Letter Sequence Approval |
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MONTHYEARML20216H9971997-04-10010 April 1997 Responds to Region IV 961113 Memo Requesting Review of Licensee Position on Compliance W/General Design Criteria for Dual Function air-operated Containment Penetration Valves Project stage: Approval 1997-04-10
[Table View] |
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Category:INTERNAL OR EXTERNAL MEMORANDUM
MONTHYEARML20211G2671999-08-27027 August 1999 Notification of 990909 Meeting with Util in Rockville,Md to Discuss Proposed TSs for Emergency Feedwater Sys at Waterford 3 ML20209G2421999-07-14014 July 1999 Notification of 990722 Meeting with License in Rockville, MD to Discuss Changes in EOI Licensing Organization Including Division of Responsibilities within New EOI Corporate Licensing Group ML20206F8831999-04-30030 April 1999 Informs That NRC Staff Will Discuss Encl Draft for RAI with Eoi,Re EOI Response to GL 95-07, Pressure Locking & Thermal Binding ML20205R8871999-04-20020 April 1999 Notification of 990504 Meeting with Util in Rockville,Md to Discuss Proposal to Submit Consolidated Security Plan for Util Sites ML20197J6251998-12-0909 December 1998 Revised Notification of Licensee Meeting with Licensee on 981216 in Arlington,Tx to Discuss Actions Being Implemented in Performance Improvement Plan for Selected Weaknesses Identified During Architect Engineer Insp ML20195G1121998-11-17017 November 1998 Notification of 981201-02 Meeting with Entergy Operations in Taft,Louisianna to Conduct Joint Workshop for Licensing Personnel from Entergy & Nrc,Project Directorate IV-1 ML20153F8051998-09-23023 September 1998 Notification of Licensee Meeting with Util on 981216 in Arlington,Tx to Discuss Actions Being Implemented in Performance Improvement Plan for Selected Weaknesses Identified During Architect Engineer Insp ML20151U7971998-09-0808 September 1998 Notifies of 980929 Meeting with Util in Rockville,Md to Discuss Level of Instructions & Details for Transferring Quality Assurance Plan Details from Current Program Plans at Four Sites to Std Quality Assurance Program Plan ML20153H6671998-09-0808 September 1998 Revised Notification of 981007 Meeting with Util to Discuss Level of Instructions & Details for Transferring QA Plan Details from Current Program Plans at Four Sites to Std Program Plan at All Sites.Originally Scheduled for 980929 ML20237A2811998-08-12012 August 1998 Notification of 980827 Meeting W/Nrc & Util in Rockville,Md to Discuss Level of Instructions & Details for Transferring QA Plan Details from Current Program Plans at Four Sites ML20249A2101998-06-11011 June 1998 Notification of 980702 Meeting W/Util in Rockville,Md to Discuss Level of Instructions & Details for Transferring Quality Assurance Plan Details from Current Program Plans at Four Sites to Std Quality Assurance Program Plan for Site ML20216D6351998-04-13013 April 1998 Notification of 980416 Meeting W/Util in Rockville,Md to Discuss Entergy Operations,Inc Initial Proposal to Standardize Security Plans for Listed Plants ML20216B5481998-04-0808 April 1998 Notification of 980512 Meeting W/Entergy Operations,Inc in Arlington,Texas to Present Results of SALP Rept for Waterford Steam Electric Station,Unit 3 ML20217E8471998-03-26026 March 1998 Notification of Significant Licensee Meeting W/Util on 980402 to Discuss Entergy Operations,Inc Annual Performance Assessment ML20197B8721998-03-0505 March 1998 Notification of 980401 Meeting W/Util in Jackson,Ms to Discuss Licensing Issues & Regulatory Performance Efficiencies W/Licensing Staff for Plants.Meeting Agenda Encl ML20203A0411998-02-0505 February 1998 Notification of 980219 Meeting W/Util in Rockville,Md to Discuss SFP re-rack & SFP Cooling at Plant,Unit 3 ML20203B4131998-02-0505 February 1998 Notification of 980319 Meeting W/Entergy Operations,Inc,In