ML20213C835

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Forwards First Round Questions as Result of FSAR Amend 1 Review.Finds That 70% of Questions Have Been Resolved Before But Have to Be Addressed Again Because Applicant Failed to Bring SAR Up to Date
ML20213C835
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 12/20/1978
From: Satterfield R
Office of Nuclear Reactor Regulation
To: Varga S
Office of Nuclear Reactor Regulation
References
CON-WNP-0250, CON-WNP-250 NUDOCS 7901080224
Download: ML20213C835 (13)


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NRR READIt'G FILE DEC 2 0 Ir3 ICSB READING FILE DOCKET FILE.

HEMORANDtR1 FOR:

S. Varga, Chief, Light Water Reactors Branch No. 4, DPil FROM:

R. M. Satterfieldl,Ghief. Instrumentation and Control

.Systems Branch, DSS SUNECT:

WASHINGTON PUBLIC POWER SUPPLY SYSTEM NUCLEAR PROJECT 2, FIRST ROUND QUESTIONS Plant Nare:

Washington Public Power Supply System Nuclear Project 2 Docket Number:

50-397 Licer. sing Stage:

OL Milestone Humber:

22-05 Responsible Branch:

LMt-4 and Project Leader:

M. Lynch Requested Completien Dato:

December 1,1973 Review Status:

Complete The enclosed questions are the result of our review of the FSAR through

/candment 1.

Many cf the issues addressed by these questions and those generated during our acceptance review are not new. They are the same issues which were resolved during our reviews of previous BWR plants.

The WPPS-2 reviewer estimates that approximately 70% of the ICSS questions asked thus far fall into this category. He are forced to deal with these issues again becAuse little has been done by the applicant to update his SAR to ensure consistency with recently approved SARs.

In my view, this is a waste of valuable resources.

It is r.y hope that we can prevent docketing of future applications similar to HPPS-2. For WPPS-2, I encourage DPM to impress on the applicant the need to bring their applica-tion up to date. The ICSS review schedule for WPPS-2 does not allow time for that effort.

If we must continue to ask numerous questions which were l

pursued on presious applications, I see little chance that we will be able to produce an SER on schedule.

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AL sicygg yy M.SATTggpggLD R. M. Satterfield, Chief y

Instrumentation and Control Systems i

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Branch, DSS 7-a3f

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Enclosure:

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S. Hanauer R. Mattson R. Boyd M. Lynch Di.Ross F. Rosa Rt Satterfield M. Srinivasan A

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kAShihGTod PUSLIC PO5ER SUPPLY SYSIca NUCLhAn PF0 JECT 2 FIEST EOUND QUESTIONS 031.080 The ESAB still contains vany conflicting or

( 1. 2.1.1) conr using statements-which must be resolved inorder (3.1 C) for the review to proceed. For each of the (3.11) questAons below, pro vide a FS AE revision which

( 3.11. 2.3) is responsive to the staff's need for inf ormation (4. 4. 3.3) satisf ying the requirements of the " Standard

( 6. 2. 4.1)

Fornat and Content of Safety Analysis Reports for (6.2.4.2)

Nuclear Power Plants".

(6.2.4.3)

(6. 7.1. 2 )

(1) Clarif y the discrepancy between the definition of (7.1. 2. 6) passive failures in electrical, instrumentation,

( 7. 2.1.1) and control systems in FSAE Sections 1. 2.1.1.1.1. 2. L (7. 3.1. 2) an d 3.11. 2. 3, 6. 2. 4.1.1, and 6.7.1.2.c.

(4.6.1.4)

(7.6.1. 7 )

(2) Clarify the discrepancy between the response

( 7. 6.1. E) to Question 031. 001 (b) and FSA B Figures 7.2-1b (7.6.2. 8) an d 7.2-1 c.

( 8. 2.1)

(8.3.1)

(3) Amend FSAE Section 4.4.3.3.3 to provide (E

1. 2-5) the actual values of the measured parameter (F 5.4-Sa) which are to be used in WPPS 2.

(F 7.2-1b)

(F 7.2-1c)

(4) Clarify the discrepancy between the 25%

(F 7.4-la) pump speed interlock value described in (F 7.7-7c)

FSAR Sec tica 4.4.3.3.3.1 and the 20% value

( F E07E1 E0TC) which is given in FSAE Figure 7.7-7c.

(C C31.0 01)

(T 3.11-1)

(5) Iescribe the primary and secondary modes of (T 6.3-2) operation of the isolation valves which is (T 7.1-2) referenced in ISAB Section 6.2.4.2.

(T 7.2-1)

(T 7.3-1)

(6) Clarify the discrepancy between the (T 7.3-2) description of the solenoid valves in (T 7.3-3)

FSAB Section 6. 2. 4.2 and the design which (T 7.3-4) is presented in your response to guestion (T 7.3-5)

' 031. 001 (h).

