ML20100K213
| ML20100K213 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 04/08/1985 |
| From: | Andrews R OMAHA PUBLIC POWER DISTRICT |
| To: | John Miller Office of Nuclear Reactor Regulation |
| References | |
| LIC-85-142, NUDOCS 8504120319 | |
| Download: ML20100K213 (6) | |
Text
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Omaha Public Power District 1623 Harney Omaha. Nebraska 68102 402/536-4000 April 8, 1985 LIC-85-142 l
Mr. James R. Miller, Chief Office of Nuclear Reactor Regulation Division of Licensing U. S. Nuclear Regulatory Commission Washington, DC 20555
References:
(1) Docket No. 50-285 (2)
Letter from OPPD (R. L. Andrews) to NRC (J. R. Miller) dated January 9, 1985 (LIC-85-338)
(3)
Letter from NP.C (J. R. Miller) to OPPD (R. L. Andrews) dated March 4, 1985
Dear Mr. Miller:
Fire Area 34B, Request from Exemption from 10 CFR 50, Appendix R The Omaha Public Power District received Reference (3) requesting additional information about Fire Area 34B at the Fort Calhoun Station.
Pursuant to Reference (3), please find attached forty (40) copies of the District's response.
Sincer.ely,
h?f/kx/
R. L. Andrews Division Manager Nuclear Production RLA/CWN/dao Attachment cc:
LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N.W.
Washington, DC 20036 8504120319 850408 ADOCK 0500 5
i Mr. Robert D. Martin hDR l
Regional Administrator d
l U. S. Nuclear Regulatory Commission
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Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 l
Mr. E. G. Tourigny, NRC Project Manager l
Mr. L. A. Yandell, NRC Senior Resident Inspector E meuamengrgaugopportunity
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REQUEST FOR ADDITIONAL INFORMATION APPENDIX R - REQUEST FOR EXEMPTION FA-34B FORT CALHOUN STATION REQUEST 1.
The response to Question 1.b is not clear.
Six valves are listed as being required to be closed.
Five valves appear to be powered from Fire Area 34B-West and cne from Fire Area 34B-East.
It is not clear that the power can be removed from these valves if the fire is in 34B-West and does not trip the appropriate breakers and similarly the single valve in Fire Area 34B-East.
Provide a description of the method to remove power from these valves assuming their respec-tive fires.
Provide a discussion of the effects of the loss of coolant as the result of these valves being open until they can be closed from outside of the control room (this assumes spurious opera-tion due to damage of the control cable due to the fire).
DISTRICT RESPONSE In the response to question 1.b, seven valves are listed as being required to be cl osed.
These valves and their respective power sources are:
Valve No.
Power Source PCV-102-1 MCC-3C1 (Fire Area 34-B East)
PCV-102-2 MCC-4B1 (Fire Area 34B-West)
PCV-103-1 Cor. trol Room (via AI-185 in 34B West)
PCV-103-2 Control Raan (via AI-185 in 34B West)
TCV-202 AI-185 (Fire Area 34B-West)
HCV-240 AI-185 (Fire Area 34B-West)
HCV-249 AI-185 (Fire Area 34B-West)
As stated on page 3 of Reference (2), Fire Area 34B is now divided into two distinct, separate Fire Areas, 348-East and 34B-West.
The al ternate shutdown capabili ty described herein is for Fire Area 34B-West only.
Therefore, it can be seen that power for valves PCV-102-1, PCV-103-1, and PCV-103-2 can be removed independent of Fire Area 34B-West.
To remove power from valve PCV-102-2, all power to its motor control center, MCC-4B1, will be removed by opening circuit breaker 184B-2 at the 480V swi tchgear.
This breaker is l ocated in the switchgear room, Fire Area 36B, independent of Fire Area 34B-West.
Additionally, PORY block val ve, HCV-150, is in series wi th PCV-102-2.
This valve is powered from MCC-3B1 located in Fire Area 348-East and can be closed from the control room.
