ML18005A802

Responds to Station Blackout Rule.Listed Mods & Procedure Changes Identified in Parts B & C Will Be Completed within 2 Yrs of Notification Provided by NRR

ML18005A802
Person / Time
Site:	Harris
Issue date:	03/03/1989
From:	Mcduffie M CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RTR-REGGD-01.155, RTR-REGGD-1.155 TAC-68552, NUDOCS 8903140107
Download: ML18005A802 (10)

Text

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REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR: 8903140107 DOC. DATE: 89/03/03 NOTARIZED: NO DOCKET g FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTH. NAME AUTHOR AFFILIATION MCDUFFIE,M.A. Carolina Power 6 Light Co.

RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to station blackout rule.

DISTRIBUTION CODE: A050D COPIES RECEIVED:LTR ENCL SIZE-TITLE: OR Submittal: Station Blackout (USI A-44) 10CFR50.63, MPA A-2 2 D

NOTES:Application for permit renewal filed. 05000400 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR E CL ID CODE/NAME LTTR ENCL PD2-1 PD 1 BECKER,D INTERNAL ACRS NRR PD1-4 PM NRR/SELB NRR/SPLB NRR/SRXB NUDOCS-ABSTRACT EXTERNAL: LPDR NRC PDR NSIC R

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, i CARL Carolina Power 8 Ught Company P. O. Box 1551 ~ Raleigh, N. C. 27602 MAR 03 1989

'89 MP -8 p2;36 M. A. McDUFFIE SERIAL: 6[S, 89 10r3 ':.:,i"" '

Senior Vice President Nuclear Generation OCFR%0,.63,'1" United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-000/LICENSE NO. NPF-63 RESPONSE TO STATION BLACKOUT RULE (TAC 68552)

Gentlemen:

On 3uly 21, 1988, the Nuclear Regulatory Commission (NRC) amended its regulations in 10CFR50. A new section, 50.63, was added which requires that each light-water-cooled nuclear power plant to be able to withstand and recover from a station blackout (SBO) of a specified duration. Utilities are expected to have the baseline assumptions, analyses and related information used in their coping evaluation available for NRC review. It also identifies the factors that must be considered in specifying the station blackout duration. Section 50.63 requires that, for the SBO duration, the plant be capable of maintaining core cooling and appropriate containment integrity. Section 50.63 further requires that each licensee submit the following information:

1. A proposed station blackout duration including a justification for the selection based on the redundancy and reliability of the onsite emergency AC power sources, the expected frequency of loss of off-site power, and the probable time needed to restore offsite power;

2. A description of the procedures that will be implemented for SBO events for the duration (as determined in 1 above) and for recovery therefrom;gpssand

3. A list and proposed schedule for any needed modifications to equipment and associated procedures necessary for the specified SBO duration.

The NRC has issued Regulatory Guide 1.155 "Station Blackout" which describes a means acceptable to the NRC staff for meeting the requirements of 10CFR50.63. Regulatory Guide (RG) 1.155 states that the NRC staff has determined that NUMARC 87-00 "Guidelines and Technical Bases for NUMARC Initiatives Addressing Station Blackout At Light Water Reactors" also provides guidance that is in large part identical to the RG 1.155 guidance and is acceptable to the NRC staff for meeting these requirements.

Table 1 to RG 1.155 provides a cross-reference between RG 1.155 and NUMARC 87-00 and notes where the RG takes precedence.

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'lS-89-003 / Page 2 Carolina Power R Light Company has evaluated the Shearon Harris Nuclear Power Plant against the requirements of the SBO rule using guidance from NUMARC 87-00 except where RG 1.155 takes precedence. The results of this evaluation are detailed below.

(Applicable NUMARC 87-00 sections are shown in parenthesis.)

A. Pro osed Station Blackout Duration NUMARC 87-00, Section 3 was used to determine a proposed SBO duration of four hours. No modifications were required to attain this proposed coping duration category.

The following plant factors were identified in determining the proposed SBO duration:

l. AC Power Design Characteristic Group is P2~ based on:

a. Expected frequency of grid-related LOOPS - does not exceed once per 20 years (Section 3.2.1, Part 1A, pp. 3-3);

b. Estimated frequency of LOOPs due to extremely severe weather places the plant in ESW Group 3 (Section 3.2.1, Part lB, pp. 3-0);

c. Estimated frequency of LOOPs due to severe weather places the plant in SW Group 2 (Section 3.2.1, Part IC, pp. 3-7);

d. The off-site power system is in the Il/2 Group (Section 3.2.1, Part 1D, pp. 3-10);

e. Plant-specific pre-hurricane shutdown requirements and procedures which meet the guidelines of Section 0.2.3 of NUMARC 87-00 have been implemented, with the exception of load testing the TDI emergency diesel generators due to conflicts with post operating maintenance requirements imposed by Technical Specifications which would render the diesels inoperable for some durati )n.

2. The emergency AC power configuration group is C based on:

(Section 3.2.2, Part 2C, pp. 3-13)

a. There are two emergency AC power supplies not credited as alternate AC power sources (Section 3.2.2, Part 2A, pp. 3-15);

b. One emergency AC power supply is necessary to operate safe shutdown equipment following a loss of off-site power (Section 3.2.2, Part 2B, pp. 3-15).

3. The target EDG reliability is 0.95.

a. A target EDG reliability of 0.95 was selected based on having a nuclear unit average EDG reliability for the last 100 demands greater than 0.95, consistent with NUMARC 87-00, Section 3.2.0.

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'LS-89-003 / Page 3 B. Procedure Descri tion Plant procedures have been reviewed and modified, if necessary, to meet the guidelines in NUMARC 87-00, Section 0 in the following areas.

