ML20127J041
| ML20127J041 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 05/17/1985 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20127H656 | List: |
| References | |
| NUDOCS 8505210355 | |
| Download: ML20127J041 (34) | |
Text
. _ _ _ - _.
t SAFETY EVALUATION BY NRC REGION V SUPPORTING AMENDMENT NO.
TO FACILITY OPERATING LICENSE NO. DPR-54 SACRAMENTO MUNICIPAL UTILITY DISTRICT
. RANCHO SECO NUCLEAR GENERATING STATION DOCKET NO. 50-312 I.
INTRODUCTION A.
DESCRIPTION OF PROPOSED ACTION
.This Safety Evaluation addresses an application by the Sacramento Municipal Utility District (the_ licensee or SMUD) to amend the Operating License of the Rancho Seco Nuclear Generating Station (the facility) to reflect modifications to the facility electrical distribution system. The Safety Evaluation also addresses the acceptability of.certain of these modifications.
-B.
BACKGROUND INFORMATION
- As a result'of the issuance of NUREG-0737, " Clarification of TMI Action Plan Requirements" and NUREG-0696, Functional Criteria for
' Emergency Response Facilities", the licensee initiated design of the following:
1.
Provisions for early start and automatic sequencing of auxiliary feedwater pumps.
.s.
2.
A Technical Support Center, along with the required instrumentation, data collection and data processing equipment.
3.
Improvements to the habitability of'the Control Room (CR) to meet the requirements of NUREG-0800, Standard Review Plan _(SRP) Section 6.4 " Control Room Habitability System" with the addition of redundant, safety-related air conditioning and filtration systems.
4.
~A Post Accident Sampling System.
5.
Additional Instrumentation.
Due to the limited spare electrical capacity available to power this new equipment and the need to have the capability to start the auxiliary feedwater pumps early in the electrical loading sequence following an accident or loss of offsite power, the licensee has added the following electrical equipment to the plant: Two diesel 8505210355 850517 PDR ADOCM 05000312 P
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. generators,.two. trains of independent Class 1E 4160/480V power, four
' power supplies, and some additional non-Class IE equipment.
trains'of independent Class IE 120V control and instrumentation To house.this new equipment, the licensee has constructed,two new 1
Cutegory 1. structures: a Diese1~ Generator Building and a Nuclear Service Electrical Building (NSEB).
4 As1 construction of these buildings and. installation of the new 55..
l equipment:was completed, 'the licensee energized the new buses using Class J1E bus ducts and. cable ties ~between the. existing Auxiliary Building ^and the NSEB. A portion of the equipmenc listed above was
=
ienergized at the~beginning of the recently concluded Cycle 6.
'Thellicensee originally planned to energize the balance of the new loads prior to operation.in Cycle 7. -However, due to identification of. generic problems' with the new diesel generators, these~ units-will
~
not be available for use when originally planned. Nonetheless, the
- licensee has: identified means by which a portion of the remaining-new loads can be energized;pending qualification of the new diesel
-generators; The licensee has proposed revisions to the facility technical specifications to reflect this temporary mode of operation.
- C.
SCOPE OF REVIEWE ibis. review considers the following:
1.
The acceptability of_the revisions to the electrical and fire protection technical specifications proposed for the period during which the plant electrical systems are loaded, fconfigured and operated as described in this evaluation.
- 2. :
The acceptability of the design of the Nuclear Service
' Electrical Building and the acceptability-of the~ electrical.
c distribution system while it is configured and operated as a.
' described herein.
3.
'The acceptability of the design of;the fire protection system as. installed in'the Nuclear. Service Electrical Building.
In performing this review we have considered the suitability of the l electrical design with respect lto the applicable General: Design
- Criteria, )RIC Regulatory Guides and the Branch Technical Positions and Industry-Codes and Standards listed in NUREG-0800, " Standard :
Review Plan for the Review of-Safety Analysis Reports for Nuclear Power Plants", ' Section 8.1.
In reviewing.the structural design of the Nuclear Service Electrical Building, we have'used~ the guidance set forth in NUREG-0800,. Sections 3.7.1 and 3.8.4.
In reviewing the e
suitability'of the design of'the Nuclear Service Electrical Building
.with respect to fire protection, we have utilized the applicable teriteria set forth in NUREG-0800, BTP CMEB 9.5-1, Sections C.5, C.6
,,L, Land C.7 and Sections III.G, and III.J of Appendix R to 10'CFR 50.
In reviewing.the proposed changes to the Technical Specifications, it C.
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'3.
~
'we iave compared the proposed revisions with the present facility
-specifications to verify the. revisions were-consistent with and appropriate:to.the facility changes and did not introduce an.
! unreviewed safety question or reduce the overall level;of safety of operations.
2 II. -EVALUATION:
A.
DESCRIPTION OF MODIFICATIONS 1.
Electrical' Distribution System In order to accommodate the additional electrical loads
. required by NUREG-0737, " Clarification of TMI Action Plan Requirements",.the licensee has undertaken a significant
' expansion of the electrical distribution and ' standby electrical
. systems.of the. facility. For comparison purposes,.the applicable safety-related portions of the original AC and DC systems are shown in Figures 1-and 2 (some non-safety related.
' components and circuits are.also shown). When all presently-planned modifications are complete,.the AC circuits shown in Figure 1 will appear as shown.in Figure 3; and the DC circuits' of Figure 2 will be supplemented by the additional equipment o
.and circuits shown.in Figure 4.
I'
-Examination of, Figures 1 and 3 shows'the principal changes to JtheAC system are the addition of:
4.16 KV Buses'4A2 and 4B2' Diesel Generators GEA2 and-GEB2.
-480 Volt Buses 3A2'and 3B2-
. Transformers X43A2 and X43B2A Bus Duct Extensions to Buses 4A2 and 4'B2-
. Cable Interties between Buses 3A/3A2 and 3B/3B2
- m Associated Circuit Breakers As shown in' Figure 4, the additions!to the DC systems include-four' safety-related batteries, "A2", "B2", "C2" and "D2", with'
-the. associated battery chargers and inverters; and three non-safety related batteries '.'GA", "GB"' and N1", 'with
~
' associated chargers and inverters.- In addition.to a dedicat'ed battery charger,.each of the new safety-related batteries has a l,
spare charger that can be placed in service if needed. 1As in
~
-the original plant: design,.each spare charger serves as.a backup.for two batteries.
2.
.. NUCLEAR SERVICE ELECTRICAL BUILDING (NSEB)
'The'NSEB is a three story, 13,000 square-foot, reinforced' H
-concrete structure. This building will house much of the-electrical distribution system and other support hardware for-the required TMI modifications. This equipment includes-the new 4160 Volt switchgear, the new 480 Volt load centers, batteries and ciargers, inverters, relay panels, isolation
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1 L panels, auxiliary feedwater system control panels and' computer systems for'various; display functions.' The. licensee.. defines the:NSEB as a quality and teismic Class 1 structure.
.In order to provide.the physical and electrical separat 6n.
1 f
. required 'for buildings of this type, the -building is divided-into a train "A" side and a train "B" side. The licensee; states-these areas are separated by an eight foot corridor with
~
three. hour rated fire walls.
In addition, each side of the
. building has a separate cable shaft with threc. hour interior
^
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Lfire walls, and a separate, tunnel connecting to the. Auxiliary.
' Building. Each side of-the building also,.has a' separate;
~
16-inch diameter electrical raceway for connecting.480 Volt =
- power,and control circuits..to the' Auxiliary Building. Separate e
HVAC systems (both normal and essential) are also provided for each side of.the. building. The licensee-statesithat all train--
'"A" cable trays are confined to the train' "A" section of the v
NSEB and all train."B" cable trays are in the train,"B" section of the building.
q
.+
.3.
-NSEB' FIRE PROTECTION SYSTEM FiresuppressionequipmentinstalledintheNSEBinc1bes;
~
Carbon Dioxide and Halon 1301 vapod systems, and Wt Spriskler, Pre-Action Sprinklerc and Spray. water systems.
In addition, fire hoses and portable extinguishers are provided. Fire
~
detection systemsfinclude heat'and ionization smote' detectors.
2.
-In most areas -important to safety,. both types of ' detectors are used and are connected in.al cross-zoned' configuration. Manual-fire alarm and Pull stations are also provided.
~
B.
ELECTRICAL SYSTEM OPERATION'IN CYCLE 7-i
~-
As: major portions of these modifications 'h' ale be'en completed, the the increased capabilities have been implesented. The9aitial' change was made for the recently concluded operating cycle ^
(Cycle 6), and consisted of energizing the new 480 Volt buses, 3A2
~
and 3B2,.via cable' interties from busesJ3A and 3B, respectively.
