ML20147C003

Discusses Possible Dangers of LOCA in Containment Purging During Normal Plant Oper.Requests Either Commitment to Limit Purging or Justification for Continuing.W/Encl ANO 7812080207

ML20147C003
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	11/28/1978
From:	Schwencer A Office of Nuclear Reactor Regulation
To:	Reed C COMMONWEALTH EDISON CO.
References
NUDOCS 7812180116
Download: ML20147C003 (6)

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'% # November 28, 1978 Docket Nos. 50-295 and 50-304 Commonwealth Edison Company l ATTN: Mr. Cordell Reed Assistant Vice President Post Office Bcx 767 Chicago, Illinois 60690 Gentlemen:

RE: CONTAINMENT PURGING DURING NORMAL PLANT OPERATION A number of events have occurred over the past several years which j directly relate to the practice of containment purging during normal i plant operation. During recent months, two specific events have occurred which have raised several questions relative to potential failures of automatic isolation of the large diameter purge pene-trations which are used during power operation. On July 26, 1978, the Northeast Nuclear Energy Company reported to the NRC such an event at Millstone Unit No. 2, a pressurized water reactor located in New London County, Connecticut. On September 8, 1978, the Public Service Electric and Gas Company reported a similar event at Salem Unit No. 1, a pressurized water reactor located in Salem County, New Jersey.

During a review of operating procedures on July 25, 1978, the licensee discovered that since May 1, 1978, intermittent containment purge operations had been conducted at Millstone Unit No. 2 with the safety actuation isolation signals to both inlet and outlet redundant containment isolation valves (48 inch butterfly valves) in the purge inlet and outlet penetrations manually overridden and inoperable.

The isolation signals which are required to automatically close the purge valves for containment integrity were manually overridden to allow purging of containment with a high radiation signal present.

The manual override circuitry designed by the plant's architect / engineer defeated the high radiation signal and all other isolation signals to these valves. To manually override a safety actuation signal, the operator cycles the valve control switch to the closed position and then to the open position. This action energized a relay which blocked the safety signal and allowed manual operation independent of any safety actuation signal. This circuitry was designed to permit reopening these valves after an accident to allow manual operation of certain safety equipment.

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2 On September 8, 1978, the staff was advised that, as a matter of routine, Salem Unit No. 1 has been venting the containment through the containment ventilation system valves to reduce pressure.

In certain instances this venting has occurred with the containment high particulate radiation monitor isolation signal to the purge and pressure-vacuum relief valves overridden. Override of the containment isolation signal was accomplished by resetting the train A and B reset buttons. Under these circumstances, six valves in the containment vent and purge systems could be opened with a high particulate isolation signal present. This override was performed after verifying that the actual containment particulate levels were acceptable for venting. The licensee, after further investigation of this practice, determined that the reset of the particulate alarm also bypasses the containment isolation signal to the purge valves and that the purge valves would not have auto-matically closed in the event of an emergency core cooling system (ECCS) safety injection signal.

These events and information gained from recent licensing actions have raised several concerns relative to potential failures affecting the purge penetration valves which could lead to a degradation in containment integrity and, for PWR's a degradation in ECCS pe rf ormance. Should a loss-of-coolant accident (LOCA) occur during purging there could be insufficient containment backpressure to assure proper operation of the ECCS. As the practice of containment purging during normal operation has become more prevalent in recent years, we nave required that applicants for construction permits or operating licenses provide test results or analyses to demonstrate the capability of the purge isolation valves to close against the dynamic forces of a design basis LOCA. Some licensees have Technical Specifications which prcnibit purging during plant operation pending demonstration of isolation valve operability.

In light of the above, we request that you provide within 30 days of receipt of this letter your commitment to cease all containment purge during operation (hot shutdown, hot standby, startup and power operation) or a justification for continuing purging at your facili:ies. Specifically, provide the following information:

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(1) Propose an amendment to the plant Technical Specifications based upon the enclosed model Technical Specification, or (2) If you plan to justify limited purging, you must propose a Technical Specification change limiting purging during operation to 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> per year as described in the enclosed Standard Review Plan Section 6.2.4, Revision 1. Your justification must include a demonstration (by test or by test and analysis similar to that required by Standard Review Plan 3.9.3) of the ability of the containment isolation valves to close under postulated design basis accident conditions. Within thirty i days of receipt of this letter, you are requested to provide a schedule for completion of your evaluation justifying continuation of limited purging during power operation.

