ML17244A721
| ML17244A721 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 06/20/1979 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17244A722 | List: |
| References | |
| TASK-08-02, TASK-RR NUDOCS 7908010327 | |
| Download: ML17244A721 (17) | |
Text
SAFETY EVALUATION MODIFICATION TO SAFETY INJECTION ACTUATION SYSTEM R.
E.
GINNA NUCLEAR POWER PLANT UNIT 1
I.
INTRODUCTION The licensee Rochester Gas and Electric Coproration in its submittal of June 7, 1979 proposed certain modifications to the safety injection actuation system logics for R.
E. Ginna Nuclear Power Plant, Unit 1
in response to Item 3 of IE Bulletin 79-06A dated April 14, 1979.
Since the date of licensing until the issuance of IE Bulletin 79-06A safety injection was initiated, in addition to other parameters, based on coincident trip of one-of-three matched pairs of low pressurizer level and low pressurizer trips.
Item 3 of IE Bulletin 79-06A directed all facilities using pressurizer water level coincs.dent with pressurizer pressure for automatic initiating of safety injection to trip the low pressurizer level setpoint bistables so that when pressurizer pressure reaches the low setpoint, safety injection would be initiated regardless of the pressurizer level.
Because of the concern that this action has resulted in placing R.
E.
Ginna Nuclear Plant Unit 1 in a condition (one-out-of-three trip) which is more susceptible to spurious actuation of the safety injection system, the licensee has proposed the following modifications and Technical Specification changes to alleviate this si tuation.
II.
EVALUATION The proposed modification to the safety injection actuation system consists of removing the pressurizer level signal from each of the pressurizer level/pressure channel trips and converting the system to a two-out-of-three logic based on the pressurizer low pressure trips.
The instrumentation logic receives pressurizer pressure signals from three pressure transmitters and initiates a safety injection actuation when two of the three signals reach the low pressure setpoint.
This modification does not involve a change in the setpoint.
These modifications will satisfy the requirements of IEEE 279-1971, and other applicable standards.
The modifications will be implemented with the plant in the shutdown condition.
III.
CONCLUSION Based on our review of the licensee's modifications to the safety injection the requirements of IEEE 279-1971 and Technical Specifications are correct; submittal, we conclude that the actuation system logic satisfy that the associated change in and therefore, are acceptable.
ENCLOS 1
FIRE PROTECTION -
ROBERT E.
GINNA, DOCKET NO. 50-244 STAFF RES PONS E TO THE LICENS EE '
COMMENTS (DATED MARCH 13)
ON SER Technical S ecifications:
(1)
Licensee's Comment Basi.s for Section 3.14,P 3.1,4-4.
The yard hydrants on the'outheast corner of the yard loop provides back-up fire suppression capabi1ity not ~rimar capability for the trans-formers and standby auxiliary feedwater. building.
Staff's Res onse We accept the licensee's contention that this yard hydrant provides ~back-u, instead of ~rimar fire suppression capability for the above described areas.
(2)
Licensee's Comment Specification 4.15.2.e.
For clar'ification, the method of obtaining the sample from the day tank has been discussed with members of the NRC staff.
It was agreed that a sample would be withdrawn from the fuel line running from the day tank to the diesel engine.
Staff's Res onse We accept the proposed method of sampling.
Fire Protection Safet Evaluation Re ort (1)
Licensee's Comment P.3-2 item 3.1.4, P.4-9, item 4.4.5 and P.5-2 item 5.1.6.
A curb will be installed around the reactor coolant pump only if an automatic suppression system is installed (see item 3.1.39).
In this case it would be installed by 6/81.
If an oil collection system is installed, curbs will not be installed.
Staff's Res onse We agree.
(2)
Licensee's Comment
~P.3-2 item 3.1.8 calls for the intermediate building cable tunnel opening to be sealed.
This is inaccurate since an entrance is necessary.
Item 3.1.5 calls for a three hour rated "A" labelled door for this opening.
Staff's Res onse In P.1:2-4 and P.4.3-7 of the licensee's "Fire Protection Evaluation", dated March 1977 and also in the licensee's response to the staff's request for additional information Ho. 57, the licensee stated the opening will be sealed.
(3)
Licensee 's Comment P.3-.2 item 3.1.8.
In order to resolve concerns about a fire barrier between the nitrogen storage building, which is used to store hydrogen as well, and the auxiliary building and about the hydrogen piping within the auxiliary building (see item 3.1.48) an alternative is being considered.
This alternative would involve moving the hydrogen stora'ge to a separate location removed from the auxiliary building and relocating the hydrogen piping in the auxiliary building.
