Summary of Meetings Held on 9/18-20/79 to Discuss Potential Unreviewed Safety Question on Systems Interaction for B&W Pl (Generic Letter 79-49)


                              UNITED STATES 
                         WASHINGTON, D. C. 20555  

                             October 5, 1979 


          (I&E INFORMATION NOTICE 79-22) 

I.   Introduction 

     A series of meetings was held with all four light water reactor vendors
     and the corresponding utilities to discuss the effect of I&E 
     Information Notice 79-22 on nuclear power plant owners. I&E Information 
     Notice 79-22, issued on September 14, 1979, notified the nuclear 
     industry of a potential unreviewed safety question at Public Service 
     Electric and Gas Company's Salem Unit 1 nuclear facility. The meetings 
     were held in the Bethesda offices of the NRC according to &he following 
               Westinghouse - September 18, 1979 
               Combustion Engineering - September 19, 1979 
               Babcock and Wilcox - September 20, 1979; a.m. 
               General Electric - September 20, 1979; p.m. 

     The Nuclear Regulatory Commission staff was seeking additional 
     information from operators of all nuclear power plants on a potential 
     unreviewed safety question involving malfunctions of control equipment 
     under accident conditions. This equipment consists of electrical 
     components used for reactor and plant control under normal operating 

     Some of this equipment could be adversely affected by steam or water 
     from certain pipe breaks, such as in the main steam line inside or 
     outside plant containment buildings. The consequences of a control 
     system malfunction could result in conditions more or less severe than 
     those previously analyzed. The NRC staff Intends to determine the 
     degree to which the validity of previous safety reviews are affected 
     and whether changes in design or operating procedures will be required. 

II.  Background 

     As part of the Westinghouse Environmental Qualification Program, IEEE 
     323-74 has been reviewed, in particular, sections dealing with 



     interactions. Westinghouse design philosophy is that if a component is 
     necessary to function in order to protect the public, it is 
     "protection" grade. Should a non-protection grade component perform 
     normal action in response to system conditions, it must be shown to 
     have no adverse impact on protection grade component response. If a 
     component did not receive a signal to change state, it was assumed to 
     remain "as is". Part of the environmental qualifications require the 
     demonstration that severe environments will not cause common failure of 
     "protection" grade components. An outgrowth of the environmental 
     qualification program review was a defemination if the severe 
     environment can cause a failure of a non-protection grade component 
     that was previously assumed to remain "as is" and alter the results of 
     the design basis analysis. 
     Westinghouse formed an Environmental Interaction Committee whose 
     charter was to identify, for all high energy line breaks and possible 
     locations, the control systems that could be affected as a result of 
     the adverse environment and whose consequential malfunction or failure 
     could exceed the safety limits previously satisfied by accident 
     analyses presented in Westinghouse plants' SARs. The Committee was also 
     to establish, for any adverse interactions identified, recommendations 
     to resolve the issue. The assumed ground rules for the investigations 
     performed by Westinghouse are enumerated on page five of Enclosure 2. 
     The investigation resulted in a compilation of potential control system 
     consequential failures (due to environmental considerations) which 
     affected plant safety analyses. The investigation considered seven 
     accident scenarios and seven control systems interactions in a matrix 
     form, as shown on page 6 of Enclosure 2. The accidents are: 1) small 
     steam line rupture; 2) large steam line rupture; 3) small feedline 
     rupture; 4) large feedline rupture; 5) small LOCA, 6) large LOCA; and, 
     7) rod ejection. The control systems are: 1) reactor control; 2) 
     pressurizer pressure control; 3) pressurizer level control; 4) 
     feedwater control; 5) steam generator pressure control; 6) steam dump 
     system control; and 7) turbine control. 
     The investigations identified potential significant system response 
     interactions in the: 

          a.   steam generator power operated relief valve control system; 

          b.   pressurizer pressure control system; 

          c.   main feedwater control system; and, 

          d.   rod control system. 

III. Discussion 

     A.   The first In the series of meetings was with Westinghouse and 
          utilities that own Westinghouse reactors. The meeting was attended
          by seventy (70) persons representing the NRC, PSE&G along with 
          nine other utilities, Westinghouse and the other three light water 
          reactor vendors, utility owner groups, four A/E consultants, the 
          ACRS, AIF and EPRI. The list of attendees is presented as 
          Enclosure 1. 
          Westinghouse's presentation is included as Enclosure 2. 

