ML20214N831

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Forwards Request for Addl Info Re Util Action Plan for Performance Improvement & Preliminary List of Issues to Be Resolved in Electrical,Instrumentation & Control Portion of Proposed SER
ML20214N831
Person / Time
Site: Rancho Seco
Issue date: 09/05/1986
From: Stolz J
Office of Nuclear Reactor Regulation
To: Julie Ward
SACRAMENTO MUNICIPAL UTILITY DISTRICT
References
TAC-61635, NUDOCS 8609170083
Download: ML20214N831 (16)


Text

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, September 5, 1986 M1 b df Docket No. 50-312 ocket F JPartlow NR R NThompson L PDR RIngram Mr. John E. Ward PBD#6 Rdg Gray File Assistant Gene'ral Manager, Nuclear FMiraglia SMiner Sacramento Municipal Utility District 0GC-MNBB 9604 GKalman 6201 S Street ACRS-10 RWeller P. O. Box 15830 EJordan BGrimes Sacramento, California 95813 1

Dear Mr. Ward:

1

SUBJECT:

ACTION PLAN FOR PERFORMANCE IMPROVEMENT - REQUEST FOR ADDITIONAL INFORMATION From our initial review of your Action Plan for Performance Improvement we found that, in general, it lacks the technical detail we require to prepare a Safety Evaluation. In our July 29, 1986 letter we provided you with general comments which we noted should be considered in preparation of your supplement to the Action Plan. Enclosed with this letter (Enclosure 1) is a detailed list of questions which will require responses to provide a basis for our Safety Evaluation.

i To provide you with an example of the type of detail we require to prepare our Safety Evaluation, we are enclosing (Enclosure 2) a copy of a preliminary list of issues to be resolved in the Electrical, Instrumentation and Control a portion of the proposed Safety Evaluation Report. You may have already provided some of the information that addresses those issues; however, you should assure that future submittals provide sufficient detailed inform _ tion to adress the listed issues.

The reporting and/or recordkeeping requirements contained in this letter affect fewer than ten respondents; therefore, OMB clearance is not required under P.L.96-511.

Sincerely, d [1 Q John F. Stolz, Director '"f PWR Project Directorate #

Division of PWR Licensing-B

Enclosures:

As Stated cc w/ enclosures:

See next page

  • See previous white for concurrences. ..

[C PBD-6 PBD-6 PBD-6 PB #6 SMiner;cf* GKalman* RWeller* JStolz[34 9/3/86 9/3/86 9/3/86 9/5/86 8609170083 860905 PDR ADOCK 05000312 P PDR

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i Docket No. 50-312 DISTRIBUTION Docket File JPartlow NRC PDR NThompson L PDR RIngram Mr John E. Ward PBD#6 Rdg Gray File AsshqtantGeneralManager, Nuclear FMiraglia SMiner Sacra Qnto Municipal Utility District OGC-MNBB 9604 GKalman 6201 S 5 reet ACRS-10 RWeller P. O. Box 5830 EJordan Sacramento, California 95813 BGrimes

Dear Mr. Ward:

SUBJECT:

ACTION P (N FOR PERFORMANCE IMPROVEMENT - REQUEST FOR ADDITIONAL '

INFORMATION From our initial review ohyour Action Plan for Performance Improvement we found that, in general, it lacks the technical detail we require to prepare a Safety Evaluation. In our July 29, 1986 letter we provided you with general comments which we roted should be considered in preparation of your supplement to the Action Plan. Enclosed withs this letter (Enclosure 1) is a detailed l list of questions which will requira responses to provide a basis for our Safety Evaluation.

To provide you with an example of the type of detail we require to prepare

our Safety Evaluation, we are enclosing (Enclosure 2) a copy of a preliminary outline of the Electrical, Instrumentation a'nd Control portion of the proposed Safety Evaluation Report. You may have already, provided some of the information that addresses the issues discussed in the outline. However, you should assure that future submittals provide sufficient' detailed information to cover the issues discussed in the outline. \

The reporting and/or recordkeeping requirements conta ned in this letter t affect fewer than ten respondents; therefore, OMB clearance is not required under P.L.96-511.

