ML20073E588

Revised Station Blackout Analysis

ML20073E588
Person / Time
Site:	Peach Bottom
Issue date:	04/30/1991
From:	PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
Shared Package
ML20073E585	List: ML20073E581 ML20073E588
References
NUDOCS 9104300302
Download: ML20073E588 (27)

Text

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.....-g ENCLOSURE 1

Peach Bottom Atomic Power Station, Unita 2 and 3 Revined Station Blackout Analysin 9104300302 91ru124 f,' DR AgoCK 05000277 PDR April 1991

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L TABLE OF CONTENTS Page Introduction 3 A. Prop.osed Station Blackout Duration

1. AC Power Design Characteristic Group . . . . . . 4

2. Emergency AC (EAC) Power Configuration Group . . . . 5

3. I'arget EDG Reliability . . . . . . . . . . . . . . . 6

4. Alternate AC (AAC) Power Source . . . . . . . . . . 6 B. Procedure Dee_cription

1. Off-site AC Power Restoration . . . . . . 7

2. Severe Weather . . . . . . . . . . . . . . . . . . . 7

3. Station Blackout Response . . . . . . . . . . . . 8 C. P_roposed Cop _irig Assessment

1. Condensate Inventory for Decay Heat Removal. . . . . 9

2. Class IE Battery Capacity . . . . . . . . . . . 10

3. Compressed Air . . . . . . . . . . . . . . . . . . 10

4. Effects of Loss of Ventilation . . . . . . . . . . 10

a. HPCI and RCIC Pump Room Analysis

b. Control Room Analysis

c. Cabla Spreading Room Analysis

d. Containment Analysis

e. Other Plant Areas

5. Containment Isolation . . . . , . . , , . . , , 14

6. Reactor Coolant Inventory . . . . . . . . . . . . 14

7. Equipment Quality Assurance . . . . . . . . . . . 14 D. Proposed Plant Modifications . . . . . . . . . . . . 15 E. Proposed Schedule to Implement _ Station Diackout Procedu_r_al Changes . . . . . . . . . . . . . . . 15 F. Attachments Figure 1 - Station One-Line Diagram Figures 2 Containment - Suppression Pool SBO Analysis Table 1 - Electrical Loads for Safe Shutdown - 2 EDGs Table 2 - Electrical Loads for Safe Shutdown - 1 EDG Table 3 - Operator Actions - 2 EDGs Table 4 - Operator Actions - 1 EDG Table 5 - Containment Isolation Valves i

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INTh0 DUCTION on July 21, 1988, the NRC amended its regulationn in 10CFR50. A new section, 50.63, was added which requires that each light-water-cooled nuclear power plant be able to withstand and recover from a station blackout (SBO) of a specified duration.

10CFR50.63 further required that each licensee submit the following information.

1. A proposed station blackout duration, including a justification for its selection based on the redundancy and reliability of the on-site emergency alternating current (AC) power sources, the expected frequency of loss of offsite power, and the probable time needed to restore effeite pm.ter.

2. A descriptica of the procedures that will be implemented for station blackout events for the duration (as determined in 1 above) and for recovery therefrom.

3. A list and proposed schedule for any needed modifications to equipment and associated procedures necessary for the specified station blackout duration.

The NRC also issued Regulatory Guide 1.155, " Station Blackout," (August, 1988) which describes a means acceptable to the NRC for meeting the requirements of 10CFR50.63. Regulatory Guide (RG) 1.155 states that the NRC has determined that the document issued by the Nuclear Utility Management and Resources Council, NUMARC 87-00, " Guidelines and Technical Bases for NUMARC Initiatives Addressing Station Blackout At Light Water Reactors," also provides guidance that is in large part identical to the RG 1.155 guidance and is acceptable to the NRC for meeting the requirements of 10CFR50.63. Table 1 to RG 1.155 provides a cross-reference between RG 1.155 and NUMARC 87-00 and notes where the RG takes precedence.

Philadelphia Electric Company (PECo) evaluated the Peach Bottom Atomic Power Station (PBAPS) in accordance with the requirements of the SB0 rule using guidance in NUMARC 87-00, except where RC 1.155 takes precedence. The results of this evaluation were submitted to the NRC as required by 10CFR50.63(c)(1) by our letter dated April 17, 1989. As a resul t of subsequent NRC reviews of licensee submittals and NRC discussion with NUMARC, NUMARC requested that we supplement our April 17, 1989 submittal to the NRC indicating that 1) our April 17, 1989, submittal was based on use of the NUMARC 87-00 guidance including recently provided clarifications, and/or 2) any deviations from the accepted NUMARC 87-00 guidance have been or will be clearly indicated. Also, we were to affirm our understanding that the emergency diesel generator (EDG) target reliability would be maintained. Accordingly, we evaluated our April 17, 1989, station blackout submittal with respect to the requirements of 10CFR50.63, including recent clarifications of the guidance in NUMARC 87-00, and submitted a revised SBO analysis to the NRC on April 3, 1990.

In our April 3, 1990 submittal, we verified that 1) our use of the NUMARC 87-00 guidance is consistent with the recent 1

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clarifications, 2) the applicability of the MUMARC 87-00 assumptions is documented, and 3) identified and described all departures from the accepted NUMARC 87-00 methodology.

The NRC revi ewed our April 3, 1990, station blackout submittal and issued a Safety Evaluation Report (SER) on August 8, 1990. In the SER, the NRC concluded that PBAPS, Units 2 and 3 do not conform to the station blackout rule and that a revised response should be submitted.

At an April 5, 1991 meeting with the NRC, we presented more detailed SB0 analysis information and changes to our previous submittals based on our March 12, 1991 commitment to manage the essential Design Basis Accident EDG loads to its cortected 2000-hour rating of 3000 kW, with one exception noted. Accordingly, this letter documents the information presented during this meeting as well as serving as a complete SB0 analysis for PBAPS, Units 2 and 3, superseding our April 3, 1990 and April 17, 1989 submittals.

The appliceble NUMARC 87-00 sections are shown in parenthesis.

A. P_ rop _o s e d_S t; a t i o n_B l a c k o u t_ Du r a t i o n NUMARC 87-00, Section 3, was used to determine a required coping duration category of eight hours. This section documents the plant factors that were identified in determining the proposed station blackout duration and the basis for the determination that an alternate AC (AAC) power supply is available to power safe shutdown loads during a SB0 event.

