ML13099A447
| ML13099A447 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 04/10/2013 |
| From: | Duke Energy Carolinas |
| To: | Office of Nuclear Reactor Regulation |
| Boska J | |
| References | |
| Download: ML13099A447 (38) | |
Text
Apparent Violation of a License Condition on Fire Protection Condition on Fire Protection Oconee Protected Service Water (PSW)
(
)
System Milestones April 10, 2013
Duke Energy Participants
Preston Gillespie Senior Vice President Nuclear Operations gy p
Scott Batson Oconee Site Vice President
Tom Ray Oconee Plant Manager
Ed Burchfield Oconee Engineering Manager g
g g
Bob Guy Oconee Organizational Effectiveness Manager
Jim Fuller PSW Project General Manager
Eddie Anderson PSW Engineering Director
Eddie Anderson PSW Engineering Director
Chris Nolan Regulatory Affairs Director 2
Agenda Opening Remarks Scott Batson g
Opening Remarks Scott Batson Project Organization & Controls Tom Ray Schedule Considerations Ed Burchfield Overview of Milestones Ed Burchfield Closing Remarks Preston Gillespie 3
Opening Remarks Scott Batson 4
Opening Remarks Opening Remarks March 11, 2013, Oconee committed to full implementation of NFPA 805 on or before November 15, 2016 March 11, 2013, ONS committed to five interim milestones for the phased implementation of the PSW milestones for the phased implementation of the PSW system PSW implementation schedule is both aggressive and realistic PSW project completion has been identified site wide as one of the highest priorities for the site beyond safe one of the highest priorities for the site beyond safe operation of the Oconee Units Rigorous compensatory measures will remain in place to g
p y
p mitigate fire risk in the interim 5
Opening Remarks Lessons learned from project experiences are being Opening Remarks incorporated to expedite project completion Duke Energy is providing all necessary resources to complete the PSW project at the earliest opportunity complete the PSW project at the earliest opportunity Critical path field work is being worked around the clock Engineering activities are being worked on an expedited Engineering activities are being worked on an expedited basis Project dashboard has been established and updated kl t i
t il t
d weekly to measure progress against milestones and schedule adherence performance 6
Opening Remarks Milestone Schedule:
Opening Remarks Milestone Schedule:
10/01/2013 Commercial power path to SSF 07/18/2014 Power path from Keowee 10/01/2014 Power path from PSW to HPI system y
06/03/2015 Align PSW pump to steam generators 02/04/2016 PSW S t
l t 02/04/2016 PSW System complete 11/15/2016 Satisfy the requirements of NFPA 805 7
Opening Remarks Estimated Fire CDF Impact of Each Milestone Opening Remarks 100.00%
Cumulative Impact of Milestones on Fire CDF 38%
37%
22%
14%
13%
80.00%
40.00%
60.00%
0.00%
20.00%
Current Off site Pwr to Keowee Pwr to PSW Pwr to HPI PSW Pump PSW Complete NFPA 805 met 8
Current Off-site Pwr to SSF/ PSW Keowee Pwr to PSW PSW Pwr to HPI PSW Pump PSW Complete NFPA 805 met Estimated Cumulative Base Fire CDF Reduction
Project Organization & Controls Tom Ray Tom Ray 9
Project Organization & Controls Project Organization & Controls Management Oversight g
g Dedicated Project General Manager reporting to Senior VP Nuclear Operations Dedicated Project Engineering Director recently added Daily project progress reviews with ONS Site VP Daily project progress reviews with ONS Site VP and station leadership Weekly project progress reviews with fleet executive leadership NSRB / NOS (independent) project progress reviews reviews 10
Project Organization & Controls Project Organization & Controls Improvements in Project Execution p
j Project Command Center (PCC)
Dedicated Project Engineering Team Prioriti ation of project ork Prioritization of project work Improved metrics and project controls Site Ownership Site Ownership Project completion is Site Initiative Dedicated Site Projects Integration Manager and Team Creation of dedicated Design Basis Engineering Group and Manager Group and Manager 11
