ML18026A279
| ML18026A279 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 10/30/1996 |
| From: | Butler F, Gorman T, Jebsen E PENNSYLVANIA POWER & LIGHT CO. |
| To: | |
| Shared Package | |
| ML18026A281 | List: |
| References | |
| EC-013-0859, EC-013-0859-R04, EC-13-859, EC-13-859-R4, NUDOCS 9612160357 | |
| Download: ML18026A279 (128) | |
Text
NUCLEAR ENGINEERING. File ¹ R2-1 Qg CALCULATION/ STUDY COVER SHEET and 1.'age Total 1 of147 NUCLEAR RECORDS TRANSMITTALSHEET .
. '2. TYPE: ~Stud >3. NUMBER: EC-013-0859, >4. REVISION: 4 h
- 5. TRANSMITTAL¹: Pl(P ') 8. UNIT: 3 *>7. QUALITYCLASS; P *>8! DISCIPLINE: E
). 9. DESCRIPTION: A endix R Safe Shutdown Path 2 Anal sis for fires in the
. Control Roo'm Fire Zones- .
SUPERSEDED BY: EC-
- 10. Alternate Number. SEA-EE-061 11. Cycle 12: Computer Code or Model used: Fiche P Disks P Am't
- 13. Application: A endix R
- >14 Affected Systems
- 013 013H
- 'fN/A then line 15 is mandatory.
- >15. NON-SYSTEM DESIGNATOR:
k
- 16. Affected Documents:
- 17.
References:
'LA-4505
- 18. Equipment / Component ¹:
-19. DBD Number: DBD 019,.DBD 076
>20. PREPARED BY %21. REVIEWED BY Print Name Thomas'A. Gorman Print Name Eric R. Jebsen Si nature Si nature
%22. APPROVED BY/ DATE 23. ACCEPTED BY PP&L/ DATE Print Name F.G. Butler Print Name Si nature /a ao Si nature TQBECDMPLETEDBYNUCLEARRECDRDS p ECE ) qEp NR-DCS SIGNATURE/DATE ADD A NEW COVER PAGE FOR EACH REVISION h
'ie Fields NUCLEA f
FORM N PM-QA4221-1, Revision 1 IELDS 96i2f60357 96i206 PDR ADQCK 05000387 F PDR
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. ENGINEERING CALCULATIONSTUDY
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REVISION DESCRIPTION SHEET REVISION NO' CALCULATIONNUMBER: EC-013-0859 This form shall be used to record the purpose oi reason for the revision, indicate the revised pages and I or affected sections and give a short description of the revision.
Check (x) the appropriate function to add, replace or remove the affected pages.
A R R Description I Revised Affected d p m Purpose of Revision
'ages Sections d I v X Replace. page 1; put rev. 0 in back-up
,1a Add page 1a 2to29 X Replace old pages 2 thru 29 with new pages 2 thru 29 29a to 29d X Add pages 29a thru 29d 38 Replace old page 38 with new page 38 1448 to Replace old pages 1448 thru 1474 with new pages 1448 thru 1474 1474 1475 8 X Add pages 1475 and 1476 1476 REVISION TYPE: 0 .SUPERSEDED BY CALCULATIONNUMBER EC-(check one) Q FULL REVISION g} PAGE FOR PAGE FORM NEPM-QA4221-2, Revision 1
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Susquehanna Steam Electric Station Appendix R Analysis for a Control Room Fire O. Section TABLE OF CONTENTS Title
1.0 INTRODUCTION
. 2.0 OB JECTIVE 6
3.0 CONCLUSION
S AND RECOMMENDATIONS 4.0 ASSUMPTIONS/INPUTS 5.0 , METHODS
= 6.0 ~
REFERENCES 13
".7.0 RESULTS 17 I
~Aendicee Control Room Appe'ndix R Compliance Report 29 Appendix R Cable Hit Resolution Worksheets 76
,C Resolution of MOV "Hot Short" Issue 1448 EC-013%859 Revision'4 Page 2
Susquehanna Steam Electric Station Appendix-R Analysis for a Control Room Fire
1.0 INTRODUCTION
a 1.1 Puruoae This calculation identifies those cables routed in the Susquehanna Steam Electric Station (SSES) Control Room fire area that are potential Appendix R non-compliances (i.e. "hits"). The Control Room fire area CS-9 consists of the following fire zones:
0-26A 0-26E 0-26F - 0-26G 26H 0-26I 0-26J '-26K 0-26L 0-26M 0-26N 0-26P 0-26R In the context of this report, "Control Room" refers to Fire Area.CS-9 in its entirety.
. For a fire in anyone of these-fire zones, credit is takeri for Safe Shutdown Path,2, Alternate Shutdown using the Remote Shutdown Panel (refer to section 1.3).
This report evaluates the Path 2 cable/component noncompliances ("hits") in Fire Area CS-9 and identifies the method of achieving Appendix R compliance for each. Appendix A provides a summary of this information. Appendix B provides the individual hit resolution worksheets for the Path 2 cable hits in the Control Room. Appendix C evaluates the,NRC IN 92-18 MOV Hot Short Concern for the Control Room fire. 'SES 1.2 B~ack round In October of 1987,,Pennsylvania Power and Light Company (PPEcL) completed the re-analysis of Appendix R Compliance Assessment for a fire in the'Control
. Room (Reference 6.2.12). This analysis identified specific- areas of non-compliance with respect to Appendix R cables required for Safe Shutdown Path 2 (termed "cable'its") routed in the Control Room. Circuit isolation and coniporient cable failure modes were evaluated and recommendations for achieving compliance were identified in the report Subsequent to this, the Appendix R Closeout Project Team was formed. This team's role was to implement the recommendations provided in the original issue of the analysis..In performing the actions necessary to implement the recommendations made in the analysis, modifications were performed, procedural aetio'ns were put in place and, in some cases, additional analysis providing justification for the acceptability of the existing condition was provided: In most cases, the information included in this analysis required recourse to'either a DCP, EC-0134859 Revision 4 Page g
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Appendix R Analysis for a Control Room Fire an operating procedure or another analysis to fully understand the final disposition for the noncompliance.
This calculation was revised to update this Appendix R Control Room Fire Analysis by incorporating the information from each of the above-mentioned areas
'nd consolidating it into one composite location.
I Revisions 2 and 3 to this calculation were prepared to address NRC Information Notice 92-18 related to MOV "Hot Shorts". Revision 4 was prepared to address the revised Spurious Actuation Criteria agreed to between PAL and the'NRC.
Discussions were held between PPEcL and the NRC on numerous occasions relative to spurious operations criteria. On January 25, 1996 a meeting was held in PP8cL's Allentown offiice to discuss the spurious actuation criteria to be applied to the evaluation of fires in fire areas outside of the Main Control Room. The results
. of this discussion was transmitted to the NRC in PLA-4442. This PLA also transmitted revision 3 of this calculation. which contained the evaluation of the NRC IN 92-18 MOV "Hot Short" issue.
Upon review of this submittal, NRC initiated a telephone conversation on July 25, 1996 in which they informed PP&L that they wanted PAL to apply the same, spurious actuation criteria discussed for the areas. outside the Main Control Room to the evalaution of fires in the Main Control Room. After a review of the feasibility of honoring this request, PP8cL requested a follow up telephone coversation on September 4, 1996 to clarify the NRC's request.
In this telecon, the NRC confirmed that the Control Room fire analysis should apply the criteria from Generic Letter, 86-10 paragraph 5.3.10 to Control Room circuits isolated from the Main Control Room, should use the criteria from PL'A-4442 for all non-isolated circuits and should add consideration for spurious initiation of systems that could result in an inadvertent and uncontrolled RPV overfill condition. The revised Spurious Operation Criteria was transmitted to the NRC under PLA-4505.
'F 1.3 Control Room-Fire Shutdown Scenario Path 2 For a Control Room fire, plant shutdown is accomphshed by use of the Alternative Shutdown Path controlled from the Remote Shutdown Panel (RSP). This shutdown path is defined as "Path 2". For a serious Control Room fire necessitating evacuation, a manual plant scram is initiated, the MDIV's closed, the Reactor Feedwater'umps are tripped and the Reactor
'are'anually Feedwater Pump discharge valves are closed prior to evacuating the Control Room. Although NRC GL 86-10 Section 3.8.4 typically allows the operator to perform a plant SCRAM prior to evacuating the Main Control Room, the NRC has stated in a telecon on September 4, 1996,-that they would grant us .an EC-013-0859 Revision 4 Page g
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Susquehanna Steam Electric Station Appendix R Analysis for a Control Room Fire additional operator action of closing the, MSIV's prior to evacuating the Main Control Room. Our request to have the NRC of6cially confirm this position and grant us this additional operator action prior to Main Control Room evacuation was documented in PLA-4505.
In addition, PLA-4505 requested that the NRC.also approve the additional pre-evacuation operator actions described above. These additional operator actions are necessary to prevent an RPV overfill condition caused by a feedwater flow controller failure (high) during feedwater coastdown after closing the MSIV's, I
s The discussion addressing the requirements of NRC GL 86-10 Section 3.8.4
-regarding operator actions performed prior to leaving the Main Control Room is.
contained. in section 7 of this calculation under the heading for the MSIV's and Feed water.
In the Path 2 safe shutdown scenario, Reactor Coola'nt makeup is provided by the
'CIC System. The reactor depressurization function is provided by opening orie of three specific SRVs or cycling'them from the RSP. In addition, the ability to manually initiate ADS from-the relay rooms'has been preserved. The decay heat removal function is provided by RHR operating in the'shutdown cooling mode.
The Reactor Recirculation pumps are assured tripped.'he MSIVs isolate on loss of ofF-site power, manual isolation signal, or low
'vacuum in the main condenser. The manual isolation signal is provided for in the Plant Procedures ON-100/200-009, and the analysis is simplified ifthe MSIVs are or can be closed for all shutdown paths. This simplifies the analysis by 'losed making shutdown paths the same regardless of whether or not off-site power is available. The NRC has stated that for SSES 'manual closure of the MSIV's by the
.operator prior to evacuating the Main Control Room is an acceptable action. In addition to the analysis simplification features described above, this action, along with closing the Feedwater Pump discharge valves'and tripping the Feedwater Turbines, mitigates the efFects of a spurious RPV injection from the Feedwater System.
'he support functions either remove heat or supply power to the front line process system functions of reactivity control,, reactor 'oolant makeup, reactor .
depressurization and decay heat removal. Cooling for equipment's provided by the Emergency Service Water System. RHRSW provides cooling water for the RHR System.
Power is supplied by the Emergency Diesel Generators (in the case of a LOOP) and the batteries to the various components within the AC and. DC Electrical Distribution System.
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.Susquehanna Steam Electric Station Aypendix R Analysis for a Control Room Fire t
'rea cooling for the RCIC Rooms, the RHR pumps, the ESWS pumps and the Emergency Diesel Generators is provided by the ECCS'Room Coolers, ESWHVAC and EDGHVAC Systems, respectively.
2.0 OBJECTIVE This calculation revision serves to consolidate all information related.to, the analysis performed to demonstrate compliance for the Susquehanna Steam Electric
'tation (SSES) with the requirements of 10CFR50 Appendix R for a Control Room Fire. This calculation was revised to:
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'a. Incorporate changes to the safe shutdown component and cable data resulting from plant modifications.
- b. Incorporate changes to include the final method of resolution (i.e. hit disposition) for the Appendix R non-compliances identified in the original analysis.
c.'-'Incorporate as-built information from'the modifications performed, in response to those dispositions crediting plant changes as a method of achieving compliance in the original issue of. this analysis.
d." Consolidate .information from various studies that are inter-related and collectively address the method of achieving Appendix R compliance for a fire in the Control Room.'.
Document the'implementation of the Spurious Operations Criteria provided by PPEcL to the NRC in Attachment A to PLA-4505.
i This calculation revision encompasses the criteria and assumptions for a Control Room fire evaluation outlined in'EC-013-0814 (Reference 6.2.10), and serves to ~
supersede that document in its entirety.
Changes made within this revision of this calculation are indicated by a revision bar in the right hand column. Editorial and format changes are not noted with a revision bar.
3.0 CONCLUSION
S AND RECOMMENDATIONS The results compiled in Section 7 demonstrate that measures are currently in place, to address each of the potential Appendix R non-compliances (i.e. cable hits)-
identified for a Control'Room fire. A rigorous review of the cable hits in Fire Area has identified that each cable hit is adequately addressed by one or more of
'S-9 the following methods:
- a. A modification was implemented to change the, circuit to provide circuit isolation.
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Sustiuehanna Steam Electric Station Appendix R Analysis for a Control Room Fire
- b. An existing analysis has concluded that cable failure will not prevent safe shutdown.
- c. Procedural actions are in place to manually operate equipment to satisfy the Path 2 safe shutdown.
- d. Deviation requests are in place that justify the acceptability of the existing configuration.
The review performed, as documented herein, concludes that the Susquehanna Steam Electric Station is in full compliance with the requirements of 10CFR50.48 and Appendix R with respect to safe shutdown in the event of a Control Room fire. The results of the analysis performed to address the MOV "Hot Short" Issue, NRC Information Notice 92-18, is contained in Appendix C.
4.0 ASSUMPTIONS/INPUTS 4.1 Re lato Evaluation Criteria The criteria used to analyze for a fire in the Control Room and the ability to meet 10CFR50.48 Appendix R requirements to accomplish and maintain shutdown are as follows:
4.1.1 =
PP8cL is committed to 10CFR50.48, Appendix R Sections III.G, J, and O..
Section III.G contains the requirements for fire protection capability.
4.1.2 Section III:G.3 discusses the option of providing alternate shutdown if Section III;G.2 separation requirements cannot be met. +
4.1.3 Section III.L discusses the requirements for alternate shutdown capability. While not a direct commitment, it is invoked via Section III.G.3. Therefore,Section III.Lrequirements apply to the analysis for a Control Room fire.
4.1.4 Generic Letter 86-10, Item 3.8.4 provides NRC guidance related to Control Room fire considerations. The NRC has stated that for SSES an operator action to close the MSIV's in the event of a Main Control Room Fire prior to evacuation is
. accceptable. This position has been transmitted to the NRC for formal acceptance in PLA-4505. PLA-4505 also requested approval from the NRC to trip the Feedwater Pump Turbine and close the Feedwater Pump discharge valves prior to evacuating the Contol Room.
EC-013-0859 Revision 4 Page 7
I Susquehanna Steam Electric Station Appendix'R Analysis for a Control Room Fire 4.2 Safe Shutdown Re uirements for a Control Room Fire For the first'72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> post-fire, the analysis considers shutdown with and without the availability of oQsite power. After 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, offsite power can be assumed restored:
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."4.2.2 A LOCA, seismic event, or any other.'Design Basis Accident is not considered to occur concurrent with a fire. The fire is considered to be the single failure.
4.2.3 The reactor is tripped in the Control Room. The MSIV's are closed in the Control Room. The Feedwater Pump Turbines are tripped and the Feedwater Pump discharge valves are closed in the Control Room. Additional. operator actioris prior to Control Room evacuation were not assumed.
