ML13317A246
| ML13317A246 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 08/03/1982 |
| From: | Pigott D ORRICK, HERRINGTON & SUTCLIFFE, SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC COMMISSION (OCM) |
| Shared Package | |
| ML13317A247 | List: |
| References | |
| TAC-48143, NUDOCS 8208050482 | |
| Download: ML13317A246 (33) | |
Text
1 DAVID R. PIGOTT ALAN C. WALTNER 2
Of ORRICK, HERRINGTON & SUTCLIFFE A Professional Corporation 3
600 Montgomery Street San Francisco, California 94111 4
Telephone:
(415) 392-1122 5
CHARLES R. KOCHER JAMES A. BEOLETTO 6
SOUTHERN CALIFORNIA EDISON COMPANY P.
- 0. Box 800 7
2244 Walnut Grove Avenue Rosemead, California 91770 8
Telephone:
(213) 572-1900 9
Attorneys for Applicant, Southern California Edison Company 10 11 UNITED STATES OF AMERICA 12 NUCLEAR REGULATORY COMMISSION 13 14 In the Matter of
)
Docket No. 50-206 15 SOUTHERN CALIFORNIA EDISON
)
COMPANY
)
16 (San Onofre Nuclear
)
17 Generating Station Unit 1)
)
18 19 SUPPLEMENTAL REQUESTS FOR EXEMPTION AND 20 PETITION FOR RECONSIDERATION 21 The Nuclear Regulatory Commission's ("NRC") Fire 22 Protection Rule, which became effective on February 17, 1981, 23 required fire safety plans and schedules to be submitted to 24 NRC by March 19, 1981, and required implementation of fire 25 protection measures on an accelerated schedule thereafter.
26 10 C.F.R. § 50.48(c).
NRC recognized that this schedule was PR ADOC" PDR
1 optimistic, and agreed to utilize the exemption process to 2
alleviate hardships resulting from the timetable.
10 C.F.R.
3
§§ 50.12(a), 50.48(c)(6); 45 Fed. Reg. 76603.
4 By its application submitted March 19, 1981, and 5
supplemented on November 9, 1981, (the "exemption request")
6 Southern California Edison Company ("Applicant") requested an 7
exemption from the schedule contained in 10 C.F.R.
8
§ 50.48(c)(5) for the filing of plans and schedules for 9
installation of fire safety equipment designed to provide a 10 safe shutdown capability at Applicant's San Onofre Nuclear 11 Generating Station Unit 1 ("SONGS 1").1/ The exemption 12 request sought a schedule coordinated with the integrated 13 assessment of required plant backfit as part of the SEP 14 Integrated Assessment. By order dated May 10 and filed 15 May 13, 1982 (the "exemption decision"), the NRC partially 16 granted Applicant's exemption request, but set July 1, 1982, 17 as the deadline for filing fire safety plans and schedules.2/
18 19 1/
By a separate exemption request filed December 28, 1981, Applicant sought, and received on March 11, 1982, an 20 exemption from the requirement to install battery-powered lighting inside containment. By an exemption request filed 21 November 9, 1981 and supplemented on January 6 and February 9, 1982, Applicant sought a slight delay in the 22 implementation schedule for battery powered lighting.
Implementation of the affected measures was completed before 23 NRC acted on this second request. These earlier exemptions are not affected by the current exemption and reconsideration 24 reauests.
25 2/
Exemption applications for similar schedular relief were 26 (footnote continued on next page) 2
1 Despite the problems presented by lack of 2
coordination with SEP and the scope of required measures at 3
SONGS 1, Applicant complied with the July 1 deadline by 4
submitting plans and schedules on that date (the "July 1 5
submission").
The problems faced at the time of the original 6
exemption remain under the current schedule. By letter dated 7
June 30, 1982 from K. P. Baskin to the Director, Office of 8
Nuclear Reactor Regulation, Applicant therefore requested 9
that the Commission reconsider its decision to apply a 10 uniform July 1, 1982, deadline to all facilities, and instead 11 consider the facts and circumstances peculiar to Applicant 12 that warrant a schedule better coordinated with SEP.
13 Applicant is particularly concerned that the July 1 14 submission may be found to conflict with SEP requirements as 15 SEP progresses.
16 The July 1 submission confirmed the factual basis 17 for Applicant's exemption request:
the nature and scope of 18 required safe shutdown measures at SONGS 1 necessitate 19 20 (footnote continued from previous page) 21 filed by 44 other licensees. However, as the Commission noted, none of these other applications sought linkage 22 between the fire safety program and SEP.
The fire safety requirements of 10 C.F.R. § 50.48, Appendix R are 4
23 particularly burdensome at SONGS 1. These requirements overlap substantially with SEP.
Applicant therefore faces a 24 special situation deserving of particular schedular relief.
However, the Commission applied the same filing deadline -
25 July 1, 1982 --
to Applicant as to other licensees, in acting upon Applicant's exemption request.