1. AC Power Design Characteristic Group is P2 based on the following.

a. Expected frequency of grid-related loss of offsite power (LOOP) events does not exceed once per 20 years (Section 3.2.1, Part 1A, p. 3-3).

b. Estimated frequency of LOOP cvente due to extremely severe weather (ESW) places the plant in ESW Group 3 (Section 3.2.1, Part 18, p. 3-4).

c. Estimated frequency of LOOP evento due to severe weather (SW) places the plant in SW Group 2 (Section 3.2.1, Part IC, p. 3-7).

d. The offsite power system in in the 11/2 Group (Section 3.2.1, Part 1D, p. 3-10).

Each of the two offsite power sources is stepped down from 13 kV to 4 kV through an emergency auxiliary transformer and is connected through interlocked circuit breakers to every 4 kV emergency switchgear bus (sea Figure 1). Every 4 kV emergency switchgear bus is energized from one of these two sources at all times during normal operation. Upon loss of one offsite power source, automatic transfer is made to Page 4 of 27

s the second source. Each offsite source can supply all engineered safeguard buses to ensure that all safe shutdown loads can be accommodated. Loss of both offsite power sources results in the automatic starting and alignment of the four shared EDGs and, therefore, by design affects both units. The loads are progressively and sequentially added such that core cooling, containment integrity, and other vital safe shutdown functions are maintained.

2. The emergency AC (EAC) power configuration group is "D" based on the following factors (Section 3.2.2, Part 2C, p.

3-13).

a. There are three shared EAC power supplies not credited as alternate AC power sources for the station (Section 3.2.2, Part 2A, p. 3-15).

b. Two EAC power supplies are necessary to operate safe shutdown equipment for both units for an extended period following a station loss of offsite power event (Section 3.2.2 Part 2B, p. 3-15).

All six cases for the various combinations of two EDGs have been analyzed to establish that the necessary safe shutdown loads for both units can be powered by the two EAC EDGs. Table 1 is a summary of the results of this analysis. Table 1 contains'the loading for all equipment that is required to maintain both units in long-term safe shutdown. By design Table 1 differs from Updated Final Safety Analysis Report Tablec 8.5.2c through 8.5.21, which list loads for a simultaneous Loss of Coolant Accident (LOCA) and LOOP. Since all battery chargers are powered by the two EDGs, redundant channels of safe shutdown Control Room instrumentation will be available. In addition, Table 1 contains some discretionary loads that are energized in the analyzed configuration, but are not required for safe shutdown. In all cases, the EDG loading is within its 2000-hour rating of 3000 kW.

A modest number of operator actions are needed to maintain both units in long-term safe shutdown with two EDGs available. Table 3 summarizes these operator actions.

The PBAPS, Unita 2 and 3 standby AC power supply system consists of four shared EDGs and eight 4 kV emergency auxiliary switchgear buses. Each EDG feeds one 4 kV bus per unit. Because all four EDGs are shared between the two units, the single f ailure criterion applies to the shared EDG system, not on a per unit basis. Therefore, since two EDGs are needed to power safe shutdown loads for both units, a third EDG satisfies the minimum redundancy requirement.

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3. The target EDO reliability of 0.975 will be maintained.

A target EDG reliability of 0.975 is justi fied based on having a nuclear unit average EDG reliability for the last 100 demands greater than 0.95, consistent wi th NUMARC 87-00, Section 3.2.4.

An EDO reliability program will be implemented to monitor and maintain the EDG target reliability of 0.975 utilizing the guidance in Regulatory Guide 1.155, Section 1.2. If the EDG performance falls below the target reliability l level of 0.975, action will be taken as required by the '

EDG reliability program to restore the affected EDG to the l target reliability 1cvel.

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4. An AAC power source will be utilized at the PBAPS to power safe shutdown loads for both units during a 5B0 event which meets the criteria specified in Appendix B to NUMARC 87-00. The AAC powor source is the remaining Class 1E EDG sinc i" EDG meets the assumptione in Section 2.3.1 of NUMce W!'00. That is, one EDG.is available to serve as the .,' Asring an SBO event after assuming that the requireu EAC power sources, accounting for single failure, are not available to power safe shutdown loads.

The AAC power source for the PBAPS utilizes the excosa redundancy of the EDG configuration. PBAPS has four EDGs

, shared between two units. A LOOP event or a station blackout affects both units at the same time (i.e., there is not one blacked-out unit and one non-blacked out unit).

Our station blackout analysis was performed based on both units.being blacked out at the same time, which is consistent with the design of the electrical distribution system at PBAPS.

A loading analysis has been performed which confirms that the EDGs can power the required safe shutdown loads while maintaining the appropriate voltage and frequency standards during a LOOP event. This analysis has identified loading conditions that must be met prior to the starting of a Residual Heat Removal (RHR) pump or a High Pressure Service Water (HPSW) pump. The reeults of the loading analysis are applicable to the loading of the l AAC power source.

In accordance with NUMARC 87-00, Section 2.4.1, the PBAPS AAC power source will be available to power necessary safe shutdown equipment within one hour of the onset of the i station blackout event. Any one of the four EDGs can be used as an AAC power source, and has sufficient capacity l and capability to operate systems necessary to shutdown i

both unita during a ntation blackout event.

An AC independent coping analysis was performed for the one hour duration prior to bringing the AAC power source on-line during an SBO event. This one hour coping l Page 6 of 27 l-

assessment confirmed that the plant emergency equipment ensures the safe shutdown of both units. The ene-hour period was used as the basis for the coping assessment.

It does not mean that all of the identified operator actions are required at exactly one hour into the station blackout event.

The EDG used as the AAC power source during a station blackout has the capability of powering safe shutdown systems and equipment to provide reactor vessel water level and pressure contrul, battery charging, selected room ventilation, selected emergency lighting, emergency service water, and necessary system controls and instrumentation. Table 2 is a summary of the EDG loading during the station blackout condition. This table shows the specific configuration for the E-1 EDG; however, this EDG loading is typical of the loading associated with the other three EDGs. All four EDGs, each serving as the AAC, were analyzed. Table 2 contains the maximum loading that could be powered by the AAC EDG; however, not all of the equipment loaded on the AAC EDG is required to maintain both units in a safe shutdown condition for the eight-hour coping duration. The required SBO safe shutdown equipment is annotated on Table 2.