(7) Clarify the discrepancy between the isolation valve arangement which is described in FSAR 3

Section 6. 2. 4. 3. 2.1. 2.1 and that which is

cejgg-shown in FS AR Figures 5.4-9a and 7.4-la.

(8) In order for the staff to be able to continue our review, provide a cross-reference between GE diagram numbers (III-XXX X) which are used in the FS AR diagrams and included in the list of references on these diagrams and the WPPS-2 figures.

(9) Clarify the reference to FS AR Figure 1.2-5 which is contained in FSAR Section 7.2.1.1.4.2. e by specifying the exact physical loca tion and arrangement of the turbine governor oil line pressure switches and their sensing lin es.

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. 031.C80 (10) Cuantif y the delay time bef ore the reactor node switch scram is automatically bypassed in F S AR Sectica 7.2.1.1.4.4.5.

(11) C1'arify the discrepancy between note 1 of FS AR Table 7.1-2 and line 3 of Table 7.2-1 (f uel zone water level).

(12) Clarify the discrepancy between the response to Question 031.001(s) and the content of drawing 807E180TC Sheets 1 th ru 9.

(13) Clarify the ref erence, in FSAR Section 7.3.1.2.7, to FSAR Sections 8. 2.1 and

8. 3.1. This clarification should clearly state the range of voltage and f regnency for which all Class 1E instrumentation and control equipment is gualified and the range of voltage and frequency to which it will be exposed in your plant.

(14) Clarify the divisional assignments which are nade for the RPS motor genera tor sets in F S AR Section 7.6.1.4.2. Specifically, justify the designation of these busses as "c ri tical".

(15) Clarify the discrepancy between FS AR Figure 5.2-6 and FSAR Tables 7.2-1, 7.3-1, 7.3-2,

7. 3 -3, 7.3-4 and 7.3-5 with regard to the low level set point and range.

(16) Clarify the discrepancies between the Amendment 1 revision of FSAB Table 6.3-2 and other submittals of information in the FSAR such as FSAR Table 7.3-3 for the spray valve differential-pressure.

(17) Clarify the discrepancy between FSAR Section 7.6.1.8.1.2 and FSAR Table 7.1-2.

(18) Clarify the reference to four RPS divisions in FSAR Section 7. 6.1. 8. 3. 2.

l (19) Clarify the discrepancy between the conten t of FSAR Section 3.11 and 7.6.2.8.2.1.1.4.

l l

(2' ) Clarify the discrepancy between FSAR Chapter 0

l 3.10 and Section 7.6.2.8.2.1.5.

l (21) Clarify the references to Table 3.11-1 for the l

Eeactor and Control Building environments in l

FSAR Section 7.6.1.7.8.

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-3 031.081 Identify each type of relay in the WFPS-2 which (3.10) must he energized or which must remain energized (3.11) during a seismic e vent. For each of these relay types, provide the following information:

(1) Th,e minimum voltage at which it must operate, (2) The voltage at which it was seismically qualified, (3) The nornal operating voltage, and (4) The locations and f unctions of this type of relay.

Ehere a particular relay was not qualified by test or was not tested in both the energized and de-energized state, justif y the seismic qualification of the relay.

031.082 Justify the content of FS AR Section 7.6.2.3.2.1 (7. 6. 2. 3) in teras of the requirements of General Design criteria 1,2,3,4, 13, 14, 16, 19, 23, an d 55.

031. C83 (ESP) The response to Question 031.006 and FSAR (3.11.3 )

Appendix 3.11A do not satisfy the staff's (3.11 A) need f or additional inf ormation on eq uipment (Q C31. 0 06) q u alification. In order to ensure tha t your environmental (Q031. 0 56) gualifica tion program conf orms with General Design (Q O31. 057)

Criteria 1, 2, 4 and 23 of Appendix A and Sections (QO31.059)

III and II of Appendix B to 10 CFR Parts 0, and to the national standards mentioned in Part II " Acceptance' Criteria" (which includes IEEE S td 323) contained in Standard Review Plan Section 3.11, provide an amended response to Cuestion 031.006 for the f ollowing:

(1) logic equipment for SBGTS (QO31. 006 item 4)

(2) Se nsors:

(a) Rod Block Monitor flow transmitte rs (b) Main Steamline Tunnel Temperature Thermocouple (c) B 22-N 0 24 A (3) All items listed in Questions 031.056 and 031.059.

031.084 The staff notes that the specification req uirements (T3.11 A-1) of FSAR 2able 3.11A-1 are incomplete in that they do not address the maximum and minimum values of all of the parameters which are cited in Section 3(7) of IIEE Std 279-1971. Please amend the PSAR to provide the cited data f or all Class 1E components.

