ML20135F038

Submits Supplemental Response to NRC Bulletin 80-06, Engineered Safety Feature Reset Controls

ML20135F038
Person / Time
Site:	Fort Calhoun
Issue date:	03/07/1997
From:	Gambhir S OMAHA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
IEB-80-06, IEB-80-6, LIC-97-027, LIC-97-27, NUDOCS 9703110140
Download: ML20135F038 (12)

Text

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% 998 Omaha Public PowerDistrict 444 South 16th Street Mall Omaha NE68102-2247 March 7 1997 LIC-97-027 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station P1-137 Washington, D.C. 20555-0001

References:

1. Docket No. 50-285

2. NRC Bulletin 80-06. " Engineered Safety Feature (ESF) Reset Controls." dated March 13, 1980

3. Letter from OPPD (W. C. Jones) to NRC (K. V. Seyfrit) dated June 6 1980 (LIC-80-0068)

4. Letter from OPPD (W. C. Jones) to NRC (K. V. Seyfrit) dated February 27, 1981 (LIC-81-0024)

5. Letter from 0 PPD (W. C. Jones) to NRC (R. A. Clark) dated May 15.

1981 (LIC-81-0062)

6. Letter from OPPD (S. K. Gambhir) to NRC (Document Control Desk)  ;

dated January 21, 1997 (LIC-97-0004) I

SUBJECT:

Supplemental Response to Bulletin 80 06 NRC Bulletin 80-06 noted that reset of Engineered Safety Feature (ESF) actuation signals during the course of an accident could cause some plant components to return to the normal (pre-accident) mode of operation, without operator knowledge or intent. j Licensees were requested to review safety-related systems to determine what equipment 1/

failed to remain in emergeney mode following ESF reset and to propose corrective actions  !

to resolve the problem. Omaha Public Power District (OPPD) provided an initial response and supplemental information for Fort Calhoun Station (FCS) in References 3, 4. and 5.

Licensee Event Report (LER)96-016 (Pseference 6) described a scenario in which High f Pressure Safety Injection flow could be diverted through valves PCV-2909. PCV-2929. PCV '

2949. and PCV-2969 during a small break Loss of Coolant Accident by resetting ESF actuation signals in accordance with plant procedures. A primary cause of this condition was lack of depth in evaluation and review of IEB 80-06. As corrective action in the LER. OPPD committed to amend the earlier IEB 80-06 responses to correct inaccuracies, and to provide the conclusions of a modification evaluation for the valves noted above. Attachment 2 of this letter provides the necessary supplemental information.

9703110140 970307 '

PDR ADOCK 05000285 2UUO1 l(($$$%E,5hh,5 45.5124 Employment with EqualOpportunity

, l U. '.S Nuclear Regulatory Commission i LIC-97-027 Page 2

. Administrative corrective actions for some affected equipment are listed in Attachment

2. OPPD will complete the changes to applicable procedures no later than July 31, 1997.

These actions will provide compliance with the intent of IEB 80-06.

The control circuitry of valves PCV-2909, 2929, 2949, and 2969 will be modified to prevent opening of the valves upon reset of ESF. This modification (MR-FC-97-004) will be completed no later than the end of the 1998 Refueling Outage. As additienal enhancements, OPPD may in the future decide to implement circuit modifications which will keep other equipment in desired modes following ESF reset. Such modifications would negate the need for some of the procedure changes previously discussed.

This letter is provided under oath. Please contact me if you have any questions.

Sincerely, N

S. K. Gambhir Division Manager Engineering & Operations Support Attachments TCM/tcm c: Winston & Strawn J. E. Dyer, NRC Acting Regional Administrator, Region IV l W. D. Johnson, Chief - Reactor Project Branch B Region IV

{

L. R. Wharton, NRC Project Manager i W. C. Walker, NRC Senior Resident Inspector j l

l i

l l

}

LIC-97-027 Attachment 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )

) .