Rockville,Md to Discuss Level of Instructions & Details of Transferring QA Plan Details from Current Program Plans at Four Sites to Standard QA Program Plan for Use at All Sites ML20198N9261998-01-13013 January 1998 Revised Notification of Meeting W/Util in Arlington,Tx Re Enforcement Conference to Discuss Details Re Valve ACC-126A Being Left in Manual Position.Purpose of Meeting Revised ML20198M8351998-01-12012 January 1998 Notification of 980122 Meeting W/Util in Rockville,Md to Discuss Site Licensing Status for Listed Plants & to Explore Ways to Standardize Licensing Submittals & Issuances ML20198P2561998-01-12012 January 1998 Notification of Significant Licensee Meeting W/Util on 980120-21 in Arlington,Tx to Review Examination for Operator Licensing ML20198G1071998-01-0707 January 1998 Notification of Significant Licensee Meeting W/Util on 980206 in Arlington,Tx to Discuss Engineering Issues & Process That Were Evaluated During Insp in Dec 1997 ML20198G3421998-01-0606 January 1998 Notification of Licensee Meeting W/Util on 980123 in Arlington,Tx to Discuss Details Re Valve ACC-126A Being Left in Manual Position ML20198L1701997-10-21021 October 1997 Notification of Significant Licensee Meeting W/Util on 971113 to Discuss Results of Aug 1997 Operability Assessment Insp ML20198K0791997-10-15015 October 1997 Notification of 971022 Meeting W/Entergy Operations,Inc in Rockville,Md Re Standard Quality Assurance Manual for Entergy Sites IR 05000382/19970131997-07-15015 July 1997 Notification of Meeting W/Licensee in Arlington,Tx on 970729 Re Operability of Containment Isolation Valves Concerning Insp Rept 50-382/97-13 ML20141D2511997-06-25025 June 1997 Notification of Licensee Meeting W/Listed Attendees on 970806 in Region IV Training Room Re W3 Performance Improvement Meeting ML20148D8171997-05-28028 May 1997 Revised Notification of Licensee Meeting W/Util on 970529 to Discuss Licensee Progress in Implementing Focus Plan ML20138H5111997-05-0101 May 1997 Notification of 970529 Meeting W/Util in Taft,La to Discuss Licensee Progress in Implementing Focus Plan ML20137Y8401997-04-21021 April 1997 Notification of 970423 Meeting W/Util in Killona,La to Discuss Containment Isolation Design & Licensing Basis for Plant,Unit 3 ML20137W6841997-04-15015 April 1997 Notification of 970502 Meeting W/Listed Attendees in Jackson,Mi.Meeting Agenda Encl ML20216H9971997-04-10010 April 1997 Responds to Region IV 961113 Memo Requesting Review of Licensee Position on Compliance W/General Design Criteria for Dual Function air-operated Containment Penetration Valves ML20137C9201997-03-20020 March 1997 Forwards Documentation of Meeting Conducted in Region 4 Office on 970225 to Discuss NRC Enforcement Policy as Applied to Nonescalated Enforcement ML20137A1991997-03-18018 March 1997 Notification of 970321 Meeting W/Util in Rockville,Md to Discuss Containment Isolation Design & Licensing Basis for Facility ML20135F8821997-03-13013 March 1997 Notification of Licensee Meeting W/Util on 970408 to Discuss Inadequate Containment Fan Cooler Flows ML20135B3721997-02-25025 February 1997 Notification of Licensee Meeting W/Util on 970324 to Discuss Update of W3 Focus Plan ML20134P2231997-02-20020 February 1997 Discusses Ti 2515/122 Evaluation or Rosemount Pressure Transmitter Performance & Licensee Enhanced Surveillance Programs multi-plant Action B-122 ML20134M2471997-02-14014 February 1997 Submits List of Plants Not Meeting Selection Criteria for Ti 2515/118 Insp on Basis of Factors Such as SWS Operating Experience,Contribution of SWS to Plant Risk Assessment, Licensee Programs in Response to GL-89-13 ML20236M1381997-01-14014 January 1997 Recommends That Region IV Pursue Appropriate Enforcement Action Re Waterford 3 Interpretation of Surveillance Requirement 4.6.2.2 for Containment Air Coolers.Tsb Concludes That Plant in Violation of