ML17311A262
| ML17311A262 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 09/02/1994 |
| From: | Brian Holian Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 9409140144 | |
| Download: ML17311A262 (33) | |
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t UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON> D.C. 20555-0001 September 2,
1994 LICENSEE:
Arizona Public Service Company FACILITY:
Palo Verde Nuclear Generating Station, Units 1, 2, and 3
SUBJECT:
SUHHARY OF HEETING HELD ON JULY 27,
- 1994, TO DISCUSS
. FIRE PROTECTION ISSUES On July 27, 1994, the NRC staff met with representatives of Arizona Public Service Company (APS) to discuss the status of the Fire Protection Program at Palo Verde.
Significant issues discussed included their fire protection licensing basis (including deviations),
Thermo-Lag, and their 10 CFR Part 50, Appendix R, Reconstitution Project.
Persons attending the meeting are listed in Enclosure 1.
The viewgraphs presented at the meeting are in Enclosure 2.
APS representatives summarized their fire protection licensing basis.
All three units were licensed to operate after January 1,
- 1979, and therefore are considered non-Appendix R plants.
The Palo Verde Technical Specifications contain the standard fire protection license condition. 'PS representatives discussed their fire protection change
- process, whereby they ensure that safe shutdown can be demonstrated and that no unreviewed safety question exists.
This topic included a discussion of deviations from NRC fire protection guidelines.
- APS, by letter of April 29,
- 1993, had submitted requests for deviations from commitments associated with Part 50, Appendix R.
- The deviations clarify, or add detail to, circuits and separation
- schemes, discuss process variable exceedences, credit an additional operator action, and discuss the addition of the Train E charging pump to the analysis.
The staff had briefly reviewed these deviations prior to the meeting, and following the licensee's presentation of their fire protection change
- process, the staff stated that these changes are appropriate to be included in the licensee's change process and do not need prior staff review and approval.
Accbrdingly, the deviation letter of April 29, 1993, is considered withdrawn, completing staff action on TAC Nos.
- H86935, H86936, and H86937.
The licensee described their Thermo-Lag reduction effort.
Preliminary engineering analyses performed by the licensee support the elimination of approximately 80 percent of the Thermo-Lag used to meet Appendix R commitments (e.g., there will be no 3-hour barriers credited in the new analyses).
A large amount of the Thermo-Lag that no longer needs to be credited in the analyses was conservatively installed on circuits to minimize manual actions.
These manual actions have now been determined, by the licensee, to be feasible and in accordance with Appendix R.
The staff notes that the licensee does not plan on actually removing the Thermo-Lag barriers that are no longer credited in the analyses, unless ampacity concerns warrant their removal.
The licensee also discussed deviations that were approved by the staff for Palo Verde in January 1990, primarily regarding interveqing steel penetrations that did not have the insulation insta] l,ed.,aq;.extgggi,yely as the tested configuration.
The stpff~ommehted'Qh'a't'~thg<Qi'je',
'hould be careful 9409>4oi44 940vo~'DR
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APS Company not to inappropriately broaden the scope of these deviations in their application to the Thermo-Lag reduction effort.
The staff also commented that the licensee should perform a comprehensive study of the circuits to ensure that, for example, Thermo-Lag that was originally installed for spurious signal issues is not removed based on a revised analysis.
The licensee commented that the appropriate analyses would be completed prior to removing credit for any fire barrier.
The staff noted that a followup inspection would most probably be conducted to ensure that the Palo Verde units are in compliance with their original licensing basis.
Finally, the licensee summarized their ongoing Appendix R reconstitution project.
The Final Safety Analysis Report has been
- updated, with the exception of pending deviatipns.
An updated implementation schedule was provided.
Brian E. Holian, Senior Project Hanager Project Directorate IV-2 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket Nos.
STN 50-528, STN 50-529, and STN 50-530
Enclosures:
l.
Attendance List 2.
Viewgraphs cc w/enclosures:
See next page
Arizona Public Service Company Palo Verde CC:
Mr. Steve Olea Arizona Corporation Commission 1200 W. Washington Street Phoenix, Arizona 85007 T.
E. Oubre, Esq.
Southern California Edison Company P. 0.
Box 800
- Rosemead, California 91770 Senior Resident Inspector Palo Verde Nuclear Generating Station 5951 S. Wintersburg Road
- Tonopah, Arizona 85354-7537 Regional Administrator, Region IY U. S. Nuclear Regulatory Commission Harris Tower h Pavillion 611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011-8064 Mr. Charles B. Brinkman, Manager Washington Nuclear Operations ABB Combustion Engineering Nuclear Power 12300 Twinbrook Parkway, Suite 330 Rockville, Maryland 20852 Mr. Aubrey V. Godwin, Director Arizona Radiation Regulatory Agency 4814 South 40 Street
- Phoenix, Arizona 85040 Chairman Maricopa County Board of Supervisors 111 South Third Avenue
- Phoenix, Arizona 85003 Jack R.