Omaha Public Power District ) Docket No. 50-285 (Fort Calhoun Station )

Unit No._1) )  ;

AEEIDAVII S. K. Gambhir, being duly sworn, hereby deposes and says that he is the Division Manager

- Engineering & Operations Support of the Omaha Public Power District; that as such he i is duly authorized to sign and file with the Nuclear Regulatory Commission the attached )

information concerning supplemental response to the requirements of NRC Bulletin 80-06; that he is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge, information and belief.

(

WY S. K. Gambhir Division Manager Engineering & Operations Support STATE OF NEBRASKA)

) ss COUNTY OF DOUGLAS)

Subscribed and sworn to before me, a Notary Public in and for the State of Nebraska on this _7 *^ day of March, 1997.

GENIRAL NOTAM State of Nebmh

1. Jut lE B. KUHR

. qLt= u,comatip.AprH.20eo Notary Public-

.i

LIC-97-027 Attachment 2 Page 1 Omaha Public Power District (OPPD)

Supplemental Response to Bulletin 80-06 NRC Inspection and Enforcement Bulletin (IEB) 80-06 noted that reset of Engineered Safety Feature (ESF) actuation signals during the course of an accident could cause some plant components to return to the normal (pre-accident) mode of operation, without '

operator knowledge or intent. Licensees were requested to review safety-related systems

-to determine what equipment failed to remain in emergency mode following ESF reset and '

i to propose corrective actions to resolve the problem. OPPD provided responses to IEB 80-06 in letters dated June 6.1980 (LIC-80-0068). February 27, 1981 (LIC-81-0024), and

, May 15, 1981 (LIC-81-0062). The June 6,1980 letter defined what components at Fort

! Calhoun Station (FCS) could return to their pre-accident state following reset of the j ESF lockout relays. The February 27, 1981 letter transmitted the results of follow-up reviews to determine if circuit modifications were required. The May 15, 1981 letter

provided details of circuit modifications for several valves discussed in the first letter.

In June 1996, an OPPD Operations Engineer generated a Condition Report questioning the i adequacy of the original responses to IEB 80-06 after noticing the repositioning of valves following ESF resets during training on the plant simulator. As a result, OPPD personnel performed Engineering Analysis EA-FC-96-051 to review the FCS ESF controls >

for the effects of ESF reset using the guidelines in IEB 80-06. The review looked at component control circuits to determine which components could reset (e.g.. a pump stops if ESF has started it, a valve closes if ESF has opened it, etc.) regardless of the J plausibility of the sequence of events. The reset data was compared to the information provided in the original IEB 80-06 submittals and to the directions given the plant Operators in the Emergency and Abnormal Operating Procedures.

The review identified a reportable condition. Licensee Event Report (LER)96-016 described a scenario in which High Pressure Safety Injection flow could be diverted through valves PCV-2909, PCV-2929. PCV-2949, and PCV-2969 during a small break Loss of Coolant Accident by resetting ESF actuation signals in accordance with plant procedures.

A primary cause of this condition was lack of depth in evaluation and review of IEB 80-  !

06, As corrective action in the LER, OPPD committed to amend the earlier IEB 80-06 responses to correct inaccuracies, and to provide the conclusions of a modification i evaluation for the valves noted above.

i No safety significant concerns were identified beyond the one discussed in LER 96-016. l The results of the analysis are summarized in Tables 1 and 2.

Table 1 lists the components identified in the two original submittals which could I change state on ESF reset. This table summarizes the present status of the circuits if modified since the submittals and how the component is addressed in the current '

Emergency Operating Procedures with respect to ESF signal reset. Errors in the original submittals are noted.

. -- - . - - . -- .~. - .. - - - -

LIC-97-027 Att.achment 2 Page 2 Note: Table 1 contains some components whose control circuits were modified to mitigate the effect of the ESF reset and would not normally be part of the IEB 80-06 submittal update. This additional data consolidates the information from the original IEB 80-06 submittals.