Staff's Res onse The staff will evaluate the proposal when the licensee decided on, and provided details of, the.modification.
(4)
Licensee's Comment P.3-4 item 3.1.20 has the "A" and "B" label designations switched for the diesels.
Staff's Res onse We agree the SER is in error.,
(5)
Licensee's Comment P.3-4 item 3.1.22 (3) and P.4-5, item 4.3.1.3 require snow removal procedures during snow storms.,
We believe the words "to the extent "practical" should be added to this.
The length-and intensity of a storm has a tremendous bearing 'on what. is necessary during a storm.
This was discussed during our deliberations of this particular item.
~St ff'l We request the 1 icense'e to prescribe the condition under which snow removal operation will be initiated.
(6)
Licensee's Comment P.3-6 item 3.1.29 and P.4-5 item 4.3.1.2.
These paragraphs require the diesel fire pump engine to be operated for a minimum of 1/2 hour each month.
The Technical Specifications require a 15 minute test, not a 1/2 hour test.
Therefore, these paragraphs should be corrected to reflect a
15 minute. test.-
As discussed with the NRC Staff, the 15 minute test is adequate to determine oper ability.
V Staff's Res onse The licensee is requested to justify his request for deviation from this requirement which is explicitly provided in NFPA 20, 1976, Section 8-6.1.
(7)
Licensee's Comment P.3-7 item 3.1.38 and p.4-14 item 4.11.
This requirement has never been discussed with us by the NRC Staff.
The wall separating the north and south sections of the intermediate building has never been considered a fire barrier.
The fire hazards analysis used the wall as a zone border but pointed out that the wall was there for radiological considerations and the drawings do not indicate that it qualifies as a fire barrier.*
We see no justification for upgrading this wall.
Staff's Res onse The licensee's "Fire Protection Evaluation", dated March 1977, treats this wall as a fire barrier.
The BTU loadings in the intermediate building are calculated as though each floor in the building is divided into two fire areas by the wall and the fire hazards in the building are discussed accordingly.
Our evaluation has considered this wall as a fire barrier. If the licensee does not want to consider the subject wall as a fire barrier, their analyses should be revised.
(8)
Licensee's Comment P.3-11 item 3.1.15.
In the schedule for completion of modifications, Table 3. 1, this item is incorrectly listed as being complete.
Although flame retardant coating has been applied in the east cable vault, the modifications in the relay room will not be completed until 6/81.
Staff's Res onse We request that the licensee justify extending the implementation date until June 1981 which is significantly beyond our target date of October 1980.
(9)
Licensee's Comment P.3-11 item 3.1.29.
To be consistent with Technical Specification 4.15.2.e, it should be clarified that testing of the diesel fire pump fuel oil is required after }3une 1, 1979.
The deferred effective date is allowing time for a sample tap in the fuel oil line to be installed.
Staff's Res onse We accept that the diesel fire pump fuel oil test will be started on June 1, 1979.
(10) Licensee's Comment P.4-2 item (4) states that source range neutron detectors
'are required during shutdown.
This is not true and should be deleted.
Shutdown condition can be ensured through addition of sufficient borated water to the primary system.
Staff's Res onse I
We do not consider shutdown without means of monitoring the reactor reactivity "safe". If the concentration of boron instead of neutron is to be monitored~such provision should be listed as required for safe shutdown.
(ll) Licensee's Comment P.4-4 item 4.3.1.1 states there are two locations for wall hydrants on the plant.
Actually, there are four.
~5ff' We have re-checked the licensee's fire water piping diagram and verified that there are four wall hydrangs.
(12) Licensee's Comment P.4-5 item 4.3.1.3 discusses modifications to the fire service water piping to reduce the number of interior hose stations that might be isolated if one section of the piping were taken out of service.
Actually, planned modifications are for the purpose of preventing isolation of both fixed protection and hoselines that protect the same area.
Staff's Res onse The plant's fire water piping arrangement is such that a break in pipe sections 10-FS-125-10 or 10-FS-125-11, or isolation of these sections for the purpose of repair or maintenance would disable all interio'r hose stations in the auxi liary and the intermediate buildings.
We do not believe such possibility should'e neglected.
Because it does not appear possible to provide back-up manual hose capability within one hour (Tech Spec requirement) to so many interior hose stations without appropriate modifications to the piping system, certain limitation to the operating condition has to be imposed if the licensee. does not agree to this modification.
(13) Licensee's Comment P.4-6 item 4."3. 1.4 refers to elevation 293 of the auxiliary building.
We believe this should be elevation 293 the controlled (south) side of the intermediate building.
Staff's Res onse Me agree.
