ML17056B472
| ML17056B472 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 10/23/1991 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17056B471 | List: |
| References | |
| 50-410-91-17, NUDOCS 9111040108 | |
| Download: ML17056B472 (58) | |
Text
ENCLOSURE 1 APPENDIX A Notice f Violation Niagara'ohawk Power Corporation Nine Mile Point Unit 2 Docket No. 50-410 License No. NPF-69 During an NRC inspection conducted on July 28 - September 7, 1991, a violation of NRC requirements was identified. In accordance with the "General Statement ofPolicy and Procedure for NRC Enforcement Actions," 10 CFR 50 Part 2, Appendix C (1991), the violation is listed below:
Nine Mile Point Unit 2 Technical Specification 6.8.1 requires that written procedures be implemented that meet or exceed the requirements of Regulatory Guide 1.33, Appendix A, which includes administrative procedures for equipment control through the use of markups (i.e.,
tagging).
'NMPC administrative procedure (AP) 4.2, Control of Equipment Markups, section 5.5, provides specific requirements for the application of markups, including maintaining configuration control on marked up components.
'I Contrary to the above, on June 17, 1991, the service water valve 2SWP*V136D, the inlet supply valve to unit cooler 2HVR*UC404D, was taken to the closed position during establishment of a markup to support a maintenance activity on the unit cooler, without adequate configuration control of that marked up component.
Specifically, further processing of the markup in the field was terminated due to the inability to operate one
'of the valves specified in the markups, and the markup was subsequently voided and disposed of without control personnel noting the fact that the 2SWP*V136D was shut.
As a result, the valve was left in the abnormal position until July 2, 1991.
This is a Severity Level IV violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, Niagara Mohawk Power Corporation is hereby required to submit a written statement or explanation to the U.S.'Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555, with a copy to the Regional Administrator, Region I, and a copy to the NRC Resident Inspector within 30 days of the date of the letter transmitting this Notice.
The reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each violation: (1) the reasons for the violation, or, ifcontested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved; (3) the corrective steps that will be taken to avoid further violations; and (4) the date when full compliance willbe achieved.
Where good cause is shown, consideration'ill be given to extending this response time.
OFFICIALRECORD COPY a: VIO91-17.NMP
NC E2 ctober 17 19 1 Enf r'c men onf rence Between NMP NRC - Attende
.S. Nuclear Re I to Comm ion Name
~Pition C. Beardslee A. Burritt R. Capra C. Cowgill R. Fuhrmeister D. Haverkamp J. Luehman J. Menning C. Sisco J. Tappert R. Temps J. Trapp J. Wiggins Reactor Engineer, Division of Reactor Safety (DRS)
Operations Engineer, DRS Director, Project Directorate I-1, Office of Nuclear Reactor Regulation (NRR)
Chief, Projects Branch No. 1, Division of Reactor Projects (DRP)
Acting Enforcement Coordinator Chief, Reactor Projects Section No. 1B, DRP Enforcement Specialist, Office of Enforcement (By Phone)
Project Manager, NRR Operations Engineer, DRS Reactor'ngineer, DRP Resident Inspector, Nine Mile Point Unit 2 Senior Reactor Engineer, DRS Deputy Director, DRP Nia ara Mohawk Power Cor oration W, Baker M. Colomb J. Firlit E. Klein B. Sylvia C. Terry M. Wetterhahn G. Wilson Licensing Program Director Manager - Operations Unit 2 Vice President - Nuclear Generation Engineering Executive Vice President - Nuclear Vice President - Nuclear Engineering Winston & Strawn Managing Attorney OFFICIALRECORD COPY a: VIO91-17.NMP
ENCLOSURE 3
NINE MlLE POINT UNIT 2 ENFORCEMENT CONFERENCE INSPECTION'O'. 60-410/91-1 7 SECONDARY CONTAINMENTUNIT COOLER OPERABILITY OCTOBER 17, 1991
AGENDA OPENING REMARKS B. R. SYLVIA CHRONOLOGY M. J. McCORMICK, JR.
