ML19345B158

Forwards Requests for Addl Info for Review of Alternate Shutdown Capability & Auxiliary Feedwater Initiation in Safety Analyses.Proposed Mods Should Be Submitted Prior to Installation.Response for Unit 1 Requested in 30 Days

ML19345B158
Person / Time
Site:	Farley
Issue date:	11/05/1980
From:	Tedesco R Office of Nuclear Reactor Regulation
To:	Clayton F ALABAMA POWER CO.
References
NUDOCS 8011260239
Download: ML19345B158 (17)

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'os UNITED STATES -

I\\ m 'j NUCLEAR REGULATORY COMMISSION

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. WASHINGTON, O. C.20555 o r hy %*... /g j

November 5, 1980 Docket Nos. 50-348 and 50-364

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Mr. F. L. Clayton, Jr.

Senior Vice President

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SUBJECT:

REQUEST FOR ADDITICNAL INFORMATION FOR JOSEPH M. FARLEY NUCLEAR PLANT.

UNITS.1 AND 2 i

As a result of our continuing review of safety analyses for the Joseph M. Farley Nuclear Plant, we have developed the enclosed requests for additional information and positions.

i j is our position and request for additional information for alternate shutdown capability for three of Farley nuclear plant fire areas: the control room, cable spreading room and alternate shutdown panel rcom.

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! is cur position and request for additional information for auxiliary i

feedwater initiation. Ycur commitment to make acceptable modifications should be submitted. prior to November 14, 1980. Modifications other than those shown in i may be equally acceptable.

Droposals for modifications related to Enclosures 1 and 2 should be submitted in time for our evaluation prior to installation.

Installation of auxiliary feedwater initiation modifications in-Unit 1 are governed by the NUREG-0660 implementation schedules.

Installation of auxiliary feedwater initiation modifi-cations in Unit 2 should be made no later than ccmpletion of the first refueling outage. Fire; protection system modifications for Unit 1 should be made per the implementation schedule of revised 10 CFR 50.48. Fire protection system modifi-1 cations for Unit 2 should be completed prior to full power operation.

.1 Please provide'the information requested in the enclosures. Our review schedule for Unit 2 is based on the assumption that the additional information will be

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available for our raview by November 14, 1980. Our review schedule for Unit 1 is

-based on the assumotion that the additional information will be available for our 4

review within 30 days of receipt of this letter. However, when the Unit 1 and 2 l

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F. L. Clayton system designs are identical, you shculd provide the information requestea for Unit I simultaneously with the Unit 2 information.

If you cannot meet these dates, please inform us within seven days after receipt of this letter so that we may revise cur scheduling.

Sincerely, E

CC Robert L. Tedesco, Assistant Director for Licensing Division of Licensing

Enclosures:

1.

CEB Request for Additional Information 2.

Recuest flo.13 Re Auxiliary Feedwater Initiation cc w/ enclosure:

See next page f

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1 Mr. F. L. Clayton, Jr.

Alabama Power Company cc:

Mr. W. O. Whitt Executive Vice President Alabama Power Company Post Office Box 2641 Birmingham, Alabama 35291 Ruble A. Thomas, Vice President Southern Company Servicas, Inc.

Post Office Box 2625 Birmingham, Alabama 35202 George F. Trowbridge, Esquire Shaw, Pittman, Potts and Trowbridge 1800 M Street, N.W.

Washington, D. C.

20036 Mr. Robert A. Buettner, Esquire Balch, Bingham, Baker, Hawthorne, Williams and Ward Post Office Box 306 Birmingham, Alabama 35201 George S. Houston Memorial Library 212 W. Burdeshaw Street Dothan, Alabama 36303 Resident Inspector U. S. Nuclear Regulatory Commission Post Office Box 1814 Dothan, Alabama 36302 i

ENCLOSURE 1 CEB REQUEST FOR ADDITIONAL INFORMATION JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 i

DOCKET NOS. 50-348 AND 50-364 Requests from the following branch in NRC are included in this enclosure.

Requests and' pages are numbered sequentially with respect to requests transmitted following issuance of SER Supplement No. 3.

'1 Branch Page No.

Chemical Engineering Branch 280-1 thru 280-7 i

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l 280.0 Chemical Engineering Branch L

280.1 Position and request for additional infonnation for fire protection supplemental safety evaluation by Power Systems Branch.

L Introduction o

In accordance with section 9.5.1. Appendix A, position 0.1.(C) of NRC l

p Standard Review Plan, it is the staff's position that cabling for redundant 3

safety divisions should be separated by walls having a three haur fire rating.

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That is cabling associated with the primary method of shutdown, for each of the y

a nuclear plant's fire areas, should be pnysically separated by the equivalent 9

of a three-hour rated fire barrier from cabling associated with the redundant L."

method of snutdown.

