ML20154M720

Comments on Draft Reg Guide Endorsing IEEE Std 603-1980. Guide Should Recommend That Figure 7 Be Used W/Caution

ML20154M720
Person / Time
Issue date:	12/06/1983
From:	Morris B NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
To:	Morrison W NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
Shared Package
ML20151H810	List: ML20151H807 ML20151H908 ML20151H913 ML20151H919 ML20151K741 ML20151K873 ML20154M705 ML20154M720 ML20154M728 ML20154M743
References
RTR-REGGD-01.XXX, RTR-REGGD-1.XXX NUDOCS 8603140442
Download: ML20154M720 (2)

Text

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DEC 6 1983 MEMORANDUM FOR:

Wilbur Morrison, Acting Chief Instrumentation and Control Branch, DF0, RES FROM:

Bill Morris, Chief Electrical Engineering Branch, DET, RES

SUBJECT:

DRAFT REGULATORY GUIDE ENDORSING IEEE STANDARD 603-1980

- With reference to your memorandum to G. A. Arlotto, dated November 10, 1983, requesting review and comments on the subject draft guide, Mr. Arlotto has asked me to reply on behalf of DET.

We have the following comments:

1.

Section 6.3.1(1) on page 20 of the standard contains a serious typographical error which substantially alters its meaning. Specifically, the third line in 6.3.1(1) contains, in error, the words " detect the event and." These words should be effectively deleted by an appropriate " exception" in the guide, so that the line reads "provided to limit the con (sequences)."

Detection of the event itself is a proper design provision only for the second option in 6.3.1(2). This correction also renders 6.3.l(1) con-sistent with Section 4.7.4.1 of IEEE Standard 279-1971 which is worded properly, and does not require the alternate channels to dettet the event.

2.

The upper left " diamond" in Figure 7 y'yes"s, by convention, two mutually ield exclusive alternatives designated by and "no."

Consider an event where an instrument sensing line to a steam generator level instrument ruptures, simultaneously causing a loss of water from the steam generator and a controls malfunction that acts to lower the water level, based on false "high level" signals to the level controller. This event requires a safety function; specifically the introduction of additional feedwater.

It also causes an action by the (non-safety) level control system.

Figure 7, however, shows these two events as mutually exclusive, a contradiction.

Thus, Figure 7 is confusing, and a recommendation should be made in the guide to the effect that Figure 7, if used, should be used with caution.

3.

The paragraph at the bottom of page 4, which continues into page 5, should be deleted.

It adds nothing.

It is also confusing since it addresses matters not covered in the rest of the guide.

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W. Morrison 2

4.

For clarification, the following sentence should be added to the first

" basis" statement on page 5:

"These recommendations, which are not included in IEEE Standard 497-1977, are also acceptable for the identi-fication, design, installation, and maintenance of display instrumentation required for the manual actuation of safety functions for which there is

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no automatic actuation.

5.

Item 3 on page 5 should be deleted. The current version of Regulatory Guide 1.53 does not " match" IEEE Std 603-1977 and is, therefore, out of date.

IEEE Std 379-1977 is not endorsed by a regulatory guide and is covered in the present C.5 on page 6.

6.

Page 6, Item 1:

Insert "the provisions for Type A instruments in" between "IEEE Std 603-1980," and " Regulatory Guide 1.97" in the second line.

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(Only the " Type A" provisions are applicable.)

7.

Page 7:

The statement, "For additional guidance with regard to equipment qualification refer to Regulator placed with a new provision C(x)y Guide 1.89," should be deleted and re-

, as follows:

All references to "IEEE Std. 323-1974" should be replaced by " Revision 1 to Regulatory Guide 1.89, Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants."

8.

A new section, C(y), should be added as follows:

All references to IEEE Std 338-1977 should be replaced by " Revision 2 to Regulatory Guide 1.118, Periodic Testing of Electric Power and Protection Systems."

If you have any questions, please contact D. F. Sullivan, EEBR, X37946.

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Bill M. Morris, Chief Electrical Engineering Branch Division of Engineering Technology Office of Nuclear Regulatory Research

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