26 3
1 coordination with SEP. Moreover, as a result of the NRC's 2
exemption decision, Applicant may be required to implement 3
the remaining fire protection measures on a schedule 4
substantially in advance of that originally contemplated by 5
NRC, as discussed more fully below. For these reasons, 6
Applicant requested in its July 1 submission exemptions from 7
the implementation schedules for the Modifications and 8
Additions identified therein, to allow implementation of 9
these measures in coordination with SEP. Specifically, the 10 following exemptions-were requested:
11
- 1. An exemption from the schedular implementation 12 requirements of 10 C.F.R. § 50.48(c)(3) was requested 13 for Modifications and Additions identified in Enclosure 14 1 to the July 1 submission, with the exception of the 15 RSP additions, to be implemented as part of any 16 modifications identified during SEP Integrated 17 Assessment, or no earlier than the following dates:
18 (a) for Modifications, prior to startup from the next 19 refueling outage which is currently expected in late 20 1983, and (b) for Additions, prior to startup from the 21 second refueling outage from the date of the July 1 22 letter, which is currently in mid-1985.
23
- 2. An exemption from the schedular implementation 24 requirements of 10 C.F.R. § 50.48(c)(4) was requested 25 for the RSP additions identified in Enclosures 1 and 2 26 to the July 1 letter, to be implemented as part of any 4
1 modifications identified during SEP Integrated 2
Assessment, no earlier than the dates listed under item 3
1 above.
4 Applicant's July 1 submission indicated that this 5
supplemental submission would be provided by July 31, 1982.
6 I.
UNIT I FACES SUBSTANTIAL SITE-SPECIFIC BURDENS UNDER THE CURRENT SCHEDULE NOT 7
FACED BY OTHER LICENSEES AND NOT CONTEMPLATED DURING NRC'S SCHEDULAR 8
DEVELOPMENT 9
As demonstrated by Applicant's July 1 submission, 10 Applicant will be required to make extensive modifications to 11 SONGS 1. It is estimated, based on conceptual engineering 12 performed to date, that the total cost to Applicant of these 13 measures will be approximately $50 million. The Fire 14 Protection Rule provides a number of compliance options.
15 Because extensive facility modifications would have been 16 required under an alternative or dedicated shutdown approach 17 in any event, Applicant elected to adopt a separation and 18 fire suppression approach involving many of the same 19 measures, by providing two fully safety-qualified shutdown 20 trains meeting the separation requirements, together with any 21 necessary fire suppression measures. Applicant considers the 22 additional costs resulting from this safety-related approach 23 to be justified by the broad safety benefits that will be 24 provided.
25 By adopting this approach, however, Applicant has 26 become subject to an accelerated implementation schedule 5
1 originally designed by NRC to address less extensive 2
modifications.
Separation and suppression modifications that 3
require plant shutdown are to be implemented under 10 C.F.R.
4
§ 50.48(c)(3) before start up after the earliest of the 5
following events commencing 180 days.or more after the 6
effective date of the Fire Protection Rule (February 17, 7
1981):
(1) the first refueling outage, (2) another planned 8
outage that lasts for at least 60 days, or (3) an unplanned 9
outage that lasts for at least 120 days. This schedule would 10 require implementation of all of the measures identified by 11 Applicant during the current outage, with the exception of the 12 modifications associated with the Remote Shutdown Panel, which 13 is the only alternative shutdown system identified by NRC.
14 As described below, application of this schedule could cause 15 a prolonged outage of SONGS 1 lasting two or three years.
16 Because Applicant elected to implement a safety 17 related system offering additional safety benefits, the scope 18 of the improvements proposed for SONGS 1 will be of a 19 magnitude similar to, and in some cases more extensive than, 20 that of alternative or dedicated shutdown systems proposed by 21 other utilities. Thus, the NRC's implementation schedule is 22 inappropriate for SONGS 1, and has the unanticipated result 23 of discouraging Applicant's adoption of a safety-related 24 approach. The accelerated schedule was intended by NRC to 25 apply to situations involving minimal additions of fire 26 barriers and suppression equipment, and not the extensive 6
1 safety related modifications proposed by Applicant.
2 Even the minimal separation and suppression 3
measures contemplated for other facilities were to be 4
implemented during a longer period than Applicant now faces.
5 Separation and fire suppression measures were originally to 6
have been installed during the first outage (meeting the 7
requirements listed above) commencing 180 days after the 8
effective date of the Fire Protection.Rule.
Since the plans 9
and schedules were to be filed within 30 days of that 10 effective date, a period of at least 150 days originally was 11 allowed between the filing of plans and schedules and the 12 commencement of modifications and additions requiring plant 13 shutdown. However, since the NRC's exemption decision 14 extended the deadline for filing plans and schedules, and did 15 not include a corresponding extension of the implementation 16 schedule, this additional 150 day period has disappeared.
17 Thus, for this reason as well, Applicant requested exemptions 18 from the implementation schedules contained in 10 C.F.R.
19
20 If the requested exemptions are denied, Applicant 21 may be forced to switch to a non-safety related alternative 22 or dedicated shutdown approach in order to qualify for a 23 longer implementation period. In such an event, Applicant 24 may request NRC approval to modify its July 1 submission to 25 reflect any such change.
26 7
1 Many of the modifications identified by Applicant 2
will require coordination with SEP.
Under the current 3
timetable, if Applicant is held to its July 1 submission, 4
duplicative, wasteful and inefficient modifications may 5
result. Ongoing analysis may also produce alternative fire 6
safety approaches that will better serve health and safety 7
concerns. Coordination with SEP is also precluded because 8
SEP is on a schedule some months behind the fire safety 9
program. Because of the scope of required modifications, the 10 need to analyze alternative fire safety approaches, and the 11 need to coordinate the fire safety program with SEP, 12 Applicant also requested reconsideration of the NRC's 13 decision to impose a July 1, 1982 deadline for filing plans 14 and schedules, to allow modification of the July 1 submission 15 as SEP progresses.