Addi tional assurances against inadvertant opening can be obtained by opening breaker H02 at MCC-381 in Fire Area 34B-East.
Valves TCV-202, HCV-240, and HCV-249 are solenoid-operated valves powered from panel AI-185 which is located in Fire Area 34B-West.
The method to remove power to these valves is to remove all DC power tu panel AI-185.
This is accomplished by opening circuit breaker number 16 at 125V DC bus no. 2 (EE-8G) which is located in Fire Area 36B, independent of Fire Area 348-West.
Therefore, in the case of a fire in Fire Area 34B-West, the follow-ing circuit breakers outside of the control room must be opened:
Breaker No.
2 at 480V Bus 1848-2 (F.A. 368)
Breaker No.
16 at 125V Bus No. 2 (F.A. 36B)
Breaker No. A01 at 480V MCC-3C1 (F.A. 34B-East)
Breaker No. H02 at 480V MCC-3bi (F.A. 34B-East)
It is estimated that this can be accomplished within approximately 3-5 minutes following detection for a fire in F. A.
The possibili ty of a fire causing spurious operation in this short a period of time is minimal.
Val ves PCV-103-1 and PCV-103-2 are pressurizer spray valves and spurious operation does not cause a loss of coolant.- Valves HCV-240 and HCV-249 have a check valve in line with them and would, therefore, not lead to a loss of coolant.
PORV's PCV-102-1 and PCV-102-2, and PORY block valve HCV-150 can be closed from Fire Area 34B-East.
Inadvertent opening of these valves will result in a small break LOCA.
This event is analyzed in the USAR and will be tenninated as soon as power to these valves is failed.
This will not result in uncovering of the core.
Letdown valve TCV-202, as discussed above, can be closed in approximately 3-5 minutes.
It is also backed up by fail closed valves LCV-101-1 and LCV-101-2.
Inadvertent opening of TCV-202 will result in an uncontrolled letdown which is within the make up capaci ty of the charging pumps and therefore will not result in a LOCA.
REQUEH 2.
The response to Question 1.f is concerned with the manpower to perform a safe shutdown and for the fire brigade.
It appears that the minimum number of people required to perfone a safe shutdown in the event of a fire is seven, and the minimum fire brigade size is five for a minimum nusber of people on site of 12.
The list of personnel provided in the response only lists 10 people.
Provide a revised response which clearly specifies the minimum personnel requirements and list each person, by title, for both groups.
DISTRICT RESPONSE The response to question 1.f states that there are seven operators on site at all times, not that seven operators are required for safe shutdown of the plant.
Although a minimum operating crew of seven persons is required, the Technical Specifications 5.2.2.g states:
e "A fire brigade consisting of 5 members shall be maintained on site at all times #.
The fire brigade shall not include the minimum shif t crew necessary for safe shutdown of the unit (2 members).
- Fire brigade composition may be less than the minimum require-ments for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence of fire brigade members provided immediate action is taken to restore the fire brigade to within the minimum requirements."
As datailed on Page 10 of Reference 2, the manpower requirements are for 5 fire brigade members, 2 operators in the control room, one STA in the control room, and an additional two operators available for the fire-safe shutdown procedures outlined in Reference 2 to accomp-lish Steps 1.e.2 and 1.e.3.
Therefore, only ten persons (4 opera-tors, plus an STA, plus 5 fire brigade members) are required for achieving safe shutdown and fire fi ghti ng.
Manpower allocation is as follows:
Fire Brigade (per Standing Order G-28) 1 Shift Supervisor (Leader)
Water Plant Operator Phone Talker 2 Security Personnel Control Room (Tech. Spec 5.2)
Reactor Operator Assistant Reactor Operator Shift Technical Advisor Room 81 (Auxiliary Feedwater Throttling)
- Auxiliary Building Operator Switchgear Room
- Turbine Building Operator
- Requi red to accompli sh steps i.e.2 and 1.e.3 outli ned in Reference 2.
