ML19353B109

Forwards Response to Request for Addl Info Re Compliance w/10CFR50,App R.Revised Shutdown Methodology Assumes Greater Reactor Coolant Pump Seal Leak Rates & Therefore Necessary to Reprioritize Actions to Restore Charging to RCS

ML19353B109
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	11/30/1989
From:	Cockfield D PORTLAND GENERAL ELECTRIC CO.
To:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
NUDOCS 8912110214
Download: ML19353B109 (14)

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David W. Cockfield Vice President, Nuclear u

Trojan Nuclear Plant Docket 50-344 License NPF-1 Mr. John B. Martin Regional Administrator, Region V U. S. Nuclear Regulatory Commission 1450 Maria Lane, Suite 210 Walnut Creek CA 94596-5368

Dear Mr. Martin:

Portland General Electric Company (PGE)

Responses to the Request for Additional Information To Title 10 to the Code of Federal Regulations, Part 50 (10 CFR 50) Appendix R Audit Items i

The purpose of this letter is to provide PGE's responses to the additional Nuclear Regulatory Commission (NRC) concerns regarding PGE's compliance with 10 CFR 50. Appendix R.

By letter dated April 28, 1989, PGE provided proposed resolutions to the unresolved items identified during the NRC's 10 CFR 50 Appondix R Audit

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which was held on August 22-26, 1988. As a result of NRC's review of the proposed resolutions, additional concerns were identified. The NRC first communicated the concerns to PGE by telephone on September 25 and 26, 1989, and subsequently by letter dated October 24, 1989.

Attachnent A to this letter provides PGE's responses to the six NRC concerns as stated in the October 24, 1989 letter. Attachment B to this

. letter, provides a status summary of additional Appendix R commitments.

Sincerely, (y

Attachments c:

U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington DC Mr. David Stewart-Smith State of Oregon Department of Energy Mr. R. C. Barr j

NRC Resident Inspector I {

Trojan Nuclear Plant f.

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P 121 S.W Salmon SUeet, Fbftland, Oregon 97204

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Trojan Nuclear Plant Mr. John B. Martin i

Docket 50-344.

Attachment A i

License NPF-1 November 30, 1989 Page 1 of 12 RESPONSES TO KUCLEAR REGULATORY COMMISSION (NRC) CONCERNS REGARDING PROPOSED RESOLUTIONS TO TITLE 10 0F THE CODE OF FEDERAL REGULATIONS. PART 50 (10 CFR 50) APPENDIX R AUDIT ITEMS 1.

Engineered Sofety Features Blackout Duration NRC Concern:

"The revised Trojan methodology falls to substantiate a basis for the reduction of a previous self-initiated 40 minute station black-out to a 5 minute self-initiated station blackout. A multiple high impedance f ault analysis was not performed to arrive at this timeline."

PGE Response:

The " blackout" duration in which the Train B 4.16 kV Engineered Safety Features (ESP) Switchgear, A2, will be without power has been reduced from 40 minutes to 5 minutes. Neither the original duration of 40-minutes, nor the revised duration of 5-minutes was predicated on the results, or lack, of a high impedance fault analysis. The 40-minute duration was a somewhat arbitrary time duration based on the original assumptions regarding Power Operated Relief Valve (PORV) spurious operation and Reactor Coolant Pump (RCP) seal leak rates. The revised alternative shutdown methodology assumes greater RCP seal leak rates and therefore it was necessary i

to reprioritize the actions to restore charging to tne reactor i

L coolant system (RCS) and RCP seals, l

The " blackout" duration includes the time between opening the offsite power feeder breaker, A-201, and closing the Emergency Diesel Generator feeder breaker A-208, to switchgear A2 (see Figure 2 for the single line diagram).

This time frame was obtained i

by re-prioritization of manual actions to:

(1) open breakers to l

safe shutdown loads to mitigate spurious operation, (2) open E

breakers to non-safe shutdown loads of concern.('

.g.

pressurizer e

i heaters and reactor coolant pumps) to mitigate spurious operation, (3) manually start the Emergency Diesel Generator (EDG) EDG2B, and j

(4) close the EDG2B power feeder breaker A-208.