16 Tables 7-1 through 7-9 in Enclosure 1 to 17 Applicant's July 1 submission best illustrate the scope of 18 the Modifications and Additions that will be required to 19 achieve separation to comply with the Fire Protection Rule 20 and Tables 9-1 and 9-2 summarize the changes that will be 21 necessary. These tables are included in this submission as 22 Appendix A. Most of the circuits reviewed will require 23 Additions or Modifications. Among the more significant 24 Additions are a second 4KV Switchgear Room, approximately 25 1000 power and control circuits to meet separation 26 requirements and for new equipment, a new Auxiliary Feedwater 8
1 Train, a Remote Shutdown Panel, and new redundant valves for 2
3 The Modifications and Additions described in 4 to the July 1 submission may be impacted by the 5
results of SEP Integrated Assessment. The broad objective of 6
the SEP is to reassess the Safety of older nuclear power 7
plants in accordance with the intent of the requirements 8
governing the licensing of current plants, and to provide 9
assurance, possibly involving backfitting, that operation of 10 these plants conforms to the general level of safety required 11 of modern plants.
The SEP Topics which may impact the 12 Modifications and Additions for Fire Protection Safe Shutdown 13 are:
14 111-2 Wind and Tornado Loadings.
15 111-4 Tornado Missiles.
16 III-5.A Effects of Pipe Break on Structures, Systems and 17 Components Inside Containment.
18 III-5.B Pipe Break Outside Containment.
19 V-10.B RHR Reliability.
20 V-11.A Requirements for Isolation of.High and Low Pressure 21 Systems.
22 V-11.B RHR Interlock Requirements.
23 VII-3 Systems Required for Safe Shutdown.
24 The resolution of open items in the area of applied 25 criteria and backfit requirements resulting from SEP 26 Integrated Assessment may lead to design changes to the 9
1 Modifications and Additions of Fire Protection Safe 2
Shutdown. The requirement for backfit on backfit is not the 3
most efficient nor cost effective method of resolving NRC 4
concerns. SEP Integrated Assessment was intended to resolve 5
this problem. Examples of the relationship between the Fire 6
Protection Modifications and Additions and the possible 7
backfit requirements of SEP are provided below.
8 The new circuits that will be installed must 9
satisfy the separation requirements of Appendix R. These 10 requirements will be used as design criteria for the location 11 of these circuits. SEP Topics III-5.A and III-5.B involve 12 the review of pipe breaks inside and outside containment and 13 their effect on neighboring safe shutdown equipment. An 14 integrated design approach would include the requirements 15 resulting from these topic reviews as part of the design 16 criteria for locating the new circuits. This would eliminate 17 the risk of routing the new circuits associated with 18 redundant trains of safe shutdown equipment in an area where 19 they would be impacted by a high energy pipe break. Similar 20 design criteria should be applied to the design of the new 21 Auxiliary Feedwater Train and in addition, the possible 22 effects of tornadoes should be included as defined in SEP 23 Topics 111-2 and I11-4.
24 The Modifications and Additions of Fire Protection 25 Safe Shutdown provide improved redundancy through separation 26 of the systems and equipment required for safe shutdown. As 10
1 such, these modifications will both impact and be impacted by 2
the SEP review of Topic VII-3.
In some cases, new equipment 3
is required to be added to the Fire Protection Safe Shutdown 4
system since they resolve possible single failure concerns 5
which might arise from SEP Integrated Assessment of the Safe 6
Shutdown Topic and Topic V-10.B. Topics V-11.A and V-11.B 7
have resulted in NRC concerns with respect to the RHR system 8
which are to be resolved as part of SEP Integrated 9
Assessment. The resolution of these concerns may create new 10 requirements on the RHR system which should be included as 11 design criteria in conjunction with the criteria for these 12 systems resulting from Fire Protection.
13 These specific examples demonstrate the difficulty 14 that will result from the NRC's timetable. Wasteful, 15 unnecessary and duplicative expenditures may be made with 16 little or no benefit to the public health and safety.
17 Coordination of the Appendix R program with SEP will avoid 18 many of these problems.
To correct this situation, the NRC 19 should grant Applicant's requested exemptions from the 20 implementation schedule of the Fire Protection Rule.
The NRC 21 should also reconsider the July 1 filing requirements 22 contained in its exemption decision, to allow subsequent 23 modification of Applicant's submissions.
24 25
//
26
//
11
1 II. THE REQUESTED EXEMPTIONS AND RECONSIDERATION WILL BEST SERVE THE 2
PUBLIC HEALTH AND SAFETY 3
As described in its earlier submissions and as 4
recognized in the NRC's exemption decision, Applicant has 5
substantially upgraded fire safety measures at SONGS 1 during 6
recent years.
In 1978 and the first half of 1979, Applicant 7
and Commission Staff engaged in extensive discussions, 8
analysis and correspondence culminating on July 19, 1979 with 9
the issuance of Amendment No. 44 to Provisional Operating 10 License No. DPR-13 for SONGS 1, which incorporated a list of 11 modifications to the facility summarized in the Staff's Fire 12 Protection Safety Evaluation Report (FPSER).
