ML17256A625
| ML17256A625 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 04/11/1983 |
| From: | Crutchfield D Office of Nuclear Reactor Regulation |
| To: | Maier J ROCHESTER GAS & ELECTRIC CORP. |
| References | |
| TASK-09-06, TASK-9-6, TASK-RR LSO5-83-04-018, LSO5-83-4-18, NUDOCS 8304120622 | |
| Download: ML17256A625 (12) | |
Text
April 11, 1983 Docket No. 50-244 LS05-83-04-018 Hr. John E. Ilaier, Vice President Electric and Steam Production Rochester Gas and Electric Corporation 89 East Avenue Rochester, New York 14649
Dear Nr,
Ilaier:
DISTR I BUTION Docket NRC PDR Local PDR ORB Reading NSIC DCrutchfield HSmith GDick TNambach OELD ELJordan JNTaylor ACRS (10)
SEPB R. Ferguson V. Benaroya O.Parr L.Rubenstein
SUBJECT:
FIRE PROTECTION RULE - 10 CFR 50.48(c)(5) - ALTERNATIVE SAFE SHUTDOWN - SECTION III.G.3 OF APPENDIX R TO 10 CFR 50 - (SEP TOPIC IX-6)
R. E. Ginna Nuclear Power Plant The Fire Protection Rule (10 CFR 50.48 and Appendix R to 10 CFR 60) became effective on February 17, 1981.
Paragraph 60.48(c)(5) required submittal of design descriptions of modifications needed to satisfy Section III.G.-3 of Appendix R to 10 CFR 50 by Harch 19, 1981.
You responded to these requirements in a submittal dated March 19,
- 1981, as supplemented by letters dated October 16,
- 1981, November 9, 1981 and July 28, 1982;
Additional information and c'larification were obtained through telephone conference calls on August 31, 1981 and March 16, 1982; Your submittal discussed the various means used to achieve and maintain safe shutdown conditions,witliout equipment or cabling in any one fire
- area, and proposed modifications or alternatives required due to 'unaccept-able interactions caused by a fire.
In your October 16, 1981 letter, you requested exemptions from the 72-hour requirement of achieving cold shutdown for four of the fire zones.
We have reviewed your submittals and have >concluded that the alternative shutdown methods you described for SD+
these four zones meet the safes shutdown requirements of Appendix R and that exemptions for these zones are not requiredi Oased on our review of Dsu ass~>)
the safe shutdown eva'l4ation, we conclude that your proposed modifications will meet the requirements of Appendix R of 10 CFR 50, Section III.G.3 and III.Lfor those areas identified in Section 2.1 of our enclosed Safety Eva:{'Ijation.
8304i20622 8304ii PDR ADDCK 05000244 F
PDR OFFICE/
SURNAME/
DATE0 NRC FORM 318 (10-80) NRCM 0240 OFFICIAL RECORD COPY USGPO: 1881~8-KO
- 0 A++ ply I
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Nr. John E. Haier April ll, 1983 In regard to your letter dated November 17,
- 1982, ale are unable to consider your request for a schedular exemption until a firm schedule has been proposed.
Your letter isolated that you plan to integrate the fire protection;modifications with modifications from the Systematic Evaluation Program and that the integration is expected to be completed by April of 1983.
lte understand that in the integration process some aspects of the fire protection modifications,'ay be altered.
Your complete modification plan, including schedules, should be included in your schedular exemption request.
Sincerely, Original signed by Dennis N. Crutchfie'Id, Chief Operating Reactors Branch b5 Division of Licensing
Enclosure:
Safety Evaluation cc w/enclosure:
See next page OFFICEI SURNAME$
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NRC FORM 318 (10.80) NRCM 0240 O F F IC IAL RECORD COPY V80PO: 1981~&960
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Nr. John E. Haier April ll, 1983 CC Harry H. Yoigt, Esquire
- LeBoeuf, Lamb, Leiby and t1acRae 1333 New Hampshire Avenue, N.
W.
Suite 1100 Washington, D. C.
20036 ter. Michael Slade 12 Trailwood Circle Rochester, New York 14618 Ezra Bialik
'ssistant Attorney General Environmental Protection Bureau New York State Department of Law 2 World Trade Center New York, New York 10047 U. S. Environmental Protection Agency Region II Office ATTN:
Regional Radiation Representative 26 Federal. Plaza New York, New York 10007 Herbert Grossman, Esq.',
Chairman Atomic Safety and Licensing Board" U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Ronald C. Haynes, Regional Administrator Nuclear Regulatory Commission, Region I 631 Park Avenue King of Prussia, Pennsylvania 19406 Resident Inspector R.
