ML20127M059
| ML20127M059 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 01/21/1993 |
| From: | Durr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Opeka J CONNECTICUT YANKEE ATOMIC POWER CO. |
| References | |
| NUDOCS 9301280097 | |
| Download: ML20127M059 (3) | |
See also: IR 05000213/1992080
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JAN 211993
Docket No. 50-213
Mr. John F. Opeka
Executive Vice President - Nuclear
Connecticut Yankee Atomic Power Company
P.O. Box 270
Hartford, Connecticut 06141-0270
Dear Mr. Opeka:
SUBJECT: INSPECTION REPORT NO. 50-213/92-80
This refers to your letter dated August 7,1992, in response to conversations between the
NRC Region I staff and CYAPCO personnel. The purpose of these conversations was to
obtain additional information on selected topics and clarification of the unresolved item
regarding the discrepancies noted in the NRC's Safety Evaluation Report for Connecticut
Yankee Appendix R, Post-Fire Alternative Shutdown Capability, dated October 16, 1991.
Thank you for providing the requested information and the written notification of apparent
discrepancies in the NRC's Safety Evaluation Report (SER) for the Connecticut Yankee
Appendix R, Alternate Shutdown Capability, dated October 16, 1991. These items will be
evaluated and a determination of adequacy made at a future NRC inspection.
We note in your August 7,1992, comments to the unresolved SER Item No. Il(c), fourth
paragraph, you reference the necessity to terminate offsite power via the load dispatcher. In
addition, in your response to question Nos. 4 and 5, it is not clear that instructions or
procedures exist for operator actions to be taken in the event of fires of various types and
size. Please provide written rationale, within 30 days of receipt of this letter, for these
questions.
Your cooperation with us is appreciated.
Sincerely,
n up.s tv~ ant 1
Jc cyn P. D.;T
Jacque P. Durr, Chief
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Engineering Branch l
9301280097>930121
DR ADOCK 0500 3 Division of Reactor Safety
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John F. Opeka 2
cc:
W. D. Romberg, Vice President, Nuclear, Operations Services
J. P. Stetz, Vice President, Haddam Neck
G. H. Bouchard, Nuclear Unit Director
D. O. Nordquist, Director of Quality Services
R. M, Kacich, Director, Nuclear Licensing
Gerald Garfield, Esquire
Nicholas Reynolds, Esquire
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Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
State of Connecticut SLO Designee
bec:
Region I Docket Room (with concurrences)
R. Blough, DRP
L. Doerflein, DRP
W. Raymond, SRI, Haddam Neck
P. Swetland, SRI, Millstone
V. McCree, OEDO
DRS/EB SALP Coordinator
R. De La Espriella, DRP .
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JAN 211993
John F. Opeka 3
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NORTHEAST UTILITIES cener.i On.ces . seiden street. Beran, connecticut
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P.O. BOX 270
HARTFORD. CONNECTICUT 06141-0270
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August 7, 1992
Docket No. 50-213
Bi4208
U.S. Nuclear Regulatory Commission
Attention: Document Control Desk
Washington, DC 20555
Gentlemen:
Haddam Neck Plant
Response to Unresolved Item
Apoendix R inspection 50-213/92-80
During the week of June 22 through June 26, 1992, the NRC conducted an Appendix R
inspection for the Haddam Neck Plant. As a result of this inspection, one
unresolved item was identified. Connecticut Yankee Atomic Power Company (CYAPCO)
agreed to resolve this item in writing by August 7,1992. In subsequent
conversations between the NRC Staff and CYAPC0 personnel on June 26, July 3 and
July 6,1992, the NRC requested additional information on select topics, CYAPC0
and the Staff agreed to include these responses in the letter addressing the
unresolved item from the Appendix R inspection for Haddam Neck.
The unresolved item concerned the apparent discrepancies in the NRC's Safety
Evaluation Report for Connecticut Yankee Apg)endix R Post-Fire Alternative
Shutdown Capability, dated October 16, 1991. These discrepancies had not
been communicated to the NRC Staff in writing. CYAPC0 committed to provide
cocents in writing by August 7, 1992.
The response to the unresolved item and the responses to the NRC's request for
further information are documented in the accompanying attachment.
We trust you will find this information satisfactory, and we remain available to
answer any questions you may have.
Very truly yours,
7
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4 . M. Fox [
President and Chief Operating Officer
cc: T. T. Martin, Region I Administrator
A. B. Wang, NRC Project Manager, Haddam Neck Plant
W. J. Raymond, Senior Resident inspector, Haddam Neck Plant
(1) A. B. Wang letter to E. J. Mroczka, "Haddam Neck Plant--Appendix R Post-
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Fire Alternative Shutdown Capability," dated October 16, 1991.
