ML17279A771

Proposed Tech Specs Transferring Control of RHR V-8 to Alternative Remote Shutdown Panel During Normal Operation & Clarifying That Action a.2 Not Applicable to RHR V-8

ML17279A771
Person / Time
Site:	Columbia
Issue date:	01/05/1988
From:	WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:
Shared Package
ML17279A770	List: ML17279A769 ML17279A771
References
TAC-66927, NUDOCS 8801130217
Download: ML17279A771 (14)

Text

TABLE 3.3.2-1 (Continued)

I SOLAT ION ACTUATIOtl I NSTAUIIENTATION VALVE GROUPS HINIHUH APPLICABLE OPERATED BY OPERABLE CIIANtIELS OPEAATIOtIAL TRIP FUNCTION SIGNAL PER TRIP ST~STEW a CONDITION ACTION

4. REACTOR CORE ISOLATION COOLING SYSTEH ISOLATION

a. RCIC Steam Line Flow - High 8 1 1, 2, 3 22

b. RCIC/RHR Steam Line Flow - High 8 1 1, 2, 3 22

c. ACIC Steam Supply Pressure - Low 8, 9 2 1, 2, 3 22

d. RCIC Turbine Exhaust Diaphragm Pressure - High 8 2 1, 2, 3 22

e. RCIC Equipment Room Temperature

- Iligh 8 1 1,2,3 22

f. RCIC Equipment Room h Temperature - tligh 8 1 1,2,3 22

g. RWCU/RCIC Steam Line Routing Area Temperature - lligh 8 1 1, 2, 3 22

h. Drywell Pressure - High 9 2 1, 2, 3 22

i. Hanual Initiation(h) 8 1 1, 2, 3 24

5. RIIR sYsTEH sIIUToowN a.

cooLING Reactor Vessel Water HGRE 150LRTIGII (jj ~A+cE Level - Low, Level 3 6 2 1,2,3 26

b. Reactor Vessel (RIIR Cut-in Permissive) Pressure - High 6 1 1, 2, 3 26

c. Equipment Area Temperature - High 6 1 1, 2, 3 26

d. Equipment Area Venti1 ation h Temp. - High 6 1 1, 2, 3 26

e. Shutdown Cooling Suction Flow Rate High 6 1 1, 2, 3

f. RIIR Heat Exchanger Area Temperature - High Room 606 6 1 1, 2, 3 26 Room 507 6 1 1, 2, 3 26 Room 605 6 1 1, 2, 3 26 Room 505 6 1 1, 2, 3 26

g. Hanual Ini tiation 6 1/group 24 8801130217 8801oS>7 PDR ADDCN, 050 PDR P

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TABLE 3.3.2"1 (Continued)

ISOLATION ACTUATION r NSTRUMEHTATIOH ACTION STATE!iiEHTS ACTION 20 Be in at least HOT SHUTOGWH within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLO SHUTQGWN within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

ACTION 21 Be in at least STARTUP with the associated isolation valves closed within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> or be in at least HOT SHUTQOWH within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLO SHUTOOWN within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

ACTION 22 Close the affected system isolation valves within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and declare the affected system inoperable. ~

ACTION 23 Be in at least STAPTUP within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

ACTIOH 24 Restore he manual initiation function to OPERABLE status within B hours or close the affec ed system isalation valves within the next haur and declare the affected system inoperable or be in at leas- HOT SHUTOOWN within the nex ~M hours and in COLO SHUTQGWH within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

ACTION 25 Establish SECONOARY CONTAINMENT INTEGRITY with the standbv gas treatment system aperating within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

ACT;ON 26 Lock close or close, as applicab)e, the affected system isolation valves within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and declare the affected system inoperable.

TABLE NOTATIONS

'May be bypassed with reactcr steam pressure < 1037 psig and all tur'bine stap valves closed.

" <<hen handling irradiated fuel in the secondary containment and during CORE ALTERATIOHS and operations with a potential for draining the reac ar vessel.