A limited number of operator actions will be required to connect safe shutdown loads to the AAC EDG. Table 4 contains a summary of these operator actions.

B. P roc edu re_De sc r_ip ti on Plant procedures have been reviewed for SBO with the f ollowing results.

1. Off-site AC power restoration in accordance with NUMARC 87-00, Section 4.2.2.

a. System operation (i.e., the load dispatcher) procedure, " System Restoration following Complete Shutdown" establishes a priority for the load dispatcher for restoration of a transmission path to energize the PBAPS startup electrical power feeds,

b. Station procedure SO 53.7G, "Offsite AC Power Restoration following Loss of Grid" coordinates with System Operation restoration procedure and establishes a sequence of switching operations required to restore AC power via the normal station startup electrical power feeds.

c. Station procedure SE-11 " Station Blackout" will be revised to coordinate with SO 53.7G.

2. Severe weather restanse in accordance with NUMARC 87-00, Section 4.2.3.

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a. Emergency Response Proceduro ERP-101 requires an

" unusual event" to be declared in the event that a hurricane warning is issued from the load dispatcher predicting wind speeds of 75 MPH or greater at the station,

b. A new severe weather procedure will include the following actions.

1. Inspect the site for missile hazards and reduce such hazards, ii. Demonstrate EDG operability prior to the arrival of a hurricane, 111. Review station blackout procedures, iv. Review operability of Emergency Core Cooling Systems (ECCS) equipment.

v. Initiate emergency repairs, as needed, of ECCS and other selected systems required to cope with a blackout.

vi. Suspend appropriate surveillance test procedures.

vii. Evaluate the need for calling in additional personnel.

2. Station blackout response in accordance with NUMARC 87-00, Section 4.2.1.

a. SE-11 has been revised to address the use of security keys.

b. SE-11 will be revised to ensure that on-shift Operations personnel have guidance regarding the verification of isolation valves listed in Table 5, as appropriate.

c. SE-11 will be revised to address the maintenance of water inventory in the Condensate Storage Tank (CST).

d. SE-11 will be revised to address the location of portable lighting.

e. SE-11 will be revised to address the removal of selected ceiling tiles and the opening of selected control panel doors.

f. SE-11 will be revised to show tables for loading of EDGs as AAC power sources,

g. SE-11 will be revised to deenergize selected MCCs and non-essential equipment.

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4. SO procedures for starting RHR and HPSW pumps have been revised to address checking of existing EDG loading.

C. Proposed _ Coping _As_sossment The ability of PBAPS to cope with a station blackout event in accordance with RG 1.155, Section 3, and NUMARC 07-00, Section 7, has been evaluated using both NUMARC 87-00 calculations and non-NUMAU 87-00 calculations. Most of the evaluations used in the stata,i blackout assessment are non-MUMARC 87-00 computer or manual calculations. The simplified methodology of the NUMARC 87-00 calculations were not appropriate for most plant areas.

The coping assessment considered (1) the adequacy of the condensate inventory, (2) the capacity of the Class IE batteries, (3) the station blackout compressed air requirements, (4) the effects of loss of ventilation on station blackout response equipment, (5) the ability to maintain containment integrity, (6) the ability to maintain adequate reactor coolant inventory, and (7) the use of safety related equipment (i.e., equipment within the scope of our Quality Assurance Program).

1. Condensate _Invento.ry,_for_ Decay Heat _ Removal.(Section L2 l_).

Using the guidance provided in Section 7.2.1 of NUMARC 87-00, we have calculated that 166,713 gallons por unit of make-up water to the reactor vessel are required during the 8-hour station blackout event. The breakdown or make-up water is as follows: 117,066 gallons for decay heat removal; 17,280 gallons for recirculation pump seal leakage; 20,367 gallons for vessel level shrinkage when depressurizing the reactor pressure vessel; and 12,000 gallons for identified Technical Specifications allowed primary system leakage (25 gpm).

A calculation determined that a minimum of 100,018 gallons were available in the condensate storage tank for High Pressure Coolant Injection (HPCI) and Reactor Core Isolation Cooling (RCIC) system suction. Therefore, the difference between the total required condensate inventory (166,713 gallons) and the CST dedicated volume (100,018 gallons) is about 66,700 gallone. Assuming a minimum torus water level, we have determined that 66,700 gallons of additional make-up water corresponds to less than one foot of torus water level. Therefore, a combination of CST water and torus water is sufficient for the HPCI and RCIC system to provide make-up water to the reactor vessel during the station blackout coping duration. Note, each unit has a dedicated CST. Also, HPCI ana RCIC may be initially aligned with either the CST or the torus. Both alignments have been considered, and neither affects the safe shutdown analysis.

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2. Class _1E_ Battery _Capaci_ty_(SectiorL7 2 2.)

, The AAC power source energir.> the 125V battery _hargers within one hour of the onset of ntation blackout. These battery loads include power *:estoration from either the EAC EDG power supplies or the preferred offsite power source. A battery capacity calculation han been perfor ned in accordance with NUMARC 87-00, Section 7.2.2, to verify that the Class IE batteries have suf ficient capacity to meet station blackout loads for one hour without battery charging and for the subsequent seven hours with charging.

Operator actions are credited in this analynis at one hour to reduce the DC loading.

3. Compressed J r_(Section 7.2.31 )

Air-operated valven relied upon to cope with a station ,

blackout for eight hours have sufficient backup l air / nitrogen sources to perform their required functions or fail in the safe position. The Automatic Depressurir.ation System (ADS) valves are provided with a separate short-term, safety grado, pneumatic supply and also a long-term, backup, safety grade, pneumatic supply of nitrogen.

4. Ef fects of Loss of Verttila.tiorL(.Se_c tiord. 2_. 4) .. .

The AAC power source will provide ventilation to various areas within one hour of a station blackout event.

Certain of these areas will contain significant heat loads prior to the initiation of ventilation. Descriptions of the arttbient air temperature analyses for the identified dominant areas of concern are provided below, a, llPCI and kCIC Pump _ Room _ Analysis The initiation of a station blackout ev e t will result in an immediate reactor scram. soth IIPCI and RCIC systems will initiate on low reactor water level.