SAFETY SIGNIFICANCE C. D. TERRY LOSS OF CONFIGURATION CONTROL M. J. COLOMB INVESTIGATION ROOT CAUSE CORRECTIVE ACTIONS
SUMMARY
B. R. SYLVIA
ih
CHRONOLOGY
6/ I 7 6/18 6/19 6/20 6l2 I 6/22 6/23 6/24 6/25 6/26 6/27 6/26 6l29 6/30 7/ I 7/2 UCAOAD LOGGED INOP UCAOID ACTUAL OUT OF SERVICE GTS TRAltl
'8'ECLARED INOP GTS TAAIII
'A'ECLARED INOP DIV I Ef lEAG DIESEL GEN DECLARED IIO:
OPERAT IONS PERSONNEL DISCOVER VALVE SHUT DUR'NG PEAFOAI IA~I"E OF SURVEILLANCE
LOSS OF CONFIGURATION CONTROL IVIARK-UPFOR UNIT COOLER 404D RED MARKUP ISSUED TO PLANT OPERATOR ON 11 PM - 7 AM SHIFT TO ISOLATE UNIT COOLER 404D FOR PREVENTIVE IVIAINTENANCE.
~
OPERATOR SUCCESSFULLY CLOSED INLET VALVETO UNIT COOLER, REIVIEMBERED HANGING A TAG, BUT WAS UNABLE TO Cl OSE THE OUTLET VALVE.
o NOTIFIED THE S.S.S. AND RETURNED TO CONTROL ROOM WITH THE REMAININGTAGS, TURNED THEM OVER TO HIS S.S.S. WITH AN EXPLANATIONOF THE PROBLEM.
AT SHIFT TURNOVER, THE DAY WORK S.S.S.
ASSUMED RESPONSIBILITY FOR THE UNIT COOLER STATUS AND DIRECTED MAINTENANCETG TRY TO CLOSE THE STUCK VALVE,WITHOUT SUCCESS.
THE IVIARKUP FORIVI WAS IN THE S.S.S.
OFFICE, BUT HAD NO SIGNATURES TO THE BEST OF ANYONE' RECOLLECTION.
AT'HIFT TURNOVER (DAY TO AFTERNOON}
THE S.S;S.
ON AFTERNOON SHIFT ASSUMED RESPONSIBILITY FOR THE UNIT COOLER STATUS.
OPERATIONS MANAGEMENT DECIDED TO CANCEL 404D WORK.
~
MARKUP WAS VOIDED IN COIVIPUTER AND PAPERWORK WAS DISCARDED BASED ON PAST PRACTICE.
INLET VALVETO 404D WAS STILL CLOSED.
AFTERNOON S.S.S. TOLD THE S.S.S. THAT THE JOB WAS SCRAPPED.
LOSS OF CONFIGURATI N CONTROL MARK-UP FOR UNIT COOLER 4 4D fCONTINUED)
~
MIDNIGHTS.S.S.
CHECKED THE MARKUP COMPUTER AND FOUND NO RECORD OF MARKUP, WHICH CONFIRIVIED HIS TURNOVER.
HE DECLARED 404D OPERABLE.
~
FIFTEEN'AYS LATER, THE 404D INLET VALVE WAS FOUND CLOSED BY A SHIFT OPERATOR PERFORMING A MONTHLYSURVEILLANCE.