The FPSER 13 specified 17 categories of modifications required to be made 14 to the facility, as well as setting forth areas for further 15 study including safe shutdown capability. Many of the 16 modifications were to be integrated with SEP.
The FPSER 17 concluded that "an adequate basis has been provided to assure 18 that the plant can be maintained in a safe condition during 19 the interim period until final fire protection modifications 20 have been completed."
FPSER at page 4-1.
Additional 21 requirements were later imposed by 10 C.F.R. § 50.48 and 22 Appendix R thereto.
23 In response to Amendment No. 44 and Appendix R, 24 Applicant engaged in rapid and extensive installation of fire 25 safety equipment, as outlined in the exemption application.
26 All required measures have been implemented. Only safe 12
1 shutdown issues remain to be resolved.
2 In its exemption decision, the Commission found 3
that SONGS 1 "has been upgraded to a high degree of fire 4
protection already and the extensive reassessment involved in 5
this request for additional time is to quantify, in detail, 6
the differences between what was recently approved and the 7
specific requirements of Section III.G to Appendix R of 10 8
C.F.R. § 50."
Exemption at page 6. The Commission further 9
found that:
10 "the licensee has completed a substantial part of the fire protection features at San 11 Onofre Unit 1 in conformance with the requirements of the Fire Protection Rule and 12 is applying significant effort to complete the reassessment of any remaining 13 modifications which might be necessary for strict conformance with Section III.G. We 14 find that because of the already-completed upgrading of these facilities, there is no 15 undue risk to the health and safety of the public involved with continued 16 operation.
17 Id.
18 Because of the substantial fire safety improvements 19 already implemented at SONGS 1, the requested exemptions and 20 reconsideration will offer substantial benefits without 21 health and safety concerns. As outlined more fully in the 22 exemption request, coordination with SEP will avoid 23 unnecessary and conflicting modifications to SONGS 1 and will 24 permit a better designed.fire safety program that will best 25 serve the public.
26
//
13
1 The additional time necessary for orderly 2
implementation of these two programs and installation of a 3
fully safety qualified system is not unreasonable. The 4
review of SEP topics is expected to be complete in December, 5
1982, at which time the integrated assessment will begin.
6 The integrated assessment is scheduled to be completed in 7
April, 1983.
The additional time required to coordinate the 8
two programs, therefore, is small in relation to the total 9
scope and cost of these retrofit programs. The 10 implementation schedule requested is commensurate with that 11 currently applied to other licensees installing alternative 12 or dedicated shutdown systems.
13 III. EXEMPTIONS FROM THE IMPLEMENTATION SCHEDULES ARE APPROPRIATE IN THIS CASE.
14 15 The NRC has recognized that its fire protection 16 implementation schedule is ambitious and in many cases 17 unachievable. Only 30 days were allowed after the effective 18 date of the Fire Protection Rule to submit plans and 19 schedules, although the NRC knew that "the time required for 20 this re-examination, reanalysis and redesign could vary from 21 a few months to a year or more."
Exemption decision at page 22
- 3. NRC sought to avoid the harshness of its schedule through 23 the exemption process, and 44 of the 72 plants subject to the 24 Rule sought schedular relief. By granting Applicant an 25 extension of the deadline to submit fire safety plans and 26 schedules to July 1, 1982, NRC appreciated the magnitude of 14
1 the task faced at SONGS 1.
2 The NRC also established an ambitious 3
implementation schedule for fire safety measures. With the 4
exception of the safe shutdown systems, and certain minor 5
implementation problems addressed through the exemption 6
process, Applicant has met this ambitious schedule. The safe 7
shutdown additions and modifications are another matter.
8 Simply stated, the current implementation schedule for these 9
measures could require an extended plant shutdown lasting for 10 years while Applicant awaits delivery of necessary systems.
11 Supply of backup power during such an extended outage will 12 result in substantial costs to Applicant's rate payers 13 without corresponding safety benefits. However, the 14 Commission has determined that interim operation of SONGS 1 15 will not impair public health and safety.
16 The current schedule-has the additional effect of 17 discouraging Applicant's adoption of a safety related 18 approach. As discussed above, NRC's implementation schedule 19 originally permitted separation and suppression measures 20 requiring plant shutdown to be installed during the first 21 outage meeting certain requirements beginning at least 180 22 days after the effective date of the Rule (150 days after the 23 original deadline for filing plans and schedules).
- However, 24 non-safety related dedicated shutdown systems are to be 25 completed within 30 months of NRC approval and alternative 26 shutdown systems requiring plant shutdown are to be installed 15
1 during the first outage (meeting certain requirements) 2 commencing at least 180 days after NRC approval. The 3
operation of this schedule is capricious at SONGS 1, since 4
the measures necessary to achieve separation are in most 5
cases at least as extensive as dedicated systems would be at 6
most plants. Further, because the implementation period for 7
separation and suppression measures has been consumed by the 8
preparation of plans and schedules, the current 9
implementation schedule would require all additions and 10 modifications to be made during the current outage, despite 11 the fact that many of these measures will require at least 30 12 months to implement.