Within about 10 minutes into the transient, operators will secure the IIPCI system and une the RCIC syetem j to maintain adequate core cooling. The RCIC system l is designed to provide adequate make-up water to the l reactor vessel following reactor shutdown.

( Operability of the equipment in the !!PCI pump room is ensured by an analysis performed as part of the station fire protection analysis which calculates that the ambient air temperature will be about 156'E af ter four hours of IIPCI operation without I

supplemental cooling. This analysis demonstrates l

operability of flPCI room components at temperatures in excess of 156"F. Therefore, operation of the IIPCI system is verified for the short duration (about 10 Page 10 of 27

minutes) of the initiation of a etntion blackout event.

A non-NUMARC 07-00 analysis was performed to determine the renditing air temperature in the RCIC room during a station blackout event. The analysis assumed that the RC'C pump room cooler vauld not be operational for the first hour of the station blackout event. No credit was taken for improved ventilation by opening the doors leading out of the RCIC pump room. The RCIC pump room cooler comes on-line at one hour into the transient when the AAC EDG comes on line. The analysin shows the maximum air temperature in the RCIC pump room to be 145'F after one hour, at which point the room cooler comes on-line. The maximum RCIC pump room temperature after eight hours of RCIC operation is calculated to be 144"F. In this analysis only the safety-related components of the RCIC pump are assumed to be available. This analysis was performed without crediting the operation of the non-safety related gland son 1 condenser, which conservatively increases the room heat load. In addition, the operators will defeat the system high temperatures and low steam supply isolations to ensure long term availability of the RCIC and HPCI nystems.

The station fire protection analyses demonstrated equipment operability of RCIC system components up to 163 F for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This envelopes the RCIC pump room temperature profile for the eight hour station blackout event,

b. Con.ttol_Roo.m_ Analysis A non-NUMt.RC 87-00 analysis was used to calculate the ambient air temperatures in the shared Unit 2 and Unit 3 Control Room during a station blackout event.

Ventilation is lost in the Control Room for the first hour of the transient. Then the emergency ventilation system comes on-line when the AAC EDG is loaded. Heat loads included in the calculntions were obtained from existing Heating, Ventilation and Air Conditioning (HVAC) calculations. These heat loade accounted for the absence of AC powered lighting which would not be operational during a station blackout event.

At one hour into the station blackout transient, the Control Room temperature was calculated to be 105'E without room cooling or operator actions. With room cooling operational and operator actions to remove ceiling tiles one hour into the station blackout event, the resulting temperature af ter eight hours was calculated to be 118 F assuming conservative initial conditions. The initial Control Room conditions assumed a 76*F ambient temperature, 30%

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relative humidity, 95'F outside air temperature, and 105'F adjacent room temperature. Operator actions include removing selected ceiling tigen before control room tempera;are reaches 105 F to establish adequate crose ventilation. Alno, to ensure proper equipment operability, doors to Control Room cabinets containing shutdown equipment must be opened within 30 minutes of the start of the station blackout event,

c. C ab l e_S p r e a_d_i n.g_Ro om_ An a l ys i s A non-NUMARC 87-00 analysis was performed to determine the ambient air temperature in the cable spreading room during an 8-hour station blackout induced loss of ventilation, llent generation during station blackout is from operating electrical components such as 125 VDC power distribution panels, relays, and emergency lighting. The calculation predicted that the 8-hour loss of ventilation temperature would be 147'F.

The Arrhenius equation was applied to ensure the operability of the electronic components located in the cable spreading room which are needed to safely shutdown both unita during a SBO event. Based on our analysis, we concluded that the electrical components can reasonably be expected to operate at 147"F in the cable spreading room for at least the 8-hour period of the station blackout event,

d. Containment Anal,ysi_s A non-NUMARC 87-00 analysis was used to determine the primary containment (drywell) and suppression pool (totus) response to a station blackout event. The containment and suppression pool will hentup during the station blackout due to reactor decay heat and assumed primary system leakage. In accordance with NUMARC 87-00, a primary system leakage of 61 gpm was assumed. This includes 25 gpm identified leakage (i.e., maximum leakage allowed by Technical Specifications) plus 18 gpm leakagn from each recirculation pump seal.

The containtmnt and suppression pool analysis assumed that the RIIR torus cooling and RilR shutdown cooling modes of operation were not available during the station blackout event. No credit needs to be taken for torus pressurization in order to achieve and maintain safe shutdown during the SBO event and recovery. The resulting primary containment temperatures and pressures were eniculated to be 284 F and 40 psig, respectively, at eight hours into the station blackout event (see the attached Figures 4 and 5). The primary containment temperature of 284 F is less than the primary containment LOCA Page 12 of 27

qualification ter .rature. The resulting containment pressure of 40 psig is significantly less than the primary containment design pressure of 56 psig.

The suppression pool temperature and pressurn response to a station blackout event is shown in the attached Figures 6 and 7. The resulting prensure of about 30 poig is less than the denign supprension pool pressure which is 56 psig.

The integrated volume of water used from the CST to provide make-up water to the reactor vessel during the station blackout is shown in Figut e 8. The containment w ppression pool analyr's shows that the total water inventory requirement from the CST will be less than 90,000 gallons, which is lenn than the initial minimum CST inventory.

The containment and suppression pool analysin shows that tnere will be significant margin'between the suppression pool temperature heat capacity temperature limits (llCTL) during depressurization of the reactor vessel, lloweve r , the calculation indicates that at about seven hours into the transient and at 150 psig reactor pressure and 215"E suppression pool temperature, the llCTL will be reached and exceeded by about 8"F. However, this was concluded to be acceptable because a further analysis was performed which assumed reactor vessel depressurit',ation from 350 psig to zero reactor pressure at this point. The resulting containment pressure would be about 44 psig which is less than the containment design pressure of 56 psig. The attached Figures 2 through 9 summarize the calculated containment and suppression pool response to a station blackout event of eight hours.

e. Other Plant Areas increased temperature in-the steam tunnel at PDAPS does not affect any equipment necessary for safe shutdown during a station blackout. Therefore, it was not co'nnidered a possible dominant area of j concern and was not analyzed.