Project Considerations Ed Burchfield 12
Project Considerations Project Considerations PSW project structured to expedite field installation p
j p
First phase of engineering changes address installation, but not tie-ins to existing plant systems Completion of design packages for PSW/Plant Interfaces Completion of design packages for PSW/Plant Interfaces Work prioritization to support phased implementation for expedited risk benefits Resolution of vendor quality issues (conditional releases)
Dedicated team assigned to resolve remaining issues Engineer assigned to vendor facility Engineer assigned to vendor facility 13
Project Considerations Auxiliary Building / Reactor Building Cooling Solutions Project Considerations y
g g
g
Alternate cooling capability will be provided to portions of the Auxiliary Building (including Control Area Complex) and the Reactor Building
Cooling to the Auxiliary Building and Reactor Building relies upon the Low Cooling to the Auxiliary Building and Reactor Building relies upon the Low Pressure Service Water and/or Chilled Water systems, which are primarily located in the Turbine Building
Alternate cooling system will be located outside the Turbine Building
The project to install alternate cooling is being performed in two phases:
Phase 1 design is based upon a mission time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />
Phase 2 design will meet NFPA 805 requirements g
q 14
Project Considerations Project Considerations Engineering Change Process 15
Overview of Milestones Ed Burchfield 16
Milestone 1 C
i l th t th SSF Commitment B October 1 2013 PSW po er to the Standb Sh tdo n Facilit (SSF)
Commercial power path to the SSF
By October 1, 2013; PSW power to the Standby Shutdown Facility (SSF) will provide the following:
Commercial power source to the PSW switchgear
Power path from the PSW switchgear to the SSF
Power path from the PSW switchgear to the SSF
Ability to align the PSW power path to the SSF as required from SSF control room Milestone Definition C
i l f
d ill b bl f
idi l
t th
Commercial power feed will be capable of providing normal power to the PSW switchgear and backup power to SSF. Completed turnover of the commercial power line portion of the power feed from PSW Electrical Distribution System to the SSF This milestone will be satisfied with the Distribution System to the SSF. This milestone will be satisfied with the completion of the following activities:
System testing completed
Operations procedures in place Operations procedures in place
Operators trained
Technical Support Center (TSC) members trained 17
Milestone 1 C
i l th t th SSF Remaining activities to completion:
Commercial power path to the SSF Engineering Activities:
Complete restructuring of nine Engineering Change (EC) packages to support milestone turnovers including work orders and required Integrated Design Reviews
Clearance of PSW Building conditional releases for XPSW 600VAC MCC, CT7 10 MVA Transformer, B7T Switchgear, and 125VDC Power Distribution Center and Panel Boards Center and Panel Boards
Complete engineering analysis of testing results to validate system capabilities under SSF scenarios Complete turnover of the commercial power line portion of the power feed
Complete turnover of the commercial power line portion of the power feed from PSW Electrical Distribution System 18
Milestone 1 C
i l th t th SSF Remaining activities to completion:
Commercial power path to the SSF Field Work Activities:
SSF equipment tie-in activities & engineered electrical equipment power-up testing
Field work activities to support turnover of necessary EC Packages
PSW Building and PSW Building equipment (resolution of issues identified during testing and potential replacement / retest of equipment with procurement issues)
Auxiliary Building cable tray installation (raised floor grating and cable tray separators installation)
Licensing Activities:
None anticipated
None anticipated 19
Milestone 2 PSW f
K H d PSW power from Keowee Hydro Commitment