In the revised alternative shutdown methodology, the timeline was reevaluated to determine realistic time frames for completing the l

required manual actions. The methodology utilized in the new timeline included a review of the stroke time of valves requiring manual operation and a Plant walkdown to determine the time required l

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Trojan Nuclear Plant Mr. John B. Martin

' Docket 50-344 Attachment A License NPF November 30, 1989 Page 2 of 12 to reach the location of the componont and to complete the manual action. The time frames to complete a sequence of actions for each operator were evaluated to determine if the required time con-straints to complete operator actions were met [e.g., deenergization of the pressurizer PORVs, establishment of EDG cooling, reestablish-ment of RCS makeup, initiation of Auxiliary Feedwater (AFW) flow).

If the required time constraints were not met, the sequence of

'a operator actions was re-prioritized until a feasible sequence and l

time frame was established. This metholodogy provides the basis for l

the five minute " blackout" duration.

Figure 1 provides a visual representation of the revised alternative shutdown timeline. This figure shows the sequence of manual actions completed by each operator during the first 30 minutes after evacuation of the control Each of the bars on Figure 1 represent the approximate time room.

for the individual operator to perform the referenced actions.

The most critical time constraint to meet is reestablishing RCS makeup (approximately 13 minutes based on the RCP seal leakage rate stated in Westinghouse Owner's Group analysis WCAp-10541). A reevaluation of the original manual actions to reestablish RCS makeup, which were the basis for the " blackout" duration of 40 minutes, demonstrated that the required actions could be completed within 13 minutes. By prioritizing the actions to restore power to r

the A2 bus and aligning the charging system, and then incorporating-these actions into the detailed timeline analysis, the " blackout" duration was reduced from 40 to 5 minutes.

Isolation of power to-switchgear A2 for approximately five minutes will not affect safe shutdown. Deonergization of the ESF loads is required to mitigate spurious operation. Offsite power, if available, will power non-ESF 1cada and provide power to lighting buses and other equipment which, although not required for safe shutdown, could facilitate-shutdown actions.

l Although switchgear A2 will be without power for five minutes, the l

remote shutdown panel, C-160, will be available for monitoring required safe shutdown instrumentation, with the exception of the l

RCS temperature and neutron source range flux indicators.

(Refer to Item 6 for further discussion on the time requirements for monitor-ing the RCS temperature and neutron source range flux indicators.)

Panel C-160 instrumentation and control circuits are powered via the plant ESF power distribution system and are, therefore, battery-backed.

Although a multiple high impedance fault analysis has not been performed for the Trojan Nuclear Plant, a caution statement has been

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Trojan Nuclear Plant Mr. John B. Martin Docket 50-344 Attachment A License WPF-1 November 30, 1989 Page 3 of 12 included in the Emergency Fire Procedures (EFP)-0, " Procedure in the Event of a Fire," and EFP-1, " Alternative Shutdown for Evacuation of Control Room Caused by Fire." This caution statement informs the operators that multiple grounds induced by fires may cause the loss of ESF power suppiles, and if multiple faults are suspected, then ESF buses should be stripped and the safe shutdown loads reener-gized.

In addition, PGE is currently performing a Plant-specific multiple high impedance fault analysis which is expected to be completed by January 31, 1990.

2.

Control of offsite Power NRC Concern:

"The revised Trojan methodology forces the plant onto the emergency diesel generators regardless of whether offsite power is available."

PGE Response:

The revised alternative shutdown methodology credits actions to open the offsite power feeder breakers to the 4.16 kV ESF Switchgears, Al and A2.

All other offsite power feeder breakers to non-safe shut-down loads will remain in their normal operating position during the shutdown process with the exception' of the RCPs and the pressurizer heaters. Figure 2 shows the single line diagram for the Trojan L

Nuclear Plant. By opening. feeder breakers A-101 and A-201, spurious L

operation of ESF components will be mitigated.

Breakers H-104, l

H-105, H-204, H-205, A-504 and A-604 are also opened to mitigate l

spurious operation of the RCPs and the pressurizer heaters. The l

offsite power feed is available for all remaining non-safe shutdown l

components. This approach prevents a complete station blackout except in the event that offsite power is lost.