4.2.4 The automatic actuation of equipment (e.g., generators, valves, pumps etc.) is assumed potentially lost if control circuits could be adversely affected by the Control Room fir'e. Spurious inadvertent actuation of equipment is considered in the analysis. The spurious actuation criteria applied was transmitted to the NRC in PLA-4505 for formal acc'eptance. This criteria is summarized in section 4.4.4 a'nd explained in more detailed in the Appendix R Compliance Manual, Calculation EC-013-0843. A separate analysis to document the results of the evaluation to address NRC IN 92-18 related to MOV "Hot Shorts" is contained in Appendix C.'eturn 4.2.5 to'the Control Room post fire is acceptable provided the specific conditions described in NRC'Generic Letter 86-10 are met. This option, however, was not used in this. analysis due to th'e difficulty of meeting the necessa'ry conditions.
4.2.6 Damage to=systems in the Control Roo'm due to a Control-Room fire cannot be predicted. Therefore, a bounding analysis was performed to demonstrate that safe shutdown to cold shutdown'could be achieved from outside the main Control-Room. The as'sumption of "limited fire" damage was not used in this analysis.
4.2.7 : For the equipment required for shutdown at the Remote Shutdown Panel, a review was performed to determine the existence of proper isolation 'and circuit independence from the affects of the Control Room fire. For those cases where isolation was not adequate, measures were taken (modifications, procedural
. actions, etc.) to ensure the ability to operate the component, when required .
4.3 Procedural Actions and Re airs 4.3.1 Manual actions, other than those discussed in section 4;2.3, may be credited to rest'ore power, assure valve lineups, isolate cable faults, etc. provided these actions can be performed outside of the main control room and with available manpower.
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'I 4.3.2 No "repairs" are allowed to achieve hot shutdown. Repairs to Cold Shutdown
'ystems are acceptable provided specific detailed procedures, and dedicated repair parts are available onsite and the time required to make the repairs is reconciled with the Shutdown scenario..
a Note: The NRC designates 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> as the require) time to be able to reach cold shutdown.
4.4 Circuit Failure Criteria 4.4.1 The following fire damage to electrical equipment was considered:
s a) hot shorts
- b) open circuits
,c) shorts to ground 4.4.2 If all possible'ailure states of the equipment (valves fail open or closed) were evaluated and found acceptable, the specific circuit failure modes were considered to have no impact on safe shutdown.
4.4.3, =Hot short conditions were not postulated to,be cleared by the fire condition..Only manual actions to'solate the circuit or other appropriate manual actions were considered to mitigate the spurious signal. Equipment damage due to hot shorts as postulated in NRC IN 92-18 has been addressed by a separate analysis contained in A'ppendix C.
4.4.4
'f For fires in the main Control Room, SectIon III.L*requires that spurious operation equipment that can affect safe shutdown functions be considered. The spurious operation criteria for circuits isolated from the main Control Room is contained in NRC Generic Letter 86-10'paragraph 5.3.10. 'That criteria reads as follows:
~ The safe shutdown'capability should not be adversely affected by any one spurious actuation or signal resulting from a fire in any plant area; and
~ The safe shutdown capability should not be adversely affected by a fire in any plant area which results in the loss. of all automatic function (signal, logic) from the circuits located in the area in conjunction with the one worst case spurious actuation or signal resulting from the fire; and
,~ The safe shutdown capability should not be adversely affected by a fire in any plant area which results in spurious actuation of the redundant valves in any one high-low pressure interface line.
For application of this criteria for all situations other than Hi/Lo pressure interfaces, it is assumed that one spurious operation occurs prior to actuating the transfer switch at the RSP. This spurious operation,may be as a result of a hot I,
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, Appendix R'Analysis for a Control Room Fire short on a circuit'that is isolated from the main Control Room or on one that is not. It is not necessary to postulate spurious operation of equipment in each of these two categories: i.e isolated and non-isolated circuits.
For circuits remaining in the main Control Room that are not isolated, all potential spurious operations must be addressed on a one-at-a-time basis. Each individual spurious operation must be identified and a mitigating action to prevent an impact to safe shutdown must be developed. In developing this mitigating action, however, it is not acceptable to ignore a potential hot short on one piece of equipment as a mitigating action. for another piece of equipment.
The act of actuating the transfer switch at the RSP is the mitigating action to address any spurious operation for circuits isolated from the main Control Room.
For circuits not.isolated form the main Control Room, some other means of mitigiting the effects of the potential spurious operation must be available.
I Examples of ways to mitigate either prior to or during the process of the fire the effects of each spurious operation are as follows:
~ Provide a fire barrier or wrap
~ Route the circuit of concern in a dedicated raceway that does not contain any other normally energized circuits'that could cause a hot short Reroute or relocate the circuit/component
~ Provide a Procedural Action, such as:
- Have the breaker-for the component of concern normally racked out fuses removed) so that inadvertent operation is'not,possible. [Note:
'or For Hi/Lo pressure interface components, a 3 phase hot short on the ac power cable or 2 hot shorts of the'proper polarity oil the dc power
.cable must still be evaluated.]
- Perform an action in response to the. fire condition to mitigate the impact of the spurious operation. [Note: Ifthis action involves manually operating an MOV using the hand wheel, it must be demonstrated that fire damage did not result in a hot short with the potential to damage the valve (i.e. NRC IN 92-18 concern)]
- ~ Identify'other equipment, that can prevent the spuriously operated component from affecting safe shutdown For a more detailed explanation of the spurious operation criteria applied in the .
control room fire analysis see Calculation EC-013-0843 and PLA-4505.
4.4.5 For three-phase AC circuits, the probability of getting a hot short on all three
'hases in the proper sequence to cause spurious operation of a motor is considered sufficiently.low as to not require evaluation except for any cases involving High/Low pressure interfaces. For ungrounded DC circuits ifit can be shown that EC-013-0859 Revision 4 Page /0
I Susquehanna Stcam Electric Station Appendix R Analysis for a Control Room Fire only two hot shorts of the proper, polarity without grounding could cause no further evaluation is necessary except for any cases involving spurious'peration, High/Low pressure interfaces.
4.5 Confirmin Anal sis
. 4.5.1 The Control Rod Drive System (scram function) was evaluated in Calculation EC-013-0849 (Reference 6.2.13) and dispositioned as not a concern to, accomplish the scram function. This system was not addressed in this calculation. ~
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5.0 METHODS 5.1 The components required for safe shutdow'n for path 2 are developed in calculation EC-013-0979 (Reference 6.2.1), Safe Shutdown Paths for Fires Outside and Inside of Control Room. The cables required,to support the performance of. the components on this path were developed in calculation EC-013-0883 (Reference 6.2.15), Safe Shutdown Cable Selection. The complete listing of components/cables to be analyzed'fora Control Room fire was generated from the Appendix R Compliance Database Management System (ARCDMS)
(Reference 6.9.1). This report is included herein as Appendix A and identifies all the cable hits for Path 2 in the Control Room.
I In order to ensure the accuracy and completeness of this listing, as a part of the preparation of revision 1 to this calculation, a line by line comparison was performed between Appendix A of calculation EC-013-0859 Revision 0 and the Appendix A contained herein. Any differences identified were reconciled. Any changes made to Appendix A subsequent to revision 1 were specifically checked as a part of that revision.
5.2 Each component and associated cable identified in Section 5.1 was'reviewed to.
determine whether proper isolation of the cable exists. If isolation with separate'ontrol power fusing exists, component operability is assured outside the Control Room. Appendix C addresses the MOV hot short concerns of NRC IN 92-18.
'I capability was determined based on a reviewJl'solation of schematic diagrams and was documented in one of the following locations:
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- a. Existing Worksheets in Appendix B
- b. Appendix A of Revision 0 of this calculation
- c. Calculation EC-013-0854 (Reference 6.2.10)
I Collectively, the above-mentioned documents determine the isolation capability for all of the Path 2 cables in the Control Room.
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Many of the cables originally identified as not having proper isolation have been resolved by DCPs that modified the component circuitry to provide control remote
'.3 the control room'and isolation from cable, faults caused by the Control Room 'rom The specific DCP references are identified in Appendix A and Section 6.6. 'ire.
The remaining cables that were not directly isolated were reviewed to analyze the effects of electrical faults/failures'(hits) on the cables, The" failure, mqdes considered are as follows:
I a) Shorts-to-Ground
,, b) Hot Shorts c) Open Circuits The effect on component operation was then analyzed and the resulting effect on system operation was evaluated.- If it could be shown that the failures did plant safe shutdown using Path 2 capabilities, it was so documented on not'ffect hit worksheet and no further action was required.
the'able t
For those systems. that could-result in an inadvertent overfilling of the RPV, the impacts were addressed on a system basis. The systems identified as having this potential are: Feedwater; Condensate; CRD; Standby Liquid Control; HPCI; RCIC; RKVLPCI (of the non-safe shutdown division); Core Spray. Each of these systems was analyzed separately for its impact on safe shutdown. For any impacts a separate mitigating action was identified. The above referenced system impact are contained in section 7. 'valuations.
5.4 For cables whose failure could affect safe shutdown, the following methods were employed to resolve the cable "hit".
1 a) Determined if.a DCP is 'necessary to modify the circuit to provide circuit isolation.
b) Determined if prior analysis has been performed that assures that failure will not prevent safe shutdown. 1
. c). Determined if procedural actions were in, place. (e.g.,'operating procedure to a power supply breaker) to satisfy Path 2 safe shutdown. 'trip d) Reviewed and referenced deviation requests that justify the acceptability of the existing configuration.
5.5 The results of-the analysis for the cable hits and their final disposition wer6 on the Appendix R Analysis Cable Hit Worksheets, provided herein as 'ocumented Appendix B.
5.6 A summary of the method of compliance for each cable hit was completed and provided in Appendix A; This report documents the cable hits for a Control Room'C-0134859 Revision 4 Page /g.
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fire, the final disposition, the supporting analysis document reference, if appropriate, and the dispositioning document reference l
5.7, A summary of the results of the analysis and evaluations is contained in Section 7.
6.0 REFERENCES
The following references were used to conduct this study. Only those references identified by a revision bar were reviewed for this latest revision of this calculation.
6.1 Re lato Documents 6:1.1 10CFR Part 50.48 and 10CFR 50, Appendix R 6;1.2 Generic Letter 86-10 6.1.3 ISSUE Inspection Procedure 64100,,'.1.4 SER, dated August 9, 1989.
0 6.1.5 6.2 PLA-4505, Spurious Operation Criteria for Fires at SSES Calculations
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New No. Rev. Old No. Title 6.2..1 EC-013-0979 0 SE-B-NA-016 Safe Shutdown Paths for Fires Outside and Inside Control Room 6.2.2 EC-013-0858 0 SEA-EE-019 'ppendix R Required Cables for the MSIV's 6.2.3 EC-013-0845 0 SEA-EE-051 Appendix R.ADS/SRV Spurious Cable Analysis 6.2.4 EC-013-0860 0 SEA-EE-020 Evaluation of Reactor Recirculation System
,=- Cables for Appendix R Compliance
. 6.2;5 EC-013-0964 0 SE-B-NA-038 Main Steam Line Drain Valves 6.2.6 EC-013-0624 0 SE-AAA-059 Appendix R - Coordination Calculation for Diesel Generator Synchronization Circuits 6.2.7 EC-013-0725 0- SEA-EE-078 Appendix R Evaluation of NCRs 88-0007 through 88-0012 6.2.8 EC-013-0863 0 SEA-EE-060 'ppendix R--Hit Resolution for CSHVAC I Components/Cables 6.2.9 EC-013-0814 0 SEA-EE-057 Appendix R - S/D Path 2 Analysis in CR
- Fire Zones '(addItional components)
Revision 4 'C-013-0859 Page /P .
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'i Sus'quehanna Steam Electric Station Appendix R An'alysis for a Control Room Fire 6.2.10 EC-013-0854 0 SEA-EE-018, Verification of Equipment Isolation at the RSP in the event of a CR fire 6.2.11 EC-013-0846 0 SEA-EE-052 Evaluatiori of Appendix R Ventilation System Non-Compliances 6.2.12 EC-013-'0849 ,0 SEA-EE-017 Acct of Fire on the Operation of SDV Vent and Drain Valves
. 6.2.13 EC-013-0883 0 SEA-EE-012 Safe Shutdown Cable Selection ~
6.2;14 EC-013-0873 0 SEA-EE-033 Evaluation to Ensure Isolation of RCS Flow Diversio'n in the Event of a Plant Fire EC-013-0788 0 SEA-EE-447 Disposition of EDR G10122 - Appendix R
'.2.15 Flow Diversion Components - HPCI 6.3 ~Drawin s 6.3.1 E-296,E-297, SSES,Unit 1 & Common, G.E./Bechtel Cable No. Cross-Reference, dated 3/06/86.
E-298,E-299, SSES Unit 1 & Common, G.E./Bechtel Cable No. Cross-Reference,
'.3.2 dated 3/06/86.
6.3.3 'E-294, Revision 5, Open, List of Raceway Wrapped with Fire Barrier Material Unit 1 and Common.
6.3.4 E-295; Revision 4, 10/09/86, List of Raceway Wrapped with Fire Barrier Material Unit 2.
6.3.5 ElP0600, Interim Drawing Change Notice, IDCNNo. 2, dated 6/17/87.
6.3.6 Panel Module Wiring List Rev. Date Panel Module M1-H12-538-2 5 8/15/85 0700 M1-H12-226 3 6/15/83 070'1 Ml-H12-586 14 8/15/85 '702 Ml-H12-543, 17 ~
6/3/83 0703 M1-H12-562 '12 9/9/85 0704, M1-H12-530 15 5/8/80 0705 Ml-H12-563 13 1/13/86 . 0706 Ml-H12-1082 3 7/11/85 Control Room
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Ml-H12-590 9/9/85 'ontrol Room Jl-867 4 10/81 Control Room Ml-H12-589 'l l 1/31/85 Control Room Ml-H12-529 9 8/2/83 =
0700
, Ml-H12-553 10 4/10/85 0701 M1-H12-704 14 10/16/84 0702 EC-0134859 Revision 4 Page /Q
'I Susquehanna Stcam Electric Station Appendix R Analysis for a Control Room Fire 6.3.7 Raceway Schedule D~iN . Rev. Date.
E-72 65 1/2/86 E-73 64 11/6/85 E-74 62 8/2/84 E-76 . 50 8/31/84 E-77 49 1/3/85 E-78 53 5/29/84 6.3.8 Circuit Schedule D~iN: Rev, Date E-82 . 60 1/2/86 E-83 59 1.1/6/85 E-84 56'6 8/2/84 .
E-86 8/3 1'/84 E-87 43 1/3/85 E-88 49 5/29/84 6.3.9 Schematic Diagrams - Sheets'and revisions as noted in the Appendix B
'orksheets.