LCO 3.6.2.2 ML20133G3981997-01-13013 January 1997 Forwards NRC Approved Operator Licensing Exam (Facility Outline & Initial Exam Submittal & as-given Operating Exam) for Tests Administered on 960909-20 ML20133D8061997-01-0707 January 1997 Notification of 970122 Licensee Meeting W/Util in Taft,La to Discuss Results of Systematic Assessment of Licensee Performance Rept ML20149M0471996-12-10010 December 1996 Forwards Internet Mail Received from PM Blanch ML20135B6231996-11-27027 November 1996 Notification of 961217 Licensee Meeting W/Util in Arlington, Tx to Discuss Evaluation Approach & Results of UFSAR Assessments at Each Facility ML20135B7021996-11-27027 November 1996 Notification of 961218 Public Meeting W/Util in Arlington, Tx to Discuss Status of Plant Performance Improvement Program ML20134L6121996-11-19019 November 1996 Notification of 961121 Meeting W/Entergy Operations,Inc,In Rockville,Md to Discuss Views on Funding for Decommissioning Costs of Nuclear Power Plants as May Apply for Each of Four Nuclear Plant Sites ML20129K2221996-11-0606 November 1996 Notification of 961120 Predecisional Enforcement Conference W/Util in Arlington,Tx to Discuss Inservice Testing of Valves ML20134C9121996-10-0808 October 1996 Notification of 961114 Meeting W/Util in Rockville,Md to Discuss Results of Self Assessment of Accuracy of Info in FSAR for Each Plant Site ML20129B5691996-10-0101 October 1996 Forwards Final Accident Sequence Precursor Program Analysis of Operational Event Which Occurred at Plant on 950610 ML20203C0191996-04-0909 April 1996 Discusses OI Rept 4-95-070 Re Alleged Discrimination Against Employee of Wackenhut Corp (Twc) Who Disagreed with Supervisor Instruction to Move Morse Watchman Key.Action Not Appropriate at This Time ML20203C0161996-02-23023 February 1996 Discusses Initiation of OI Rept 4-95-044 Re False Allegations That Fire Watch Records Were Being Falsified ML20203C0041996-02-12012 February 1996 Discusses OI Rept 4-95-047 Re Alleged Discrimination. Allegation Not Substantiated,Therefore Enforcement Action Not Appropriate in This Case 1999-08-27
[Table view] Category:MEMORANDUMS-CORRESPONDENCE
MONTHYEARML20211G2671999-08-27027 August 1999 Notification of 990909 Meeting with Util in Rockville,Md to Discuss Proposed TSs for Emergency Feedwater Sys at Waterford 3 ML20209G2421999-07-14014 July 1999 Notification of 990722 Meeting with License in Rockville, MD to Discuss Changes in EOI Licensing Organization Including Division of Responsibilities within New EOI Corporate Licensing Group ML20206F8831999-04-30030 April 1999 Informs That NRC Staff Will Discuss Encl Draft for RAI with Eoi,Re EOI Response to GL 95-07, Pressure Locking & Thermal Binding ML20205R8871999-04-20020 April 1999 Notification of 990504 Meeting with Util in Rockville,Md to Discuss Proposal to Submit Consolidated Security Plan for Util Sites ML20197J6251998-12-0909 December 1998 Revised Notification of Licensee Meeting with Licensee on 981216 in Arlington,Tx to Discuss Actions Being Implemented in Performance Improvement Plan for Selected Weaknesses Identified During Architect Engineer Insp ML20195G1121998-11-17017 November 1998 Notification of 981201-02 Meeting with Entergy Operations in Taft,Louisianna to Conduct Joint Workshop for Licensing Personnel from Entergy & Nrc,Project Directorate IV-1 ML20153F8051998-09-23023 September 1998 Notification of Licensee Meeting with Util on 981216 in Arlington,Tx to Discuss Actions Being Implemented in Performance Improvement Plan for Selected Weaknesses Identified During Architect Engineer Insp ML20151U7971998-09-0808 September 1998 Notifies of 980929 Meeting with Util in Rockville,Md to Discuss Level of Instructions & Details for Transferring Quality Assurance Plan Details from Current Program Plans at Four Sites to Std Quality Assurance Program Plan ML20153H6671998-09-0808 