E SAFETY SIGNIFICANCE - INTRODUCTION:
~
COMPONENTS OF STANDBY GAS TREATMENT SYSTEM (SGTS)
FANS/FILTERS VENT STACK/TUNNEL REACTOR BUILDING UNIT COOLERS
~
RELIANCE UPON UNIT COOLERS EVALUATED OYER SEYERAL YEARS (DETAILED NRC STAFF REVIEWS)
ENGINEERING ANALYSIS USED, TO ESTABLISH "DELTA-T"REQUIRElVIENTS FOR OPERATIONS SEASONAL AND OTHER ADJUSTMENTS IVIADE PERIODICALLY BASED UPON OUTSIDE AIR AND LAKE TEMPERATURE AND RX BUILDINGHEAT LOAD CHANGES
- (SPENT FUEL)
~
SIMPLIFIED GUIDANCE PROVIDED TO OPERATIONS PERSONNEL REGARDING COOLING SYSTEM OPERABILITY CONSIDER TRAIN INOPERABLE IF ANY UNIT COOLER IS OUT OF SERVICE GUIDANCE WAS USED TO INDICATE SYSTEM "TECHNICALLYINOPERABLE" IN LER 91-16 ENGINEERING ANALYSIS CAN BE USED TO DETERMINE ACTUAL SYSTEM OPERABILITY
AIRINLEAKAGE FROM OUTSIDE LAKE WATER UNITCOOLERS &,
RECIRCULATION COOLING SYSTEM HEAT VAPOR AIR LEAKAGETO SECONDARY CONTAINMENT
~ EQUIPMENT HEAT
~ LIGHTS/
CABLES SOTS PCV STACK
SAFETY SIGNIFICANCE - ANALYSIS:
~
ANALYSIS COMPARES HEAT LOADS FOR DIVISION I AND DIVISION II EMERGENCY'PERATING CONDITIONS
~
DIVISION II HEAT LOADS ARE 146,000 BTUH LESS THAN DIVISION I.'. PRESENT ANALYSIS IS BASED ON DIVISION I BEING OPERABLE (DIVISION II 600 VOLT BUS FAILURE IS WORST CASE DESIGN LIMIT)
UNIT COOLER 404D IS IN DIVISION II
~
PRESENT DESIGN COOLING CAPACITY OF UC404D IS 73,875 BTUH
~
THE LOSS OF UC404D WOULD NOT CHANGE THE REQUIRED DIFFERENTIAL TEMPERATURE I
SAFETY SIGNIFICANCE -
ONCLUSIONS:
~
UC404D WAS APPROXIMATELY3% OF TRAIN B HEAT REMOVAL CAPABILITY I
~
TRAIN B COULD LOSE APPROXIMATELY4% OF CAPACITYWITHOUT INCREASING DELTA-T
~'OSS OF CONFIGURATION CONTROL ON UC404D HAD NO IMPACT ON SGTS OPERABILITY SYSTEM WAS CAPABLE OF PERFORMING ITS SAFETY FUNCTION
~
NO VIOLATIONOF SGTS TECHNICAL SPECIFICATIONS
INVESTIGATION:
~
PROBLEM IDENTIFIED BY NMPC OPERATIONS.
~
NMPC MANAGEMENTDIRECTED THOROUGH INVESTIGATION.
~
THOROUGH INVESTIGATION PERFORMED (THREE ROUNDS OF INTERVIEWS}TO IDENTIFY FACTS AND ROOT CAUSES.
0
ROOT CAUSES:,
~
POOR WORK PRACTICES (OPERATOR AND STATION SHIFT SUPERVISORS RESPONSIBLE):
COMMUNICATIONS EMPLOYEE ACCOUNTABILITY SU PERVISOR ACCOUNTABILITY
~
CONTRIBUTING FACTOR - NO GUIDANCE ON VOIDING-MARKUPS.
'ORRECTIVE ACTIONS:
~
REVIEWED INCIDENT WITH OPERATING SHIFTS STRESSING:
IMPORTANCE OF CONFIGURATION CONTROL ACCOUNTABILITYFOR ACTIONS NEW DIRECTION PROVIDED ON HANGING AND VOIDING OF MARKUPS:
REQUIREMENT TO DOCUMENT TAGS AS THEY ARE HUNG/REMOVED tEACH COMPONENT}.
PRINT/PERFORM A RESTORATION FOR ANY REPOSITIONED COMPONENT {WHETHER OR NOT MARKUP IS ISSUED)
SAVE/FILE ALL MARKUPS
~
RESPONSIBLE PERSONS COUNSELLED/DISCIPLINED.
~
LONG-TERM PLAN TO BENCHMARKAND IMPROVE THE MARKUP PROCESS.
ADDITIONALINFORMATION
CONTAINMENT SYSTEMS SECONDARY CONTAINMENT STANDBY GAS TREATMENT SYSTEM LIMITING CONDITIONS FOR OPERATION 3.6.5.3 Two independent standby gas treatment (SGTS) subsystems shall be OPERABLE.
APPI ICABILITY:
OPERATIONAL CONDITIONS 1, 2, 3, and ".
ACTION:
a.