Table 2 contains a list of components identified as changing state on ESF reset but not ,

included in the original IEB 80-36 submittals. These components either should have been ,

included in the original submittals, or have come under the IEB 80-06 applicability due to implementation of modifications since 1980 This table surmiarizes the present status  ;

of the circuits and how each ccmponent is addressed in the current E0Ps with respect ,

to ESF signal reset.

Coccectivelctions The corrective actions for the various components are contained in Tables 1 and 2. In several instances, no action was considered necessary. For other equipment, the addition of a note to applicable procedures was considered acceptable. The purpose of the note is simply to notify the operator of the equipment which will reposition so that he/she is not surprised.

The remaining items involve equipment where OPPD will add steps to the procedures to prevent restart. For these itens, equipment restart was considered undesirable but without adverse effect on plant shutdown. OPPD will complete the changes to applicable procedures no later than July 31, 1997. These actions will provide compliance with the intent of IEB 80-06.

The control circuitry of valves PCV-2909, 2929, 2949, and 2969 will be modified to ,

prevent opening of the valves upon reset of ESF. This modification (MR-FC-97-004) will i be completed no later than the end of the 1998 Refueling Outage. As additional l enhancements, OPPD may in the fu;ure decide to implement circuit modifications which will keep other equipment in desired modes following ESF reset. Such modifications would negate the need for some of the procedure changes previously discussed.

Finally, appropriate OPPD modification design procedures have been revised to ensure i proper actions are taken relative to IEB 80-06 when modifying Engineered Safeguards I equipment.

LIC-97-027 Attachment 2 -

Page 3 Table 1 Evaluation of the Original Response to IE Bulletin 80-06 IEB 80-06 Response Present Plant Configuration Component Description and Proposed Corrective Action to Tag and Address the ESF Reset Number ESF Action Each Component Configuration /Controis at initial IEB 80-06 Response Additional Information Configuration / Proposed can go to its the Time of the Bulletin LIC 80-0068 LIC 81-0024 Administrative Corrective pre-DBA State Response Controls Action y on ESF Reset PCV-521 Waste Disposal No spedal controls, placed Committed to update EP-35 to identify Committed to a modification to PCV-521 removed and No mrrective Gas to Stack in service for waste gas reset. have valve remain dosed replaced by action required, release PC7650 FCV-532A/B/C, which do the valves remain VIAS Closes EP-35 Update Completed. not open when the ESF dosed.

MR-FC-80-52 complete signal is reset.

MCV-484 CCW isolation to Normally dosed, opened for Committed to update EP-35 to identify Committed to a modification to Mod. FC-89-032 added N, No mrrective SDC HX A outlet Shutdown Cooling operation reset. have valve remain open. PC7651 backup and changed the action required.

HCV-485 CCW isolation to .

logic so that if iristrument EOP/AOP ,

SDC HX B oudet EP-35 Update Completed. MR-FC-80-53 Completed air is lost and RAS is provides the reset the valve will ne ssary actions RAS opens redose. (This is a to override the 6 revision of the original reset effect wmu u na st.)

HCV-480 CCW isolation to Normally dosed, opened for Committed to update EP-35 to identify Committed to a modification to Mod. FC-89-032 added N, No corrective SDC HX Ainlet Shutdown Cooling operation resel have valve remain open. PC7651 backup. There was no action required.

HCV-481 CCW isolation to logic change.

SDC HX B inlet EP-35 Update Completed. MR-FC-80-53 Completed RAS opens HCV-489A/B AC-1 A CCW Three of four heat The response correctly identified the A review conduded that no mod A minimum of two out of A note will be isolation Valves exchangers in service per valves as "not locked out," meaning was required, all valves are open. four HXs always in added to the HCV-490AG AC-13 CCW OI-CC-1. retuming to the pre-DBA state. service as required per a p pIica bie i isolation Valves (Basis that all valves are open was OI-CC-01. procedures to MC,V-491A/B AC-1C CCW Information in EP-35 Information in EP-35 was considered incorrect.) ESF reset would mme describe the reset isolation Valves indicated that the valves adequate to address the issue. well past the peak CCW action.