September 1998 Revised Notification of 981007 Meeting with Util to Discuss Level of Instructions & Details for Transferring QA Plan Details from Current Program Plans at Four Sites to Std Program Plan at All Sites.Originally Scheduled for 980929 ML20237A2811998-08-12012 August 1998 Notification of 980827 Meeting W/Nrc & Util in Rockville,Md to Discuss Level of Instructions & Details for Transferring QA Plan Details from Current Program Plans at Four Sites ML20249A2101998-06-11011 June 1998 Notification of 980702 Meeting W/Util in Rockville,Md to Discuss Level of Instructions & Details for Transferring Quality Assurance Plan Details from Current Program Plans at Four Sites to Std Quality Assurance Program Plan for Site ML20216D6351998-04-13013 April 1998 Notification of 980416 Meeting W/Util in Rockville,Md to Discuss Entergy Operations,Inc Initial Proposal to Standardize Security Plans for Listed Plants ML20216B5481998-04-0808 April 1998 Notification of 980512 Meeting W/Entergy Operations,Inc in Arlington,Texas to Present Results of SALP Rept for Waterford Steam Electric Station,Unit 3 ML20217E8471998-03-26026 March 1998 Notification of Significant Licensee Meeting W/Util on 980402 to Discuss Entergy Operations,Inc Annual Performance Assessment ML20197B8721998-03-0505 March 1998 Notification of 980401 Meeting W/Util in Jackson,Ms to Discuss Licensing Issues & Regulatory Performance Efficiencies W/Licensing Staff for Plants.Meeting Agenda Encl ML20203A0411998-02-0505 February 1998 Notification of 980219 Meeting W/Util in Rockville,Md to Discuss SFP re-rack & SFP Cooling at Plant,Unit 3 ML20203B4131998-02-0505 February 1998 Notification of 980319 Meeting W/Entergy Operations,Inc,In Rockville,Md to Discuss Level of Instructions & Details of Transferring QA Plan Details from Current Program Plans at Four Sites to Standard QA Program Plan for Use at All Sites ML20198N9261998-01-13013 January 1998 Revised Notification of Meeting W/Util in Arlington,Tx Re Enforcement Conference to Discuss Details Re Valve ACC-126A Being Left in Manual Position.Purpose of Meeting Revised ML20198P2561998-01-12012 January 1998 Notification of Significant Licensee Meeting W/Util on 980120-21 in Arlington,Tx to Review Examination for Operator Licensing ML20198M8351998-01-12012 January 1998 Notification of 980122 Meeting W/Util in Rockville,Md to Discuss Site Licensing Status for Listed Plants & to Explore Ways to Standardize Licensing Submittals & Issuances ML20198G1071998-01-0707 January 1998 Notification of Significant Licensee Meeting W/Util on 980206 in Arlington,Tx to Discuss Engineering Issues & Process That Were Evaluated During Insp in Dec 1997 ML20198G3421998-01-0606 January 1998 Notification of Licensee Meeting W/Util on 980123 in Arlington,Tx to Discuss Details Re Valve ACC-126A Being Left in Manual Position ML20198L1701997-10-21021 October 1997 Notification of Significant Licensee Meeting W/Util on 971113 to Discuss Results of Aug 1997 Operability Assessment Insp ML20198K0791997-10-15015 October 1997 Notification of 971022 Meeting W/Entergy Operations,Inc in Rockville,Md Re Standard Quality Assurance Manual for Entergy Sites IR 05000382/19970131997-07-15015 July 1997 Notification of Meeting W/Licensee in Arlington,Tx on 970729 Re Operability of Containment Isolation Valves Concerning Insp Rept 50-382/97-13 ML20141D2511997-06-25025 June 1997 Notification of Licensee Meeting W/Listed Attendees on 970806 in Region IV Training Room Re W3 Performance Improvement Meeting ML20148D8171997-05-28028 May 1997 Revised Notification of Licensee Meeting W/Util on 970529 to Discuss Licensee Progress in Implementing Focus Plan ML20138H5111997-05-0101 May 1997 Notification of 970529 Meeting W/Util in Taft,La to Discuss Licensee Progress in Implementing Focus Plan ML20137Y8401997-04-21021 April 1997 Notification of 970423 Meeting