. With one standby gas treatment subsystem inoperable:
In OPERATIONAL CONDITION 1, 2 or 3, suspend all VENTING or PURGING of the drywell and/or suppression chamber"" within 30 minutes, and restore the inoperable subsystem to OPERABLE status within 7 days, or be in at least HOT SHUTDOWN within the next 12 ho'urs and in COLO SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
2.
In OPERATIONAL CONDITION *, restore the inoperable subsystem to OPERABLE status within 7 days, or suspend handling of irradiated fuel in the reactor building, CORE ALTERATIONS, and operations
~ with a potential for draining the reactor vessel.
The provisions of Specification 3.0.3 are not applicable.
b.. With both standby gas treatment subsystems inoperable:
In OPERATIONAL CONDITION 1, 2, or 3,.suspend all operations involving VENTING, PURGING, or pressure control of the drywell or suppression chamber and initiate action within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, and in COLO SHUTDOWN within the-following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
2.
In OPERATIONAL CONDITION ", suspend handling of irradiated fuel in the reactor building, CORE ALTERATIONS or operations with a potential for draining the reactor vessel.
The provisions of Specification 3.0.3.
,are not applicable.
" When irradiated fuel is being handled in the reactor building and during CORE ALTERATIONS and operations with a potential for draining the reactor vessel.
"" The requirement to suspend VENTING or PURGING with one inoperable SGTS sub-system shall not apply to the.use of valves 2CPS"AOV108 (14-inch) and 2CPS"AOV110 (14-inch), or 2CPS*AOV109 (12-inch) and 2CPS"AOV111 (12-inch), for primary containment pressure control, provided 2GTS"AOV101 is closed, and its
.2-inch bypass line is the only flow path to the standby gas treatment system.
NINE MILE POINT " UNIT 2 3/4 6-43
CONTAINMENT SYSTEMS SECONOARY CONTAINMENT STANOBY GAS TREATMENT SYSTEM
-SURVEILLANCE RE UIREMENTS 4.6.5.3
. Each standby gas treatment subsystem shall be demonstrated OPERABLE:
a.
At least once per 31 days by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the subsystem operates for at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> with the heaters OPERABLE.
b.
At least once per 18 months or (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings or (2) following paint-ing, fire or chemical release in any ventilation zone communicating with the subsystem by:
1.
Verifying that the subsystem satisfies the in-place penetration and bypass leakage testing acceptance criteria of less than 0.05K and uses the test procedure guidance in Positions C.5.a, C.5;c, and C.5. d of RG 1.52", Revision 2, March 1978, and the subsystem flow:.
rate is 4000 cfm a 10K..
2.
Verifying within 31 days after removal that a laboratory analysis of a representative carbon sample obtained in accordance with Position C.6.b of RG 1.52", Revision 2, March 1978, meets the laboratory testing criteria of Position C.6.a of RG 1.52", Revision 2, March 1978, for a methyl iodide penetration of less than 0. 175K; and C.
3.
Verifying a subsystem flow rate of 4000 cfm a 10K during system operation when tested in accordance with ANSI N510-1980.
After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation by verifying within 31 days after removal that a laboratory analysis of a representative carbon sample obtained in accordance with Position C.6.b of RG 1.52",
Revision 2, March 1978, meets the laboratory testing criteria of Position C.6. a of RG 1.52", Revision 2, March 1978, for a methyl iodide penetration of less than 0.175X.
" ANSI N510-1980 is applicable in place of ANSI N510=1975, and ANSI N509-1980 is applicable in place of ANSI N509-1976.
NINE MILE POINT - UNIT 2 3/4 6-44
CONTAINMENT SYSTEMS SECONOARY CONTAINMENT STANOBY GAS TREATMENT SYSTEM SURVEILLANCE RE UIREMENTS 4.6.5.3 (Continued) d.
At least once per 18 months by:
1.
Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is less than 5.5 inches Water Gauge while operating the filter train at a flow rate of 4000 cfm k 10K.
2.
Verifying that the filter train starts and isolation valves open on each of the following test signals:
a.
Manual initiation from the control
- room, and b.
Simulated automatic initiation signal.
3.
Verifying that the decay heat removal air inlet valves are closed and can be manual.ly opened.
e.
4.
Verifying that the heaters dissipate 20.0 a 2.0 kW when tested in accordance with ANSI N510-1980.
