ML20056B416
| ML20056B416 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 08/17/1990 |
| From: | Kintner L Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 9008280257 | |
| Download: ML20056B416 (56) | |
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August 17, 1990
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o Items 021, 022 and 023 . Licensee plans to submit proposed TS !
changes to extend surveillance intervals and allowed outage times i for ECCS instrumentation, Isolation Activation instrunentation and l Rod Block instrumentation by October 31, 1990. The staff advised j
-it could review these changes on a priority 2 basis provided they
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were consistent with the BWR Owners Group Topical- Reports and the !
, staff's associated Safety Evaluation Reports.
o item 034 - The licensee met with staff in the Technical Specification i Branc.h, NRR, on September 11,~12, and 13 to discuss some of the proposed a draft improved TS. Grand Gulf is the lead BWR-6 plant.- The licensee .!
now plans to submit a request for license amendment June 30, 1991, !
after the Improved STS are issued. ,
o Item 054 - Licensee plans to withdraw its request for changes to the L TS to eliminate small test, vent ar.d drain valves from the TS table, i since the complete table will be moved to the updated FSAR by the Improved TS (withdrawn by licensee's letter dated June 27,1990).
o Item 011 - The licensee plans to submit a request to amend the >
license condition on fire protection and move TS to the updated FSAR per Generic Letter 88-12. The previous request for amendment submitted May 19, 1987, per Generic Letter 86 10, will be withdrawn at that time. The new license condition will reference the CGNS Fire Protection Plan and the staff's Safety. Evaluation Report. In a meeting with the licensee on December 6,1989 (Heeting Summary dated December 20, 1989), the staff discussed the proposed submittal and '
provided the staff's Draft Safety Evaluation Report for review of the facts contained therein., Licensee provided its comments on the staff's Draft SER in this meeting (Enclosure 3). (The present target 3 date for submittal is August 17,1990).
The licensee advised that a report is being prepared on work done to complete site and structures for a one. unit site. Included will be soil stability.
-dewatering wells to maintain design basis groundwater level, and a clay blanket to seel Unit 2 excavation. .
Origiani sisped att Lester L. Kintner, Senior Project Manager oosi7 Project Directorate IV-1 goo 02 g % ocoo k :' Division of Reactor Projects - III PDR IV, Y and Special Projects P
Office of Nuclear Reactor Regulation
Enclosure:
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OFFICIAL RECORD COPY Document Name: GRAND GULF UMT 1
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UNITED STATES b ,; i [s . 1 NUCLEAR REGULATORY COMMISSION!
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- August 17, 1990 Docket No. 50-416 o
' LICENSEE: Entergy Operations, Inc.
FACILITY: Grand Gulf Nuclear Station, Unit 1 '
SUBJECT:
SUMMARY
OF JUNE 15, 1990 MEETING WITH ENTERGY OPERATIONS, INC.
REGARDINGGRANDGULFNUCLEARSTATION, UNIT 1(GGNS-1)
The NRC Project Manager and Resident Inspector met with the licensee at the GGNS-1 site to discuss licensing activities. A list of attendees is given in
' Enclosure 1. Enclosure 2 is an agenda and handout prepared by the licensee.
- Enclosure 3 contains licensee's comments on the staff's draft Safety Evaluation of the GGNS-1 Fire Protection Program. Enclosure 4 contains the 10 CFR 50.59 analysis of the use of low pressure coolant injection nozzles for shutdown cooling.
The. licensee described plans for consolidation of certain functions at the corporate level of Entergy Operations,-Inc. includingengineering(under Cloninger)qualityassurance(underDewease},andlicensing,healthphysics, environmental considerations and contracts (under Muench). Organizational relationships are shown on sheet 2 of Enclosure 2. Before major changes are put into effect, the licensee will meet with NRR to discuss them. The
. licensee also advised that Guy Cesare will transfer to the Grand Gulf operations staff and M.J. Meisner, Waterford 3 Licensing Manager, would replace him as Grand Gulf Licensing Director in August 1990.
The licensee also described its SGNS Cycle Licensing Plan, in which licensing activities for one 18-month fuel cycle are scheduled (sheets 3 through 9 of Enclosure 2). Near term activities were also listed separately (Sheets 10,11 and 12 of' Enclosure 2).
For the fourth refueling outage (RF04), beginning October 1, 1990, the licensee identified six licensing actions ond the dates they are needed to meet the outage schedule (Agenda Item III, Sheet 1 Enclosure 2). These actions are:
August 1,1990 - Safety Evaluation of Criticality Analyses for new fuel in spent fuel pool (completed. July 16,1990).
August 15, 1990 - License Amendment to implement Generic Letter 87-09 granting reliefs from Technical Specification (TS) 3.0.4.
September 24, 1990 - License Amendment to provide TS for the alternate decay heat removal system (ADHRS) and change TS for ECCS injection and reactor pressure vessel isolation.
October 1, 1990 - Inservice Inspection reliefs.
Novenber 1,1990 - License Amendment to chance TS for Fuel Cycle 5 Reload.
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November 15, 1990 - License Amendment to change license condition deferring installation of post accident neutron flux monitor.
The licensee provided target dates for submittals related to RF04 licensing actions as follows:
June 29, 1990 - ADHRS and associated TS changes (completed July 5, 1990).
June 20, 1990 - Inservice Inspection Reliefs (completed July 9, 1990).
June 20, 1990 - Post Accident neutron flux monitor (completed June 22,.1990).
The staff provided the status of review of the RF04 licensing actions as follows:
o The telephone calls of May 23, and May 30, 1990, regarding the ADHRS resubmittal resulted in appropriate action to revise the ADHRS submittal, o The 10 CFR 50.59 analysis made to revise the cinal Safety Analysis Report to indicate that low pressure coolant injection nozzles could be used instead of the feedwater ring for the normal shutdown cooling path (Enclosure 4) did not contain analytical or test information to justify the conclusion that the proposed flowpath provides sufficient mixing. The Basis for TS 3/4.9.11 states thot " sufficient coolant.
circulation would be available through the reactor core to assure dCCurete temperature indication and to distribute and prevent stratification of the poison in the event it becomes necessary to activate the standby liquid control system." Further the analysis did not determine the effect on control rods, instrument tubes or fuel assemblies of the proposed routine injection cf coolant between fuel assemblies rr.ther than in the feedwater ring.
o The staff is reviewing the assumptions regarding probability of the distribution of gaps in the boraflex panels of high density spent fuel racks. Assumptions were made for the new fuel criticality analysis, based on the results of blackness surveillance tests in 1988 and 1990 which found gaps in the panels. The staff recommended that monitoring (blackness testing) be done to determine any gap redistribution following an operational basis earthquake, o The May 31, 1990 resubmittal of the proposed license amendment to defer installation of the post accident flux monitor apper :o have an acceptable analysis about the issue of no significant u ards consideration.
The staff commented on other key licensing issues (Agenda Item IV, Sheet 1, Enclosure 2) as follows:
.x o The May 4,1990 resubmittal of TS changes to correct a deficiency by requiring containment when handling loads over spent fuel appears to be unacceptable for the same reason the initial submittal on January 26,.1989, was unacceptable. The proposal does not-specify the loads which will require containment (loads having a potential energy grater than 17,000 foot-pounds based on the licensee's analysis).
Rather, the criteria given in the Standard Review Plan is used to define a " suspended load" as one which "if dropped onto irradiated fuel assembiies could cause offsite releases in excess of 25% of 10 CFR 100 dose limits."
o The May. 31, 1990 resubmittal of TS changes to correct a deficiency in the standby liquid control system TS appears to have the same unacceptable-features as the initial submittal on June 19, 1989.
The proposal would allow excessively large concentrations of sodium pentaborate and potential precipitation and plugging of pipes.
o The May 7, 1990 submittal providing proposed TS changes for correcting the TS deficiency regarding testing of two motor operated control room isolation valves deleted the valves from the TS rather thcn correcting the response times for the as-built valves. Since these valves are isolation valves and must be opened and closed following an accident, it appears their deletion from the TS is unacceptable, o Another key licensing issue is the requirement for increased heat removal capability of the fuel pool cooling _ and cleanup system.
The licensee's submittal of April 27, 1989, was found to be unacceptable and a revised submittal was. proposed in a February 15, 1990 meeting. The licensee planned to submit this revised proposal on July 18, 1990, together with a proposed TS change to increase the allowable fuel storage to the full capacity of the high density spent fuel racks. Presently, it is limited to 2324 cells of the 4348 total installed because'of inadequate heat removal capability.
Judging b3 the slow and inadquate responses to staff concerns on the above safety signu1 cant licensing issues, the NRC Project Manager stated that insufficient priority and manpower appear to be put on those issues by the licensee as compared to the TS changes requesting operational flexibility such as ADHRS, GL 87-09 reliefs, and ISI reliefts.
The licensee highlighted some of the items in the Cycle Licensing Plan (Enclosure 2, Sheets 3to9).
O ltem 036 - Licensee now plans to submit a proposed TS change to relocate cycle specific parameters from the TS to the Updated FSAR per Generic Letter 88-16 by January 1,1991. The staff indicated it would favor this submittal for review prior to review of the Improved TS because it does not involve the NRR Technical Specification Branch, and, therefore, would not impact the high priority Improved Technical Specification Program.
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.oL Items 021, 022 and 023 - Licensee plans'to submit proposed TS-changes to extend surveillance intervals and allowed outage times for ECCS instrumentation, Isolation Activation instrumentation and :
Rod Block instrumentation by Octobe~r 31, 1990. The staff advised it could review these changes on a priority.2 basis provided they '
were consistent with the BWR Owners Group Topical Reports and the .
staff's associated Safety Evaluation Reports.
o Item 034 - The-licensee met with staff ~in the. Technical Specification Branch, NRR, on Septe:nber 11,12, and 13 to discuss some of the_ proposed draft improved TS. Grand Gulf is the lead BWR-6 plant. The licensee '
now plans to submit a request for license amendment June 30, 1991, '
after the Improved STS'are issued.
o Item 054 - Licensee plans-to withdraw its request for changes to the
-TS to eliminate small test, vent and drain valves from the TS table, since the complete table will be moved to the updated FSAR by the .;
Improved TS (withdrawn by licensee's letter dated June 27,1990). ;
o Item 011 - The licensee plans to submit a request to amend the '
license condition on fire protection and move TS to the updated-FSAR per Generic Letter 88-12. The previous request for amendment ,
submitted'May 19, 1987, per Generic Letter 86-10, will be withdrawn at t
-that time. The new license condition will reference the GGNS Fire Protection Plan and the staff's Safety Evaluation Report. In a '
meeting with the licensee on December 6,1989 (Meeting Summary dated :
December 20,1989), the staff discussed the proposed submittal and provided the staff's Draft Safety Evaluation Report for review of-the facts contained therein. Licensee provided its comments on the staff's Draft SER in this meeting (Enclosure 3), (Thepresenttarget date for submittal is August 17,1990).