W/Util in Killona,La to Discuss Containment Isolation Design & Licensing Basis for Plant,Unit 3 ML20137W6841997-04-15015 April 1997 Notification of 970502 Meeting W/Listed Attendees in Jackson,Mi.Meeting Agenda Encl ML20216H9971997-04-10010 April 1997 Responds to Region IV 961113 Memo Requesting Review of Licensee Position on Compliance W/General Design Criteria for Dual Function air-operated Containment Penetration Valves ML20137C9201997-03-20020 March 1997 Forwards Documentation of Meeting Conducted in Region 4 Office on 970225 to Discuss NRC Enforcement Policy as Applied to Nonescalated Enforcement ML20137A1991997-03-18018 March 1997 Notification of 970321 Meeting W/Util in Rockville,Md to Discuss Containment Isolation Design & Licensing Basis for Facility ML20135F8821997-03-13013 March 1997 Notification of Licensee Meeting W/Util on 970408 to Discuss Inadequate Containment Fan Cooler Flows ML20135B3721997-02-25025 February 1997 Notification of Licensee Meeting W/Util on 970324 to Discuss Update of W3 Focus Plan ML20134P2231997-02-20020 February 1997 Discusses Ti 2515/122 Evaluation or Rosemount Pressure Transmitter Performance & Licensee Enhanced Surveillance Programs multi-plant Action B-122 ML20134M2471997-02-14014 February 1997 Submits List of Plants Not Meeting Selection Criteria for Ti 2515/118 Insp on Basis of Factors Such as SWS Operating Experience,Contribution of SWS to Plant Risk Assessment, Licensee Programs in Response to GL-89-13 ML20236M1381997-01-14014 January 1997 Recommends That Region IV Pursue Appropriate Enforcement Action Re Waterford 3 Interpretation of Surveillance Requirement 4.6.2.2 for Containment Air Coolers.Tsb Concludes That Plant in Violation of LCO 3.6.2.2 ML20133G3981997-01-13013 January 1997 Forwards NRC Approved Operator Licensing Exam (Facility Outline & Initial Exam Submittal & as-given Operating Exam) for Tests Administered on 960909-20 ML20133D8061997-01-0707 January 1997 Notification of 970122 Licensee Meeting W/Util in Taft,La to Discuss Results of Systematic Assessment of Licensee Performance Rept ML20149M0471996-12-10010 December 1996 Forwards Internet Mail Received from PM Blanch ML20135B6231996-11-27027 November 1996 Notification of 961217 Licensee Meeting W/Util in Arlington, Tx to Discuss Evaluation Approach & Results of UFSAR Assessments at Each Facility ML20135B7021996-11-27027 November 1996 Notification of 961218 Public Meeting W/Util in Arlington, Tx to Discuss Status of Plant Performance Improvement Program ML20134L6121996-11-19019 November 1996 Notification of 961121 Meeting W/Entergy Operations,Inc,In Rockville,Md to Discuss Views on Funding for Decommissioning Costs of Nuclear Power Plants as May Apply for Each of Four Nuclear Plant Sites ML20129K2221996-11-0606 November 1996 Notification of 961120 Predecisional Enforcement Conference W/Util in Arlington,Tx to Discuss Inservice Testing of Valves ML20134C9121996-10-0808 October 1996 Notification of 961114 Meeting W/Util in Rockville,Md to Discuss Results of Self Assessment of Accuracy of Info in FSAR for Each Plant Site ML20129B5691996-10-0101 October 1996 Forwards Final Accident Sequence Precursor Program Analysis of Operational Event Which Occurred at Plant on 950610 ML20203C0191996-04-0909 April 1996 Discusses OI Rept 4-95-070 Re Alleged Discrimination Against Employee of Wackenhut Corp (Twc) Who Disagreed with Supervisor Instruction to Move Morse Watchman Key.Action Not Appropriate at This Time ML20203C0161996-02-23023 February 1996 Discusses Initiation of OI Rept 4-95-044 Re False Allegations That Fire Watch Records Were Being Falsified ML20203C0041996-02-12012 February 1996 Discusses OI Rept 4-95-047 Re Alleged Discrimination. Allegation Not Substantiated,Therefore Enforcement Action Not Appropriate in This Case 1999-08-27
[Table view] |
Text