- Newman, Esq.
Newman 8 Holtzinger, P.C.
1615 L Street, N.W., Suite 1000 Washington, D.C.
20036 Mr. Curtis Hoskins Executive Vice President and Chief Operating Officer Palo Verde Services 2025 N. 3rd Street, Suite 220
- Phoenix, Arizona 85004 Roy P. Lessey. Jr.,
Esq.
Akin, Gump, Strauss, Hauer and Feld El Paso Electric Company 1333 New Hampshire Avenue, Suite 400 Washington, DC.
20036 Ms. Angela K. Krainik, Manager Nuclear Licensing Arizona Public Service Company P. 0.
Box 52034
- Phoenix, Arizona 85072-2034 Mr. William T. Stewart Executive Vice President, Nuclear Arizona Public Service Company Post Office Box 53999
- Phoenix, Arizona 85072-3999
APS Company
~ 9 WF(
7 ScZ September 2,
1994 not to inappropriately broaden the scope of these deviations in their application to the Thermo-Lag reduction effort.
The staff also commented that the licensee should perform a comprehensive study of the circuits to ensure that, for example, Thermo-Lag that was originally installed for spurious signal issues is not removed based on a revised analysis.
The licensee commented that the appropriate analyses would be completed prior to removing credit for any fire barrier.
The staff noted that a followup inspection would most probably be conducted to ensure that the Palo Verde units are in compliance with their original licensing basis.
Finally, the licensee summarized their ongoing Appendix R reconstitution project.
The Final Safety Analysis Report has been
- updated, with the exception of pending deviations.
An updated implementation schedule was provided.
ORIGINAL SIGNED BY:
Brian E. Holian, Senior Project Manager Project Directorate IV-2 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket Nos.
STN 50-528, STN 50-529, and STN 50-530
Enclosures:
1.
Attendance List 2.
Viewgraphs cc w/enclosures:
See next page DISTRIBUTION w all enclosures:
k t-Fil ran A. B. Beach, RIV PD 4-2 Reading DISTRIBUTION w Enclosure 1:
R.
Zimmerman D. Foster-Curseen E. Jordan, D/AEOD ACRS (10)
W. Russell/F. Hiraglia NRC
& Local PDRs T. quay B. Holian K. Perkins, RIV/WCFO J.
Roe OGC NRC Participants J; Mitchell, EDO OFC NAME PDIV-2 DRPW PD IV-2/PH DFoster-Curseen LTran PDIV-2 PH BHolian:
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Jg EE PD
/D TQ ag DATE 8
/94 8/ Q94 8 >94 8,94 8
/94 OFFICIAL REC RD COPY DOCUMENT NAME:
PVFPJL27.HTS'RC A(F CEQTFg ~;" y
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's APS Company September 2,
1994 not to inappropriately broaden the scope of these deviations in their application to the Thermo-Lag reduction effort.
The staff.also commented that the licensee should perform a comprehensive study of the circuits to ensure that, for example, Thermo-Lag that was originally installed for spurious signal issues is not removed based on a revised analysis.
The licensee commented that the appropriate analyses would be completed prior to removing credit for any fire barrier.
The staff noted that.a followup inspection would most probably be conducted to ensure that the Palo Verde units are in compliance with their original licensing basis.
Finally, the licensee summarized their ongoing Appendix R reconstitution project.
The Final Safety Analysis Report has been updated, with the exception of pending deviations.
An updated implementation schedule was provided.
ORIGINAL SIGNED BY; Brian E. Hol i an, Seni or Project Hanager Project Directorate IV-2 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket Nos.
STN 50-528, STN 50-529, and STN 50-530
Enclosures:
l.
Attendance List 2.
Viewgraphs cc w/enclosures:
See next page DISTRIBUTION w all enclosures:
Docket File E.
Adensam L. Tran E
A. B. Beach, RIV PD 4-2 Reading DISTRIBUTION w Enclosure I:
R.
Zimmerman D. Foster-Curseen E. Jordan, D/AEOD ACRS (10)
W. Russell/F. Hiraglia NRC
& Local PDRs T. Quay B. Holian K. Perkins, RIV/WCFO J.