The' licensee advised that a report is being prepared on work done to complete site and structures for a one-unit site. Included will be soil stability, dewatering. wells to maintain design basis groundwater level, and a clay blanket t
to seal Unit 2 excavation.
t Lester L. Kintner, Senior Project Manager Project Directorate IV-1 Division of Reactor Projects - III I IV, Y and Special Projects l Office of Nuclear Reactor Regulation c
Enclosures:
L As stated
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9 Enclosure 1 Entergy Operations - NRC Meeting June 15, 1990 Attendees Name Affiliation L.L! Rintner NRC, Project Manager .
P.R. Simpson Entergy Operations Nuclear Licensing
-J.O. Fowler Entergy Operations Nuclear Licensing G.A. Zinke Entergy Operations Nuclear Licensing W.K. Hughey. Entergy Operations Nuclear Licensing C.M. Dugger- Entergy Operations Outage Scheduling W.R. Patterson Entergy Operations Management)
J.L. Robertson Entergy Operations NuclearOperations)
J.G. Cesare Entergy Operations Director,NuclearLicensing)
M.J. Meisner Entergy Operations W3LicensingManager)
M.L. Crawford Entergy Operations ManagerNuclearLicensing)
,J.L. Mathis' NRC, Resident-Inspector GGNS I
't . . NRC) ENTERGY 0PERATIONS, INC. __ Enclosure 2 :
LICENSING ACTIONS STATUS MEETING
. JUNE 15, 1990 9:00 A. M.
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I.- INTRODUCTION J. G. CESARE I II. 'SPECIAL= TOPICS OF INTEREST A. PLANT STATUS Auc UPCOMING EVENTS G. A. ZINKE B. ENTERGY OPERATIONS ORGANIZATION J. G. CESARf!
C.. CYCLE LICENSING ~ PLAN G. A. ZINKr.'
III. RF04 SUPPORT ISSUES .
A. 'ENTERGY OPERATIONS ACTION ALTERNATE DECAY HEAT REMOVAL G. A. ZINKE SYSTEM PCOL WIDE-RANGE NEUTRON MONITORING M. L. CRAWFORD SYSTEM DEFERRAL ,
INSERVICE INSPECTION RELIEF M. L. CRAWr0RD REQUESTS B. NRC ACTION L. L. KINTNER CYCLE 5 CRITICALITY ANALYSIS CYCLE 5 RELOAD ANALYSIS GL 87-09 (3.0.4 EXCEPTIONS)
IV. STATUS OF OTHER KEY LICENSING ISSUES
- A. TECN SPEC IMPROVEMENT PROGRAM G. A. ZINKE -;
! 8. DISCUSSION / RESOLUTION OF PM COMMENTS G. A. ZINKE ON OTNER SUBMITTALS l
STANDBY LIOUID' CONTROL SYSTEM-(TS)
FIRE PROTECTION RELOCATION GL 88-12 C. STATUS /SCNEDULE OF NRC ACTION ON L. L. KINTNER GGNS SuBMITTALS-ATTACHMENTS L
- 1. RECENT ENTERGY OPERATIONS SUBMITTALS
- 2. FORECAST (NEXT 90 DAYS)
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i ENTERGY OPERATIONS-CYCI 1E LICENSING PLAN CONCEPT O
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CYCLE LICENSING PLAN DATE: 06/15/90 PAGE NO. 1 RESP FINAL SOURCE ITEM COMMENTS DESCRIPTION PRIORITY- DEPT DUE DATE DOCUMENT NO.
NL 06/20/90 (T) Need by October to-001 ASME Relief Request for ISI '
support RFO4 002 ADHRS actions: 06/22/90 (T) AECM-90/
0056 a) Resolve comments b) NRC approval 09/24/90 (N) 003 NRCB 88-08-Supp 3; Thermal stresses 'NL 06/29/90 (T) a) Based on LLK request on unisolable piping to RCPB b) Need info from NPE to support submittal GL 87-09 (3.0.4 Exemptions) Final NRC. 06/29/90 AECM-90/
004 0050 Resolution 005 GL 90-04; Generic' Safety Issue NL M6/29/90-(D) Provide status of all Resolution GSI resolutions for GGNS NL 06/29/90 (D) No new fuel changes in 006 Current Cycle Safety Analysis time period' 007 Revise VPMO Title ~in Tech Spec. NL 07/18/90 (T)
NRCB-90-01; Rosemount Transmitters NL 07/18/90 (D) LAS 90/009 issued 008 009 Revise Environmental Protection Plan NL 07/18/90'(T) co delete commitment for salt disposition evaluation M9005161.2/SNLICFLR - 1
CYCLE LICENSING PLAN -
DATE: 06/15/90 PACE NO. 2 ITEM RESP- FINAL SOURCE NO. DESCRIPTION PRIORITY DEPT DUE DATE DOCUMENT COMMENTS 010 High Density Spent Fuel Rack NL 07/18/90 (T) Finalize single
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St failure discussion
{ pra e Jestriction ModiffcationCbjAh,'
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011 ' Relocation of Fire Protection TS in NL 07/31/90 (T) accordance with GL 89-01 012 Cycle 5 Criticality Analysis NRC 08/01/90 (N) AECM-90/
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0 03 013 NMS Quarterly Status Reports NL 08/30/90 (T) 11/30/90 (T) 014 Hydrogen Control Quarterly Status NL 08/30/90 (T)
Reports 11/30/90 (T) 015 South Security Boundary Upgrade NL 08/31/90 (T) SERI to provide Status Reports 10/31/90 (T) bimonthly status reports thru GGNS Projects 016 Revise TS Surveillance 4.7.4.e to NL 08/31/90 (T) May be deferred to allow snubber testing at power TSIP
- 017 Delete or revise requirement to NL 08/31/90.(T) May be RF04 S/U l verify measured drive flow to be restriction less than established drive flow for APRMs (TS Table 4.3.1.1-1, Note h)
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CYCLE' LICENSING PLAN e DATE: 06/15/90 PAGE NO. 3 ITEM RESP FINAL SOURCE NO. DESCRIPTION PRIORITY PEPT DUE DATE DOCUMENT CONNENTS 018 GL 90-03: Vendor Equipment Technical 09/24/90 (D) Need to conduct Information Program (VETIP)-
- project meeting / issue LAS 019 GL 89-10; MOV Testing NL 09/30/90'(D) Submit Project Plan by RF04 020 Submit DCRDR Supp Summary Report NL' 09/31/90 (D) Per AECM-90/0079 021 Extend Surveillance Int and A0Ts for NL 10/31/90 (T)
ECCS Instruments 022 Extend Surveillance Times and.A0Ts NL 10/31/90 (T) for Isolation Actuation Instrumentation 023 Extend Surveillance Times and.A0Ts NL 10/31/90 (T) for Rod Block Instrumentation 024 Reload PCOL for Cycle $ NRC 11/01/90 (N) AECM-90/ Submitted 0092 Awe.iting NRC approval 025 Plant Specific Core Stability NL 11/01/90 (T) Likely result of BWROG CS/NRC report l
l 026 UFSAR Rev. 5 update NL 12/01/90 (D) On schedule 1
f 027 H Control Report NL 12/31/90 (T) Awniting'NRC response 2
l to UCOG Report 028 59.59 Annual Summary Report NL 12/31/90 (T)
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CYCLE LICENSING PLAN DATE: 05/15/90 PAGE NO. 4,__
ITEM RESP FINAL SOURL PRIORITY DEPT DUE DATE DOCUML;f COMMENTS NO. DESCRIPTION 029 Relocation of RETS in accordance NL 03/31/91 (T) 9 with GL 89-01 030 Revise refueling platform main NL 03/31/91 (T) hoist to reflect installation of cylindrical refueling mast 031 Fire Hazards Analysis submittal NL 05/07/91 (D)
(annual) 032 50.59 Annual Summary Report NL 05/31/91 (D) 033 Removal of the 3.25 limit on NL 06/30/91 (T) ext *nded surveillance intervals in accordance with GL 89-14 Submit PLC sssociated with NL 06/30/91 (T) Draft to NRC by 06/90 034 Improved TS (TSIP) 035 Cycle 6 Criticality Analysis NL 08/23/91 (T) 036 Relocate cycle specific parameters NL 09/30/91 (T) from TS in accordance with GL 88-16 037 Modify TS description of fuel NL 09/30/91 (T) assemblies to allow substitution in accordance with GL 90-02 038 Eliminate requirement to remove the NL 10/31/91 (T) '
fuel transfer canal gate in Mode 5, High Water Level
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CYCIE LICENSING PLAN .
