Perry electrical system design calculations, voltage and short circuit studies and trar.smission system interface criteria.

In 1978, served as Lead Electrica' Eagineer and was responsible for supervision of personnel involved in all electrical engineering aspects.

In 1980, was Senior Engineer on assignment as .

Supervisor of Construction Quality Engineering.

Responsibilities included supervision of personnel involved in monitoring contractors' QA/QC performance during construction.

In 1982, was Senior Engineer in Nuclear Construction Engineering Section. Responsibilities included supervision of engineering personnel, providing construction support for electrical, civil, structural and chemical disciplines. Was alco responsible for cost and schedule control of all primary engineering consultants.

In 1984, was named to present position of General Supervising Engineer, Nuclear Construction Engineering Section and responsible for the on-site engineering to support the construction program for the Perry Plant.

PROFESSIONAL MEMBERSHIPS: - Secretary, Nuclear Power Engineering Committee of Power Engineering

- Society of Institute of Electrical and Electronic Engineers

- Registered Professional Engineer, State of Ohio Exhibit "A"

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P.O. SOX 97- a P ERRY. CHIO 44081 5 T EL. EPH ON E ( 216) 2s9 37 37 E ADDRESS-1c 'CENTER RO AD W Serving The Best Loca:ic- in :he Naticn August 9,'1982 4 PY-CEI/CEN-598

-Mr. R. C. 31itchell Project Manager-General Electric.ccapany 175 Curtner Avenue San Jose, CA 95125-Re: PNPP Units #1 and #2 Quotation No. 149A Request for Modification

Dear Mr. Mitchell:

-As previously dis:ussed, to prevent inadvertent injections of baron into the reactor vessel, it has been determined th'at the automatic SLCS initiation and RWCU isolation

. provided by the subject quote should be replaced by a manual initiation. system.

Because of uncertainty concerning the final ATUS mitigation systen require =ents this change sheuld not be. incorporated on the panels prior to delivery. The manual initiation'systen design. should detail the changes required to the documents and equip =ent so that these changes can be =ade af ter equipment delivery in the event

=anual initiation of the SLCS is' allowed by the final ATWS rule, or if no rule is.

issued prior to startup of the Perry Plant.

Tne manual initiation design should include annunciators to ensure the operator is informed of the event and is able' to deter =ine the necessity for SLCS initiation and RWCU isolation'within the~120-second period available. The operator will =ake'this determination based on the APRM readings and/or rod position indication after the 25-second delay' associated with ARI operation. Since the SLCS initiation /RUCU isolation ti=e has not been changed no further plant analysis should be required. -An assessment should be made of the impact of this change on system reliability.

To supperi licensing schedules, it is requested that this design be completed and issued by September 15, 1982. Addi'.ional canhours should be provided by T&M estimate by August' 23, 1982 General Electric is authorized to proceed on this design subject to approval of the estimated =anhours. g Very truly yours,

b. W E H..L. Hrenda /

Responsible Engineer

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H. A. Putre cc: E. M. Bu::elli - R230 Senior Engineer-D. R. Green - U225 E. C. Will=an.- W250 .

NDS File-41.2/C22/SP-M P0/DC - R290 SKE Y "0'

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.9 T3, J. J. Larsen nooM rnow  : E. C. Willman oArc ~ July 22, 1983 GE-NEB 0 PH o N r . 5238 nocM W240 s u sJ ccT. Manual Initiation of Standby ,

Liquid Control System C41 Please write a FDDR to remove the.following cables.from FDI-WNVB:

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C22A-XX-110 C22A-XX-119 C22A-XX-lli C22A-XX-120 C22A-XX-ll2 C22A-XX-121 C22A-XX-ll3 C22A-XX-122 C22A-XX-114 C22A-XX-123 C22A-XX-115 C22A-XX-124 C22A-XX-ll6 C22A-XX-125 C22A-XX-ll7 C22A-XX-126 C22A-XX-ll8 C22A-XX-142 This will. remove features not required for our manual initiation concept for the Standby Liquid Control System C41.

D. R. Gr6en Senior Project' Engineer ECN/iw cd: 'J.-H.:Bellack.

'E. C. Christiansen - T43

-R. E.-Colecan -'R230 P. A. Nichols - W250 F. R. Stead 'S245 Electrical File PC/DC - R290.