          During the Westinghouse meeting, they identified, for all 
          high-energy line .


breaks and possible locations, the control systems that could be affected as
a result of the adverse environment and whose consequential failure could 
invalidate the accident analyses presented in Westinghouse plants' SARs. 
Recommendations were also presented for resolving the adverse interactions 

Westinghouse's investigation identified seven accidents and seven control 
systems that could possibly interact and presented them in a matrix form as 
shown in Enclosure 2, page 6. As can be seen the potential interactions that
could degrade the accident analyses are in the: 

     a.   Automatic Rod Control System 

     b.   Pressurizer PORV Control System 

     c.   Main Feedwater Control System 

     d.   Steam Generator PORV Control System 

Westinghouse stated that the possible matrix interactions may increase as 
more detailed analyses are performed but the interactions will remain for 
all of their plants and the interactions may be eliminated only if 
conditions are such that plant specific designs mitigate the interactions 
because of: 

     a.   system layout; 

     b.   type of equipment used; 

     c.   qualification status of equipment utilized: 

     d.   design basis events considered for license applications; and, 

     e.   prior commitments made by utility to the NRC. 

The Westinghouse analysis did not consider plant operators as part of the 
control systems nor was the time allotted for operator "inaction" 
considered. The assumed operator action times, as stipulated in plant 
analysis, were used without modification. Equipment in a control system or 
part of a control system was assumed to fail as a system in the most adverse 
direction for conservatism. Westinghouse stated that the possible matrix 
interactions will remain for all of their plants and the interactions may be 
removed only if conditions are such that plant specific designs mitigate the 
interactions because of: 

     a.   system layout; 

     b.   type of equipment used; 

     c.   qualification status of equipment utilized; 

     d.   design basis events considered for license application; and, 

     e.   prior commitments made by utility to the NRC. 

It should be noted that Westinghouse only analyzed accidents and not 


Further, long-tem investigations may be required to analyze the transient 
cases. Initial conditions and assumptions are shown on pages 5, 7, 9, 14, 
15, 22, 23, 27, 28, 33, 37 and 38. 

Westinghouse presented their analyses for the four control systems 
identified as follows: 

A.   Steam Generator Power Operated Relief Valve Control System 

     The areas of concern for this system are: 

     1.   multiple steam generator blowdown in an uncontrolled manner; 

     2.   loss of turbine driven auxiliary feedwater pump; and, 

     3.   primary hot leg boiling following feedline rupture. 

     The assumptions used are presented on page 15 of Enclosure 2. Potential
     solutions to the Steam Generator PORV Control System interaction 
     problems were presented as both short term and long term. The 
     short-term solutions are to: 

     1.   investigate whether the SG PORV Control System will operate 
          normally or fail in a closed position when exposed to an adverse 
          environment; and, 

     2.   modify the operating instructions to alert operators to the 
          possibility of a consequential failure in the SG PORV Control 
          System caused by an adverse environment. 

     If evident, close block valves In the relief lines. 

     The long-term solutions are: 

     1.   redesign the SG PORV Control System to withstand the anticipated 

     2.   relocate the SG PORVs and controls to an area not exposed to the 
          environment resulting from ruptures in the other loops; 

     3.   install two safety grade solenoid valves in each PORV to vent air 
          on a signal from the protection system, thereby ensuring that the 
          valve will remain closed initially or will close after opening; 

     4.   install two safety grade MOVs in each relief line to block venting
          on signal from the protection system. 

     Westinghouse presented similar analyses for the other three control 
     systems along with the assumptions, areas of concern and potential 
     solutions. These are presented in Enclosure 2. 

          a.   Steam Generator PORV Control System pp. 14-21, Enclosure 2. 


          b.   Main Feedwater Control System pp. 22-26, Enclosure 2, 

          c.   Pressurizer PORV Control System pp. 27-32, Enclosure 2. 

          d.   Rod Control System pp. 37-42, Enclosure 2. 

     At the end of Westinghouse's presentation, the NRC staff caucused to 
     discuss their future plans and actions. When all attendees reconvened 
     the meeting was opened to discussions of the impact of the NRC 10 CFR 
     50.54(f) letter, vendor and utility plans, and staff plans. 