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The staff concluded, as documented in the Farley fire protection Safety

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j Evaluation Report, transmitted by memorandum from S. H. Hanauer to D. 3. Vassallo i t.

f4 dated February 12, 1979, that cabling located in a ramoer of fire areas (the

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cable spreading room, the control room, and a number of cable chase rooms li containing redundant cables) do not meet the staff's, position. Thus, a single l

design basis fire in any of these areas may prevent safe shutdown.

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to assure a method of shutdown, the staff required a remote or alternate method of shutdown for each of these fire areas.

Ik4 NN The licensee was requested by letter dated April 13, 1979 to provide for our I

approval a summary of the alternate shutdown methods including present design, t??

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280-2 electrical modifications, and procedural steps, required to bring the plant to safe shutdown in the event of a fire. As a result of our request, the licensee provided (by letter dated December 26, 1979) drawings and change notices of final design modifications to allow cold shutdown without reliance on the cable spreading room or the control room.

Evaluation i

The drawings and change notice information provided by the licensee in response j

to our request for a summary of the alternate shutdown methods contains i

detailed wiring change instructions that are being implemented at Farley Unit 1.

l The information provided is too detailed and does not include the summary e

information requested.

The licensee was informed as to this finding and was requested informally to provide the following information for each of the subject areas requiring an alternate shutdown method.

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F 1.

A table listing of electrical and mechanical equipment including k

h instrumentation that are associated with the primary.ethod of achieving e

9 and maintaining ho shutdown.

1 2.

A table listing of electrical and mechanical equipment including instru-mentation that are associated with the alternate or remote method of l'i achieving and maintaining hot shutdown. This listing must include both

.I active and passive equipment whose failure could affect the capability of 1

achieving or maintaining hot shutdown.

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' l 280-3 V

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A table listing of redundant equipment listed in items 1 and 2 above I.

n-with associated essential cables (instrumentation, control and power)

[$'i separated by the required three hour fire rated barrier.

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A table listing of alternate or remote equipment listed in item 2 above with essential cables (instrumentation, control and power) that j

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are located in the subject fire area and separated by less than the required three-hour fire rated barrier from thei redunefant counterparts.

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Detailed electrical schematic drawings that show the essential 7

• t cables to be duplicated elsewhere and electrically isolated from he subject fire areas,

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The results of an analysis that demonstrates that failure (open,

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ground, or hot short) of the subjer : cabling will not affect the h

capability to achieve and maintain hot shutdown when using the j

I alternate or remote shutdown method, or y

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Justify non-compliance with the subject staff position.

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.4 As a result of this request, the licensee provided additional information, b

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informally, at the August 19, 1980 and September 18, 1980 meetings in Beth.sda t

and by letters dated September 12, 22, and 30,1980.

.nc additional infor-Fj 4

mation consisted of (1) a description of now instruments required for the alternate method of shutdown are isolated from the control room instruments, di (2) a description (including detailed electrical schematic drawings) that f

shows the isolation of alternate snutdown cabling from the control room and r.4 93 Q

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I cable spreading room, and (3) a statement to the effect that no redundant cabling necessary for hot or cold shutdown are located in a single chase.

i The following is our evaluation based on the information provided.

r l-l (1 ) Instrumentation I.

Instrumentation identified by the licensee and operabie from the alternate

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shutdown panel included steam line pressure, pressuri:er level, pressurizer j

I, pressure, steam generator wide range 'aater level, and one of four reactor li coolant system hat leg temperature instruments.

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In regard to steamline pressure, pressurizer level, and pressurizer

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1 pressure instruments, the licensee stated that the instrument loops

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(initially routed through the control room to tne hot shutdown panel) ii have been replaced by dedicated instrument loops.

Cabling associated h

ith the subject instruments on the hot snutdov' 'anel are electrically

. ependent and separated by the required three-hour fire barrier from j

redundant instruments located in the control room. This meets our j

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i position for alternate shutdown and is accepta51e for the control room, I

cable spreading room, and alternate shutdown panel room.

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For the remaining instruments, the licensee stated that the instrument j

loops (initial'y routed through the control room to the hot shutdown

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panel) have been rerouted to the hot shutdown panel first and then an

e 1i electrically isolated output signal from the hot shutedwn panel is provided for control rocm indication. This meets our position for t!i!

an alternate sh"*dewn capab'ility for the control room or cable spreading lt (ij room. However, at s..e hot shutdown parel our positicn, that redundant i

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280-5 safety divisions be separated by walls having a three hour fire rating, l

has not been meet. That is a single design basis fire at the hot shutdown panel may cause both cont-A room and hot shutdown panel indications to i

be lost. For this item, the licensee stated that additional redundant and electrically independent instruments are available in the control The additional inr,truments include narrow range steam generator room.

i level and three reactar coolant system hot leg temperature instruments.

i These addition;i ',struments are physically separated by -he required three-hour barrier from the het.hutdown panel room. This meets our b

position for alternate shutdown and is acceptable for the control room, cable spreading rcom, and the hot shutdown panel room.