By keeping the non-ESF buses energized, power will be available to lighting buses L

and other equipment, which, although not required for safe shutdown, I

could facilitate shutdown in the event offsite power is available.

The Train A switchgear remains doenergized throughout the shutdown process since Train B is utilized for alternative shutdown.

Con-trolled reenergization of the Train B switchgear is initiated by closure of the EDG2B feeder breaker, A-208, subsequent to a manual start of the diesel.

By utilizing the methodology to shut down via the Train B EDG, the shutdown process can be performed without interruption by a fire-induced loss of offsite power.

In the event the shutdown process were to be initiated via the offsite power feed to the Train B switchgear, a loss of offsite power could complicate

1 l

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Trojan Nuclear Plant Mr. John B. Martin j

Docket 50-344 Attachment A

]

License NPF-1 November 30, 1989 Page 4 of 12 the alternative shutdown procedures by having to re-initiate the EFPs at a potential critical point in the operation of safe shutdown equipment.

In the event the Train B EDG fails to start, the offsite power feeder breaker to switchgear A2, A-201, will be reclosed to utilize offsite power if it is available. This contingency action will be added to the Emergency Fire Procedure (EFP)-1, " Alternative Shutdown for Evacuation of Control Room Caused by Fire," by December 31, 1989.

3.

Pressurizer Power-Operated Relief Valves and Block Valves L

NRC Concern:

l L

"The revised Trojan methodology appears to make inappropriate assumptions regarding fire effects and failure modes of PORVs and PORV block valves."

PCE Response:

The pressurizer power-operated relief valve (PORV), PCV-456, is pro-L vided with a double-pole switch configuration in the valve's main control switch to enable an operator to manually deenergize the valve. This switch, when manually actuated, prevents spurious opening of the valvo by a single hot short. Two proper polarity shorts are required to spuriously open the valve subsequent to actuation of this switch.

A design change to pressurizer PORV, PCV-455A, to incorporate the double-pole switch configuration in l

l this valve's main control switch, will be completed by the end of the 1990 refueling outage.

The most limiting fire scenario with regard to the effects of a

spurious PORV operation, is the control room or cable spreading room fire.

In order to minimize these effects, the first step in EFP-0 upon identification of a fire in the control room or cable spreading room, is to close the PORVs and place the control switches in the-pull-to-lock position. This action effectively deenergizes the PORVs from the control room and prevents spurious opening of the aalve by a single hot short.

If this action fails, the block valves are closed as a contingency action. This is the only reliance on the PORV block valves in the revised alternative shutdown method-ology.

If the fire progresses to the point where control room evacuation is required, EFP-1 would be implemented. This procedure verifies that the PORVs are closed and in the pull-to-lock position prior to leaving the control room, and then dispatches the Assistant Control Operator (ACO) to deenergize the PORVs at their associated distribution panels. The action taken to deenergize the PORVs at the distribution panel is a backup action to the double-pole switch operation in the control room and also ensures isolation of the circuit from potential fire-induced faults, thereby further

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Trojan Nuclear Plant Mr. John B. Martin Docket 50-344 Attachment A License NPF-1 November 30, 1989 Page 5 of 12 minimizing the possibility of PORV spurious operation.

Since PORY PCV-455A currently does not have the double-pole control switch, it is the first to be deenergized.

The time from_when the ACO leaves the control room to the time when the breakers for both PORVs are opened, is approximately 3-minutes.

A " smart fire" could damage the circuits for the pressurizer PORVs and cause two proper polarity faults subsequent to the operator action to close the pressurizer PORVs in the control room via the double-pole switch and prior to the operator action to deenergize the PORVs at the DC distribution panel.

It is PGE's position that the probability of this " smart fire" occurring is low and does not warrant additional design considerations. The actions in the control room and the back-up action at the distribution panel will ensure that the pressurizer PORVs will not spuriously open.

4.

High-Low Pressure Interface Boundaries NRC Concern:

"The revised Trojan methodology appears to make inappropriate assumptions regarding fire effects and failure modes of motor operated valves at hi-low pressure interface boundaries."