     Westinghouse stated that they would establish an action plan along the 
     guidelines of NUREG-0578. Westinghouse also stated that their 
     investigations were carried further than FSAR analyses and they would 
     need to evaluate consequential failures on a realistic basis; this 
     evaluation may eliminate some problems. Westinghouse stated that their 
     investigations are lower probability subsets of SAR analyses which in 
     themselves are sets of low probability, Westinghouse expressed doubts 
     that a conclusive determination can be made of the qualification status
     of all of the involved equipment in 20 days. 

     Robinson plant representatives noted that their secondaries are open 
     and therefore breaks outside of containment present no problem. They 
     indicated their basic approach to answering the 20-day letter will be 
     to follow the  short-term Westinghouse recommendations. 
     Representatives of Salem also stated that their intent is to follow the
     short-term Westinghouse recommendations to satisfy the request of the 
     20-day letter. 

     Utility representatives stated that they will respond to the 20-day 
     letter by addressing the four control systems identified in a manner 
     suggested by the Westinghouse recommendations unless the NRC staff 
     provides directions to the contrary and further established guidelines 
     stating their position on the problem along with their recommendations.

B.   The second in the series of meetings was held with Combustion 
     Engineering and utilities that own CE's reactors. The meetings were 
     attended by 52 persons representing the NRC, all four light water 
     reactor vendors, five utilities, various consultants, the ACRS, AIF and
     EPRI. The list of meeting attendees is presented as Enclosure 3. 

     They explained the concerns presented by Westinghouse and the four 
     control systems that could be affected as a result of the adverse 
     environment of a high energy pipe break and whose consequential failure
     could invalidate the accident analysis of plant SARs. 

     Previous analyses did not specifically take control systems into 
     account in accident scenarios and the systems were considered passive 
     in the analyses. The staff explained its earlier understanding 
     regarding control systems interaction in accidents as one in which the 
     accidents were expected to be quick and the control systems did not 
     have the time to contribute significantly to the consequences. If most 
     of industry reviewed their accident analyses according to the staff 
     position on control system contribution, then a need does, in fact, 
     exist to further the scope of accident analyses to include potential 
     consequential failure modes of the 


     control systems. 

     Industry representatives stated that in the allotted 20 days, they 
     could only skim the surface in accident review with the inclusion of 
     control system interactions. An initial approach would be of a 
     mechanistic nature to determine what control system would be involved 
     and what type of hardware would be necessary to initiate fixes rather 
     than using an analytical approach to determine the contribution of 
     control systems on accident consequences. 
     Combustion Engineering's plans are to identify the control systems that
     could cause interactions and then look at resolutions to the problem on
     a per plant basis since some solutions are plant dependent. The action 
     process to be followed is presented as Enclosure 4 and is as follows: 

          1.   Identify those non-safety related control systems, inside and
               outside containment, whose malfunction could adversely affect
               the accident or transient when subJected to an adverse 
               environment caused by a high energy pipe break. 

          2.   Determine the limiting malfunctions and their impact during 
               high energy pipe breaks for those control systems. 

          3.   Determine the short tem and long tem corrective actions. 

     Combustion Engineering stated that in their plants, operation of 
     control systems is not required in order to mitigate the consequences 
     of the transients analyzed in Chapter 15. The analyses in Chapter 15 
     include the assumption that these control systems respond normally to 
     each transient and that their operational mode is that which would be 
     most adverse for the transient under consideration. The consequences 
     produced by any credible malfunction of these control systems would be 
     less severe than any which would be produced by the mechanisms 
     considered as causes of the transients analyzed in Chapter 15. 
     Some discussion followed dealing with the failure modes of control 
     system and whether the failure mode is in the most adverse direction or
     in the design direction. Resolution of this topic was not obtained but 
     will be addressed on a plant-by-plant basis. 

     Again utilities presented their concerns over the 20-day letter and 
     what is expected of them in this time frame. They stated that in order 
     to follow the directions of the letter all components would have to be 
     reviewed to determine if the non-safety grade system failure mode would
     aggrevate the accident consequences. 
C.   The third in the series of meetings was held with Babcock and Wilcox 
     and utilities that own B&W reactors. The meetings were attended by 
     fifty-six (56) persons representing the NRC, reactor vendors, 
     seven-utilities, various consultants, the AIF and EPRI along with the 
     Union of Concerned Scientists. 


     The NRC staff explained  the background history leading up to the 
     "20-day" letter and the fact that they consider the problem a generic 
     one common to all LWRs. 