By July 18, 2014; PSW power from the Keowee Hydro Station (KHS) will provide equipment for:
KHS power path to the PSW switchgear P
th f th PSW it h t
th SSF
Power path from the PSW switchgear to the SSF
Equipment to align KHS power to the SSF from the PSW switchgear Milestone Definition
A power path is installed from the KHS through the PSW building to the SSF. Equipment is installed and field work completed including attendant control logic and instrumentation. This milestone will be ti fi d ith th l ti f th f ll i
ti iti satisfied with the completion of the following activities:
System testing completed
Operations procedures in place
Operators trained
Operators trained
Technical Support Center (TSC) members trained 20
Milestone 2 PSW f
K H d Remaining activities to completion:
PSW power from Keowee Hydro Engineering Activities:
Complete restructuring of EC Packages to support milestone turnovers, work orders to support full KHS testing and final SSF testing orders to support full KHS testing, and final SSF testing
Complete Integrated Design Review of SSF Power from KHS through PSW Building
Clear applicable conditional releases associated with PSW Building 10 MVA Clear applicable conditional releases associated with PSW Building 10 MVA Transformer CT6 and Neutral Grounding Resistor, PSW Building Switchgear B6T, PSW Building Switchgear B6T Transition Section, PSW Building 5MVA Transformer, and PSW Building 600VAC Load Center
Complete design reviews to evaluate KHS backup power to SSF for SSF scenarios 21
Milestone 2 PSW f
K H d Remaining activities to completion:
PSW power from Keowee Hydro Field Work Activities:
KHS Emergency Start Cable Re-route (KHU pre-outage and outage work tie-ins)
KHS AC Power Tie-ins (KHU Outage work)
Receive and install remaining engineered equipment: Keowee Junction Box Licensing Activities:
None anticipated 22
Milestone 3 PSW P t
HPI S t
I t ll d PSW Power to HPI System Installed Commitment
By October 1, 2014; PSW power to the High Pressure Injection (HPI) System will provide equipment for:
PSW power path to each units A&B HPI pumps
Equipment to start/stop the selected HPI pump from the associated Oconee
Equipment to start/stop the selected HPI pump from the associated Oconee control room
PSW power path to the associated valves for each unit
HP-26 (RCS Inlet Valve)
HP-24 (BWST Suction Valve)
HP-139 and HP-140 (RCP Seal Flow Valves)
RC-155, RC-156, RC-157 and RC-158 (SG Hot Leg Vent Valves)
RC-159 and RC-160 (RV Head Vent Valves)
Equipment to select the HP-24, HP-26, and RCS Vent Valves power source (normal station power or PSW power) from the associated Oconee control room 23
Milestone 3 PSW P t
HPI S t
I t ll d Milestone Definition PSW Power to HPI System Installed
A power path is installed from PSW building to the HPI System on each Oconee Unit. Equipment is installed and field work complete.
Functional verification of valve control circuits is complete. Testing of HPI P A
d B PSW P O
U it i l t HPI Pumps A and B on PSW Power on one Oconee Unit is complete.
This milestone will be satisfied with the completion of the following activities:
System testing completed as described above
System testing completed as described above
Operations procedures in place
Operators trained
Technical Support Center (TSC) members trained pp
(
)
24
Milestone 3 PSW P t
HPI S t
I t ll d Remaining activities to completion:
PSW Power to HPI System Installed Engineering Activities:
Complete required documentation for Main Control Board Addition and HPI S
C System Repowering EC Packages including work orders to support HPI System testing
Complete Integrated Design Review of HPI Power from Keowee Hydro Station through PSW Building Station through PSW Building 25
Milestone 3 PSW P t
HPI S t
I t ll d Remaining activities to completion:
PSW Power to HPI System Installed Field Work Activities:
PSW Power Feed (Power cable hookup to 600VAC MCCs and testing of MCCs)
HPI System Repowering
DC cable installation for all three units
Partial discharge testing of Unit 1 4160VAC power cable from PSW Building.