HCV-492A/B AC-1D CCW would dose on ESF Reset. temperature, reference '

Isolation Valves EA-FC-95-10. The " loss" of two heat exchangers SlAS opens would have a minimal effect t

i LIC-97-027 Attachment 2 -

Page 4 Ta'ole 1 Evaluation of the Original Response to IE Bulletin 80-06 IEB 80-06 Response Present Plant Configuration Component Description and Proposed Corrective Action to Tag and Address the ESF Reset Number ESF Action Each Component Configuration / Controls at initial IEB 80-06 Response Additional Information Configurationf Proposed can go to its the Time of the Bulletin LIC 80-0068 LIC 81-0024 Administrative Corrective pre-DBA State Response Controls Action on ESF Reset PCV-2909 St Loop Check Valves norma!!y placed in The response correctly identified the A review conduded that no mod Normal operation -

EOPs and AOPs PCV-2929 Valve leakage the automatic mode valves as retuming to the pre-DBA state was required. automatic mode. If S!AS have been PCV-2949 cooler pressure (open). Existing procedures ' were is reset with RCS above updated to pull PCV-2969 control valves considered adequate. 400 psig. HPSI flow may fuses before ESF be diverted through SI- reset.

SIAS doses The potential diversion of HPSI flow to 222. The control circuit the core was not identified. will be modified in 1998.

HCV-2o08A/B SI-1A Valves were opened for The response correctfy identified the The submittal indicated that the Va!ve kept in the open No corrective HCV-2809A!B Si-1B normal operation per OI-CC- valves as "not locked out." meaning loss of CCW flow could be position per OI-CC-1 action required

• HCV-2810A/B St-2A 1. retuming to the pre-DBA state. detected by the low flow Checklist HCV-2811 A/B SI-2B controllers which operate HCV-2812A/B SI-2C Information in EP-35 annunciators in the Control Room '

HCV-2813A/B St-3A indicated that the valves and corrective action taken. This HCV-2814A/B SI-3B would dose on ESF Reset. statement was accurata in thatit is HCV-2815A/B SI-3C possible. (This implies that the Bearing Coo er valves are normally dosed, wtiich CCW isolation is not correct.)

Valves SIAS opens FCV-269 Boric add makeup Valve opened as required for The response was accurate, the valves . A review conduded that no mod Valve opened as required No corrective inlet vafve makeup to the VCT were , identified as "not locked out." was required. for makeup to the VCT action required.

mecnsng retuming to the pre-DBA state.

SlAS doses LCV-218-2 VCT Outlet Valve Valve is open for normal The response was accurate, the valves A review conduded that no mod Valve open for norrnal A note will be power operation. The valve were identified as "not locked out," was required. operation. added to the SIAS doses doses on an acddent signal. rneaning retuming to the pre-DBA state. a p piic a bIe i procedures to describe the reset action.

_ _ _ _ _ _ . _ _ . _ _ _ _ _ . _ . _ . __ _ _____________ ____ _.____ _ ___________ ____________ _ _ _ _ _ . _ _ . _ _ _ _ _ ~ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ . _ _ = , _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ _ . _ . _ _ . _ _ _ . _ _ _ . _ _ _

LIC-97-027 Attachment 2 -

Page 5 Table 1 Evaluation of the Original Response to IE Bulletin 80-06 IEB 80-06 Response Present Plant Configuration Component Description and Proposed Corrective Action to Tag and Address the ESF Reset Number ESF Action Each Component Configuration / Controls at initial IEB 80-06 Response Additional Information Configuration / Proposed can go to its the Time of the Bulletin LIC 80-0068 LIC 81-0024 Administrative Corrective pre-DBA State Response Controls Action en ESF Reset CH-4A Boric Acid Pump The pump is off during The response indicated that A review conduded that no mod EOPs do not identify the A note will be CH-4B normal operation. The pump administrative controls were in place in was required. pump as stopping on ESF added to the SIAS starts start on SIAS. EP-35. Reset. a p piica bie procedures to (The Response was in error: EP-35 did describe the reset not indicate that the pump was "not action.