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The, Reactor Systems 3 ranch has indicated the possible need for two versus i

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one hot leg temperature instruments. The licensee was informed as to the p

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possible need of two hot leg instruments.

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(2) 3' ectr 3altsolation of Alternate Shutdown Ecuioment

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in response to our request for detailed electrical schematic drawings k b ka shcwing electrical isolathn of all alternate shutdcwn equi: ment, the F

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1,i licensee provided drawings for the folicwing equi;

ment: Charging pumps

[ di Ic and Ib, component cooling water pumps lA and 18, motor driven Aux.

Ndik feed puma IB, emergency pressuri::er heater back-up group 13, and boric acid transfer pump 13.

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280-6 I

For each of the above listed equipment, the instrumentation and control

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power source for both primary and alternate methods of shutdown is f

designed to be provided through a single fuse or circuit breaker.

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a single failure of a cable located in the control room or cable spreading room may cause loss of this power source and failure of both primary and alternate methods of shutdown.

In order to reestablish the power source e

and maintain hot shutdown frors the remote or alternate shutdown panel,

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the plant operator must perform a number of manual operations in various ic rooms of the plant. These manual operations include throwing of a transfer switch in Room 202, resetting a breaker or replacing of a fuse in a switchgear room, and closing of a pump start or stop switch at the remote shutdown panel.

The susceptibility of this design to single fa,ilure and the consequent manual operations needed to reestablish power oa r'

does not meet review guidelines defined in Section 7.4, Part III (; age 7.4-6 h:.i Li and 7) of MRC Standard Review Plan. The licensee was informed that it 1:

Nl my our position that each of the above listed equipment must be designed such as to prevent a single failure in the main control room or the cable

!5 spreading room from defeating the capability for affecting safe shutdown j

from the remote control station and vise versa. As a result the licensee V

indicated that the existing design would be changed to provide redundant k

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power sources that will meet our single failure position. Pending

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documentation of the changed design and inf0rmation, we find this N

acceptable.

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280-7 In addition to the above listed equipment, other equipment, such as valves are subject to spurious operation or failure due to a control l

t or cable spreading room design basis fire. To reestablish the operability of valves due to their failure, the plant operator must perform a number of manual operations throughout the plant. For a typical valve these operations include determining the valve's position at the velve, removing power by either lifting a wire or tripping a

notor control center breaker, and opening or closing the valve by using the valve's hand wheel. This design, for remote gperation of valves, does not meet creiew guidelines defined in Section 7.4, part III (page 7.4-6 and 7) of NRC Standard Review plan. The licensee was informed that

'.t is our positian that one remote location be provided for manual control and alignment. operations needed to achieve and maintain the plant at hot shutdowr.

(3) Alternate Shutdown for the Cable Chase Rooms The licensee stated "....that m case exists in either unit 1 or unit 2 wnere redundant trains of cabling recessary for hot or cold shutdown are located in a single chase. Therefore, the loss of one chase could not preclude the plant's capability to achieve hot or cold shutdcwn."

This statement provided in a le:ter dated August 28, 1980 is in disagree-rrent with information provided on page 4-178 of the Farley Nuclear plant Fire protection program Reevaluation. The licensee was informed of this disagreement and our requirement that an alternate shutdown capa-bility be provided for each cable chase ocm located in fire area 13

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that contain redundant safe shutdcwn cables.

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ENCLOSURE 2 REQUEST NO. 13 RE AUXILIARY FEEti,ATER INITIATION JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. 50-348 AND 50-364 Our review of your " Response to the TMI-2 Action Plan" submitted June 20, 1980 has restited in the need for additional information.

Requests and pages are numbe"ed sequentially. The alpha numeric item designations correspond to the items in the TMI-2 Action Plan. The following requests are included in this enciesure.

Request No.

Page No.(s).

13 10 thru 13 I

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'13 Positian and request for additional information on II.E 1.2, Auxiliary Feedwater Initation and Indication.

j A meeting at the Joseph M. Farley Nucleat-Plant with representatives of Alabama Power Co"3ny, Bechtel Corporation, and Westinghouse Electric Corporation was held on October 22, 1980. The purpose of the meeting was to review the actuation logic for the Unit 2 Auxiliary Feessater System va?ves and pumps and other instrumentation and control features i

j related to the operation of the Auxiliary Feedwater System. Based on i

j our review of the control and protection system for the Auxiliary Feedwater System, we conclude that the applicant should address several concerns and implement appropriate modifications to resolve these. Our positions with regard to these concerns are as follows:

1.