Termination of cable in manual alignment switch after partial discharge testing
Functional verification of valve control circuits and testing of HPI Pumps A and B on PSW Power Licensing Activities:
Licensing Activities:
None anticipated 26
Milestone 4 PSW P I
t ll d PSW Pump Installed Commitment
By June 3, 2015; PSW pump installed will provide equipment for:
PSW powered PSW pumps and flow path for providing water to each unit's SG
Equipment to start/stop the PSW pump from the Oconee Unit 2 control room
PSW power path to the associated valves required to establish a flow path from CCW to the SGs path from CCW to the SGs
PSW-6 (Isolation valve)
PSW-23 and PSW-25 (Flow Control Bypass Valves)
PSW-14 (Shared, Mini-flow Recirculation Valve)
(
)
PSW-22 and PSW-24 (Flow Control Valves)
Equipment to align a flow path from the CCW system through the PSW pumps to the SGs from the associated Oconee control room
27
Milestone 4 PSW P I
t ll d PSW Pump Installed Milestone Definition
PSW booster and high head pumps with piping, valves, and flow instrumentation installed and associated turnover to Operations complete to provide function equivalent to the station Auxiliary Service Water (ASW)
System Additional activities required for the pump to meet NFPA 805 System. Additional activities required for the pump to meet NFPA 805 requirements are provided in Milestone 5 and 6. Turnover of EC Packages for Phase 1 Cooling, PSW Pipe Header, PSW Pump Room, and Condensate Test Line is complete. This milestone will be satisfied with the completion of the following activities:
System testing completed
Operations procedures in place O
t t
i d
Operators trained
Technical Support Center (TSC) members trained 28
Milestone 4 PSW Pump Installed Remaining activities to completion:
PSW Pump Installed Engineering Activities:
Complete EC Packages and associated work orders for Phase 1 Cooling
Complete ECs for PSW Pipe Header, PSW Pump Room, and Condensate p
p p
Test Line and associated work orders
Complete supporting 10 CFR 50.59s
Complete Integrated Design Review of ASW Pump and Piping replaced by PSW Pump and Piping
Complete design reviews to evaluate CCW System response for PSW scenarios 29
Milestone 4 PSW P I
t ll d Remaining activities to completion:
Fi ld W k A ti iti PSW Pump Installed Field Work Activities:
Remove existing Station ASW System components and Station ASW Switchgear to make room for new PSW System Components P
f PSW S t
f ti l t ti d i t t d fl t
ti
Perform PSW System functional testing and integrated flow testing
Complete installation of Phase 1 AB/RB cooling equipment, currently planned to include:
T 500 t i
l d hill t id T
bi B ildi
Two 500 ton air-cooled chillers outside Turbine Building
Piping and valves to supply chilled water to 24 AHUs and 13 fan units
PSW power to chillers and AHUs
Diesel driven pump for feeding lake water to one RBCU on each Oconee unit Diesel driven pump for feeding lake water to one RBCU on each Oconee unit
Alternate PSW power supply for one RBCU on each Oconee unit
Complete turnover of EC Packages for Phase 1 Cooling, PSW Pipe Header, PSW Pump Room, and Condensate Test Line 30
Receive and install remaining engineered equipment
Auxiliary Building HVAC Control Panels and Heat Detectors
Milestone 4 PSW P I
t ll d Remaining activities to completion:
PSW Pump Installed Licensing Activities:
Respond to existing open PSW Request for Additional Information (RAI) targeted by July 1, 2013 g
y y
Provide timely response to potential future RAIs
Work with NRC to obtain SE for the PSW UFSAR and Technical Specification changes with a target need date of October 1, 2013
Submit report to the NRC required by Selected License Commitment (SLC) 16.9.9, Required Action C.1 prior to station ASW removal 31
Milestone 5 PSW S t
C l t PSW System Complete Commitment
By February 4, 2016; PSW system completion provides the following:
PSW power to station vital DC battery chargers providing DC power to controls and instrumentation to allow system control and monitoring from the control room for an extended period of time the control room for an extended period of time
PSW power to 400 kW of pressurizer heaters for each unit
Ability to select pressurizer heater power source (normal station power or PSW power) from the Auxiliary Building PSW power) from the Auxiliary Building
Auxiliary Building and Reactor Building equipment environments suitable for equipment operation