locked out*)

DW-46A Vacuum Deareator Placed in service as The response indicated that No modification was required. New vacuum deareator No corrective DW-46B Pump required. Typically one unit administrative controls were in place in pumps were installed with action required. -

is operating. EP-35. load shed at the 480V 1 load center. The reset (The response was in error. The "not circuit was eliminated.

locked out" identification was not contained in EP-35.)

WD-2A RCDT Pumps Operated as required. The response indicated that The response was that a OI-WDL WD-2A in A note will be  ;

WD-2B administrative controls were in place in modification was being considered OFF, WD-2B in AUTO added to the SlAS 480V Load EP-35. for mote protection only and not in a p pIic a bie Shed response to IEB 80-06. EOPs do not identify the procedures to (The Response was in error, EP-35 pump as stopping on ESF describe the reset contains no administrative controls.) Reset. action.

HCV-344 Containment Spray Valve aligned for automatic The response identified the Coenmitted to update EP-35 to EOPs identify the same No further action HCV-345 header valves operah administrative control regarding the need open via the hand controller action as EP-35 required.

to terminate spray flow at 3 psig CSAS opens containment pressure and resetting the Complete per PC6796 accident lockout relays as adequate.

• PCV-1849 Containment Normally open, closed by The response indicated that the valve none Valve replaced by PCV- No further action Instrument Air low header pressure and closed by low header pressure and 1849A and PCV-18498. required Isolation Valve CIAS CIAS. Valves do not open on No further action required. Reset of ESF, closed by CIAS and low low header pressure and '

pressure closes an ESF signal.

WD-3A Containment Sump Operated as required. Committed to update EP-35 to identify none OI-WDL one pump A note will be WD-3B Pumps reset. selected as the lead added to the pump. a p plic a ble SIAS 480V Load EP-35 Update Completed. procedures to Shed describe the reset action.

LIC-97-027 Attachment 2 ,

Page 6 Table 1 Evaluation of the Original Response to IE Bulletin 80-06 IEB 80-06 Response Present Plant Configuration Component Description and Proposed Corrective Action to Tag and Address the ESF Reset Number ESF Action Each Component Configuration / Controls at initialIEB 80-06 Response Additional Information Configuration / Proposed can go to its the Time of the Bulletin LIC 80-0068 UC 81-0024 Administrative Corrective pre-DBA State Response Controls Action on ESF Reset WD-27A Auxiliary Building Operated as required. Committed to update EP-35 to identify none OI-WDL one pump A note will be WD-27B Sump Area No.21 reset. selected as the lead added to the Pumps pump. a p p Ii c a bie WD-40A Auxiliary Building EP-35 Update Completed. procedures to WD-40B Sump Area No. 22 describe the reset Pumps action.

WD-26A Auxiliary Building WD-268 Sump Pump SIAS 480V Load Shed VA-49 Control Operated as required The fan was simply identified as usibly not included Corrected in MR-FC- FC- No corrective Room Toilet operating on ESF reset.94-020 action required.

Exhaust Fan VIAS Trip 86A/OPLS OPLS Lockout Set for automatic operation Committed to update EP-35 to identify MR-FC-80-42 Completed Set for automatic No corrective 86B/OPLS Relays reset. PC-5813 operation action required.

