ML20128Q523

Responds to Re Contradictory Statements Submitted in Three Util Ltrs.Circulator Speed Instruments Not Relied Upon in 10CFR50,App R,Re Fire Protection Evaluation Because of Close Proximity Between Loops

ML20128Q523
Person / Time
Site:	Fort Saint Vrain
Issue date:	05/15/1985
From:	Lee O PUBLIC SERVICE CO. OF COLORADO
To:	Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
P-85168, TAC-54373, NUDOCS 8506040226
Download: ML20128Q523 (8)

Text

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P.O. Box 840 Denver, CO 80201- 0840 OSCAR R. LEE VICE PRESIDENT May 15, 1985 Fort St. Vrain Unit No. 1 P-85168 Regional Administrator Region IV U.S. Nuclear Regulatory Commission MAY 2 Il95 611 Ryan Plaza Drive, Suite 1000 jp Arlington, Texas 76011 Attn: Mr. Eric H. Johnson Docket No. 50-267

SUBJECT:

Apparent Contradictory Statements

REFERENCE:

1) NRC letter, Johnson to Lee, dated 4/16/85 (G-85139)

2) PSC letter, Lee to Johnson, dated 4/1/85 (P-85113)

Dear Mr. Johnson:

In reference 1 the NRC outlines what appears to be contradictory statements submitteo in three PSC letters. The three statements of concern are addressed below.

Statement of Concern 1.

P-85065 dated February 28, 1985, related to Regulatory Guide 1.97 " Instrumentation," indicates that the circulator speed instruments are Category I safety-related; PSC Response 1.

This statement is accurate. Circulator speed instruments were not relied upon in _the 10CFR50, Appendix R Fire Protection Evaluation because of close proximity between loops.

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Statement of Concern' 2.:

P-85098 dated April 1, 1985, related to " Upgraded Technical ispecifications,"

indicates that core delta-pressure

indication is.not relied upon;.

PSC Response

~2.. This statement

'is accurate.

The core delta-pressure indicator-involved is PDT-1112.

Statement of Concern

3..

P-85113 datied April.- 1,1985, related to " Fire Protection,"

states:

"In lieu -of reliance _ on circulator speed instrumentation,-the shutdown model has been revised to rely on core differential pressure instrumentation to confim core flow."

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'PSC; Response i

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3..

The_ term " core. differential pressure instrumentation" is inaccurate. The correct tem should have been " circulator helium flow",.

The actual instruments involved are PDT-1157-2 and PDT-1158-2. -Attachment A to this letter summarizes -

the~ -refarences. to PDT-1157-2 and PDT-1158-2 in Reports-1 through 4.. To avoid confusion, two pages in Report No. 4

.are being revised per this. letter, as noted in Attachment A.

This letter forwards 20 copies of those two pages.

Please arrange 'to have them inserted into the 20 copies of Report No. 4 previously submitted via' reference 2.

The threeL letters referenced in Reference 1 were reviewed for other

._ inconsistencies and none were found. The inaccuracy contained in P-85113 created _an: apparent inconsistency between-the three letters.

PSC 'has concluded -that the term " core

. differential pressure instrumentation" was used.in error. Since more accurate terminology was used in numerousL other locations in the - Fire Protection Evaluation -Reports, 'the intent of.P-85113 was consistent with'other correspondence.

PSC has procedures which govern the preparation and review of correspondence to the NRC for accuracy;and responsiveness.

We will-continue; tc adhere to those' procedures'and give particular attention to the consistency of all correspondence to the NRC.

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-Mr.-M H.' Holmes at (y questions' on -. -this subject, please ' contact

'If3 you have-an 303) 571-8409.

'Very truly yours, 0.R. Lee,hJh./}%<

0*& n Vice President-Electric Production ORL:pa LAttachment-

' Enclosures 4

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3

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Attachment'A to P-85168 TABULATION OF REFERENCES TO IfLIUM FLOW INSTRUMENTATION N REPORTS I TMtOUGH 4 Report No. I Figure 2.1-6 o Helium Flow o C-2101 & 3 Flow (PDI-l157-2 & I158-2)

Table 2.3-1 Circulator i A & IC Helium Flow Table 3.1, pg.13 POI-I157 & 8-2 h No.2 Table 2.3-1, pp. 2 & 3 Circulator C-2101 & 3 Helium Flow Table 2.3-2, pg. 3 PDl-l157 & 8-2 Table 4.1-1, pg.' 3.-

o Circulator i A & IC, C-2101 & 3, Flow, Low Range o PDT-115) & 8-2 Report No. 3 Section 4.17, pg. 4-6 Circulotor Helium Flow a

Report No. 4 Section 2.21, pg. 2-7 o Circulator Helium Flow o Core differential pressure (need to revise to circulator helium flow)

.. Table 3.10-1, pg. 5 Circulator delta P (need to revise to circulator helium flow)

Section 4.10, pg. 4-6 Helium Flow Instrument Cables pg. 4-12 Helium Flow instrument Cables Table 4-1,4.10(g)

Helium Flow Instrument Cables

Potential deficiencies relative to location of bearing water surge tank level instrumentation cables in proximity to each other are being resolved through proposed modifications and exemption requests.

Section 4.10 describes the'

. proposed modification for re-routing cables associated with one train of bearing

' water surge tank level instrumentation. Exemption Request 3.10 oddresses the resulting separation and protection for this instrumentation function.

Fire detection coverage is *o be prow _u os described in Section 4.5.

2.20 FEEDWATER FLOW MONITORS (4.16)

E Potential deficiencies relative to location of feedwater flow monitors. and associated cables located in proximity to each other within the Turbine Building are being resolved through proposed modifications and on exemption request.