This configuration =iscshown in Figure 5, where it is seen the*'
c.
circuit' breakers connecting buses 3A'and 3A2, and buses 3B and 3B2,
]
- arelshown'as normally closed (N.C.).
],,
~Because the.new diesel generators,;GEA2 and GEB2,'are not expecte'd,~
to be qualified for service at the beginning-of the next -operating.
-'I
. cycle.(Cycle 7), the licensee cannot fully < implement'all of the
- remaining-modifications at this time. Instead,- th~erlicensee proposes'to.. implement;only.those additional modifications and
-l electrical loads that can be energized within the present, capacity and component ratings. As proposed by.the licensee,.this
. implementation will involve two modes of operation: (1) operation when there has~been~a loss of offsite power sources (LOOP) and. (2) operation when there has not been a loss 'of offsite_ power' sources (NLOOP)..These two modes are needed because of.the substantial-4 e
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' difference in' the' amount ofipower available to energize safety loads
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7 in the two modes.
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- Figure 6'shows the. proposed operational configuration when there is
.not a loss"of offsite power.~ It~is seen that for this Jconfigurati'on, the.4160 volt buses of thei"A" train;(buses 4A and
?
'4A2).are individually powered from.Startup Transformer No. 1, and the corresponding buses'of the "B" train are powered from Startup LTransformer"No.?2. Power to new 480 volt bus 3A2 is supplied from
' new.4160 volt bus.4A2 via new' transformer X43A2. - - A similar
. arrangement is seen'toibe employed for the "B". train via new
~
atransformer X4332A.~
'r dh iForalossofiffsite' power (LOOP) condition,thearrangementin.
c
' Figure 6.is changed by the automatic opening of the circuit breakers ef;
- supplying; power to buses-4A,'4B, 4A2,-4B2, 3A2 and 3B2.. Under these
~
conditions, power is automatically supplied to buses 4A and 3A and g
. buses 4B and 3B by. diesel generators GEA and GEB respectively.
Train'"B" sequencing will include automatic closure of the Class 1E
~ train "B"? electrical. cable' tie breakers between the old'480 volt
- switebgear,3B and the new 480 volt"loadcenter 3B2, thereby energizing bus 13B2. This sequencing will also automatically
^
re-energize the train "B" Control Room essential HVAC which-is
~
_ 4: '
' supplied from bus 3B2..The operator will' manually close the-O train "A", Class IE' electrical cable tie breakers between the old 480
'?
- voltiswitchgear 3A: and -the new 480 volt loadcenter 3A2. Automatic
'loadinglof bus 3B2 is'provided as an' interim measure (pending
~
'1 y qualification'of new diesel generators GEA2 andLGEB2) to retain the-
.. current capability.for automatic restoration of power to the Control
- Room-HVAC.'
^Li..
~
- As for'the four;n'ew Class IE batteries 'added by the licensee, these F
abatteries.will'normally;be maintained charged by battery chargers-
.e:-
powered.by,the new buses'3A2 and 3B2. The. backup-chargers for these-J batteries, however, L are fpowered from existing buses ;3A and 3B. f -
~
M C.
ACCEPTABILITY 0F NSEB STRUCTURE Y
,3 A:
fBy letters dated November 26,_1980 and November 156 1984, the-
~
~
1 1 licensee provided.information concerning the design criterih and codes and standards. applicable!to the construction of the NSEB.
These commitments ~were as'follows:
Codes and' Standards'
.., ~
LAmericantConcrete' Institute, Standard'349-76 and 1979 Supplement to-
,s
- t
' Code Requirements for' Nuclear Safety-Related Concrete Structures.
~
Th_
r
-American Institute for Steel Construction (AISC) Specification for
- W, the Design,- Fabrication-and Erection of Structural Steel for Buildings, adopted February 12,:1969, and Supplements Nos. 1, 2'and
+
v3,
. N
^
_.'w r-
6 e
/
American Institute for Steel Construction (AISC), Specification for'
~
Structural Joints-Using ASTM A~325 or A 490 Bolts Approved by the Research Council on' Riveted and Bolted Structural Joints-of-the-
~ Engineering Foundation, February 4,1976.
' LAmerican Welding. Society (AWS), Structural _ Welding Code 1(AWS DI.1-72, Rev. 1-1973).
n l
Other nationally recognized industry standards, such as those published by the American Society for Testing and Materials'(ASTM),
'to describe material properties, testing procedures, fabrication and s
construction methods.
NRC' Regulatory Guides
~
-s
[1.60,~ Design Response Spectra for Seismic Design of Nuclear Power Plants 1.61, Damping Values for Seismic Design ~ of Nuclear Power _ Plants 1.76, Design Basis Tornado for. Nuclear Power Plants
_.1.142, Safety-Related Concrete Structure for Nuclear Power Plants
'(other than Reactor Vessels and Containment)
~
Bechtel Topical' Reports
~
BC-TOP-3A, Tornado;and' Extreme Wind Design. Criteria-for Nuclear-3-
Power PlantsE BC-TOP-4A,-Seismic Analysis of Structures and Equipment for Nuclear-Power -Plants BC-TOP-9A,' Design.of' Structures for-Missile Impact
~
In1 designing'the NSEB to these codes, standards and guides, the' s
~ licensee stated that where a conflict occurred between existing codes, the more_ restrictive _ design code was deemed to. govern.
The licensee also provided information concerning the loads and load combinations,used.in thel design,'and the-specifications for:the
. major construction' materials. The_ licensee stated the building.
- design was based on maximum ground accelerations for the Operating
-Basis' Earthquake (OBE)"and the: Safe Shutdown Earthquake (SSE) conditions of-0.13g and 0.25g.respectively. We note these are the-
- same earthquake _ values ~previously-used by_the. licensee in the design of:the other Class 1Estructures at this site.
On April.29 and'30,'1985,, a. staff reviewe'r visited the Rancho Seco facility to review;the' Design Report.for the NSEB and selected' P~
calculations. As a' result of this visit, the: staff concluded the s
licensee _had' acceptably implemented the"designLcriteria listed
~
-above.
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.Although the-l'icensee did not reference Regulatory Guide 1.91,-
" Evaluations' of Explosions ~ Postulated to Occur on Transportation
- Routes'Near Nuclear'. Power' Plants" and Regulatory Guide 1.115,
-" Protection,Against. Low Trajectory Turbine: Missiles," we have
. examined the NSEB with respect to this. guidance and~ conclude that'
~because of distance:from. transportation: routes =and-the specific-
- onsite location', the NSEB conforms-to this guidance.
Based'on the foregoing, we conclude:
The licensee's conformance with the' recommendations of
~
' Regulatory Guides 1.60 and 1.61 assures that the seismic inputs
? to the analysis.of the NSEB'are adequately defined so as to i
form a conservative basis for the design of this building to withstand seismic loadings.-
The~ criteria used in.the analysis,. design and construction of
.the NSEB to. account for anticipated: loadings. and postulated-conditions that may occur during'its service lifetime are in conformance with established criteria, codes, standards, and-specifications acceptable to.thefstaffi These include
'T Regulatory Guides 1.91,.1.115,:1.142 and.indestry standards ACI-349.and AISC;" Specifications for the Design, Fabrication,-
a-and Erection of Structural-Steel for Buildings."
The~use of the guidance and criteria listed above provides reasonable assurance.that, in the. event of winds, tornados,-
earthquakes, and various postulated accidents, the structures-will withstand the specified design conditions without--
y
- impairment' of structural integrity or the performance of H
, required safety. functions.
D.:
. ACCEPTABILITY OF ELECTRICAL MODIFICATIONS.
iBy'-letters dated November 15, 1984 and March'15, 1985, the' licensee provided 'information" concerning the tdesign criteria,-_ regulatory guidance and industry codes and standards;used in the: design, '
analysis and installation of the,el'ectrical modifications. described
, above.
The'~ documents referenced included the following:
General' Design Criterion ~2
- Design Ba' sis for Protection Against Natural Phenomena.
General Design Criterion 4 Environmental and Missile Design-Bases.
. General Design Criterion 5-Sharing of Systems, Structures and Components.
. General Design Criterion 17 Electrical Power Systems.
! 7.c General Design Criterion 18 Inspection and Testing of Electrical' Power Systems.
j '.
L i
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3:
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SReguiatory Guide 1.6 Rev? O Independence Between Redundant,.
Standby (Onsite) Power Sources..
'rp$~.