031.085 The staff notes that several systems (e. g.

17.6.1. 4)

Safe ty/ Relief Valve Discharge Line. Temperature

( 7. 7.1.1)

Monitoring and Reactor Vessel Head Leak Detection) are listed in both Sections 7.6 and 7.7 of the FSAR. Provide a general revision of the FSAR to eliminate such ambiguous design descriptions.

_4 031.086 The standby liquid control system (SLCS) is

( 9. 3.5. 3) designated as a special safety system in the (7.4.1. 2)

WPPS-2 design. To assure the availability of the SICS, you have provided two sets of the compenents required to actuate the system in parallel red undancy. However, our review indicates that you have not provided redundant heating systems and the heating equipment supply emergency bus is not identified nor r ed und an t.

The staff has concluded, therefore, that the statement in FSAS Section 9.3.5.3 that "a single failure will not prevent system operation" is not true. Prov ' de a modified design of the SLCS which satisfies the single f ailure criterion or j ustify the presen t design.

031.087 With regard to FSAE Section 3.11.2.3, please provide

( 3.1 1. 2. 3) the following additional information an c clarifications:

(1) Frovide a copy of the procedures for the following aging simulations:

(a) Thernal, (h) Radiation, (c) Operation, and (d) Seismic.

(2) Justify the aging temperature which was used in terms of the maximum normal environmental conditions which are listed in FS AR Table 3.11-1.

(3) Cuan tify the thermal aging acceleration rate and provide the technical basis for this rate.

(4) Cuantify the aging time used for each plant location listed in FSAR Table 3.11-1 which contains a valve which has been qualified in accordance with IEEE S td 382-1972.

Identify the valves which are so qualified.

(5) Provide information similar to that requested in Parts 2 thru 4 above for radiation aging and, in addition, describe how the neutron fluences were accounted f or.

l (6) Frovide the criteria f or determining the limits j

of an actuator family including:

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(a) Definition of the limits of an actua tor

family, (b) The criteria which were used to assure that the sample valve operator is a valid i

representative of the f amily, an d t

(c) A demonstraticn of how the criteria were applied.

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, 031.087 (7) Frovide a Table of the following infornation f or all class 1E valve actuators in the WFPS-2 design:

(a) The equipment specifica tions as per Section 3 of IEEE Std 382-1972, (tI) Identification of the f amily membership, (c) Identification of the samples, (8) Quantify the number of operating cycles each test specimen was subjected to.

(9) Specify the frequency range which was used in the seisnic gualification and aging of the samples.

(Note that the range which is permitted by IEEE Std 382-1972 does not agree with Branch Technical Position ElCSB 10 which is presented in Appendiz 7 A to the Standard Beview Plan.)

(10) Describe the methods which are used to assure that equipnent which is not qualified for all service conditions will nct spuriously operate d uring exposure to service conditions (including excessive exposure times) f cr which the equipment is not required to function to mitigate the effects of accidents on other events.

031.088 Clarify the discrepancies between the following (6.2.4.3)

Sections and Figures of the FSAR with rega rd to (7. 6.1. 4) isolation of Beactor Water Cleanup System upon

( 7. 7.1. E)

Standby Liguid Centrol System initiation:

19.3.5.2)

(P 7.3-11a)

(1) Sections 6.2.4.3.2.1.1.7, 7.7.1.8, 7.6.1.4.3.6, (F 7.7-14) an d 9. 3. 5. 2

( T 7.3-13)

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(2) Figures 7.3-11a, 7.4-3, and 7.7-14 (3) Table 7.3-13 031.089 The single failure analysis presented in FSAR l

(1.7)

Section 6. 7. 3.1 is inadequate. Revise Section.6. 7.3.1 l

( 6. 7. 3.1) to include single f ailures of electrical compcnents such as the spurious closing of relay contacts on K4. (See GE Dwg 851E708TD.)

Also, please provide the electrical schematic and one line drawings of this system f or our review.

031.090 Contrary to the statement in FSAR Section 7. 2.1.1.2,

( 7. 2.1.1) the staff has noted that the HPS motor generator (F 7.2-l a) sets are not Class 1E. Therefore, please:

(Q O 31. 032)

(1) Clarify the discrepancy between FSAR Sections

7. 2.1.1.1 and 7. 2.1.1. 2 with reg ard to the qualification of the motor genera tor sets.

' 031.090 (2) Describe how the design and implementa tion of the WPPS-2 EPS satisfies the requirements of IEEE Std 379 -1972 Section 6.6 (with special emphasis on the last paragraph).

031.091 The st'aff believes that inadequate physical

( E 7. 2-9) separation may have been provided in the EPS cabinets because, in similar plants, the wiring from the relay contacts 14A an d 14C (via cabinet penetration Y) and 14E and 14G (via cabinet penetration 2) appears on terminal strip CC. (See GE DWG 807E166TU.)