6.3.10 DCN 88-0933 - ESW Flow Indication P
6.3;11 M-1002, Revision 3, Appendix R - Safe Shutdown Component List N
6.4 Procedures Procedure. Rev. Title' 6.4.1 EO-100-102 7 RPV Control 6.'4.2 EO-200-102 7 'RPV Control 6.4.3 EO-100-112 7 Rapid Depressurization 6.4.4 EO-200-112 7 Rapid Depressurization 6.4.5 GO-100-002 22 ~
Plant Startup, Heatup and Power Operation 6.4.6 GO-200-002 24 Plant Startup, Heatup and Power Operation, 6.4.7 ON-013-001 4 Response to Fire 6.4.8 ON-030-001 p 3 Local, Operation of Control Structure HVAC 6.4.9 ON-054-001 . 3 Loss of Emergency, Service Water (ESW) 6.4.10 ON-100-009 3 Control Room Evacuation
,6.4.11 ON-104-001 3 Unit 1 Response to Loss of Quite Power 6.4.12- ON-200-009 3 , Control Room Evacuation 6.4.13 OP-024-001 10 Diesel Generators EC-0134859 Revision 4 Page /W
Susquehanna Steam Electric Station Appendix R Analysis for a Control Room Fire I ~
6.4.14 OP-054-001 8 Emergency Service Water System (ESW) 6.4.15 OP-149-002 22 RHR Operation in Shutdown Cooling Mode 6.4.16 OP-249-002 25 RHR Operation in Shutdown Cooling Mode 6.4.17 OP-100-00.1 . Remote Shutdown - Normal Plant Operating Lineup 6.4.18 OP-200-001 "
Remote Shutdown - Normal Plant Operating Lineup
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. 6.5 .Deviation Re uests 6.5.1'eviation Request No. 2, Revision 4, "Suppression Pool Temperature Indication".
6.5.2 Deviation Request No. 37, Revision 4, "Control:Room Raised Floor and Control.
Structure Cable Chase Fire Protection".
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6.6 Modifications.
I DCP Title 6.6.1 86-3008C HVAC Fan Operation Transferred from Control Room 6.6.2 86-'3008D RHR Pump Room Cooling Fan Operation Transferred from Control Room 6.6.3 86-3008E HVAC Fan Operation Transferred from Contrdl Room 6.6.4, 86-3008F Unit 1 RHR SW Pump Room Fan Control 6.6.5 86-3009C HVAC Fan Operation Transferred from Control Room 6.6.6, 86-3009D RHR Pump Room Cooling Fan Operation Transferred from Control Room 6.6.7 86-3009E HVAC Fan Operation Transferred from Control Room 6.6.8 86-3009F Unit 2 RHR SW Pump Room Fan Control
. 6.6,9 86-3010C HVAC Fan Operation Transferred from Control Room-6.6.10 86-3010D Common Unit ESW Pump Room Fan Control 6.6.11 88-3016H Add 2nd Location for CS HVAC Operation 6.6.12 88-3016I ESW Loop A and Loop B Diesel Generator Coolers Supply I
and Return Isolation Valves Diesel "A" Operation - Modify Wiring on Local'ontrol 6.6.13 88-3016J Switch 6,6.14 88-3016K Diesel "B" Operation - Modify Wiring on Local Control'witch 6.6.15 88-3016L Diesel "C" Operation - Modify Wiring on'Local Control Switch 6.6.16 88-30'16M Diesel "D" Operation - Modify Wiring on Local Control Switch 6.6.17 88-3016N DG E Modify Wiring on Local Control Switch 6.6.18 88-3017A Emergency Switchgear Room Cooling Fan 6.6.19 88-3017E . RHR HX SW Valves HV-11210B and HV-11215B - Unit'1 6.6.20 88-3017F RWCU Isolatio'n Valves - Fire in the Control Room 6.6.21 88-3018E Appendix R Cable isolation for RHR SW Valves
. 6.6.22 88-3018F- RWCU Valve Isolation for Control Room Fire (U2)
EC-0134859 Revision 4 Page /C
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Susquehanna Steam Electric Station Appendix R Analysis for a Control Room Fire 6.7 'n ineerin Work Re uests EWR Title I 6.7.1 M80821 Ap'pendix R - Cables/Components for Emergency Diesel Operation 'enerator
. 6.7.2 M80805 Unit 1 - RWCU Valve'Isolation 6.7.3 M80546 Appendix R - ESW Issues Analysis 6.9 Databases V
6.9.1 Appendix R Compliance Database Management System (ARCDMS), dated November 1, 1994 (including outstanding change'mechanisms through August 23, 1995) 6.9.2 SEIS Equipment Index, dated 7/22/87.
6.10 Miscellaneous PAL Memorandum No. EE1233, dated 9/24/87,'ppendix R'Activity 10-V'.10.1 Raceways Recommended to be Protected.
6.11 Non-Conformance Re orts 6.11.1 NCR 87-0,725 6.11.2 NCR 87-0726 6.11.'3 NCR 87-0744 6.11.4 NCR 87-0745, 7.0: RESULTS 7.1 Cable Hit Resolution Re oit Develo ment v
v I
As a part of revision i to this calculation, the Cable Hit Resolution Report ~
(Appendix A) generated from the Appendix R Compliance Database Management System (ARCDMS) was verified "line by line" to ensure consistency with Appendix A of the previous'revision (Reference 6.2.12). DifFerences between the two reports were reviewed and justified. Any'hanges to this information as a result of subsequent revisions were checked as a part of that revision.
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Susquehanna Steam Electric Station Appendix R Analysis for a Control Room Fire-7.2 Cable Hit Worksheet Develo ment J
Revision 1 of this calculation reviewed and updated all cable hit worksheets affected by the implementing actions taken as a part of the Appendix R Closeout Project.
Cable hit worksheets for the CSHVAC cable hits were extracted from. calculation EC-013-0863 (Reference 6.2.8). Some cable hit worksheets for cables for certain RCIC components were extracted from calculation EC-013-0814 (Reference 6.2.9). These worksheets were included in Appendix B so that all worksheets for the Control Room Analysis would be contained in one location.
t In some cases, a separate study addresses the specific cable hits (e.gts certain cable hits for RBHVAC, Flow Diversion, SPM and RCIC). In such" cases, a worksheet was not developed for the specific cable hit,and instead, the respective applicable calculation was referenced iii Appendix A. =
In some cases, a cable hit is associated with a number of different components. In many such cases, only one cable hit worksheet was generated and each of the components was identified on the worksheet.
7.3 Cable Hit Evaluation Summa b .S stem-The following is a discussion on a system basis of the implemented solutions for Path 2 cable hits or potential system impacts identified or postulated for 'esolvirig Control Room fire:
7.3.1 ADS Calculation EC-'013-0845 (Reference 6.2.3) concluded that for a fire in the Control Room to spuriously actuate ADS at least two (2) hot shorts in conjunction with the spurious operation of a CS or RHR pump must occur simultaneously.. The ADS circuit for one division.requires that pressure permissive contacts (K9A and K10A) be closed when the low pressure system is available. Therefore, spurious operation of ADS due to a fire in the Control Room is not considered credible.
As a more plausible but still not credible event, it can be postulated that a Control Room fire could result in two selective hot shorts on'the ADS actuation circuitry such that, upon initiation of the RHR pump by the operator from the'emote' Shutdown Panel, a spurious ADS actuation could occur. In the unlikely event that this were to occu'r, the effect of this eventloss,of motive steam to drive RCIC,
'ould be mitigated by use of the RHR System in the LPCI 'mode from the Remote Shutdown Panel to achieve a Path 2 safe shutdown. Eventually, RHR could be s ~
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EC-013-0859 Revision 4
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L Susquehanna Steam Electric Station Appendiz R Analysis for a Control Room Pire placed into the Alternate Shutdown Cooling mode for accomplishing the decay heat removal function.
,Therefore, the loss of RCIC at the Remote Shutdown Panel due to a spurious ADS, even though considered to be a non-credible event, would not affect the
.732 Conderisate'\
'bilityto achieve and maintain safe shutdown.
Inadvertent injection by the condensate system could be postulated as a result of a Control Room fire. This inadvertent injection, however, would'ot be possible until the reactor pressure was reduced to below 600 psig. The normal operating
.pressure'or the SSES reactor is 1050 psia which corresponds to a temperature'f 550 F. 'The condensatesystem shutoff head of 615 psia corresponds to a temperature of 489'. This represents a temperature difference of 61 F. At a vessel cooldown rate of 90'i hour, it would take approximately 40 minutes before vessel pressure would reach the level at which condensate could inject.
Since this condition will not occur until the vessel is at a lower pressure and a very if low power level, an analysis'will be performed to determine the SRV discharge piping can sustain the loads from this condition. Since adequate time exists to perform an operator action to prevent or mitigate the effects of this condition, this, remains as an option should the'results of the analysis described above not be favorable.
a LOOP will cause a loss of power to the 13.8 kv switchgear, this operator
'ince action will only be required if a LOOP does not occur with the fire. Therefore, should this action be required to be performed, normal lighting should be available.
As a result, emergency lighting to meet the requirements of Appendix R Section III.J need not be installed's long as it can be shown that the fire will not damage normal lighting.
7.3.3 CRD The postulated concern for the CRD system circuits that-are not isolated from the
-main Control Room is the inadvertent and uncont'rolled" injection into the RPV resulting in a vessel overfill condition at high pressure. This condition for CRD would re'suit in an injection rate of less than 100 gpm. An injection rate of this magnitude would allow greater than 30 minutes for the operator to respond. The operator would respond by taking control of the unit at the RSP. The impact of inadvertent, CRD injection would be mitigated by throttling. back on the RCIC injection rate at high pressures and the RHR SDC injection rate at low pressures.
ina'dvertent injection by the CRD system will have "no impact on safe 'herefore, shutdown.
Revision 4'C<13-0859 Page
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Susquehanna Steam Electric Station Appendix R Analysis for a Control Room Fire 7.3.4 CSHVAC.
A fire in, the Control Room could damage cables for Control. Structure HVAC equipment, by causing grounds, open circuits, or hot shorts. 'The cable failures were analyzed in Calculation EC-013-0863 (Reference 6.2.8) and those that could prevent the proper functioning of equipment, and potentially result in the, loss of, CSHVAC, were identified.
A modification was performed (DCP 88-3016H) to provide a backup control panel to ensure that in case of a Control Room fire, the CSHVAC system components required for Pa'th 2 safe shutdown would remain functional. The "new" Control Structure HVAC Alternate Control Panel OC879 was installed in Area 21, Elevation 783'-0" and provides for local operation arid for isolation from Control Room damaged circuits. During normal plant operation, the transfer switches are in the normal position and the control switches are in the auto position.
In addition to the alternate HVAC panel, Plant Procedure ON-100/200-009 requires an operator to secure any, battery equalizing charges in progress and to implement Procedure, ON-030-001 to restore Battery Ro'om Ventilation, iflost due to a fire in the Control Room.
For the case of a fire in the Control Room, procedural actions contained in Procedure ON-030-001 assure that the smoke from the Control Room fire will not acct those areas of the Control Structure that must be habitable for remote operation of the CSHVAC System.
By performing the above-mentioned procedural actions and controlling CSHVAC at Panel OC879, the availability of CSHVAC to support Safe Shutdown Path 2 for a Control Room fire is preserved.
7.3.5 CSS In the event of a fire in the Control Room, certain cables for the Core Spray System automatic initiation logic could fault, potentially resulting in the spurious actuation of a Core Spray Pump.
ll Core Spray System circuits'are not isolated from the Main Control Room. By a number of independent spurious operations on the Core Spray System 'ssuming components, a vessel'overfill condition caused by inadvertent injection could be' postulated. Should this condition occur, it would not occur until the RPV was at low pressure and safe shutdown could still be accomplished by further depressurizing the RPV with the SRV's available at the RSP, using RHR in the LPCI mode and, ultimately, using RHR in the Alternate Shutdown Cooling mode:
Any excess water flow from the Core Spray System resulting from this condition
\
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Susquehanna Stcam Electric Station Appendix R.Analysis for a Control Room Fire t
E could be integrated with the shutdown approach described above with no impact to safe shutdown.
7.3.6 EDG HVAC Ventilation Fans OV512A, B, C, D are required for cooling of the Diesel Generator Rooms and c'ould be lost due to a fire in the Control Room. Without the fan running the room temperature could exceed the recommended operating design temperature of the equipment, and could prev'ent.the system from performing its intended safe shutdown function. l
.In the original design, a Control Room fire-induced fault could-either blow the control circuit fuse or create an open circuit, thereby disabling fan control from the Room.. However, new temperature switches (TSHL-08271A, B, C and 'ontrol D), one in each Diesel Generator Room, have been installed (per DCP 86-3010C) to automatically start the respective room fan when room temperature exceeds the switch-setp oint:
This modification isolates the Control Room portion of the circuitry and thus assures that the Diesel Generator Room fans will operate to support safe shutdown Path 2 in the event of a Control Room fire. No operator response is required as the fan automatically starts on high temperature.
C I
.7.3.7 Electrical I
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A. Diesel Generators I Diesel Generators A, B, C and D are standby power supplies which provide Class lE power to the Appendix R Safe Shutdown equipment in the event of total loss of'ooffsite power. A fiAh diesel, diesel generator is available as a substitute if. any one of the four diesel units is temporarily 'out of service.
However, no credit is taken for Diesel Generator E to achieve Appendix R .
compliance.
Each of the diesel generators'an be 'operated at their respective local generator and engine control panels (OC519A'thro'ugh E and OC521A through E).or at the plant operating benchboard (OC653) in the main Control Room. A local-remote selector switch enables the operator to transfer control from the main Control Room to the local panels by isolating the control circuits from'C653.
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In the original design, the selector switch in the Control Room panel isolated only one side of the remote control circuits. Thus, a Control Room fire which results in conductor shorts or shorts to ground at OC653 could have disabled EC-013-0859 Revision 4 Page 7 /
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Susquehanna Steam Electric Station Appendix R Analysis for a Control Room Fire I
the engine or generator control circuits and prevented operation from the local control panels for a Path 2 safe shutdown. Since a loss of oAsite power was assumed for this fire, the unavailability of the diesel generator during a Control Room fire would adversely aFect safe shutdown capability."
Modifications (DCP 88-3016J, K, L, M and N) were performed to completely isolate both sides of the Control Room circuits. This design ensures that local control of the diesel generators remains available in the event of a Control Room fire. Procedure ON-100/200-009 contains the operator action to locally start the Diesel Generators, ifrequired, in response to a loss of offsite power..
B. 4.16KV Safeguards Switchgears In the event of a Control Room fire, certain cables for control and indication of the breakers from the Emergency Diesel Generators to the 4.16 kV ESS Switchgears could fail resulting in the loss of power to the buses. However, this cable fault can be isolated by operation of a local control switch.
Procedures ON-100/200-009 require an operator to'manually close the breaker at the switchgear in order to re-energize the bus, should the breaker fail to close automatically. 'I I
To prevent failures in the following associated circuits (of a common power source) cables from causing loss of 4.16KV Safeguards Switchgear 1A201, 1A202, 1A203, 1A204, 2A201, 2A202, 2A203, and 2A204, circuit coordination between the primary and secondary side fuses of the potential transformer was performed in Calculation EC-013-0624 (Reference 6.2.6) for the following cables:
Cable ~Com onent
- 1) NK1A0401G 4.16KV Safeguards Switchgear 1A201
- 2) NKIA0402G '4.16KV Safeguards Switchgear 1A202
- 3) NKIA0403G 4.16KV Safeguards Switchgear 1A203
- 4) NK1A0404G 4.16KV Safeguards Switchgear 1A204
- 5) NK2A0401G 4.16KV Safeguards Switchgear 2A201
- 6) NK2A0402G 4.16KV Safeguards Switchgear 2A202
- 7) NK2A0403G 4.16KV Safeguards Switchgear 2A203
- 8) NK2A0404G 4.16KV Safeguards Switchgear 2A204 The calculation concluded that adequate circuit coordination currently exists.'