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NUCLEAR REGULATORY COMMISSION o ' WASHINGTON. D.C. 306tHe01
\ ,, ,,, # April 10, 1997 MEMORANDUM TO: William D. Beckner. Cirector Project Directorate IV-1 Division of Reactor Projects II/IV FROM: Carl H. Berlinger. Chief ogNS Containment S stems and Seve Accident ranch ,
Division of S stems Safety and Analysis
SUBJECT:
TASK INTERFACE AGREEMENT (TIA) - WATERFORD 3 REQUIREMENTS FOR THE CAPABILITY OF CONTAINMENT ISE ATION VALVES TO CLOSE TO MAINTAIN CONTAINMENT INTEGRITY (TAC N0. M97234)
The purpose of this memorandum is to respond to a Region 1.V request dated November 13, 1996. The request was to review the licensee's position on compliance with the General Design Criteria for dual function (i.e..open safety function on a safety injection actuation signal and/or containment function to isolate the containment) air-operated containment penetration valves.
Before address 1rg the specific designs one needs to understand the roles of a system safety function and containment isolation function. In general, a-system which penetrates containment has an important role to play in the overall operation of the plant. Some perform a safety function in a pre / post LOCA manner while others are important to the overall operation of the plant, in either case, however, the requirement to perform a containment isolation function is the same. Containment isolation is always considered to be a safety function. The only remaining question is when the isolation function needs to be performed.
Let us reverse the order and first discuss the role of the containment isolation valves for a non-safety system. For this system class, it is normally assumed that the need for the system function ceases when the need for containment isolation is identified. Receipt of a containment isolation signal will cause the containment isolation valves to automatically actuate.
This satisfies the containment function while at the same time ending the nornial functioning of the system.
The safety system containment isolation philosophy is quite similar. The difference relates to the priority of the function. Unlike for a non-safety system, the safety system function dces not cease when the need for containment isolation is identified. The safety function simply takes priority over containment isolation. As long as the system is able to provide
Contact:
J. Kudrick. SCSB/DSSA 415-2871 1 0 9709170131 970410 i
PDR ADOcK 05000302
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e 4-Equally limportant'to the ability to change valve position is knowing when- ,
to initiate containment isolationi Sufficient instrumentation should be available to the operator for-this purpose. This would include leak . .
detection as well as sufficient discrimination to determine which system !
is leaking.
QUESTION 4 If the answer to Question 3 is yes. are manual actions an acceptable
-means of meeting this requirement?
BESPONSE Manual action is an acceptable means for meeting this requirement. But.
it should be remote manual and normally from the control room.
With respect to the acceptability of the accumulators that exist within the ,
plant we are currently discussing this issue with the licensee. We will report resolution in a future amendment, I DJSTRIBUTION:
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its safety function, containment isolation should.not be implemented.
However, if the system is not able to perform its safety function, then containment isolation becomes its number one priority.
By having the safety system function take first priority eliminates the need for automatic containment isolation. Remote isolation 1s-the accepted mode for this type of system. With remote isolation capability, however, comes the need to know when isolation is needed. This generally means leak detection and some means to determine system operability.