Roe OGC NRC Participants J. Mitchell, EDO OFC PDIV-2 DRPW PDIV-2/PH PDIV-2 PM SPLB lg EE
'PD
/D BHolian:
k 8/> 94 NAME DFoster-Curseen LTran 8
94-DATE 8
/94 8/ +94 OFFICIAL REC RD COPY DOCUMENT NAME:
PVFPJL27.MTS 8
/94 TQ a
W/94
Enclosure 1
Ju 27 199 Fire Protection Issues Meetin Palo Verde Nuclear Generatin Station List of Attendees arne Frank Garrett Nancy Turley Pat Madden Paul Gill Daniele Oudinot Linh Tran Brian Holian Or anization APS Fire Protection APS Licensing NRR/DSSA NRR/DE NRR/DSSA NRR/DRPM NRR/DRPM
Presentation to the Nuclear Reactor Regulation (NRR) on the 4'M~
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July 27, 1994
AGENDA I. PVNGS Fire Protection Licensing A.
History B.
Current PVNGS Licensing Basis C.
Fire Protection Program Change Process II~ Thermo-Lag A.
Summary of SQ.64(f) Response B.
Current Status of Thermo-Lag Reduction Effort C.
Overview of Future Actions III.Appendix R. Reconstitution Project Modifications A.
Overview B.
Status
PVNGS Fire Protection Licensing
PVNGS Fire Protection Licensing History PVNGS construction permit application docketed prior to July 1, 1976 (BTP 9.6-1, Appendix A plants)
~m PVNGS units licensed to operate after January 1, 1979 (Non-Appendix R plants)
Fire Protection removed from Technical Specifications and Standard License Condition implemented (1987 for U1 8 U2, initiallyfor U3) 1989 discussions with staff over a 50.69 for a fire protection change Violation 90-02-05 issued due to the 60.59 change
+~ Inconsistent guidance on NRC review of Appendix R deviations
Major Elements of PYNGS CUrrent Licensing Basis 10 CFR 50.48 10 CFR 60, Appendix A, GDC 3 Commitment to 10 CFR 50, Appendix R, Sections III.G, III.J and III.O BTP APCSB 9.6-1 Appendix A, dated 8I23/76 Standard License Condition UFSAR Chapter 9.5.1 Fire Hazards Analysis
Fire Protection Program Change Guidance Standard License Condition allows for changes to be made without NRC approval as long as changes do not adversely affect the ability to achieve and maintain safe shutdown Generic Letter 86-10 guidance:
~ Licensees committed to meet Appendix R,Section III.G, III.J and III.O should identify and justify deviations in the FSAR or FHA
~ Provisions of 10 CFR 50.59 apply directly for changes the licensee desires to make in the fire protection program that would not adversely affect the ability to achieve and maintain safe shutdown. In this context, the determination of the involvement of an unreviewed safety question defined in 50.59{a){2) would be made based on the "accident...previously evaluated" being the postulated fire in the fire hazards analysis for the fire area affected by the change.
GL 88-12 states that former TS requirements willbecome an integral part of the Fire Protection Program and changes willbe subject to the Standard License Condition
Current Fire Protection Program Change Process Change Initiated Submit to NRC for Review Can Safe Shutdown be Demon-trated?
YES YES Does Change Result na USQ?
YES Does NRC Want to Review Change?
Don't INake The Change ls Change a Deviation from App. R or a Sensitive ssue NO YES Discuss with NRC Incorporate Change in UFSARlFHA
I I
II~
Summary of Thermo-Lag at PYNGS
Summary of RAI Response Pursuant to 50.54 f 1660 ft 1320 ft 1-hour 3-hour g~ PVNGS provided barrier amounts for all fire-rated barriers; specific details of individual enclosure dimensions, and diagrams of typical configurations/installations.