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Docket No. 50-213
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) Attachment No. 1
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Haddam Neck Plant
! Response to Unresolved. Item from the Appendix R
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Inspection and Responses to.the NRC Request
i for Further Information
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August 1992
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U.S. Nuclear Regulatory Commission ,
B14208/ Attachment /Page 1-
August 7, 1992
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Response to Unresolved Item: '
Upon review of the NRC's SER for Connecticut Yankee Appendix R Post-Fire
Alternative Shutdown Capability dated October 16, 1991, CYAPCO submits the
following comments:
1. Page 2, Section 2.1, 2nd paragraph, 1st line:
For your information, an additional manual operator action is to connect
the fire hose to the DWST/ Fire Water.
2. Page 3, Section 2.2, 1st paragraph:
a) There is only one atmospheric dump valve. ,
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b) Component cooling water system operability is not required and may
not be available for control room (S-1), old switchgear room (S-2),
and cable spreading area (S-3A) fires.
3. Page 4, first paragraph, second full sentence:
"a maximum. allowable ambient air temperature of 149'F would have to be
present" should read:
"a maximum allowable ambient air temperature of 149'F would have to be
exceeded."
4. Page 4, third paragraph, fourth line:
" cable spreading area / room," should read " cable spreading area,"
5. Page 4,- fifth paragraph,' first sentence: This refers to Train B only.
6. Page 5, last paragraph, third line from the bottom: typo "deenergized"
should be "deenergize."
s 7. Page 6, fifth paragraph, third sentence:
Service water pump D will be started from the "B" switchgear roem and
valves SW-MOV-1, 2, 3, 4, 5, 6 and SW-FCV-129 will be deenergized and
repositioned as required to provide cooling water to the diesel.
8. Page 7:
a) Fourth Paragraph:
" Main steam atmosphere vent valves" should be " atmospheric dump
valve."
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U.S. Nuclear Regulatory Commission
B14208/ Attachment /Page 2
August 7, 1992
b) Sixth paragraph:
"SW-MOV-5 and 6" should be "SW-MOV-5 or 6."
c) Last paragraph:
i The only safe shutdown components which would require transfer from
the control room to switchgear room "B" are CAR fans 3 and 4. The
other components can either be controlled from the control room or
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9. Page 8:
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a) Fourth line:
Local operator actions may be required to recover. from'this fire,
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however, the control room will not be evacuated. The kill switches
will be closed as needed to overcome spurious operation of the
b) Third paragraph from the bottom:
FW-MOV-35 and 160 would be deenergized at their respective MCC's in
the cable vault, unless it was necessary to induce a loss of off-
site power.
10. Page 9:
a) Third paragraph from the bottom, third line, same coment as 7a.
b) Third paragraph from the bottom, fifth'line:
The Primary Water Transfer Pumps may be disabled by this fire,
therefore PWST availability cannot be assured.
c) Second paragraph from the bottom, same coment as 7b.
11. Page 10
a) First paragraph, same as~ coment 7c.
b) Third paragraph, same as coments 8a and 7c.
c) Fourth paragraph:
Control of the RCP's and pressurizer heaters could be lost frcm the
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control room. It may be necessary to terminate off-site power via
the load dispatcher to accomplish this function.
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B14208/ Attachment /Page 3
August 7, 1992
12. Page 11
a) First paragraph, same as comment 6.
b) Last paragraph, same as comments 7a and 10b.
13. Page 12, first paragraph, same as comment 7b.
NRC requests for further information:
14. In a letter dated January 22, 1990,(2) the NRC Staff requested additional
information rega By letter dated
March 29,1990,gding post-fire safe shutdown capability.CYAPC0 provided res
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for additional information. NRC question #9 was " Discuss your plans to
provide operational procedures for operator use in the event of a fire."
Reouest 1:
Clarify your response to question #9 as it pertains to A0P 3.2-45. Is
this an Appendix R procedure? Have the operators been trained in the use
of this procedure?
Response to Reouest 1:
! A0P 3.2-45 is an Appendix R procedure. Initial training on this procedure
l was provided to all licensed operators via a read-and-sign process.
Continuing training for new licensed operators is provided as part of
Licensed Operator Initial Training under lesson plan CYOPLOA0PL2400,
" Station Fires."
Reouest 2:
Clarify your discussion on the operability requirements for the component
cooling water system as it pertains to Appendix R safe shutdown
capability.