13 Finally, the risk is still strong of wasteful and 14 duplicative expenditures resulting from failure to coordinate 15 the fire protection program with SEP.
Regardless of NRC's 16 decision to require fire safety plans and schedules in 17 advance of SEP, the implementation of the two programs 18 clearly should be coordinated. Applicant has attempted to 19 anticipate conflicts between the two programs and to plan 20 accordingly. However, sufficient flexibility must be allowed 21 to address specific unanticipated conflicts as they occur.
22 Accordingly, an exemption from the implementation 23 schedule contained in 10 C.F.R. § 50.48(c) should be granted 24 to allow implementation of fire protection measures in 25 coordination with SEP.
26 16
1 IV.
RECONSIDERATION IS APPROPRIATE AND DESIRABLE IN THIS CASE 2
3 Reconsideration of the exemption decision is 4
appropriate under the NRC's exemption regulation, which 5
provides that:
6 The Commission may, upon application by any interested person or upon its own initiative, 7
grant such exemptions from the requirements of the regulations in this part as it.
8 determines are authorized by law and will not endanger life or property or the common 9
defense and security and are otherwise in the 10 public interest.
11 10 C.F.R. § 50.12(a).
12 The Commission's ability to-reconsider a decision 13 is inherent in its ability to decide in the first instance.
14 In re Florida Power and Light Co. (St. Lucie Nuclear Power 15 Plant, Unit 2), CLI-80-41, 12 NRC 650 (December 12, 1980).
16 See Trujillo v. General Electric Co., 621 F.2d 1084, 1086 (10 17 Cir. 1980),
Albertson v. FCC, 182 F.2d 397, 399 (D.C. Cir.
18 1950).
The Commission has recognized that it may reverse a 19 prior decision on reconsideration:
20 "Where a court is convinced that its declared law is wrong and would work an injustice, it retains 21 the power to apply a different rule of law in the interests of settling the case before it 22 correctly. Surely an administrative tribunal has 23 comparable flexibility."
24 In re Public Service Company of Indiana, Inc. (Marble Hill 25 Nuclear Generating Station, Units 1 and 2) ALAB-493, 8 NRC 26 253 (August 30, 1978).
17
1 Although the Commission has variously required that 2
petitions for reconsideration not raise issues for the first 3
time, In re Kansas Gas and Electric Co., et al. (Wolf Creek 4
Generating Station, Unit No. 1) ALAB-477, 7 NRC 766 (May 17, 5
1978), or, conversely, that they not repeat issues raised 6
before, In re Houston Lighting and Power Co., et al. (South 7
Texas Project, Unit Nos. 1 and 2) ALAB-387, 5 NRC 638 8
(March 31, 1977), where important new data relevant to the 9
NRC's decision becomes available, reconsideration is proper.
10 As demonstrated by the July 1 submission and 11 request for reconsideration, which was not before the NRC 12 when it issued its exemption decision, Applicant's proposed 13 approach to safe shutdown capability under Appendix R will 14 involve extensive modifications to the facility.
15 Site-specific factors dictate the need to coordinate these 16 measures with SEP.
Coordination of safe shutdown and SEP 17 measures will ensure an efficient and consistent retrofit 18 program. Applicant's ability to modify the July 1 submission 19 is essential to this coordination. Implementation of the 20 required equipment on an accelerated basis will not further 21 public health and safety goals. As discussed above, the NRC 22 has found that the measures already implemented at SONGS 1 23 are sufficient so as not to endanger life or property or the 24 common defense and security.
25 26 18
1 V. CONCLUSION 2
Applicant accordingly requests that the NRC grant 3
the exemptions from the Fire Protection Rule implementation 4
schedule outlined above and reconsider its exemption 5
decision, to allow implementation of safe shutdown measures 6
at SONGS 1 in coordination with SEP.
7 DATED:
August 3, 1982.