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DISPOSITION REQUEST h DEC 161983 D

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PROJECT Perry yqiy 1 Po CR soviPueNT (MPL OR DESCRIPTION OR 301HI c41-1050_SLC miCINV

,.5 Mm occuteeNT NO. l SM NO.j Mev. l 7 fts i e i Standby Licuid control 8YO63 O oeveATioN o&9CRIPfl0N Uni t 2 - 5.K %Lg-7,yi i

ATW$ FDI's issued for site work for SLC are not in agreement with the latest P410 CEI has requested SLC be returned to manual initiation (see PWA Rev. 0). CFI has' requested some changes recommended by their human factors st 'Issed rDI's involved I are WNST, WNSV, WNTE, WNTF WNVR WNUX.

O h Changes detailed on the attached sheets are required.

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TH6 MAA)UAl. /lIWS S.'CS Mo&s) iS ST/lL NORG Ril/ASLE k WA/

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. Sh t of I S I DEVIATION DESCRIPT_ ION AND SUGGESTED DISPOSITION

1. Deletion of valve indication for C41-F037A, B, C41-F038 A, B, C41-F040 A, 8. from 828E234CA and H13-P601 is required to agree with P&ID 762E433 CA Rev. 1.

2. On 8'28E234CA, Sheet 5 and P601, delete DIV 2 indication of C41-F031 as one indication considered sufficient.

3. Delete the circuit from C41-F036 to the Division 2 out-of-service indication. The input to DIV. I from C41-F036 will be maintained to indicate valve F036 closure.

4. Delete valve C41-F008 from 828E234CA sheet I table.

5. Delete the SLC pump auto trip indication to be consistent from a Human Factors standpoint with other like control. Pump or MOV overload or PWR loss indication already exists on the system status panel.

6. Delete SLC Manual override indication since CEI is not installing automatic SLC injection.

7. Delete "RRCS Test Fault" to out-of-service window on P601-188 and m 19B as SLC is being made manual and there is a "RRCS trouble" annunciator and "RRCS Test Fault" indicator on P680.

8. Revise SLC control back'to manual operation. Maintain existing control switchesy K%CfPT F s e. IT'# M 9 6 t Le w . #arg,g .

9. Move locally mounted control switches for C41-C001 A, B and C41-F001A, 8 from the containment to the Motor Control Center to resolve the concern of qualification of the CR2940 switch for containment environment. Delete the local status indication of C41-C001 A, B. CHWGi sw er c w as To ggy ueA us.s. %.n

10. For SLC test tank valves C41-F016 and C41-F31 change from valve status light indication on H13-P601 to an annunciator window on H13-P601.

11. The annunciator window should read SLC in Test .

Test TNK VLV Open

12. On Elementary 828E2342A sheet 2 correct reference sheet number from SH2 to SH7 at SRU-1. SRU-2, SRU-3.

B. Suggested Disposition

1. Refer to ECA 800619-2, Rev. 3, PWA 4160KL, Rev. 1 and this FDDR for authority. '

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, FDDR KL1-964 REV. 0 9%*

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2. Modify H13-P601-18#, -198, panels H13-P632, P642, P710. P713 arrangement in accordance with the attached sketches and instructions. Revise necessary wire list and panel drawings for completion of this FDDR wNvt wapackage, Tv M$.ar-a3 3 .- Revise FDI's WNST, WNSV,WR9R. W A P, WNVB and WNUT to make changes necessary for implementation of this FDDR and PWA 4160KL.

FDI Sul44ARY

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S WNST Rev. 0 will not be implemented. The FDI needs revision to delete theswitchesandindicatinglights53A,B,54A,Bandre/dandgreen lights for 54A, B.

WNSV 4.3.1 Do not install the two new indicating lights 4.3.2 4.3.3 Do not install the new C41A-501B '

4.3.4 Do not install the for switch indicators 4.3.5 4.3.6 Install only the marker for the new meter '

4.3.8 Do not install J438, J439 4.3.10 Do not add wiring to above deleted devices 4.4.1 Da not insta 1 the two new indicating lights or switch 4.4.2 4.4.3 indicators a.4.4 Do not install new C41A-501A 4.4.5 Do not install switch indicators and legends 4.4.6 Install only legend for meter 4.4.7 No change 4.4.8 Do not install-jacks associated with deleted junctions above 4.4.9 4.3.10 Do not install conduit associated with deleted functions above 4.3.11 No change NRB:pab/2Q-2 -

10/25/83

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FDDR XL1-964 REV. 0-Sh g of /g.

wm 4.3.1 Do not delete relay C41A-K2A 4.3.2 pd s 4.3.3 ' se*8' e

. # I 4.3.7 Do not install relays C41A-K3A, X/A, K(A and K6A WNTF l

4.3.1 Do not delete relay C41A-K?.R 8 # #% ,

is 4.3.2 '