~Guring CORE ALTERATIONS and operations with a potential for draining the reactor vesseI.

(a)A channel may be placed in an inoperable status for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> surveillance without placing the rip system in the tripped con- for'equired dition provided at least ane 'other OPERABLE cnannel in the same trip sys em is monitoring that parameter.

(b)Also actuates the standby gas treatment system.

(c)Also trips and isolates the mechanical vacuum pumps.

(d)A channel is OPERABLE if 2 of 4 detectors in that channel are OPERABLE.

(e)Also actuates secondary cantairment ventilation isola ion dampers per Table 3.6.5.2"1.

(f)Closes only RWCU system outboard isolation valve RWCU-V-4.

(g)Only va1ves RHR-V-123A and RHR-V-123B in Valve Group 5 are required ror pr.'mary i so 1 ation.

(h)Manual initiation isolates RCIC"V-B only and only with a coincident reactor vessel level-low, level 3.

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TABLE 3.6.3-1 (Continued PRIMARY CONTAINMENT ISOLATION VALVES MAXIMUM ISOLATION TIME VALVE FUNCTION AND NUMBER VALVE GROUP(a) Seconds)

Automatic Isolation Valves (Continued)

Reactor Closed Cooling 60 RCC-V-5 RCC-V-21 RCC-V-40 RCC-V-104 Radiation Monitoring Supply 8 Return PI-VX-250 PI-VX-251 PI-VX-253 PI-VX-256 PI-VX-257 PI-VX-259 Residual Heat Removal RHR-V-123A, B(g) 5. 15 RHR-V-8(g) (K5 6 40 RHR-V-9(g) 6 40 RHR-V-23(g) 6 90 RHR-V-53A,B(g) 6 40 RHR-V-24A,B(c) 10 270 RHR-V-21 10 270 RHR-V"27A,B(c) 10 36 Reactor Mater Cleanup System RMCU-V-1(d) 30(j)

RMCU-V-4 21(3)

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TABLE 3.6.3-1 (Continued)

PRIMARY COHTAINMEHT ISOLATION VALVES MAXIMUM ISOLATION TIME VALVE FUNCTION AND NUMBER VALVE GROUP a Seconds) n I d. Other Containment Isolation Valves (Continued) m Radiation Monitoring N.A.

PI-EFCX-72f P I-EFCX-73e Transversing Incore Probe System N.A.

TIP-V-6 TIP-V-7,8,9,10,11(e)

TABLE NOTATIONS

• But greater than 3 seconds.-

IIProvisions of Technical Specification 3.0.4 are not applicable.

(a) See Technical Specification 3.3.2 for the isolation signal(s) which operate each group.

(b) Valve leakage not included in sum of Type B and C tests.

(c) May be opened on an intermittent basis un'der administrative control.

(d) Hot closed by SLC actuation signal.

(e) Hot subject to Type C Leak Rate Test.

(f) tlydraulic leak test at 38.2 psig.

(g) Not subject to Type C test. Test per Technical Specification 4.4.3.2.2 (h) Tested as part of Type A test.

B (i) May be tested as part. of Type A test. If so tested, Type C test results may be excluded from sum of ID other Type 0 and C tests.

CL B

(j) Reflects closure times for containment isolation only.

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Refer ence 3)

RHR-V-8 5 V-9 CHRONOLOGY OF EVENTS

1. JUNE, 1983 - AMENDMENT NO. 31 TO WNP-2 FSAR In (}-040.079 the NRC required compliance with BTP RSB 5-1 to preclude a LOCA thru the Hi/Low Pressure Interface. It states in part:

"These two motor operated valves and their associated cable may be subject to a single fire hazard."

In the Supply System's response, the acceptability of RHR-V-8 and V-9 was specifically addressed.

This amendment was reviewed and accepted by the NRC with no conditions attached to our license, nor were there any additional questions and/or concerns identified in the SER or its supplements.