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l (2) A. B. Wang letter to E. J. Mroczka, "Haddam Neck Plant--Request for
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Additional Information Regarding Conformance With Appendix R Post-Fire
Alternate Shutdown (TAC No. 66169)," dated January 22, 1990.
(3) E. J. Mroczka letter to U.S. Nuclear Regulatory Commission, "Haddam Neck
? Plant 10CFR50, Appendix R Compliance Review, Response to Request for
Additional Information (TAC No. 66169)," dated March 29, 1990.
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B14208/ Attachment /Page 4
August 7, 1992
Response to Reauest 2:
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Component cooling water availability is required to support centrifugal
charging pump operation. Both centrifugal charging pumps may be lost for
control room, switchgear room "A" and primary auxiliary building (zone A-
1A) fires. For these fires, the charging metering pump will be utilized
to maintain pressurizer level during plant cooldown. The charging
metering puinp can operate independently of the component cooling water
system.
The charging metering pump may be lost for metering pump cubicle, "B"
diesel generator room, switchgear room "B" and waste disposal building
fires. For these fires, operability of one centrifugal charging pump and
one component cooling water pump is required.
Reauest 3:
Clarify your discussion on the availability of water sources.
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Response to Reauest 3:
All fire shutdown' scenarios assume the initial availability of the DWST as
a source of steam generator makeup. The technical specification volume o'
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50,000 gallons is adequate to supply steam generator feedwater for
approximately 3.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />, at which time an additional water source must be
provided. From the viewpoint of steam generator water chemistry, the
water sources which operators would attempt to utilize (in decreasing
, order of preference) are:
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1) Primary Water Storage Tank (PWST)
2) Recycle Primary Water Storage Tank (RPWST)
3) Well Water
4) Fire Water
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The first three options may not be available under loss of offsite power
conditions or due to fire damage to water transfer pumps. A gasoline
powered pump is also available to transfer water from the PWST or RPWST to
the DWST. This pump has been provided to support shutdown for non-fire
events and has not been credited in The Connecticut Yankee Appendix R
shutdown analysis.
The Appendix R backup to the DWST is the fire water system. The fire
water system is available for all fires and provides unlimited supply of
steam generator makeup inventory. Identification of these water sources
and the order in which operators would try to establish them is provided
in A0P 3.2-51.
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B14208/ Attachment /Page 5 '
August 7, 1992
Reouest 4:
Explain why CYAPC0 doesn't restore offsite power with the EDG-B running.
Response to Reouest 4:
Appendix R does not require establishing offsite power. Appendix R
assumes worst case fire scenarios. Plant design and procedures must be in
effect that assume these worst case fire conditions. However, fires of
lesser magnitude than " worst case" are possible. The operators are able
to assess the damage to the plant and restore systems as they deem
beneficial. It is reasonable to assume that the operators would restore
offsite power under conditions that allow restoration. There are no
control interlocks preventing the operators from placing offsite power in
- parallel with the diesel.
Reouest 5:
Why does CYAPC0 need to initiate a station blackout (SBO) in a cable
spreading area fire? Why does CYAPC0 need to initiate an SB0 in an "A"
switchgear room fire? Discuss how a control room fire could result in an
SBO.
Response to Reouest 5:
Before operator actions for specific fires are discussed, it is important
that the reasoning for operator shutdown actions be reviewed. Operator
actions for specific fires will then be discussed. These actions are only
utilized as a last resort and only during an all encompassing fire.
OPERATOR ACTIONS
1) The first operator shutdown action for any large fire is to gain
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control of plant systems so that required shutdown functions can be
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{ 2) The concept of plant system control can be broken down into three
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a. Control of components that are not essential to shutdown
systems, and are subject to fire damage.
l b. Control of components that are essential to shutdown systems,
t and are subject to fire damage.
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l c. Utilization of components that are essential to shutdown
j systems, and are free of fire damage.
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B14208/ Attachment /Page 6
August 7, 1992
3) All operator shutdown actions are based upon items 2a, 2b, or 2c.
A careful examination and understanding of items 2a and 2b is
essential .
4) Item 2a: Control of components that are not essential to shutdown
systems. and are sub.iect to fire damaoe
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If a component, its cabling, or devices, are located in the subject
fire area, there are two possible consequences due to fire damage:
Operability of the component is lost. The component cannot be
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controlled using its normal control circuitry. For example,
if a pump is running, there is the possibility it cannot
shutoff using its normal control circuitry. The necessary
operator action in this case would be to disconnect power to
the component. Similarly, if a component is not operatins. it
cannot be started.
b. The position or status of a component can change. Fire damage
can cause spurious operation or change the position of a
componeni sue to a hot short. For example, a pump that was
not running could start due to a hot short. Or, a deenergized
solenoid valve becomes energized and changes position. The
necessary operator action in this case would be to disconnect
power to the component.