Thus, a fire in the Control Room will not impact the availability of the 4.16KV Switchgears to support safe shutdown due to associated circuits concerns.
EC-013-0859 Revision 4 Page Z.2
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Susquehanna Steam Electric Station Appendix R Analysis for a Control Room Fire
'.3.8 ESW,HVAC Ventilation Fans 1V506A, B and 2V506A, B are required for cooling of the RHR Service Water Pump Rooms. Fans OV521A, B, C and D are required for cooling of the ESWS Pump Rooms. Each of these fans could be lost due to a fire in the Control Room. Without the fans running, the respective room temperature could exceed the recommended operating design temperature of the equipment, and could prevent the system fr'om performing its intended safe shutdown function.
In the original design, a Control Room fire-induced fault could either blow the control circuit fuse or create an open circuit, thereby disabling fan control from the Control Room. However, new temperature switches in the respective pump rooms have been installed, as noted below, to automatically start the respective room fan when room temperature exceeds the switch setpoint.'Com Temp DCP D~escri tioo Switches Reference 1V506A RHRSW Pump Room Fan TSHL-18201A 86-3008F 1V506B ~
RHRSW Pump Room Fan TSHL-,1 8201B 86-3008F 2V506A RHRSW Pump Room Fan TSHL-28201A 86-3009F 2V506B RHRSW Pump Room Fan TSHL-28201B 86-3009F OV521A ESSW Pump Room Fan TSHL-08206A 86-3010D OV521B ESSWiPump Room Fan TSHL-08206B 86-3010D OV521C ESSW Pump Room Fan, TSHL-08206C 86-3010D OV521D Pump Room Fan,,
'SSW TSHL-08206D 86-3010D 1
These modifications isolate the Control Room portion of the circuitry, 'thereby assuring the operability of the pump room fans to support Safe Shutdown Path 2 in the event of a Control Room fire. No operator response is required as the fans automatically start on high temperature.
7.3.9 ESWS The Emergency Service, Water (ESW) System provides cooling water to the Emergency Diesel Generators which are required for Appendix R Safe Shutdown.
Each loop supplies cooling w'ater to the diesel coolers through separate inlet and outlet motor operated valves. Control of the valves is from the Main Control Room Panel OC653 In 1988, an evaluation was performed which indicated that a fire in the Main Control Room could have caused control cables associated with either the ESW valve controls on OC653 or the auto-loop transfer logic to be damaged, thereby, impacting the operability of ESW. The valves on both loops could have also
'puriously closed due to a short in the control. cables. Such spurious closure of the EC-013-0859 Revision 4 Page gg
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Susquehanna Stcam. Electric Station Appendix R Analysis for a Control Room Fire valves would had to have been immediately corrected whenever the diesel engine is .
running to support Appendix R safe shutdown.
h To prevent loss of Emergency Service Water to the Diesel Generator-coolers, isolation, of the following cables and local control for the following valves'was "necessary.
Cable ~
- Valve AKOS0404C, G HV-01112A AKOS0405C, G -
HV-01122A BKOS0406C, G HV-01112B, BKOS0407C, G . HV-01122B CKOS0408C, G . HV-01'112C CKOS0409C, G . HV-01122C DKOS0410C, G HV-01112D DKOS0411C, G . HV-01122D e
A modification was implemented (DCP 88-30161) which removed control of the ESW valves from the main Control Room panel OC653, and located it to new control pariels OC521A, B, C and D. Therefore, a fire in the Control Room will not impact the operability of the ESW System to support Safe Shutdown Path 2.
7.3.10 Feedwater
'he concern for the spurious operation of the feedwater circuits that are not isolated from the main Control Room is the inadvertent and uncontrolled injection by the feedwater system resulting in a vessel overfill condition at high pressure. 'As mitigating action, the NRC has stated that the use of an immediate operator '
action to close the MSIV's prior to evacuating the'main Control. Room is an acceptable mitigating action. Closing the MSIV's will remove the motive steam to the feedwater turbine and steam driven pump.'his alone, however, will not stop feedwater injection and prevent any impact to safe shutdown.
. If after performing this action, the feedwater flow controller were to fail high in conjunction with a loss of the 54" feedwater trip there is a sufficient amount of steam available in the'main steam system to continue to drive the feedwater turbine driven pump such that a vessel overfill condition would result in less than 1,minute.
To prevent 'this condition an additional operator action to close the feedwater pump discharge valve prior to evacuating the Control Room is necessary. 'This is' currently an immediate operator action in the Control Room Evacuation Procedure, ON-100/200-009.
This 'additional action, however, will not prevent the undesired condition from occurring since the circuits for feedwater pump discharge valves are not isolated Revision 4 'C-013-0859 Page
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Susquehanna Steam Electric Station Appendiz R Analysis for a Control Room Fire from the Control Room and; as such, are susceptible to post evacuation hot shorts.
As" a positive action to assure that this condition does not occur, the,feedwater turbines must also be tripped by the operator prior to evacuating the Control
, Room.
It has been verified that a hot short cannot restart the feedwater turbine once it has been tripped. This is true since re-starting the turbine requires that the operator drive the motor speed changer to zero, press the tuibine reset button and, then, increase turbine speed with the motor'speed.changer. In addition, the feedwater pump discharge'valve for the particular turbine must also spuriously open. This combination of cable faults is considered to be too remote to be credible.
Each of these actions at the "operating benchboard, 1/2C651, in the same vicinity where the unit. is scrammed. Therefore, both of these actions could be performed in. rapid sequence'following the action of manually scramming the unit.'he combined time.to perform 'these actions in conjunction with the reactor scram, and closing the MSIV's is estimated to be on the order of 1 minute.
y 7.3.11 Flow Diversion A. Reactor Head Vent Valves In the event of a'ontrol Room fire, inadvertent RCS blowdown via the spurious opening of the Reactor Head Vent Valves HV-B21-1F001, 1F002 (Unit 1), 2F001 and 2F002 (Unit 2) is p'revented by normally depowering,the 1F001 and 2F001 valves. Startup procedures GO-100-002 and GO-200-002 require an operator to lift lead 1R at the MCCs specified
~S below.'alve HV-B21-1F001 MCC,1B236 Cubicle 102 HV-B21-2F001 . MCC 2B236 Cubicle 102 H
Since these valves "are de-powered closed during normal plant operation,'a Control Room fire cannot result in spurious actuation of both'series valves.
This precludes the possibility of flow diversion via the Reactor Head Vent line.
B. Main Steam Line Drain Isolation Valves Spurious opening or failure to close the Main Steam Line Drain Isolation HV-B21-1F016, 1F019, 2F016 and 2F019 is possible as a result of a 'alves Co'ntrol Room fire. However, Calculation EC-013-0964 (Reference 6.2.5) has determined that the flow diversion that would result in the event both isolation valves were to open would be insufficient to impact Path 2 safe shutdown capability. 'dequate steam generated by decay heat would be- available,to EC-013-0859 Revision 4 Page
t Susquehanna Steam Electric Station Appendix R Analysis for a Control Room Fire
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support RCIC operation despite the flow diversion to the', HP Condenser.
Therefore, the spurious opening of both valves in series would not impact Safe Shutdown Path 2.
For the condition described in Appendix C, Resolution of the MOV,"Hot Short" Issue, prior to entering RHR in the Alternate Shutdown Cooling mode, .
it'must be assured that the main steam line drain is isolated from the HP Condenser.. Calculation EC-,083-0530, Effect of Flow Diversion through the Open Main Steam Line Drain Valves, has determined'that, when using
'Alternate Shutdown Cooling, this line must be isolated in approximately 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> in order to prevent an impact to the ECCS systems taking suction from the Suppression Pool. In order to isolate this system, either the F019 or the F021 and F033,valves must be closed.'his operator action applies to both, units. An operator action has been added to drawing E-690 to capture this required operator action.
Since this action is not required for a minimum of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> after the event, 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> battery powered emergency lights would not be effective in aiding the operator. -Due to the simplicity of this action, hand-held lighting routinely carried by the operators is considered to be adequate for this action.
Reactor Water Clean-up Isolation Valves-To isolate the RWCU System for a fire in the Control Room, either isolation valve HV-G33-1F001 (2F001) or HV-G33-1F004 (2F004),is required to close and not spuriously open to preclude RCS flow diversion. In the original design, neither valve was isolated for a Control Room fire. A Control Room fire could have resulted in cable faults leading to the inability to close or the potential spurious opening of the two Reactor Water Cleanup Isolation Valves
-HV-G33-'1F001, 1F004, 2F001 and 2F004. This condition in conjunctio'n with the spurious opening of the HV-G33-1F033/2F033 valve would create a flow diversion.
I
, Although the RWCU letdown line has pressure switches on either side of the F033 valve that will activate to de-energize and close this valve protecting the piping system in the event of an inadvertent opening of the F033 valve, a modification (DCP 88-3017F and 18F) was implemented to provide valves HV-G33-1F004 and 'HV-G33-2F001 with circuit, isolation through a new isolation control transfer switch at the Remote Shutdown Panel. The transfer'witch is dedicated to valves HV-G33-1F004 and HV-G33-2F001. The dedicated transfer switch provides the operator at the Remote Shutdown Panel with the flexibilityto determine when letdown through the RWCU System is to be terminated or restored.
EC-013-0859 Revision 4 Page 2 +
Susquehanna Steam Electric Station Appendix R Analysis for a Control Room Fire The circuit isolation ensures that the valve is protected from spurious operation in the event of a Control Room fire. The valve opening circuit, closing circuit position indication and thermal overload bypass circuits were modified with remote shutdown isolation contacts such that all Control Room components and devices are isolated upon transfer to the Remote Shutdown Panel 1C201 (2C201).
D. Suppression Pool Filter Pump Suction Valves The potential for spurious actuation of both valves HV-15766 and HV-15768 (Unit 1) or HV-25766 and HV-25768 (Unit 2) was evaluated in Calculation EC-013-0725 (Reference 6.2.7). Due to a lack of circuit isolation, a Control Room fire can result in inadvertent flow diversion via the Suppression Pool.
Filter Pump Suction Valves. Therefore, an operator action to close these valves should a decrease in suppression pool level occur has been included in the plant procedures. See Calculation EC-013-0725 for the details.
7.3.12 HP,CI !
Calculation EC-013-0788 evaluated the impact on plant 'safe shutdown of a spurious initiation of HPCI during a Control Room fire.'purious initiation of HPCI would only be a concern if the reactor high level trip was defeated by the same fire'.
This condition can be postulated to occur from a combination of a hot shorts and/or two shorts to ground on the start and/or control circuitry for selected efFects of the event within approximately 3 minutes. 'o components. Should this condition occur, action must be, taken to mitigate the address this, a plant modification will be implemented to prevent the condition from occurring. See Calculation EC-013-0788 for the. details.
The condition of three independent hot-shorts causing spurious operation of the system and the condition of sequential selected cable faults on the HPCI control circuitry that initiates the system for 25.to 30 seconds and then is overcome by a fault to ground which disables,.the 54" trip within. the next 30 to 40 seconds have been reviewed'with the NRC and are considered to be a non-credible event that are not required to be included in the Appendix R design basis. '
7.3.13. MSIVs In the event of a Control Room fire, various cables for the Inboard Main Steam Isolation Valves (HV-B21-1F022A, B, C and D and HV-B21-2F022A,', C and D) and Outboard Main Steam Isolatio'n Valves (HV-B21-1F028A, B, C and D and HV-2F028A, B, C and D) could experience a fire-induced fault to cause the EC-013-0859 Revision 4 Page "Z7
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Susquehanna Stcam Electric Station Appendix R Analysis for a Control Room Fire MSIV's to remain open. An inadvertent opening of two,MSIV's in any, single main steam line could result in an undesired RCS blowdown. These cable faults, however, would not prevent closure of the MSIV's should a trip signal from variable, such as low condenser vacuum or low, low, low'eactor vessel a'rocess level, be received.
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To address the condition of an inadvertent and uncontrolled injection'f the feedwater system, the NRC has stated that man'ual closure of the MSIV's will be allowed for SSES as an immediate operator action. This action will remove the motive steam from the feedwater turbine driven,pump and prevent injection by
'eedwater. To use an immediate operator action, other than a reactor scram, for the Control Room fire scenario Generic Letter 86-10 requires a demonstration of the capability to'perform the action and an assurance that a subsequ'ent.spurious operation cannot negate the e6ects of the manual action.
For the action of manually closing the MSIV's prior to evacuating the main Control Room, it has been'verfied that a subsequent spurious operation cannot negate the effect (i.e a subsequent hot short or series of hot shorts cannot reopen these valves)., This action is currently included in Procedure ON-100/200-009, Evacuation of the Control Room, as an immediate operator action. Since the location from which the reactor is scrammed is within a few feet of the location from which the MSIV's will be closed, it is reasonable to assume that this action can'be accomplished in a short period of time by a single operator. As such, this additional immediate operator can be performed in the event of a Control Room fi're. The combined time for performing this action in conjunction with the reactor scram and the actions itemized above for the feedwater system is estimated to be on the order of 1 minute.
As a'n added precaution to assure these valves are closed, Procedures ON-100-009 and.ON-200-009 require an operator to trip the following breakers in the event of a Control Room fire.
Breaker Valves 1Y201A-CB2A and 1Y201B-CB8B HV-B21-1F022A, B, C and D HV-B21-1F028A, B, C and D 2Y201A-'CB2A and 2Y201B-CB8B HV.-B21-2F022A, B, C and D HV-B21-2F028A, B, C and D J
h Removing power to the MSIVs ensures that, the outboard and inboard MSIVs are closed in the event of a Control Room fire.
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4 Susquehanna Steam Electric Station Appendix R Analysis for a Control Room Fire 7.3'.14 RBHVAC I 4'he Reactor Building Ventilation System fans are required operable to provide =
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cooling to various rooms to support Safe Shutdown Path 2. Without the fan running, the room temperature could exceed the recommended operating design temperature of the equipment, and could prevent equipment within.the respective room from performing its intended safe shutdoWn function.
Temp DCP
~Com . D~escri tion 'witches Reference.
1V210B RHR Pump Room Unit Cooler Fan TSHL-17660B 86-3008D 2V210A RHR Pump Room Unit Cooler Fan
- TSHL-27660A,86-3009D 1V208A RCIC Pump Room Unit Cooler Fan TSHL-17661A 86-3008E 2V208A RCIC Pump Room Unit Cooler Fan TSHL-27661A 86-3009E 1V222A Emg. Swgr. Room Unit Cooler Fan TSHL-17631A 86-3008C 2V222A 'mg. Swgr. Room Unit Cooler Fan TSHL-27631A 86-3009C s
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Cable- Hit Worksheets for the above-mentioned components are provided in Appendix B with the exception 'of the following cables: FKOV1451M, FKlB2541C, D, E, F (for 1V222B) and FK2V2541F (for 2V222B). These cable hits are dispositioned in Calculation EC-013-0846 (Reference 6.2.12).
In the original design, a Control Room fire-induced fault'to certain cables for these.
fans could either'low the control circuit fitse or create an open circuit, thereby disabling fan control from the Control Room. However, new temperature switches in the individual rooms have been installed; as noted below, start the fan when the room temperature exceeds the switch setpoint.
to'utomatically e
The temperature switch co'ntrol scheme does not require any operator response as the fan automatically starts on 'high temperature to maintain room temperature within design limits.