Sincerely, \

\

'N John F. Stolz, Director PWR Project Directorate #6 Division of PWR Licensing-B i

Enclosures:

l As Stated g 4

cc w/ enclosures:

See next page

/d A /} A h PBD-6 PBD- PBD-6 PBD#6 SMiner GKalman RWeller JStolz 9/3 /86 7g/ 7/86 .f)f/J/86 8/ /86

. Mr. John E. Ward Rancho Seco Nuclear Generating Sacramento Municipal Utility District Station cc:

Mr. David S. Kaplan, Secretary Sacramento County and General Counsel Board of Supervisors Sacramento Municipal Utility 827 7th Street, Room 424 District Sacramento, California 95814 6201 S Street P. O. Box 15830 Ms. Helen Hubbard Sacramento, California 95813 P. O. Box 63 Sunol, California 94586 Thomas Baxter, Esq.

Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.

Washington, D.C. 20036 Mr. Ron Columbo Sacramento Municipal Utility District Rancho Seco Nuclear Generating Station 4 4440 Twin Cities Road Herald, California 95638-9799 Mr. Robert B. Borsum Babcock & Wilcox Nuclear Power Generation Division Suite 220, 7910 Woodmont Avenue Bethesda, Maryland 2C814 Residept Inspector / Rancho Seco c/o V. S. N. R. C.

14410 Twin Cities Road Herald, California 95638 Regional Administrator, Region V U.S. Nuclear Regulatory Commission 1450 Maria Lane, Suite 210 Walnut Creek, California 94596 Director Energy Facilities Siting Division Energy Resources Conservation &

Development Commission 1516 - 9th Street Sacramento, California 95814 Mr. Joseph 0. Ward, Chief l Radiological Health Branch i State Department of Health Services 714 P Street, Office Building #8 Sacramento, California 95814 l

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9 Enclosure 1 RANCHO SEC0 NUCLEAR GENERATING STATION DOCKET NO. 50-312 REQUEST FOR ADDITIONAL INFORMATION

1. Provide further discussion regarding the review of the systems included in the System Reviev and Test Program.which will be performed by the System Engineer. Indicate th'e s' cope of th'e design verification to be conducted including the documentation examined.for:each system and the means t. sed to confim that the system design basis and licensing criteria are being met.
2. Based on past concerns identified with, regard to the functioning of the instrument air system, the staff believes that additional testing as recomended in Regulatory Guide 1.68.3 beyond a loss of instrument air should be conducted. Specifically, the staff recomends that in addition to a sudden loss of air test, a gradbal loss of pressure test should be perfomed and proper system response ,to this condition verified as -

recommended in Regulatory Guide 1.68.3.

3. Identify and discuss how control room personnel will monitor the plant to determine if the plant is within the post-trip winde,t when the SPDS is unavailable.

4 List the functional steps within the Action Plan that result in odifica-ti.on to the control room, then ccmpare these steps to the process used for the Detailed Control Room Cesign Review.

5. List all control room modifications identified by the Action Plan and for each modification discuss the role of the human factors discipline in the Action Plan activities which led to the modification.
6. Identify and discuss how the control roon will be validated for responses to emergencies and abnormal events subsequent to the design modifications identified by the Action Plan.
7. Section 4A.1.2.2 - Include NUREG issued by NRC, e.g. . NUREG-0667, NUREG-0737, etc.
8. Section 4. A.2.2 - Scope of program should include not only loss of air and power on the system as a whole or individual component basis but should include functional loss based on partial loss of system which could affect a group of components in the system.
9. Section 4.A.2.3 - In accordance with the methodology discussed, it appears that loss of electrical power, , instrument air or loss of ICS/NNI are considered individually. The methodology shoulo also include loss of ICS/NN! together with loss of offsite power or instrument air.

s 10. The licensee's July 3,1986 submittal, " Rancho Seco Action Plan for Performance Improvement," makes the initial statement that, "The steadily degrading performance of the plant and its staff are symptomatic of more serious deficiencies than those associated with the December incident."

This acknowledgement combined with the NRC identified performance problems has raised broad concerns about the safe and reliable operation of the Rancho Seco facility. Therefore, to approve the Rancho Seco Action Plan the staff is seeking a program that addresses the adequacy of system testing including verification that systems are tested in all configurations required by design-basis analysis. This same concern existed at Davis-Besse for which their System Review and Test Program (SRTP) was determined acceptable by the staff.