DATE: 05/15/90 PAGE NO. 5 ITEM RESP FINAL SOURCE NO. DESCRIPTION PRIORITY DEPT DUE DATE DOCUMENT COMMENTS 039 Modify the LLRT requirement for the NL 10/31/91 (T)
HFTS hatch so that the hatch rf<y be closed and tested without drat'~;,g the canal (Appendix J Exemption) 040 Delete requirement for pneumatic NL 10/31/91 (T) Requires analysis BYPL testing of W isolation check valves 041 Cycle 6 Reload PCOL NL 11/05/91 042 UFSAR Rev. 6 update NL 12/01/91 (D) 043 50.59 Ar.uual Summary Report NL 12/ J1/91 (D) 044 Delete MSL radiat. ion high scram and NRC TBD Awaiting SER isolation (BWROG issue) 045 Delete MSIV Leakage Control System NRC TBD Awaiting SER (BWROP. Issue) 046 Obtain NRC approval on SBO rule submittals 047 NRC TBD AECM-90/ Awaiting TS Amendment lRWCUValveNestArea 0040 048 WRNM Deferral NRC TBD AECM-90/ Awaiting approval E49 Z31 Deeper Olcrifi'ation NRC TBD AECM-C0/
0074 Asaiting TS Amendment 050 Light Loads Resolution NRC TBD AECM-90/ Awaiting TS Amendment 0076
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CYCLE LICENSING PLAN -
ht?E: 06/15/90 PAGE NO. 6 ITEM l RESP FINAL SOURCE NO. DESCRIPTION PRIORITY DEPT DUE DATE DOCUMENT C0lWEENTS 051 Respond to Groundwater / Settlement NRC TBD Reg II audit received Audit by MAEC-90/0113/
awaiting NRR report 052 GL 88-01; Respond to Additional NRC TBD Awaiting NRC letter NRC TS Concerns on Drywell Leakage per MTI-90/012 Monitoring 053 Pressure / Temperature Curve for NRC TBD AECM-90/ Awaiting TS Amendment RG 1.99, Rev. 2 0048 054 LLRT Requirements on Vent / Drain NRC TBD AECM-88/ Awaiting TS Amendment Valves 0177 M9005161.2/SNLICFLR - 6
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. l RECENT KEY ENTERGY OPERATIONS SUBMITTALS l AECM # DAIE SUBJECT I AECM 90/0047 03/26/90 UPDATED SERVICE LIST (EFFECTIVE MARCH 1, 1990)
AECM 90/0058 03/30/90 SECURITY BOUNDARY UPGRADE AECH-90/0060 03/30/90 STATION BLACK 0UT RULE, 10CFR50.63 1 AECM 90/0050 04/06/90 PROPOSED AMENDMENT TO THE OPERATING LICENSE (PCOL-88/03) (TS 3.0.4 FLEX 1BILITY)
AECM 90/0062 04/16/90 HIGH GROUNDWATER ELEVATION AECM-90/0065 04/18/90 UPDATE ON DESIGN DEFICIENCY THAT COULD AFFECT LONG TERM POST-LOCA CORE SPRAY (LER 90-003-01)
AECM-90/0063 04/23/90 GENERIC LETTER 88 01: ADDITIONAL INFORMATION REGARDING GGN'.i IGSCC PROGRAM AECM 90/0048 04/26/90 PRESSURE TEMPERATURE LIMITS (PC0i.-90/06)
AECM-90/0068 04/26/90 CRITICALITY ANALYSIS FOR CYCLE 5 AECM-90/0056 04/27/90 ALTERNATE DECtY HEAT REMOVAL SYSTEM AND LPCI MANUAL REALIGNMENT (PCOL-90/03)
AECM 90/0079 04/30/90 SUPPLEMENTAL
SUMMARY
REPORT - DETAILED CONTROL ROOM DESIGN REVIEW AECM-90/0041 04/30/90 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING BORAFLEX GAP ANALYSIS AECM 90/0003 05/04/90 LOAD HANDLING CONTROLS (PCOL-89/02, REVISION 1)
AECM-90/0040 05/04/90 RWCU SYSTEM ISOLATION ACiUATION INSTRUMENTATION l (PCOL-90/02)
AECM 90/0067 05/04/90 RESPONSE TO GENERIC LETTER 89-19: REQUEST FOR ACTION RELATED TO RESOLUTION OF UNRESOLVED SAFETY ISSUE A-47 l
AECM-90/0085 05/04/90 SINGLE ACTIVE FAILURE DURING TESTING COULD CAUSE BREACH OF CONTROL ROOM ENVELOPE (LER 90-005) i AECM 90/0086 05/04/90 AMENDMENT N0. 65 TO FACILITY OPERATING LICENSE REGARDING TRANSFER OF OPERATIONS TO ENTERGY OPERATIONS, INC.
AECM # A Q.Al[ E!)g.(1 AECM 90/0074 05/07/90 CONTROL ROOM EMERGENCY FILTRATION SYSTEM REQUIREMENTS (PCOL-90/05)
AECM 90/0083 05/08/90 HIGH GROUNDWATER ELEVATION AECM 90/0078 05/09/90 SUBMITTAL OF FIRE HAZARDS ANALYSIS, REVISION 4 AECM-90/0072 05/09/90 SERI RESPONSE TO NRC SER ON AUDIT OF PIPE SUPPORT i CALCULATIONS AECM 90/0089 05/17/90 IMPROVED TECHNICAL SMCIFICATION DEVELOPMENT PROGRxM AECM 90/0088 05/18/90 FINAL RESPONSE TO GENERIC LETTER 89 04, GUIDANCE ON DEVELOPING ACCEPTABLE IllSERVICE TESTING PROGRAMS i
AECM 90/0093 05/23/90 PROPOSED AMENDMENT TO THE OPERATING .lCENSE (PCOL-88/03) (G.L. 87-09)
AECM-90/0001 05/'J1/90 50.59 SAFETY EVALVATION ANNUAL REPORT JUNE 1,1989 THROUGH DEC. 31, 1989 AECM 90/0012 05/31/90 STANDBY LIQUID CONTROL SYSTEM SPECIFICATION 3.1.5 (PROPOSED AMENDMENT TO THE OPERATING LICENSE -
PCOL 89/03, REV. 1 AECM 90/0102 05/31/90 IMPROVED TECHNICAL SPECIFICATION DEVELOPMENT PROGRAM AECM 90/0051 05/31/90 PCOL 90/01 NEUTRON MONITORING AECM-90/0103 06/06/90 CRITICALITY ANALYSIS FOR CYCLE 5 AECM 90/0104 06/06/90 AMENDMENT C5 TO OPERATING LICENSE REGARDING TRANSFER TO ENTERGY OPERATIONS AECM-90/0094 06/07/90 UPDATED SERVICE LIST AECM 90/0097 06/11/90 SECURITY BOUNDARY UPGRADE AECM 90/0092 06/11/90 PCOL 90/07 CYCLE 5 RELOAD AECM 90/0106 06/11/90 OPERATIONAL QUALITY ASSURANCE MANUAL REV. 9 i
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l NL SUBMITTAL FORECAST j NEXT 90 DAYS j I
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SUBMITTAL DESCRIPTION TARGET SUBMITTAL _DATE J
- 2) Reg. Guide 1.97/NMS Revised PCOL 06/20
- 3) Boraflex Gap OBE Surveillance 06/20 1
- 4) Physical Protection Plan 06/22 >
- 5) ADHRS Comment Resolution 06/22
- 6) GL 90-04; Generic Safety Issue Resolution 06/29
- 8) CCSA; 10CFR50.71(e) Annual Submittal 06/29
-9) Monthly Operating Report 07/13 4
- 10) NRCB 90-01; Rosemount Transmitters 07/18 s
- 11) HDSF Storage Rack Restriction 07/18 ;
- 12) Revise VPN0 Title in TS 07/18
- 13) Certification of Available Decommissioning Funds 07/26
- 14) Semi-Annual Environmental Protection Program 07/31 -
Reports
- 15) 2nd Quarter Security Safeguards Event Log 07/31
- 16) Relocation of Fire Protection TS GL 89-01 07/31
- 17) Monthly Operating Report 08/15
- 18) Semi-Annual Effluent Release Report (,0/30
- 19) NMS Quarterly Status Reports 08/30
- 20) Hydrogen Control Quarterly Status Report 08/30 4
l Enclosure 3 l
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Licensee Coments >
on Staff's Draf t Safety Evaluation of the GGNS-1 Fire Protection Program
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~ M U6 g() AECM 90/0044 Pasa 1 cf 22 h/ls/70 Section 2.2 - Discussion (Fire Area 1)
Excerpt: "The calling, floor, and all walls are complete 3-hour fire rated barriers, except for the interfaces with stairs and elevators, which are 2-hoar fire rated".
Comment: The floor and some walls are nonrated exterior barriers. The previous excerpt should be revised to address those walls and the Auxiliary Building floor slab which are nonrated exterior barriers.
Excerpt: "The average fire load in Fire Area 1 is equivalent to a 15 minute severity with a maximum of a 30 minute fire severity for one fire zone".
Comment: The average fire load in Fire Area 1 is less than 15 minutes and the eaximum fire severity in any zone is less than 45 minutes.
Excerpt: " Fire detection is provided through the area and partial automatic sprinkler system coverage exists in zones containing Division 1 and Division 2 safe shutdown cables".
Comment: The previous excerpt implies that fire detection is provided throughout Fire Area 1. Fire detection is not provided throughout Fire Area 1 but is provided in the fire zones which contain safety-related components.
Section 2.2.1 - Fire Zone IA101 (Fire Area 1)
Excerpt: " Fire Zone 1A101 forms part of a perimeter corridor within the Auxiliary Building. At one end of this fire zone there is a fire rated barrier, whereas, the other end is open into adjacent Fire Zone 14117".
Comment: Fire Zone 1A101 is open into adjacent Fire Zone 1A114 to the south and open into adjacent Fire Zone 1A117 to the north, thus the above statement describing the fire rated barrier at one end of Fire Zone 1A101 should be corrected.
Excerpt: "The fire load in Fire Zone IA101 is low and equates to a fire severity of 15 minutes".
Comment: The combustible loading in Fire Zone 1A101 amounts to less than a 30 minute fire duration.
FIRECMTS/SCIVFLR - 1
.. . Attachme;t 1 AECM 90/0044 Paga 2 cf 22 Section 2.2.2 - Fire Zone 1A117 (Fire Area 1)
Excerpt: "The average fire load in this fire zone is equivalent to a 15 '
minute severity".
- Comment: The combustible loading in Fire Zone 1A117 amounts to less than a 30 minute fire duration. The previous excerpt should be revised to indicate that the combustible loading in Fire Zone 1A117 amounts to less than a 30 minute fire duration.
Excerpt: " Fire detection is provided throughout the zone and partial area sprinkler protection is provided west of a Column Line 5.5". ,
Comment: Partial sprinkler coverage is provided in that portion of Fire Zone ,
1A117 that is east of column line J.5, thus the above statement describing sprinkler protect 4on " west of 5.5" should be corrected.
Section 2.2.3 - Fire Zone 1A120 (Fire Area 1)
Excerpt: " Fire Zone 1A120 is positioned next to Fire Zone IA117 and separates it from Fire Zone 1A114. Fire Zone 1A120 contains no safe shutdown cables and offers a 90 foot separation space between redundant cables located in Fire Zones 1A117 and 1A114. The average fire load is low (15 minute fire severity) and consists of five cable trays".
Comments Fire Zone 1A120 separates Fire Zones IA117 and 1A114 by anIn than l
90 feet. The combustible loading in Fire Zone 1A120 amounts to less l than a 30 minute fire duration and the major contributor to this combustible loading is electrical cable.
Section 2.2.4 - Fire Zone 1A114 (Fire Area 1)
Excerpt: "The separation distance to the redundant division in Fire Zone 1A117 is about 106 feet, which includes the space in Fire Zone IA120".
Comment: As discussed in the Fire Area 1 analysis of the FHA, Fire Zone 1A120 separates Fire Zones 1A114 and 1A117 by a distance of more than l 90 feet. Since exact separation distances between redundant divisions located in Fire Zones 1A114 and 1A117 are not delineated in the FHA, the statement above should be revised to read "more than 90 feet" in lieu of "about 106 feet".
FIRECMTS/SCIVFLR - 2
Att0thment 1 AECM 90/0044 l P 33 3 cf 22 )
gection 2.3 - Evaluation (Fire Area 1)
Escorpt: "However, the fire load is low and consists cf IEEE Std 383 l qualified cable insulation. There is no fire loading on the floor, !
except for the possibility of a transient exposure fire". )
Comment: Relative.ly small quantities of insitu combustible other than IEEE 383 cabling are located in Fire Area 1. The previous excerpt I should be revised to indicate that the fire load is low and consists primarily of IEEE Std. 383 qualified cable insulation. Similarly, there is no sinnificant fire loading on the floor, except for the possibility of a transient exposure fire.
