ML20024F223
| ML20024F223 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 08/25/1983 |
| From: | Johari Moore NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Gleason J, Paris O, Shon F Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-SP, NUDOCS 8309090082 | |
| Download: ML20024F223 (20) | |
Text
Of * CUq(c, UNITED STATES
, [gy... f[' 'p, NUCLEAR REGULATORY COMMISSION E
- .g','jq WASHINGTON, D C. 20555 August 25, 1983 James P. Gleason, Esq, Chairman Dr. Oscar H. Paris Administrative Judge Administrative Judge 513 Gilmoure Drive Atomic Safety and Licensing Board Silver Spring, MD 20901 U.S. Nuclear Regulatory C0amission Washington, DC 20555 Mr. Frederick J. Shon Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555 In the Matter of Consolidated Edison Company of New York (Indian Point, Unit 2)
Power Authority of the State of New York (Indian Point, Unit 3)
Docket Nos. 50-247-SP & 50-286-SP
Dear Administrative Judges:
Pursuant to-your request made during the hearings in this proceeding at Tr. 7593-94, I am enclosing for your information a copy of the Staff's Safety Evaluation Report concerning the safe shutdown capability in the event of fire of Indian Point Unit 2.
This document has been issued as part of the Staff's Appendix R review.'
Copies of the document are being transmitted to all the parties to this proceeding.
Sincerely, 8309090082 830825 a f/JLE9R'.MrymLct PDR ADOCK 05000247 G
Janice E. Moore PDR Counsel for NRC Staff
Enclosure:
As stated DESIGNATEDORIGIN1TJ(
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i Docket No. 50-247 Mr. John D. O'Toole, Vice President Nuclear Engineering and Quality Assurance Consolidated Edision Company of New York, Inc.
4 Irving Place New York, New York 10003
Dear Mr. O'Toole:
SUBJECT:
SAFETY EVALUATION REPORT - APPENDIX R TO 10 CFR PART 50, ITEMS III.G AND III.L - INDIAN POINT 2 Enclosed is the staff's Safety Evaluation Report regarding the safe shutdown capability in the event of fire for Indian Point 2.
The safe shutdown capability was evaluated against the requirements of Sections III.G and III.L of Appendix R to 10 CFR 50.
We conclude that the Indian Point 2 Nuclear Plant is in accordance with Appendix R,Section III.G.3 and III.L requirements.
The enclosued SER addresses the Consolidated Edison submittal dated January 10, 1983.
The subsequent Appendix R submittal of July 13, 1983, is under review and will be covered under a separate SER.
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Sincerely, I:
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even. Var,ga!'
d
, Operating Reactors! anch No. 1 Division of Licensing
Enclosure:
SER cc w/ enclosure:
See next page
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Vr. Jonn D. O'Toole Consplidated Edison Company of New York, Inc.
cc:
Dr. Lawrence R. Quarles Ms. Ellyn Weiss Apartment 51 Sheldon, Harmon and Weiss Kendal at Longwood
.1725I Street, N.W.
Kennett Scuare, Pennsylvania 19343 Suite 506 Washington, D. C.
20006 Joseph D. Block, Esquire Executive Vice President Administrative Mr. Charles W. Jackson Consolidated Edison Company Vice President, Nuclear Power of New York, Inc.
Consolidated Edison Company 4 Irving Place of New York, Inc.
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New York, New York 10003 Broadway and Bleakley Avenues
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Buchanan, New York 10511 Thomas J. Farrelly, Esquire Law Department Mr. M. Blatt Consolidated Edison Company Director, ' Regulatory Affairs of New York, Inc.
Consolidated Edison Company 4 Irving Place of New York, Inc.
New York, New York 10003 Broadway and Bleakley Avenues Buchanan, New York 10511 Robert L. Spring Nuclear Licensing Engineer Mr. Frank Matra Consolidated Edison Company Resident Construction Manager of New York, Inc.
Consolidated Edison Company 4 Irving Place of New York, Inc.