This wiring is powered from two separate cla ss 1E de buses. Insuf ficient physical separation is provided between these buses on CC, the associated cables, and in penetrations I and 2, which also serve the plant process computer system. Provide a modified design f or the routing of Class 1E circuits inside of the RPS cabinets or provide suitable viring diagrams to show that this concern is not applicable to yo ur plant.

031.092 The staff believes tnat the physical separation (F7.2-9) provided in the design of the RPS cabinets may not satisfy the req uirements of IEEE Std 279-1971 or the WPPS-2 separation criteria and is, therefore, unacceptable. As an example, it has been noted on similar plants that the cabinet lighting circuit (which is not trea ted as an associated circuit) crosses cabinet penetration 187 in RPS cabinet A and (as a result) becomes associated with the containment isolation system wiring going to 187..

The staff requires the following corrective action:

( 1) Provide a modified design for the routing of non-Class 1E circuits in RPS cabinet A which satisfies the separation criteria.

( 2) Review the design of all other Class 1E cabinets for similar defects and provide the staf f with a listing of the cabinets which were reviewed.

(3) Advise the staff of your findings and plans for suitable modifications which are necessary to satisfy the separation criteria.

(4) Identify and justify all exceptions to items

( 1), (2), or (3) above.

n

. 031.092 (ESP) (5) Frovide panel layout drawings and one line diagrams which show the routing and physical sepa ra tion betwe,en the reactor trip sensors ah d:

(M The high level cut offs for the HPCS a nd BCIC, and (b) Ihe post accident reactor vessel level in dication system.

031.093 Provide the design criteria and a description of

( 7. 2.1.1) the scram discharge volume switches and their (7. 2.2. 2) qualification testing in accordance with the requirements of Section 7.2 of the Standard Format.

Include the following information:

(1) Ean uf act urer

( 2) Type of float (self equilizing or sealed)

(3) Float material and magnet material (4) Qualification Test Conditions (a) Eater temperature (b) Fress ure (c) Duration of test conditions (d) Number of test cycles (e) Period between test cycles (I) Extremes df external temperature, pressure, and h umidity (g) Badiation source, strength, and dose.

031.094 The response to Cuestion 031.033 is incomplete.

( 7. 2. 2.1)

Arend FS AB Sections 7.2. 2.1. 2.1.5, 7.3. 2.1. 2.1. 6. 2, (7.3.2.1) and 7.3.2.2.2.1.5.1.2, the response to Question (7. 3. 2. 2) 031.033, and all other similar locations in the (0031.033)

FSAE to describe the provisions which are made in your design for satisf ying Position C.4 of Regulatory l

Guide 1.47. (Please note tha t Posi tion C. 4 is no t intended to address the testing of annunciators, but l

is intended to provide manual initiation of system level in dication of inoperable and bypassed i

status.)

031.095 The disc ussion of ho w the instrumentation (7.3.2) and controls satisfy IEEE std 279-1971 Sec tion 4.1 is inadeguate. Quantif y the bus voltage relay pick-up and drop-out values.

l 031.096 Justify the design practice of indica ting a loss l

(7.3. 2.1) of pcwer to motor starters by de-energizing indicating lanps. Include in the justification a l

discussion of how an operator can distir',..ish between a failed lamp and system bypass. Also demonstrate that the loss of these in dicating l

lights is not a violation of IEEE S td 279-1971 Section 4. 20 with regard to timely and l

unambiguous information, i

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0 31.097 (RSP)

The response to Question 031.026 is unacceptable.

( C C31. 026)

It is the staff's position that isola tion devices which are used to provide electrical independence between class 1E and ncn-Class 1E egaipmen t must te designed, qualified, and implemented in accoraance with all of the requirements f or Class 1E equipment and are an integral part of the system which th.ey are intended to protect. Therefore, provide an amended response to the staf f 's q uection and include all of the information which the staff has previously requested.

031.098 (ES P) It is the staff's position that the use of (7.6) the Eod Worth Minimizer is unacceptable for the protection of the public nealth and safety because it does not satisfy the requirements of IEEE Std 279-1971. Therefore, amend the FSAR by deleting this system from Section 7.6.

031.099 The response to Cuestion 031. 03 0 (c) and FSAR

( 3. 4)

Section 7.3.1.2.8.1 are incomple te. P ro vide (7.3.1. 2) a revised response to Question 031. 0 30 (c)

( Q C31. 0 30) which addresses the protection of Class 1E equi pmen t from internal flooding. (e. g.

Failure of the main condenser cooling line or fire protection system) 031.100 (ESP) It is the staff's position that the analyses of (7.3.2.1) conpliance with the requirements of IEEE Std

( 7. 3. 2. 2) 279-1971 (which is presented in FSAR Sections (Q 031. 081) 7.3.2.1.2.3.1 ma d 7. 3. 2. 2. 2. 3.1.1) are too general (0031.084) in content to satisf y the inf ormation needs of (0031.091) the staff. The staff's needs in this regard are (QO31.092) presented in Section 7. 3.2 of the Standard Format.