Excerpt: "Also, the actuation of the fire detection system throughout Fire Area 1 would alarm and summon the fire brigade".
Comment: This implies that automatic fire detection is provided throughout Fire Area 1; however, fire detection is provided only in zones containing safety-rrlated equipment. (Ref. Section 2.2 comments).
FIRECHTS/SCIVFLR - 3 l
L l.
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Attothment 1 AECM 90/0044 Pa33 4 cf 22 Section 3.2 - Discussion (Fire Area 2) l Excerpt: " Finally, the Auxiliary Building walls on elevations 185 and 228 feet are 3-hour fire rated since they are also the containment wall".
Comment: The sentence above could be misconstrued to mean that all walls on Elevations 185'-0" and 228'-0" are 3-hour rated barriers. According ,
to the FHA the only 3-hour rated fire barrier on Elevations 185'-0" '
and 228'-0" is the containment wall. l
.]
Excerpt: "Of the 30 fire zones in Fire Area 2, only 14 have safe shutdown I equipment or cables".
Comment: Fifteen of the 30 fire zones in Fire Area 2 contain safe shutdown equipment or cables; therefore, the previous excerpt should be -
revised.
Excerpt: " Group C currently contains both Division 1 and 2 safe shutdown system components in Fire Zone 1A305.... All Division 2 cables in Fire Zone 1A305 are provided with 3-hour fire rated barriers *
(wrapping). However, by letter dated July 31, 1986, the licensee indicated that the Division 2 cabling would be eliminated from Fire Zone 1A305 and therefore, this fire zone would be in compliance with Appendix R".
Comment: The proposed modification described in AECM 86/0209 dated July 31, 1986 for Fire Zone 1A305 has been completed. Per the FHA, Fire Zone 1A305 contains only Division I safe shutdown system components. The above st.atement should be revised to reflect that Group C Fire Zones, explicitly Fire Zones 1A305, 1A204, and 1A224, only contain Division I safe shutdown system components.
Excerpt: "The highest fire severity in Fire Area 2 is 65 minutes as represented by the ASTM E-119 fire test curve".
Comment: The highest fire severity in Fire Area 2 is less than 60 minutes.
Excerpt: " Fire protection in Fire Area 2 includes fire hose stations and-fire extinguishers throughout the area".
Comment: The above statement could be misconstrued to mean that fire hoses and extinguishers are provided within all fire zones of Fire Area 2.
Fire Zones IA439, 1A440, 1A441, IA442, 1A506, and 1A508 are not I
provided with hose stations or portable fire extinguishers. The previous excerpt should be revised to indicate that hose stations and L extinguishers are strategically located.
FIRECMTS/SCIVFLR - 4 T , = , - - :---- - - - - - - - - . e. _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
Atta:h:ent 1 AECM 90/0044
. Pass 5 cf 22 ,
section 3.3 - Evaluation - (Fire Area 2)
Excerpt: "The four groups of fire zones in Fire Area 2 are separated from '
each other by 3-hour fire rated barriers, except for the steel blowout pansis".
Comment: Fire Area 2 can be subdivided into four groups, thr e of which are located within the Auxiliary Building proper and the remaining group ,
is located in the Enclosure Building. The three svoups located '
within the Auxiliary Building are separated from each other by 3-hour rated barriers except for the steel pressure .elief panels. However, the group consisting of those fire zones located within the Enclosure Building communicates with each of the other three groups through-nonrated concrete barriers of the blowout shaf ts.
l Excerpt: "The fire zones within Group C are separated by nonrated barriers and contain both Division 1 and 2 safe shutdown components. All of the Division 2 safe shutdown components in Croup C are located in Fire Zone 1A305 and these cables will, by a design change, be eliminated from this Fire Zone (IA305)". l Comment: The aforementioned design change for Fire Zone 1A305 has been completed. Per the FHA, Fire Zone 1A305 only contains Division I safe shutdown system components. The above statement should be revised to reflect that Group C Fire Zones (IA305, IA204, and 1A224) only contain Division I safe shutdown system components.
Excerpt: "The nonrated steel pressure relief panels located in the north and south walls and the floor of Fire Zone 1A125 (blowout shaft) are the only means of communication between Group A and C fire zones".
Comment: The FHA states that Fire Zone 1A124 is communication means between Groups A and C, not Fire Zone 1A125.
Excerpt: *fne closest Division 1 and 2 safe shutdown components are located in Zones 1A204 and 1A105. These components are separated horizontally by more than 30 feet for any of the communication paths between Fire Zones 1A105 and 1A204".
' Comment: Per the FHA, the closest Division I raceway in Fire Zone 1A204 to the closest Division II raceway in Fire Zone 1A105 is provided with a horizontal separation distance of more than 20 feet for any of the communication paths between Fire Zones 1A105 and 1A204. The abeta statement should be revised to reflect a horizontal separation distance of "more than 20 feet" in lieu of "more than 30 feet".
I FIRECMTS/SCIVFLR - 5
Att:chment 1 )
AECM 90/0044 l Pass 6 ef 22 l (Section 3.3 Continued) ;
Excerpt: "However, the incompleteness of the fire barriers is due only to l the 1-3/4" inch steel blowout panels, which are unrated, but offer substantial passive resistance to the spread of fire".
1 Comment: As previously mentioned in this section, the groups of fire zones located within the Enclosure Building communicate with the three -
groups located in the Auxiliary Building through the nonrated concrete barriers of the blowout shafts.
Excerpt: "In the specific case of Group C Fire Zones, which is the only group to contain redundant divisions, all Division II cables will be rerouted out of this fire zone, therefore, the concern for redundant divisions in this area to be damaged is mitigated".
Comment: The aforementioned design change for Fire Zone 1A305 has been completed. Per the FHA, Fire Zone 1A305 only contains Division I safe shutdown system corponents. The above statement should be revised to reflect that Group C Fire Zones (1A305, 1A204, and 1A224) only contain Division I safe shutdown system components.
Section 3.4 - Conclusion (Fire Area 2)
Excerpt: " Based on the above evaluation, the staff concludes that the existing fire protection measures, separation distances, steel blowout panels, and 3-hour fire rated barriers and the rerouting of Division 2 cables out of Fire Zone 1A305, provide a level of fire protection equivalent to the technical requirements of Section III.G.2.a c f Appendix R. Therefore, the deviation for Fire Area 2 should be granted".
Comment: The rerouting of Division II cables out of Fire Zone 1A305 could be omitted since this is historical fact (Ref. Section 3.3.
Comments).
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Attacha:nt 1 AECM 90/0044
, Pass 7 cf 22 Section 4.2 - Discussion (Fire Area 6)
Excerpt: "The average fire load in Fire Area 6 is a 40-minute fire severity and, in one Fire Zone (1A201), it is 60 minutes as represented by the ASTM E-119 fire test curve".
Comment: The average fire load for Fire Area 6 is less than 60 minutes in lieu of 40 minutes as stated above and in one Fire Zone (1A201), it is less than 75 minutes.
Section 4.3 - Evaluation (Fire Area 6)
Excerpt: "Until the fire was extinguished, the low fire load in the fire zones, the 1-hour fire barrier wraps on both divisions within Fire Zone 1A211, separation distances of more than 28 feet, and the IEEE Standard 383 qualified cable insulation provide reasonable assurance that the fire would not threaten redundant safe shutdown system components simultaneously".
Comment: Per the FHA, Division I and II safe shutdown couponents that are not protected with barriers in Fire Zone 1A211 are separated from each other by 26 feet. Previous statements made in Section 4.3 -
Evaluation also reflect this 26 foot separation distance. The above statement should be revised to read "more than 26 feet" in lieu of "mors than 28 feet".
FIRECMTS/SCIVFLR - 7
- - r Att0:he::t 1 AECM 90/0044 Pago 8 cf 22 Section.5.2 - Discussion (Fire Area 11)
Excerpt: "An automatic sp'rinkler system is provided for both Fire Zones 1A301 and 1A321 .
Comment: The previous excerpt implies that automatic sprinkler protection is provided throughout Fire Zones 1A301 and 1A321; however, partial I coverage is provided in each of the two zones.
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Excerpt: " Fire Zone 1A322 contains both Division 1 and 2 components and I these redundant divisions are separated by 23 feet. The only j combustible in this separation space is lube oil contained within three plant-chilled water system chillers and two enclosed cable i trays". '
B Comment: Cabling located within the :wo enclosed cable trays is not postulated to be contributing combustibles. Therefore, the two enclosed cable trays shoulf not be considered as intervening >
combustibles.
Section 5.3 - Evaluation (Fire Area 11)
Excerpt: "The principal concern with the level of fire protection in Fire Area 11 was that because of the lack of an area-wide fire suppression system and spatial separations between redundant safe shutdown system components that are not free of intervening combustibles, a fire of significant magnitude could develop and spread through the spatial separations and, thus, jeopardize the safe shutdown capability. The primary fire load is composed of IEEE Std. 383 qualified cables. The 25 gallons of lube oil in the chillers located in Fire Zone 1A322 is contained within metal casings".
Comment: Per the FHA, Division I and II safe shutdown components located in Fire Zone 1A322 are separated by 23 feet with no intervening electrical combustibles. Also, Division I and II safe shutdown components located in Fire Zone 1A316 that are not provided with fire rated barriers (wraps) are eparated by 25 feet. The intervening combustibles within this separation distance consists of IEEE Std. 383 qualified cable installed in accordance with the separation requirements of Reg. Guide 1.75. For clarity the above statements
- should be revised similarly to the following
FIRECMTS/SCIVFLR - 8 l
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. Att0:hment 1 AECM 90/0044 >
Pago 9 cf 22 l (Section 5.3 Continued)
"The principal concern...and, thus jeopardize the safe shutdown capability. The primary fire load in Fire Zone 1A316 is composed '
of IEEE Std. 383 qualified cables. The primary fire load in Fire l'
Zone 1A322 is the 25 gallons of lube oil in the chillers which is contained within metal casings. The only intervening combustibles within the 25 foot separation distance described for Fire Zone 1A316 are IEEE 383 qualified cables. The only intervening '
er .bustible within the 23 foot separation distance described for FA.e Zone 1A322 is the lube oil contained in the chillers".
Excerpt: "In Fire Zones 1A316 and 1A322 which contain redundant divisions, the 1-hour fire rated barriers (wraps) on both Division 1 and 2 cables and the sprinkler system coverage provide assurance that one division of safe shutdown system components will remain free of fire damage".
Comment: (See preceding comment on Section 5.3). Per the FHA, the only intervening combustible within the 23-foot separation distance described for Fire Zone 1A322 is the lube oil contained within the '
chillers and no fire barriers (wraps) are provided for redundant divisions of safe shutdown components. In Fire Zone 1A316, wraps are provided for both divisions of safe shutdown components within the described 25 foot separation distance. For clarity, the above statement should be revised to reflect that wraps on both Division I and II cables are provided in Fire Zone 1A316.