     The utility representatives stated that they will answer the letter 
     themselves without specific participation of the owners group, which 
     they consider germane only to TMI-2 related subject. Most of the work, 
     the detailed action plans of which have not yet been established, will 
     be performed by the various utilities and their architect engineers and
     consultants, with generic material supplied by the reactor vendor. 

     The utility representatives understand the environment to be plant 
     specific and will use that environment in their analyses for control 
     system failure. The system failure will include not only component 
     failure but also failure of transducers, wires, and hot and cold 
     shorts. The adequacy of fixes for the long-tern and the combination of 
     consequential failures is not expected to be considered in the allotted
     20 days. 
     Babcock and Wilcox representatives stated that in the past, evaluations
     were performed for the sequence of events leading up to the trip, a 
     time of about 5 to 10 seconds. Prior to that time the control systems 
     have no effect on the accident sequence or consequence. Failure of 
     control systems will be investigated in view of the severity of the 
     possible accident, if the control system failure increases the 
     consequences, then that system will be considered. 
     The approach proposed by B&W and the utilities is outlined in Enclosure
     6 and is as follows: 

          1.   Evaluate the impact of IE 79-22 on licensing basis accident 

          2.   Identify accidents which will yield the adverse environment. 

          3.   Define inputs and responses used. 

          4.   Verify conclusions and Justify continued operation. 

     The utilities will alert the plant operators to the potential failure 
     of the plant control systems in total or in providing correct 
     information. The abnormal and emergency procedures will be reviewed to 
     determine how failure of non-safety grade systems or improper 
     information will affect the prescribed operator action. 

D.   The fourth and final in the series of meetings was with General 
     Electric and utilities that own GE reactors. The meeting was attended 
     by 52 people representing the NRC, three reactor vendors, nine 
     utilities, architect engineers, consultants, and the AIF. The list of 
     attendees is presented as Enclosure 7. 
     The NRC staff presented highlights of the previous meetings and the 
     concerns identified by Westinghouse. The staff stated that a more 
     sophisticated evaluation of the accident analysis is required to see if
     the course and consequences of the accident are altered by 
     consequential failure of non-safety grade control systems. 


          General Electric representatives stated that their analyses have 
          considered high energy pipe breaks in many locations and are more 
          detailed since BWRs have a larger number of pipes inside and 
          outside containment carrying radioactive liquids. The BWR leak 
          detection capabilities are correspondingly greater. Special 
          attention is given to separation criteria viz., various systems 
          are in separate cubicles and inside a class 1 secondary as well as 
          primary containment. 

          The high energy line break is not considered a problem. In 1970, 
          Dresden 2 experienced opening of a safety valve and a resulting 10
          psi and 340 F environment. The equipment was examined and the 
          qualifications were subsequently upgraded. 

          GE representatives stated that they performed sensitivity studies 
          on their non-safety grade systems to determine if they are heavily
          relied upon during an accident. The studies revealed that there 
          was no heavy dependence upon those systems. 

          It must be noted that the CE non-safety grade system and 
          components comprise only approximately 25% of a typical plant 
          total. The utilities will perform their own analyses on BOP 
          systems to satisfy the requirements of the "20-day" letter. 
IV.  NRC Comments 

     The NRC staff stated that they understood the requests by the nuclear 
     industry regarding position and direction the request found in the NRC 
     10 CFR 50.54(f) letter dated September 17, 1979 but would wait until 
     the conclusion of the scheduled meetins with all four light water 
     reactor vendors. The staff further stated a Commission Information 
     paper would be prepared discussing the staff's judgment regarding the 
     magnitude of the concern and the appropriateness of industry's response
     for resolution of the problem. 
     More specific staff statements were made in terms of generating a plant
     specific matrix of potential environmental interactions of control 
     system for each plant. The NRC requested that they be notified of 
     further analyses and the individuals that will perform them either 
     reactor vendors, the owners groups, or the individual utilities. 

     The NRC noted that at this time, it is not evident which utilities are 
     faced with what environmental interaction problems. The effects of 
     implementing all of the Westinghouse recommended short-term "fixes" may
     be contradicted by other sequences. Multiple failure analyses could be 
     performed but this would take months and could not possibly be ready in
     20 days. 

     The NRC recommended that utilities check if qualified equipment is in 
     place to determine the magnitude of a total qualification program. 