Specific exanples of areas where additional information is required to enable us to complete our review are presented in Questions 031.081, 031.084, 031.091, and 031.09 2. Therefore, please provide an amended FSAB which contains j

more specific analyses of how the General i

Electric design has been implemented in HPPS 2.

(Please note that references to the FSAR Sections which contain the necessary informa tion are acceptable in lieu of repeating this information in Section 7.3.2.1.2.3.1.)

031.101 lden tify the equipment which has been environmentally l

(7. 3. 2. 2) qualified by previous operating experience and, for l

each item, provide the basis for the extrapolation in accordance with the requirements of IEEE Std 323-1971.

i 031.102 Amend FSAE Section 7.3 to describe the methods which l

(7. 3. 2.1) will be used to provide for emergency operation of l

locked emergency switches and valves.

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031.103 The descriptica of the area temperature monitoring (7.3 )

system in FSAE Sections 7.3 and 7. 6 is insuf ficient.

(7.6)

Therefore, provide t'ae following additional (F7.6-5) infctmation:

(1) Identify the interfaces betkeen the Class 1E and non-Class 1E parts of this system.

(2) tescribe how redundant components are electrically isolated and physically separated.

(3) Describe how the electric isolation devices were qualified and quantify tne limits of this gualification in terms of voltages and currents.

(4) Irovide the schematics for the Class 1E portions of this system, including the isolation devices.

(5) Frovide the bases and methods which were used to select the test samples to satisfy the criteria identified in response to (3) a bo ve.

031.104 The description of the control room and the

( 7. 5)

Figures of FS AR Section 7.5 are ins uf ficient (Q C31. 034) to support the response to Question 031.034.

Therefore, please amend the FSAR to include a layout drawing of the control room. This drawing should be of sufficient detail to clearly show-(1) The location and identification of each cabinet and panel, (2) The location and routing of each conduit and cable tray and pan, (3) The location and field of each emergency light, and (4) The loca tion and identification of each indicator and relay centact f or which credit is taken in satis fying the requirements of Sections 4.19 and 4.20 of IEEE Std 279-1971.

031.105 The description of the procedure for reactor shutdown

( 7. 4.1. 4) from outside the control room is inadequate. Provide (Q C31. 048) the following additional information:

(1) Erovide plant layout sketches which show where the switches are located.

.(2) rescribe the method which will be used to seal the transf er switches.

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, 031.105 (3) Descrite the consequences of an inadvertent actuation of one cr more of the switches.

(4) Identify and justify each transf er switch shich is not kired to the bypassed and inoperable status indication system.

(5) Iescribe the methods and indications available outside of the control room by which the operator can:

(a) verify relief valve operation, (b) determine reactor pressure, temperature, and le vel, (c) determine suppression pool level and tenperature, (d) determine containment pressure, an d (e) determine service water flow and tempe ra ture through the RHR heat exchangers.

G31.106 Confirm that the Primary Containment Atmosphere (7. 6.1.13)

Monitoring System (including sensors) will be seismically a nd environmentally gualified.

Identify and justify all exceptions. Also describe the methods which were used to seisaically qualify the dryvell hydrogen and oxygen monitoring system.. Include the limits of

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acceleration for which the system is qualified and identify the limiting component.

031.107 FSAR Section 7.6.2.13.3.5.19 indicates that the (7. 6. 2.13) post 10CA containment monitors are in continuous operation. This appears to be a change from previous BWR designs in which the hydrogen and oxygen subsystem sas activated by an accident signal.

Please clarify this aspect of your design.

031.108 FSAE Figures 5.5-2, 7.7-7, and'7.7-8 and Sections (3.11) 3.11, 4.4.3.3, 5.4.1, 7.6.1.8 and 7.6.2.8 contain many

( 4. 4. 3. 3) discrepancies and are theref ore unacceptable. Provide a (5.4.1) consistent set of drawings and other informa tion which (7. 6.1. 8) represent the design of the Reactor Recirculation System I

( 7. 6.2. E) for the WPPS-2. The response should, as a minimum:

(F S.5-2 )

( F 7. 7-7)

(1) Frovide setpoint inf ormation (range, accuracy of (F7.7-8) instrument and setpoint) for t he following:

( F 8.1-9 d)

(a) Low total feedwater permissive (H 13-P63 4),

l (b) Steam line recirc ulation pump dif f erential-temperature (K634),

(c) C001A rated speed permissive for CB3A Trip 2, (d) Pump speed greater than 15% but less than 40 %,

(e) C001 A less than rated voltage permissive.for closing CE2A, (f) Generator protective trip voltage, and (g) Beactor power permissive for low speed start.

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. 031.108 (2) Identify the control option of Note 7 in Figure 7.7-8 which applies to the WPPS-2 design.

