ML20108D933
| ML20108D933 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 03/30/1984 |
| From: | Willman P ILLINOIS, STATE OF |
| To: | Goddard R NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| Shared Package | |
| ML20108D925 | List: |
| References | |
| FOIA-84-274 OL, NUDOCS 8412130505 | |
| Download: ML20108D933 (5) | |
Text
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.h OFFICES " F THE ATTORNEY TENERAL Ge Las Div n
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Richard J.
Goddard, Esq.
ff Office of the Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Re:
Illinois Power Co. (Clinton Power Station), 50-461 OL
Dear Mr. Goddard:
I am writing as part of our continuing informal discussions concerning settlement of Contention III in the above captioned proceeding.
Enclosed is Illinois' proposal to revise Contention III.
This proposal sets forth the specific concerns that Illinois has at this time about the control room at the Clinton Power Station.
We wish to discuss this proposal during our next meeting, which is scheduled for April 11, 1984.
Please note that our proposal includes the dismissal of the current Contention III (c), which, of course, requires Prairie Alliance's concurrence.
I am also writing to confirm your representation that the NRC Staff will make available a transcript of the meeting, scheduled to take place in Bethesda, Maryland on April 5, 1984, on the Clinton Power Station Safety Parameter Display System.
Please call Allen Samelson if this is not the case.
Yours truly, 8412130505 840614 PDR FOIA DOVE 84-274 PDR PHILIP WILLMAN Assistant Attorney General Environmental Control 'livision PLW:dmw Encl.
cc:
Sheldon Zabel Jean Foy
8 Proposed Contention III III.
The design and fabrication of the Clinton Power Station (CPS) control room layout and instrumentation have not been modified to meet current regulatory requirements.
Specifically:
(a)
The reactor pressure vessel water level measurement devices are deficient in.that they fail to meet the provisions of Reg. Guide 1.97, Revision 3 as follows:
(1)
The devices for the upset range and the fuel zone range are not environmentally qualified over their entire range, and therefore fail 4
to comply with 10 CFR 50.49 and the provisions in Reg. Guide 1.89 and Reg. Guide 1.97.
(2)
The upper 56 inches between the upper end of the wide range level instrumentation and below the centerline of the main stream line is not j
monitored by redundant instruments.
Thus it does not comply with the provisions of Reg.
I Guide 1.97.
l-I (3)
Important monitors in the fuel zone range level f^
instrumentation and the upset range instrumen-tation are not powered by station standby I
i sources.
Thus they do not meet the provisions of Reg. Guide 1.97.
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r (b)- The~ method for detecting inadequate core cooling is
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deficient because it relies heavily upon the reactor pressure vessel water level monitoring instrumentation This instrumentation is neither totally qualified, powered by Class IE Power sources or redundant over the entire range.
Thus it does not meet the pro-visions of NUREG-0727, item II.F.2, and Reg. Guide 1.97.
(c)
(deleted)
(d)
The Safety Parameter Display System (SPDS) is deficient because:
(1)
Computer signals have'not been shown to be adequately isolated from other safety-related signals.
There is no assurance that failures in the SPDS will not affect safety related signals and functions.
Thus it does not comply with 10 CFR 50, App. A, GDC 24.
(2)
The color yellow is not used consistently between the ARM /PRM displays and the SPDS dis-a play (2/10/84, IP to NRC, U-0695, 2.2.6).
IP I
therefore fails to conform to the provisions of l
NUREG-0700, Sections 6.5.1.6 and 6.7.2.7.
(3)
Although limited time-history information.is l'
2vailable in the form of rate of change data l'
and trending capabilities (2/10/84, IP to NRC, U-0695, 2.6.3), the SPDS does not appear to readily provide a 30 minute time-history display of the necessary pu ameters following an accident.
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'Thus it does not meet the provisions of
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- 'NUREG-0835, Section 3.2.
(4)
The AR/PR display, as illustrated in Appendix 3 of 2/10/84, IP to NRC, U-0695, is located ad-jacent to the Standby Information Panel (Figure 2, IP to NRC, U-0695) and is not readily visible or accessible to an operator at the~ control console.
The CPS therefore does not comply with the provisions of NUREG-0835, Section 4.4.3.1.b.
(5)
The NRC has not yet verified compliance of the Clinton Power Station with Generic Letter 82-33.
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(1)
IP states t t the CPS wi comply wit Reg.
Guide 7, Revision 3 (9/9/83, IP.
o NRC, U-0 3), but the N intends to eview CPScom-liance with R
. Guide 1.97 Revision 2 (1/25/84, Rosa to God rd).
(I)( )
The CPS reactor pressure vessel water level monitoring equipment (IP parameter designation I
A2) is deficient, as described above.
I h
There are no data in IP's_" Compliance Report on Reg. Guide 1.97 [ Revision 3]" (9/9/83, U-0633) to show IP's compliance with five design and -
r-qualification criteria for accident monitoring
. instrumentation found in Reg. Guide 1.97, 1
Revision 3.
Those criteria are:
channel avail-ability, equipment identification; interfaces; servicing, testing and calibration; and direct measurement.
(3)
)
Compliance with Reg. Guide 1.97 is noti verified because the NRC has not yet completed its review.
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