FIRECMTS/SCIVFLR - 9
Att3th:ent 1 AECM 90/0044 Pago 10 cf 22 Section 6.2_- Discussion (Fire Area 19)
Excerpt: "For ecse of discussion, the fire zones in Area 19 can be classified into three separate groups (1, 2, and 3)."
Comment: The fire zones in Fire Area 19 are classified as Groups A, B, and C ,
by the FHA. To eliminate confusion and retain consistency, Section ;
6.2 Discussion should be revised to address Groups A, B, and C in lieu of Groups 1, 2, and 3.
Excerpt: " Group 3 consists of Fire Zones 1A431, IA437, 1A438, 1A444, 1A523, 1A524, 1A525, 1A527, 1A528, IA529, 1A530, 1A531, 1A532, 1A533, 1A534, IA536, 1A537, 1A602, 1A603, 1A604, and 1A606".
Comment: (See also preceeding comment on group labeling). Fire Zone 1A519 is listed in the Group C Zones by the THA and has been omitted from the above statement.
Excerpt: " Fire Area 19 la bounded by 3-hour fire rated barriers and nonrated exterior barriers. However, the exterior barriers are of reinforced concrete and would qualify as 3-hour fire rated barriers.
The only exceptions to the 3-hour rating are the stairwells and '
Elevator No. 3 enclosures, which wre 2-hour fire rated".
Commenn: Fire Area 19 consists of fire zones located in the Auxiliary and Enclosure Buildings. The exterior barriers of the Auxiliary Building are of reinforced concrete and would qualify as 3-hour fire rated barriers; however, the exterior barriers of the Enclosure Building are metal and would not qualify as 3-hour rated barriers.
Excerpt: " Group 1 communicates with Group 2 through nonrated barriers and with Group 3 through nonrated hatchways between the floors".
Comment: (Sze also previous comment on group labeling). According to the FHA, Group A communicates with Group B through nonrated barriers and open boundaries.
FIRECMTS/SCIVFLR - 10
AttO: brent 1 AECM 90/0044 Pass 11 cf 22 (Section 6.2 Continued)
Eacorpt: " Fire Zone 1A417 contains both divisions of safe shutdown components.
Between column line G.4 and 21 feet west of G.4, both divisions are ,
protected with a 1-hour fire rated wrap. Unprotected portions have l a 21 foot separation free of intervening combustibles".
Comment: Per the FHA, all Division I and II safe shutdown cable and raceway j located between Column Line G.4 and 23 feet west of G.4 are protected ;
with a nominal I hour fire barrier. The above statement should be revised to reflect this "23" foot distance in lieu of a "21" foot distance. j l
l Excerpt: " Fire Zones IA523, 1A519, and 1A525 are located on Elevation 185 feet and do not contain any safe shutdown components. These fire I zones are separated from the fire zones located on Elevation 166 feet .
I by 3-hour rated fire barriers, except for two nonrated hatches in the floor at Elevation 185 feet. These hatches interface with Fire Zone 1A427 and 1A428, which contain safe shutdown components".
Comment: Per the FHA, Fire Zone 1A427 does not contain any safe shutdown components.
Excerpt: "The intervening combustibles between these hatches consist of IEEE Std. 383 oualified cables. The hatches are constructed of steel or concrete and steel and offer substantial physical barriers against the spread of fire and heat".
Comment: The FHA states that the intervening combustibles between the hatches r on Elevation 185'-0" (Fire Zones 1A524, 1A527, 1A519, and 1A523) consist primarily of IEEE-383 cable.
Excerpt: "All fire zones that contain safe shotdown components have fire detection systems and a majority c,f the other zones also contain fire detection systems. In addition,, fire hose stations and portable fire extinguishers are available throughout the area. In all fire zones, the fire severity is considert.bly less than the fire rating of the existing barriers and, in no case, is the fire severity more than 60 minutes as-represented by the ASTM O-119 fire test curve".
Comment: The fire zones which contain safe shutdown components are provided with fire detection; however, of the remaining 29 fire zones only 12 are provided with fire detection. Twelve of 29 zones does not constitute a majority. Additionally, hose stations and fire extinguishers are not provided throughout the area. No hose stations '
are provided in Fire Zones IA525 or 1A537. Portable fire extinguishers are not provided in Fire Zone 1A525. Finally, the greatest fire severity duration for Fire Area 19 is less than 75 minutes in lieu of 60 minutes as mentioned in the excerpt.
FIRECMTS/SCIVFLR - 11
Att:ch::nt 1 AECM 90/0044 i' Pass 12 cf-22 (Section 6.2 Continued)
Excerpt: "Until the fire is extinguished, the spatial separations and high ceilings, the 2- and 3-hour fire rated barriers and 1-hour fire rated barrier wraps, the IEEE Standard 383 qualified cable insulation, the partial area sprinkler systems, and the absence of fire loading on the floors provide reasonable assurance that a fire would not i threaten redundant safe shutdown system components simultaneously.
- It is expected that any fire would rensin small and would be easily extinguished by the fire brigade".
Comment: The phrase, " absence of fire loading on the floors" implies that no r combustible loading exists. This phrase should be refashioned in such a way as to indicate the absence of sinnificant fire loading.
Section 6.4 Conclusion (Fire Area 19)
Excerpt: " Based on the above evaluation, the staff concludes the existing fire detection and sprinkler systems in fire zones having redundant safe shutdown system components separated by a distance of 21 to 115 feet (with minimal intervening combustibles) provide a level of fire protection equivalent to the technical requirements of Appendix R,Section III.G.2.b. Therefore, this deviation should be granted."
Comment: The 21 foot separation distance mentioned in the above statement is the separation distance described for Fire Zone 1A417 (it is actually 23 feet - see previous comment on Fire Zone 1A417). No exc tion was filed for 1A417 nor was one required. For clarity, the above statement should be revised to reflect separation distances of "more than 110 and more than 115 feet" in lieu of the "21 to 115 feet" described.
FIRECMTS/SCIVFLR - 12
N . Attach:ent 1 AECM 90/0044 l Pago 13 cf 22 ]
l section 7.2 - Discussion (Fire Area 25) l Excerpt: "The deficiencies related to lack of 20-feet separation distance j for each of these combinations of safe shutdown train components was '
corrected by the licensee." )
Comment: The previous statement should be revised to address the " Exception" in lieu of the deficiencies. The " exception" for Fire Area 25 related to a lack of 20 foot separation distance for each of these combinations of safe shutdown train components and the necessary corrections that were provided by the licensee. As detailed in AECM 86/0190 dated July 24, 1986, the combination of the fire protection provided for Fire Area 25, modifications to achieve literal compliance, and the proposed exception will ensure that safe shutdown capability will not be precluded for a fire in Fire Area 25.
Excerpt: "The licensee stated during the June 18, 1986 meeting that the analysis of this fire area would be revised to reflect the availability of the 20 SRVs and, that these valves fail in a safe position. By letter dated July 24, 1986, the licensee docketed the above information".
Comment: AECM-86/0190 dated July 24, 1986 dockets the above information, however, SERI did not commit to revise the FHA and no discussion was made of these valves failing in a " safe position". What is explained by this AECM is that these SRVs can be opened with power from either division so that loss of one division of control power to an SRV does not compromise depressurization capability for that valve.
Excerpt: "The fire severity based on the fire loading in Fire, Area 25 ranges from 15 minutes to less than 60 minutes as represented by the ASTM i
E-119 fire test curve".
Comment: The fire severity in Fire Area 15 ranges from 15 minutes to less ther 90 minutes in lieu of 15 minutes to 60 minutes as stated above.
FIRECMTS/SCIVFLR - 13
Attechner.t I h ASCM 90/0044 Pass 14 cf 22 Section 7.3 Evaluation (Fire Area 25) ,
Escorpt: "The availability of 20 SRVs, of which only six are required, mitigates the concern for fire damage to redundant SRVs because of the arrangement and spacing of all of the SRVs. Only two SRVs could be damaged by any one fire leaving 18 SRVs intact." AECM 86/0190 dated July 24, 1986 explains that besides the six " safe shutdown SRVs" an additional fourteen valves could be utilized to achieve depressurization but does not state that a fire within 1A112 would not affect more than 2 SRVs".
Comment: The conclusion that only two SRVs could be damaged by any one fire is an NRC conclusion and is not based on the System Energy submittal.
Since this conclusion is not supported by analysis, it should be '
deleted.
Section 7.4 - Conclusion (Fire Area 25)
Excerpt: " Based on the above evaluation, the staff concludes that the existing fire protection and the licensee's modifications result in Fire Area 25 being in compliance with Section III.G.2 of Appendix R.
Therefore, this deviation is not required."
Comment: This is an NRC conclusion and is not based on the licensee's submittals. It is the licensee's conservative opinion that in addition to the modifications described in AECM 86/0190 dated July 24, 1986, this exception is required.
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- -
- Attachment 1 l AECM 90/0044 Page 15 cf 22 Section 8 2 - Discussion (Fire Area 42)
Excerpt: " Fire Area 42 contains 21 fire zones located on elevations 133 feet through 177 feet. The floor, ceiling, and walls of Fire Area 42 are either 3- or 2-hour fire rated barriers, except for the nonrated exterior doors of Fire Zone DC309". .
Comment: To enhance clarity, it should be indicated that Fire Area 42 contains 21 fire zones located on Control Buildina Elevations 133'-0" feet through 177'-0" feet.
Excerpt: " Seventeen of the 21 fire zones in Fire Area 42 do not contain any ,
safe 1hutdown components. The other four fire zones (OC302, 0C303, OC308 and OC402) contain both Division 1 and 2 safe shutdown system Compo!ents".
Comment : Fer tne FRA, fourteen of the 21 fire zones in Fire Area 42 do not contain any safe shutdown components. Four fire zones (OC302, 0C303, DC308, and OC402) contain both Division I and II safe shutdown system components. Fire Zones DC406A, DC518A, and OC613A contain only safe t shutdown ductwork.
Excerpt: "Four AHU/EF trains exist. A minimum of two trains are required '
for proper ventilation. There are two complete sets of equipment in Fire Zone DC303. The Z77 ductwork does not cross Fire Zones DC302/00303 room boundary".
Comment: There are two complete sets of equipment in Fire Zone OC303 and two complete sets in Fire Zone OC302. The above excerpt only describes i the equipment in Fire Zone 0C303.
s Excerpt: " Fire Zone 0C308 is separated from Fire Zones DC302 and OC303 by 2-hour fire barriers, and all three zones have a postulated combustible loading equal to less than 15-minute fire severity".