5) Item 2b: Control of comoonents that are essential to shutdown
systems. and are sub.iect to fire damaae
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If a component has cabling or devices that are subject to fire
damage, it could also experience the same possible faults as
. described in item 4. There are two possible operator actions for
equipment that has to be operated that is subject to fire damage:
a. Isolate power to the equipment and manually operate the
equipment.
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b. Isolate the portion of the equipment's circuitry that is ,
subject to fire damage and provide alternate circuitry for
local control.
PLANT DESIGN
The physical layout of specific electrical distribution equipment
and associated cables at the Haddam Neck Plant is unique. An
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U.S. Nuclear Regulatory Commission
B14208/ Attachment /Page 7
August 7, 1992
understanding of their physical layout is critical before describing
operator actions for specific fires.
1) Offsite power: Two electrical power busways provide offsite
power to the "A" switchgear room by means of traversing the
cable spreading area.' Both buses (metalclad busway) enter the
cable spreading area from the south side, making parallel runs
for about sixty feet before going up to the "A" switchgear
room. The parallel busways have a horizontal separation
distance of about nine feet in the cable spreading area.
2) Generator and Bus control cables: The control cables for both
emergency diesel generators and their associated buses (Bus 8
and Bus 9) pass through the cable spreading area and the "A"
switchgear room in route to the control room. The control
cables for the "B" diesel generator and bus 9 can be isolated
from the cable spreading area, "A" switchgear room and the
control room, by means of disconnect switches located in the
"B" diesel generator room. Control of Bus 9 and thc "B"
diesel generator (after isolating their control cables) is
then accomplished by local controls in the "B" diesel room.
All isolation switches and their switching logic meet the
requirements of Appendix R. It is important to note that the
isolation switches were intended to be operated with equipment
deenergized. It is not intended to operate the generator
control isolation switches with the generator running, and
similar action is true for Bus 9 control wiring.
3) About ninety five percent of plant equipment has power and
control cables that pass through the cable spreading area and
the "A" switchgear room. As a result of fire damage, we could
loose control of these components in respect of not being able
to shut them off. By selective deenergization of switchgear,
we could shut these components off.
SPECIAL FIRE DAMAGE CONDITIONS
1) Fire damage: For both the cable spreading area and the "A"
switchgear room:
a. Both sources of offsite power are subject to fire
damage.
b. Control cables for both emergency diesel generators are
subject to fire damage.
c. About ninety five percent of plant equipment has cabling
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in both fire areas that would be subject to fire damage.
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B14208/ Attachment /Page 8
August 7, 1992
2) Discussion of fire damage for specific electrical components:
a.- If both offsite buses and their immediate switchgear
were being subjected to uncontrolled . fire damage,
procedures require the buses _ be deenergized. This
action would prevent damage to the busways_ from
electrical faults and prevent. additional repair action.
This action would also lead to a loss of normal power. ,
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b. If the diesel generator control cables were experiencing
fire damage or it was -evident that there was a
possibility of fire damage, both diesels would be
shutdown. The "B" diesel would then have its control
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wiring isolated, and the diesel would be restarted. The !
rationale for operators to take this preemptive action
is generator. protection. Waiting for fire damage to
induce the shutting down of the diesel generator can be
very detrimental to the operation of the generator.
Electrical. faults could be experienced on the voltage
control circuitry and the speed control circuitry that
can lead to abnormal operation and possible damage to
the generator,
a) Cable Spreading Area Fire:
There is one fire scenario in the cable spreading area which could
result in an SB0. This scenario is very improbable, requiring a
specific set of circumstances. Should this occur, the SB0 would be
of short duration; about the time it takes to start the "B" diesel.
The scenario which' could lead to SB0 would require an extremely
large fire, encompassing most, if not all of the cable spreading
area. For this scenario, it is feasible that there could be a loss
of offsite power as a result of damage to both 4160 volt electrical
buses. Loss-of offsite power would initiate the start of the "B"
diesel. _ However, there are control cables _for the "B" diesel in the
cable spreading area. If the fire affected the control cables to
the "B" diesel, the control cables would have to be isolated from
the diesel. This cannot be done with the diesel running. Operators.
would shut down the "B" diesel, isolate the control cables and
restart the diesel under local control. For this scenario, the -
plant is-in SB0_ from the time of shutting down-the diesel until the
diesel is restarted.