2. MAY 10, 1984 - LICENSEE EVENT REPORT 84-031 Notification of physical wiring problems and thermolagging/fire barriers associated with Safe Shutdown (SSD) path. No concerns were raised regarding Hi/Low Pressure Interface valves. Identified a cable that provides an isolation signal to RHR-V-123A that was not protected.

3. June 7, 1985, Letter to GC Sorensen from DF Kirsch (NRC Region V),

"Nonconformance of Safe Shutdown Equipment to Appendix R Require-ments." Referred, to LER 84-031 and requested further information regarding deficiencies found with respect to SSD in the event of a Control Room Fire. Requested response within 10 days, did not speci-fically address any valves.

4. June 17, 1985, Letter to DF Kirsch from GC Sor ensen. Response to NRC Region V request (item 3 above), included description of seven defi-ciencies as well as proposed resolution (Attachment A).

Deficienc (No. 7 in letter)

In the Control Room, the physical separation between the control switches for two series high-to-low pressure system interface valves (RHR-V-53A and RHR-V-123A) is not sufficient to preclude hot shorts from opening both valves simultaneously and failing the low pr essur e safe shutdown system during a Control Room fire.

Pro osed Resolution:

One of the two series valve control circuits will be routed to a transfer switch located in the Remote Shutdown Room allowing isola-tion. Operation of this transfer switch will be specified in the Main Control Room evacuation procedure.

5. March 14, 1986, Letter to GC Sorensen from DF Kirsch (NRC Region V).

NRC prepared and issued an SER relative to the nonconformance issue identified in references 3 and 4 above.

"As indicated in the enclosed SER, the NRR staff has found the Supply System's proposed resolutions to be acceptable with the proviso that the transfer switch to be located outside the control room (see Defi-ciency 7, Reference 2) normally should be set in the "isolate" posi-tion. We suggest that you obtain verification that the Supply System accepts and will implement this proviso."

"

Item seven deals with the potential opening of the high/low RHR pressure interface due to a control room fire generating an open signal to both valves RHR-V-53A and RHR-V-123A which are in series.

As an interim measure, the licensee must remove power from one of these valves, such as by opening the breaker to the valve. Although this is an acceptable means to resolve the high/low pressure interface problem the licensee has proposed installing a transfer switch outside of the control room in order to isolate one valve from the control room in the event of a fire in the control room. This is acceptable provided that the transfer switch is maintained normally in the "iso-late from the control room" position., >Pending acceptance of this interim measure, the interim measures and corrective actions are acceptable,"

6. A ril 4, 1986 NRC Re ion V Ins ection Re ort No. 86-05 Item 4.4.2 (page 8) of this report indicated that the Licensee had determined that three sets of'HR .system valves need analysis and protection. The NRR (Region V) stated that RHR-V-53A and 123A should be de-energized.

"Several potential candidates were identified and discussed with the licensee. The licensee was able to resolve all concerns with the additional valves emphasis added .

7. April 24, 1986 - Generic Letter 86-10 issued. This GL was surrounded by controver sy and confusion as evidenced by the workshops that were held around the country prior to its issuance.

The staff's present position with regard to RHR-V-8 and V-9 appears to be based solely on an interpretation of this generic letter.

8. May 23, 1986, Letter to GC Sorensen from EG Adensam, "WNP-2 Fire protection - Request for Additional Information" NRR requires fur ther signal/spurious automatic function loss evalua-,

tion.

9. June 11, 1986 meeting with NRC in Bethesda to discuss NRC's request for additional information. First indication that there may be valves, other than those noted in the April 4, 1986 inspection report, of concern to NRR.

10. June 30, 1986, Letter, G02-86-613, GC Sorensen to EG Adensam, "WNP-2 Fire Protection Program - Request for Additional Information".

Response to 12 questions from NRC (nothing rel ated directly to RHR-V-8/V-9).

Supply System reiterates single failure analysis approach (guestion 5) ll. June 1986 During this month the Supply System had numerous telephone conversa-tions with John Ridgley in which we specifically discuss RHR-V-8 and V-9 and our technical and licensing bases for not being required to remove power.