PGE Response:

At Trojan, the following components are considered high-low pressure l

interface boundaries:

The pressurizer PORVs the reactor vessel l

head vent valves, the Residual Heat Removal (RHR) hot-leg suction l

isolation valves, and-the excess letdown isolation valves (reference Topical Report PGE-1012. Volume II, Trojan Nuclear Plant, Fire L

Protection Plan, Appendix R Review", Table 3-5).

Generic Letter p

86-10 Implementation of Fire Protection Requirements", states that three-phase AC, or two-phase DC proper polarity faults must be L

postulated for'high/ low pressure boundarios even though this type of fault is considered a low probability event.

PGE's position with regard to spurious operation of the PORVs is described in the above response to item 3.

The double-pole switch configuration for PORV PCV-456 limits hot-short spurious operation of the valve to a two-phase proper polarity DC f ault only. The same will be true for PCV-455A af ter installation of a double-pole switch for this valve during the 1990 refueling outage. A procedurally controlled and high priority backup action is taken at the distri-bution panels to ensure the valves are deenergized. This action is taken by the ACO immediately after evacuation of the control room.

By limiting the potential scenarios for PORV spurious operation l

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Trojan Nuclear Plant Mr. John B. Martin Docket 50-344 Attachment A License.NPF-1 November 30, 1989 Page 6 of 12 to the lowest probability events, and by taking additional procedu-rally controlled protective actions, sufficient protection is provided against spurious PORV operation.

In the case of the reactor head vent valves, spurious operation is not a concern as these valves are closed during normal operation with the fuse for each valve's power circuit removed. The RHR l

hot-les suction isolation valves are in series and are closed during normal operation. The breaker for one of the valves is maintained in the open position which prevents spurious operation of the valve and thus prevents a pathway for a loss of reactor coolant.

The letdown isolation valves are closed during normal operation and fall closed on a loss of electrical power.

Spurious operation of these valves is mitigated by opening the appropriate breakers during the implementation of EFP-1.

These breakers would be opened at the same time as those for the PORVs.

Based on the recognized low probability of a two or three phase proper polarity fault sustaining equipment operation, measures taken to prevent the valves from spuriously cperating, and the procedural controls to mitigate spurious operation,- sufficient protective measures have been established to limit the probability of occurrence and the adverse effects of high/ low pressure boundary spurious operation.

5.

Isolate Service Water System NRC. Concern:

"The revised Trojan methodology fails to substantiate a basis for the assumption that support systems for the emergency diesel generators remain unaffected during a cable spreading room or control room fire."

PGE Response:

The revised alternative shutdown methodology includes operator action to trip the EDGs prior to evacuating the Control Room, and manual' actions at local control stations to isolate the service water system control circuits from the effects of a control room or cable spreading room fire.

The local operator actions include decoupling the control circuits for the service water booster pumps, P-148B and P-148D, and opening the breakers and decoupling the control circuits to the service water pumps P-108B and P-108C. These actions are completed by the ACO in the Train B switchgear room immediately after evacuation of

L Trojan Nuclear Plant Mr. John B. Martin Docket 50-344 Attachment A License NPF-1 November 30, 1989 Page 7 of 12 the control room (see Figure 1).

These actions by the ACO isolate the service water control circuitry from the effects of the control i

room or cable spreading room fire, thereby eliminating the potential i

for spurious operation of the service water systems and allowing control of the service water system pumps independent of the control room. Prior to control room evacuation, service water cooling to the EDGs is periodically verified to assure that the EDCs do not spuriously start without service water cooling. Topical Report PGE-1012. Volume I, " Trojan Nuclear Plant, Fire Protection Plan, Program Description", Section 4.3.1.1, describes decouple switch-design and operation. Table 4-1 lists the decouple switches that are available, and Figures 4-1 through 4-3 of this section provide-typical schematic diagrams of circulta utilizing the decouple capability.

A " smart fire" could damage control circuits and cause spurious start of the EDGs in conjunction with damaging circuits causing the loss of control of the service water pumps and service water booster pumps prior to the operator action to isolate the circuits from the control room or cable spreading room fire. The probability of this

" smart fire" occurring is low and does not warrant design changes to the EDG circuitry.~

It is PGE's position that the actions to stop l

the EDGs prior to evacuating the control room and to subsequently l

push the emergency stop button at the local control panel can be completed prior to damage to the EDGs due to a spurious loss of service water cooling.