E. Ginna Plant c/o U., S; NRC 1503 Lake Road
- Ontario, New York 1'4519
- Director, Bureau of Nuclear Operations State of New York Energy Office
'Agency. Building 2 Enpire State Plaza
. Albany, New York 12223 "Supervisor of the Tov(n of Ontario 107 Ridge Road West
- Ontario, Hew York 14519 Dr.
Emme th A. Luebke Atomic Safety and Licensing Board U.
S. Nuclear Regulatory Commission Washington, D. C.
20555 Dr. Richard F.
Cole Atomic Safety and Licensing Board
.U.
S. Nuclear Regulatory Commission
.. Washington, D. C.
20555 I"
1
UNITED STATES NUCLEAR REGULATORY COViMISSION Vi'ASHINGTON,D. C. 20555 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION FIRE PROTECTION TO 10 CFR 50, APPENDIX R ITEMS III.G.3 AND III.L ROCHESTER GAS 5 ELECTRIC CORPORATION R.
E.
GINNA NUCLEAR POWER PLANT DOCKET NO. 50-244 1.0 INTRODUC7ION Rochester Gas and Electric Corporation, the licensee,
.has addressed the R. E. Ginna safe-shutdown capability in a submittal dated March 19, 1981..
Additional information has been provided by letters dated October 16,
- 1981, November 9, 1981 and July 28,
- 1982, and telephone conference calls on Augus't.31, 1981 and.March 16, 1982.
The submittal discussed the various means used to achieve and maintain safe shutdown conditions, determined whether safe shutdown could be achieved without equipment or cabling in any one fire 'area, and proposed modifications or alternatives required due to unacceptable interactions caused by a fire.
The licensee has requested an exemption from the 72-hour requirement of achieving cold shutdown since this requirement may not be met in four fire zones.
This exemption was requested in the October 16, 1981 letter.
The staff has concluded that the alternative shutdown methods described by the licensee
.for the four zones meet the requirements of Appendix R to 10 CFR 50 and therefore an exemption for these zones is not necessary.
2.0 EVALUATION 2.1 III.G Compliance During hot shutdown, reactivity control will be accomplished and maintained by the use of either a charging pump, or a safety injection pump taking water from the refueling water storage tank.
The reactor coolant makeup is provided by using the same charging pump or safety injection pump.
Primary system pressure can be increased with these pumps; system pressure can be reduced, if necessary, by releasing steam through the main steam power operated relief valves (PORVs) wi'th the resulting pressure reduction coming from cooldown through the secondary system.
Decay heat removal is accomplished by. providing feedwater to the steam generators with either the turbine driven auxiliary feedwater pump or the standby auxiliary feedwater pump.
Energy is released via steam discharges through the main steam PORVs.
Cold shutdown is maintained by using the RHR system, with solid 'steam generator operation and controlled steam generator blowdown as the proposed alternate cooldown method.
A neve control panel is proposed to be located in the tech'nical support center of the All Volatile Treatment (AVT) building.
We conclude that the use of these systems or the alternative cooldown methods to the RHR system will provide safe shutdown, and are therefore, acceptable.
These alternative methods are further discussed in III.L-Compliance.
The new control center located in the AVT building, incl.udes controls and instrumentation which will be used in case of disabling fire in several ar eas of the plant.
Isolation for the control center itself will be pro-.
vided by a fiber optic transfer switch and an optical transfer permissive re]ay.
Areas where a fire could affect safe shutdown are the air handling rooms, battery rooms, cable tunnel, control room, diesel generator cable vaults, and'elay room.
When the equipment in these areas are operated
~from the control room in the normal mode, their control circuits are isolated from the dedicated control circuits by the open contact of the control transfer relay.
Between the control room and the motor control center (MCC) or switchgear room, the isolation devices for power circuits are circuit breaker transfer switches and manual disconnect switches rated
'or the. loads involved.
The isolation devices for the control circuits
'are fiber optic transfer premissive relays, control switches and transfer relays.
We conclude that the methods of isolation are acceptable.
The licensee has identi'fied five additional areas where alternative shutdown means are to be used.
These areas are the auxiliary building basement west (ABBW), auxiliary bui lding operating south (ABOS), containment vessel building east (CVBE), containment vessel building west (CVBM), and the audi liary building residual heat pit (ABRH).