After each complete'or partial replacement of a HEPA filter bank by verifying that the HEPA filter bank satisfies the inplace penetration and bypass leakage testing acceptance criteria of less than 0.05K in accordance with ANSI N510-1980 while operating the system at a flow rate of 4000 cfm a lOX.
After each complete or partial replacement of a charcoal adsorber bank by verifying that the charcoal adsorber bank satisfies the inplace penetra-tion and bypass leakage testing acceptance criteria of less than 0.05K in accordance with ANSI N510-1980 for-a halogenated hydrocarbon refrigerant test gas while operating the system at a flow rate of 4000 cfm 4 10X.
NINE NILE POINT - UNIT 2 3/4 6-45
INTERNALCORRESPONDENCE FOAM 112 2 A 4240 55.01 013 FROM T.
D. Fay Document Control K
T NIAGARA u MOHAWK DISTRICT Nuclear Division DATE June 21, 1991 FILE CODE SUBJECT N<P2 Technical Specification Interpretation
- 425, Rev.
5:
Unit Cooler Operability and Secondary Containment'elta-T Requirements I TERPRETATI 4 ZQZi Attachments A, B, C,
D and E to this interpretation provide the operational requirements for safety-related unit coolers at NMP2 for the remainder of the second fuel cycle.
Attachment A
provides the required differential temperature (Delta-T) which must be maintained between service water and secondary containment -(SC) air.
Attachment B provides general guidelines for inoperable secondary containment unit coolers.
Attachment C,
D, E provide specific direction, for every safety related unit, cooler in the plant.
The applicable OPERATIONAL CONDITIONS can be determined from the corresponding LCO's listed on the appropriate attachment.
In addition to,the requirements on the Attachments, the following general requirements apply:
1.
In OPERATIONAL CONDITIONS 1, 2,
and 3 with secondary containment air temperature equal to or greater than 804F and less than or equal to 100'F, the Delta-T corresponding to outside air temperature specified on Attachment A must be maintained between service water supply header temperature and secondary containment air. If the Delta-T specified on Attachment A is not maintained or if the average of all the ECCS room temperatures falls below service water supply header temperture, declare one otherwise OPERABLE division of SGTS inoperable and take the Action of LCO 3.6.5.3.
2.
In OPERATIONAL CONDITIONS 1, 2 and 3 with secondary containment air temperature less than 80'F or greater than 100'F, declare one otherwise OPERABLE division of SGTS inoperable and take the ACTIONS of LCO 3.6.5.3.
3.
With the exception of 2HVR*UC408A and B and 2HVR*UC409A and B, all Secondary Containment unit coolers are required to be OPERABLE in OPERATION CONDITIONS 1, 2 and 3.
With one or more of the required SC unit coolers out of service, take the action specified on Attachment D.
For the redundant unit coolers 2HVR*UC408A and B and 409A and B,
one unit cooler in each motor control center is required OPERABLE.
With both 2HVR*UC408A and B inoperable or both 2HVR*UC409A and B inoperable, declare the components in the respective motor control center inoperable and enter the respective LCOS.
0
4.
In OPERABLE CONDITION "*" (when irradiated fuel is being handled in the reactor building, during CORE ALTERATIONS and operations with a potential for draining the 'reactor vessel),
neither Delta-T nor the operability of SC unit coolers impacts the operation of the SGTS system or the integrity of secondary containment.
The secondary containment (SC) draw-down analy'sis assures that
- the, SC can be restored to a 1/4" water gage negative pressure within 360 seconds after a
LOCA, assuming a single failure of one 600V bus.
The 360 second draw-down period is used to determine the radiological consequences of the accident.
To achieve the 360 second draw-down time, the analysis assumes that a minimum differential temperature (Delta-T) exists between service water and SC air.
To assure that the plant operates within the design
- basis, the Delta-T assumed in the analysis (Attachment A) is imposed as an operational requirement.
It is not necessary"to maintain the Delta-T requirements in the individual ECCS pump rooms or in the RHR heat exchanger rooms.
These rooms need only be maintained at or above service water temperature.
The operability requirements for safety-related unit coolers are based on the Technical Specification operability requirements for plant equipment, the definition of OPERABLE,=and Equipment Qualification requirements, For unit coolers in the secondary containment, the requirements of the Secondary Containment Drawdown Analysis are also taken into account.