Therefore, a fire in the Control Room. will not impact the availability of the RBHVAC System to support Path'2 Safe Shutdown.
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7.3.15 RCIC e I II The RCIC components required for Path 2 safe shutdown are properly is'olated from'a Control P.oom fire. The potential impact of spurious operation of RCIC components resulting from the fire-induced damage to cables for the RCIC automatic actuation logic was evaluated and determined not to impact. safe shutdown. Sufficient time exists to take control of the RCIC system at the RSP and to mitigate the effects of any spurious operations affecting the RCIC system.
See Calculation EC-0i3-0788 for details:
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'Susquehanna Steam Electric Station Appendix R Analysis for a Control Room Fire
,7.3.16 RHR The circuitry'for the majority of the RHR components required for Path 2 Safe Shutdown are properly isolated from a Control Room fire. However', several" cables for the RHR automatic actuation lo'gic and one cable for valve HV-E11-2F008 are not isolated. Fire-induced faults to select RHR automatic actuation logic cables could result in inadvertent spurious actuation of RHR safe, shutdown components., In addition, fire damage to the 2F008 cable could preclude operability of the valve from the RSP. These cables are. routed in the space below the Control Room. raised floor (in Fire Zones 0-26G and 0-26J) and in the "cable shaft under the north and south soffits (Fire Zones 0-26M and 0-26R).
Deviation Request No. 37 was issued and,subsequently approved by. an SER justifying that the fire protection features provided under the Control Room raised floor and cable chases and cable shafts as described in the deviation request are adequate for the existing cable installation and provide an equivalent degree of safety as required by Appendix R. The, deviation request concluded that the addition of raceway wrapping and fully-automatic fire suppression systems in Fire Areas CS-9 to meet the requirements of 10CFR50 Appendix, R,Section III.G.2 would not significantly increase the level of fire protection in these fire areas.
Another potential concern for the non-safe shutdown division of the RHR System who'se.circuits are not isolated from the main Control Room is inadvertent and uncontrolled injection'nto the RPV. By assuming a number of independent spurious operations on these RHR System components, a vessel overfill condition could be postulated. Should this condition occur, however, it would not-occur until the RPV was at low pressure and safe shutdown could still be accomplished by further depressurizing'the RPV with'the SRV's available at the. RSP, using'HR in the LPCI mode and, ultimately, using,RHR in'the Alternate Shutdown, Cooling mode. Any excess water flow from the Core Spray System resulting from this condition could be integrated with the shutdown approach described above with no impact to safe shutdown.
C Therefore, adequate measures are in place to mitigate against the potential for, and consequences of, a possible fire in the Control Room from impacting the RHR cables that are not isolated.
7.3.17 RHRSW The Unit 1 and Unit 2 Residual Heat Removal Heat Exchanger Service Water Valves HV-11210B and HV-11215B (Unit 1) and HV-21210A and HV-21215A (Unit 2) are Appendix R Path 2 Safe Shutdown components that=must have the capability of being operated outside the Control Room. For a fire in the Control '
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Susquehanna Steam Electric Station Appendix R Analysis for a Control Room Fire I,
l Room, these valves are provided with control capability at the Remote Shutdown Panels 1C201B and 2C201B to support RHR Shutdown Cooling.
In the original design, all of the "control circuitr'y for these valves from the Control Room could be isolated at the RSP except for the thermal overload bypass circuitry to Control Room Panel OC697. In the event of a fire in the Control Room, the cable for the bypass circuit could have short circuited to ground causing the valve's control circuit fuse to blow which would have compromised the operability of the valves at the RSP.
't DCPs 88-3017E and 18E, added isolation circuitry to valves HV-.11210B and HV-11215B and HV-21210A and HV-21215A thermal overload bypass circuitry to assure the control capability of the valves at the RSP during an Appendix R Path 2 shutdown. Thus, a fire in the Control Room will not impact the ability to operate these valves from the RSP to support Path 2 safe shutdow'n..
e 7.3.18 RRS In order to support. Path 2 Safe Shutdown in the event of a Control Room fire, the Reactor Recirculation Pumps are required to be automatically or manually tripped prior to pla'cing RHR into the Shutdown Cooling mode.
'I A. Two cables, one for each of the Unit 1 and 2 Reactor Recirculation Pumps .
. (1P401A and 1P401B) are routed in cable shafts under the north and south soffits-(Fire Zones 0-26M and 0-26R) ofFire Area CS-9.
Deviation Request No. 37 was issued and subsequently approved per an SER justifying that the fire protection features provided under the control room, raised floor and the cable chases and c'able shafts are adequate for the existing cable installation and provide an equivalent degree of safety as required by Appendix R. The deviation request concluded that the addition of raceway wrapping and fully-automatic fire suppression systems in Fire Areas CS-9 to meet the requirements of 10CFR50 Appendix R, Section III.G.2 would not significantly increase the level of fire protection in thes'e fire areas.
B. A fire in the Control Room (in Fire Zone 0-26H) could damage-certain cables for the Units 1 an'd 2 Reactor Recirculation Pumps resulting in the inadvertent spurious operation of the respective pump(s). In,the unlikely event of this occurrence, Procedure 'ON-100/200-009 requires an operator to trip Recirculation Pumps motor generator set (2 per unit) locally at the the'eactor respective 13.8KV.cubicles for the drive motors. This ensures that a fire in the .
Control Room that results in the, spurious start of the RRS pumps can be tripped. manually thereby preserving Safe Shutdown Path 2 functionality.
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Susquehanna Stcam Electric Station Appendix R Analysis for a Control Room Fire 7.3.19 Standby Liquid Control The, postulated concern for the Standby Liquid Control system circuits that are not isolated from the main Control Room is the inadvertent and uncontrolled injection into the RPV resulting in a vessel overfill condition at high pressure. This condition would result in an injection rate of less than 100 gpm. The available .
quantity of flow from this system is also limited to the inventory in the SLC Tank.
An injection rate of this magnitude would allow'greater than 30 minutes for the operator to respond. The operator would respond by taking control of the unit at the RSP. The impact of inadvertent SLC injection would be mitigated by throttling back. on the RCIC injection rate at high pressures and the,RHR SDC injection rate at low pressures. Therefore, 'inadvertent injection by the SLC system will have no impact on safe shutdown.
7.3.20 SPM Suppression pool temperature monitoring for the remote shutdown panels is provided by the SPM System for each unit. While two redundant divisions of the system are provided for e'ach unit and displayed at the units remote shutdown panel, there is a possibility that cable failure induced by a Control Room fire could result in the loss of suppression pool temperature indication at the remote shutdown panels.
In the event that both divisions of suppression pool temperature indication at the remote shutdown panel fail, alternative indirectmethods are available and acceptable to provide suppression pool temperature status. Suppression pool temperature can be inferred from suppression chamber atmosphere temperature and atmosphere pressure indication which are available at the remote shutdown panel. Because the chamber remains a relatively constant volume, the pool heat-up or cooldown rate will be related to these two air parameters.
Deviation Request No. 2 was issued and subsequently accepted by the NRC in an SER justifying the acceptability of utilizing the alternative means. of monitoring suppression pool temperature. Therefore, no further action is necessary.
7.3.21 SRVs In the event of a fire in a Control Room fire zone requiring evacuation and plant shutdown from the Remote Shutdown Panels, a SRV is required to be per Calculation EC-013-0845 (Reference 6.2.3) while the remaining opened'ntermittently ADS/SRVs are required to remain closed. For this Path 2 shutdown method, one out of three SRVs will be cycled to open and close manually by the operator at the Remote Shutdown Panel in order to depressurize the reactor vessel while maintaining sufficient steam pressure supply to the RCIC pump turbine.
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Susquehanna Steam Electric Station Appendix R Analysis for a Control Room Fire A fire-induced cable failure resulting in the spurious opening of one SRV has been determined to have an insignificant affect on the steam supply to the.RCIC pump turbine. In addition to this, symptom based Procedures EO-100-102 and EO-100-'12, require the operator to open additional SRV valves should this be necessary to depressurize the reactor to allow the use of low pressure injection systems.
This can be accomplished by depressurizing using an ADS/SRV controlled by an individual keylock switch in the relay room. The individual keylock switch circuits in'the r'clay rooms are independent of the 'Control Room and will function
'egardless of fire damage in the Control Room. Procedures. ON-100-009 and ON-200-009 provide the direction for an operator to manually control the ADS SRV's from the relay rooms.'
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Fire Ar Evaluation for: CS-9 Appe dix A Dat . /10/29 Required Shutdown Path: 2 Page 9 Control Room Appendix R Compliance Report
.'ffected Fire Analysis"- Dispositioning:.,
S stem Unit .- Com onent '::,Cable Zone Dis osition:,. Documen't;-
HV01120C CKOS0417C 0-26G Circuit modified to provide isolation from Control Room Appendix B DCP 88-3016I 0-26H Circuit modified to provide isolation from Control Room Appendix B DCP 88-3016I 0-26M Circuit modified to provide isolation from Control Room Appendix B DCP 88-30161 Do'cument":.:'.'LOWDIV HV01120D DKOS0419C 0-26H Circuit modified to provide isolation from Control Room Ap endixB DCP 88-30161 HV01122A AKOS0405C 0-26H Circuit modified to provide isolation from Control Room Appendix B DCP 88-30161 HV01122B BKOS0407C 0-26H Circuit modified to provide isolation from Control Room Appendix B DCP 88-3016I HV01122C CKOS0409C 0-26G Circuit modified to provide isolation from Control Room Appendix B DCP 88-3016I 0-26H Circuit modified to provide isolation from Control Room Appendix B DCP 88-3016I 0-26M Circuit modified to provide isolation from Control Room Appendix B DCP 88-3016I HV01122D DKOS0411C 0-26H Circuit modified to provide isolation from Control Room Appendix B DCP 88-30161 1 HV1 5766 EK1EC5101 0-26H Operator Action Required EC-013-0725 ON-100-009 EK1 Q403?K 0-26H Operator Action Required EC-013-0?25 ON-1 00-009 0-26N Operator Action Required EC-013-0725 ON-1 00-009 EK1 Q4169C 0-26H Operator Action Required EC-013-0725 ON-1 00-009 EK1 Q4169F 0-26H Operator Action Required EC-013-0725 ON-1 00-009 HV1 5768 FK1EC5208 0-26H Operator Action Required EC-013-0725 ON-100-009 FK1 Q0628G 0-26H Operator Action Required EC-013-0725 ON-1 00-009 FK1 Q4170C 0-26H Operator Action Required EC-013-0725 ON-1 00-009 FK1Q4170F 0-26H Operator Action Required EC-013-0725 ON-1 00-009 HVB211F001 EK1 Q160?C 0-26H Will not impact shutdown Appendix B GO-1 00-002 HVB211F002 FK1 Q1608C 0-26H Will not impact shutdown Appendix B GO-1 00-002 HVB211F016 EK1P62204 0-26H Spurious valve operation will not impact shutdown EC-013-0964 ON-1 00-009 HVB211F019 FK1P62315 0-26H Spurious valve operation will not impact shutdown EC-013-0964 ON-1 00-009 HVG331F001 EK1P64202 0-26H Modified HV-G33-1F004 circuitry to ensure operability Appendix B DCP 88-3017F HVG331F004 FK1 P6F202 0-26H Modified HV-G33-1F004 circuitry to ensure operabili Appendix B DCP 88-3017F FLOWDIV 2 HV25766 EK2E0002A 0-26H Operator Action Required EC-013-0725 ON-200-009 0=261 Operator Action Required EC-013-0725 ON-200-.009 0-26R Operator Action Required EC-013-0725 ON-200-009 EK2Q4037K 0-26H Operator Action Required EC-013-0725 ON-200-009 EK2Q4169C 0-26H Operator Action Required EC-013-0725 ON-200-009 EK2Q4169F 0-26H Operator Action Required EC-013-0725 ON-200-009 HV25768 FK2E0014A 0-26H Operator Action Required EC-013-0725 ON-200-009 FK2Q0628G 0-26H Operator Action Required EC-013-0725 ON-200-009 FK2Q4170C 0-26H Operator Action Required EC-013-0725 ON-200-009 FK2Q4170F 0-26H Operator Action Required EC-013-0725 ON-200-009 HVB212F001 EK2Q160?C 0-26H Will not impact shutdown Appendix B GO-200-002 HVB212F002 FK2Q1608C 0-26H Redundant valve is available EC-013-0725 ON-200-009 HVB212FO'I6 EK2P0178A 0-26H Spurious valve operation will not im act shutdown EC-013-0964 ON-200-009
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APPENDIX C RESOLUTION. OF THE MOV "HOT SHORT" ISSUE NRC INFORMATIONNOTICE 92-18 I
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1.0 Purpose
The purpose of this calculation is to document the final disposition of the MOV "Hot Short" issue described in NRC Information Notice (IN) 92-18, Potential for Loss of Remote Shutdown Capability During a Control Room Fire.
The resolution of this issue for SSES is possible due to the redundancy provided in Path 2,
. the safe shutdown path used to mitigate the effects of fires in the main Control Room..
The normal line up expected to be 'used for the Control Room fire scenario is to use RCIC for vessel make up, to use RCIC assisted by SRV's to control the reactor pressure,'to use RHR Suppression Pool Cooling during the time when steam is being dumped into the Suppression Pool and to use RHR'in the Shutdown Cooling mode after the reactor has been depressurized to less than 98 psig.'hould a single hot short damage any one of the valves required'for this expected line up, the following options are available using the equipment and procedures provided at the Remote Shutdown Panel
~ IfRCIC is lost, then reactor pressure can be quickly reduced to the level where injection using RHR in the LPCI mode is possible.
~ If the normal RHR Shutdown Cooling mode is lost, then RHR can be used in the
, Alternate Shutdown Cooling mode.,
~ If RHR Suppression Pool Cooling is lost, the RHR in the Alternate Shutdown Cooling mode can be used.
'I This calculation uses the redundancy available in Path 2 to determine the minimum number of Path 2 valves that must be protected from a hot short occurring and damaging the valve prior to transfer of control to the Remote Shutdown Panel. By preventing damage to this minimum set of valves, it will be assured that the requirements of Appendix R can be met even ifa damaging hot short were to occur.
2.0 Description of Problem: .
The postulated condition of concern is that a fire in the Control Room can cause "Hot Shorts", i.e. short circuits between control wiring and power sources, for certain'motor-operated valves (MOV's) needed to shut the reactor down and'to maintain it in a safe .
condition. Ifa fire in the Control Room forces the operators to leave the Control Room,
'these MOV's can be operated from the Remote Shutdown Panel (RSP). Hot Shorts, combined with the absence of thermal overload protection, however, could cause valve damage before the operator has actuated the transfer switches and taken control of these valves at the'RSP.
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Thermal overload protection for MOV's at SSES is bypassed in order to meet the requirements of Regulatory Guide 1.106, Thermal Overlo'ad Protection for Electric Motors on Motor-Operated Valves. The intent of this requirement is to,assure that thermal overloads do not prevent the MOV's from performing their safety-function during an accident. At SSES, the location of the thermal overload contacts in the MOV control circuitry would be ineffective in mitigating the effects of hot shorts even'f the thermal
'verloads were not bypassed.
/
Similarly, the'location in the MOV control circuitry of limit switch and torque. switch contacts renders these protective devices ineffective in mitigating the effects of MOV hot shorts.