Instead of initiating an SRTP designed to provide a comprehensive evaluation and functional demonstration via review and testing of systems important to safe plant operation (similar to Davis Besse), SMUD has initiated an SRTP for Rancho Seco which provides a review of those systems identified from a " systematic review" of issues and recommendations as well as a review of previous tests cojiducted. The Rancho Seco SRTP as structured was to assure that the systems chosen (selection method is unclear at this time) have retained their FSAR functional' basis, and have been adequately tested. SMUD appears to have retrofitted a test program (SRTP) to support their initial Plant; Performance and Management Improvement Program (PP&MIP) to resolve the NRC's concern over safety system functional demonstration rather than initiating the Davis Besse approach and discarding their init'ial PP&MIP. Therefore, it will need to be determined if the Rancho.Seco SRTP resolves the staff's concerns as was accomplished by the D' avis Besse SRTP.

~.:

A1though the Rancho Seco PP&MIP is'a very broad and massive program whose interaction with the SRTP is not yet clearly understood, the PP&MIP may be an acceptable approach (versus the Davis Besse SRTP) provided the following general concerns can be resolved:

(a) It is not cicar how the systems to be reviewed as part of the SRTP will be selected. For example, will the tentative list of systems in Section 4D be submitted to the PAG for approval and then adjusted from the input received from the PP&MIP, or will the initial selection of systems be based on preliminary output from the PP&MIP? Clarification of the system selection process is required including how the output of the PP&MIP will be used in that process. System selection was the staff's basic concern expressed at the June 17-18, 1986 site visit resulting from a review of the first draft of the Action Plan for Performance Improvement.

(b) It is not clear how the Rancho Seco SRTP is modeled after the Davis Besse SRTP. For example, the Davis Besse SRTP identified those systems important to safety, and then performed systems reviews and functional tests. The Rancho Seco SRTP will identify systems for review and test from the output of the PP&MIP. The selection process appears to be different. Also, one of the Davis Besse SRTP 1

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% objectives was to identify important and recurring design problems, and determine corrective actions. Recurring design problems do nnt appear to be addressed in the Rancho Seco SRTP. The staff would like a clarification as to how the Rancho Seco SRTP is modeled after the Davis Besse SRTP, and how the results of a review of the Davis Besse SRTP will be factored into the Rancho Seco plan.

(c) Oversight of the Davis Besse SRTP is performed by the Independent Process Review Committee (IPRC) set up by Toledo Edison. The IPRC is responsible for the review of all system review reports, review and approval of all corrective actions, review of proposed draft test outlines, and review of test results. The Rancno Seco SRTP only describes an independent review of the Test History Review of the System Status Report. How will the in-process independent review of other portions of the SRTP be performed?

11. Section 1.2 ARecommendationReviewandResobutionBoard(RRRB)anda Performance Analysis Group (PAG) has been established. Describe how these groups' responsibilities relate to your Management Safety Review Committee.
12. Section 1.4 (a) The staff does not understand what Section 1.4.1, " System Review and Test Program," is stating (i.e., it does not appear to summarize Section 4D, " System Review and Test Program.").

(b) Clarify how the five systems were selected as the dominant cause for severe and complex post trip plant transients, as identified in Section 1.4.2.

13. Section 4A.4 The plant interview program should provide very useful data. In reviewing this program, however, it would be helpful for the staff to have additional information not provided in the submittal.

Specifically, what is the specific scope of personnel interviewed

(" cross section" is too general), what are the backgrounds and training of the personnel carrying out the interviews, what are the questions being asked, how does the program encourage personnel to

" identify issues or concerns, and what will be the basis for determining that specific concerns will be acted on?" In general, the staff would like to see more detail provided on the interview methodology. Since " operational" problems are often associated with human factors deficiencies, it is important to identify these items. It is not clear that the method used will get at these issues or whether the personnel involved are appropriately trained.