The EDG room was not analyzed for losn of ventilation-because room ventilation is provided when the AAC EDG

-comes on-line.

The electrical inverters are located in open areas l: throughout the plant. We determined that any heat generated from the inverters would have minimal thermal effect on the plant area. Thus, these areas

were not considered as a potential dominant area of i

concern.

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The emergency switchgear room and emergency morvice water pump rooms do not contain any equiptnent necessary to support safe shutdown during the first hour of the station blackout. These rooms have ventilation fans which become operational at one hour into the station blackout event when the AAC EDG comes on-line. Therefore, thene rooms are not considered a potential dominant area of concern.

A NUMARC 87-00 analysis was performed to determine the steady state operating temperature of the battery rooms. Heat loads in the battery roomn include the 125V DC batterien, 24V batteries. 250V distribution panels, and cables to batterieo. The NUMARC 07-00 calculation predicted the steady state room temperature to be 110"F. Since thin temperature is less than 120*F and room ventilation in provided at one hour into the transient thene battery rooms are not considered a potential dominant area of concern.

5. Containment _Isol_ation_(Secti_on 7.2 5)

The list of containment isolation valves for each unit has been reviewed to verify that the valven which munt be capable of being closed or that munt be operated (cycled) under station blackout conditions can be positioned (with indication) independent of the preferred and blacked-out station's AC power supplies. The attached Table 5 contains primary containment isolation valves that do not qualify for exclusion no defined in NUMARC 87-00, Section 7.2.5. Also, this list includes valven that are normally closed and that fail as-is. These valves can be accessed and verified as being cloned, as necessary during a station blackout, by mechanical position indication or by manually closing. Where applicable, the inboard and outboard valves have been identified; however, only one valve would be required to be verified in the closed position in order to ensure containment integrity.

6. Reag_ tor _ Cool ant _I nventi ory_.( Sec ti.on_2.. 5 )

The station batteries and the AAC nource power equipment necessary to maintain adequate reactor coolant nyntem inventory to ensure that the core in cooled for the required coping duration.

7. Equi pme n t_Qu a l i.ty_ As su ranc e.

Most of the equipment that is assumed to achieve and maintain safe shutdown of both units during a SB0 event is safety related and 1: covered by PEco'n Quality Annurance (QA) program as required by Appendix B of lOCFn50.

Station blackout equipment that is not safety-related will be maintained in accordance with the guidance of Regulatory Guide 1.155 Section 3.5 and Appendix A.

Examples of non-safety related station blackout equipment include the CST, CST water level instrumentation, and the Page 14 of 27

4 kV bus 00A19. 11 0 part of the 13kV system is needed for response to a SBO event.

D. Prpposed Plant Modifigations The guidelines in Regulatory Guide 1.155 nnd t.he methodology presented in the !1UMARC 07-00 document were used to veri f y.

proper operability of plant equipment during a station blackout event. Therefore, no plant equipment modifications are necessary to satisfy station blackout requirements specified in 10CFR50.63.

E. Etoposed Schedule to implement _ Station Blackout Procedural l

. Changes The future procedure changen identified in Parts A. B, and C of this submittal will be completed within one year after the notification provided by the Director. Office of 11uclear Regulation in accordance with 10CFR50.63(c)(3).

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V V V V o ,

0 2 4 6 s Time. Hour Figure 2 Peach Bottom Atc.mic Power Station Stotter. Dioc kout holysie 880 E60 -

s.O - \

520 -

500 -

480

-(

460 -

4 W 440 -

I h j 420 - 7 n

400 -

I 380 -

~~

360 -

l 340 -

{ '

l 320 O 2 4 6 3 Time. Heur Figure 3 l

l Page 17 of 27

Peoch Gottom Atomic Power Station Station ploc kout Arolysie 3 60 340 -

320 -

LOCA Test Profilo 3m - -

w 260 -

260 -

.I SDO Calculated Response 240 -

= J 220 -

sw -

160 -

1e -

140 -

9 G $ 1 1 1 1 0 0 2 4 6 8 Time, Hour F10uro'4 Peach Bottom Atomic Power Station SteHon Blackout Anotysle 45 40 -

36 -

30 -

l 2, -

E

o -

15 10 S

I t i f f I t 1 0 2 4 6 e Time, Hour Figuro 5 ,

i Page 18 of 27

_ . _ . . - . . - _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . _ ______._1.______ . _

^

. . . a 1 4

Peach Bottom Atomic Power Station Station Diocked Anolyste an -

. rw

/'

l too - Atmosphere i

160 -

170 -

160 -

]

• 160 -

)'

140 -

130 -

120 -

110 -

too -

' ' ' ' ' ' i-

so O 2 4 6 e Time. Hour Figure 6 4

Peach Bottom Atomic Power Station Stotion Bloc kout Ano6ysie i

j.!

JS' --

I go

$ 1 ts - .

l l 20 -

l 4.

T 15 -- . 1 10 -

8 -

l--

l 0 ' '

O 2 4 6 3 Time. Hour Figure 7 Page 19 of 27 i

J Peach Bottom Atornic Power Station Stotbn Diochi A AnoWe

~

90 BC .

• /c

• i c.o 3 ~

to -

d *

}d a ,, .

20 to

, , , , t i i 4 6 e 0 2 wa., sour .

Figure 8 .

Peach Bottom Atomic Power Station Etetion Blachout Anotysis 240

so - .