New Yp' rk,- New York 10003 Broadway and Bleakley Avenues Buchanan, New York 10511 Senior Resident Inspector Brent L. Brandenburg U. S. Nuclear Regulatory Commission Assistant General Counsel P.O. Box 38 Consolidated Edison Company Buchanan, New York 10511 of New York, Inc.
4 Irving Place - 1822 Ezra I. Bialik New York, New York 10003 Assistant Attorney General Environmental Protection Bureau New York State Department of Law 2 World Trade Center New York, New York 10047 C
Regional Administrator - Region I U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pennsylvania 19406 M
O INDIAN' POINT UNIT 2 NUCLEAR POWER PLANT SAFETY. EVALUATION REP,0RT APPENDIX R 40 10 CFR SD 10 INTRODUCTION _
On February 19, 1981, the fire protection rule for nuclear power plants, 10 CFR 50 48 and Appendix R to 10 CFR 50 became effective.
This rule required all licensees of plants licensed prior to January 1, 1979, to submit by March 19, 1981:
{1} plans and schedules for meeting the applicable requirements of Appendix R, {2} a design description of any modification proposed to provide alternative safe shutdown capability pursuant to Section III.G.3 of Appendix R, and
{3} _ exemption requests for which the tolling provisions of Section 50 48{c}{6} were to be invoked.
Section III.G of Appendix R, " Fire Protection of Safe Shutdown Capability,"
was retrofit to all pre-1979 plants regardless of previous
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SER positions and resolutions.
By submittals dated March 19 and nay 19, 1981, the licensee addressed the post fire shutdown capability of the plant.
A review of these submittals did not give a complete descrip-tion of the systems and equipment intended to be used for post fire safe: shutdown.
Therefore, a meeting was' held with Con Ed in New York'on July 1, 1982 to discuss the proposed O
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alternate safe shutdown sy Yem for the plant.
At the con-clusion of the meeting, the Licensee agreed to provide a response to 12 action items.
These speci'fic action items and the scheduled dates for th'e responses were transmitted to Con Ed via a memo from S.
A.
Varga (NRC) to J.
D. O'Toole
{ Con Ed} on August b, 1982 By the same memo the staff recom-mended in'terim actions to provide for modifications to the Indian Point 2 plant to mitigate the risk of core melt due to fires in certain areas. The licensee submitted a report on January 10, 1983 in which they addressed these action items and interim actions.
Our evaluation of the Licensee's submittal fotLows:
2.0
. SYSTEMS USED FOR POST FIRE _SA_FE SHUTDOWN _
2.1 Systems Recui red f or Safe Shutdown si Safe shutdown of,the reactor is initially performed by control rod insertion f rom the control room.
This can also be accomplished by deenergizing the control rod drive motor generator set at the 480V switchgear.
Reactor shutdown is caintained by boric acid inj ection via the boric acid transfer pumps taking suction from the boric acid storage tank.
A secondary boration method utilizes water inj ecti on i
from the refueling water storage tank via gravity feed to
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the suction of one of the charging pumps.
Reactor coolant i nventory is maintained by use of one of the three charging. pumps taking suction from the refueling water storage tank.
I Decay heat. removal is accomplished by utilizing the auxiliary feedwater pumps which pump water from the condensate storage tank to the steam generator with stea,m relief via the atmospheric dump va lv es.
Additional sources of water are the city water storage tank (on site) and the city water supply.
The city water storage tank can provide water by gravity feed while the city water suppty provides its own pumping f acilities.
Primary system pressure is maintained
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either by the pressurizer heaters and spray via a charging al' pump or by use of,one of the power operated relief valves.
To go from hot to cold shutdown the residual heat removat system i s required.
To achieve this function a steam driven auxiliary feedwater pump is normally'used during the' shut-down before the RHR system is brought on Line.
A motor driven auxiliary feedwater pump can be used, i f required, during the shutdown.