In addition, operator actions will be l

completed at the Train B switchgear room to isolate the control l

circuits for the service water pump, service water booster pumps, and the EDG.

6.

Power to Process Diagnostic Instrumentation NRC Concern:

l' l

"The revised Trojan methodology fails to provide a basis for the l~

acceptability for a 9 minute loss of process diagnostic instrumen-l tation on the Bailey instrument network."

l L

PGE Response:

The need for source range flux indication is associated with restor-L ation of AFW flow since reestablishment of AFW flow will initiate l

cooldown and cause a potential increase in reactivity. Source range i

flux indication is required when a potential exists for an increase in reactivity. RCS temperature indication is required to verify natural circulation and monitor RCS cooldown. Both of these functions are required subsequent to establishment of APW flow. As

t Trojan Nuclear Plant Mr. John B. Martin Docket 50-344 Attachment A License NPF-1 November 30, 1989 Page 8 of 12 indicated in Figure 1, AFW flow is established approximately 20 minutes into the shutdown scenario which provides sufficient margin to the steam generator dryout time of 30-minutes. Therefore, the unavailability of the source range flux and RCS temperature indicators is acceptable for approximately 10 minutes into the shutdown process'(see. Figure 1).

Both indications are provided at the Remote Shutdown Station on the-Bailey Net-90 syst(ms which is powered from motor control center B24, which relies on onsite or offsite ac power. A decouple switch is available on the Bailey Net-90 system to isolate the Bailey Net-90 circuits from a fire in the control room or cable spreading room.

Decoupling of the Bailey Net-90 system is an immediate action completed by the Shif t Supervisor at the Remote Shutdown Station subsequent to evacuation of the control room. Power is restored to the Bailey Net-90 system-immediately after the EDG feeder breaker, A-208, is closed to Switchgear A2, and the breaker to bus YO6 is closed at motor control center B24.

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Trojen Nuolear Plant Mr. John B. Martin

.Dockett50-344 Attachment A

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{lgQ l November 30, 1989 Page 9 of 12 MANUAL ACTIONS REQUIRED IN THE FIRST 30 MINUTES INTO ALTERNATIVE SHUTDOWN O

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(2.01 (9.2) a2.6) llllllllllllllllllllllllllllll 0.0 5.0 10.0 15.0 20.0 25.0 30.0 TIME (MINUTES)

O DENOTES THE ACTION PERFORMED AS DESCRIBED IN THE FOLLOWING PAGES.

( ) DENOTES TIME TO COMPLETE THE DESCRIBED ACTION NOT INCLUDING TRANSIT TIMES.

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Trojan Nuclear Plant Mr. John B. Martin Docket 50-344 Attachment A License NPF-1 November 30, 1989 Page 10 of 12 Notes for Figure 1 1

1.

Open lockout relay to the Train A Emergency Diesel Generator (EDG),

EDG1A, and start the Train B Emergency Diesel Generator EDG28.

2.

Wait until service water cooling and Heating, ventilation, and air l

conditioning (HVAC) support to EDG2B has started prior to leaving the EDC2B room.

3.

Align service water to cool the Train B Auxiliary Feedwater (AFW) Pump, P102B, align the AFW flow control valves to the D Loop Steam Generator, E-201D, and manually close the steam generator blowdown isolation valves.

Communicate with the Shift Supervisor when actions are completed.

4.

Monitor the Condensate Storage Tank. level, Refueling Water Storage Tank l

level, and EDG Diesel Puel Oil Day Tank level as necessary.

l S.

Deenergize Train A Engineered Safety Feature (ESP) Switchgear, Al. and non-ESF loads [e.g. Reactor Coolant Pumps (RCPs) and pressurizer heaters),

then proceed to the Train B ESF Switchgear, A2, room and rackout the the offsite power feed to A2.

Deenergizo loads not required for alternative I

-shutdown at Motor Control Centers B22 B24, and B26.

i L

6.

Control Steam Generator Power Operated Relief Valve (PORV), as necessary, during depressurization.

7.

Deenergize Pressurizer PORVs and valves powered from the DC distribution panels:

D10 D30, D20, and D40.