(14) Licensee's Comment P.4-9 item 4.4.4 discusses the battery room ventilation system.
The sy'tem described is the proposed modification, not the existing system.
The existing system has nearly 100K makeup air.
Staff's Res onse We agree.
Licensee's Comment P. 4-10 item 4'.6 discussed emergency lighting.
Clarification would help here as the implication is that emergency lighting is not now generally available.
Battery operated emergency lighting units are being added throughout the plant,
- However, in addition to the normal lighting system, emergency lights are,'.
presently installed throughout the plant and are run off the emergency busses.
'~R'ff'
'R M,e agree.
(16) Licensee's Comment P. 4-11 item 4.9.1 calls for the door between the relay room and the computer room to be upgraded to a three hour labelled door.
Since the walls are rated at two hours and the modified ceiling at one'. hour, the door requirement should be 1 1/2 hour, "8" label.
Staff's Res onse Combustibles in the computer room correspond to nearly 3-hour' fire severity.
The 3-hour fire rating is required for the wall, the ceiling, the door and penetration seals to contain such fire.
(17) Licensee's
.Comment P. 4-14 item 4.12 discusses the cable tunnel accesses.
There seems to be some confusion as to the accessibility of the tunnel.
There are three tunnel endings. 'he ending at the control building is sealed with no access.
The ending 'at the intermediate building is open but-a modification is planned to close this opening with an access incorporated in the barrier.
All three barrier closings will be.rated at three hours.
Staff's Res onse Me accept the licensee's revised description.
(18) Licensee's Comment P.
5-1 item 5.1.3 states that "some" valves required for safe shutdown and primary coolant temperature instrumentation could be 'damaged in 'a reactor coolant pump lubricating-oil fire.
One valve in each reactor coolant pump area could be damaged.
Further-more, other flow paths are available should the valve in either reactor coolant pump area he inoperable.
These flow paths would permit the plant to be maintained in a safe shutdown condition.
In addition, loss of'he primary coolant temperature indication for:a'loop would not preclude the plant from being maintained in a safe shutdown condition.
Staff's 'Res onse The licensee's submittals does not include a description of the separation between these redundant-valves and the separation between the redundant instrumentation.
The staff is stilie unable to determine if more than one valve or one temperature indication could be damaged by a fire.
The licensee is requested to provide a detailed description of such separation..
Uicensee's Comment P. 5-2 item 5.1.6 {2) states that a hose station will be provided for all hazards and safety-related equipment.
Certain safety-.
related equipment is not combustible and does not require protection.
Protection will be provided by means of suppression 'for any hazards which could affect safety related equipment.
'Staff's'Res 'onse We request the licensee to provide a description of his conceptual design of the proposed suppression systems.
(20) Licensee's Comment P.5-4 item 5.3.3 and P.5-5 item 5.3.6(6) have the "A" and "B" diesels reversed.
Staff's Res onse (21)
We agree.
Licensee 's Comoent P.
5-5 item 5.3.6 (7) was not discussed or committed to.'afe shutdown capabilities should a fjre occur in this area will be addressed in the Shutdown Analysis which is item 3.,2,1, It. should be noted that flame retardant cable coating has been appTi'ed to the cables in this vault and detection will be installed, There is no external heat source in this vault and hence a fire has low credibility.
Staff's Res onse Based on the present fire hazards
- analysis, we cannot agree with the licensee's.implication above that cable coating and fire detection provide adequate protection for this cable vault.
{22) Licensee's Comment P.5-6 item 5.4.2 states that certain transient combustibles were not included in the licensee's Fire Portection Evaluation and that there were "large" quantities of paper,
- clothes, and paints on
" the operating floor.
All these transients were included in the report in a lump figure rather than being spelled out individually.
Much of the paper in the listed nine cabinets has been removed and the clothes are actually rags for cleaning purposes.
The'ontents of these cabinets were however included in the Fire Protection Evaluation.
Staff's Res onse Our SER states that such transient combustibles as wood scraps, oil in drums, gas bottles, etc., which we found in this area during the site visit were not included in the licensee's analysis.
(23) Licensee's Comment P.5-7 item 5.4.6(6) talks about doors and entrances.
There is only one entrance at this level and it will be upgraded with a 3-hour rated door.
Sta'ff',s Res onse (24)
We agree Licensee's Comment P.5-7 item 5.4.6 suggets storage of paper, cloth, etc.
should be limited to approximately one weeks'upply-at the most.
To be consistent, this time period should be two weeks as shown in item 3.1.47.
Staff's Res onse We agree.