(3) If you plan to justify unlimited purging you need not propose a Technical Specification change at this time. You must, however, provide the basis for purging and a schedule for responding to the issues relating to purging during normal operation as described in the enclosed Standard Review Plan Section 6.2.4, Revision 1, and the associated Branch Technical Position CSB 6-4. As discussed in these documents, purging ouring normal operation may be permitted if the purge isolation valves are capable of closing against the dynamic forces of a design basis loss-of-coolant accident. Also, basis for unlimited purging must include an evaluation of the impact of purging during operation on ECCS performance, an evaluation of the radiological consequences of any design basis accident requiring containment isolation occurring during purge operations, and an evaluation of containment purge and isoiation instrumentation and control circuit designs. Within thirty days of receipt of this letter, you are requested to provide a schedule for completion of your evaluation justifying continuation of unlimited purging during power operation. ,

i Pending completion of the NRC staff review of the justification for continued purging in (2) or (3) above, you should commit to either cease purging or limit purging to an absolute minimum, not to exceed 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> per year.

The staff believes that both the Millstone and Salem events resulted from lack.of proper management control, procedural inadequacies, ,

and possible design deficiencies. While the containment atmosphere was properly sampled and the purging (venting) discharges at both f acilities were within regulatory requirements, the existing plant operating procedures approved by the licensee's management did not adequately address the operability of the purge valves and the need for strict limitations on (or prohibition of) overriding a safety actuation closure signal. The requirements for valve operability were not discussed and the related Technical Specifi-cations were not referenced in the procedures. Design deficiencies probably contributed to the events as the safety actuation bypass condition is not annunciated nor is a direct manual reset of the safety actuation signal available. Consequently, we have developed i the position specified below to assure that the design and use 1 of all override circuitry in your plant is such that your plant .

will have the protection needed during postulated accident conditions. l Whether or not you plan to justify purging, you should review the design of all safety actuation signal circuits which incorporate a manual override feature to ensure that overriding of one safety actuation signal does not also cause the bypass of any other safety actuation signal, that sufficient physical features are provided to facilitate adequate administrative controls, and that the use of each such manual override is annunciated at the system level for every system impacted. Within thirty days of receipt of this letter, you are requested to provide (1) the results of your review of override circuitry and (2) a schedule for the development of any design or procedural changes imposed or planned tc assure correction of any non-conforming circuits. Until you have reviewed circuitry to the extent necessary to verify that operation of a bypass will affect no safety functions other than those analyzed and discussed on your dockets, do not bypass that signal. Our Office of Inspection and Enforcement will verify that

you have inaugurated administrative controls to prevent improper nanual defeat of safety actuation signals as a part of its regular inspecti 9n program.

Sincerely, i Original Signed By i

A. Schwencer, Chief Operating Reactors Branch #1

, Division of Operating Reactors i-

Enclosures:

1. Model Technical Specification

2. Standard Review Plan

3. Branch Technical Position CSB 6-4 cc: w/ enclosures See next page DISTRIBUTION Docket File NRC PDR Local PDR ORB 1 Rdg A. Schwencer C. Parrish Project Manager l

M. Mlynczak W. Russell I&E (3)

D. Eisenhut OELD B. Grimes ,

TERA ,

J. Buchanan '

ACRS (16)

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Commonweal th Edison Company cc: Robert J. Vollen, Esquire 109 North Dearborn Street Chicago, Illinois 60602 Dr. C9 cil Lue-Hing Director of Research & Development Metropolitan Sanitary Di strict of Greater Chicago 100 East Erie Street Chicago, Illinois 60611 Zion-Benton Public Eibrary District 2600 Emmans Avenue Zion, Illinois 60099 Mr. John W. Rowe Isham, Lincoln & Beale Counselors at Law One First National Plaza, 42nd Floor ,

I Chicago, Illinois 60603

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