2:o -

210 -

20o - - HCTL

~

,; so -

g too -

N SBO Calculated Responte g

co -

K '

1:0 \

110 ico -

( ,

. ,, 0.6 C.B 1 1,2 0 0.2 0.4 *

(Thowsenes)

Reactor Pressure, pi.g Figure 9 i

i Page 20 of 27

- TABLE 1 SAFE SHUTDOWN LOADS DURING A LOOP BOTH UNITS 2 EDGs l

eat blESEL COMllNATION LOADIN6 $UMNARY DIEED.SEl4E2 1 I O!EEELSE_li.I4 DltiLLB E1 &_E3_ _ _ _

- - ~

E12 E13 E2 iYED i E12 E13 E3 f*JD I E12 E13 E4 BFJD I I TIOM Nip ~ifr~F4I6 1 iU6 I-~T06 T'TETFT- Wto ~~6~I4f 6-~~-

0 2 Core Spray Nip 9 0 0 1 0 0 0 1 0 0 632 I 602 1 602 0 fW 3 ip Service Wtr hp (1) 6t2 0 B22 0 T [iiT $erviee Wtr h p Th i e it$ 1 e- ~ 6 N$~l T~'~4 NS~~

0 1 0 0

$ CRD Pusp 8 0 0 1 0 0 0 0 1 0 0 0 6 Motor Operated Vivs 0 0 0 1 0 0 Tfeergency Lighting (1) (T 26 3f T 64 ff 7 4~l" f4 M 4F~

0 1 0 0 0 6 DG Jekt tool hun hp 9 0 0 1 0 0 1 Lube Oil Aux pump i i ST F ~T) I n 6-~ TIT-~~Tr~0 T l~'

TMTuiTEnTrDiirTD t Aftr Cool Aux Pop i i 0 1 0 0 0 la Du $ tart Air Cosp 9 0 0 1 0 0 Tik%VThiiTaifthrge 1 1 16 i T i 18~1 1 T 18 (3) 60 30 1!0 1 60 30 150 I 60 30 ito 12 125V Batt Chargers 13 Inst pc 4 LPS Invrte (2) E2 lb 25 1 22 16 25 1 22 18 5 TORW pusps 0 0 6 i ~1 0 e i I 6 0 15DrpellCoolerFans 0 0 0 1 0 0 0 1 0 0 0 16 Cntrl b Vent f ans (1) 0 0 10 1 0 0 10 1 0 0 10

~Ti:eiglgr 1 BiliTans (Il 6 ~6' il~l e~ b' 4I I 0 0-~~ll 21 1 0 0 21 1 0 0 El 18EstegSwgrExhFans (1) 0 0 19 Bat Rocs Exh Fans (1) 0 0 13 1 0 0 13 1 0 0 13

~S ~R Vnt & Pep Rs Fans it) 43 0 41 1 0 6 43 T ~~~0-~~ 6-~~43~

21 IUR Rs Cool () nits (1) 13 0 13 i 13 0 13 1 13 0 13 0 1 0 0 0 22IKIRstoolUnits 0 0 0 1 0 0 23 RCIC Rs Cool Units (1) 1 1 0 l 1 l 0~l 1 ~i 0 '

0 1 0 0 0 24 CS Rs tool thits 0 0 0 1 0 0 0 0 0 1 0 0 0 1 0 0 0

~

25 SGIS Exh Fans 0 l 0 0 0 i e 6 ~e 26 S615 Exhaust Htr 0 0 0 1 0 0 0 27SLCPuip B B e i 6 0 0 1 0 0 0 29 SLC Heater 0 0 0 1 0 0 46 8 0 0 1 46 6 0 0 l 40 -~0 f ti SW Vib I travl Scrn I I 8 Screen Wath Nip 37 20 74 1 37 20 64 1 37 20 64

~301P0/204V Vist his 61 0 0 61 0 0 0 31 plant Stack Dil Fan 0 0 32 Rn krea, Ref Flr 4 0 0 22 l 0 0 22 1 0 0 22 Ccip Htrs & Vnt Fns _l _ _ _ _

l 6

~33 H Skid Mtd Equip 8 0 0'I O 9 e i 0~ 6 0 1 0 0 0 34RirCcipressors 0 0 0 I e 0 74 0 l 6B 61 109 e 13 68 0 35 Mise Loads /Sys loss (2) 10) i 13 103 a 13 I i I 2613 103 TOT;t. 2613 lei I 2613 10) 2965 1 2722 2974 1 2722 2357 DIESEL 10ift. 27E2 e includes intake structure ventilation i Interililent leads (See Miihent 5 for detailsF 0 Includes transforser BA104 no-load losses (16kW)

(1) Requiredleads .

(2) Scie leads say be required (3) Only 6 of B battery chargers are required Page 21 of 27

~

• TABLE 1 (Cont.)

EAC DIESEL COMBINAil0N LOADIWG BUMMARY DIESELS E2 8 E3 1 DIEEELSE28E4 1 DIEEELS E31 E4 - _ - _ .

[22 E23 E3 kJD I E22 E23 E4 BKFD i E32 E13 E, ByJD 1 1 1 RHR N2p (1) 0 1410 14[6 1 0 liis 1410~f~I4If a 1410 2CoreSprayPuep 6 0 0 1 0 0 0 1 0 0 0 3 Hp Service Wtr hp (1) _

6 602 132 _ l _0 002 602 l 202 0 602 4 Eser Servlet Wtr Pip (1) 205 0 0 1 205 0 0 t 105 0 0 5CRDPusp 6 0 0 1 0 0 0 1 0 0 0 6 Meter Operated Vivs 0 0 0 1 0 0 0 1 0 0 0

^

i'

~

7EnergencyLighting (2) 20 39 96 1 20 35 164 I it 1[4 8 00 Jekt Cool kn Pop 9 0 0 1 0 0 0 1 0 0 0 2 Lube Oil Aus Pusp _

l _

l 9 DG Fuel Oil irns hp (1) 0 54 5II e 56 58I Li 0 56 4 Aftr Cool Aux Pip I I .

le DG $ tart Air Cesp B 6 0 1 0 0 0 1 0 0 0 11250V424VBaiChrge 16 16 4 l 16 16 4 1 1 i 16 12 125V Batt margers (3) 30 60 150 1 30 le 150 1 30 30 160 13 inst AC 4 W S Invrtr (2) 19 19 46 1 19 19 46 I 6 9 59 14 RBCW Pusps 0 0 0 1 0 0 0 1 0 0 0 15DrywellCoolerFans 0 0 0 1 0 0 0 1 0 0 0 16 Cntrl Rs Vent Fans (1) 0, 0 . It 1 0 0 10 1 10 0 0 17 Eserg Swgr Sply fans (1) 0 0 41 1 0 0 41 1 41 0 0 18 Eserg Swgr Exh Fans (1) 0 0 21 l 0 0 21 1 21 0 0 19 Bat Roos Eih Fans (1) 0 0 13 1 0 0 13 1 13 0 0 20 DG Vnt 4 pap Rs Fans (1) 0 43 43 1 0 43 43 1 4F 4 43~