First lockout reset EP-35 Update Completed.

will have the ESF 4160V Breakers associated with it trip

. _ _ . _ . . _ _ - _ . ..____z______m - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _--_ - _ _ _ _ _ _ _ _ . - _ _ _ _ _ _ . _ . _ - _ _ _ _ . _ _ _ _ _ _ _ _

.i LIC-97-027-Attachment 2 Page 7 Table 2 Compliance with IEB 80-06, Review of ESF Equipment not Considered in the Original Response Component Description and ESF Action Condition Effect of ESF Roset EOP Directed Action Prcposed Corrective - ,

Tag Number Existed at the Action time of the IEB 80-06 Submittal EHC-3A EHC Pump,480V Load Shed no Will start on reset if selected as Standby EOPs do not address this issue. A step will be added to the applicable Pump-offsite power only procedures to take the control switdi to .i pullout prior to ESF Reset i EHC-38 EHC Pump, ,480V Load Shed no Will start on reset if selected as Standby EOPs do not address this issue. A step will be added to the applicable ~ t Pump procedures to take the control switch to .

pullout prior to ESF Reset.  ;

FW-2A Condensate Pump SIAS Load Shed no Pump in standby can start - use of 43/FW The use of 43/FW is addressed in EOP- No mrrective action required" I blocks start 00. The switch is to be placed in the

• FW-4A Feed Pump. SIAS Load Shed "off" position.

FW-5A Heater Drain Pump, SIAS Load Shed b FW-58 i FW-2B Condensate Pump. SlAS Load Shed no Pump in standby can start-use of 43/FW The use of 43/FW is addressed in EOP- No corrective action required ~ i if aligned for auto standby start blocks start 00. The switch is to be placed in the t "off" position. l FW-2C Condensate Pump. SIAS Load Shed Yes -should Pump in standby can start - use of 43/FW The use of 43/FW is addressed in EOP. No corrective action required

• if aligned for auto standby start and have been blocks start 00. The switch is to be placed in the ,

OPLS load shed. reported "off" position. +

t FW-48 Feed Pump, SlAS Load Shed or no Pump in standby can start - use of 43/FW The use of 43/FWis addressed in EOP- No corrective action required.

00. The switch is to be placed in the  ;

CSAS if aligned for auto standby blocks start start "off" position.  ;

FW-4C Feed Pump, SlAS Load Shed or Yes - should Pump in standby can start - use of 43/FW The use of 43/FW !s addressed in EOP- No corrective action required' I CSAS if aligneu for auto standby start have been blocks start 00. The switch is to be placed in the and OPLS Load Shed reported "off" position.

FW-5C Heater Drain Pump, SIAS Load Shed Yes - should Pump in standby can start - use of 43/FW The use of 43/FW is addressed in EOP- No corrective action required ~ i and OPLS Load Shed have been blocks start 00. The switch is to be placed in the r reported "cff" position.  !

FW-8A Condenser Evacuation Pump. OPLS no if this is the standby pump it will start none A step will be added to the applicable ,

procedures to take the applicable control Load Shed blocks standby start switch to pu!!out prior to ESF Reset..

FW-8B Condenser Evacuation Pump, OPLS no if either pump is the standby pump it will none A step will be added to the applicable .

FW-8C Load Shed blocks standby start start procedures to take the applicable control  ;

switch to pullout prior to ESF Reset. '{

HCV-1105 FCV-1101 Bypass no Valve will reopen if previously open EOo-05 provides direction on use of the A note will be added to the applicable [

HCV-11% FCV-1102 Bypass valve for isolation and feeding if the procedures to describe the reset action.

main feed ring is used. i SGIS close .

HCV-400C Conta.nment Air cooler outlet valves Yes - should Normally the coolers associated with VA- EOPs clearly identify that the hand No corrective action required.

• HCV-401C have been 3A and VA-3B are used. Valves are controllers are to be placed in open for '

HCV-402C CIAS open reported normally throttled and will retum to the ESF reset -

,HCV-403C throttled position 4 f

t

LIC-97-027 Attachment 2 -

Page 8 Table 2 Compliance with IEB 80-06, Review of ESF Equipment not Considered in the Original Response Component Description and ESF Action - Condition Effect of ESF Reset EOP Directed Action Proposed Corrective -

Tag Number Existed at the Action time of the IEB 80-06 Submittal RC-4A-HTRS PZR Backup Heater Bank 1 Group 2 Yes - should Heaters wit! reenergize if previously in The use of the heaters is addressed in A note will be added to the applicable 3, Bank 2 Group 5,480V Load Shed have been servim and pressurizer level is above the the EOPs but not in the context of ESF pro dures to desenbe the reset action.

reported low level cutoff. reset.

