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 Oconee Protected Service Water (PSW)
( )
System Milestones April 10, 2013
Duke Energy gy Participants p
Preston Gillespie Senior Vice President Nuclear Operations Scott Batson Oconee Site Vice President Tom Ray Oconee Plant Manager Ed Burchfield Oconee Engineering g g Manager g
Bob Guy Oconee Organizational Effectiveness Manager Jim Fuller PSW Project General Manager Eddie Anderson PSW Engineering Director Chris Nolan Regulatory Affairs Director 2
Agenda 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 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 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 operation of the Oconee Units Rigorous g compensatory p y measures will remain in p place to mitigate fire risk in the interim 5
Opening Remarks Lessons learned from project experiences are being incorporated to expedite project completion Duke Energy is providing all necessary resources to 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 basis Project dashboard has been established and updated weekly kl tto measure progress against i t milestones il t and d
schedule adherence performance 6
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 System S t complete l t 11/15/2016 Satisfy the requirements of NFPA 805 7
Opening Remarks Estimated Fire CDF Impact of Each Milestone Cumulative Impact of Milestones on Fire CDF 100.00%
13%
14%
22%
80.00%
37% 38%
60.00%
40.00%
20.00%
0.00%
Current Off-site Off site Pwr to Keowee Pwr to PSW Pwr to HPI PSW Pump PSW Complete NFPA 805 met SSF/ PSW PSW Estimated Cumulative Base Fire CDF Reduction 8
Project Organization & Controls Tom Ray 9
Project Organization & Controls Management g Oversight 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 and station leadership Weekly project progress reviews with fleet executive leadership NSRB / NOS (independent) project progress reviews 10
Project Organization & Controls Improvements p in Project j Execution Project Command Center (PCC)
Dedicated Project Engineering Team Prioritization Prioriti ation of project work ork Improved metrics and project controls Site Ownership Project completion is Site Initiative Dedicated Site Projects Integration Manager and Team Creation of dedicated Design Basis Engineering Group and Manager 11
Project Considerations Ed Burchfield 12
Project Considerations PSW p project j structured to expedite p field installation First phase of engineering changes address installation, but not tie-ins to existing plant systems 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 13
Project Considerations Auxiliaryy Building g / Reactor Building g Cooling g Solutions 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 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 designg will meet NFPA 805 requirements q
14
Project Considerations Engineering Change Process 15
Overview of Milestones Ed Burchfield 16
Milestone 1 C
Commercial i l power path th to th SSF t the Commitment B
By October 1 1, 2013 2013; PSW po powerer to the Standb Standby Sh Shutdown tdo n Facilit Facility (SSF) will provide the following:
Commercial power source to the PSW switchgear 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
Commercial i l power ffeed d will ill b be capable bl off providing idi normall power tto th 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 SSF. This milestone will be satisfied with the completion of the following activities:
System testing completed Operations procedures in place Operators trained Technical Support Center (TSC) members trained 17
Milestone 1 C
Commercial i l power path th tot theth SSF Remaining activities to completion:
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 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 from PSW Electrical Distribution System 18
Milestone 1 C
Commercial i l power path th tot theth SSF Remaining activities to completion:
Field Work Activities:
SSF equipment tie-in activities & engineered electrical equipment power-up testingg 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 19
Milestone 2 PSW power from f Keowee K H Hydro d
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
Power path th ffrom th the PSW switchgear it h tto th 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 satisfied ti fi d with ith ththe completion l ti off th the ffollowing ll i activities:
ti iti System testing completed Operations procedures in place Operators trained Technical Support Center (TSC) members trained 20
Milestone 2 PSW power from f Keowee K H Hydrod Remaining activities to completion:
Engineering Activities:
Complete restructuring of EC Packages to support milestone turnovers, work orders to support full KHS testing 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 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 power from f Keowee K H Hydrod Remaining activities to completion:
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 Power P to t HPI System S t Installed I t ll d 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 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 Power P to t HPI System S t Installed I t ll d Milestone Definition 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 Pumps P A and d B on PSW Power P on one Oconee O Unit U it is i complete.
l t This milestone will be satisfied with the completion of the following activities:
System testing completed as described above Operations procedures in place Operators trained Technical Support pp Center ((TSC)) members trained 24
Milestone 3 PSW PowerP to t HPI System S t Installed I t ll d Remaining activities to completion:
Engineering Activities:
Complete required documentation for Main Control Board Addition and HPI S
System Repowering EC C Packages including work orders to support HPI System testing Complete Integrated Design Review of HPI Power from Keowee Hydro Station through PSW Building 25
Milestone 3 PSW Power P to t HPI System S t Installed I t ll d Remaining activities to completion:
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:
None anticipated 26
Milestone 4 PSW P Pump IInstalled t ll d 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 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 Pump IInstalled t ll d 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.