Ability to control and monitor HPI, PSW and SG heat removal from the Ability to control and monitor HPI, PSW and SG heat removal from the associated Oconee control rooms Milestone Definition
PSW System is installed as described in April 14 2010 NFPA 805
PSW System is installed as described in April 14, 2010, NFPA 805 LAR, turned over to Operations, and functional 32
Milestone 5 PSW S t
C l t Remaining activities to completion:
PSW System Complete Engineering Activities:
Complete EC activities for Phase 2 Reactor Building cooling solution
Complete EC packages for:
Repowering Pressurizer Heaters and Vital I&C Battery Chargers from PSW
Vital I&C Battery Chargers normal power supply cable re-route f
Pressurizer heater component environmental qualification
Perform Integrated Design Review of PSW backup power to pressurizer heaters and Vital I&C Battery Chargers Complete design re ie s of q alit / f nctionalit of PORV electrical
Complete design reviews of quality / functionality of PORV electrical components to support PSW scenarios 33
Milestone 5 PSW S t
C l t PSW System Complete Remaining activities to completion:
Field Work Activities:
Perform field work for Phase 2 cooling solutions
Diesel driven pump for feeding lake water to a second RBCU on each Oconee unit
Alternate PSW power supply for a second RBCU on each Oconee unit
Receive and install 600 VAC Automatic Transfer Switches C
l t fi ld k
i t d ith bl i f t
t l
d
Complete field work associated with cable infrastructure, manual and automatic transfer switches, pulling and terminating cable, installing power cables from PSW Building 600 VAC load center to manual transfer switches and cables to Vital I&C Battery Chargers y
g
Replace 600 VAC MCC breakers in the AB and East Penetration Rooms, cable and 600 VAC breakers inside the RB with components qualified to expected temperature environments 34 Licensing Activities
None anticipated
Milestone 6 NFPA 805 C li NFPA 805 Compliance Commitment
By November 15, 2016; Completion of all remaining support activities and documentation including items 23, 32, and 43 from Table 2.9-1 "Implementation Items" of the December 29, 2010, O
NFPA 805 S f t E l
ti R
t Oconee NFPA 805 Safety Evaluation Report Milestone Definition F ll li ith NFPA 805 Li C
diti D
Full compliance with NFPA 805 License Condition D 35
Milestone 6 NFPA 805 C li Remaining activities to completion:
NFPA 805 Compliance Engineering Activities:
Develop Variance From Deterministic Requirements (VFDRs)
Fire PRA updates Fire PRA updates
Analysis including pre-Fire Risk Evaluation (FRE) calculation, FRE development, manual action feasibility calculation, application calculation, post-FRE calculation, Nuclear Safety Capability Assessment calculation and others as required.
Implementation including preparing UFSAR updates, Design Basis Document for Fire Protection Program, NFPA 805 related drawing changes, and updating procedures updating procedures Licensing Activities
None anticipated 36
Closing Remarks Preston Gillespie 37
ACRONYMS AB - Auxiliary Building AC - Alternating Current NFPA - National Fire Protection Association NRC - Nuclear Regulatory Commission g
AHU - Air Handling Unit ASW - Auxiliary Service Water BWST - Borated Water Storage Tank CCW - Condenser Circulating Water CDF Core Damage Frequency g
y NSRB - Nuclear Safety Review Board NOS - Nuclear Oversight ONS - Oconee Nuclear Station PCC - Project Command Center PORV Power Operated Relief Valve CDF - Core Damage Frequency DC - Direct Current EC - Engineering Change ECR - Engineering Change Request FRE - Fire Risk Evaluation PORV - Power Operated Relief Valve PSW - Protected Service Water RAI - Request for Additional Information RB - Reactor Building RBCU - Reactor Building Cooling Unit HPI - High Pressure Injection HVAC - Heating Ventilation and Air Conditioning I&C - Instrumentation and Controls IDR - Integrated Design Review KHS - Keowee Hydro Station RCP - Reactor Coolant Pump RCS - Reactor Coolant System SE - Safety Evaluation SG - Steam Generator SLC - Selected Licensee Commitment KHS - Keowee Hydro Station KHU - Keowee Hydro Unit kW - Kilowatt LAR - License Amendment Request MCC - Motor Control Center SLC Selected Licensee Commitment SSF - Standby Shutdown Facility TSC - Technical Support Center UFSAR - Updated Final Safety Analysis Report VAC - Volts Alternating Current VFDR V
i F
D t i i ti R i
t 38 VFDR - Variance From Deterministic Requirement