The current protection system logic is such that the motor driven I

auxiliary feedwater pump discharge valves are not automatically fully opened following a low icw stean generator level signal, or sign 1 indicating trip of the main feedwater pumps or a blackout sequence signal if the valve operating mode switches are in the modulate position.

(These signals will, however, start the motor driven auxiliary feedwater l

pumps). The low low steam generator level signal is the primary Auxiliary Feedsater System actuation signal for loss of feedwater accidents that do not involve initiation of safety injection.

4 The logic should be modified such that all automatic protective l

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signale shown in Figure 7.2-14 of the Final Safety Analysis Report' will automatically open the motor driven pump discharge valves J

j regardless' of the position of the valve operating mode switches.

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The redundant solenoid valves in the control air lines. to the auxiliary 4

feedwater pump discharge valves are presently arranged to be " energized to close or modulate" the discharge valves and "de energize to open" the discharge valves. When the auxiliary feedwater system is ir. un, Uic loss of a single power supply would,thus, open all of the auxiliary i

feedwater pump discharge valves resulting in full auxiliary feedwater 1

I flow to the steam generators. Manual' control of the discharge valves from the control room would be precluded by the loss of either of the i

power supplies for the redundant solenoid valves. While these failure J

. des cause uniesirable transients resulting in inadvertent plant cooldown transients during normal operations, we find that such failures are un-i acceptable with respect to the safety function of controlling auxiliary feedwater flow following its initiation by the protection-system. The logic and failure modes of the solenoid valves should be modified such that the loss of single pcwer supply will not cause the pump discharge valves to open. Dependence on manual corrective actions which could be taken to limit auxiliary feedwater flow, e.g., closure of block valves, control of turbine driven pump speed, tripping pumps, etc.,

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i are not an acceptable alternative to resolve this concern in the long term.

3 3.

All manual control stations for both the motor and turbine driven pump i

discharge valves ara presently powered from a single train power source.

Loss of this power causes these valves to fail open and results in loss of the capability to modulate auxiliary feedwater flow using any of the pump.s discharge valves. The power distribution should be modified such that the turbine -driven pump discharge valve manual control stations are powered from

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the power source used to derive power for the turbine driven pump steam i

admission valves and related controls.

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Air accumulators are provided for the turbine driven auxiliary feedwater pump steam admission valves since air is requirea for their operation and the normal air supply is from the non-safety grade instrument air system. The Unit I design utilizes a check valve and a solenoid operated valve, which closes by action of a pressure switch on low pressure, to isolate the accumulator from the instrument air system and assure accumulator air availability. The Unit 2 design uses two series check vaives to assure the ay?.iiacility of the accumulator air. There is presently no way to independently verify by testing the operability of each check valve. The advantage of the Unit 1 design, i.e., diversity 1

and the fact that it is easier to verify its operability by testing, l

appears to make it a more reliable system to perform this safety function.

l The system design for this function should be the same for both units.

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Alabama Power Company should provide the design basis for this system.

The design basis should address a rapid and a slow depressurization of the normal air system as well as the method of independently testing i

the redundant means for isolating the accumulators from the normal air supply.

If a check valve is used as part of the isolation function, the concerns contained in IE Bulletin flo. 80-01 related to the check valve seat material should be addressed.

It is our conclusion that the above items should be implemented during the first refueling outage of Unit 2.

The basis for this conclusion is that alternative actions could be taken to recover from the events which are the basis for our ccncerns.

However, with respect to Item 1 above, the administrative controls involving operating procedures should be modified during the interim

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i period. The operating procedure for unit startup should be modified to include the specific individual steps for sligning the auxiliary feedwater l

system valve ~and other controls within the startup procedure with a requirement for sign-off of individual alignment steps. Startup procedure UDP-12 should include sign-off. of actions indicated in Section 4.1.3 of procedure SOP-22.0.

We requested that the flow diagram and brief explanation of operation for

'the safety grade air supply to the turbine driven auxiliary feedwater pump steam admission valves and the steam generator power operated atmospheric f

relief valves be provided.

In a telephone conversation on October 24, 1980, we requested information on.the power sources used for control of the operation of the instrument air system compressors and the power source dependence of the steam generator power operated atmospheric relief valve controls and the controls i

for the condenser steam dump.

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DISTRIBUTION:

Docket Nos: 50-348 and 50-364 T. Dunning NRC PDR G. Harrison Local PDR V. Benaroya LB2 Reading File R. Ferguson DEisenhut R. Anand RPurple R. Satterfield RTedesco A. Ungara TNovak F. Rcsa SVarga EReeves ASchwencer LKintner ORB #1 File KParrish MService I&E (3) bec: NSIC TERA ACRS (16)