^
Systems.
and'Between Their-Distribution-4
- a,
Regulatory. Guide'1.'9 Rev. 2 Selection, De' sign, and Qualification-ofjDiesel Generator Units,Used as Standby _(Onsite) s
'i Sc
=
Electric' Power Systems,at Nuclear.
Power Plants.
Use of IEEE Standard-308,
., Regulatory Guide-1.32 Rev. 2
" Criteria for-Class IE Power-Systems for Nuclear Power; Generating Stations."
' Regulatory Guide 1.47 Rev._0- -
Bypassed and Inoperable' Status Indication for Nuclear Power-4 Plant Safety Systems.
. Regulatory Guide 1.75 Rev. 2 -
Physical Independence of Electric Systems.
- s-Regulatory Guide'1.89 Rev. 0 -
Qualification of Class IE:
Equipment for Nuclear Power Plants.
Regulatory Guide 1.100 Rev. 11-Seismic-Qualification of.
Electric Equipment for Nuclear Power Plants.
^ ' ' '
~
Regulatory Guide 1.118 Rev. 2 -
~ Periodic Testing'of Electrical; Power and Protection Systems.
y b
I'-
Installation Design and.
Installation of-Large Lead Storage. Batteries for Nuclear 7g 7
Power Plants.
Maintenance, Testing, and fRegulatory Guide 1.129,
' February.1978 Replacement of Large Lead m,
Storage Batteries for Nuclear 7
Power Plants.
1
- g _
Regulatory Guide'1.131,-
~ Qualification Tests of Electric.
August 1977 Cables, Field Splices', and Connections for Light-Water-
. Cooled Nuclear Power Plants.
N-Guidance for Application of-Branch Technical Position-
.ICSB-21 Regulatory Guide 1.47.'
.' Branch Technical-Position Adequacy of Station Electric t
PSB.
Distribution System Voltages.
R I
'7'-
3 4
'Y' 4
3 D i,.
9-4 ANSIN45.2-1977) xQuality Assurance Program
, Requirements. for Nuclear. Power Plants.
- 1
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' Packaging, Shipping,. Receiving,
-~
. Storage and Handling of Items. for -
. Nuclear; Power-Plants.
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- Criteria for_ Protection Systems for. Nuclear Power Generating
~ Stations.
- IEEE Standard 308-i9i41
'1I2 Criteria fon Class IE Power
' Systems.for Nuclear Power p
Generating. Stations.
Qualifying Class IE Equip' ment -
for Nuclear Power Generating Stations.
h IEEE' StaridardI338-1977 Criteria for Periodic Testing of-1 Nuclear Power Generating Station Safety Systems.
.-g IEEE Standard.344A1975 Recommended Practices for--
Seismic Qualification of Class-IE
. Equipment for Nuclear Power 1
Generating Stations.
A IEEE Standard 383-1974 J-i
. Type Test of Class IE Electric.
~ Cables,. Field Splices, and
[A
. Connections for Nuclear Power Generating' Stations.
Criteria for Indepen'dence of '
IEEE Standard 384-1981 ClassLIE Equipment;and Circuits.
IEEE Standard 387-1977 fCriteria for Diesel Generator Units Applied as Standby Power Supplies for Nuclear Generating Stations.
IEEE Standard 450-1980 Recommended Practice for m
' Maintenance, Testing, and Replacement of Large Lead Storage Batteries'for' Generating Stations-and Substations.
-IEEE Standard.484-1975 Recommended Practice for Installation Design and-Installation of Large Lead-7 y
. Storage Batteries for Generating Stations and Substations.
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'IEEE Standard 535-1979-Qualification of Class IE Lead
_ Storage ~ Batteries for Nuclear Power Generating. Stations.
~
.'IEEE Standard 650-1979 Qualification of Class IE Static Battery Chargers and Inverters c
for Nuclear Power Generating'
5 Stations.
_In referencing the foregoing: documents, the licensee stated that s
when"there,is not complete agreement between Industry _ Standards and
~
1NRC documents,.NRC' documents take precedence.
e
. While providing an overall-commitment to the guidance contained in the.above documents, the licensee also noted several areas where exceptions ~ exist.- Each of these is. discussed below.
- General Design' Criteria 17-
~~
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_.The' licensee notes.that during Cycle 7, the train "A" Control Room essential _ heating', ventilating and air conditioning (HVAC) system
~
will not. normally be capable of being powered by the onsite ' power n
source. This is because this'new-HVAC system was designed to be
- 4
' powered by the new diesel generator,'GEA2.,As noted previously,
, J.
'this new diesel ~is not yet_ qualified for service; therefore, the.
planned source of onsite power for this system is not available.
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-When: allowance =is made for the maximum possible required safety-loads on the existing "A". train diesel generator' GEA, there'is u J
~
insufficient capacity'to assure the capability of also powering the train "A" Control Room HVAC from this source. The licensee notes, however,' andlwe: agree.that it is probable that if an accident did.
- occur, the specific natr o of the accident would allow some of the
" required _ safety loads" t be shut down after an initial period of m
9fi
_ operation.. For example, if the: accident was a "large break =LOCA",_
there.would be no need for high pressure injection and:this load HP' could be removed. Conversely,;if.the accident was a "small break, LOCA", there would be no need:for. low' pressure-injection..Thus,.
~
sufficient ' power could probably be 'made available for ' operation of:
this HVAC: system.
)
.Notwithstanding~thh~ foregoing, it is noted that the other (train-4C "B") Control-Room essential HVAC willL be capable of ~being powered by onsite power. This is'because of'the extra capacity available from the. existing:"B" train diesel generator', GEB. This additional capacity is available because in contrast'with train '!A", the strain "B" diesel.is not.needed to power the train "B" Auxiliary
' + '
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- Feedwater Pump. This in' turn,.is because this train is normally.
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aligned to use the steam turbine drive as the prime mover'for the train "B" auxiliaryL feedwater pump
'rather than the electric motor r-drive which'aust be used on train "A".
'Thus,.because_of the limited electrical capacity available pending' qualification of the new diesel. generators, a loss of offsite power s -
would result'-in (at least a temporary) situation where the Control l$~S 1
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WW 33-lRoomHVACsystem;wasnon-redundant. This is not a change, however,
~
- because prior to this modification, the facility (as ~ originally
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constructed) only.had :a single non-redundant Control Room HVAC f1.
system. Therefore, we conclude the proposed temporary condition
.does!not constitute a' reduction in the present level of safety, and m
is a step in the process of providing an increased level of safety l
'when-the.new diesel generators are.available. Accordingly, we find
- operation.in the proposed. mode acceptable during Cycle 7 and ending prior'to startup in Cycle 8.
~ Regulatory Guide 1.32/IEEE 308-1974-
-The licensee states the physical position of the. battery charger output circuit' breaker is not monitored as required by Section 5.3.4(5)C of IEEE Standard 308-1974. The. licensee-justifies this.on the basis the DC: output breaker of'the charger is considered to be ' closed at all times when the charger is in service. Further, y
the licensee states the molded case type of breaker can
' automatically trip open only:for an internal fault inside the charger because ~ the breaker trip point.is above ithe maximum output
- level of the charger. In addition, there will be an alarm any time-the' charger output. breaker automatically trips ^open-due to-internal faults',;and charger: failure will be alarmed..In addition,.the
~
-licensee ~ states that manual opening of the charger breakers is I
-administrative 1y controlled, and is only done when the charger is to
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be taken out of service s-at which time the' spare charger is inanediately. switched 'on.
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'While we agree administrative controls can be_ effectively utilized
~
to assure operability for systems important to safety, we also believe; monitoring.provides defense in depth'against operational errors
~ Therefore,. in response to the ' staff's inquiry into this matter, the: licensee, by letter dated March 21,.1985, agreed to n'-
provide battery bank voltage'as an' input.to.the plant monitoring M
. computer prior.to operation in: Cycle 8.
We-believe the monitoring proposed by the~ 1icensee:is effectively equivalent to monitoring -
battery charger ~ output circuit breaker position.
.On the basis.of the existing alarms for signaling battery charger malfunctions, the licensee's existing administrative controls, the.
licensee's commitmentito install battery bank voltage monitoring-priorLto operation.in. Cycle 8, and because certain of the loads to
- be powered by these new battery banks are those required by' NUREG-0737 and thus contribute'to the safety'of plant operations, we' conclude that operation in Cycle 7 with existing alarms and administrative controls ~~is acceptable.
[
Regulatory Guide 1.128/IEEE 484-1975; 4
~The-licensee has presented calculations which indicate that average hydrogen concentrations'.in the battery roomsLin the NSEB will be l
well below;the two percent limit specified by this Regulatory Guide.