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2.2 Areas Where Alternate Ssie Shutuown is Reouired The speci fi c plant areas for whi'ch'the safe shutdown system is desjgned to provide alternate' shutdown cap-abi li ty are summarized below:
, Zone 1A Electrical and Piping Tunnel
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Zone 2
~ Containment Spray PumpTRoom
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Zone 2A -' Primary Wat.er Makeup Pump Room Zone 5 - Charging Pump Room
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Zone 6A - Waste Storage and Drum han'dLing Area
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. Zone 10 - Diesel Generator Room -
Zone 11. - Cable. Spr ea di ng Room Zone 13A - Valve Room Zon'e 14 - Switchgear Room il 1
Zone 15 - C.entral control Room Zone 18A - Valve Room and Cerridor Zone 32A - El'ectrical Tunnel Zone 74A - Electrical Penetration Area' 2.3 Section III.G.2 of Appendix R The Licensee has divided the plant i n t o s ev'e r a l '1 i r e zones and has made an evaluation of the consecuences of a ' fire in a zone spreading to an adjacent zone.
By letter dated January 10, 1 83, t h e Licensee provided a list of fire lf s
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4 zones which do not comply with the requirements of Section III.G.2 of Appendix R and requested either exemptions to the: requirements of Appendix R or committed to make modi-fications for these fire zones.
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2.4
, Alternate safe shutdown System By Letter dated August 6, 1982, from NRC to con Ed, the staff recommended interim actions to provide for modifi-cations to Indian Point 2 plant to mitigate the risk of
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. core melt due to fires in certain plant areas.
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response to the staff recommendations, the Licensee pro-vided an a Lternate capability power source by providing hardwire connections-through transfer switches to the at fotL0 wing c omp o n,e nt s :
,A.:omponent cooling water pump l
j Two service water pumps l
A ' charging pump
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A~ hardwire connection through a transfer switch to a motor driven ~auxiLiliary feedwater (AFW) pump is also provided although the turbine driven pump wilL be used after reactor i
trip for secondary heat removal in the steam generator.
l The' motor driven AFW nump is a backup for the turbine driven I
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s pump.
Alternate power is a lso provide'd through trcnsf er syitches to local connection boxes to power a safety injection pump, RHR pump, and a motor control center.
These connections are not hardwired since these components are used for cold shutdown.
The " ca s ua lt y" cables to be used for these connections are' stored on site.
The Licensee has proposed to use an onsite gas turbine GT-1 as an alternate backup power source in case of loss of
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norma,t-emergency power at IP-2 and concurrent loss of
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offsi.te power.? The diesel generators cannot be used as an aL' ternate power source since aLL generators are Lost in'the event of fiYe in diesel generator.~oom, electrical tunnel, c a b.L e s p'r e a d i n g room, land switchgear room.
The v-onsite gas turbine GT-1 is connected to the Indian Point 1
'440V switchgear and can be manually st'arted from the l~,
Indian Point 2 control room.
It should be noted that IPlt was shutdown in 1974 The emergency power connections can l
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be made from the IP1 440V switchgear to the IP2 components i-assantial for. safe shutdown.
The alternate power can also 9
i be received from two gas turbines located at the Buchanan e
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substation.
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The Licensee has provided the folLowing instrumentation for alternate safe shutdown systems:
Pressurizer pressure Pressurizer Level Steam senerator pressure Steam generator Level C o nd er. s a t e storage tank level Refueling water storage tank Level Auxiliary feedwater pump suction and discharge pressure Safety inj ection pump discharge pressure Service water pressure at the intake to the component cooling water heat exchangers Flow indicators for component cooling water flow to the it charging pumps, safety injection pumps and RHR pumps.
In addition, the Li censee has committed to provi,de the i
i following instrumentation as part of the alternate safe shutdown system!
I Hot leg temperature Cold t~e g temperature Source range flux monitor
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s AlL the above instrumentation is pneumatic, mechanical or i
i powered from the IP1 switchgear to ensure it. availability in the event of a fire in critical areas.