Comment: Fire Zones OC302 and OC303 each hava postulated combustible loading of less than 15 minutes while Fire Zone OC308 combustible loading amounts to less than 30 minutes.
l FIRECMTS/SCIVFLR - 15 1
-g - ~ - _ - - - , - - . - - . -- ___m .._ _ _ . _ _____ ______.____.__.U
Attothment 1 AECM 90/0044 Pago 16 ef 22 l (Section 8.2 Continued)
Excerpt: "Other fire protection features are in the form of smoke detection systems in all zones having safe shutdown systems components. Fire extinguishers and hose stations are also available throughout the '
area".
Comment: Smoke detection is provided in all fire zones containing safe :
shutdown system components except Fire Zones DC406A, 518A, and OC613A which only contain safe shutdown ductwork. Fire extinguishers and hose stations are provided throughout Fire Area 42 except in Fire Zones DC412A, OC507C, OC518A, OC603B, and OC613A (HVAC Chases).
Encorpt: "The fire severity, based on zone fire loadings, ranges from 0 to 90 minutes as represented by the ASTM E-119 fire test curve.
However, for Fire Zones 0C302, 0C303, and 00308, the fire severity is only 15 minutes. In Fire Zone DC402, the fire severity is 60 minutes, but this zone has two automatic fire suppression systems on an area-wide basis".
Comment: Fire zone fire durations range from 0 to less than 120 minutes. As previously mentioned, the firt duration in Fire Zones DC302 and OC303 are less than 15 minutes each while the postulated fire duration in OC308 is less than 30 minutes. ihe ;vstulated fire duration in DC402 is less than 75 minutes.
Section 8.3 - Evaluation (Fire Araa 42)
Excerpt: "The main concern with the level of fire protection in Fire Area 42 was that because of the lack of complete 3-hour fire rated barriers between redundant divisions, a fire of significant magnitude could develop and damage redundant divisions of safe shutdown system components. However, in the fire zones containing safe shutdown divisions, the fire load is low and coverage of two fire suppression
~
systems is available. In no instance within this fire area is the fire severity more than 90 minutes and, hence, less than the fire rating of the area / zone barriers throughout Fire Area 42".
Comment: The previous excerpt could be misconstrued to state that coverage by two automatic fire suppression systems is provided in all fire zones containing safe shutdown divisions when automatic coverage by two fire suppression systems is provided throughout Fire Zone OC402.
Additionally, the greatest fire severity within Fire Area 42 is less than 120 minutes, hence, it is less than the fire rating of the fire area barriers. -
FIRECMTS/SCIVFLR - 16
Att:chme:t 1 AECM 90/0044
, Paga 17 cf 22 :
(section 8.3 Continued)
Excerpt: "If a fire were te occur in any of the four groups of fire zones, the staff expects that it would develop slowly, and remain small with low heat release and slow rise in area temperature".
Comment: The previous mentence refers to four groups of fire zones within ,
Fire Area 42, however, the FHA only describes three groups. One group with no safe shutdown, one group with both Division I and II safe shutdown, and one group containing safe shutdown ductwork. The statement could be revised to indicate that a fire anywhere within Fire Area 42... slow rise in area temperature.
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Attachment 1 AECM 90/0044 Pago 18 cf 22 Section 9.2 - Discussion (Fire Area 50)
Excerpt: " Fire Area 50 is separated from other plant areas by 3-hour fire rated barriers, except for interfaces with stairwells and an elevator, which are 2-hour fire rated. The only fire zones in Fire Area 50 that contain safe shutdown system components are Fire Zones DC503 and 0C504. Essentially, this is the control room area for Unit 1".
Comment: The only fire zones in Fire Area 50 that contain safe shutdown system components are Fire Zones 0C503, 0C504, and 0C617. Fire Zones OC503 and OC504 are essentially the Control Room for Unit 1. Fire Zone OC617 contains only Division I safe shutdown cable and raceway and is separated from other fire zones by 2-hour walls and 3-hour ceiling and floor. No fires are postulated within or adjacent to Fire Zone OC617 which exceed the fire rating of the floor, ceiling or walls of this zone.
Excerpt: " Fire Zone 0C504 contains redundant divisions; however, all Division 2 components are protected with a 3-hour rated barrier".
I Comment: Fire Zone 0C504 consists of the space above the Control Room suspended ceiling and does contain redundant divisions of safe shutdown cabling, however, due to implementation of the Alternate Shutdown System modifications, no fire barriers are provided for the redundant divisions of safe shutdown cabling located in Fire Zone .
0C504. The previous excerpt should be revised to reflect that no fire barriers are provided, nor required, due to the availability of the Alternate Shutdown System as described in the FHA.
Excerpt: "However, the licensee has provided an alternative safe shutdown system. The licensee will provide isolation transfer switches for compliance with Section III.G.3 and III.L of Appendix R. The alternative safe shutdown room will be indep'endent of the control room area after the first refueling outage.
Comment: This statement should be revised to reflect that these modifications are complete.
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Attachment 1 ;
AECM 90/0044 Pago 19 cf 22 ;
Sectfan 9.4 - Conclusion (Fire Area 50)
Excerpt: " Based on the above evaluation, the staff concludes that the existing fire protection features in conjunction with the proposed modifications by the first refueling outage and the alternative shutdown capability in the aforementioned fire area provide a level of protection equivalent to the technical requirements of Section III.G.3 of Appendix R."
Comment: This statement should be revised to reflect that these modifications are complete.
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1 FIRECMTS/SCIVFLR - 19
Att chment 1 ,
. P:33 20 cf 22 Section_10.2 Discussion (Fire Area'59) I Excerpt: " Fire Area 59 comprises manhole MH01, which has four compartments".
Comment: As described in the FHA, Fire Area 59 is the yard which includes all components outside of the power block, including those underground. The above statement should be revised to reflect that Fire Area 59 "contains" manhole MH01.
Excerpt: "The fire load within Fire Area 59 is low, consisting of IEEE Std 383 qualified cables. A fire hydrant is about 50 feet away from manhole MH01".
Comment: As previously mentioned, the above statement should be revised to 4 describe the fire load within Manhele MH01 in lieu of Fire Area 59. l l
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FIRECMTS/SCIVFLR - 20
Attech:ent 1 !
Pago 21 cf 22 Section 11.3 - Evaluation (Raceway Supports) l Excerpt: "The calculated deflectier, cuased by the loss of a support is minimal and the overlapping of wraps by 4 inches allows for this deflection without impairing barrier". l Comment: The word " caused" is incorrectly spelled. This statement should be revised to indicate that knowool fire barriers are overlapped by 4 inchos.
Safety Evaluation Report (Appendiz R)
Excerpt: "Also in SSER No. 1, the staff stated that for a control room fire, the RCIC system, safety / relief valves and one division of the RHR system would be controlled from the remote shutdown panel (alternate shutdown capability). This alternate shutdown capability was to include isolation switches at the remote shutdown panel f'.r RCIC, one ADS valve and one division of RHR".
Comment: Section 9.5.6 of SSER No. I does not aention a specific number of ADS valves required. However, Section 9.4.2 of the SER and the FHA both indicate that a minimum of six ADS valves are required.
Excerpt: 1. ADS valves - a minimum of six valves will be available either in the control room or at the remote shutdown panel; i
- 2. RHR system trains A and B - Suppression pool cooling, alternate shutdown cooling and LPCI modes;
- 3. Standby service water system trains A and B; i 4. Standby diesel generators A and B;
- 5. Emergency core cooling system (ECCS) rooms ventilation (HVAC);
- 6. Standby service water pumphouse HVAC;
- 7. Diesel generator rooms HVAC;
- 8. Remote shutdown panel system; and
- 9. Electrical distribution systems for the above equipment.
L Comment: The list of required saf6 shutdown systems should be expanded to include "ESF Switchgear Room HVAC" and " Safeguard Switchgear and Battery Room HVAC". Item No. 8 of the existing list should be changed to read " Remote and Alternate Shutdown Systems" and Item No.
9 should also specify" (Portions of L11, L21, L51, R20, and R21)".
FIRECMTS/SCIVFLR - 21
I.. j , -
f Att:thrent l' AECM 90/0044
. 'Pago 22 ef 22 General consent:
- 1. For consistency, reference to Divisional components should be indicated' by Roman Numerals I and/or II in lieu of Arabic Numerals 1 and/or. 2.
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i ah 'g FIRECHTS/SCIVFLR - 22
, ! ,'i ' ' Attachment 2 AECM-90/0044 p Page 1 of 2 KEY REVISIONS TO THE GGNS FIRE HAZARDS ANALYSIS FROM 1985 THROUGH 1990 ,
1985 FRA Submittal ~
The Fire Hazard Analysis (FHA) was submitted on May 7 1985 reflecting and evaluation which compared the Grand Gulf Fire Protection Program with the positions of Appendix R. This FRA bore Bechtel Specification Number '5026-M-500.0, Rev. 1.
1986 FHA SUBMITTAL A revised FHA was submitted May 7, 1986 bearing MP&L Specification Number M-500.0,.Rev. O. This revision of the FHA reflected the following changes:
o Preparation under the controls of NPE Administrative Procedures in lieu of Bechtel Procedures, i o Revisions to the combustible heat load calculations.
o Updetad informatien due to completion of the Fire Area 25 analysis.
1987 FHA SUBMITTAL Revision 1 of the FHA was submitted on April 7, 1987. The following changes were incorporated:
o Ai.brnate shutdown system completed.
o Three hour fire barriers were not provided on safe shutdown raceway in f 's Zone OC504 due to implementation of alternate shutdown, o Automat (c sprinkler protection was provided in Fire Zones 1A417, ,
1A424, and 1A428.
o Various fire zones not provided with automatic fire detect' ion were identified to include safety-related piping and valves, o Power supply for the RPS sensors, trip unit Neutron Monitoring System, Nuclear Steam Supply Shutoff System, Leak Detection System, and Process Radiation Monitoring System was changed from RPS BUS to Class IE UPS.
o Fire Zone 1A603 was revised to reflect-the presence of a non-rated hatchway.
o Revisions to the combustible heat load calculation.
M9004121/SCIVFLR - 1
. .r .
Attachment 2-AECM-90/0044 Page 2 of 2 1988 FHA SUBMITTAL-Revision 2 of the FHA was submitted May 11, 1988 and incorporated the i following. changes:
o Deletion of the 2-hour rating for various walls within Fire Area 26; the north, south, and east walls of Fire Zone OC305; and the wall separating Fire Zone 0C603 and 0C614, 1989 FRA SUBMITTAL Revision 3 of the FHA was submitted on May 5, 1989. The following ~
changes were incorporated:
?
o Smoke detection added in Fire Zone IA430.
o The wall separating the Unit I and 2 Control Room spaces was relocated, o Deleted the 2-hour fire rating for the walls of Fire Zone 00110.
o Fire Area-59 (Yard) was revised to reflect the presence of the newly constructed Modification and Engineering Facility.
1990 FRA SUBMITTAL Currently, the FHA is at Revision 4 which was submitted on May 9, 1990. ;
The following changes were incorporated.