The specific alternative shutdown modifications for these areas are discussed in Section III.L-
'Compliance, of this SER.
2.2 III.L Com liance 2.2.1 Reactivity control and reactor coolant makeup is provided by the injection of borated water from the refueling water storage tank via one charging pump or safety injection pump.
Decay heat removal is provided by the injection of feedwater via one turbine driven auxiliary feedwater
- pump, and the release of steam through the main steam PORVs.
As a backup, the standby auxiliary feedwater pump can provide the necessary feedwater flow to the steam generators.
Primary system pressure can be increased by the use of one charging pump or one safety injection pump.
Primary pressure can be decreased by venting steam through the main steam PORV with pressure reduction resulting from cooldown through the secondary system.
The licensee has evaluated the ability to attain the performance goals of safe shutdown.
Where unacceptable interactions
- occur, the rerouting of cables, performance of manual operations, addition of instrumentation and equipment, and the use of the proposed remote shutdown control center will be employed to assure safe shutdown.
This control center will be powered with its own AC and DC power source.
All system controls, indica'tors, and instrumentation required to achieve and maintain safe shutdown conditions are provided at the remote shutdown control center.
The following instrumentation will be provided to monitor the reactor condition and system status:
(a)
Cold leg temperature of T avg, (b)
Hotl eg temperature, (c)
Source range flux instrumentation, (d)
Pressurizer pressure and level, (e)'. Steam generator pressure and level, (f)
Auxiliary feedwater flow, (g)
Refueling water storage tank and condensate. storage tank level, (h)
Reactor coolant system temperature and pressure, (i)
Hain steam line pressure, and (j)
Residual heat removal, safety injection and charging flow.
lPe conclude that the above instrumentation provides sufficient information to successfully achieve and maintain safe shutdown condition, and are there-fore, acceptable.
2.2.2 The licensee has stated that associated circuits are not isolated from the normal shutdown circuits due to the complexity of cable routing and high density of cables.
- However, the new dedicated circuits will be routed out of these high fire hazard areas and will be in separate conduit
'with appropriate electrical isolation.
Our concern is that fire induced short circuits, opens, or grounds in non-safety related circuits associated with shutdown circuits could affect the safe shutdown of the normal or alternative shutdown system.
The licensee has provided a detailed methodology by which interactions between associated circuits and dedicated safe shutdown circuits/components will be 'prevented.
(a).
T e
1 Associated Circuits Common Power Su 1
- All power circuits are iso ated through the use of co-ordsqated c>rcuit breakers and transfer switches rated for the loads involved.
(b).
T pe 2 Associated Circuits Spurious Si nals
- Cabling has been rerouted outside the fire zone to meet III.G.2 requirements.
To prevent spurious actuation of certain primary pressure boundary
- valves, these components will be deenergized during normal plant operations.
Additionally 'all dedicated shutdown circuits are provided with isolation devices.
(c).
T e 3 Associated Circuits Common Enclosure All dedicated shutdown circuit cabling are run in separate conduit and are provided with fsolation devices.
Based on the licensee's
- response, we conclude that the methodology of preventing interactions between associated circuits and dedicated shutdown circuits is acceptable.
However, in lieu of providing a formal list of all associated circuits evaluated, we will require that= the appropriate system drawings be available at the site for independent verification of implementation of the methodology.
2.2.3 The licensee has stated that the alternative shutdown. procedures will be written when the shutdown system is installed.
A personnel and manpower review will also. be performed at that time.
We find this acceptable pending the review of the procedures by Region I.
In the applicant's fire analysis, the plant was divided into 62 fire zones.
The analysis demonstrated that the plant could achieve cold shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in at least 57 of the 62 zones.'owever, fires in the remaining five zones may require an excess of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to achieve cold shutdown.
These zones are:
the auxiliary building basement west (ABBW), containment
.. vessel basement east (CVBE), containment vessel basement west (CVBW),
auxiliary building operating south (ABOS) and auxiliary building residual heat pit (ABRH).
Each of these areas contains one or more components of the residual heat removal (RHR) system.
For these
- areas, the applicant has proposed the following alternative methods to be used to achieve safe shutdown.
(a)
ABBW Zone - This zone, located directly above the ABRH zone, contains the two redundant RHR pump cooling units which provide ventilation to the ABRH zone.
A fire in this area could render both cooling units inoperable.
This zone is provided with smoke detectors.