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-o-3.0 EVALUATION 3.1 Performance Goals _
The performance goals for post-fire safe shutdown for reactivity control, reactor coolant makeup, reactor coolant pressure control and decay heat removal can be met using the existing systems and equipment discussed i n S e c t i o n 2.'1.
The control,of these functions can be accomplished using the alternate shutdown methods or the control room depending on the location of the fire.
The Licensee's alternate shutdown method relies on procedures and actions at the remote shutdown panels or LocalL'y at the equipment.
The process monitoring instruments to be used for a post fire shutdown'.are listed in Se ction 2.4.
f 3.2
_72-Hour Requirement The alternate shutdown systems have the capability of achieving cold shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> af ter a fire event using only onsite power sources.
3.3 Repairs In case of fire involving the RHR pumps or cables, the licensee proposes to make repairs by connecting cables
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from LoceL connection boxes to power an RHR pump.
The RHR oump would only be required for cold shutdown, and adequate time would be available for installation of the casualty cable which is stored on site.
3.4 Associated Circuits AlL circuits associated sith alternate shutdown wilL be independent f rom those identified fire zones for which alternate shutdown is provided.
'A L L controls and inst ru--
mentation required for alternate safe shutdown are Local.
The alternate shutdown power sources are.
routed outside of thelfire' areas to be avoided and are independent of the existing Indian Point Unit No. 2 power sources.
The proposed methods for protecting the Y
safe shutdown capability are consistent with the guide-Lines provided by the staff.
A summary of the associated circuit concern is as follows:
3.4.1 Power Source The alternate shutdown system is provided with a gas i
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turbine power source with cabling routed from the Indian Point Unit No. 1 switchgear room.
The *Lternate componentspoweredfromIPh1 switch-j safe shutdown system l
8 gear do not rely on component power or contr:
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from any IP-2 buses wh*.n transferred to the IP-1 power supply by the transfer switches.
Fire in any area of IP-2 wilL not affect the alternate safe shutdown system supply from IP-1.
The Licensee stated that coordination of IP-2 breakers is not required in order to assure operability of the saf e shutdown system.
3.4.2 Common Enclosure The common enclosure associated circuits for the Indian Point 2 alternate safe shutdown system are routed only in IP-1 areas and not into any IP-2 fire zone, with the exception of associated circuits for transfer switches and for a manhole which contains the normal power feeds al to four of si,x service water pumps, the normal power feed to transfer switches whi ch supply two remaining service water pumps (Nos. 23 and 24), and the power feeds from these transfer switches to service water-pumps 23 and.24.
Thus, Loss of aLL cables in the man-hole could result in Loss of alL service water capability.
For hot shutdown as weLL as for cold shutdown, service water is required for cooling of component cooling water heat exchangers.
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'A fire affecting either the norma L or alternate power feed to the transfer switch would not cause a resultant fire in the switch panel.
If the switch were aligned l
to the cable affected by the fire, the maximum voltage applied would not exceed the normal voltage of the power circuit.'
However, a fire in the manhole would remove both normal and alternate power supplies from service water pumps 23 and 24.
Addi ti ona l Ly, certain of the associated circuits are routed to the IP-2 switchgear room.
To resolve this potential problem, the cables associated with the normal power feed to transf er switches and at the power fee.d from tnese transfer switches to service I
water pumps 23 and 24 wilL be provided with a fire barrier material that has been, tested to demonstrate I
protection of better than 55 minutes.
The licensee 1
consecuently has requested an exemption from the separation requirements of Section III.G.2 of Appendix R l
in this fire zone.
The Chemical Engineering Branch is evaluating this exemption request.
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e 3.4.3 Sourious Sional The Licensee has considered atL spurious signals in his fire zone ana Lysis and has proposed e.anua L valve opera-tions by operators to assure that an unrecoverable plant condition wilL not occur.
The Licensee has ideitified five high/ Low pressure interfaces which do not meet the separation require-ments of Section III.G.2.
These five are:
a.
RHR Letdown valves b.
CVCS Letdown valves c.
CVCS excess Letdown valves d.