I o Installation of the Alternate Decay Heat Removal System (ADHRS).
The ADHRS'was added to a list of safety-related equipment in the FHA.
o Installation of an access hatch in a pipe chase. The FHA was 1 revised to include a description of this limited access.
2 1
l M9004121/SCIVFLR - 2
1,. t I
il .
l' Enclosure 4
- o 10 CFR 50.59' Analysis of the use of Low Pressure Coolent Injection Hozzles for Shut? awn Cooling 3
5 i
o 2
w
. ,, j CRAND CULF NUCLEAR STATION UNIT ONE CHANGE. TESTS OR EXPERIMENTS -
[* SAFETY EVALUATION FORM PART-I - CENERAL I
ll Originator: 1. J. Vrisht Evaluation No: CFRMISC0086R00 M f g R 99/0036 Document Evaluated: . _ _ . - _ _ mp m- 2-p !
Revision: 0
References:
GCNS T.S. 3/4.4.9 and 'SAR F Figure 5.4-18,15.2.15, 3/4.9.11 15.2.18 SCEJ 89/162- SEGE 88/0892 FSAR Seetions 15.1.5,15.2.9, AECM 89/0042 4.7, 5.4.7 i
SER Section 5.4.2 l Attachment =
0 ..l
p
Description:
Two primary return flowpaths are used for each division of RMR i
shutdown cooling. One return path is to the core shroud via the feedveter A or 3 lines, and the other is to the upper containment pool. To facilitate future i outage maintenance which will make these normal return paths unavailable, l another flowpath, not described in the FSAR, will be used. This flowpath will l
utilize RHR LPCI A and B injection piping to return cooled reactor water to the vessel. Except for the new injection point, the proposed flowpath is-identical to the RRR shutdown cooling flowpath discussed in FSAR Section 5.4.7. Note chac this discharge path is used by the alternata. shutdown cooling mode described in SER Section 5.4.2 and shown in FSAR Figures 15.2.15 s,nd 15.2.18.
This 10CFR50.59 evaluation addresses the proposed new flovpath for e7 shutdown cooling.
I The proposed use of the LPCI A and B 11oes for RER shutdown cooling return will be limited to the following conditions of operation during Modes 4 and 5:
- 1. Flow- '
8100 gym (Max.)
, RPV Water Temperature 140 'T LPCI Water Temperature 70 *F l Maximum Temperature Differential 70 'F L' Duration 14 Days l
Cycles 60
- 2. Flow 8100 gym (Max.)
RPV Water Temperature 200 *F LPCI Water Temperature 90 'F-Maximum Temperature Differential 110 *F Duration 15 Minutes e--
Cycles 60 l Analyses have been performed to verify that the proposed operation will not r have an adverse effect on the LPCI A and 8 nozzles, flow deflectors, and thermal shields. The results of the studies show that the increase in usage factor for the flow deflectors, thermal shields, and nozzles is negligible and remains below design allowables. Also, ASME Code stress NVPCFP CFRMISc0086R00 Form 316.1, Rev. 5 Page 1 of 5
I 4 . 4 ]
]
limits are not exceeded. The analyses are documented in SCEJ 89/162. In 1
addition, the design pressure and temperature for the LPCI A and 8 piping will not be exceeded by the proposed operation.
Fuel movement in the vicinity of the LPCI A and B nogales during the )
proposed RER shutdown cooling operation will be limited to that described j in SEGE 88/089 for the LPCI C nozzle (for Alternate Decay Reat Removal' 1-System operation). ^
As discussed in AECM 89/0042, adequate core circulation is provided by
- () natural coolingcirculation whenvessel.
to the reactor the LPCI lines are used to return RER shutdown 4
- Part - II - SAFETT ANALYSIS REPORT / TECHNICAL SPECIFICATIONS FOt C::ange Required? [ I ] Yes [ ] No CRf..
y fooqs
.0 1 A99)
(If Yes) lo a- I ,
~
Technical Specification Change Required? [ ] Yer ( I ] No CRf (If Yes)
PART - III - TECHNICAL SPECIFICATIONS ,
_ TES I NO Implementation or performance of the acet described in the evaluated document will require a change to the GGNS Unit One Ta ;al Specifications.
Re . J The requirements for residual heat removal are discussed in Technical Specifications 3/4.4.9 and 3/4.9.11. Use of the proposed flowpath would meet all Technical Specification requirements for shutdown cooling operation during Modes 4 and 5..
Therefore, no Tech. Spec. chanies will be required.
PART - IV - UNREVIEWED' SAFETY QirESTION Implementation or performance of the action described in the evaluated document will:
YES X NO 1. increase the probability ot' occurrence of an accident previously evaluated in the FSAR.
BASIS: The following accidents were determined to be applicable to the proposed use of LPCI A and B piping for return of RER shutdown cooling flow to the reactor vesselt
- a. Failure of Shutdown Cooling - The proposed flovpath only involves a NWPCFR CHtMISC0086R00 Form 316.1, Rev. 5 Page 2 of 5
.. r -l i
change to the final injection path:
- for shutdown cooling flow. All other shutdown cooling . functions (i.e. ,
interlocks, suction piping, pumps, best exchangers....) are the same as previously described in the FSAR.- >
The flow parameters for the. proposed i flovpath are within the original design. limits. No new failure modes are introduced, therefore, the frequency classification of this accident is not increased.
Y
- b. Inadvertent' Shutdown Cooling Operation - This Accident is relative to safe 3 .mly if the reactor is not-in a shurdown mode and is operating at or near criticality. giace the. ,
proposed flowpath will only be used -
~
in Modes 4 and 5, the reactor will not be returned to criticality 'during this operation. Therefore, the t L
I accident frequen,cy elassiff tation will not be increased.
Since the frequency classification o T for applicable accident scenarios is not increased and the original design specificaticas are not azeeeded, the proposed operation will not increase the probability of an accident previously evaluated i's the FSAR.
TES I NO 2.' increase the consequences of an accident previously evaluated in the FSAR.
BASIS: The LPCI piping which will be p
used in the proposed flovpath is part of the emergency core cooling system used for accident mitigation as described in FSAR Chapter 15. This piping is designed for pressures and temperatures which bound the proposed operation. In addition, the usage factors for the LPCI nomsles, flow deflectors, and thermal-shields remain below design allowables.
Because of this, the LPCI responi.:. to an-accident would not be affected, and there would be no increase in the consequences of an accident previously evaluated in the FSAR.
b:
c l
1 NWPCFR CTPMISC0086R00 Form 316.1, Rev. 5 Page 3 of 5 L
l
L
,\
increase. the probability of a malfunction I M3~ 3.
TES- -
L of' equipment'important to safety previously evaluated in the FSAR. 4 L
BASISt. The proposed flovpath for RER L shutdown cooling does not exceed ' original 1 L design specifications for_ the RER system -
L and the reactor vessel for the conditions L noted above.- The' flow parameters are s within the design limits for the LPCI *
, piping. In addition, the LPCI nostles s .
L flow deflectors, and thermal shields were rsviewed and it was found that fatigue O~ usage factor remains below code e.llowable.
t-Since all original design requirements are !
I met, no increase in tha probability of--
occurrence of a malfunction of equipment previously evaluated in the=FSAR will result.
- l YES 1 No 4. -increase =the consequences of a a t
malfunction of equipment important to
- safety previously evaluated in the FSAR.
BASIS: The LPCI piping will not be used -
in a manner different than that for which l_ it was designed.: The design conditions for this flovpath are not. exceeded and no '
new failure modes are introduced. For this res. son, there is no increase in the coast.quences of a malfunction of' equipment important.to safety previously evaluated in the FSAR.
TIS I No 5. create the possibility of an accident of a different type than any already evaluated in the FSAR.
BASIS: _ The LPCI piping vill not be used in a manner different than that for which it was designed. The design conditions a for this flowpath are not exceeded and no new failure modes are introduced.
Therefore, the use of this flowpath will not create the possibility of ;an accident of a different type than any already' evaluated in the FSAR.
NWPCTR CFRriSC0086R00
' Fora 316.1 Rev.=5- Page 4 of 5
k6 c; ,
(,
s YES: .I NO 6. crea;4 the possibility of s'aalfunction of equipment taportant'to safety .
, different than previously. evaluated in=
the FSAR.;
BASIS: The LPCI piping will not be used -
in a manner different then that for which:
it was designed. The design conditions' for this flovpath'are not exceeded and no new failure modes are introduced. The.
L_ -use of the LPCI flowpath will not change the' design function of RER for shutdown
(. cooling to the extent that it would-place-
- . the system in a mode which could lead to 1 a possible malfunction outside-the I
! -existing boundary of FSAR analysis.
l Therefore, the-use of this flovpath will 1 not create the possibility of a malfusetion of equipment of a different type than any previously evaluated iniche ,
FSAR.
L YES X N0 7. reduce the margin of safety as definedL in the basis for any technical specification.
BASIS:- When RER-shutdown cooling is- 1 operated through the proposed flovpath, '
l s ' sufficient core decay heat removal.and.
aJ.zin will be provided. -This has been demonstrated by actual use of.this flovpath during RF03. Therefore, the-
! margin' of safety as established in the basis of the, Technical Specifications has j not been degraded.
f 0 '- 1 -M Evaluated sy/Date
'l Reviewed / Approved /P/. M. _r: /d/4 /89 Supervisor /Date Reviewed / Approved: 10 4 87
?rt cipal Engineer /Da e Reviewed / Approved i Responsible ManaSer/Date FLANT SAFETY REVIEW CONNITTEE REVIEW Reviewed / Approved:
Chairman, PSRC/Date NVPCTR CFRMISC0086R00 Form 316.1 Rev. 5 Page 5 of 5
- - ~ ~ - -
neR Cunct Rtomanar - --- ----- 7 g -. . .. .
NPE CRANGE REQUEST NW!BER: NPEP'SA R: 19/0058 .
NUCLEAR LICENSING SCR NUNSER:
ADVANCE' CHANGE REQUEST: _ YES [ NO_ '
i Docth!ENT IDENTIFICATION NWISER:_ N/A
^
UNIT APFLICABILITY: I GGNS Unit One l
'GGNS Unit.Two l Both Units 1
JUSTITICATION/ NECESSITY FOR CHANGE: -SKs PAca 2 o F 2 .
I 1 4
SUBJECT OF CHANGE: A6h A bELMCAIPrievd oF RMA 5MarbotAM CoottNo RETOAtd TMAoucR TME Lec t A i a 1N 3'ECT roAt '
LihlE G _
' ATTECTED TSAR PAGES, TASLES, AND. FIGURES: PAGE 6.1-If . 7. 4 = 16 .
- 7. 4 - l 7 f. 4 - 57 * -
I
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I!! PACT ON TECN. SPECS. : _ YE'. NO ,
~
SATETY EVALUATION (10CTR30.39) ATTACHED: IYES NO
+
_ ORIGINATOR: '
A .