'The staff has performed independent calculations for the worst case t
situation which confirm these results. Nevertheless, while f.
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inspecting these rooms, the staff noted the air supply and air =
. return registers were installed on duct extensions such that the registers were about' twenty inches below the ceiling.
Because
'R.G. 1.128 states "The ventilation system shall. limit hydrogen concentration to less than two percent by volume.at any location n,
Lwithin the battery area'.', the staff inquired as to the effect of the lowerediregisters on producing non-uniform hydrogen concentrations.
Of particular concern was'the possibility for formation cf hydrogeu
-l pockets"..In response, the licensee cited.NUREG/CR-0304, " Mixing of Radiolytic Hydrogen Generated within a Containment Compartment Following a LOCA" to demonstrate that even.in the absence of forced ventilation there would be very little non-uniformity of concentration. We have reviewed this reference and agree with the
-licensee's-conclusions. Accordingly, we conclude the design of the-
~
battery. rooms in the NSEB conforms to the guida'nce'in R.G. 1.128 with respect-to maintaining. hydrogen concentrations below two percent at all locations.
- Inh he' licensee's submittal of March 15, 1985, it:was stated that' t
ithe. requirements of R.G. 1.128 were met except that hydrogen surveys-would not be conducted. The licensee presented a justification of.
this position based'on the. low hydrogen concentrations that were'
~
calculated to occur.' The staff advised the licensee, however, that
~
'the hydrogen surveys were only required following.. initial battery
- installation and served to validate the theoretical' calculations of-
. hydrogen concentrations. Because of.the importance of-validating calculations to" assure their accuracy, the staff' asked the licensee to perform the post-installation surveys..
By' letter dated May.14,
.1985-(RJR 85-220); the licensee agreed to this. request.
~
- Appendix R to 10 CFR'50/ Regulatory Guide' 1.75/IEEE 384-1981; The licensee states-that with two exceptions, the design.and d'
installation of the modifications to the auxiliary electric system have been based on the requirements of Appendix R, Regulatory Guide 1.75'and IEEE 384. As a matter of clarificationi however, the,
' licensee also notes that the Auxiliary Building and: Reactor Building
.were constructe'd before R.G. 1.75'was issued. As a result the H
raceway systems in'these original. buildings,-which now connect to the NSEB raceways, were' designed to meet the original' plant. criteria L
for. separation of redundant trains. ~The, licensee adds that these ~
L raceways are now being. upgraded to meet the new NRC: fire' protection-requirements for Rancho Seco - including those 'of Appendix R to 10 L
CFR 50.
LTheLlicensee states the first exception to conformance with Appendix R occurs in Fire Areas 84.1 and 85.1, where cables from both= electrical. divisions are present. These fire areas are the L@*
'second and third' floor corridors of the NSEB; and the~ cables
-involved are those which control the essential HVAC system supply air dampers for the Switchgear Rooms and Electrical Equipment Rooms.
A fire in this area, therefore, could misposition one or both of.
these" dampers.
If this were to occur, HVAC service to one or both trains of essential electric power in the NSEB could be disabled.
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By letter dated May 16, 1985, however, the licensee reported that this was acceptable for Cycle 7 because, with the electrical loads-
~
to be_used in this cycle, the equipment in the NSEB necessary for plant shutdown could remain functional with-a loss of HVAC service.
This'is-discussed further in the section titled " Environmental ~
1 Effects on1 Equipment." In-discussions-with'the licensee's_
representatives,wthe licensee also notes there :is little risk of
+ _
Lactually--losing the HVAC' service because of'the_very low installed
- fire loadings in these areas-(estimated fire-durations of 0.00 and' 0.02' hours, respectively), the preparation of pre-fire plans for
- each area (which includes a list of the components'that might be
_affected by a fire in_ the _ area), and the time' available (a few hours)- for correcting the condition before high temperatures would occur through heatup. We.also note that, in the absence of fire
-damage, alarms aresent to the Control Room whenever high temperatures occur :in the Switchgear Rooms..In the above letter, the~1icensee also committed to correct this condition prior to Toperation in Cycle 8.
Based on these considerations, we conclude that operation with this configuration during Cycle 7,does not present an undue risk to the -
^
, health and safety of the public. JAccordingly, we find such operation in the proposed. mode acceptable.
~The-second.' exception'noted by the licensee is the absence of fire 7
detection and suppression systems for the roof-mounted-essential-HVAC-' systems. The licensee justifies this omission on the basis'of -
low fire loading in the area,. wide separation of the redundant.
' essential HVAC units, the absence of intervening combustibles and the-natural dissipation of heat buildup into the surrounding open air. Based on this reasoning'the licensee has requested an-
~
' exemption from the provisions of Appendix R which would otherwise
' require such-.a system. This exemption, however, is the subject ofa separate licensing action. -Based on the staff's review of the fire protection-features of the NSEB, the physical arrangement of.the equipment, and the materials.present, we conclude there is a very-low. probability of a fire involving both trains of the roof-mounted.
essential HVAC. Accordingly, we further conclude operation of the facility pending resolution of the request for. exemption, would not result in an undue. risk to the; health and safety of the puolic. We therefore find such; interim operation ac'ceptable.
'On the basis of'the licensee's description of the NSEB, the design and-separation criteria specified by the licensee for~this
^
_ structure, and inspection of the facility, we conclude that except as noted'above, the facility meets the requirements of Appendix R.
Branch Technical Position PSB Adequacy of Station Electric Distribution System Voltages As a result of the' proposed modifications to the facility electrical system, the licensee has performed a voltage analysis to determine if any changes in the protective-undervoltage or overvoltage li setpoints or technical specifications were required to support the
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T additional loads. As a result of.this analysis it was determined
- that an additional voltage drop would occur in the startup transformers such that' corrective action was needed. To correct the.
icondition so that all electrical equipment would have voltages as
~
. described in the. licensee's' response to the letter from William Gammill to Power Reactor Licensees dated August 8, 1979, the'
. licensee determined it was necessary to increase the presently-
.specified minimum switchya'rd voltage from 214 kilovolts lto
+
215' kilovolts. During a visit to the facility, the staff examined
.these' calculations and concluded.the calculations appeared to have been performed properly. With this. increase in the minimum switchyard voltage, the licensee has determined that no other changes are. required in the existing settings for the undervoltage and overvoltage protective relays. Because the-switchyard voltage N
,is.a limiting condition for operation addressed by technical
! specifications 3.7.1.J and 3.7.2.H, the licensee has also proposed 1 7 to increase the11imiting values in these. specifications by one L,' '
- kilovolt. ' Based on the foregoing, we' conclude'the licensee has-satisfactorily addressed the requirements of PSB-1.
~ Control Room Habitability The original. design of the facility provided a single HVAC system-J' for the Control: Room. This system was powered from' electrical n1
.. train "B" (Bus:3B and MCC S2B1) and was automatically loaded onto
.the essential bus following generation of a Safety Features
' Actuation Signal (SFAS). Because of upgrading the Control Room HVAC system, including addition'of an HVAC system for the Technical Support Center (TSC), Bus 3B and MCC S2B1 could no longer accommodate the-new electrical load. As a result it was necessary for'these loads to be moved to new bus ~3B2.
In addition, as part of the upgrading, a redundant HVAC system for the Control Room and TSC was also'provided and was designed to be powered by electrical train
~ ;
A". This system will be connected to new bus 3A2.
As discussed in paragraph B, above, during Cycle 7 new. buses 3A2 and 3B2 will be energized via transformers X43A2 and X43B2A while offsite power is available, and will be' energized via the cable
. interties from buses 3A and 3B respectively if there is a loss of offsite power.
In-the licensee's submittal of November 15, 1984,
-the' licensee proposed that in the event of a-LOOP, buses 3A2 and 3B2.
t would be. energized by manual-closing of the breakers' associated with.
- i the cable interties. The staff noted, however, that although an
' upgraded' system was being provided, this represented a reduction in the' level of safety from the present installation because it was a g
s change from automatic to manual initiation of.the Control Room HVAC system. This reduction 'in the level of safety was ' brought to the attention of the licensee. JAs a result, the licensee modified the
. electrical design for Cycle 7 to provide automatic' connection of new<
. bus 3B2 (and thus the train "B" Control' Room HVAC system) 'via' the cable intertie to bus 3B, and automatic, initiation of the train "B"
. Control-Room /TSC HVAC systems 'According to the licensee, and we
' agree, this arrangement provides substantially the same. level of.