8 Respectfully submitted, 9
DAVID R. PIGOTT ALAN C. WALTNER 10 Of ORRICK, HERRINGTON & SUTCLIFFE A Professional Corporation 11 CHARLES R. KOCHER 12 JAMES A. BEOLETTO SOUTHERN CALIFORNIA EDISON COMPANY 13 14 David R. Pi'ott 15 One of Counsel for the Applicant 16 Southern California Edison Company 17 18 19 20 21 22 23 24 25 26 19
TABLE 7-1 EXISTING SAFE SHUTDOWN COMPONENT STATUS REACTOR COOLANT SYSTEM (RCS); FIGURE 1:
Physical Equipment/Components Required Location Electrical Current for Safe Shutdown by Fire Zone Power Supply Separation Phys-Power Proposed Train 1 Train 2 Train I Train 2 Train 1 Train 2 ical Supply Solution*
1 Vital Bus #2 Via Reg Bus #2 MCC-2A No Yes E
L' 431 LT 430A 1
1 Vital Bus #2 Via Reg Bus #2 MCC-2A No Yes E
1 Vital Bus #1 Via Reg Bus #1 Vital Bus #1 No No E
1 Vital Bus #3 Via Reg Bus #3 Vital Bus #3 No No E
TT 400 TT 420 1
1 Vital Bus #1 Vital Bus #3 Via Reg Bus #1 Via Reg Bus #3 No No E
1 Vital Bus #1 Vital Bus #3 No No E
1 Vital Bus #1, 2, 3, 4 No No E
via Reg. Bus #1, 2, 3, 4 Pressurizer Pressurizer Heaters Grp #A Heaters Grp #B 1
1 480V SWGR #1 480V SWGR #2 NA Yes Source Range Source Range Vital Bus #1, #2 & #3 Channel N1201 Channel N1202 NA NA via Reg Bus #1, #2 & #3 No No B
- A. Addition of independent power supply equipment and circuits E. Install new equipment B. Reconnection of power source F. Install fire suppression and/or C. Relocate equipment enclosure D. Fire barrier G. Provide nitrogen backup
TABLE 7-2 EXISTING SAFE SIUTDOWN COMPONENT STATUS CHEMICAL AND VOLUME CONTROL SYSTEM (CVCS);
FIGURE 2:
Physical Equipment/Components Required Location Electrical Current for Safe Shutdown by Fire Zone Power Supply Separation Phys-Power Proposed Train I Train 2 Train 1 Train 2 Train 1 Train 2 ical Supply Solution*
RWST D-1 3C N/A N/A N/A MOV 883 3C MCC #3 N/A N/A LCV 1100B LCV 110OD 2A 2A MCC #1 MCC #2 No Yes C
Charging Charging 4160V 4160V No Yes A, D Pump G-8B Pump G-8A 2A 2A Bus #1C Bus #2C Vital Bus #4 FCV 1112 19A Via Reg Bus #4 N/A E, G IA CV 305 1
Utility Bus N/A E, G FCV 1115D FCV 1115E 19A 19A Pneumatic No No F, G FC 1115A FC 1115B 16A 16A Vital Bus #4 No No B
via Reg. Bus #4 MOV 356 MOV 357 1
1 MCC #1 MCC #2 Yes Yes LCV 1112 1
Utility Bus No No E, G
- A. Addition of independent power supply equipment and circuits E. Install new equipment B. Reconnection of power source F. Install fire suppression and/or C. Relocate equipment enclosure D. Fire barrier G. Provide nitrogen backup
TABLE 7-2 (Continued)
EXISTING SAFE SHUTDOWN COMPONENT STATUS CHEMICAL AND VOLUME CONTROL SYSTEM (CVCS);
FIGURE 2:
Physical Equipment/Components Required LocaLion Electrical Current for Safe Shutdown by Fire Zone Power Supply Separation Phys-Power Proposed Train I Traini 2 Train I
Train 2 Train 1
Train 2
ical Supply Solution*
CV 202 CV 203 1
1 Pneumatic No N/A F, G SV 202 SV 203 1
1 Utility Bus Utility Bus No No B, F CV 525 CV 526 1
2E Vital Bus #1 Vital Bus #5 Yes Yes LCV 1100E LCV 1100C 2A 2A MCC-1 MCC-2A No Yes C
CV 527 CV 528 1
2E Vital Bus #1 Vital Bus #5 Yes Yes Regen. Heat 1
N/A N/A N/A Ex. #E-13
- A.
Addition of independent power supply equipment and circuits E.
Install new equipment B. Reconnection of power source F.
Install fire suppression and/or C.
Relocate equipment enclosure D.
Fire barrier G.
Provide nitrogen backup
TABLE 7-3 EXISTING SAFE SHUTDOWN COMPONENT STATUS AUXILIARY FEEDWATER SYSTEM; FIGURE 3:
Physical Equipment/Components Required Location Electrical Current for Safe Shutdown by Fire Zone Power Supply Separation Phys-Power Proposed Train I Train 2 Train I Train 2 Train I Train 2 ical Supply Solution*
Pump #G-10S Pump #G-10 9C 9C 480V SWGR #1 Steam No Yes A,E (Steam Driven)
NOV 1202 CV 3213 9C 6
MCC #1 Pneumatic No Yes E
N/A SV 3213 N/A 6
N/A Vital Bus #5 N/A Yes FCV 2300 FCV 3300 3B 3B Pneumatic No Yes F
FCV 2301 FCV 3301 3B 3B Pneumatic No Yes F
FC 2300 FC 3300 16A 16A Vital Bus
- 1 Vital Bus
- 5 Yes Yes FC 2301 FC 3301 16A 16A Vital Bus #1 Vital Bus #5 Yes Yes LT-450 FT 3453A, B
1 3B Vital Bus #1 Vital Bus #5 Yes Yes LT 451 FT 3454A, B 1
3B LT 452 FT 3455A, B 1