I 3.0
Background:
f The initial approach to address this'issue was to identify those MOV's required to support safe shutdown for Control Room fires and to determine which were susceptible to the postulated failure mode. The information'related to this step was compiled in Calculation EC-013-0730, This calculation determined that,39 valves on Unit 1 and 40 valves on Unit 2 that were required to support safe shutdown were susceptible to the postulated MOV failure mode.
, Those valves determined to be susceptible to damage due to hot shorts were slated for a modification to relocate the torque and limit switches to a location within the control circuitry where they would be effective in interrupting a hot short due to a Control Room
'ire and preventing valve motor damage:
Since the original circuit review of the affected valves determined the valves did not have a sufficient number of spare conductors to accomplish the required circuit changes, new cable would have to be run for many of these valves. This significantly escalated the cost of the work. The total cost for all of this work was estimated to be approximately $ 8.0 million.
I Due to the large cost of resolving this issue using physical modifications, additional evaluations were determined to be required to assess the safety significance of this issue.
Two calculations, were prepared to hssess the safety significance of this issue. Calculation
'C-013-0983 performed a risk analysis of the MOV Hot Short issue. The results of this
.calculation and the fire hazards analysis'documented in Calculation EC-013-0555 determined that the safety significance of this issue was extremely small. Based on these results, Deviation Request No. 41 was prepared and issued to the NRC on June 21, 1993 as an attachment to PLA-3980.
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In early 1995, the NRC verbally requested some clarifications on the information contained in Deviation Request No. 41. The response to this NRC request for additional information was transmitted to the NRC by PPkL in PLA-4341 dated August 2, 1995.
I In a meeting on January 25, 1996 with the NRC in Allentown, the NRC informed PPEcL that they would be rejecting Deviation Request No. 41; Their reasoning was that other utilities had already dealt with this issue successfully without incurring significant costs.
. This calculation provides the final resolution for this issus for SSES.
Based on a series of discussion with the NRC, a revised spurious operations. criteria for Associated Circuits was developed. This criteria was transmitted to the NRC in PLA-
- 4505. This criteria has been applied in the evaluation contained in this appendix of the impact of MOV "Hot Shorts" resulting from Control Room fires.
4.0 Results and
Conclusions:
~
This calculation evaluates the list of potential problem valves with respect to the MOV hot short issue as documented in Calculation EC-013-0730 and performs a system evaluation of the valves and determines for each of the valves which other valves, must be able to be operated in order to achieve and maintain safe shutdown for a Control Room fire.
Table 1 provides a summary of the disposition for each valve on Unit 1. Table 2 provides a summary of the disposition for each valve on Unit 2. For each of. the valves identified in Tables 1 and 2 that required some mitigating action to preclude an impact to safe shutdown capability, a review of the possible solutions for each valve was performed.
l Table 3 provides a summary of the potential solutions for each of these valves. Table 4 provides a summary of the recommended solution for each valve.
Calculation EC-013-0730 identified 39 problem valves for Unit 1 and 40 problem valv'es for Unit 2. The system review documented within this appendix has reduced the number of problem valves to 12 for Unit 1 and 12 for Unit 2. Of these 24 valves, the modification review performed in this calculation has determin'ed that all of these valves can to mitigate the effects of MOV hot shorts by making wiring adjustments without be'odified running new cables. The preferred solution for each of these valves is to install interposing relays, since this solution eliminates the potential for damaging hot shorts for all fires except those occurring in the MCC.
4 The option oF relocating the torque and limit switches solves the problem for the fire in the main Control Room, but creates a susceptible condition for fires elsewhere in the plant.
Should the torque and limit switch relocation option be the only feasible option, for a particular MOV, the potential for a hot short in other areas of the plant causing valve damage must be investigated and it must be determined that such damage will not impact 8 h EC-013-0859 .
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the ability to achieve and maintain safe shutdown. This evaluation is to be conducted as a part of the engineering performed for each valve modification.
5.0
References:
5.1 Calculation EC-013-0730, Rev..0, Appendix R Safe Shutdown Path 2 MOV Hot Short Spurious Actuation.
5.2 Calculation EC-013-0555, Rev. 1, Appendix-R Hot Shorts, in the Control Room.
5.3,Calculation EC-013-0983, Rev. 0, Risk Analysis of Appendix R MOV Hot Short Modifications.
5.4 Calculation EC-013-0725, Rev. 2, Evaluation of the Containment Instrument Gas Valves and Suppression Pool Clean-up Valves, 5.5 Calculation EC-VALV-1043, Rev. 0, MOV Evaluation for Spurious Oper'ation due to Hot Short 5.6 PLA-3980 dated June 21, 1993 transmitting Deviation Request No. 41.
I 5.7 PLA-4341 dated August 2, 1995.
5.8 PLA-4505 Associated Circuits- Spurious Operation Issue.
6.0 Disposition Discussion:
6.1 Assumptions arid Requirements:
.6.1.1. Safe Shutdown as a result of fires in the main Control Room is classified as Alternate Shutdown. As such, the requirements of 10CFR50 Appendix R Section III.L apply-6.1.2. For fires in the main Control Room Section III.Lrequires that spurious operatioq of equipment that can affect safe shutdown functions be considered. The spurious operation criteria for circuits isolated from the main Control Room is contained in NRC Generic Letter 86-10 paragraph 5.3.10. That criteria reads as'follows:
~ The safe shutdown capability should not be adversely affected by any one spurious actuation or signal resulting from a fire in any plant area; and
~ The safe shutdown capability should not be adversely affected by a fire in any plant area which results in the loss of all automatic function (signal, logic) from the circuits EC-013-0859 Page /~~
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resulting from the fire; and
~ The safe shutdown capability should not be adversely, affected by a fire in any plant area which results in spurious actuation of the redundant valves in any one high-low pressure interface line.
For application of this criteria for all situations other than Hi/Lo pressure interfaces, it is
. assumed that one spurious operation occurs prior to actuating the transfer switch at the RSP., This spurious operation ma'y be as a result. of a hot short on a circuit that is isolate'd from the main Control Room or on one that is not: It is not necessar'y to postulate spurious operation of equipment in each of the'se two categories: i.e isolated and non-isolated circuits.
For circuits remaining in'he main Control Room that are not isolated, all potential spurious operations must be addressed on a one-at-a-time basis. Each individual spurious operation inust be identified and a mitigating action to prevent an impact to safe shutdown must be developed. In developing this mitigating action, however, it is not acceptable to ignore a potential hot short on one piece of equipment as a mitigating action for another piece of equipment. I The act of actuating the transfer switch at the RSP is the mitigating action to address any spurious operation for circuits isolated from the main Control Room. For circuits not isolated form the main Control Room, some other means of mitigiting the effects of the potential spurious operation must be'available.
6.1.3. This appendix addresses the additional mitigating actions necessary to assure that
. MOV damage as a result of hot shorts will not prevent achieving safe shutdown using the systems and components described in the body of this calculation.
6.2 Additional Mitigating Actions for A'ssuring Safe Shutdown: '
6.2.1. The MOV's impacted by this issue are listed in Table 1 for Unit 1 and Table 2 for-Unit 2. The MOV's listed pertain to the following systems and perform the following functions in support of safe shutdown'...
~ RCIC- performs the RPV pressure control and inventory make-up functions.
~ RHR- performs the decay heat removal function.
~ RHRSW/ESW- performs the decay heat removal function.
~ Suppression Pool Drain valves- one of these two series valves must remain closed to prevent a flow diversion from the suppresion pool that could affect the RPV inventory control function and decay heat removal function.
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~ Reactor Recirc. Pump Suction Valve- this valve must be closed prior to entering shutdown cooling to prevent short-cycling of the shutdown cooling flow.
~ Reactor, Water Clean-up Valve- this valve must be closed to prevent a loss of RPV inventory through the RWCU line'to either Liquid Radwaste or the Condenser.
l Should these primary safe shutdown capabilities be affected by MOViHot Shorts that
~ damage the equipment, there are other available modes of operation allowed for the
~ systems listed above. For example, the SRV provided at'he RSP can'perform the pressure control function described'for RCIC above and RHR can perform the inventory'.
make-up function described above for RCIC.
I This calculation will demonstrate how these redundant capabilities will be used to mitigate the effects of MOV hot shorts. Through the use of these redundant capabilities, this calculation will demonstrate how compliance with Appendix R is achieved.
6'.2.2. RCIC System Valves: The valves listed in tables 1 and 2 related'to the RCIC system could be damaged as a result of the postulated phenomenon. Ifany one of these valves i's damaged, RCIC may not be available for use at the RSP. This would impact the RPV pressure control and inventory make-up safe shutdown functions.
Ifthis were to happen, however, the reactor could be depressurized using the available SRV's at the RSP and vessel inventory make-up could be accomplished using RHR in the LPCI mode. By using RHR in the alternate shutdown cooling mode in accordance with ON-149/249-001, Suppression Pool Cooling can be accomplished using the same flow path. See Figure 1A attached for the Unit 1 flow path and Figure 1B attached for the Unit 2 flow path.
Prior to entering Alternate Shutdown Cooling, ON-149/249-001 requires that the. main steam drain line valves be closed. Calculation EC-083-0530, Effect of Flow Diversion Through the Open Main Steam Line Drains, determined that these valves would be required to be closed within 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of entering Alternate Shutdown Cooling to prevent an adverse impact to Suppression Pool level. Since the main steam line drain valves'are normally open, but are required closed and these valves could be prevented from.
automatically closing by the Control Room fire, these valves may be required to b' manually closed locally.
Since this action is not required for a minimum of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> after the start of the event-, 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> battery powered emergency lights would not be effective in aiding the operator. Due to the presence of diesel backed essential lighting in the general area that is unlikely to be' damaged by a Control Room fire and due to the simplicity of the required action, hand-held lighting typically carried by the operator is considered to be adequate for this action.
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I' Therefore, damage to any of the valves listed in tables 1 or 2 related to the RCIC system will not impact the ability to achieve or-maintain safe shutdown of the reactor. Therefore, no further action needs to be taken for'these valves.
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6.2.3. RHR System Valves: As stated in Section 1 of this appendix, impacts to the RHR system can be mitigated by relying on RHR Alternate Shutdown Cooling where normal shutdown cooling and suppression pool cooling is impacted or by relying on RCIC when impacts to the main RHR flow path valves are impacted:
6.2.3.1. HV-151-F008/009 and HV-251-F008/009: These valves are the shutdown cooling containment isolation valves. By relying on RHR Alternate Shutdown Cooling, these valves which normally must open to establish a,flow path fo'r normal shutdown cooling are only required, for this scenario, to remain closed and to prevent a Hi/Lo pressure interface flow diversion from the reactor.
A"review of the electrical schematics for these valves has determined that a hot short in the main Contr'ol Room cannot cause the spurious opening of HV-151-F008/009 or HV-251-F008/009. This is true because of the location of'the contacts for the low pressure permissive for these valves. Within the circuit, these contacts, which are physically located in the reactor building, are located below the hot short location and would, .
therefore, prevent the spurious opening of the valve until, the reactor pressure was less than 98 psig. Prior to reaching 98 psig, the transfer switches at the RSP would have been actuated and spurious operation would be.
prevented.'amage to any of these valves will not impact the ability to achieve or maintain safe shutdown of the reactor. Therefore, no further action needs to be taken for these valves.
6.2-.3.2. HV-151-F006A/B/C/D and HV-251-F006A/B/C/D: These valves are the shutdown cooling pump suction valves. They are normally closed. By relying on RHR Alternate Shutdown Cooling, the need for these valves can be i'educed: For this scenario, these valves must remain closed. Therefore, the only. concern is flow diversion from the RHR flow path, since the F008 and F009 valves remain closed in RHR Alternate =
I On unit 1, the F006B valve can be operated at the RSP. On unit 2; the F006A.valve can be operated at the RSP. All valves (F006 A/B/C/D for each unit) are electrically isolated from the Control Room by transfer switches at the RSP.
Since the criteria of Generic Letter 86-10 paragraph 5.3.10 requires the as'sumption of any
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one spurious operation for circuits that are isolated from the main Control Room, it must be assumed that only one of these valves spuriously operates. Ifthe F006B on unit 1 were to spuriously open, flow diversion from the RHR flow path would be prevented by the
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EC-013-0859, Page/
N combined eFect of the F006A, C, D and the F008 valves. Therefore, spur'ious operation of, the F006B valve is not a concern.,
Ifeither the F006A, C or D valves were to spuriously open,'he F006B on unit 1 would remain closed and prevent a flow diversion from the RHR flow path. Therefore, spurious opening of any of these valves is not a concern..
The situation on unit 2 is identical for the F006A valve Damage to any one of these valves will not impact the ability to achieve or maintain safe shutdown of the r'eactor. Therefore, no further action needs to be taken for these valves.
6.2.3,3 HV-151-F024B/028B and HV-251-F024A/028A: These valves are the Suppression Pool Cooling'return line isolation valves. These valves are normally closed.
Ifeither of these valves were to be damaged by an MOV Hot Short, RHR Suppression Pool Cooling would be impacted.
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The loss of Suppression Pool Cooling, however, can be mitigated by the use of RHR in the Alternate Shutdown Cooling mode of operation by taking suction on'the Suppression Pool through the F004 valve and routing the flow through the RHR heat exchanger. As such, the Suppression Pool Cooling return valves are only required to remai'n in their normally closed position to prevent flow diversion from the RHR flow path.
Since both of these valves and the HV-151-F027B'and the HV-251-F027A valves on unit 1 and 2, r'espectively, are isolated from the main Control Room by transfer switches, flow diversion due to a sihgle spurious operation is not possible.
Damage to any, one of these valves will not impact the ability to achieve or maintain safe '
shutdown of the reactor. Therefore, no further action needs to be taken for these valves.
6.2.3.4. HV-151-F007B and HV-251-F007A: These valves are the RHR Pump minimum flow valves. They are normally open. They are desired open until RHR flow reaches approximately '2400 gpm.
Ifa spurious operation result in the inability to close, these valves,'this will divert approximately 1000 gpm fiow from the RHR flow path. This will not impact safe shutdown since approximately 9000 gpm will still be available. This amount of flow is
'ufhcient to support shutdown. The diverted flow will return to the Suppression Pool.
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Ifa spurious operation results in the inability to open this valve, this could a6ect the operator's ability to slowly fillthe RHR discharge piping should the LOOP,,which must be
, postulated as a part. of this Appendix R scenario, result in a system draindown due to loss of keepfill. The operator, however, can still accomplish the sloC filling of the discharge EC-013-'0859 Page j7'/-g g
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A 'I piping, required as a mitigating action to deal with the loss of keepfill, without damaging the pump provided he throttles opens the F048 valve shortly after starting the pump.
II Damage to these valves will not impact the ability to achieve or maintain safe shutdown of the reactor. Therefore, no further action needs to be taken for these valves.
6.2,3,5. HV-151-F016B and HV-251-F016A: These valves are the normally closed,
, outboard Containment isolation valves for the Unit 1 division II and Unit 2 division I RHR Containment Spray System.- The inboard Containment isolation valves are HV-151-F021B on unit 1 and HV-251-F021A on unit 2 are normally closed. valves. Only the F016 valves are isolated from the main Control Room by transfer switches at the Remote Shutdown Panel. When the. transfer switch for the F016 valves are actuated at the RSP, a close signal is given to the valve. In addition, the open and close control circuits from the main Control Room are isolated. Since the F021 valves are not isolated from the main Control Room, they are considered to be vulnerable to hot shorts occuring'after the actuation of the transfer switches at the RSP.