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wait ws? Clarifyincluded (Se tho se finu rat oie)?

ns ntify l ms (Sect o m con reviected expe to be re view idei nal prob e ct on ]

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te systemrring ope m tho from Will the fir ssirg ct reoccu con Bullot n 7914is w m i

(c) affe re view IE systems of the 4D 2 which the in Figu re chnical Will com plet o all res?

te (d) since ren ced a c of adequa yISTcedu pro Sect o i n 1.e.2 refe ve rify thc ISI (e) a nd s ubmittal. re view ces syste m rve illan su (f) Will spe thecification

I I 14. Section 48.4 (a) Items .1-2, .1-3, and .1-4 imply that only specific procedures (associated with December 25th event) and recent procedure revisions (since May 1985) will be targeted for review and correction. However, the nature of the problems identified with procedures suggests that these problems may be indicative of more widespread deficiencies. Why has the scope of the review been so narrowly defined when it seems that a broader and more comprehensive review of procedures, including both technical and human factors evaluations, would be appropriate?

(b) Items .1-4 and .1-5. Based on the content of the submitted Rancho Seco Procedures Generation Package, the program of verification and validation should have accomplishe'd these actions. The inclusion of these tasks in the program suggests that these evaluations were never accomplished as stated. Were these evaluations ever performed? If so, what specific changes will be ma.de in the program to ensure that a more effective evaluation is performed? If not, why?

15. Section 4B.5 Items .2-1 and .2-2. It appears that the tasks associated with upgrading maintenance procedures is incomplete. Why is there no program element to validate /v'erify these procedures?
16. Section 4D (a) How is the review of Test Spec'ifications, Special Test Procedures, Surveillance Procedures, and restart test results by the Test Review Group documented as referenced in Section 1.c.2?

(b) How will the selection of systems be performed by the SRTP director? Will he submit a tentative list to the PAG for approval and then adjust that list as input is received from the PP&MIP, or will he wait for preliminary output from the PP&MIP before starting system I reviews? Clarify the <;ystems selection process and what systcms are '

expected to be included (Section 1.d).

(c) Will the system review identify those design weaknesses which could affect reoccurring operational problems (Section 1.e)? '

(d) Will the systems review confirm the modified system configurations since completion of the IE Bulletin 79-14 walkdown (Section 1.e)?

(e) Section 1.e.2 referenced a Figure 40-2 which is missing from the submittal.

(f) Will the system review verify the adequacy of all technical specification surveillances and ISI & IST procedures?

4 (g) How will the results of the review of the Davis Besse test program be factored into the Rancho Seco testing program as described in Section 1.f?

(h) How will the results of the material condition walkdown be factored into the System Status Report recommendations?

(i) Clarify why an independent review of only the Test History Review section of the System Status Report will be perfonned by the Test P.eview Group and not all sections.

(j) Does completion of the balance of the ten-year inservice inspection consist of periodic testing of pump and valves (Section 1.f.2)?

(k) Describe what is considered as an appropriate system functional test to confirm the adequacy and effectiveness of the Action Plan as discussed in Section 1.f.3.

(1) Clarifywhatismeantbynormalkestingassociatedwiththeplant performance monito;ing program as discussed in Section 1.f.3.

(m) When is the training program for; test engineers to be performed as discussed on p. 40-14? Will the program be completed prior to system review initiation? What will the course outline consist of?

17. Table 1-A The system function description is to be compiled using appropriate technical documents. From thfs compilation the Systems Engineer is 4 to determine the need for additional testing. Was this process the basis for the statement, that, "...the regular refueling outage system tests will provide complete function testing of the RPS." on page 1 of Table 1-A?
18. Table 1-C Jlarify why verification of system operability per Technical Specifications is accomplished by tests other than technical specification surveillances for some systems in Table 1-C (e.g., S/G & MS).
19. Appendix r3 (a) Finding B.6 (1) Describe how the HPI vs. PTS concerns are directly handled in the E0Ps.

J 4 (2) Why were the PTS guidelines exceeded during the December 26 event?

(3) Discuss the rationale of using overly conservative PTS guidelines which do not allow the operators to know if a real problem exists which might require emergency pressure reduction.

(4) Describe how operator training has been revised to resolve conflicting priorities during implementation of the E0P's, and give examples.

(b) Finding B.7 (1) Describe what simulator was used for the operator training.

(2) Provide details of the differences between the B&W simulator and the facility.

20. Appendix G (a) Clarify the PAG acceptance of sy tem for restart process. Must the corrective actions be complete. prior to restart for PAG acceptance?