3B
- A. Addition of independent power supply equipment and circuits E. Install new equipment B. Reconnection of power source F. Install fire suppression and/or C. Relocate equipment enclosure D. Fire barrier G. Provide nitrogen backup V
TABLE 7-3 (Continued)
EXISTING SAFE SHUTDOWN COMPONENT STATUS AUXILIARY FEEDWATER SYSTEM; FIGURE 3:
Physical Equipment/Components Required Location Electrical Current for Safe Shutdown by Fire Zone Power Supply Separation Phys-Power Proposed Train 1 Train 2 Train 1 Train 2 Train 1 Train 2 ical Supply Solution' LI 450A FI 3453 16A 16A Vital Bus #1 Vital Bus #5 Yes Yes LI 451A FI 3454 LI 452A FI 3455 N/A CV 3201 N/A 9A N/A Pneumatic N/A N/A SV 3201 N/A 9A N/A Vital Bus #5 Yes N/A CV 113 N/A 9A N/A Pneumatic N/A (D
N/A PC 8 N/A 9A N/A Pneumatic N/A X
Condensate Storage 10 N/A N/A Tank #D-2
- A. Addition of independent power supply equipment and circuits E. Install new equipment B. Reconnection of power source F. Install fire suppression and/or C. Relocate equipment enclosure D. Fire barrier G. Provide nitrogen backup e
TABLE 7-4 EXISTING SAFE SHUTDOWN COMPONENT STATUS MAIN STEAM SYSTEM; FIGURE 4:
Physical Equipment/Components Required Location Electrical Current for Safe Shutdown by Fire Zone Power Supply Separation Phys-Power Proposed Train 1 Train 2 Train 1 Train 2 Train 1 Train 2 ical Supply Solution*
CV78 CV79 19 19 Pneumatic Yes No G
CV76 CV77 19 19 Pneumatic Yes No G
SV87 SV88 19 19 DC Bus #1 DC Bus #1 Yes No B
SV85 SV86 19 19 DC Bus #1 DC Bus #1 Yes No B
LT450 LT450C 1
1 Vital Bus #1 MCC-2A No Yes C
LT451 LT451C LT452 LT452C x
LI450A L1450C 16A 9E Vital Bus #1 MCC-2A Yes Yes L1451A L1451C L1452A L1452C
- A. Addition of independent power supply equipment and circuits E. Install new equipment B. Reconnection of power source F. Install fire suppression aad/or C. Relocate equipment enclosure D. Fire barrier G. Provide nitrogen backup
1;V.
TABLE 7-5 EXISTING SAFE SHUTDOWN COMPONENT STATUS SALT WATER COOLING SYSTEM; FIGURE 5:
Physical Equipment/Components Required Location Electrical Current for Safe Shutdown by Fire Zone Power Supply Separation Phys-Power Proposed Train 1 Train 2 Train 1 Train 2 Train 1 Train 2 ical Supply Solution*
Pump G-13A Pump G-13B 4
4 480V SWGR #1 480V SWGR #2 Yes Yes POV 5 POV 6 4
4 Pneumatic Yes N/A G
SV-24 SV-25 4
4 125VDC 125VDC Bus #1 Bus #2 Yes Yes I. Ex.E-20B II. Ex.E-20A 3A 3A N/A N/A N/A N/A (D
- A. Addition of independent power supply equipment and circuits E. Install new equipment B. Reconnection of power source F. Install fire suppression and/or C.
Relocate equipment enclosure D. Fire barrier G. Provide nitrogen backup V
TABLE 7-6 EXISTING SAFE SHUTDOWN COMPONENT STATUS COMPONENT COOLING WATER SYSTEM (CCWS);
Figure 7:
Physical Equipment/Components Required Location Electrical Current for Safe Shutdown by Fire Zone Power Supply Separation Phys-Power Proposed Train 1 Train 2 Train I Train 2 Train 1 Train 2 ical Supply Solution*
Pump G-15A Pump G-15B 3A 3A 480V SWGR #1 480V SWGR #2 No Yes D
MOV 720A MOV 7208 3A 3A MCC #1 MCC #2 No Yes C
TCV 601A TCV 6018 3E 3E Pneumatic No No C, G YM 601A YM 601 3E 3E Vital Bus #1 Vital Bus #1 Via Reg Bus #1 Via Reg Bus #1 No No B, C Ht. Ex.E-20A
- 11. Ex.E-20B 3A 3A N/A N/A N/A N/A
- A. Addition of independent power supply equipment and circuits E. Install new equipment B. Reconnection of power source F.
Install fire suppression and/or C. Relocate equipment enclosure D. Fire barrier G. Provide nitrogen backup R
TABLE 7-7 EXISTING SAFE SHUTDOWN COMPONENT STATUS RESIDUAL HEAT REMOVAL SYSTEM (RIRS); FIGURE 6:
Physical Equipment/Components Required Location Electrical Current for Safe Shutdown by Fire Zone Power Supply Separation Phys-Power Proposed Train I Train 2 Train I Train 2 Train 1 Train 2 ical Supply Solution*
1 MCC-1 MCC-2 No Yes C
1 Vital Bus #1 Vital Bus #1 Via Reg Bus #1 Via Reg Bus #1 No No B, C TC 601A TC 601B 16A 16A Vital Bus #1 Vital Bus #1 Via -Reg-Bus-#1-Via-Reg--Bus 1
No No B9 C TI 601A TI 601B 16A 16A Vital Bus #1 Vital Bus #1 Via Reg Bus #1 Via Reg Bus #1 No No B, C Hf.
Ex.E-21A H1.