12 July 16, 1986, Letter, G02-86-656, GC Sorensen to EG Adensam, "Final Resolution of Hi/Low Pressure Interface Concern" This is response to NRC's SER dated March 14, 1986. This appears to be first formal indication that multiple spurious actuations must be considered with respect to Hi/Low Pressure Interface valves.

13. August 1986 - NRC Region V Inspection 86-25 dated December 29, 1986.

RHR valve position noted as an open item, deferred to NRR for resolution.

14. Due to direct interaction with representatives from NRR and Region V at the August 1986 inspection exit meeting a letter committing to remove power, as suggested by the NRR repr esentative, was drafted.

Simultaneously, a hurried change was made to the FSAR (Amendment 37),

which contained an error in referring to power removal as the preferred approach. During the review of the draft response, safety ramifications not previously recognized were identified that required us to reconsider removing power from RHR-V-8.

A decision was made to continue to interact with the staff to reconcile or obtain satisfactory justification for modifying the RHR-V-8 design.

15. October 20, 1986, Letter EG Adensam to GC Sorensen "Request for Addi-tional Information" In item 7, Hi/Low Pressure Interface in RHR System the NRC requested:

a) Document your commitment to remove power from the RHR-V-8 valve during non-shutdown operating conditions.

b) Document your commitment to remove the power from the RHR-V-123A and RHR-V-1238 valves either at the valve or at the MCC.

c) Provide a schedule and justification for the schedule to imple-ment items a) and b) above.'6.

December 1, 1986, Letter, G02-86-1049, GC Sorensen to EG Adensam "INP-2 Fire Protection, Request for Additional Information",

o Removed power from RHR-V-123A 8 V-123B o Reconfirmed position contained in our response of July 16, 1986 (i.e.- do not intend to remove power). Provided additional tech-nical and regulation based justification.

17. April 7, 1987 - NRC Region V Inspection Repor t 87-02 (participants included Adensam, Ridgley, Campe, Hulman, et al).

Item 2.G - Hi/Low Pressure Interface Analysis specifically addressed RHR-V-8 and V-9.

Per EG Adensam, NRR assumed responsibility to resolve regulatory con-flicts and provide specific direction addressing those conflicts.

18, Hay 13, 1987, Letter G Kni ghton to GC Sorensen, "Compl i ance with Requirements of Appendix R to 10CFR50 Regarding Prevention of LOCAS at Hi/Low Pressure Interfaces."

"We (NRC) are advising you that we require WPPSS to implement appr o-priate modifications to these isolation valves (RHR-V-8 and V-9) as soon as practical...."

Further asked us to advise of planned modifications to ensure isola-tion as well as schedule for completion.

19. June 3, 1987,'etter G02-87-190, GC Sorensen to NRC, "Response to Generic Letter 86-10 Interpretation of Hi/low Pressure Interface Concerns".

Supply System committed to provide preferred option by mid-August

20. August 20, 1987, Letter, G02-87-232, GC Sorensen to NRC, "Resolu-tion of Generic Letter 86-10 Hi/Low Interface Concern" Identified providing a transfer switch on the remote shutdown panel for the RHR-V-8 valve as the preferred method. Also identified by-passing the RHR permissive interlock as an unreviewed safety question, and pointed out the need for a T/S change to Table 3.3.2-1.

21. October 21, 1987, Letter, GW Knighton to GC Sorensen, "WNP-2 Proposed Resolution of Spurious Opening of RHR-V-8 and RHR-V-9 in the Event of a Control Room Fire".

Acknowledged our preferred action to provide a tr ansfer switch on the remote shutdown panel and to have control of RHR-Y-8 transferred to the remote panel du'ring normal operation.

22 October 9, 1987, Information Notice No. 87-50 "Potential LOCA at High-and-Low-pressure Interfaces from Fire Damage".

The Supply System was totally surprised by the Information Notice issuance and is preparing a response to address the inaccuracies contained therein.