Because of the low combustible loading in this area, no additional fire protection measures have been proposed.
However, to meet III.L requirements, a
spare cooling unit motor and cabling
>chill be kept on site as-a replace-ment.
Portable fans can be used to provide temporary cooling of the ABRH zone.
The staff concludes that the use of portable fans, and the availability of a spare cooling unit motor is acceptable.
(b)
CYBE and CVBW Zones - The RHR motor operated isolation valves and cabling are located in this area.
A fire in this area could render these valves electrically inoperable.
Manual valve operations and modifications to the dedicated shutdown system will be employed to prevent premature opening of the primary isolation valves in the RHR system.
The control power to the RHR motor operated isolation valves (located in zones CVBE and CVBW) will be unavailable (deenergized) during normal plant operation to preclude the possibility
~
of. spurious actuation.
In addition, the safety injection (SI) cold
leg injection valves, the SI accumulator.isola6on valves and the refueling water storage tank (RWST) delivery valve will be similarly deenergized.
All of the above motor operated valves can be operated manually.
The con'trol for the RWST discharge valves will be modified to include fiber optic transfer permissive relays, control switches and transfer relays to prevent spurious actuation.
We conclude that the proposed means of preserving primary pressure boundary integrity is acceptable.
(c)
ABOS Zone - This zone contains the component cooling water (CCW) pumps and heat exchangers which must be operable if the RHR system is to b'
used for cold shutdown.
This area can be exposed to transient com-bustibles; and exposure fire may disable the pump motors or power cables.
The licensee has.stated that a spare non-seismic Category I CCW pump and power cabling, along with materials for installation will be stored on site.
Procedures will be developed for the instal-lation of the pump to ensure the capability to achieve cold shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
The licensee has performed a study which confirms that such a
pump can be installed within the required time constraint.
We conclude that the concept of CCS pump replacement in the event of a fire that would damage the installed redundant CCW pump is acceptable.
{d)
ABRH Zone - This zone contains the two RHR pumps.
A fire in this zone could incapacitate both RHR pumps.
Smoke detectors are provided in this area.
Because of the low combustible loading in this area, no additional fire protection measures have been proposed.
The licensee states that, following a di sablin'g fire in the Auxiliary Building Residual Heat Removal Pit (ABRH) zone, no equipment or auxiliary equipment required for shutdown, other than the RHR system, will be affected.
Following such a fire, cooldown can be achieved by three distinct modes:
a.
- Steaming, via steam dump to the condenser and/or main steam
- PORVs, b.
Filling the steam generators with auxiliary feedwater, and c.
Solid steam generator operation with water-water heat transfer.
Cooldown of the plant would be accomplished using normal plant shutdown methods and procedures unti 1 the primary t'emperature is reduced to 350 F.
Heat removal would be accomplished by steam dump to the condenser and/or steam relief through the main steam power operated relief valves (PORVs).
Cooldown to 350oF can be achieved in 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or less employing a cooldown rate less than the Technical Specification limit of 50oF/hour.
Conti,nued steaming out the main steam PORVs can bring the primary temperature down to 260 F within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after shutdown, and to 245 F within 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br />.
Filling both steam generators with 80oF water 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> afte'r shutdown will reduce the system temperature from 245oF to approximately 180oF and remove the small amount of decay heat generated.
Following'ystem temperature reduction below 200oF, water solid
~ I steam generator operation can maintain the primary temperature below 200oF within 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> after shutdown by employing natural circulation in both the primary and secondary sides of the steam generator.
The necessary auxiliary feedwater (AFW) flow rate for the expected decay heat removal can be provided by either standby AFW pump or both AFW pumps at system pressure.
The required water discharge from the steam generators could be directed to either the condenser or outside the turbine building via the bypass
. lines around the main steam isolation valves.
- Thus, a liquid or liquid/steam mixture will not be released through the main steam PORVs.'ased on the licensee's.submittal, we conclude that the plant has the capability to achieve and maintain cold shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of plant shutdown utilizing the above described alternate cold shutdown method; 3.0 COHCLUSIONS Based 'on our review of the safe shutdown evaluation, we conclude that the licensee's proposed modifications will meet the requirements of Appendix R
of 10 CFR 50, Section, III.G.3 and III.L for those areas identified in Section 2.1 of this evaluation..
4.0 ACKNOHLEDGENENTS The following llRC personnel have contributed to this evaluation:
T.
Chan J.
Lyons T.
Wambach pate:
April ll, 1983
14
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