Ex.E-21B 1
1 N/A N/A N/A N/A MOV 813 1
MCC-1 N/A E
NOV 814 1
MCC-2 N/A E
MOV 833 1
MCC-1 N/A E
NOV 834 1
MCC-2 N/A E
Pump G-14A Pump G-14B 1
1 480V SWGR #1 480V SWGR #2 No Yes D
- A. Addition of independent power supply equipment and circuits E. Install new equipment B. Reconnection of power source F. Install fire suppression and/or C. Relocate equipment enclosure D. Fire barrier G. Provide nitrogen backup
TABLE 7-7 (Continued)
EXISTING SAFE SIIJTDOWN COMPONENT STATUS RESIDUAL HEAT REMOVAL SYSTE M Physical Equipment/Components Required Location Electrical Current for Safe Shutdown by Fire Zone Power Supply Separation Phys-Power Proposed Train I Train 2 Train I Train 2 Train 1 Train 2 ical Supply Solution*
HCV 602 1
Pneumatic N/A E,
G HC 602 16A Vital Bus #4 N/A E
via Reg Bus #4 Fl 602 16A Vital BusJ#1 N/A E
FT 602 1
Vital BusI#1 N/A E
- A. Addition of independent power supply equipment and circuits E. Install new equipment B. Reconnection of power source F. Install fire suppression and/or C.
Relocate equipment enclosure D.
Fire barrier G.
Provide nitrogen backup
TABLE 7-8 EXISTING SAFE SHUTDOWN COMPONENT STATUS INSTRUMENT AIR SYSTEM; FIGURE 8:
Physical Equipment/Components Required Location Electrical Current for Safe Shutdown by Fire Zone Power Supply Separation Phys-Power Proposed Train I Train 2 Train 1 Train 2 Train I Train 2 ical Supply Solution*
K-lA K-lB 9C 9C 480V SWGR #1 480V SWGR #2 No Yes C-4A C-4B 10 10 N/A N/A No N/A N/A CV 41 N/A 9C N/A Pneumatic N/A N/A PC I N/A 9C N/A N/A N/A Nitrogen At Various N/A N/A (D
Supply Locations in Plant
- A. Addition of independent power supply equipment and circuits E. Install new equipment B. Reconnection of power source F. Install fire suppression and/or C. Relocate equipment enclosure D. Fire barrier G. Provide nitrogen backup
TABLE 7-9 EXISTING SAFE SHUTDOWN COMPONENT STATUS ELECTRICAL POWER SYSTEM: FIGURE 9:
Physical Equipment/Components Required Location Electrical Current for Safe Shutdown by Fire Zone Power Supply Separation Phys-Power Proposed Train 1 Train 2 Train I Train 2 Train 1 Train 2 ical Supply Solution*
Diesel G. #1 Diesel G. #2 18 17A Figure 9 Figure 9 Yes Yes B
4160d Bus #1C 4160V Bus #2C 8
8 Figure 9 Figure 9 No Yes A, B, E 480V SWGR #1 480V SWGR #2 8
7 Figure 9 Figure 9 No Yes B
MCC-1B MCC-2B 18 17A Figure 9 Figure 9 Yes Yes Sequencer #1 Sequencer #2 16A 16A 125 VDC Bus #1 125 VDC Bus #2 Yes Yes 125V BATT #1 125V BATT #2
- 13A, 17B Figure 9 Figure 9 Yes Yes 13B Vital Bus #1, Vital Bus #5, 16A i6A Figure 9 Figure 9 Yes Yes
- 2, #3, #3A #4 #6 7
Utility Bus #1 N/A 16A N/A Figure 9 N/A N/A Reg Bus #1, N/A 16A N/A Vital Bus #1, N/A N/A
- 2, #3,
- 4
- 2, #3, #4
- A. Addition of independent power supply equipment and circuits E. Install new equipment B. Reconnection of power source F. Install fire suppression and/or C. Relocate equipment enclosure D.
Fire barrier G. Provide nitrogen backup
TABLE 9-1 Appendix R MODIFICATIONS 8.1 EQUIPMENT RELOCATION 8.1.1 CVCS -
MOV, TE, TC 8.2 FIRE BARRIERS 8.2.1 CVCS pumps 8.2.2 CCW pumps 8.2.3 RHR pumps 8.3 ENCLOSURES AND SUPPRESSION SYSTEM 8.3.1 CVCS -
FCVs, CVs and SVs 8.3.2 AFW FCVs 8.6 NEW EQUIPMENT 8.6.1 Electrical Equipment B - partial -
changes of existing circuit breakers and fuses.
C - isolation devices for existing equip train 1 to train 2 separation D -
reconnect SV 85 and SV 86 from DC bus #1 to DC bus #2 E - reconnect train 2 equipment from vital bus 1, 2, 3, 4 or Reg. Bus 1, 2, 3, 4 or AC utility bus to Vital Bus 5 or 6 and new Reg. Bus and Voltage Reg. for Train 2.
8.6.2 Mechanical Equipment 8.6.2.4 Instrument Air - add bottles locally for pneumatic operated valves.
Appendix A
TABLE 9-2 Appendix R ADDITIONS 8.4 NEW CIRCUITS - All depend on new raceway for separation requirements 8.5 REMOTE SHUTDOWN PANEL - New system and panel 8.6 NEW EQUIPMENT 8.6.1 Electrical Equipment A -
dependent on new 4160 Bus B -
partial -
new breakers and fuses.
C -
isolation and local control switches 8.6.2 Mechanical Equipment 8.6.2.1 CVCS - bypass for FCV 1112, CV 305 and LCV 1112 redundant letdown path 8.6.2.2 AFW - new train for redundancy 8.6.2.3 RHR - bypass for MOV 813, MOV 814, MOV 833 and MOV 834 remote operated bypass for HCV 602
- redundant equipment for FT 602, FI 602 and HC 602 Appendix A