- safety as provided by the unmodified; system.
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x b-Regarding train."A", the licensee has not implemented a similar
' modification for Cycle 7.
This is because the capacity of the
- existing train "A" diesel generator is fully utilized by other
-.pla'nned initial loads. As previously mentioned, however, postulated accidents will most likely permit removal of certain loads after
' initial operation and subsequent manual loading'of the train "A" Control-Room /TSC HVAC system.if needed.
i 0-
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Because the proposed mode o1 operation during Cycle 7 will provide substantially the same level of safety with' respect to Control Room
~
' habitability as is presently provided, we conclude this aspect of-the_ proposed modifications is acceptable.
e
. Equipmenti Electrical Capacity / Rating x
Diesel Generators..-Based on the planned loading during Cycle 7, the.
licensee concludes diesel generator GEA will have no useful spare
. capacity. Generator GEB, however, is estimated to have a spare
. capacity of about 253 kw.
This spare capacity remains after the Control-Room /TSC HVAC and'.the train "B" NSEB HVAC loads have been-energized.- The licensee notes that if it became necessary to power.
. auxiliary feedwater pump P-318 from the "B" train,- the Control-V Room /TSC HVAC, the NSEB HVAC-and the Class 2 battery charger H4BN1
. electrical loads would have to be removed from the train. The staff note's this should be necessary, however, -only if there was a I,00P.
1 combined with concurrent inability of_both the train "A" and steam turbine l driven train "B" auxiliary -feedwater pumps to operate. Even
~
under these circumstances, if the problem lies, with the train "A"
. auxiliary feedwater pump and not'the train "A" diesel ^ generator, it would-still be possible to energize the Control Room /TSC HVAC system from the train "A ' diesel.
Based on: (1) the: fact the present Control Room HVAC system is not-redundant,~(2) the combination of circumstances that would be necessary to prevent, operation of the Control Room /TSC HVAC system 1
in the proposed: configuration, and (3) the limited time the facility will be operating in3the Cycle 7 configuration, we conclude
. operation in'this mode does not reduce the present level of safety and is therefore acceptable.
Cable' Interties The licensee states the train "B" cable intertie is rated for 630 amperes continuous operation at 90*C.
The licensee also cites calculations demonstrating an' emergency rating of 890 Jamperes (at 130*C) for 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> in any twelve months up to a total of 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br />. According to the licensee,.the worst case loading on this intertie during Cycle 7.would be 865 amperes - or less than the s
emergency rating. This worst case conditibn consists of the normal electrical loads served by bus 13B2'(primarily battery chargers),
~
i plus the Control Room /TSC and NSEB HVAC; systems, the essential
> pressurizer heaters:and the Post-Accident Sampling System (PASS).
The licensee states.this estimate is conservative because part of
. the. increased amperage would operate the NSEB IIVAC system which will
' decrease the temperature in the.NSEB and thus reduce the temperature to which.the cable would be exposed (an ambient temperature of 115*F v
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o 1was assumed).
In addition, all listed loads were assumed operating
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simultane_ously atitheir full' rating.'.The licensee states _that the circuit breakers _will have trip settings;such that this~ emergency rating is lower than the breaker set points minus their tolerances.
l The-train "A" cable intertie is rated for 533 amperes continuous -
operation at 90*C or 751 amperes forf130*C emergency _ operation.
Full loading.(similar to the train "B"~1oading-listed above).
requires only 699 amperes for-this train - which again is less than-
-the emergency rating for this cable tie.
In addition,.the licensee states the actual maximum load'during Cycle _7 will be'less than~this because of the limited capacity o'f transformer X43A1.(see below).
[We have reviewed the industry standard cited.by the licensee, NEMA 1
Pub. No."WC~7-1971 (R1976), " Cross-linked-thermosetting-
^
polyethylene-insulated Wire and Cable for the Transmission and
",~
Distribution'of Electric: Energy",-the licensee's calculations related to emergency ratings and the other information submitted by.
-.the-licensee. Based on this review, we conclude that'in the event
'of a LOOP.and receipt of Safety Features Actuation Signal'(SFAS),
operation.in the proposed mode would require operation of the cable H,
Linterties at load levels in excess of their normal ratings, but within-the emergency ratings specified by the industry standard
- cited above. We also note there is=a low probability of occurrence of a LOOP combined with an SFAS during the limited period (Cycle 7) for which this. configuration is being proposed.
In addition, we note that by providing a second (train "A'!)lHVAC system for the -
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- Control Room /TSC, the proposed configuration affords the licensee =
_ probable additional means for maintaining Control Room habitability.
(as previously noted, the present system is no1-redundant).
I
. Based on the foregoing, we conclude the safety benefits gained by
.providing additional' capability to maintain Conttol Room /TSC-
- habitability and_ by~ timely implementationiof additional NUREG-0737
-requirements (s'uch as PASS), outweigh any adverse effects which-y,
.might result from operating the^ cable. interties in excess of their~
normal current ratings but within'their emergency ratings.
LAccordingly, we conclude operation in this mode during Cycle 7 is
. acceptable.
Station Service Transformers As shown in Figure 3, 'in the eve _nt-of a loss of offsite power, all loads' on buses 3A/3A2 and 3B/3B2 will be supplied via transformers X43Al and X43B2A respectively..The' acceptability of.this mode of
- operation is therefore dependent on the load carrying capacity of these transformers relative to safety-related loads.
Regarding transformer X43Al', the' licensee states this transformer is-oil-filled and has a_ nameplate rating of 1120 kva with a top oil temperature of 110*C.
Because of this temperature limit, the licensee states this transformer cannot simultaneously accommo'date both the Control Room /TSC and the NSEB train."A" HVAC.in addition to the other safety-related loads. 'The transformer can, however, s
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' accommodate either~ one of these HVAC systems in. addition to other
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. safety-related ' loads.. Under'the worst _of_these conditions-, the s
' licensee estimates'the electrical load would be-1212 kva. The.
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11icensee has calculated that under these conditions, this additional G ---
Lloading could.be functionally' accommodated by the transformer and
'that the ' decrease in transformerflife would not be significant. We
.have reviewed these calculations and-concur with the' licensee's conclusions in :this matter.
.s According'to the. licensee, the' train'"B" transformer, X43B2A, is'a
- 11500 kva transformer with insulation for a.150'C. temperature rise.
The. transformer, however,-is currently rated 1120 kva at an 80'C
_ o temperature rise iTh~e licensee states this was done to provide a
- qualified' life'in; excess of 40 years.
In the event it was necessary' cy=
Lto' operate this' transformer with the worst case emergency loading
.^"
1 proposed for Cycle'7"(1473 kva, 117 C temperature rise), the' 1
ilicensee estimates'that operation at'this load would increase the' trate of aging of the transformer-by a factor of about 36..
Based-on-h
-the estimated. life.for'.this transformer at its present rating s
(940 years), the licensee concludes the reduction in transformer-life caused byfshort' term operation at this higher load level:is racceptable;
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. Based.on the foregoing, we. agree that cperation in:the postulated i
" accident conditions might require <short term operation of-J transformers X43Al and X43B2A at load levels somewhat' greater than
-their. present nominal ratings. We also note.this would result:in!
H sometreduction in the estimated service life of these transformers.
Nonetheless, we conclude.there would be no reduction in the.
capability of the transformers to perform properly u'nder postulated accident conditions.
In addition, we conclude'that~even if-an1
~ accident 1were to occur, the period of operation"above. normal ratings-
'would be relatively short in duration so that-the effect on 3
estimated service life would not be significant.- Accordingly, we!
conclude that with. respect to transformer 1 ratings,' operation in the-proposed mode during Cycle 7 is acceptable..
' Environmental Effects on Equipment 0
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The licensee's submittal'of March 21, 1985 states the normal temperature specified for equipment located'in the NSEB is 50-80*F:
.and the abnormal specification'is 102*F-based on 10 eventsaof.
- 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> duration'each. The licensee states.these. specifications will me
^
'not be exceeded uif either the normal or essential HVAC systems operate. We have noted previously that in the event of a loss of offsite power, both the Control Room /TSC and the NSEB'~ essential'HVAC-systems could be powered by.the train "B"' electrical system, and-that the train "A" electrical system could operate either.the Control' Room /TSC or the NSEB essentia1'HVAC system.
It is also-
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'noted, however, that separate essential HVAC systems are provided.
- for 'the :NSEB -- one for ' train "A"' and 'one for train "B".
- Thus, properf environmental control of both the "A" and "B" sides of the NSEB. requires'one HVAC' system for each side.