Pressurizer power operated relief valves gi e.
Reactor vessel head vent valves These five interfaces are discussed below:
a.
RHR letdown valves The system contains two motor operated valves in series.
These valves are normalLy closed and fait as is on loss of power or open circuits.
In the event of the spurious operation ~(to an open position) of the two letdown vatves, the piping m
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7 downstream of these valves would be subj ect to reactor system pressure.
However, the spurious openings of these valves are very unlikely since the power supply switches for both of these valves are Locked out at their respective motor ccntrol centers during reactor operation.
We conclude i
that spurious operation of the RHR valves wilL not be a problem b.
C V C S_Le t.d o w n valves The system uses one solenoid operated valve (SOV)
'in series with three paraLLet SOVs inside contain-ment and two valves in series downstream outside containment.
The CVCS Letdown line is normaLLy open and ihe coolant pressure drops from 2235 psig to 225 to 275 psig when flowing through one or more of the orifices located upstream of the,three SOVs l
l in parallel.
AlL the valves fait closed on loss of air or power.
A short to ground caused by a fire or loss of power could cause either of,the
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two valves outside containment to close.
This may l
cause the relief valve located between these valves l
and three parallet SOVs to open discharging to l
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primary r eli ef t e r.C (PRT).
After some time thic could lead to blowing down into containment through the PRT rupture disc if the path'is not isolated.
The plant operators could isolate this postulated LOCA by closing solenoid operated valves inside the containment from the control room.
If valves outside containment were closed due to a loss of power which affected alL the valves, the LOCA would be automatically isolated by the fait closed valves.
We conclude that the spurious operation of the CVCS Letdown valves wilL not be a probtem.
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CVCS excess letdown vatves There are two normaLLy closed valves in series and fait closed on loss of air or power.
When these j
valves are opened, normal alignment is for flow' to l
l be directed to the volume control tank in the CVCS.
For a LOCA to result from a fire, the two air operated va tves in series would have to receive simultaneous hot shorts and another motor operated
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I valve upstream of the volume control tank would t
have to be closed by the fire. 'This would cause a d
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a relief vatve located downstream of the two air operated valves to open to protect the excess Letdown piping, passing the Letdown flow to the pressurizer relief tank.
Therefore, we conclude j
that spurious operation of either of these valves i s unli ke ly.
d.
_ Pressurizer power operated relief valves The PORV typi ca L configuration contains a PORV and its associated block valve.
These valves are normalLy closed.
The Licensee has identified five events which could damage PORV circuitry sufficiently l
to cause the valves to open.
In such a case, the a,I block valve breakers at their motor control centers can be manually operated to shut the block valve and, if necessary, the breakers racked out to prevent further matoperation.
We consider this i
approach acceptable.
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R e a c t o r _v e,s s e t.h e a d _ v e_n t valves There are two vatves in series and hot shorts simultaneous Ly opening these vatves would b'e required to'cause'a LOCA.
If simultaneous control l
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-lb-circuitry hot shorts (in the open di rection) were to occur due to a fire, local manual control at the motor control center could be used to close either or both valves.
The charging pumps would be used to replace inventory that is Lost in the interva L when the head vent is open.
We conclude o
that the spurious opening of these valves wilL not be a problem.
3.5 Safe Shutdown Procedure and Manpower The Licensee wilL develop and implement written pro-cedures for obtaining safe shutdown conditions given a fire event.
A minimum shift crew consisti ng of suf fi-it cient personnel to man the fire brigade as welL as to effect safe shutdown of the plant wilL be maintained.
Fire brigade personnel wilL not be used for plant i
l shutdown operations.
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4.0 CONCLUSION
f We have reviewed the Licenee's proposed a Lternate shut-down capability for Indian Point Unit 2 in accordance l
with the requirements of Appendix R to 10 CFR Part 50, Items III.G.3 and III.L with respect.to safe shutdown
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Based on that review, we conclude that the performance goals of reactivity control, inventory control, decay heat removal, reactor pressure control, and process control are met.
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