In summary, if the cable sp' reading room were engulfed 'in a fire that
resulted in a loss of offsite power (due to damage to the 4160
electrical buses), the "B" diesel -would start. If the fire also
damaged the control cables to the "B" diesel to the point that it'
was running. abnormally, operators would take preemptive action by
shutting down the diesel long enough to isolate the diesel from the
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B14208/ Attachment /Page 9
August 7, 1992
affected control cables. The diesel would then be restarted under
local control.
b) Switchgear Room "A" Fire:
The scenario which could lead to SB0 would require an extremely
large fire, encompassing most, if not all of switchgear room "A".
The strategy for any fire of lesser magnitude in this room is to
sequentially deenergize electrical distribution equipment at the
next circuit breaker up from the equipment subject to fire damage.
The objecthe would be to . minimize the amount of- electrical
distribution that would be deenergized. These actions would all be
. based upon the condition of being able to enter th6 switchgehr room
and localize the fire.
Appendix R requires that an evaluttion be made for the entire area
peing ssjected to fire damage. A totally encompassing fire- is
highly unlikely in that there is fire detection and suppression in
this area and the- in-situ fire loading is low. Transient
combustibles are administrative 1y controlled at low levels in this
room. However, given a totally encompassing fire in switchgear room
"A", entrance to the room is limited. It-is our position that it is
best to ceenergize off site power. This decision is based on the
following:
1) The txiliary feedwater system is available to remove decay
hea; sven if the "A" switchgear room is deenergized.
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2) The Haddam Neck Plant has a station blackout coping time of 4
hours.
3) After isolating control wiring from this fire area, the "B"
diesel can be started, the "B" switchgear room powered and
enough essential equipment energized to complete the shutdt,wn
process that might not be able to be shut off due to fire
damage (opencircuits).
4) An important consideration for this fire scenario is to first -
stabilize the plant. Utilizing the *B" shutdown method
-results in all equipment conditions being known, as opposed to
relying on the "A" switchgear which is susceptible to spurious
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actuations. Additionally, deenergizing off site-power will
shutoff nonessential loads such as the reactor coolant pumps
and feedwater pumps that might not be able to be shut off due
to fire damage (open circuits).
Similar to the discussion-for the cable spreading area fire,
the diesel will start when both 4160 volt busses are
deenergized. Assuming the all encompassing fire, the control
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August 7, 1992
cables to the "B" diesel may be damaged. Operators will shut
down the diesel long enough to isolate the control cables. It
will then be restarted under local control. The plant is in
SB0 from the time of shutting down the diesel until the diesel
is restarted. The SB0 would be of short duration; about the
time it takes to start the "B" diesel.
c) Control Room Fire:
Procedure A0P 3.2-50 governs operation from outside the control
room.
In the extreme case of a fire of such magnitude that the operators
elect to evacuate the control room, step 4.5 requires an operator to
isolate electrical distribution in the "A" switchgear room. The
rationale for this is that numerous control circuits in the control
room could be subject to spurious actuation. These loads,
nonessential to the Appendix R plant shutdown, are shed. The "B"
diesel will be shut down if it had started. The operators then
disconnert remote diesel controls and align service water for the
diesel. The "B" diesel is then restarted. The pl ar,t is
"blackedout" for the time the diesel is shut down. It should be
noted that offsite power is nd disconnected from the "A" switchgear
room by Convex and remains available. If the "B" diesel generator
fails to start (a failure beyond Appendix R considerations),
operators could close the 4160 volt offsite power breakers located
in the "A" swtichgear room. Individual distribution buses would then
have to be deenergized to minimize spurious actuations and shut off
unnecessary equipment that could not be previously shut off to fire
damage.
Reauest 6:
If CYAPC0 uses fire water for the DWST, does it affect the ability to
supply fire water to suppression systems?
Response to Reauest 6:
The use of fire water for the DWST does not affect the ability to supply
i fire water to suppression systems. CYAPC0 has identified the feed
requirement from the fire water system to the DWST to be 160 gpm, 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />
after the fire. The capacity of one fire pump is 2500 gpm rated flow at
115 psi. Removing 160 gpm for DWST feed is insignificant and well within
the capacity of the pump. Additionally, fire water to the DWST is not
required for three hours, by which time the fire is expected to be out.
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B14208/ Attachment /Page 11
August 7, 1992
Reauest 7:
Consider adding warning statement in procedure A0P 3.2-50 about inducing
an S00, where applicable.
Response to Reauest 7:
Warning statements will be added to procedure AOP 3.2-50 about inducing an
500, where applicable.
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