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2 However, as discussed above, with a LOOP and receipt of a Safety
. Features Actuation _ Signal, there is ample capacity to power _the Control. Room /TSC (via train "B") and probably ample capacity;to:
power both sides of the NSEB-(via trains "A" and "B").
If,.of course, one. electrical train failed, then at least the Control Room /TSC essential HVAC system could be maintained in-operation.
In addition,.if it were the "A" train that failed, both the Control N
Room /TSC and the'NSEB_ train "B"'HVAC systems.could be maintained in
. operation. : On the 'other hand, if the '"B" train were to fail, any.
. available. capacity in train
'_'A" would be used to energize the
+
Control' Room /TSC essential HVACisystem, and the NSEB HVAC systems could be without' power. -
l iThe licensee has considered such an occurrence and the consequent.
. effects on the equipment in the Control Room. The licensee states that when the_outside air temperature exceeds 95*F, the temperature
.of the air in the switchgear rooms can exceed 102*F. Thus considering'the maximum recorded temperature of 115 F outside air temperature, the temperature in these rooms theoretically could reach 122*F.
This, of course, is conservative in that.it ' assumes an extended period of a constant temperature of 115*F (instead of a peak) and does not.takeHinto the account the time required for heatup. Even so,'the licensee has evaluated the effect,of reaching-a_ temperature of 122*F in-these rooms and concludes that all safety-related equipment would' remain capable of performing required-
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safety functions (letter dated May 14, 1985, RJR 85-220).
.Since the licensee proposes that the essential HVAC systems for each
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side.of the-NSEB be manually loaded onto the respective electrical
- buses,.the-staff inquired-as to the signal that would alert the
-operators'to the need-for starting these systems. The licensee responded that this'need would be signaled to the Control ~ Room by'
-means of alarms initiated by high temperature conditions in the NSEB. Further' discussion, however, revealed these alarms had not yet been-implemented. -'After discussions with the staff, the
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licensee ccamitted, by letter dated May 14, 1985 (RJR 85-220),
to
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implement these alarms: prior to power operation in Cycle 7.
Because t'
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of the: limited-fission product inventory and stored _ decay heat ~
en'ergy present prior ~ to operation at power and because there are lower thermal ~and electrical loads involved:in' dealing with accidents which occur at.these levels, we conclude the proposed
' schedule for implementation of these alarms is acceptable.
u
. We have reviewed the information submitted by the licensee. Based on this review and the considerations set forth above, we conclude there is reasonable assurance that with respect to environmental effects upon equipment, operation in the proposed mode during Cycle 7 will not constitute.an undue hazard to the health and safety of the public, and is,' therefore, acceptable.
1
- E.
C A CEPTABILITY OF THE' FIRE PROTECTION MEASURES FOR THE NSED By. letters dated April-12 and May 14, 1985 (RJR 85-233), the licensee submitted preliminary and final copies of the Fire Hazard j;
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- 19
.l 4 Analysis Report for the NSEB. This report is a portion of the
- overall re-analysis of fire -hazards being performed for the Rancho Seco
- facility. By letters dated November 15, 1984 ~and April 16, 1985, the licensee submitted information concerning the conformance of:the NSEB.with regulatory fire protection guidance. Specifically, these submittals' addressed (for the NSEB only) conformance with 10 lCFR 50.48;.10 CFR 50, Appendix A, Criteria 3 and 5; 10 CFR 50, LAppendix R; Regulatory Guide 1.78; NUREG-0800, Standard Review Plan
- (SRP)-Section 9.5.1 and the following sections of NRC Staff Branch Technical. Position CMEB 9.5-1:
Section 5~.
General Plant Guidelines Section 6; Fire Detection and Suppression Section17.
Guidelines for Specific Plant Areas
'Section-II.D of this evaluation has already considered the conformance of the NSEB to the requirements of 10 CFR 50, Appendix R.
That pa'ragraph ' concludes that except for ' questions
,concerning overall plant conformance with Appendix R,..certain. cable re-routing to be performed for Fire Areas 84.1 and 85.1, and the resolution of an exemption request concerning fire detection and l
suppression systems for roof-mounted essential HVAC equipment, the NSEB meets the requirements of Appendix R.
Regarding 10 CFR 50, Appendix A,. Criterion 3, the licensee states this criterion:is satisfied because the structure has been designed
.to have appropriately rated fire walls, and because the fire protection system has adequate capacity and has been designed to minimize the effect of inadvertent actuation. Based on our review of.the design of the NSEB and its fire detection and suppression systems, we conclude that, with the exceptions previously noted, the facility has been designed to minimize-the effects of fires on-isafety-related equipment, and thus conforms to the requirements of
[
As noted, the-licensee has committed to lT
= correct one item; and the other item is the subject of a request for an exemption.' Based on conformance with. regulatory guidance'in the other areas of the building -design, we conclude use 'of the facility s
pending resolution'of the-exemption. request is'. acceptable, i.
The licensee states General Design Criterion 5 does not apply to this_ facility because Rancho Seco is.a single unit plant. Because 2 Criterion 5 addresses the sharing of systems and' structures between multiple units at a site and because Rancho Seco is a single unit
. site, we agree that Criterion 5 is not applicable to Rancho Seco.
Regarding Regulatory Guide 1.78, " Assumptions for Evaluating the Habitability of a' Nuclear Power Plant Control Room", although-Standard Review Plan (SRP) Section 9.5.1 references this guidance, the licensee states this Guide.is not applicable in the present instance because the NSEB does not contain a Control Room. The
' design of the facility supports the licensee's statement. Therefore we conclude Regulatory Guide 1.78 is not applicable to the NSEB.
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Fire-Hazards Analysis-i L
The licensee's Fire Hazard Analysis examines each of-the Fire Areas in the NSEB. For=each Fire Area, the licensee describes the maximum fire-severity, the equipment located in the fire area, the fire detection / suppression: features, the type of construction used in the -
boundaries of the fire area, the consequences of inadvertent operation'or-rupture of the fire suppression system, the~ ability.of o the-plant to achieve hot and cold shutdown following a fire in.each area,s and electrical faults that could be caused by a fire in the Jarea. This a'nalysis is then used as the basis for the physical
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separation and fire protection design of the facility.
We' have
- reviewed this analysis, and except for-the subject 'of ~ emergency h ghting, conclude.the scope and the depth of the analysis was
- acceptable. ' When the subject <of conformance with 10 CFR 50,
. Appendix R,Section III.J requirements was discussed with the licensee's. representative, the licensee ' responded by letter dated
-May 16, 1985 stating that, although not addressed in the Fire
- Hazards Analysis, inspection had been conducted and the NSEB did conform to this' regulatory requirement.
~
Branch Technical Position'CMEB 9.5-1 Certain of the sections in this Branch Technica1' Position (BTP) are
- e applicable to the entire facility and not just to the NSEB. Because this review is. limited to the NSEB, we have limited our. review to those sections applicable to an individual structure. These sections are;Section 5, General-Plant Guidelines;-Section 6, Fire Detection and-Suppression and Section 7, Guidelines for Specific Plant Areas. ~The_ licensee's evaluation of the NSEB design against theirequirements' of Sections' 6 and 7 were contained in the licensee's submittal of November 15, 1984. At the staff's request cthe licensee also submitted by. letter dated April 16, 1985, an assessment of NSEB compliance with Section 5 of this BTP. Each'of J_
.these sections is discussed below.
/ -
BTP CMEB 9.5-1, Section 5 -We have; reviewed;the licensee's assessment of conformance with thistsection of:the BTP. :Except as noted below,'we' find the design' conforms with the guidance contained in Section15. The exceptions:are as follows:
Roof-mounted HVAC Systems. Fire' detection and suppression systems are not provided for-this roof-mounted essential HVAC equipment. The_ licensee notes theue units are installed on the open roof area of the NSEB and:the equipment units of trains "A" and _"B" are separated liy 45 feet. Based on these~'
considerations, the licensee has. requested an exemption from the requirement _ for providing. fire detection and suppression systems for this open area. 'As indicated earlier, this exemption request is the subject of a separate review. For the reasons.previously stated, we conclude there is no undue risk to safety _by allowing normal plant operation until this matter is resolved.
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21 Line-type thermal detectors. Line-type. thermal detectors have
- not been installed in the cable trays as specified by the BTP, and by letter dated May 14,'1985 (RJR.85-238), the licensee.
Lwithdrew a previous commitment-to install-such detectors. The alicensee justifies this on the' basis of the separation of the "A" and "B" trains by three hour rated fire barriers, and the.