RC-4A-HTRS PZR Backup Heater Bank 3 Group 9, Yes - would Heaters will reenergize if previously in The use of the heaters is addresseo *- A note wit! be added to the applicable Bank 4 Group 11,12,480V Load Shed have been service and pressurizer level is above the the EOPs but not in the context of ESF procedures to describe the reset action.

reported low level cutoff. reset.

SI-1A LPSI Pump, RAS Trip Yes - should if the Sequencers have not been reset the Reset of RAS not identified in the EOPs No corrective action required.

have been pump will restart. Note, RAS does not as being required.

SI-1B LPSI Pump, RAS Trip reported operate if the Sequencers are reset.

ST-68 Stator Cooling Pump,480V Load Shed no Will start on reset if selected as Standby Not addressed in the EOPs A ste;, wit! be added to the applicable Pump and if 86/G1 and 86/GT1 are reset proredures to take the applicable control swiI:h to pu!!out prior to ESF Reset.

VD-7A Vacuum Priming Pump,480V Load no Will start if selected as the pump in service Not addressed in the EOPs A step will be added to the applicable Shed procedures to take the applicable mntrol switch to pullout prior to ESF Reset.

WD-28A Waste Gas Cu upw ,480V Load no Start on high pressure,480V ESF Load Not addressed in the EOPs No corrective action required *

' WD-28B Shed Shed & MCC-3A3 or 4B3 breaker reset The manual reset of MCC-3A3 and MCC-4B3 following SIAS load shed meet the criteria of bulletin 80-06.

WD-41A AUX Bldg. Sump Pump Area 23 Yes - should O!-WDL-1 -one pump selected as the lead not eddressed in the EOPs A note will be added to the applicable WD-41B have been pump. Pump will start if high level present procedures to describe the reset action.

reported VA-52A DG-1 Room HVAC Fan Yas- Fan could restart after reset of OPLS. none N mn ve ah reqdred.

Modification Subsequent modification MR-FC-90-63 OPLS Load Shed installed interlocked fan to DG controls. OPLS 4/N80, reset has no effect now.

response date 6/5/30 VA-46A Control Room HVAC, Specifically unknown No effect, remgnized in DBD .

none No corrective action required

• VA-46B concems the filtered air makeup. system remnstitution effort. Reported to the NRC includes VA-63A&B, and VA-64A&B completely in LIC-94-0192. Corrected in MR-FC- FC-VIAS Starts replaced 94-020 YCV-1045 FW-10 Steam Supply Valves no: system None,if AFW is required. The Auto none A note will be added to the applicable started from the ESF Load installed after initiation of AFW will start the pump by procedures to describe the resei accon.

Sequencers IEB 80-06 opening the valve. The circuit is a seat in Subm.bl circuit, AFW reset will not stop the pump.

LIC-97-027 Attachment 2 -

Page 9 Tabie 2 Compliance with IEB 80-06, Review of ESF Equipment not Considered la the Original Response Component Description and ESF Action Condition Effect of ESF Reset EOP Directed Action Proposed Correctwe -

Tag Number Existed at the Action time of the IEB 8046 Submittal AC-10A Raw Water Pump Yes if the sequencer Lockout relays are reset EOP floating steps riirect that the OPLS No correchve action required

• AC-10B Raw Water Pump before the OPLS lockout relays 86A/OPLS Lockout relays be reset first. No trip will AC-10C Raw Water Pump and 8EB/OPLS, the pumps will trip. occur.

AC-100 Raw Water Pump St-1A LPSIPump Si-1B LPSIPump FW-6 AFW Pump t 6

i

- - __ mm m_._______.-__ _ _ _ _ _ _ _ _ . _ _ _ _ _