(3) Identify the inputs which are received from Reference 4 to Figure 7.7-7, provide this reference, and clarify the f unction of these trips and the ATWS trips shown on Sheet f of figure 7.7-7.

(4) Clarify the discrepancy between the ATWS trips show n in Fig ure 7.7-7 and the logic description given in FS AR Section 7. 6.1. 8.1.

(5) Indicate the signal source for the " permissive when low speed auto start seguence is not activated."

(6) Ladicate the signal source for the " transfer to high speed initiated" auxiliary device.

(7) Clarify the breaker numbering scher.e used in figures 7.7-7 and 7.7-8.

( 8) Iescribe the initiating circuitry for and the location of the hydraulic line containnent isolation valves.

(9) Clarify the discrepancy between the setpoint stated in FS AB Sections 4. 4. 3. 3. 3.a and 5. 4.1. 3.

(10) Justify not environmentally qualifying the 6.9 KV switchgear.

(11) Clarify the reference to FS AR Section 7. 2.1.1. 4. 2 fo r a listing of setpoints and 7.2-1 for a listing of minimum performance requirements for the trip functions which are specified in Part 1 abo ve.

031.109 Provide the results of a failure mode and effects

( 7.7.1. 2) analysis for the reactor manual control system analyzer, identify the design features which a re pro vided to detec t these f ailures, and describe the test procedures (including test f requency) which will be used to detect these failures.

031.110 The information which is presented in FS AR Sections

( 7. 7.1. 5)

7. 7.1. 5 a nd 15 is insufficient with regard to load (15) follcwing operations. Theref ore, describe the interfaces between the dispatcher and the WPPS-2 control systems (e.g. turbine generator and recirculation flow control systems.)

031.111 The description of the intraplant radio system

( 9. 5. 2. 2) inspection and testing in FSAR Section 9.5.2.2 is inadequate. Describe the preopera tional

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- 031.111 and periodic testing which assures that radio transmissions will not cause spurious operation of relays and, as a result, nega te the pro tective f unction of Class 12 estipment.

031.112 Lescribe how the power and ref ueling in terlock (7. 6.1.1 )

circuits are separated on the ref ueling crane.

( 7. 6. 2.1) 031.113 (ESP) It is the staff's position that the rod (7. 6 )

seguence control system does not satisfy

( 15. 4.1. 2) the requirements of IEEE Std 279-1971 and,-

t h er ef or e, is unacceptable for the prevention of a control rod withdrawal accident.

Provide a rodified design f or your plant.

031.114 (ESP) It is the staff's position that the f ormat (7.6 )

and content of FSAB Sections 7.6 and 7. 7 does

( 7. 7) not provide the information which is needed to enable the sta'f to complete our reviev.

Please provide a general revision to FSAR Sections 7.6 and 7.7 which provides the information and analyses which are specified in Sections 7.6 and 7.7 of Regule tory Guide 1.70.

i 7

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UNITED STATES y*

~ *g NUCl. EAR REGULATORY COMMisslON g

j WASHINGTON, D. C. 20666 a

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DEC 2 0 578 Docket Nos.: 50-358, 50-352/353, 50-367, 50-373/374, 50-387/388, 50-410,50-322,5Qg-jg7 APPLICANT: Members of Mark II Owners Group

SUBJECT:

MEETING WITH MARK II OWNERS GROUP TO DISCUSS THE STAFF'S MARK II CONTAINMENT ACCEPTANCE CRITERIA - NOVEMBER 14, 1978

Background

The staff informed the owners of the lead Mark II facilities in its letter dated September 14, 1978, of the criteria that would be found acceptable for containment evaluation with respect to the pool dynamic loads. A meeting was held on October 19, 1978 with the Mark II owners for the purpose of having them identify those criteria for which they would propose to take exception. At this meeting, the Mark II owners provided the staff with a preliminary description of their proposed approach to resolve our concerns for those areas where they differed with our criteria. Following this meeting the staff provided the Mark II owners with information to clarify the staff's concerns related to the revised methodology for detennining the maximum pool swell height. The primary purpose of the meeting on November 14, 1978 was to discuss the Mark II owners' revised methodology for calculating the maximum pool swell height.

An attendance list, copy of our questions, and meeting handouts are enclosed.

Summary The owners for the lead Mark II plants (Zininer, Shoreham and LaSalle) took exception to a number of the staff's load definition criteria. In this meeting the Mark II owners discussed the basis for two of these exceptions.

These exceptions included the method of detennining the maximum pool swell elevation and the associated wetwell pressure.