1. AC power restoration per NUMARC 87-00, Section 0.2.2;

~ Procedure DTRM-GP-2; Restoration of Service Following a System Shutdown - Eastern Area

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Operating Procedure OP-156.02; AC Electrical Distribution, Section 8.17: Restoration of Offsite Power to Emergency Buses Following Complete Loss of Power

2. Severe weather per NUMARC 87-00, Section 0.2.3, with the exception of load testing the TDI emergency diesel generators due to conflicts with post operating maintenance requirements imposed by Technical Specifications which would render the diesels inoperable for some duration.

~ Administrative Procedure AP-301; Adverse Weather Operations Plant procedures have been reviewed and changes necessary to meet NUMARC 87-00 will be implemented in the following areas:

1. Station blackout response per NUMARC 87-00, Section 0.2.1;

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Emergency Operating Procedure EOP-EPP-001; Loss of AC Power to IA-SA and 1B-SB Busses

~ Emergency Operating Procedure EOP-EPP-002; Loss of All AC Power Recovery Without Sl Required

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Emergency Operating Procedure EOP-EPP-003; Loss of All AC Power Recovery with SI Required

2. Procedure changes associated with any modifications required after assessing coping capability per NUMARC 87-00, Section 7.

C. Pro osed Modifications and Schedule The ability of Shearon Harris Nuclear Power Plant (SHNPP) to cope with a SBO for four hours in accordance with NUMARC 87-00, Section 3.2.5 and as determined in Section "A" above was assessed using NUMARC 87-00, Section 7 with the following results:

1. Condensate Inventor for Deca Heat Removal (Section 7.2.1)

It has been determined from Section 7.2.1 of NUMARC 87-00 that 91,000 gallons of water are required for decay heat removal for the four hour coping duration category from NUMARC 87-00, Section 3.2.5. The minimum permissible condensate storage tank level per Technical Specifications provides 270,000 gallons of water, which exceeds the required quantity for coping with a four hour SBO.

NRC Document Control MLS-89-003 / Page 0 No plant modifications or procedure changes are needed to utilize this water source.

2. Class 1E Batteries Ca acit (Section 7.2.2)

A battery capacity calculation has been performed pursuant to NUMARC 87-00, Section 7.2.2 to verify that the Class 1E batteries have sufficient capacity to meet SBO loads for four hours.

3. Com ressed Air Section (7.2.3)

No air-operated valves are relied upon to cope with a SBO for four hours.

0. Effects of Loss of Ventilation (Section 7.2.0)

a. The calculated steady state ambient air temperature for the steam driven AFW pump room (the dominant area of concern of a PWR) during a SBO induced loss of ventilation is 111'F.

b. The assumption in NUMARC 87-00, Section 2.7.1 that the control room will not exceed 120'F during a SBO has been assessed. The control room at SHNPP does not exceed 120'F during a SBO.

Therefore, the control room is not a dominant area of concern.

Reasonable assurance of operability of SBO response equipment in the above dominant area of concern has been assessed using Appendix F to NUMARC 87-00 and/or the Topical Report. No modifications or associated procedures are required to provide reasonable assurance for equipment operability.

No other dominant areas of concern were identified.

5. Containment Isolation (Section 7.2.5)

The plant list of containment isolation valves has been reviewed to verify that valves which must be capable of being closed or that must be operated (cycled) under SBO conditions can be positioned (with indication) independent of the preferred and blacked-out unit's Class 1E power supplies. The following procedure changes are required to ensure that appropriate containment integrity can be provided under SBO conditions:

at When establishing containment isolation under SBO, a procedural step will be added to manually close the containment sump pump discharge isolation valve. This valve and its counterpart inside containment are normally open and fail as-is on loss of AC power.

Manual closure of the outside containment isolation valve is necessary to ensure containment integrity. Additionally, guidance will be provided for isolation of the containment spray and RHR recirculation sump suction lines in the event these valves are open (these valves are normally closed, have DC indications and fail as-is on loss of AC power).

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"'NLS-89-003 / Page 5

6. Reactor Coolant Inventor (Section 2.5 )

The ability to maintain adequate reactor coolant system inventory to ensure that the core is cooled has been assessed for four hours.

A plant-applicable ahalysis contained in Westinghouse Owners Group Background Document ECA-0.0. "Loss of All AC Power" was used for this assessment. The expected rates of reactor coolant inventory loss under SBO conditions do not result in core uncovery in a SBO of four hours. Therefore, makeup systems in addition to those currently available under SBO conditions are not required to maintain core cooling under natural circulation.

Plant modifications were identified to satisfy the 0-hour coping duration and enhance operator ability to perform required actions associated with a SBO event. These modifications are as follows:

1) The emergency lighting for the Main Control Room currently does not satisfy the 0-hour duration. Control Room emergency lighting capability will be provided by modifying, as appropriate, the power source(s) for Control Room emergency lighting.

2) Local operation of the Main Steam PORVs is required to remove decay heat from the RCS. The following changes will be made:

a) add emergency lighting in the vicinity of the Main Steam PORVs, b) add sound powered phone jacks at each Main Steam PORV, and c) improve access to each Main Steam PORV.

3) Local operation of CS-V517, RCP seal leakoff isolation valve is required to cope with a SBO event. A permanent access platform/ladder will be built for access to CS-V517. Access can currently be made by use of a temporary ladder.

The above described modifications and the procedure changes identified in Parts B and C above will be completed within two years of the notification provided by the Director, Office of Nuclear Reactor Regulation in accordance with 10CFR50.63 (c)(3).

If you should have any questions, please contact Mr. S. D. Floyd at (919) 506-6901.

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Yours very truly, M. A. McDuffie MAM/LMR/che (3858NED) cc: Mr. R. A. Becker Mr. W. H. Bradford Mr. S. D. Ebneter NUMARC

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