Ifthe F016 valve were to spuriously open and be damaged by a hot short that drives the motor to failure, the ability to close the valve will no longer be available at the RSP.
RCIC would still be available to provide vessel make up. Should the F021 valve, which is not isolated frotn the main Control Room, subsequently spuriously open, then a flow diversion from the RHR flow path for'ither Suppression Pool Cooling or Shutdown Cooling to the RHR Drywell Sprays could occur..With respect to the flow diversion from the RHR Suppression Pool Cooling flow path, suppression pool cooling could still be accomplished since the water would flow from the drywell sprays to the diaphr'agm slab elevation through the downcomers and into the suppression pool. In the case of the RHR
, Shutdown Cooling flow path, however, this flow diversion could result in a drain down of the reactor vessel to the suppression pool.
To prevent this undersireable consequence, the ability to close the F016 valve. must be preserved by eliminating the potential for a hot short to damage the valve. This will preserve the ability to close the F016 valve from the Remote Shutdown Panel. As long as this valve is closed prior to entering RHR Shutdown Cooling, the negative consequences associated with a spurious opening of the F016 and F021 valves will be averted.
Therefore, a modification must be perform'ed to prevent'damage to the 1F016B and 2F016A valves. I 6.2.3.6. Remainin RHR S stem Valves F003'004'015 F017'047'048: The remaining valves on the RHR system are required to be capable of being operated to establish the Alternate Shutdown Cooling flow path for RHR.' single spurious operation
, of any one of these valves would prevent the use of RHR in either the Suppression Pool Cooling, the LPCI or the Alternate Shutdown Cooling modes of operation. That is, all EC-013-0859 Page /4> '7
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five valves are required to be available to support operation of the system for Decay Heat Removal or low pressure make-up.
'f the single spurious operation, however, were postulated to occur on one of these valves,
'RCIC operation would still be available. Therefore, the vessel inventory make-up function
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would be addressed. As such, some time:would be available to correct the condition either by manually repositioning the valve or by some other corrective action. The time
. available would be the amount of time before RHR must be placed in Suppression Pool Cooling to remove the heat being placed in the pool by RCIC operation.
At the RSP, RCIC has the capability of taking suctio'n from either the Condensate Storage Tank or the Suppression Pool. When taking suction from the Suppression Pool, RCIC can operate for approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> before the pool temperatures will reach the level where potential damage to the pump could occur. At this point ifthe operators were to-transfer suction to the Condensate Storage Tank, there would be a minimum of6.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> of operation ifthe CST were at its minimum Tech Spec level. Therefore, there would be approximately 10.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> available to manually open any valve that might be spuriously closed by a Control Room fire hot short.
Therefore, damage to these valves must be prevented so that they may be either manually opened or operated at the RSP to support RHR system operation".
k 6.2.4 RHRSW/ESW System Valves: The RHRSW valves required for safe shutdown are the RHR Hx inlet-and outlet valves: HV-11210B and HV;11215B; HV-21210A and HV-21215A. These valves must be open to allow RHRSW flow through the RHR"Hx.
The ESW valves required for safe shutdown are the spray pond return valves: HV-
'1222B and HV-01224B1; HV-01222A and HV-01224A1. The 22A/B valves for the bypass return line are normally open and must close in this scenario. The 24A1/Bl valves are normally closed and must open for this scenario. Since the diesel generators must be available for the Control Room fire, ESW must also be available to provide cooling to the diesels. Due to the short time duration the the diesels can run without cooling (approximatelt 4-5 minutes), local manual operation of these valves may not be feasible.
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Spurious closure of either valve on a given unit will afFect the decay heat removal capability of the RHR System. Therefore, damage to these valves must be prevented so that they may be oper'ated either at the RSP or by manual means locally to support RHRSW/ESW system operation.
6.2.5. Suppression Pool Drain Valves: The Suppression Pool Drain Valves are the Containment Isolation Valves for the system: HV-15766 and 15768; HV-25766 and HV-25768. These'valves are normally closed and one valve in each line must remain closed'to prevent a flow diversion from the Suppression Pool. These valves are not isolated from EC-013-0859 Page/ j'
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a 6.2.7. Reactor Water Clean-up'Valves: The Reactor Water Clean-up system must be, isolated from the RPV in order to assure a flow'diversion to either liquid radwaste or the Condenser does not occur. To prevent this for the fire jn the main Control Room, an operator action has been included in ON-1/200-009 to open a breaker to close valve HV-on unit 1 and HV-244-F033 on unit 2. (Reference Drawing E"-690). '44-F033 I
a 6.3. Options for Resolution: The valves listed in Table 3 are the minimum set of Path 2
, motor operated valves required to achieve and maintain safe shutdown for a control room fire which have the potential for spurious operation as a result of a hot short. With a hot short in the control room, the protective features of the limit switches and torque switches the valve and the motor operator are bypassed.'he standard motor operated control
'or circuit design for these valves is shown in Figure 2. Two standard designs are shown.
The specific design for the valve is dependent on whether or not the motor operator has a locking type worm gear for the torque switch.
In order to achieve safe shutdown, operation of these motor operated valves either at the remote shutdown panel or locally for the postulated hot short scenario must be assured.
Operation of these valves can be assured by, demonstrating the feasibility of an operator action'or by one of the following modifications listed above and described below. The evaluation to determine the feasibility of opening the valves using the handwheel is documented in Calculation EC-VALV-1043.
For those valves which have existing interposing relays in the control circuitry, the control room logic continues to energize the interposing relays and the limitswitch and torque switch contacts are rewired into contactor portion of the circuitry so that the postulated hot short, does not negate the protection of the valve or motor operator. The'rewiring is shown in Figure 3. For those valves which do not.have the feature of the locking worm gear, there is a spare conductor in the, cable from the motor control center to the valve operator. The spare conductor permits the limit and torque switches to be rewired into the control circuitry between the control room contacts and the open and close'coils of the contactors so that the valve and motor operator protection is functional for the postulated hot short. The rewiring is shown in Figure 4. For those valves which do not have existing interposing relays or a spare conductor, in the cable(s) from the motor control center to the motor operator, interposing relays may be added to the control circuitry so'that the circuitry is as shown in Figure 3...
In performing the review documented in EC-VALV-1043, the Nuclear Technology- Valve Group determined that all afFected valves are locking valves. The'electrical circuitry shown on the valve schematics that would be typical of a non-locking valve is not required for these valves. Therefore, all affected valves-may have spare conductors that can to relocate the torque and limit switches provided the 42F contact in the circuit is not be'sed performing another function.
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6.4; Recommended Solution: The recommended solution for each of the valves is to install interposing relays. This solution is recommeded because it best eliminates the problem. The solution of relocating the torque and limit switches solves the problem for Control Room, but leaves open the possibility for the same problem in another area of
'he the plant.
1 The range of solutions examined for each valve are listed in Table 3. The solution that can
'. be accomplished, ifthe recommended solution of installing interposing relays is determined to not be feasible due to spatial limitations, is summarized in Table 4. Ifthe solution in Table 4 of relocating the torque and limit switches is selected, an Appendix R review of the new configuration must be performed to verify that the circuit modification does not result in an unacceptable Appendix R non-compliance elsewhere.
I There are a total of 24 valves listed in Table 4. 12 of these valves are associated with each unit. For all of the valves, the circuit changes necessary to mitigate the sects'of Control Room MOV hot shorts can be accomplished using the existing cables by rewiring the circuits. The following summarizes the types of changes-available for this population of valves:
I Torque/Limit Switch Relocation:
9 valves have spare conductors in the existing cable running from the MCC to the valve. This will allow the relocation of the Torque/Limit Switches as depicted in Figure 4 without having to pull any new cables.
7 valves have existing wiring identical to that depicted in Figure 2 for a non- .
locking valve. These valves have been determined in Calculation EC-VALV'-1043 to be locking valves. Therefore, the circuitry could have been wired identical to
.. that depicted in Figure 2 for a locking valve., This means that the 42F.contact located near the torque switch may be eliminated. This will provide a spare conduc'tor that can be used to relocate the Torque/Limit Switches in a to that depicted in Figure 4.
manner.'dentical Rewiring of Existing Interposing Relays:
3 valves require that the existing 42F contact remain in the circuit because it functions as a seal-in around a spring return hand switch. These 3 valves, however, have existing interposing relays. By rewiring these interposing relays in a manner identical to that depicted in Figure 3; the changes necessary to mitigate the e6ects of the MOV hot short can be accomplished without adding any additional cables.
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Remaining 3 valves:.
HV-251-F004A, RHR Suppression Pool Suction Valve: For this valve, the 42F coritact in series with the torque switch'also function as a seal-in around the hand-switch. The hand-switch is a maintain contact switch that would not require a seal
-in to assure complete stroking of the valve. With the contact in'its current configuration, it will prevent the valve from being reversed prior to completing a full stroke. All of the F004 valves on Unit 2 are wired in this manner, while all of the valves on Unit 1 are wired without this feature.
HV-.151-F047B and HV-251-F047A, RHR Hx. Inlet Valves, are wired similarly to the F004A valve described above.
For all of these valves, the non-reversible feature is not required. This has been determined by a review of the GE E11 and A4l drawings. Therefore, these'valves may also eliminate the 42F contact in series with the torque switch and may.be rewired to relocate the torque and limit switches as depicted in Figure 4.
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II TABLE 1" UNIT 1 MOTOR OPERATED VALVES
.VALVENO. .-SYSTEM ';DISPOSITION -
~ '>>,DISPOSITION BASIS HV-143-F023B RX RECIRC Damage to Valve due to See discussion in section 6.2.6,of Hot Shorts must be Appendix C prevented.
HV-144-F004 RWCU Operator Action An Operator Action to open breaker Required 1Y219-18 has been included on Drawing E490 and is 'contained in Off Normal Procedure ON-100-009.'his action will close valve HV-144-F033. See discussion in section 6.2.7 of Appendix C.
HV-01222B ESW Damage to Valve due to See discussion in section 6.2.4 of
'ee Hot Shorts must be Appendix C prevented.
HV-01224 B1 ESW. Damage to Valve due to discussion in section 6.2.4 of Hot Shorts must be Appendix C prevented.
HV-15766 SUPP. POOL Operator Action An Operator Action to close the 157025, DRAIN Required valve is required. See discussion in section 6.2.5 of Appendix C.
HV-15768 SUPP. POOL Operator Action An Operator Action to close the 157025 DRAIN Required valve is required. See discussion in section 6.2.5 of Appendix C.
HV-149-F007, 'RCIC No impact to Shutdown See discussion in section 6.2.2 of Appendix C, HV-149-.F008 RCIC No Impact to Shutdown See discussion in section 6.2.2 of Appendix C
'V-149-F010, RCIC No Impact to Shutdown See discussion in section 6.2.2 of Appendix C, HV-149-F012 RCIC No Impact to Shutdown See discussion in section 6.2.2 of Appendix C HV-149-F013 RCIC No Impact to Shutdown See discussion in section 6.2.2 of
\ Appendix C'ee F V-1 49-F019 RCIC No Impact to Shutdown discussion in section 6.2.2 of Appendix C HV-149-F022 RCIC No Impact to Shutdown See discussion in section 6:2.2 of Appendix C HV-1 49-F031 RCIC No Impact to Shutdown See discussion in section 6.2.2 of Appendix C EC-013-0859 Page g~
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VALVENO 'YSTEM ;: DISPOSITION '. ".DISPOSITION BASIS HV-150-F045 RCIC No Impact to Shutdown See discussiqn in section 6.2.2 of Appendix C HV-150-F046 RCIC No Impact to Shutdown See discussion in section 6.2.2 of Appendix C HV-149-F059 RCIC, No Impact to Shutdown, See discussion in section 6.2.2 of Appendix', C HV-149-F060 RCIC No Impact to Shutdown See discussion in section 6.2.2 of Appendix C HV-149-F062 RCIC No Impact to Shutdown See discussion in section 6.2.2 of App'endix C HV-149-F084 RCIC No Impact to Shutdown See discussion in section 6.2.2 of Appendix C i HV-15012 RCIC No Impact to Shutdown See discussion in section'6.2.2 of Appendix C HV-11210B "RHRSW 'Damage to Valve due to See discussion in section 6.2.4 of Hot Shorts must be . Appendix C prevented.
'V-11215B RHRSW Damage to Valve due to See discussion in section 6.2.4 of Hot Shorts must be Appendix C prevented.
HV-151-F003B RHR Damage to Valve due to See discussion in section,6.2.3.6 of Hot Shorts must be Appendix C.
prevented to preserve the RHR flow path.
HV-1 51-F004B RHR Damage to Valve due to See discussion in s'ection 6.2.3.6 of Hot Shorts must be Appendix C.
prevented to preserve the RHR flow path.
HV-151-F006A RHR No Impact to Shutdown See discussion in section 6.2.3.2 of Appendix C HV-151-F006C RHR No Impact to,Shutdown See discussion in section 6.2.3.2 of Appendix C HV-151-F006B RHR No Impact to Shutdown See discussion in section 6.2.3.2 of Appendix C HV-151-F006 D RHR No Impact to Shutdown See discussion in section 6.2.3.2 of Appendix C HV-151-F007B RHR No Impact to Shutdown See discussion in section 6.2.3.4 of Appendix C HV-151-F008 RHR No Impact to Shutdown See discussion in section 6.2.3.1 of Appendix C HV-151-F009 RHR No Impact to Shutdown See discussion in section 6.2.3.1 of
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VAI.VENO SYSTEM DISPOSlTION ';DISPOSITION BASIS HV-151-F015B RHR Damage to Valve due to See discussion in section 6.2.3.6 of Hot Shorts must be Appendix C.
prevented to preserve the RHR flow path.
HV-151-F016 B RHR Damage to Valve due to A modification to prevent damage to this Hot Shorts must be valve is required. See discussion in prevented to preserve section 6.2.3.5 of Appendix C.
the RHR flow,path.
HV-151-F017 B RHR Damage to Valve due to See discussion in section 6.2.3.6 of Hot Shorts must be Appendix C.
prevented to preserve the RHR flow path.
HV-151-F024 B RHR No Impact to Shutdown See discussion in section 6.2.3.3 of Appendix C HV-151-F028B RHR No Impact to Shutdown See discussion in section 6.2.3.3 of Appendix C HV-151-F047B RHR Damage to Valve due to See discussion in section 6.2.3.6 of Hot Shorts must be Appendix C.
prevented to preserve the RHR flow path.
HV-151-F048B RHR Damage to Valve due to See discussion in section 6.2.3.6 of Hot Shorts must be Appendix C.
prevented to prevent bypassing the RHR Hx.
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TABLE 2 UNIT 2 MOTOR OPERATED VALVES VALVENO. :-SYSTEM .DISPOSITION . '.DISPOSITION BASIS HV-243-F023A RX RECIRC to Valve due to
'amage See discussion in section 6.2.6 of Hot Shorts must be Appendix C prevented.
HV-243-F023B RX RECIRC Damage to Valve due to See discussion in section 6.2.6 of Hot Shorts must be Appendix C prevented.