The 'revised draw-down analysis takes credit for all Division I and II SC unit coolers, with the exception of 2HVR*408A/B and 409A/B.
With any one of the required Division I or II unit coolers inoperable, the corresponding SGTS train would not be able to re-establish.secondary containment to the required 1/4" negative pressure within the required 6 minutes.
Unit coolers are essentially support equipment for their. corresponding SGTS trains and loss of a unit cooler is equated to loss of the corresponding SGTS train.
Therefore, the loss of one or more unit coolers in the secondary containment, except those noted
- above, puts the plant in an action statement (Action a.1 of LCO 3.6.5.3).
The revised drawdown analysis also takes credit for the Division III HPCS unit coolers 2HVR*403A and 403B.
Loss of one of these unit coolers results in an inoperable SGTS train and, after 72
- hours, an inoperable HPCS.
Loss of both HPCS unit coolers results in an inoperable SGTS train and an immediately inoperable HPCS.
If, in addition to the two inoperable HPCS unit coolers, one or more Division I or II SC unit coolers are also inoperable, both SGTS trains are declared inoperable.
This interpretation has been approved by the Technical Review Committee a
SORC
( I91~.r
~ i"jrii<
/ '!,-.I Concurrence:
D.
K. Greene Manager Nuclear 1
Licensing 2 \\
.g i-. L~g-,
C/z-.
T.
Conway Aanager - Techn'cal Support Unit 2 TDFj'mls 001301GG Attachments M.
c rmick Plant Manager Unit 2 xc; D. J. Wolniak E. 'Klein S.
Pabby Records Management
NMP2 Secondary Containment Delta-T 2nd Refueling Cycle SC Temperature
>80 & <100 F.
M i
n I
u m
21 20 If f
e e
n g 9 I
a I
(20 F, 19.7 F)
(70 F, 19.6. F)
(80 F, 19.3 F)
T e
18 e
r a
t ur 17 2
(100 F, 17.4 F)
NOTE: Curve is not valid for secondary containment temperatures less than 80 or greater than 100 degrees F.
0 30 40 50 60 70 80 90 100 Outside Air Temperature (F)
ATTACHMENT B SECONDARY CONTAINMENT UNIT COOLERS GENERAL GUZDELZNES (See Attachment D for specifics)
Unit coolers out of service One or more Division I or one or more Division II coolers One or two Division I coolers and one or two Division.II coolers (on different Elevations)
One or two Division I coolers and one or two Division IZ coolers (on the same Elevation)
Three or more Division I coolers and one or more Division II coolers (or vice versa)
Two ECCS unit coolers in the same pump cubicle One Division III cooler (HVR*UC403 A or B)
Two Division III coolers (HVR*UC403 A and B)
Two Division III coolers (HVR*UC403 A and B) and one or more Division I or II coolers Action Receuired 3.6.5.3 (a.l) 3.6.5.3 (a.l) 3.6.5.3 (F 1) 3.6.5.3 (b.l)
System Level LCO and 3.6.5.3 (a.l) 3.6.5.3 (a.l) and after 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> declare HPCS inop 3.6.5.3 (a.l) and declare HPCS inop 3.6.5.3 (b.l) and declare HPCS inop
ATTACHMENT C UNIT COOLER HVC*ACUlA/B HVC*ACU2A/B HVC*ACU3A/B HVC*UC101&108A HVC*UC101&108B HVC*UC102 HVC*103A/B HVC*104 HVC*105 HVC*106 HVC*107 HVK*CHL1A/B HVP*UClA HVP*UClB HVP*UC2 AREA Control Room Relay Rm(E1288)
Remote Shutdown Switchgear Switchgear Switchgear Chiller Room Elect Tunnel Elect Tunnel Cable Area Cable Area Cont Room Chiller DG Control Room DG Control Room DG Control Room C NR L BLDG AND CO~4 DZU ACTION I/XI 1