21 RHR Rs Cool Units (1) 0 13 13 1 0 13 13 1 13 0 13 22 WCl Rs Cool Units 0 0 0 1 0 0 0 1 0 0 0 23 RCIC Rs Cool Units (1) 0 0 2 1 0 6 2 1 ~6 0 Y 24 CS Rs Cool Units 0 0 0 1 0 0 0 1 0 0 0 25 SGTS Exh Fant 0 0 0 1 0 0 0 l 0 0 0 l 26 55iS Exhaust Htr 0 0 0 1 6  % 0 I $ 6 6-l 27 SLC Pusp 9 0 0 l 0 0 9 1 0 0 0 l 2B SLC Heater 0 0 0 1 0 0 0 1 0 0 e 40 61 21 SW Yib 8 Travl Sern 40 0 0 1 0 6 6 4R 4 Screen Wash Pusp I I l 30120/20aV Dist his 32 29 103 1 32 29 BB I 35 16 101 61 Tf 31 plant Stack Dil Fan 0 0 0 0 ~6 6 6 32 Ra Area, Ref Flr 4 0 0 22 1 0 0 22 1 22 0 0 CcapHtrs4VntFns I i 33 0-0 Skid Mtd Equip 9 0 0~ l ~6-~~0 23 T 0 0 0 34 Air Cospressors 0 0 0 l 0 0 0 1 0 0 0 1 35 Misc Leads /Sys Lost (2)' 104 e 22 123 6 1 104 e 22 123 0 1 60 40 168 80 TOTAL 472 2458 1 472 2458 l 2742 96

- DIEEEL TOTAL 2930 2904 1 2930 2920 l 2B38 2972 i

e includes intake structure ventilation

~~1 IntersitTintTia?i~(SeTAlfaSle'n1Tfsi n ditillU 0 Includes transforser 0M04 no-load losses (IBW)

(t) Required loads

) '(Il Sose loads'~say"be'r'equired (3) Only 6 of 0 battery chargers are required Page 22 of 27 L , .- - ,. , -.

TAP.I.E 2 SAFE SHUT 00WN LOADS DURING A STATION BLACKOUT BOTH UNITS 1 EDG DIESEL E,l (Typical)

E12 E13 E22 E23 E32 E33 E42 E43 1 RHR Pump 0 0 0 0 0 0 0 0 2 Core Spray Pump 0 0 0 0 0 0 0 0 3 HP Service Wtr Pmp O O O O O O O O 4 Emer Service Wtr Pmp (1) 0 0 0 0 20S 0 0 0 5 CRD Pump 0 0 0 0 0 0 0 0 6 Motor Operated Vivs 0 0 0 0 0 0 0 0 7 Emergency Lighting (2) 64 26 20 39 25 0 78 68 8 DG Jcht Cool Aux Pmp 0 0 0 0 0 0 0 0

& Lube Oil Aux Pump 9 DG Fuel Oil Trns Pmp (1) 5 0 0 0 0 0 0 0

& Aftr Cool Aux Pmp 10 DG Start Air Comp O O O O O O O O 11 250V & 24V Bat Chrgr 1 1 16 16 1 1- 1 1 12-125V Batt Chargers (3) 30 30 30 30 30 30 30 30 i 13 Inst AC & UPS Invrtr (2) 22 18 19 19 6 9 25 0 14 RBCW Pumps 0 0 62 62 0 0 0 0 15 Drywell Cooler Fans 0 22 0 17 0 9 0 26 16 Cntrl Rm Vent Fans (1) 0 0 0 0 10 0 0 0 17 Emerg Swgr Sply Fans (1) 0 0 0 0 41 0 0 0 18 Emerg Swgr Exh Fans (1) 0 0 0 0 42 0 0 0

! 19 Bat Room Exh fans (1) 0 0 0 0 13 0 0 0 1 20 DG Vnt.& Pmp Rm Fans (1) 43 0 0 0 0 0 0 0 21 RHR Rm Cool Units 0 0 0 0 0 0 0 0 22'HPCI Rm' Cool Units 0 0 0 0 0 0 0 0 23 RCIC Rm Cool Units (1) 1 1 0 0 0 0 0 0 24 CS Rm Cool Units 0 0 0 0 0 0 0 0 25 SGTS Exh Fans 40 0 0 0. 0 40 0 0 26 SGTS Exhaust Htr 46 0 0 46 0 0 0 0 27 SLC Pump 0 0 0 0 0 0 0 0

! 28 SLC Heater 0 0 0- 0 0 0 0 0 29 SW Vib & Travl Sern 46 0 46 0 0 0 0 0

& Screen Wash Pump 30 120/208V Dist Pnis 37 20 32 29 35 16 38 40 31 Flant Stack Dil Fan 17 0 0 0 17 0 17 0 -

32 Rx Area. Ref Flr & 0 0 .0- 0 11 0 11 0 L Comp Htra & Vnt Enc 33 D-G. Skid Mtd Equip 0 0 0 23 23 0 0 23 34 Air Compressors 0 81 0 0 81 0 0 0 35= Misc Loads /Sys Loss (2&4) 146 27 252 113 78 57 89 134 E BUS TOTAL 498 226 477 394 610 162 209 322 DIESEL TOTAL 2986 Notes (1) Required Loads (2) Some loads'may be required (3) Six of eight battery chargers are required (4) Transformer 0AXO4 no-load losses included in E12 (18kW)

Page 23 of 27

TABLE 3 EAC_.OPERAT.OR_A_CTIONS _TWO EDGn AVAILABLE If n LOOP cvent occurred with only two EDan nvallnble, a modent number of operator actionn are needed to maintain both unito in long-term nafe shutdown. The following nummarizen thone operntor actions.

When any two EDGB ntart, cooling wnter will be automatically available to the EDGn from either an Emergency Service Water (ESW) or an Emergent.y Cooling Water (ECW) pump. Following confilmntion that only two EDGn are available, the operatorn will initiate the appropriate plant proceduren to backfeed nelected 4 kV bunen and establish battery charging as follown:

1. In the main control room, the chief operntor will nlign the appropriate offnite 4 kV feeder breakern control switchen to the open (TRIP) position.