The Mark II owners originally specified a maximum pool swell elevation of 1.5 times vent submergence. While this specification was determined to be conservative for most of the tests conducted in the 4-T and EPRI subscale test facilities, we could not agree with the Mark II owners, that this was a conservative specification for all cases. The staff proposed in its criteria, that the maximum pool elevation be determined from the pool swell analytical model, t

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m Mark II Owners Group DEC 2 01978 The Mark II owners, in response to our criteria, proposed an alternative method to calculate the maximum pool swell elevation. This method utilizes the maximum reverse pressure differential on the diaphragm and the corresponding drywell pressure to determine the maximum wetwell pressure.

The maximum pool elevation is then detennined directly from the pool swell analytical model such that the maximum wetwell pressure not be exceeded.

The Mark II owners provided justification for this methodology by comparing the calculated with the observed maximum pool swell and the associated wetwell pressure in the 4T facility.

The staff stated that this new method for calculating pool swell height and wetwell pressure appeared acceptable. However, our final review of this exception to our criteria would be conducted upon receipt of documentation from the Mark II owners, which should include a description and justification for this new methodology, w

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Clifford Anderson, A-8 Task Manager Containment Systems Branch Division of Systems Safety Office of Nuclear Reactor Regulation

Enclosures:

As Stated cc: See attached pages ie

l Mr. Earl A. Borgnann Vice President - Engineering The Cincinnati Gas and Electric Company P. O. Box 960 Cincinnati, Ohio 45201 cc: Troy B. Conner, Jr., Esq.

Mr. J. P. Fenstannaker Conner, Moore & Corber Senior Vice President - Operations 1747 Pennsyania Avenue, N. W.

Columbus and Southern Ohio Washington, D. C.

20006 Electric Company 215 North Front Street Mr. Willima J. Moran Coutubus, Ohio 43215 General Counsel The Cincinnati Gas and Electric David B. Fankhauser, PhD Company 3569 Mine Mile Road P. O. Box 960 Cincinnati, Ohio 45230 Cincinnait, Ohio 45201 Thomas A. Luebbers Esq.

Mr. William G. Porter, Jr.

Cincinnati City Solicitor Porter. Stanley, Arthur Room 214 City Hall and Platt Cincinnati, Ohio 45202 37 West Broad Street Colianbus, Ohio 43215 Mr. Stephen Schumacher Miami Valley Power Project Mr. Peter H. Forster, Vice P. O. Box 252 President Dayton, Ohio 45401 Energy Resources The Dayton Power and Light Ms. Augusta Prince, Chairperson Company 601 Stanley Avenue P. O. Box 1247 Cincinnati, Ohio 45226 Dayton, Ohio 45401 J. Robert Newlin, Counsal The Dayton Power and Light Company P. O. Box 1034 Dayton, Ohio 45401 1

Mr. James D. Flynn Manager, Licensing j

Environmental Affairs l

The Cincinnati Gas and l

Electric Company P. O. Box 960 I

Cincinnati, Ohio 45201 i

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Mr. Norman W. Curtis i

Vice President - Engineering and Construction Pennsylvania Power and Light Company 2 North Ninth Street Allentown, Pennsylvania 18101 cc: Mr. Earle M. Mead Prgject Manager Pennsylvania Power & Light C e ny 2 North Ninth Street Allentown, Pennsylvania 18101 Jay Silberg, Esq.

Shaw, Pittman, Potts &

Trowbridge 1800 M Street, N. W.

Washington, D. C.

20036 Mr. William E. Barberich.

Nuclear Licensing Group Supervisor Pennsylvania Power & Light Company 2 North Minth Street Allentown, Pennsylvania 18101 Edward M. Nagel, Esquire General Counssi and Secretary Pennsylvania Power & Light Company 2 North Ninth Street Allentown, Pennsylvania 18101 1

Bryan Snapp, Esq.

l Pennsylvania Power & Light Company l

901 Hamilton Street Allentown, Pennsylvania 18101 i

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Mr. Byron Lee, Jr.

Vice President Cosmonwealth Edison Company P. O. Box 767 Chicago, Illinois 60690 cc: Richard E. Powell Esq.

Isham, Lincoln & Beale One First National Plaza 2400 Chicago, Illinois 60670 4

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Niagara Mohawk Power Corporation ces:

Arvin E. Upton, Esq.

Niagara 2 hawk Power Corporation Le80euf, Lane, Letby & MacRae ATIN: Mr. Gerald K. Rhode, Vice President 1757 N Street, N. W.

System Project Management Washington, D. C.

20036 300 Erie Boulevard West-Syracuse, New York 13202 Anthony Z. Roissan. Esq.

Natural Resources Defense Council 917 15th Street, N. W.

Washington, D. C.

20005 Nr. Richard Goldsmith Syracuse 'Jniversity College of Law E. I. neitta Hall Campus Syracuse, New York 13210 T. K. De8oer, Director Technological Development Programs New York State Energy Office Swan Street Building Core 1 - 2nd Floor Empire State Plaza Albany, New York 12223 e

Mortoern Irdiana Public Service Company ocs:

Meredith Hemsmin, Jr. Emi.