I/II 1
I/XI 2
I 3
IZ 3
III 4
I/II None I
None IX None I
None II None I/II 1
I 5
II 5
IIX 5
MISC UNIT COOLERS LCO '
3.7.3 3.7.3 3.3.7.4 3.8.3.1/3.8.3.2 3.8.3.1/3.8.3.2 3.8.3.1/3.8.3 '
N/A N/A N/A N/A N/A 3.7.3 3.8.1.1/3.8
~ 1.2" 3.8.1.1/3.8.1.2 3.8.1.1/3.8.1.2 NOTES Area Analyzed 'for loss Area Analyzed for loss Area Analyzed for loss Area Analyzed for loss Area Analyzed for loss of cooling-of cooling of cooling of cooling of cooling HVY*UC2A/C HVY*UC2B/D Serv Water Pump Serv Water Pump I
6 II 6
3.7.1.1/3.7.1.2 Unit coolers are 100% redundant 3.7.1.1/3.7.1.2 Unit coolers are 1004 redundant
ATTACHMENT D SECONDARY CONTAINMENT UNIT COOLERS UNIT COOLER AREA DIV ACTION LCO NOTES HVR*UC401A/D HVR+UC401B/E HVR*UC401C/F HVR*UC402A/B HVR*UC403A/B HVR*UC405 HVR*UC406 HVR*UC408A/B HVR*UC409A/B HVR*UC412A/B HVR*UC413A/B HVR*UC415A/B HVR+UC404 '
HVR~UC407's HVR*UC410's HVR*UC411's HVR*UC414's RHS Pump Room A RHS Pump Roo RHS Pump Roo LPCS Pump Room HPCS Pump Room RHS Hx Rm A RHS Hx Rm B N Elect MCC S Elect MCC RCIC Pump Room Recirc Unit Cooler SGTS Filter Room
-Secondary
-Containment
-Area
-Unit
-Coolers I
7 II 7
II 7
I 7
III 8
I 7
II 7
I 6
II 6
'/II 7
I/II 9
I/II 10 I/II 7
I/II 7
I/II 7
I/II 7
I/II 7
3. 6. 5. 3/3. 5. 1 3.6.5.3/3.5.1 3.6.5.3/3.5.1 3.6.5.3/3.5.1 3 '.5.3/3.5.1 3.6.5.3 3.6.5.3 Various Various 3.6.5.3/3.7.4 3.6.5.3 3.6.5.3 3.6.5.3 3.6.5.3 3.6.5.3 3.6.5.3 3.6.5.3 Unit coolers are 100% redundant Unit coolers are 100% redundant
ATTACHMENT E ACTION REQUIREMENTS FOR INOPERABLE UNIT COOLERS Action 1: Both c'ontrol room chiller subsystems (HVK*CHL1A/B) and their corresponding coolers (HVC*ACU1A/B) are required OPERABLE and the control and relay room temperatures are required to remain below.90 degrees F.
Relay room coolers HVC*ACU2A/B are also required to remain OPERABLE.
With the control room chiller subsystem, the control room cooler or the relay room cooler inoperable in one Division, declare the associated division of the Special Filter Trains inoperable and take ACTIONS required by Specification 3.7.3.
With one or more chiller subsystems or coolers inoperable in both Divisions, declare both divisions of the Special Filter Trains inoperable and take ACTIONS required by LCO:3.0.3 With control room or relay room temperature greater than 90
- degrees, take ACTIONS required by LCO 3.0.3
~
~
I Action 2:
With one remote shutdown cooler inoperable
'.n a division, verify remote shutdown room temperature is less than 90 degrees F.
I With two remote shutdown coolers inoperable or remote shutdown room temperature above 90 degrees F., declare remote shutdown inoperable and take ACTIONS required -by LCO 3.3.7.4 Action 3:
NOTE:
Under certain service water supply header temperature conditions,
~o e switchqear room unit cooler per Division may be removed from service without impacting operability of the switchgear.
A service 'water supply header temperature of less than or equal to 75 degrees F is required to remove 2HVC*UC101A (or B) from service.
A service water supply header temperature of less than or equal to 65 degrees F is required to remove 2HVC*UC108A (or B) from service.
In addition, the control valves for 2HVC*UC101A & B and UC108A
& B may be failed open without impacting the operability of any unit cooler.