2. A floor operator in dinpatched to the Emergency Switchgent Room to remove the control power funen for the undervoltage trip feature on only one offnite 4 kV feeder brenker annociated with the EDG that in to used to backfeed the othern elected 4 kV bunen. The purpose of thin action in to remove the undervoltage trip signal for the breaker no that thin breaker can be cloned. When thin breaker in cloned there in voltage nynilable on the feeder nide of the other offnite 4 kV feeder bronkern and, therefore, the other breakers can be closed without further action.

The floor operator will also need to remove control power funen to large loads (e.g., RIIR , Core Spray (CS), llPSW) on each bun to be backfed. This in done to prevent overland of the EDG, if thene pumps would inndvertently start.

3. In the main control room, the chief operator will clone the 4 kV feeder breaker that had the undervoltage trip defented, then clone the 4 kV feeder breakern to the two or three (depending on the EDG combination) 4 kV bunen to be backfed and energize the appropriate load centern. During this operation, dellborate operator action by une of the nynch nwitch to allow closing of the 4 kV feeder breaker would be required to erroneously tie the EDGn together nnd in therefore not expected to occur.

4. The operator in the switchgent room will then be directed to entablish battery charging to the 2 or 3 (depending on EDO Page 24 of 27

4

, Table 3 (cont'd) combination) batteries not being charged by using the installed Appendix R transfer switches.

5. Selected non-essential DC loads will be de-energized using

a. control switches in the control room

b. circuit breakers in the cable spreading room at two panels

6. For the E1/E4 EDG combination, the control room operators will start an ESW pump and secure the ECW pump.

These operator actions for backfeeding and battery charging can easily be achieved within the one-hour assumed in the analysis for battery capacity and essential area ventilation. The operators have _ been trained in the use of the existing bacitfeed procedures and use of the existing Appendix R transfer switches.

The next operator action is to perform load management activities to reduce EDG loading so that an RHR and ilPSW pump can be placed in service for each unit. Based on our contninment nnalysis for station blackout with no RIIR in service, the operators would have at least cignt hours from the initiation of the LOOP event to place the RilR system in torus cooling or shutdown cooling. These load management actions are:

1. An operator will be diopatched to the Reactor Building to 2 or 3 (depending on the EDG combination) load centers to open the load center feed breakers to de-energize selected MCCs associated with non-ensential equipment for the LOOP event.

2. In the main Control Room the operators will use the control switches to turn off selected non-essential equipment for the LOOP event. This equipment includes the Reactor Building Closed Cooling Water (RBCCW) pumps, drywell cooler fans, Standby Gas Treatment System,-Instrument Air l Compressors, Main Turbine Auxiliaries and the Plant Stack Dilution Fans.

The final operator action is to place RIIR and IIPSW in service using the normal operating procedure. The load management activities and placing RIIR and HPSW in_ service can easily be achieved within the analyzed eight hour period.

2122c. doc l

l Page 25 of 27

. - . -- - - .- .. . .-. - . - - - . - - - . . - - - = . _:

TABLE 4 STAT 1014_ BLACKOUT _OPERAToft ACTIOt45_ _011E EDG.__AVA1 LABLE If a station blackout occurn, the 3 EDGn that are required to respond to a LOOP event (including the required EDG redundancy) will be unavailable. The following describen the operator actions that are needed to maintain safe shutdown for the required duration of eight hours with one EDG available. EDG E-1 will be used an an example since this EDG would require additional actions to establish EDG cooling water compared to those actions taken if the E-2, E-3 or E-4 EDG was used as the AAC.

If EDG E-1 is the only EDG to start, the operators are trained to trip the EDG within three minutes. If the operator falls to take this action, the EDG will trip on a protective trip of high jacket water temperature or high lube oil temperature within neveral minutes. This trip results in no damage to the EDG. tiote that each EDG has a separate closed cooling water system which in cooled by ESW.

The operators will then initiate the procedure to backfeed the 4 kV buses as follows:

1. In the main control room, the chief operator will align the offolte 4 kV feeder breakers control switchen to the open trip position.

2. A floor operator in dispatched to the Emergency Switchgear Room to remove the control power fuses for the undervoltage trip feature on E-212 4 kV feeder breaker.

3. Restart the E-1 EDG using existing proceduren.

4. In the main control room the chief operator sill close E-212 and E-232 4 kV feeder bronkers and verify that the B ESW pump han auto started.

5. In the main control room, the chief operator will clone the 4 kV feeder breakern to the remaining 4 kV bunen and energize the appropriate load centern.

6. Selected non-essential DC loads will be de-energized using:

a. control switches in the control room b, circuit breakers in the cable spreading room at two panels These operator actions can easily be achieved within the one hour AC independent coping analysis for battery capacity and essential area ventilation. The above actions are contained in existing procedures and the operators have been trained in their use on the PBAPS simulator.

Page 26 of 27

g TABLE 5 Containment Inolation Valves

• that do not Meet the NUMARC Exclusion Criteria PBAPS Units 2 & 3

_Sys_ tem Coritainment Isolation

. Valve RCIC Steam Supply MD-13-16 or MO-13-15 RCIC Torus Suction MO-13-41 or MO-13-39 HPCI Steam Supply MO-23-16 or MO-23-15 HPCI Torus Suction MO-23-58 or MO-23-57 HPCI Test Line MO-23-31 or MO-23-24 RHR Pump Suction MO-10-13A, B, C, and D RHR Containment Spray MO-10-31A or MO-10-26A RHR Containment Spray MO-10-31B or MO-10-26B RHR Test & Pool Cooling MO-10-34A and MO-10-34B RHR Torus Spray M'b 10 - 3 8 A o r MO 39 A RHR Torus Spray MO-10-38B or MO-10-39B RHR Shutdown Cooling MO-10-18 or MO-10-17 Core Spray Pump Suction MO-14-7A, B, C, and D Core Spray Full Flow Test Line MO-14-26A and MO-14-26B Torus Water Filter Pump Suction MO-14-71 or MO-14-70 RWCU Pump Suction MO-12-18 or MO-12-15 Main Steam Drain MO-2-77 or MO-2-74

• Unit 2 valves are numbered MO-2-XX-XX Unit 3 valven are numbered MO-3-XX-XX 2122b. doc Page 27 of 27