(25) Licensee's Comment P.5-8 item 5.5.3 lists containment cooling as a safety-related system required for shutdown.
In fact, it is not required for shutdown.
Staff's Res onse Table 3-1 of the licensee's "Fire Protection Evaluation",
dated March 1977, lists containment cooling units as safe shutdown related equipment.
(26) Licensee's Comment P.5-8 item 5.5.4 states that the turbine driven auxiliary feedwater pump oil tank is curbed.
It is not curbed but has drainage around it.
Staff's Res onse P.4.3-6 item of the licensee's "Fire Protection Evaluation" explicit'ly stated that the tank is located in a curbed area.
(27) Licensee's Comment P.5-9 item 5.5.5 lists the 253' 6" elevation of the intermediate building as the intermediate floor.
We agree.
(28) Licensee's Comment P.5-9 item 5.5.6(2) calls for water spray systems to be provided for a portion of the intermediate floor.
The elevation is the basement floor.
Staff's Res onse We agree.
(29) Licensee's Comment P.5-9 item 5.5.6(4) calls for the cable tunnel to be sealed.
In fact, a barrier will be provided wi th a rated door.
Staff's Res onse We agree.
(30) Licensee's Comment P.5-9 item 5.5.6 states that we committed to provide corrective modifications, "pending" the safe shutdown analysis.
This is incorrect.
We will perform modifications which are necessary following the 'analysis.
Staff's Res onse We agree.
(31) Licensee's Comment P.5-11 item 5.7.5 describes a, modification that was being planned at the time of the NRC site,visit in June 1978.
In fact, the present system has nearly 100% makeup air.
Staff's Res onse We agree.
(32) Licensee's Comment P.5-12 item 5.8.3 is incorrect.
The control room ventilation system is not required for safe shutdown.
The safe shutdown analysis will determine if the cables from the cable tunnel are required for safe shutdown and hence it should not be stated at this time that fire will leave the plant without the capability to safely shutdown.
Staff's Res onse Table 3-1 of the licensee's "Fire Protection Evaluation",
dated Narch 1977 listed the control room air handling unit, the return air fan and the ventilation d'amper as safe shutdown related equip-ment.
.We agree with the licensee's statement on the cable tunnel.
(33) Licensee's Comment P.5-13 item 5.8.6 states that "pending" the safe shutdown analysis, necessary modifications have been committed to.
We will perform any modifications which are necessary following the analysis.
Staff's Res onse We agree.
(34) Licensee's Comment P.5-13 item 5,9.3 states that a fire in this room will deprive the plant of the capability to safely shutdown.
This has not been established.
~Rff' We agree;
- however, the licensee, to this date, has not established to the contrary, (35) Licensee's Comment P.
5-13 item 5.9.5 states that the existing fire protection is inadequate to prevent a fire from damaging redundant cables in the room which serve safety-related systems required for safe shutdown.
This has not been established.
Staff's
Response
The staff made. the conclusion from our observation that the cable separation is inadequate, that both divisions of cables are present, and that the arrangement of control boards in the control room and
'elay cabinets in the room will necessitate cables serving safe shutdown, system to be routed through this cable spreading room.
(36) Licensee's Comment P..
5-15 item 5.10.4 does not include all of the fire protection provided for the area.
In addition to the C02 extinguishers, ionization detection is installed in the return air duct, one pressurized water extinguishers is installed in the room, and a
hose line is available outside the room in the turbine building.
Staff's Res onse The above information is not in either Section 4.4.6, or Drawing Ho.
D-024-014 of the licensee's "Fire Protection Evaluation" dated March 1977 which describes fire protection for this area.
The licensee is requested to revise these documents to provide such information.
(37) Licnesee's Comment P.
5-15 item 5.10.6 states that a smoke detector will be installed sn eac sa e y-h f t -related cabinet, etc.
The commitment was that early warning detection would be provided for each cabinet.
We have not agreed specifically to install smoke detectors and
- have not comnitted to putting the detection inside the cabinets.
Staff's Res'onse We agree.
(38) Licensee's Comment P.
B-2 staff response indicates a delayed decision on manual versus automatic operation of water spray system(s) pending further fire hazards analysis.
There does not appear to be any reason to defer a decision on this item and it may. adversely affect design and hence installation of any fixed systems in this area.
Therefore we request that the Staff promptly reach a decision so that our installation schedules are not adversely affected.
'~Sff'R Based on the present fire hazards
- analysis, the staff requires an automatic spray system, However, protection jn addition to the automatic suppression capability may be required to assure safe shutdown, if the shutdown analysis could not assure preservation of the safe shutdown capab il.ity.
0
~
gag Q.S $7~