Modifications as described in Section 4.10 will be made to re-route cabling ossociated with one train of feedwater flow instrurnentation.

Exemption Request 3.1I addresses the resulting separation and protection for redundant '

feedwater flow monitoring cables and instrumentation.~ Exemption Request 3.3 oddresses smoke detection for the Turbine Building.

2.21 CIRCULA. TOR HEllUM FLOW AND INLET TEMPERATURE INSTRUMENTATION (4.17) in lieu of reliance on circulator speed instrumentation, the shutdown model has i

beery revised to rely on circulator helium flow instrumentation to. confirm core flow.. Potential deficiencies relative to location of redundant instrumentation and cables for circulator helium flow instrumentation are being resolved through

. proposed modifications and an exemption request. As described in Section 4.10, modifications will be mode to re-route certain cabling associated with one train of circulator helium flow instrumentation. Exemption Request 3.10'oddresses the resulting separation and protection of redundant trains of circulator helium flow instrumentation.

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'l DC-85-04 2-7 J

TABLE 3.10-1

SUMMARY

OF REACTOR BUILDING FIRE PROTECTION SHUTDOWN REDUPOANCIES (CONTINUED)

TRAIN A EQUIPMENT REDUNDANCY SEPARATION drained to the Reactor Building sump for a j

period of 15 to 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />, prior to the need for placing a turbine water removal pump into operation.

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3. Circulator Function:

Corresponding Train B circulator On Elev. 4740', the Train A pumps and

- Circulator helium flow function components; note any Train components are located at the southwest PDT I157-2 (21315,21320)

B circulator function component is corner of the Reactor Building. The B-train redundant to any Train A circulator components are located along the south wall Bearing water surge tank level, function component.

of the Reactor Building opproximately 50 LT-21135 (16898) feet from the Train A pumps. A concrete -

wall separates the pumps, so propagation of

- Bearing water pumps P-2101 (3280) fire from one set of pumps to the redundant and P-2106 (3250) set is not likely. However, power cables from the Train A pumps os well as cabling

- Level switch LSL-2137, (7194) associated with other circulator function components are rou!ad into the general vicinity, although approximately 45 feet vertically above, the Train B.

circulator function cables and components.

Redundant cables have grating floors between them with no horizontal separation.

(See Fig. 4.10 from Report No. 3).

Train A cables for circulator function will be re-routed along the west, north and east walls of the Reactor Building to maximize separation from the Train B circulator function cables. - -

e jm Potential deficiencies relative to location of bearing water surge tank level (j) instrumentation cables in proximity to each other are being resolved through proposed modifications and exemption requests.

Section 4.10 describes the

. proposed modification for re-routing cables associated with one train of bearing water surge tank level instrumentation. Exemption Request 3.10 addresses the resulting separation and protection for this instrumentation function.

Fire detection coverage is to be provided as described in Section 4.5.

2.20 FEEDWATER FLOW MONITORS (4.16)

Potential deficiencies relative to location of feedwater flow monitors and associated cables located in proximity to each other within the Turbine Building are being resolved through proposed modifications and on exemption request.

Modifications as described in Section 4.10 will be made to re-route cabling

-ossociated with one train of feedwater flow instrumentation.

Exemption.

Request 3.1I addresses the resulting separation and protection for redundant p\\

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t feedwater flow monitoring cables and instrumentation. Exemption Request 3.3 i

LJ addresses smoke. detection for the Turbine Building.

2.21 - CIRCULATOR HEllUM FLOW AND INLET TEMPERATURE INSTRUMENT 4 TION (4.17)

In lieu of reliance on circulator speed instrumentation, the shutdown model has beery revised to rely on circulator helium flow instrumentation to confirm core flow. Potentici deficiencies relative to location of redundant Instrumentation and cables for circulator helium flow instrumentation are being resolved through proposed modifications and on exemption request. As described in Section 4.10,.

modifications will be made to re-route certain cabling associated with one train of circulator helium flow instrumentation. Exemption Request 3.10 addresses the resulting separation and protection of redundant trains of circulator helium flow instrumentation.

U,b DC-85-04 2-7

+*

s TABLE 3.IO-l

SUMMARY

OF REACTOR BUILDING.

FIRE PROTECTION SHUTDOWN REDUbOANCIES (CONTINUED)

TRAIN A EQUIPMENT REDUNDANCY

-SEPARATION drained to the Reactor Building sump for o period of 15 to 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />, prior to the need for placing a turbine water removal pump into operation.

3. Circulator Function:

Corresponding Train B circulator On Elev. 4740', the Train A pumps and

- Circulator helium flow function components; note any Train components are located at the southwest B circulator function component is corner of the Reactor Building. The B-train PDT I 157-2 (21315,21320)

.redundant to any Train A circulator components are located along the south wall

- Bearing water surge tank level, function component.

of the Reactor Building opproximately 50 LT-21135 (16898) feet from the Train A pumps. A concrete wall separates the pumps, so propogation of

- Bearing water pumps P-2101 (3280) fire from one set of pumps to the redundant and P-2106 (3250) set is not likely. However, power cables from the Train A pumps os well as cabling

- Level switch LSL-2137, (7194) associated with other circulator function components are routed into the general vicinity, although opproximately 45 feet vertically above, the Train B circulator function cobles and components.

Redundant cables have grating floors between them with no horizontal separation.

(See Fig. 4.10 from Report No. 3).

Train A cables for circulator function will be re-routed along the west, north and east walls of the Reactor Building to maximize separation from the Train B circulator function cables. t

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