     The staff advised the utilities to check the validity of their 
     operating procedures in light of the steam environment around various 
     components and the reliability of certain control valves in question; 
     also, use should be made of all information available in files of 
     vendors, A/Es, and consultants dealing with the problem. 


     The staff is aware that sufficient time is not available to identify 
     all of the potential interactions but some of the more obvious ones 
     must be reviewed. For example, some utilities might choose to operate 
     their plants in the interim period using a manual rod mode instead of 
     the preferred automatic mode; also, the PORV block valves may be 
     operated in the closed position. The determination of what systems are 
     suspect and the possible 20-day solutions must be answered by each 
     individual utility according to their plant design. Operator training 
     would have to be stressed to make the operators aware that potential 
     consequential failures may exist that would mask the real failure and 
     give erroneous readings. 
     The staff stated that for the "20-day" letter response, the utilities 
     should use engineering judgment and evaluations instead of detailed 
     analyses that would be time consuming and might limit the utility 
     response to a limited number of evaluations. 

V.   Conclusions 

     The staff indicated that there were three possible options that could 
     be followed in providing a short-term response. 

          1.   Qualify equipment to the appropriate environment; this would 
               take longer than 20 days and would, more likely, for most 
               utilities be a long-term partial solution. 

          2.   Short-term fixes should be in place pending long-term 
               solutions. It must be noted that In this situation some 
               components that are relied upon to work properly might be 
               wiped out by consequential failures under certain conditions 
               and accident sequences. 

          3.   The "worst case" plant should be selected and a bounding 
               analysis performed to determine the time frame available for 
               qualification of equipment. 

     The staff reiterated the presented recommendations, possible interim 
     solutions that are plant specific, and in addition,,requested the 

          1.   Identify equipment and control systems which are either 
               needed to mitigate the consequences of a high energy pipe 
               break or could adversely affect the consequences of these 
          2.   Check the locations, expected environment, and environmental 
               qualifications of the equipment and control system identified
               in part 1. 

          3.   If some of these are found not be qualified for the 
               environmental conditions, propose an appropriate fix, i.e., 
               design change, change in operating procedures, acceptable 
               consequences argument based on your evaluation, etc. Provide 
               a schedule for the proposed fix. 

                                   George Kuzmycz, Project Manager 
                                   Division of Project Management 

                              ENCLOSURE 1 
                            MEETING ATTENDEES 

       NRC                              WESTINGHOUSE 
     D. Ross                              K. Jordan 
     D. Eisenhut                          R. Sero 
     J. Heltemes                          R. Steitler 
     G. Kuzmycz                           G. Lang 
     J. Guttmann                          G. Butterworth 
     W. Jensen                            V. Sluss 
     S. Israel                            F. Noon 
     G. Lainas 
     V. Benaroya                          PSE&G Co. 
     R. Woodruff                          F. Librizzi 
     A. Dromerick                         R. Mittl 
     B. Smith                             J. Wroblewski 
     M. Grotenhuis                        J. Gogliardi 
     A. Schwencer                         P. Moeller 
     P. Norian                            R. Fryling 
     F. Orr 
     F. Odar                                 VENDORS 
     T. Dunning                           N. Shirley - G.E. 
     W. Gammill                           W. Lindblad - G.E. Portland 
     S. Salah                             R. Borsun - B&W 
     J. Stolz                             C. Brinkman - C.E. 
     Z. Rosztoczy 
     T. Novak                                UTILITIES 
     J. Beard                             D. Waters - CP&L 
     M. Cliramak                          M. Scott - Con. Ed. 
     D. Tondi                             G. Copp - Duke Power 
     C. Berlinger                         N. Mathur - PASNY 
     L. Kintner                           J. Barnsberry - S. Cal. Ed. 
     J. Mazetis                           K. Vehstedt - AEPSC 
     K. Mahan                             R. Shoberg - AEPSC 
     D. Thatcher                          E. Smith - VEPCO 
     J. Burdoin                           T. Peebles - VEPCO 
     P. Mathews                           P. Herrmann - Southern Co. Services
     M. Lynch                             W. House - Bechtel
     R. Scholl  						     T. Martin - Nutech
                                          J. McEment - Stafeo  
                                          M. Wetterhahn - Conner, Moore & Corber 
                                          K. Layer - BBR 
                                          E. Igne - ACRS  
                                          P. Higgins - AIF 
                                          R. Leyse - EPRI 


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