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8.

Deenergize the Train B Switchgear, A2, to mitigate spurious.

Decouple the required Train B Loads (e.g. service water pump, service water booster l

pumps, charging pump AFW pump Component Cooling Water (CCW) pump, loadcenters, motor control centers HVAC to the EDG2B room, HVAC to AFW pump room, HVAC to the charging pump room, and the power supply to the l

Bailey Net-90 (YO6).

In addition, open the breakers to selected components required for alternative shutdown.

l l

9.

. Load EDG2B to A2 and start EDG2B support equipment.

10. Start the charging pump, MP205B, after verifying with the Shift Supervisor that the charging path is aligned via the Refueling Water Storage Tank and the Boric Injection Tank, and that RCp seal injection valves are closed.

11. Start the AFW Pump Room HVAC.

t Trojan. Nuclear Plant Mr. John B. Martin Docket 50-344 Attachment A License NPF-1 November 30, 1989 Page 11 of 12 Notes for Figure 1 (cont.)

I

12. Start the CCW Pump, MP210B, after verifying with the Shift Supervisor that the CCW valves have been aligned.

Start the Diesel Puel 011 Transfer Pump, MP144B when the day tank volume has been depleted. Return to the Remote Shutdown Station to help the SS.if t Supervisor with any-unanticipated operator actions.

13. Align the charging path via the Refueling Water Storage Tank (RWST) and the Boric Injection Tank. Close the RCP seal injection valves.

14. After charging is initiated, open RCP seal injection valves to allow a flow of approximately 8 gpm/ pump.

15. Open charging pump miniflow isolation valves.

16. Align valves for the CCW system.

17. Monitor plant parameters:

Pressurizer pressure and level, and Steam Generator pressure and level.

Continuously monitor plant parameters throughout the shutdown process.

18. Verify power to the Bailey Net-90 distributed control system. Verify open RWST supply valve, M0112E, and close Volume Control Tank (VCT) supply valve, M0112B, at the Not-90.

19. Coordinate operator actions to initiate charging and monitor Reactor Coolant System (RCS) temperature and neutron source-range = flux indicators.

20. Coordinate operator actions to initiate AFW flow and monitor RCS temperature and neutron source range flux indicators.

I KLB/bsh 3905W.1189

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Trojtn Nuc1ctr Pltnt Mr. John C. Martia Docket 50-344 Attachment B

. License NPF-1 November 30, 1989

.$?

Page 1 of 1' 3

i.

STATUS

SUMMARY

OF ADDITIONAL APPENDIX R COMMITMENTS Commitment Basis Status Summary Performance of National Fire Pro-NRC letter dated June 8, 1988 PGE's commitment to-complete an tection Association (NFPA) Code PGE letter dated August 12, 1988 NFPA Code compliance review during Review for Trojan.

NRC Inspection Report 344/88-34 1989 will be met.

The final code dated October 20, 1988, Item compliance report is due from.the 344/88-34-13 vendor during December 1989.

Provide reference to engineering NRC letter dated June 8, 1988 Complete. Additional engineering evaluations in PGE-1012. " Trojan PGE letter dated August 12, 1988 references were incorporated into Nuclear Plant, Fire Protection Amendment 5 to PGE-1012 issued Plan".

July 1989.

Revise Emergency Fire Procedure

..PGE letter dated April 28, 1989 Complete. The commitment to re-(EFP)-O and EFP-1 to reflect the vise the EFPs by September 29, proper sequence of actions per 1989 was met.

The revised pro-the revised alternative shutdown cedures were issued September.28, methodology.

1989.

Complete feasibility evaluation of PGE letter dated April 28, 1989 Complete.

providing Train B Component Cooling PGE letter dated September 29, Water (CCW) cooling to the Positive 1989 Displacement Pump (PDP) by modifi-cation of electrical or piping.

systems.

Revise Volume II of PGE-1012 to PGE letter dated April 28, 1989 Amendment 6 to PGE-1012 is on delete reference to additional schedule to be issued by operators credited to assist with December 29, 1989 and will com-shutdown after one-hour.

plete this commitment.

KLB/bsh 3905W.1189

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