4.3.3.

o 4.3.6 Do not install relays C41A-K38. K48 K5B and K68 WNV8 4.3.3 Do not remove cable C41AXXett 44 /v. 9 ** ^' > W- ~ ^ ' ~ " "

4.10.4 Do not install-cable C22AXX118 **""#

4.10.5 Do not install cable C22AXX119 f,,y, y 3 , ,,,- , - < m e d.

4.10.10 Do not install cable C22AXX120 .,,u /et 4.12.2 Do ret install cable C22AXX115 ..

4.12.10 Do not install cable C22AXX124 g, f y 3 ,, ,.y. ,.,.,, ,, w,.g 4.12.16 Do nct install cable C22AXX125 4.12.17 Do not install cable C22AXX110 .

4.12.18 Do not install cable C22AXX112 4.12.22 Do not install cable C22AXX126 W /46 5 f b * ^<""'" **

4.12.23 Do not instali cable C22AXX111 enu< e s a_.

4.12.24 Do not install cable C22AXX113 4.14.47 Do not install cable C22AXX114 4.14.48 .Do not install cable C22AXX116 4.14.73 Do not install cable C22AXX117 4.10.1 Do not install cable C41AXX019 4.12.3 Do not install cable C41AXX018 4.12.4 Do not install cable C41AXX M elk 4.15.4 Do not install cable C41AXX021 4.15.5 Do not install cable C41AXX026 Aj' ,.e3 4.15.8 Do not install cable C4 AXX029

4.las t, be ser suersu. una c(4tn sat a Lt.

WNUX 4./a.(e be #er Avsrs'A (**4 r#tdarea3 4.4.2 Do not install TM041 l 4.6.3 Do not install TM060 4.2.1 Do not install TM063 W ^^^M'^^t" S Asyssa r##s is A hun smoow As p

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• COMPANY

• 7 ./ I no longer wish to

' ./.a icv. s .sa MEMORANDUM receive thi= ==ierial-yo D. R. Green naos W225 rnoM E. C. Willman oxyc September 28, 1983 PHoNc 5238 nooM W240 sueJccT Status of Standby Liquid. Control System C41 Design Change At the present time GE has made very little progress on removing the automatic ~

initiation of the Standby Liquid Control System (SLCS) C-41. They have still not issued the modification kit to the elementary diagrams that we requested in September, 1982, except on a preliminary basis. We have repeatedly asked that a

, design reviewed mod kit be issued. A promise was made by GE that this would be done at the last quarterly meeting on July 18 and 19,1983. Repeated requests for issuance of the mod kit have brought no results.

On July 22, 1983, we requested GE to prepare a FDDR to remove the cables that were involved with automatic initiation (see attached). This effort in conjunction with GAI's incorporation of the mod kit would complete the design change. As of this date no significant effort has taken place on this FDDR and GE-San Jose has informed me it is on hold.

GE is now requesting approval o'f a work authorization of S80,000 to complete the design change and bring all affected documents up-to-date. I discussed this some time ag'o with Bob Mitchell and at that time he estimated this to be a S2,000 to S4,000 effort. Also, this was just for revising drawings to include the mod kit.

. No indication was given that extra effort would be required to have a complete design change.

The work authorization includes the following:

1. 7ssue Revised Redundant Re-activity Control System (RRCS) Design Specification and Data Sheet.

2. Issue revised balance of plant information document,

3. Update Operations and Maintenance Manual.

4. Revise Manual Action Procedure.

5. Revise RRCS Elementaries and Functional Conttol Diagrams.

6. Revise SLCS elementaries and Functional and Control Diagrams. .

7. Prepare New RRCS Panel Schematic and Connection Diagram.

8. Change the Programmed Read Only Memory (PRCM) in the RRCS Panel.

9. Prepare FDI's to implement cable and PRCH changes in the control rec =.

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i D. R.' Green September 28, 1983

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In addition,iI pointed out to GE th'at number 8 is software and there must also'be a'h'ardware. change.- They agreed but had no cost estimate for the hardware. This

' item !(8) :also accounts for approximately one-third of the ' entire effort. GE'is j estimating 17 weeks to complete the work authorization.

'. From the preceding' discussion'you can -'see that we have made very little progress

.since' July. . GE has not' met- their promises and. virtually ignored our requests. We

'need to determine if proceeding in the manual direction is still correct. If'so, -

we'.will have to approve the work authorization. Management attention will be required to' ensure'GE's prompt completion-of the effort.

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