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.use of ionization detectors for area smoke detection. 'We note that. operating experience indicates a continuing need for addition of cables to cable trays.- and, because the line-type thermal detectors should be placed-on top of all other cables in the trays these' operations can cause damage to the line-type detectors and/or, reduce their' effectiveness. Because
~
alternative detector's of-proven performance ~ (ionization detectors) are_available for fire detection, we conclude there
.is no significant(risk to safety by allowing substitution of-
~
. ionization-detectors for the line-type thermal detectors.
. Conduits'1 css tha'n 4-inches in diameter. This section of the BTP permits scaling conduits under:4-inches in diameter at the-ends, rather than at the fire barrier, when the conduits extend
.more'than five feet from the< barrier. mThe licensee states that
~
in-some instances these conduits.have been sealed at the, ends
- when they did not extend more than five feet from the-fire barrier - Because the purpose of the seals is to prevent the passage of' smoke and hot gases, we conclude the most important factor is.that the seals have been installed.. Further, when the seals have been installed'at both ends of the conduits, as the licensee states;is the case, we conclude the_ length.of-the conduits is not significant. Accordingly, we find this
. deviation acceptable.
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Outdoor oil-filled transformers. The licensee notes there is an outdoor oil-filled transformer less than 50 feet from the NSEB. By straight-line' distance, the transformer is 36 feet-h from the nearest wall of the NSEB.
In addition, there is an opening in this wall at an elevation of 15 feet.-
There is, however, an intervening concrete structure that shields the-opening in the wall from a direct > oil'spra) from the
' transformer. - The distance from the transfomer to this opening-L (measured' along ' straight lines around the int ervening structure) is 41 feet. The licensee states that although this is less than the specified 50 feet, the opening is an exhaust-opening and the wall is reinforced concrete approximately 24-inches thick.
Because the opening in the wall is shielded from a direct spray o
of oil from the transformer, because it is an exhaust opening e
and is 41 feet from the transformer and because the wall'of the in NSEB is thick concrete, we conclude this deviation from the BTP does not constitute a significant fire hazard to safety-related equipment and is,.therefore, acceptable.
.The licensee has noted several items for clarification. These include the fact that combustible flexible duct couplings were a
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used in the out-of-doors section of the normal (non-safety related) HVAC system, and the fact that certain utility doors (not-serving areas containing safety-related equipment) were not electrically supervised. After reviewing the clarifications given for Section 5, we conclude they do not represent a deviation from the requirements of the BTP and are accept?ble.
BTP'CMEB 9.5-1,-Section 6' This section addresses the Staff's requirements for fire-detection ~and suppression systems.
Section 6 also references various National Fire Protection Association-(NFPA) standards as acceptable guides for implementing these requirements..We have reviewed the licensee's assessment of conformance with this section and note the following:
In contrast with the requirements of Section 6, the fire
~
. detection systems are not Class A systems as defined in NFPA 72D. We note, however, that Class A systems were defined' in the 1975 edition of NFPA 72D,-but are no longer defined in current editionslof this standard. What was originally intended by a Class A system was one which could remain operable in the presence of a single failure. The present design provides_ supervised circuits; and those systems having automatic actuation utilize cross-zoned ionization and thermal detectors - where actuation of either detector will cause an alarm in the. Control Room..Thus, even with failure of one detection system, an alarm would be received and the
' suppression system could be manually initiated or manual suppression could be utilized as appropriate. Based on these capabilities, we' conclude this is equivalent to the'previously defined Class A system and is therefore' acceptable.
The licensee states the piping for standpipes and fire hose connections is purchased to meet the requirements of ANSI B31.1, " Power Piping"; the piping supports are Seismic Category I; and the piping is analyzed for Safe Shutdown Earthquake (SSE)_ loading,_but is not Seismic Category I because it is galvanized pipe with screwed malleable iron fittings.
The licensee justifies this on the basis that the existing fire water supply is not Seismic Category I, but the fire suppression system piping is seismically supported to preclude damage to Class I equipment.
Inasmuch as the piping is designed to conform to ANSI B31.1 and is seismically supported, L
we conclude the ' system conforms to the requirements of the BTP and is therefore acceptable.
The BTP specifies that provisions for locally disarming automatic carbon dioxide systems should be key locked and under strict administrative control. The licensee, however, has not I
provided for key locking this function. The basis for this
~
decision is the licensee's desire to retain the supervised and j
administrative 1y controlled system presently used elsewhere in
'the' plant where rooms are equipped with automatic carbon m
23 dioxide fire protection systems. With this system, any local disabling of the system is reported to and annunciated in the Control Room. The licensee states that adoption of a different system for use in the NSEB would not be appropriate. The licensee thus proposes to extend the present system to the NSEB. The only difference introduced by implementing this procedure for the NSEB is that disabling the suppression system will be annunciated on the Control Room computer rather than the fire protection annunciator panel. This is necessary because there is insufficient room on the existing panel for all of the new fire protection signals that are being added.
We believe simplicity of procedures serves the interests of safety, and therefore conclude use of one procedure throughout the facility is desirable. We also believe use of an administrative 1y controlled and supervised system (i.e., with annunciation in the Control Room), such as used by the licensee, is approximately equivalent in level of safety to use of a key lock system. Accordingly, we conclude this deviation from the BTP provision is acceptable.
We have also reviewed the balance of the licensee's assessment of conformance of the NSEB to the guidance in Section 6 of the BTP. Based on this review and the foregoing discussion, we conclude the Fire Detection and Suppression systems for the NSEB acceptably conform to the requirements of this BTP.
BTP CMEB 9.5-1, Section 7 This section of the BTP addresses the requirements for various plant areas. The licensee's assessment.of the NSEB design against the requirements of this section reveals no deviations from guidance except regarding the installation of line-type thermal detectors.
Initially the licensee proposed to install line-type thermal detectors in the cable trays in Fire Areas 81 and 82 (train "A" and "B" cable tunnels). These detectors were to be used in combination with ionization detectors to provide automatic actuation of the water spray suppression systems in these areas. The licensee did, however, propose to defer installation of the line-type thermal detectors until 1988, when installation of cables in the NSEB would be complete.
This, of course, would have delayed achievement of automatic initiation of fire suppression systems in these areas until the thermal detectors were installed.
As previously noted, however, the licensee has withdrawn the earlier commitment to install line-type thermal detectors in the NSFB. When asked the effect of this on change on plans for the automatic suppression systems for fire areas 81 and 82, the licenrec, by letter dated May 16, 1985, stated that the overall plans were unaffected: other detectors would be utilized to provide the cross-zoned detection and autcmatic suppression systems planned for these areas.
In addition, because line-type thermal detectors are not being used, it is feasible to implement automatic suppression for these areas prior to
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installation of all. cables in' the NSEB. Therefore, the licensee has also' committed to provide automatic suppression for these areas p.rior to operation in Cycle 8, rather than in
'1988.' Based on an 18 month operating cycle, this should result
'in iniplementation of the automatic systems about one year Sooner.
s Because there are several ionization detectors presently in these areas which will provide l Control Room alarms in the event of a_ fire in either of these areas - thereby permitting manual initiation of the suppression systems; because the licensee has committed to provide a system which conforms to regulatory guidance. prior to operation in Cycle 8; and because this change will provide automatic suppression to these areas at an earlier date than previously proposed, we conclude this configuration provides a satisfactory interim level of fire protection for these areas and therefore, is acceptable for operation in Cycle 7.
Accordingly, except for this matter, which is to be resolved prior to. operation in Cycle 8, we conclude the design of the NSEB acceptably conforms to the guidance contained in this.
section.
The staff concludes that except for the items discussed below, the
~
fire protection design criteria for the NSEB are acceptable and meet the requirements-of 10 CFR Part 50, Section 50.48 and General Design Criterion 3.
This conclusion is based on the meeting the guidelines of Branch Technical Position CMEB 9.5-1, Sections 5, 6 and 7, as well as applicable industry standards.
In meeting these guidelines, the licensee has provided an acceptable basis for minimizing the probability and effects of fires and explosions and has provided fire detection and suppression systems of appropriate capacity and capability. Regarding the absence of a fire detection and suppression system for the roof-mounted essential HVAC equipment, we have previously concluded the risk associated with temporary operation without such equipment is sufficiently sn.all that there is reasonable assurance the facility can operate safely until this matter is resolved. Regarding the absence of automatic fire
. suppression for Fire Areas 81 and 82, we conclude that because of the alternate means currently installed and available for detecting and suppressing fires in these areas, operation in cycle 7 without automatic suppression for these areas is acceptable.