10*1-Ii ,
'N y ' DATE ,
l REVIEVER: h. J. 1Eb_
/04/P9 G OUP SUPERVISOR DATE APPROVAL: --
10 4 U PRINCIPAL ENGINEER 0 ATE ATTACWfENT:
Sefefy Salarfiar7 M. CFRM!Sc00BC 800 l .
I~
~NPE FORT! 021/03-16-87
V%'Ac N ca 1
- a.m.* .
UFSAR CHANGE REQUEST 'j
.c HPEFShk 89 /00S T l 1
Justification / Necessity for Change: I Two primary return flowpaths are used for each division of RER shutdown cooling. One return path is to the core shroud via the .
feedwater A or a lines, and the other is to the upper containment I pool. To facilitate future outage maintenance which will anke these normal return paths. unavailable, another flowpath, not described in the FSAR, will be used. B is flowpath will utilise RER LPCI A and 3' injection piping to return cooled reactor water to.the vessel. Bis ,
method of shutdown cooling mode operation was reviewed and found '
acceptable for limited use. (SEGE-89/014,PMI-89/00561,PMI-89/01339, PMI-89/00021, PMI-89/01743, MhEC-89/0084).
The UFSAR does not currently discuss normal shutdown cooling mode with injection' through the LPCI lines. The change to pages 7.4-16 and 7.4-17 are necessary to accurately describe the various.
aethods of operating the shutdown cooling mode of RER. Sa' change to
! page 6.2-85 is an editorial change that establishes cons *.r**ncy with UFSAR section 3.6.2.2 and Figure 3.6A-6. , ,
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UFSAR I
/
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, U' connseto to the reactor pressura vassol via ths BPCS injsetion line.' In addition to two check valves inside the drywell,-a check valve and an explosive-actuated valve-are located outside the drywell. . The explosive-actuated valve provides: an absolute 'i seal for long-term leakage control as well as preventing 2)
, leakage of sodium pentaborate into the reactor pressure vessel during normal reactor operation. I 1
6.2.4.3.1.1.7' RER Shutdown Cooling Return Lines !'
The RER shutdo V
line return line pene_trates _the containmen i 2
and the drywel 1scharge31nto the feedwater linef - 4<* s.4sc{wd/g
,. 6.2.4.3.1.1.8 Recirculation Pump Seal Water Supply Line The recirculation pump seal water line extends from the recir-1 # "'
culation pump through the drywell and connects to the CRD (g.2.4.3././!
supply line just inside the containment. The recirculation
- pump- seal water supply line does not penetrate the containment j gF jg.j :
and, therefore, is not subject to the. General Design Criteria- /s,/M,w, ,
concerning containment isolation.
4 gg 6.2.4.3.1.2 Effluent Lines /,, es .
Effluent lines which form part of the reactor coolant pressure boundary and penetrate containment, drywell, or both are O equipped with at least two isolation valves, one inside the drywell and the other outside the containment and located as close to the containment as practicable.
6.2.4.3.1.2.1 Main Steam, RER and RCIC Steam Lines
- The main steam lines extend from the .'sactor pressure vessel to the main turbine and condenser system, penetrating both the drywell and containment. The main steam drain lines also pene-L trate both the containment and the drywell. The RER steam I
supply line and the RCIC turbine steam line connect to the main steam line inside the drywell and penetrate both the drywell and containment. For these lines, isolation is provided by automatically actuated block valves, one inside the drywell and
, one just outside the containment.
6.2.4.3.1.2.2 Reactor Water Cleanup System Lines The reactor water cleanup (RWCU) system is located between the containment and drywell; however, the RWCU pumps are located in the auxiliary building. The suction line from the recircu-lation system penetrates the drywell and containment walls.
i Two autcmatically u tuated isolation valves, one located inside the drywell and one outside the containment, are provided to
, prevent releases to the auxiliary building; both valves are located as close to their respective walls as possible.
{'
FSAR UPDATE NPE- 91-a3 % 6.2-85 Rev. 3 12/88 CM 3'94-
e vi^in
\ 1 . w. ".
gy F$AR UPDATE ;
7.4.1.3.1.2 Classification yJgfy _
L Electrical . nodules- for the reactor shu+ dam ennling ande af th.
l- residual heat removal system are classified as safety class 3 E and seismic category I.
! 7.4~.1.3.2 Power Sources This system utilizes normal plant power sources. These include 4160 V ac, 480 V. ac,120 V ac instrument busses, and de sources.
If for any reason the normal plant sources become unavailable, F
the systam is designed to utilize onsite power sources since the RER system has safety modes of operation (e.g., LPCI) ossociated with this equipment.
7.4.1.0.1 Equipment Design L, i 7.4.1.3.3.1- General i The reactor water is cooled by taking suction from one of the recirculation. loops; the water is pumped through the system heat exchanger and back to the reactor vessel via the feedwater ,
l l lines. Part of the flow can be diverted to a nozzle.in the vessel head to provide for head cooling. The function of head
- g cooling it to condense steam generated from the hot walls of the ves:sel while it is being flooded, thereby keeping system
( A/
pressure cown.W During the initial phase of the shutdown cooling mode,-only a portion of the RER. system heat exchanger capacity is required. This allows the remaining portion of the RER system with its heat exchanger, associated pumps, and I
valving to be available for the suppression pool cooling mode.
If it.is necessary to discharge a complete core load of reactor <
fuel to the fuel pool, a means is provided for making a physical l
intertie between the spent fuel pool co and clean-up-system and the RER heat exchangers. reases the cooling l capacity of the spent fuel pool cooling clean-up system to ,
handle the heat -load for this situation.
7.4.1.3.3.2 Initiating Circuits u
The reactor shutdown cooling system is initiated by manual operator actions. There is no requirement for automatic-control.
~7.4.1.3.3.3 Logic and Sequencing The following reactor shutdown cooling operating sequence is utilized:
- a. The RER valving is aligned for. shutdown cooling mode
- b. The recirculation loop suction valve is opened 7.4-16 Rev. O
. .e [ A' L 'Ia. '{' .
- c. The RER heat Oxchangers arG linQd up for water-WatGr:
heat transfer-
[
l 7.4.1.3.3.4 Bypasses and Interlocks Interlocks are provided, as shown in Table 7.4-2, to prevent opening the reactor shutdown cooling valves except under. proper conditions.
The two pER pumps used for shutdown cooling are interlocked to trip if the reactor shutdown cooling valves and suction valves from the suppression pool are not properly pcsitioned.
, 7.4.1.3.3.5 Redundancy and Diversity The reactor shutdown cooling system contains two loops.- Either-loop is sufficient to satisfy the cooling requirements for shutdown cooling. A diverse method of shutdown cooling is provided by the alternate shutdown cooling mode, which is actually an extension of the LPCI mode. To establish the alternate mode, the normal shutdown cooling loop is bypassed by manually switching to take suction water from the suppression pool and manually opening the ADS valves to allow reactor water to flow back to the suppression pool. The ADS valves may be actuated by either- division 1 or division 2 power thus providing-redundancy in the event of a divisional power failure.
Refer to Chapter 15 and Appendix 15A for a _ system-level IHEA examination of the above operation. p y . --- ,
Although there is no instrumentation diversity requirement for the reactor shutdown cooling system, the design basis objective is achieved by two diverse shutdown cooling means.
7.4.1.3.3.6 Actuated Devices All valves in the shutdown cooling system are equipped with remote manual switches in the control room. Further discussion can be found in subsection 7.3.1.1.1 relative to the general 1
operation of the RER- system, including its other modes of operation.
7.4.1.3.3.7 Separation Since various subfunctions of the RER system perform safety-related action (LPCI and containment cooling), all of the-system equipment that is safety related satisfies the appropriate safety separation criteria (refer to section 7.3.1.1).
FSAR UPDATE
( $ f 4 9-6 $
60 J9H 7.4-17 Rev 0
E 4... C '
. Insert A' !
In addition, shutdown cooling flow may be returned to the reactor vessel through'the LPCI A or 8 lines. The use of LPCI A or 8 lines for shutdown cooling flow and LPCI C for the operation of alternate decay heat removal system is administrative 1y controlled to W operational-conditions sec( as flow ru es, maximum temperature differential, duration, cyclesangfuelmovementi.pthevicinityoftheLPCInomm1*=--?
5 alid4 fr$NiCf l*W flNeof M
~
JDs4 %fSNM $@fe)**d Insert 8 ' - --
The alternate shutdown cooling mode should not be confused'with injection through the LPCI lines during norsial shutdown cooling. (See Section 5.4.7.1.5 for additional detail on the operation of the alternate
. shutdown cooling mode.) In normal shutdown cooling the ADS valves remain '
closed and suction is taken from the recirculation loop.
i l i FSAR UPDATE "
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5.4;6.3 Performance Evaluation' l
The analytical- methods and assumptions in evaluating the RCIC l system- are presented-in Chapter 15,- Accident Analyses, and-Appendix 15A' to chapter 15, Plant Nuclear Safety Operational Analyses. The RCIC system provides the flows required from the analysis (see Figures 5.4-12 and 5.4-i3) within a 30 second interval based upon considerations not ed in subsection 5.4.6.2.4.
5.4.6.4 Preocerational Testino The preoperational and initial startup test program for the RCIC system is presented in Chapter 14, initial Test Program. l P l 5.4.6.5 Safety Interfaces The balance of plant-GE nuclear steam supply system safety
. interfaces for the reactor core isolation cooling system are:
~1) preferred water supply from the- condensate. storage tank;
',2) all associated wire, cable, piping, sensors, and valves rhich lie outside the nuclear steam supply system scope of supply; and (3) solec id actuated valve (s).
5.4.7 Residual Beat Removal System i 5.4.7.1 Desian Bases
(.~
The RER system'is comprised of three independent loops, each i loop contains.its own motor-driven pump, piping, valves, t
-instrumentation and controls. Each loop has a suction source j from the suppression pool and is capable of discharging water to the reactor vessel via a separate nozzle, or back to the-
- suppression pool via a full flow test line. In addition, the A i and B loops have heat exchangers which are cooled.by the standby service water system. Loops A and B can also take L suction from the reactor recirculation system suction' or fuel 4
! pool, and can discharge into the reactor via the feedwater l
line,4 fuel pool cooling discharge, or to the containment spray spargers. The A and B loops also have connections to reactor Lj steam via the RCIC steam line and can discharge condensate' to l the RCIC pump suction or to the suppression pool.
5.4.7.1.1 Functional Design Basis The RER system has five subsystems, each of which has its own functional requirements. Each subsystem shall be discussed separately to provide clarity.
FSAR UPDAT.-- c.
L.PC. t ' ' NPE89-03fl
'd# " i M li g y gy
( -
5.4-57 Rev. 2 12/87
. . - ., . -- -