With one switchgear room unit cooler in Division I or II inoperable verify the service water supply header temperature withxn the above limits h
With one switchgear room unit cooler in Division I or II inoperable and the service water supply header temperature exceeding the above limits for single unit cooler operation, declare the associated switchgear inoperable and take ACTIONS required by LCO 3.8.3.1 or, when not in Operational Condition 1, 2, or 3, take ACTIONS required by LCO 3.8.3.2.
With more than one switchgear room unit cooler in Division I or II inoperable, declare the associated switchgear
Action 3:
(Continued) inoperable and take ACTIONS required by LCO 3.8.3.1 or, when not in Operational, Condition 1, 2, or 3, take ACTIONS required by LCO 3.8.3.2.
Action 4: With the unit cooler inoperable, declare Division IIZ switchgear inoperable and take ACTIONS required by LCO 3.8.3.1 or, when not in Operational Condition 1,', or 3, take ACTIONS required by LCO 3.8.3.2.
Action 5: With one unit cooler inoperable, declare the associated diesel generator inoperable and take ACTIONS required by LCO 3.8.1.1 (b or d) or, when not in Operational Condition 1, 2, or 3, take ACTIONS required by LCO 3.8.1.2.
Action 6: With two unit coolers in an area inoperable, take ACTlONS required by the applicable LCO.
NOTE:
Unit coolers classified as "redundant" on Attachments C
& D are 100% redundant.
Loss of one unit cooler in a given area.does, not affect the operability of components in the area.
4 Action 7:
NOTE:
The following requirements apply to.all secondary containment unit coolers with Action g7.
With one or more unit coolers in one division inoperable, declare one SGTS train inoperable and take ACTIONS required by LCO 3.6.5.3(a.l).
With one or two Division I unit coolers and one or two Division IZ unit coolers inoperable, declare one SGTS train inoperable and take ACTIONS required by LCO 3.6.5.3(a.l),
provided the inoperabl'e Division Z unit coolers are on different elevations than the inoperable Division II unit coolers.
With one or two Division I unit coolers inoperable and one or two Division II unit coolers inoperable on the same elevation, declare both SGTS trains inoperable and take ACTIONS required by LCO 3.6.5.3(b.1).
With more than two unit coolers, in one division inoperable and one or more coolers in the other division inoperable, declare both SGTS trains inoperable and take ACTIONS required by LCO 3.6.5.3(b.1).-
Zn addition to the above requirements, the following specific requirements apply:
With two unit coolers in any ECCS pump room inoperable, in addition to the above requirements, declare the associated component inoperable take the ACTIONS required by the appropriate system LCO.
0
Action 7:
(Continued)
'With one unit cooler in the RCIC pump room inoperable, in addition to the above requirements, restore the inoperable RCIC pump room unit cooler to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or declare RCIC inoperable and take the ACTIONS required.by LCO 3.7.4 With two unit coolers in the RCIC pump room inoperable, in addition to the above requirements, declare RCIC inoperable and take the ACTIONS required by LCO 3.7.4 Action 8:
With one HPCS unit cooler inoperable, declare one SGTS train inoperable'nd'take the ACTIONS required by LCO 3.6.5.3(a;1).
In addition, restore the inoperable unit'ooler to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or declare HPCS inoperable and take ACTIONS required by LCO 3.5.1..
With two HPCS unit coolers inoperable, declare HPCS and one SGTS train inoperable and take ACTIONS required by LCOs 3.5.1 and 3.6.5.3(a.1).
With two HPCS unit coolers inoperable and one or more Division I or II unit coolers from Action 47 inoperable, declare HPCS and both SGTS trains inoperable and take ACTIONS required by LCOs 3.5.1 and 3.6.5.3(b.l).
Action 9:
With one recirculation unit cooler inoperable, declare one SGTS train inoperable and take ACTIONS required by LCO 3.6.5,.3 (a.1);
With both recirculation unit coolers inoperable, declare both SGTS trains inoperable and take ACTIONS required by LCO 3.6.5.3 (b.1).
Action 10: With one SGTS filter room unit cooler inoperable, declare the associated SGTS train inoperable and take. ACTIONS required by LCO 3.6.5.3 (a.1).
With both SGTS filter room unit coolers inoperable, declare both SGTS trains inoperable and take ACTIONS required by LCO 3 ' ' '
(b.1)
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