Once it is determined that the safety function is not operable, containment isolation becomes the number one priority. The operator is trained to properly isolate the system which means closing bcth containment isolation valves.
Now let us look at the requirements to isolate. The function must be fully safety grade. This means that the instrumentation, motive power, actuator, and valve must be all safety grade. If the valve is motor operated. it should be Class lE powered. For air power. the valve should either close upon loss of air supply or the supply should be considered essential which generally implies an adequately sized accumulator that will assure valve closure for 30 days.
Therefore, for systems with a dual requirement, the valves can and probably will have a two )osition criteria, To satisfy the safety system function, the valve position s1ould be o)en. However, to satisfy the containment isolation function, valve position slould be closed. Tn simply look at the safety system function to establish valve position meets only half of the valve requirements. Additionally, to power the valve actuator with a non-safety air supply is unacceptable when the failure position is open since the containment isolation function cannot be satisfied.
With this brief background, one can now discuss the specific questions contained with the TIA request. Specifically, Region IV has identified the following questions:
OUEST10N 1 Does the licensee comply with the requirements of Criterion 57 (i.e., do the containment spray and component cooling water containment penetration valves have a closed safety function? In particular, are the air-operated valve accumulators required to maintain the valves closed on a loss of non-safety related instrument air?
RESPONSE
The valves in question have dual requirements. For the system safety function, the valves have an open function to assure the operability of the system when needed. However, the valves also have a containment isolation function when called upon. Under this sequence, the valves have a closed function. As discussed above, the system safety function has first priority. Therefore the fail open design is appropriate. But.
the containment isolation function is equally important when the c
This means that the air supply should be-situation calls for isolation.
safety. grade to minimize the times when one loses the air sup)ly to the T1e design valve which also loses the containment isolation function.
needs safety accumulators to assure an air supply in the event of loss of non-safety instrument air, for this reason. It is unacceptable to have non-safety instrument-air without a safety backup system.
OUEST10N 2 Would similar valves for containment penetrations subject to the requirements of Criteria 55 and 56 also have a closed safety function for containment isolation, even if, the position of greater safety of the valve is to open?
RESPONSE
'All containment isolation valves subject to the requirements However, ofit is quite Criteria 55 and 56 have a closed sbfety function.
misleading to state that the position of greater safety of the valve is to open. These valves under discussion have a dual requirement; performance of the system safety function and the containment isolation Therefore for the function. Each function is a separate responsibility.
But for system safety function, the position of greater safety is open.
the containment 1 solation function, the position of greater safety is ariority the valve should closed. Since the system function has first fail open upon loss of air. However, since tie containment isolation position of greater safety is closed, the air supply should be as reliable as possible to minimize the probability of the loss of air.
This is translated to mean safety grade.
QUESTION 3 1s the licensee required to have the capability of remote manual closure of the containment penetration valves with a safety injection actuation si.gnal and/or containment spray actuation signal present?
RESPONSE
The simple response is yes. The licensee is required to be able to remotely close the valve at any time during the transient. This is particularly important if the safety system has a burned in signal to stay open to maintain the safety system function. The solution is to design the logic such that a switch in the control room can be actuated to over ride this open signal. An example of such a design can be found on the containment isolation valves connected to an external recombiner.
Normally the valves are in a closed position. To allow the recombiner to become operational, these valves must be opened even though there exists a containment isolation signal. This override logic eliminates the need to jumper the connections within the control cabinet which would be necessary without this control logic.
O s-(
4 Equally important to the ability to change valve position is knowing when.
to initiate containment isolation. Sufficient instrumentation -should be available to the operator for this purpose. This would include leak detection as well as sufficient discrimination to determine which system is-leaking, t OUrSTION 4 If the answer to Question 3 is yes, are manual actions an acceptable means of meeting this requirement?
RESPONSE
Manual action is an acceptable means for meeting this requirement. But, it should ha remote manual and normally from the control room.
With respect to the acceptability of the accumulators that exist within the plant, we are currently discussing this issue with the licensee. We will report resolution in a future amendment.
+