Northern Indiana Ptblic Service Company Assistant General Counsel ATIN: Mr. H. P. Lyle, Vice President Sethlehem Steel Corporation Electric Production 4 Engineering 701 East unird Street 5265 Hohman Avenue methlenen, Pennsylvania 18016 Hammond, indi=na 46325 NiMiam M. Eichhorn, Esq.

Eidnhorn, Morrow & Eichhorn 5243 nahman Avenue Bammond, Irdiana 46320 masard W. Osann, Jr., Esq.

Wolfe, Bustard, Leydid, Voit & Osann, Ltd.

Suite 4600 One IM Plaza Chicago, IH inois ou611 Robert J. Vallen, Esq.

109 North Dearcorn Street Chicago, IHinois 60602 i

porter County, Isaak Walton League of Amorica, Inc.

I tas 438 chesterton, IHinois 46304 Michael I. Swygert, Esq.

25 East Jacks m aculevard Chicago, IUinois 60604 Richard L. acchins, Est.

Lane Mirmigen ?eneration 53 West Jackson Soulevau.

Chicago, Illinois 60604 Naarice Ameirad, Esq.

Lowenstein, Heenan, amis & Amelrad 1025 Cormecticut Avenue, W. W.

Nashington, D. C. 2u036 James d. Caban, Est.

Rassell Eggert, Esq.

Office of the A Gwir.vi General 188 mandolph Street Chicago, IH inois 60602 r.--_..

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Long Island Lighting Company ccs:

FA<ard M. Barrett, Esq.

kmg Island Lighting Capany General Comsel ATIN: Mr. Andrew W. Wofford Vice President Lang Island Lighting Capany 175 East Old Comtry Road 250 Old Cotstry Road MLneola, New York 11501 Hicksville, New York 11801 Edward J. Walsh, Esq.

General Attomey long* Island Lighting Company 250 Old Comtry Road Mineola, New York 11501 J. P. %m w Project Manager Shoreham Nuclear Power Station P. O. Box 618 Wading River, New York 11792 Jeffrey Cohen, Esq.

Deputy Caenissioner and Consel New York State Energy Office Agency Building 2 Espire State Plaza Albany, New York 12223 Noward L. Blau Blau and Cohn,.P. C.

380 North B M rf Jericho New York 11753 Izving Like, Reilly, Like Schnieder 200 West Main Street Babylong, New York 11702 MB Tecimical Associates 366 California Avenue Suite 6 Palo Alto, California 94306 I

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Mr. Edward G. Bauer, Jr.

Vice President & General Counsel Philadelphia Electric Campany 2301 Market Street Philadelphia, Pennsylvania 19101 cc: Troy B. Conner, Jr., Esq.

Conner, Moore & Corber 1747 Pennsylvania Avenue, N. W.

Washington, D. C.

20006 W. William Anderson, Esq.

Deputy Attorney General Room 512, Main Capitol Building Harrisburg, Pennsylvania 17120 Frank R. C1okey, Esq.

Special Assistant Attorney General Room 218 Towne House Apartments P. O. Box 2063 Harrisburg, Pennsylvania 17105 Honorable Lawrence Coughlin House of Representatives Congress of the United States Washington, D. C.

20515 Roger 8. Reynolds, Jr., Esq.

324 Swede Street Norristown, Pennsylvania 19401 Willard C. Hetzel, Esq.

312 Main Street East Greenville, Pennsylvania 18041 Lawrence Sager, Esq.

Sager & Sager Associates 45 High Strer:

Pottstown, Pennsylvania 19464 Joseph A. Smyth Assistant County Solicitor County of Montgomery Courthouse Jeorristown, Pencer 1vania 19404 l

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Pr. Edward G. Bauer, Jr.

cc: Eugene J. Bradley Philadelphia Electric Company Associate General Counsel 2301 Market Street Philadelphia, Pennsylvania 19101 l

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Washington Public Power Supply System ATTN: Mr. Kneil 0. Strand Managing Director 3000 George Washington Way Richland Washington 99352 Joseph B. Knotts, Jr., Esq.

Debevoise & Libennan 700 Shoreham Building 806 Fif teenth Street, N. W.

Washington, D. C.

20005 Richard Q. Quigley, Esq.

Washington Public Power Supply System P. O. Box 968 Richland, Washington 99352 h

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r Mark II Meeting Novsmber 14 C. J. Anderson NRC/ DSS / CSS T. M. Su NRC/ DSS /CSB C. Economos BNL W. Butler NRC/ DSS /CSB R. E. Shewmaker NRC/IE K. G. Hazifotis GE L. J. Sobon GE L. C. S. Nieh S&W S. B. Mucciacciaro S&W T. Y. Chow S&W D. M. O'Connor Bechtel R.'L. O'Mara S&W H. Chau Lilco W. Museler Lilco J. E. Metcalf S&W

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