F.
-ACCEPTABILITY OF PROPOSED TECHNICAL SPECIFICATIONS The licensee has proposed a number of revisions to the present facility technical specifications to reflect the modifications made to the electrical distribution and fire protection systems and the mode of operation for Cycle 7.
These revisions include additional limiting conditions for operations as needed to reflect the new systems and components added by the licensee in response to NUREG-0737 requirements, and additional surveillance requirements for this new equipment and/or mode of operation.
The changes
n 25 proposed for each section of the technical specifications are discussed below:
Specification 3.7 - Auxiliary Electrical Systems. The changes proposed for this section are as follows:
Addition of a requirement that at least one battery charger be operable for each of the new Class 1 batter es (A2 and B2) 3 being placed in service at this time.
Addition of a requirement that the inverters connected to the new Class 1 batteries be operable.
An increase in the minimum required switchyard voltage from 214 KV to 215 KV (to accommodate an increased voltage drop through the startup transformers).
Addition of a requirement that the interconnections between the existing 480 volt switchgear (3A and 3B) and the added 480 volt switchgear (3A2 and 3B2, respectively).be operable.
Revision of specification 3.7.2.G to clarify that a Nuclear Service Bus (which may be removed from service for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) consists of buses 4A and 4A2,.or 4B and 4B2 - where 4A2 and 4B2 are the new 4160 volt buses.
Revision of specification 3.7.2.H to increase all minimum voltage levels by one kilovolt.
Revision of the bases for the above specifications to reflect the indicated changes.
Based on the plant modifications proposed for implementation for Cycle 7, the staff finds these proposed revisions appropriate, complete and consistent with regulatory guidance. The staff has also reviewed the calculations performed by the' licensee to determine the additional switchyard voltage required to retain present voltage level protective setpoints for protection against degraded electrical grid conditions for the load conditions as they will exist during Cycle 7.
No deficiencies in the assumptions or method of performing this calculation were identified. Based on the foregoing, we conclude the changes proposed for technical specification 3.7 are acceptable.
Specification 3.14 - Fire Suppression The changes to this specification proposed by the licensee consist of adding the fire detection and suppression equipment provided for safety-related areas of the NSEB to the lists of those fire protection components or systems required to be operable. The specific changes include:
Addition of operability requirements for fire detectors located in safety-related areas of the NSEB. A minimum of one smoke detector is required to be operable in each of the listed areas.
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.' Addition of operability requirements for the spray / sprinkler P'
systems-located in the NSEB cable tunnels and mechanical equipment rooms.
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~ Addition of operability requirements for the Carbon Dioxide extinguishing systems located in the NSEB switchgear and a
electrical equipment rooms.
Addition'of'the fire hose stations located on the first and second floors of.the NSEB to the list of hose stations required
.to be operable.
1 Based ~on our review of the changes proposed by the licensee, we conclude they are consistent with regulatory guidance'and the-n modifications being implemented for Cycle 7 and, are basically acceptable. _0ur review, however, revealed there were certain additional items not proposed by the' licensee that should have been proposed. Discussions with the licensee indicated.the licensee's audit also disclosed additional items that should have been proposed. By letter dated May 16, 1985, the licensee identified these items and. committed to _ submit a request for amendment of the
' facility technical specifications to' include these items.
In this
- 1etter the licensee also committed to operate in a manner equivalent to that which would be required if these items were included in the technical specifications. Based on these additional commitments, we
' conclude the licensee's present proposal for this section is-acceptable.
,~
. Specification 3.27 - Nuclear Service Electrical Building Emergency-
-Heating, Ventilation and Air Conditioning. This is a new
. specification propoced by the licensee to establish operability requirements 'for the essential HVAC systems :for the NSEB and establish allowable periods during which this equipment can be out of service. Specifically, the licensee proposes to allow the HVAC-for one train to be out of service 'for up to seven days and the HVAC for both trains to be out of service for up'to 3.5 days.
It is' the-staff's position that a system is only operable if'all of the auxiliaries necessary for'its' operation are also operable. A diesel generator, for example,-is not fully operable if its cooling,-
lubrication, fuel, starting and room cooling systems are not also operable. By_ adopting this position, it is not necessary to impose operability requirements for every auxiliary system - since the requirements are implied by the requirements imposed on the principal systems.
In the present case, the licensee is proposing a specification for a' system which is needed to assure the operability
=of Class IE electrical buses. As proposed by the licensee, however,
'it would allow the essential HVAC systems for both electrical trains
. to be out of service for up.to 3.5 days. This is clearly inconsistent with present specification 3.7.2 which makes no l
provision for continued plant operation when both trains of Class 1E power are out of service. Accordingly, we conclude the licensee's proposal in this area is not acceptable and is not' approved.
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- for
- the~ essential HVAC systems are implicit in the operability
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requirements:for the-systems they serve. Accordingly, in the-1 absence of justification for some less restrictive requirement, we conclude the-essential HVAC systems for the NSEB must meet'the same operability requirements as the. buses served via'the NSEB. On this o
basis,:no' additional: operability requirements are needed and none t
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1are issued.
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Specification 4~.6 - Emergency Power System Periodic Testina. The licensee: proposes to revise this specification =to include
~
r s operational testing-of the cable interties between buses 3A - 3A2,.
and 3BJ-'3B2, and the energizing of the Control, Room /TSC essential:
HVAC systems.7 Specifically, the proposed revision would require
? manual closing ~of'the. train "A" intertie and manual starting'of;the-a ni n
. associated Control Room /TSC essential.HVAC system;.and automatic' M
,.e closing of the train "B" intertie and automatic. energizing of the.
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train "B"; Control Room /TSC. essential HVAC system. The licensee ha's-also proposed: appropriate corresponding changes to the basis -for the'
?
j specification. We conclude the changes proposed by the licensee are 9
consistent with the proposed mode of operation in Cycle 7 andjare appropriate'and sufficient. Accordingly, we find the proposed-
'9 revision acceptable.
.y Specification-4.30 - Nuclear Service Electrical Building Emergency
/
Heatina, Ventilation and Air Conditionina. _The licensee has
~
proposed that: the essential. HVAC systems for the NSEB be tested 'each 31 days:to verify the operability of the systems. This test will consist'of measurement of the flow of the air handling unit to-y verify ~ the flow meets. or exceeds the design value ~(24,500 cfm 1.10%);
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and verifying that'th'e condensing unit is operational.
"Since these units are required to assure the operability'of the i[
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essential.HVAC systems for the NSEB,._we agree that surveillance q
specifications,should be provided. 1We)also find-the propose _d-specification incorporates an appropriate interval for testing and-
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appropriate measures for verifying operability. Accordingly, w'e
- J find this proposed addition to the facility-technical specifications,
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.i acceptable.
Specification 6.9.5 -'Special Reports. =The licensee proposes to l
revise item E.of this specification, " Status of Inoperable Fire-
' Protection Equipment," to add a reference to sections in the FireJ Protection' technical specifications requiring submission of special reports. -This is-an editorial change which is acceptable in p"
, principle.' We note, however, the list of referneces is not' complete, in-that the licensee failed to include sections 3.14.1.2,.
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3.14'.2.2 and 3.14.6.2.
Therefore, rather than create possible ambiguity regarding which sections of specification 3.14 require special reports (by' incorporating an incomplete list of references) i,
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we are denying the present request. The licensee can, of course, submit a1 revised proposal.which, if found to be complete, can be found acceptable.
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28 Ji o-III. CONCLUSIONS-Environmental Consideration This amendment involves aL change in the installation or use of a facility component located within the. restricted area as defined in 10 CFR
'Part 20.-
The staff has' determined that:theJamendment involves no-significant increase in the amounts of any effluents that may be released offsite, and that there is no significant: increase.in individual or
. cumulative occupational radiation exposure.
The Commission has
<previously. issued a proposed finding.that this amendment involves no significant hazards consideration and there has been no public comment on such finding. Accordingly, this amendment meets the eligibility criteria
.for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Fursuant to 10 CFR 51.22(b),' no environmental impact statement or envirotmental
. assessment need be prepared in connection with the issuance of this
-amendment.
L Conclusion We have concluded, based on.the considerations discussed aboie, that (1)
L; there is reasonable assurance that the health and safety of the public will not.be. endangered by operation in.the proposed manner, and (2) such activities will be conducted in compliance with the Commission's
" regulations, and the issuance of the amendment will not be inimicallto common defense and security or-to the health and -safety of the public.
Date:
Principal Contributors:
- G. Zwetzig-J. Burdoin-P.LQualls J
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