(b) Clarify why all System Status Reports do not provide restart, near term, or long term recommenda'tions.

21. Appendix H

() The test specification prerequ'isites require construction complete and turned over to startup with any exceptions duly noted and recorded. Clarify why the prerequisites do not require an evaluation of the exception's effect on the test method specified.

(b) Clarify why the test specification for the fire protection valve 4

drain line modification did not have a prerequisite requiring construction completion.

Rancho Seco Nuclear Generating Station Electrical, Instrumentation, and Control SER Issues (Preliminary) j l

INTEGRATED CONTROL SYSTEM (ICS)

Address Correlation of ICS Power Supplies to Onsite Emergency Buses Identify the Class IE or Non-Class,1E Qualification -

of Power Supplies & Distribution Systems Identify Components and Systems Controlled by ICS Include Diagrams of Controls and Power Supplies loss of ICS dc Power Issue

  • State Positicn of Compo6ents CIntrolled by ICS Following loss of dc Power Explain how a Single Power Supp1y Monitor (PSM) Failure Caused Total loss of dc Power Identify Similar 51 and 52 Switches in the Plant Address Root Cause Determination
  • Address Sensitivity of R'esistance at Input of PSM *

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  • Address Delayed Trip of 51 and 52 Switches Request that a FMEA be' done for PSM and ICS and Interfacing Systems Address Loss of Remote Control of Affected Valves from Control Room
  • Discuss the Independence of ICS with Respect to ESFAS such as MSLFL, EFIC
  • Address Backup Controls and Locations, and Indicate if they are Independent of ICS, and are Goverened by Tech. Specs., and are Safety Related .
  • Address Vulnerability of Total Loss of ICS"dc Power as a Result of Single Failure of PSM Propose Independent PSM per Power Supply
  • Assess Failures of Loss of dc Power Relay to Connect Battery-Backed Power Source
  • Address Qualification and Testability of Above Relay Discuss " Crosstalk" Problems if Redundant PSM are used

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2 Restoration of ]CS de Power Issue  !

Indicate Position of Components Following Restoration of ICS Power in clu d e n g :

Analysis to Determine the P,osition of Components Upon Restoration of ICS Power Effect of These Positions on Plant Transient Condition and Safety Margin How These Effects are Minimized Additional Issues - f fddyf et g)\%,9 . .

Total Loss of ac Power Single Failure Vulnerability of Automatic Bus Transfer Switch Partial Loss of at Power ,or dc Power Partial Restoration of ac Power or de Power Indicate if Issues have been Addressed by SMUD Discuss Effect of Other ICS Failures and Indicate Whether These Should be More or Less Severe.Than Loss of Power Events ,-

AUXILIARY FEEDWATER (AFW) SYSTEM -

Adlmr nt Sllew$ '

Include Functional Diagram State Whether the Motor or the Turbine of the AFW Dual Drive Pump are Auto Start AFW Control Valves Behavior on Loss of ICS Issue r

Address Valves Flow Balanced DFsign I

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v Include New Hand / Auto ' Controller Request How " Fail to Set Point" is accomplished Include Functional Diagram Verify Independence on New Hand / Auto Controller From ICS .

Verify Independence on Power Supply From ICS of AFW Control Valve Bypass Operated by SFAS.

Assess the Consequences of Loss of ICS ac or de Control Power Consider Consequences Upon toss of Air Supply Evaluate the Independence of Various Power Supplies with Respect to each other Perfonn Analysis of AFW System Capability to meet Single Failure given an Incapacitated SG concurrent with

- -- the Loss of Offsite Power. Concentrate in the Designa-tion of Power Supply for Components. -

Discuss how Manual Con' trol of the AFW (ICS) Control Valves is Used to Prevent Overfilling the OTSG.