REQUEST 3.
Table 1 indicates that isolation of some of the alternate shutdown equipment is by means of fuses. Verify that no fuses will be pulled in order to isolate the equipment.
l
e DISTRICT RESPONSE Table 1 lists fuses at inverters EE-8K and EE-8L.
These fuses were to be pulled to remove 120 VAC control power from panels AI-179 and AI-185 located in Fire Area 34B-West.
This involves pulling out two fuses located at each inverter, EE-8K and EE-8L.
We believe it is a simple operation and can be performed by available shift crew within 3-5 minutes of detection of fire.
Rather than pulling fuses, this can be accomplished by the following means:
(See Figure 8.1-1, Draw-ing D.2 of Table 4 in Reference (2)).
Open breaker CB-22 at DC bus #1 (Fire Area 36A)
Open breaker CB-6 at DC bus #2 (Fire Area 368)
Open feeder breaker to 120 VAC instrument bus AI-40C (Control Room)
Open feeder breaker to 120 VAC instrument bus AI-400 (Control Room)
Close bus-tie breaker between 120 VAC instrument buses AI-40A and AI-40C (Fire Area 42, Control Room)
Close bus-tie breaker between 120 VAC instrument buses AI-40B and AI-40D (Fire Area 42, Control Room)
This method ensures that 120 VAC instrument and control power is removed from panels AI-179 and AI-185 in Fire Area 34B-West, thereby isolating shutdown equipment without pulling any fuses.
Alternatively,15 amp circuit breakers may be installed in inverters EE-8K and EE-8L to facilitate isolation of AI-179 and AI-185 from Fire Area 34B-West.
These inverters are scheduled to be replaced during the 1985 refueling outage and this possibili ty will be reviewed during the design of the modification.
REQUEST 4.
We note that, in your discussion of alternative shutdcwn capability for Fire Area 348, you reference technical specifications 2.2 (CVCS),
2.5 (steam and feedwater systems including auxiliary feedwater) and 3.9 (auxiliary feedwater).
In your response to this letter, we als,o request that you (1) describe the testing performed on these systems, (2) specify which ones are tested on a monthly basis, and (3) provide the basis for not performing monthly testing for the ones not tested on a monthly basis.
District Response (1) Testing of the pumps, valves and piping in the Chemical and Volume Control System and the Auxiliary Feedwater System is done in accordance with Technical Specification 3.3(1)a which states the following:
In-Service inspection of /SME Code Class 1, Class 2, and Class 3 components and 'n-service testing of ASME Code Class 1, Class 2 and Cl ass 3 pumps and valves shall be performed. in accordance with Section XI of the ASME Boiler and Pressure Vessel Code, as required by 10 CFR Part 50, Section 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR Part 50, Section 50.55a(g)(6)(i).
r The NRC approved Inservice Inspection Program for Fort Calhoun Station covers the testing that is performed.
It also contains the exceptions to Section XI of the ASME B&PV Code that have been granted by the Commission.
In addi tion, Technical Specification 3.9(1) through (5) and Technical Specification Table 3-2 Item 22 and Table 3-3, Item 19 delineate other surveillance test require-ments for the Auxiliary Feedwater System.
(2)
The following surveillance tests are performed monthly:
a.
Auxiliury Feedwater System valve alignment check s per Technical Specification 3.9(1);
b.
Auxiliary Feedwater flow transmitter channel check per Technical Specification Table 3-3, Item 19; and c.
Auxiliary Feedwater automatic initiation circuit function check per Technical Specification Table 3-2, Item 22..
(3)
The frequency of various surveillance tests perfomed on the CVCS and AFW System are based on the Fort Calhoun Technical Specification requirements, the ASME B&PV Code Section XI requirements and the NRC approved Inservice Inspection Program for Fort Calhoun Station.
The past operating, maintenance and testing history of components in those systems has demonstrated that the presently established testing frequencies are adequate.