Approximate amounts are as follows:
Cable Trays:
1-hour 180 ft Conduit:
HVAC & Cable Tray Supports:
Junction Boxes:
Radiant Energy Heat Shield:
Regulatory Guide 1.76 3-hour 1-hour 3-hour non-rated, similar to 1-hour construction 870 sq ft 770 sq ft 670 sq ft non-rated, similar to 1-hour construction
Summary of RAI Response Pursuant to 50.54 f W~ Demonstrates aggressiveness in obtaining and verifying as-built configurations of barriers K~ Deferred determination of barriers that would not be bounded by NEI test program until issuance of NEI Application Guide and the results of the Phase 2 tests and any further testing were available 6>> Provided list of those configurations which could be most limiting {smallest and largest)
Summary of RAI Response Pursuant to 50.54 f Described the NEI ampacity test program and pending NRC acceptance of lEEE P848, Draft 11 methodology for generic applicability PYNGS described the intervening steel deviations and indicated generic deviations may not be validated by the NEI test program
Thermo-Lag Resolution Strategy Yes (Projecting 80 - 85%)
Eliminate Need By Appendix R Reanalysis No Yes Justify Using Licensing/Evaluation Approach No Yes Qualify Using Industry Test Data Resolve Remaining Issues:
Ampacity Seismic Combustibility No Perform Least Cost:
Upgrade Replacement Circuit Reroute
- R880IUt 00@
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Current Status of Thermo-Lag Reduction Effort P
Engineering analysis supports eliminating need for approximately 80-85% of Thermo-Lag used for Appendix R compliance
~ Current analysis credits Thermo-Lag which was conservatively installed on circuits to minimize manual actions
~ Manual actions have been determined to be feasible and are in accordance with Appendix R
~ 60.69 evaluation will be performed and documents updated {i.e., UFSAR, Safe Shutdown Calculation, etc.)
Thermo-Lag Deviations
Background
Intervening steel violation 86-33-09 received 3/13/87
'>> Violation 86-33-09 closed by inspection report 88-06 dated 3/14/88 UFSAR updated to include Thermo-Lag deviations 3/25/88 g~ NRR discussion regarding unacceptability of two FP UFSAR 50.59's held 7/20/89, 7/26/89, 8/3/89 W~ Deviations submitted to NRC 8/30/89 Deviations approved by NRC 1/30/90 f~ Violation 90-02-05 issued on one of the 50.59 changes due to reduction in margin of safety without staff review prior to implementation
Current Status of PVNGS Ampacity Reconstitution Effort W~ Currently scheduled to reconstitute ampacity calculation by 12/94 W~ Currently in process of evaluating database for available margins
Other Considerations P>> Combustibility
~ Evaluate Radiant Energy Heat Shield
~ Evaluate Reg Guide 1.76 Thermo-Lag
~ Update FHA for remaining Thermo-Lag
~ Model areas ifconcern exists
>~ Seismic
~ Calculations for seismic design adequately consider Thermo-Lag
Overview of Future Actions Update 50.54{f} response 90 days after issuance of Application Guide Develop ampacity issue resolution strategy and update accordingly within 90-day update NRC currently reviewing IEEE P848 and combustibility issue
III
'tatus of Appendix R Reconstitution Project Modifications
Summary of Appendix R Reconstitution Project Analysis completed in 12I92, CAR 90.014 closed 2I93 FSAR update complete except for pending deviations Identified need for:
~ Plant modifications
~ Revisions to operator actions
~ Revisions to deviations
~ New deviations
Status of Appendix R Reconstitution Project C<<rrent Window of Plant Modifications Schedule Implementation issue I/Subject Reportability PCR I Cycle 4 " At993'4""'k';"s"1994" 0 -4 "~"'; <'tS98%'~."- ~M"'ISIS~'="." '~'4"4S97'~"-="
- 1. Loss of RCP Seal Injection
- 2. Loss of Essential HVAC Equipment Rooms LER9W08 9I.IMN Pending'ER 91411 91 13 Nd INS 2NS 3NS 1Rs 2RS 3RS UI U2 U3 UI U2 U3 i~I s~
69I
- 3. Loss of RCS Sampling Capability
- 4. Ah B Train Cables in DG S1airwell
- 5. Loss of EW System hventory
- 6. Fire Panel Control Circuits/Damper Closure in Opposite Train
- 7. Associated Circuits, Common Power Supply/Lack of Fuses
- 8. Loss of Essential HVACto A Train AF Pump Room
- 9. Lossof BTrain Diesel Generator Control Room Fire Hot 91.1300 Reportable IN4 2NS 3N4 LER 92410 92-13.FBI IN6 2N6 3N5 LER~5 93.13.ZZ40I IR5 2R6 LER 92-015 66.13 HA INs 2NS 3NS 93.13 PE40I IRS Pending 'RS tlot 92-13-ss40I IR6 RepOItabie Pending 'R6 flot 92-13 F8401 INs Repartable Den ceiied Done Per EERAWO UI U2 U3 UI U2 U3 UI U2 '83 U3 UI U2 U3 Ui U1 U3 UI U2 U3 UI U2 U3 f194 Ii94 1194 Ii94 185
~12 7
497~6J97 Denotes Completed Activity
'mplementation Pending - Re-evaluation in Progress
- 10. Additional Emergency Ughting Requirements flot 9M3o04II IHS Reportable 2NS 3N5 UI U2 U3 1@5 ISS
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