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
Operators t trained t i d Technical Support Center (TSC) members trained 28
Milestone 4 PSW Pump Installed Remaining activities to completion:
Engineering Activities:
Complete EC Packages and associated work orders for Phase 1 Cooling Complete p ECs for PSW Pipe p Header, PSW Pump p Room, and Condensate 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 Pump IInstalled t ll d Remaining activities to completion:
Fi ld Work Field W k Activities:
A ti iti Remove existing Station ASW System components and Station ASW Switchgear to make room for new PSW System Components P f Perform PSW S System t ffunctional ti l testing t ti and d integrated i t t d flow fl ttesting ti Complete installation of Phase 1 AB/RB cooling equipment, currently planned to include:
Two 500 tton air-cooled T i l d chillers hill outside t id T Turbine bi B Building ildi 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 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 Receive and install remaining engineered equipment Auxiliary Building HVAC Control Panels and Heat Detectors 30
Milestone 4 PSW P Pump IInstalledt ll d Remaining activities to completion:
Licensing Activities:
Respond to existing open PSW Request for Additional Information (RAI) targeted g by y July y 1,, 2013 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 Systemt C Complete l t 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 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 Auxiliary Building and Reactor Building equipment environments suitable for equipment operation 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 14, 2010 2010, NFPA 805 LAR, turned over to Operations, and functional 32
Milestone 5 PSW S System t C Complete l t Remaining activities to completion:
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 Pressurizer heater component environmental qualification f
Perform Integrated Design Review of PSW backup power to pressurizer heaters and Vital I&C Battery Chargers Complete design rereviews ie s of q quality alit / ffunctionality nctionalit of PORV electrical components to support PSW scenarios 33
Milestone 5 PSW S System t C Complete l t 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
Complete l t fifield ld work k associated i t d with ith cable bl iinfrastructure, f t t manuall and d
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 Batteryy Chargersg 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 Licensing Activities None anticipated 34
Milestone 6 NFPA 805 C Complianceli 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
Oconee NFPA 805 S Safety f t E Evaluation l ti R Reportt Milestone Definition Full F ll compliance li with ith NFPA 805 License Li Condition C diti D 35
Milestone 6 NFPA 805 C Compliance li Remaining activities to completion:
Engineering Activities:
Develop Variance From Deterministic Requirements (VFDRs)
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 Licensing Activities None anticipated 36
Closing Remarks Preston Gillespie 37
ACRONYMS AB - Auxiliary Building NFPA - National Fire Protection Association AC - Alternating g Current NRC - Nuclear Regulatory g y Commission AHU - Air Handling Unit NSRB - Nuclear Safety Review Board ASW - Auxiliary Service Water NOS - Nuclear Oversight BWST - Borated Water Storage Tank ONS - Oconee Nuclear Station CCW - Condenser Circulating Water PCC - Project Command Center CDF - Core Damage Frequency PORV - Power Operated Relief Valve DC - Direct Current PSW - Protected Service Water EC - Engineering Change RAI - Request for Additional Information ECR - Engineering Change Request RB - Reactor Building FRE - Fire Risk Evaluation RBCU - Reactor Building Cooling Unit HPI - High Pressure Injection RCP - Reactor Coolant Pump HVAC - Heating Ventilation and Air Conditioning RCS - Reactor Coolant System I&C - Instrumentation and Controls SE - Safety Evaluation IDR - Integrated Design Review SG - Steam Generator KHS - Keowee Hydro Station SLC - Selected Licensee Commitment KHU - Keowee Hydro Unit SSF - Standby Shutdown Facility kW - Kilowatt TSC - Technical Support Center LAR - License Amendment Request UFSAR - Updated Final Safety Analysis Report MCC - Motor Control Center VAC - Volts Alternating Current VFDR - Variance V i From F Deterministic D t i i ti R Requirement i t 38