HV-244-F001 RWCU Operator Action An Operator Action to open breaker Required 2Y219-18 has been included on Drawing E-690 and is contained in Off Normal Procedure ON-'200-009. This action will close valve HV-244-F033. See discussion in section 6.2.7.of Appendix C.
HV-01222A ESW Damage to Valve due to See discussion in section 6.2.4 of Hot Shorts must be Appendix C
. prevented.
HV-01224A1 ESW Damage to Valve due to See discussion in section 6.2.4 of Hot Shorts must be Appendix C prevented.
HV-25766 SUPP. POOL Operator Action An Operator Action to close the 257025 DRAIN Required valve is required. See discussion in section 6.2.5 of Appendix C.
HV-25768 SUPP. POOL Operator Action An Operator Action to close the 257025 DRAIN Required valve is required. See discussion in section 6.2.5 of Appendix C:
HV-249-F007 RCIC No Impact to Shutdown See discussion in section 6.2.2 of Appendix C HV-249-F008 RCIC No Impact to Shutdown See discussion in section 6.2.2 of Appendix C HV-249-F010 RCIC No Impact to Shutdown See discussion in section 6.2.2 of Appendix C FV-249-F012 RCIC No Impact to Shutdown See discussion in section 6.2.2 of Appendix C HV-249-F013 RCIC No Impact to Shutdown See discussion in section 6.2.2 of Appendix C HV-249-F019 RCIC No Impact to Shutdown, See discussfon in section 6.2.2 of Appendix C HV-249-F022 RCIC No Impact to Shutdown See discussion in section 6.2.2 of Appendix C HV-249-F031 RCIC No Impact to Shutdown See discussion in section 6.2.2 of r
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VALVENO '"'YSTEM '.;:.DISPOSITION ':: DISPOSITION BASIS C 'ppendix HV-250-F045 RCIC No Impact to Shutdown See discussion in section 6.2.2 of Appendix C HV-250-F046 RCIC No Impact to Shutdown See discussion in section 6.2.2 of Appendix C HV-249-F059 RCIC No Impact to Shutdown See discussion in section 6.2.2 of Appendix C HV-249-F060 RCIC No Impact to. Shutdown See discussion in section 6.2.2 of Appendix C HV-249-F062 RCIC No Impact to Shutdown See discussion in section 6.2.2 of Appendix C HV-249-F084 RCIC No Impact to Shutdown See discussion in section 6.2.2 of Appendix C HV-25012 RCIC No Impact to Shutdown See discussion in section 6.2.2 of Appendix C HV-2121 0A RHRSW Damage to Valve due to See discussion in section 6.2.4 of Hot Shorts must be Appendix C prevented.
HV-21215A RHRSW Damage to Valve due to See discussion in section 6.2.4 of Hot Shorts must be Appendix C prevented.
HV-251-F003A ~
RHR Damage to Valve due to See discussion in section 6.2.3.6 of Hot Shorts must be Appendix C.
prevented to preserve the RHR flow path.
HV-251-F004A RHR Damage to Valve due to See discussion in section 6.2.3S of Hot Shorts must be Appendix C.
prevented to preserve the RHR flow Path.
HV-251-F006A RHR No Impact to Shutdown See discussion in section 6.2.3.2 of Appendix C HV-251-F006C RHR No Impact to Shutdown See discussion in section 6.2.3.2 of Appendix C HV-251-F006B RHR No Impact to Shutdown See discussion in section 6.2.3.2 of Appendix C HV-251-F006D RHR No Impact to Shutdown See discussion in section 6.2.3.2 of Appendix C HV-251-F007A RHR No Impact to Shutdown See discussion in section 6.2.3.4 of Appendix C HV-251-F008 RHR , No Impact to Shutdown See discussion in section 6.2.3.1 of Appendix C
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- ~VALVENO. SYSTEM .: .:; '," "'DISPOSITION;::.::..'DISPOSITIOM BASIS C 'ppendix HV-251-F015A RHR Damage to Valve due to See discussion in section 6.2.3.6 of Hot Shorts must be Appendix C.
prevented to'preserve the RHR flow path.'amage HV-251-F016A RHR to Valve due to A modification to prevent damage to this Hot Shorts must be valve is required. See discussion in prevented to preserve section 6.2.3.5 of Appendix C.
the RHR flow path.
RHR , Damage to Valve due to See discussion in section 6.2.6 of Hot Shorts must be Appendix C.
HV-251-F017A'V-251-F024A prevented to preserve the RHR flow path.
RHR No Impact to Shutdown See discussion in section 6.2.3.3 of .
Appendix C HV-251-F028A RHR No Impact to Shutdown See discussion in section 6.2.3.3 of Appendix C
'HR HV-251-F047A , Damage to Valve due to See discussion in section 6.2.3.6 of Hot Shoits must be Appendix C.
prevented to preserve the RHR flow path.
HV-251-F048A "
RHR Damage to Valve due to See discussion in section 6.2.3.6 of Hot Shorts must be Appendix C.
prevented to prevent bypassing the RHR Hx.
EC-013-0859 Page/~~'
0 Table 3- Appendix R- MOV Hot Short Valves v
Relays exist -. ;, Re'qiitre ' Ma'niial,
'MOV No. in thc Motor Coridiicto'rs'in Device Systcm- Schcmatic-Drawing Center'pare-:"
Control the existing
. Addition of Interposing Opc'ratIon of Valve, Using Field Cable to Relays Haiidwhcxcl
, ', Device'....,,. .: =Possible...:
HV-EI I-IF003 B HV-151-F003B U-I RHR E-153 SH. 11 X HV-El I-IF004B HV-151-F004B U-I RHR E-153 SH. 10 X HV-EI 1-1 F015B HV-'151-F015B .
U-'I RHR E-153 SH. 16 X HV-Ei I-IF016 B HV-151-F016B U-I RHR E-153 SH. 114 HV-El I-IF017B HV-El I-IF047B HV-El'I-IF048B HV-151-F017B HV-151-F047B HV-151-F048B
'-I U-I,RHR RHR U-I RHR E-'153 SH. 14 E-153 SH. 107 E-153 SH. 9 X
-X X
HV-I1210B HV-11210B U-I RHRSW E-150 SH. 11
'V-11215B HV-11215B U-I RHRSW E-150 SH. 12- X HV-B31-IF023B HV-143-F023B U-I RX RECIRC E-151 SH. 8 X N/A HV-01222B HV41222B ESW E-150 SH. 4 X
'HV-01224B I HV-01224B I ESW E-150 SH. 8 X HV-El I-2F003A HV-251-F003 A U-2 RHR E-153 SH. 56 X HV-E I I-2F004A HV-251-F004A U-2 RHR E-153 SH. 55 X HV-ElI-2F015A HV-251-F015A U-2 RHR E-153 SHv 61 X
=
EC-013-OS59 Page /~'y" ra
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Relays exist Spare . Require Manual Device MOV No. System Schematic in the Motor Conductors in Additioti of Operation of Draiving Control the existing Interposing Valve Using Center Field Cable to Relays Handwheel Dcvicc'- . Possible HV-El 1-2F016A U-2 RHR E-153 SH. 100 X HV-251-F01'V-251-F017A HV-E1 1-2F017A U-2 RHR E-153 SH. 59 HV-E11-2F047A HV-251-F047A U-2 RHR E-153 SH. 108 X HV-E I 1-2F048A HV-251-F048A U-2 RHR E-153 SH. 54 X HV-21210A HV-21210A U-2 RHRSW E-150 SH. 23 HV-21215A HV-21215A U-2 RHRSW E-150 SH. 22 X HV-B31-2F023A HV-243-F023A U-2 RX RECIRC E-151 SH. 24 X N/A HV-01222A HV41222A ESW E-150 SH. 32 HV-01224A1 HV41224A1 ESW E-150 SH. 33 X
'n "X'n this column means that a spare conductor exists in the valve electric circuitry. A "Y" in this column means that the valve circuitry is wired for, a non-locking operator when, in fact, the operator is locking. Therefore, a spare contact exists in the circuitry that may be eliminated. This will free up a conductor for use in relocating the Torque/Limit Switches. A "Z" means the non-reversible feature on this valve can be removed.
EC-013-0859 Page/+70
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TABLE 4 RECOMMENDED SOLUTION FOR RE UIRED VALVES
'Device MOV No. System Schematic Possible Disposition Drawing HV-E I I-IF003B HV-151-F003B U-1 RHR E-153 SH. 11 Relocate Tor ue/Limit Switches HV-EII-IF004B HV-151-F004B U-1 RHR E-153 SH. 10 Relocate Tor ue/Limit Ssvitches HV-E11-IF015B HV-151-F015B U-I RHR E-153 SH. 16 Rewire Exist. Inte sin Relays HV-EI 1-1 F016B HV-151-F016B U-1 RHR E-153 SH. 114 Relocate Tor ue/Limit Switches HV-EI I-IF017B HV-151-F017B U-I'RHR .E-153 SH. 14 Relocate Tor ue/Limit Switches HV-EI 1-1 F047B HV-151-F047B U-1 RHR E-153 SH. 107 Relocate Tor ue/Limit Switches HV-E11-1F048B HV-151-F04 8B U-I RHR E-153 SH..9 Relocate Tor ue/Limit Switches HV-11210B HV-11210B U-I RHRSW E-150 SH. 11 Relocate Tor ue/Limit Switches HV-11215B HV-11215B U-1 RHRSW E-150 SH. 12 Relocate Tor ue/Limit Switches HV-B31-IF023B HV-143-F023B U-I RX RECIRC E-'151 SH. 8 Relocate Tor ue/Limit Switches 0
HV41222B HV-01222B ESW E-150 SH. 4 Relocate Tor ue/Limit Switches HV41224B I HVA1224B I ESW E-150 SH. 8 Relocate Tor ue/Limit Switches HV-E11-2F003A HV-251-F003 A U-2 RHR E-153 SH. 56 Relocate Tor ue/Limit Switches HV-El 1-2F004A HV-251-F004A U-2 RHR E-153 SH. 55 Relocate Tor uc/Limit Switches HV-EI I-2F015A HV-251-F015A U-2 RHR E-153 SH. Rewire Exist. Inte osin Relays HV-151-F016A Relocate Tor uc/Limit Switches 61'-153 HV-E11-2F016A U-2 RHR SH. 100 HV-E 1 I-2F017A ~ HV-251-F017A U-2 RHR E-153 SH. 59 Relocate Tor ue/Limit Switches HV-E1 1-2F047A HV-251-F047A U-2 RHR E-153 SH. 108 Relocate Tor ue/Limit Switches HV-E11-2F048A HV-251-F048A U-2 RHR E-153 SH. 54 Relocate Tor ue/Limit Switches HV-21210A "
HV-21210A U-2 RHRSW E-150 SH. 23 Relocate Tor ue/Limit Switches HV-21215A HV-21215 A U-2 RHRSW E-150 SH. 22 Relocate Tor ue/Limit Switches HV-B31-2F023A HV-243-F023A U-2 RX RECIRC E-151 SH. 24 Relocate Tor ue/Limit Switches HV41222A HV-01222A ESW E-150 SH. 32 Relocate Tor uc/Limit Switches HVA1224AI HVA1224AI ESW E-150 SH. 33 Rewire Exist. Inte osin Relavs The recommended disposition is to install i'nterposing relays. The disposition provided below is provided as an option should insufficient space bc available to install thc relays. Ifthis disposition is used,
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an Appendix R review must be performed as a part of the modification package preparation to assure that
, thc change does not create a new Appendix R non-compliance in an area outside of the main Control Room.
EC-013-0859 Page/M7/
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49 40 L.C. C) L.C.
19 MN: COND.
LRW.
12 23 22 TO FPC 20 6A IA 160A I 60B KEEP FILL. pA 5pB 2IB 6 P
RPV 28A- 7A 5A ISB 17B +4 28B COND ECIR XFR FROM 48 ORIF IC B FPC 17 VAL
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SAMPLE LO 67 53A . 671 '; +%
24 24 i 53B A =,C- D B ULL 'FLPII TEST 34A, 3 IA 3IB j 34B 34B
. LO B LO 7A 7B O TO TO + 6A 6B +% LIJ RCIC RCIC 34C 31C 310 34O CONDENSATE RHR I I I- CONDENSATE D
DEACTIVATED
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- VALVE ISOLATEO FLO&'ATH RHR ALTERNATE SHUTOONV COOLING '8<~ 277~
FROM C.R.' UNI'T Pl VALVE ISOLATEO FROM C.R.
b CAN BE OPERATEO AT R.S.P.
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LRW 12 23 22 TO, FPC 20 6A IA I 60A 160B KEEP FILL PA 50B 218 6 KEEP ILL RPV 8A 44 7A 5 158 178 88 COND ECIR XFR FROM 48 ORIFIC A FPC 17 VAL LO 67 Q.
X M
671' 53B A C B ULL FLOW TEST 34A .3 I A o tt 3IB, 34B 34B LO
'A 7B LO I- o I- TO TO .
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%% 6A 6B 4 4J RCIC RCIC 34C 31C O 310 . 34O CONDENSATE RHR I- I I I- ~ CONDENSATE z;
DEACTIVATED o O ~+ DEACTIVATED LO C 0 LO
- REQUIRED VALVES CAN BE OPERATEO AT R.S.P.- F2GURE /B
- VALVE ISOLATEO FLOP PATH RHR ALTERNATE SHUTDOWN'N COOLIN6.
FROM C.R. I UNIT f2
- VALVE ISOLATEO FROM C.R.
8 CAN BE OPERATEO AT R.S.P.
RHRU2, ,FLWPATH,SHD,CLG,P
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S Transfer Switch at Remote Shutdown Panel HS-CR - Control Room Control Switch page /+7/ HS-RSP - Remote Shutdown Panel Control Switch Note: Scheme shown for manual control. at Remote Shutdown Panel 49 95 49 95 Thermal Thermal Thermal Thermal Overhad Overload Overload Overhad Bypass Bypass TS ZS TS ZS ZS Open on ZS Open when Open on Open when Open when HIGH Open when Valve is HIGH Valve is Valve is Closing Valve is 100% Closing 100% 100% Torque 100%
CLOSED Torque OPEN cLosED 42F OPEN HSS HSS HSS HSS HSS HSS HSS HSS HS-RSP i HS-CR LHS-CR HS-RSP HS-RSP.*: HS-CR LHS-CR HS-RSP Close i Close Open Open Close :':
Close Open i Open-Control Room Control Room HSS HSS HSS HSS HSS HSS HSS HSS 42R 42F 42R 42F 42F 42R 42F 42R
~CLOSE OPEN~ ~CLOSE OPEN~
Valve Operator Valve Operator With Fi ure2 Without Locking Worm Gear Locking Worm Gear
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HSS HSS HSS HSS LHS-RSP i HS-CR HS-CR Hs-RsP Close i Close Open l Open Control Room 42FX 42RX
. HSS HSS HSS HSS Interposing 42R 42F Relays 42FX 42RX 42F 42R CLOSE OPEN CLOSE OPEN~
Valve Operator With Locking Worm Gear Fi ure3
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EC-01" 9 page ~ Note: Valve Operator with Locking Worm G own Valve Operator without Locking Worm Gear I milar 49 95 Thermal Thermal Overhad Overload Bypass I
I I HS-RSP' HS-CR HS-CR S-RSP I
I Close l Close l Open Open I Control Room I
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42R 42F 42F 42R
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Valve Operator With Locking Worm Gear Fi ure4
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