Address ac Power Dependency

  • Emergency feedwater I,ntt13tiart.and. Control (_Ef1ClSystem Issue

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Include Functional Diagram MFW Control Valves & Pump Speed Behavior on Loss of ICS and Line Isolation Issue Address the Role Played by JCS on Isolation 9

Address feastbtlity of Status Quo Position of Ceponents followi.n3 Less of ICS ,

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s MAIN STEAM SYSTEM Incl. Functional Diagram

  • Atmospheric Dump Valves (ADVs) Behavior on Loss of ICS Issue 4 . __

Address the Modification that the Valve Will'Open I

to its 50% Position if $he ICS is not Powered j

Address the Effect of Failure of ICS Aux Relay in all '

the Components Where it. Participates Indicate Whether Valv'es'can be Modulated Role Played by IDADS in Monitoring ADV Solenoids Discuss Indpendence of Power Supply From ICS Turbine Bypass Valves (T8Vs) Behavior on Loss of

.IC5 Issue l

Address Same Items as Those for ADY Issue GAbovel Main Steam Line Failure Logic Response Tim Issue R* View Licensee Submittal of Feb. 19, 1986, Pg. 12 Ad pok It de rhv0 t't rdwit ed Steam Generator Overfill Protection Issue 1

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MAKEUP /HIGH PRESSURE INJECTION SYSTEM Include Functional Diagram Discuss Alarms and Protective Interlocks

_ Loss of Pump Suction Issue ",

Address Consequences of Losing RCP Seal Injection -

Flow when Pumps not Running Address Vulnerability of RCP Seal Injection to Single Failure Concurrent With the Loss of Offsite Power REMOTE AND LOCAL INDICATIONS Display and Alann Systems Description - bo9de Oc %.lk .no :

Incl. SPDS, Annunciator, RG I.97 Instrumentation Bailey Computer, Interim Data Aquisition Display System (10 ADS)andNNI Indicate Whether Systems Are Safety-Related Indentiy Power Supply Division as Related to Division for ICS and NNI Address Reactor Vessel Level Instrumentation Indication Issues - Oirco rr 4-h e k llc w. <i <3 :

Loss of ICS Power Alarm and Interactions with Fan Power Failure Main Feedwater (MFW) Flow Recorders Affected by the ICS 1

Generator Frequency Indicator Difference Between SG Level Values Monitored by SPDS and Other Control Room Indications HPI/RCS Injection Yalve Position Main Steam Relief Valve Open Monitor Reactor Building Radiation Monitor

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e Address Increase of Sample Frequency of IDADS Address Loss of Indication when ICS Power is not Available .

Discuss the Indpendence of PWR to Instruments Discuss Adequacy of Remaining Instrumentation Following Power Failure of ICS or NNI INTERACTIONS BETWEEN ICS, NNI AND PROTECTION SYSTEMS I rru E e Provde a brcus s te n of. 4h r trrue ,

, . - - OTHER ISSUES Diesel Generators Capacity Issue - Dirc un THE Follo w WG - ,

Address Existing Capacity Discuss Margins Discuss the Reasons for Load Sequencing to the Offsite Power Sources Indicate if Motor-Driven AFW Pump is Automatically loaded to DG Indicate if the Motor of the AFW Dual Drive Pump is Connected Automatically to the DG Indicate if the Motor of the AFW Dual Drive Pump is' Shed From Buses if Runing before Load Sequencer is Started Address New TDI DGs Address TCI DGs Qualification Program and Schedule for DGs Being made Operational 7

. Containment Isolation of Essential Systems Issue Address Damage to Radiation Monitor Address the Response to Item II.E.4.2 of NUREG-0737

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_Imediate Loss of Air Supply to ICS Components Issue Address Safety-Related Classification of Air Supply _

System Indicate if Air Supply System is Connected to the Emergency Buses Dircurr the Rupture of Airline Address the Consequences of Losing kir Supply System as a Result of Losing Offsite Power

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Loss of Offsite Power Concurrent With the Loss of 105 Issue f ewd < 4 k nicu us e n *{ dir m u e.

HUMAN FACTORS ISSUES

  • -Address the Need for Better Diagnostics for Breaker Position Indication, e.g., Simplified Electric Schematics Address ADVs, andthe AFWNeed for Valve Control Valves Position Indication for TBVs.

AddresstheNeedtoCorrecttheNoiseProblerwithContYol Room HVAC Address the Desirability of Having Separate Alanns for "ICS* and " Fan Power Failure" i

TECHNICAL SPECIFICATIONS '

Address the Existing Requirements Governing the Oper-ability of Systems an Components Addressed Herein Address the Need for Changing Technical Specifications as Operating Procedures are Revised s :r

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