ML20147D099
| ML20147D099 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 02/07/1997 |
| From: | Gambhir S OMAHA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LIC-97-015, LIC-97-15, NUDOCS 9702100492 | |
| Download: ML20147D099 (125) | |
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OmahaPublicPowerDistrict 444 South 16th Street Mall Omaha NE68102-2247 February 7,1997 LIC-97-015 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station P1-137 Washington, DC 20555
Reference:
- 1. Docket No. 50-285
- 2. Letter to OPPD (S. K. Gambhir) from NRC (J. E. Dyer) dated January 17, 1997.
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Subject:
Response to Questions Related to 10 CFR Part 50, Appendix R as proposed in NRC In:,pection Report 50-285/%-16.
This letter forwards Omaha Public Power District's (OPPD's) responses to the questions proposed in Reference 2 concerning the Reactor Coolant Pump (RCP)1"he oil collection system. Included as attachments are copies of relevant documents. This letter scoimarizes the licensing and design bases of the RCP lube oil collection system, evaluates equivalency of the new ABB RCP motor and discusses the internal oil leak on RCP-3D motor.
Based on OPPD's review, the current lube oil collection system will ensure safe shutdown in accordance with 10CFR50, Appendix R, consistent with the SER clarifications and approved exemptions noted in the attachments. However, we recognize that the leakage in RCP-3D is not
- in strict compliance with Appendix R, and should be repaired or reduced as much as practical.
Short term actions have been implemented to clean up and minimize the leakage. RCP-3D is %)g presently operating with a reduced, oil level which has resulted in effectively stopping the oil t leakage. Procedural guidance is currently in place to address operation of RCP-3D with a reduced oil level. Long term corrective actions are to eliminate the leakage problem in RCP-3D and plan for a modification that will collect oil from the major leak points. %O(
9702100492 970207 PDR ADOCK 05000285
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45.5124 Employment with Equalopportunity
/} U. S. Nuclar Regulatory Commission LIC-97-015 l'C/ Page 2 l
If you should have any questions, please feel free to contact me or my staff. ,
i Sinceply, ;
s S. . Gambhir
- Division Manager Production Engmeermg ,
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I' Attachments:1) OPPD Fire Protection Program Submittal, LIC-76-0180, dated 12/31/76
- 2) Program SER, LIC-78-0104, dated 8/23/78, appropriate pages
- 4) Safety Evaluation by the Office of Nuclear Reactor Regulation Supporting Amendment No. 53 to Facility Operating License No. DPR-40 OPPD FCS, Unit No.1 Docket no. 50-285
.O 5) NRC Triennial Inspection Report, LIC-88-880, dated 9/23/88
- 6) OPPD Exemption Request, LIC-88-1066, dated 11/28/88
- 7) NRC Exemption to Appendix R, III.0, LIC88-457, dated 12/20/88
- 8) 10 CFR 50, Appendix R, Section III.O White Paper Review, dated August 9, 1996
- 9) Task Assignment Form, CID No. 960584/01, dated 12/13/96
- 10) Operability Evaluation Form, NOD-QP-31, for CR No. 1996001624, dated 1/14/97
- 11) Trend Chart for Reactor Coolant Pemp Levels
- 12) OI-RC-9, Operating Instruction Reacwr Coolant Pump Operation, Revision 30, issued 01-28-97
- 13) RCP Motor P&ID c: Winston and Strawn I L. J. Callan, NRC Regional Administrator, Region IV L R. Wharton, NRC Project Manager W. C. Walker, NRC Senior Resident Inspector T. P Gwynn, NRC Director, Division of Reactor Safety lv) i
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U. S. Nuclear Regulatory Commission LIC-97-015 Page 3 l
,. NRC_Questionl.
" Provide a comprehensive discussion of how Omaha Public Power District meets the fire protection requirements of Appendix R as it relates to labe oil collection systems on the reactor coolant pumps. This discussion should describe the previous and current plant configuration and detail the scope and basis of any regulatory exemptions that have been
- granted."
OPPD Response l
DetailedReviewafEesigitandlicensing3asislotLube_OiLCollection_ System.
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The following discussion details the docketed correspondence history which provides the previous i
, and current plant configuration, details the scope and design basis of the RCP motor lube oil collection system, and states OPPD's position on the compliance issue of 10 CFR Part 50, Appendix R. !
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'G , RCP motor lube oil collection requirements date back to the NRC's Fire Protection (FP) l
(Attachment 1, dated 12/31/76) acknowledged RCP lube oil as a " major combustible." The j submittal evaluated a 15 minute fire burn in containment resulting from combustion of the total i lube oil inventory from one RCP motor (150 gallons was used for the appraisal), The evaluation l concluded that a burn of this magnitude spread throughout a steam generator bay would not l 3 prevent safe shutdown of the plant. This evaluation was referenced by OPPD as meeting the j Appendix A, " Control of Combustibles," mandate [per section D.2(a)] without a RCP motor lube I o? collection system. l The Safety Evaluation Report (SER) (Attachment 2, dated 8/23/78) granted to OPPD in response to the above submittal lists the RCP Lube Oil Collection System as an incomplete item. The SER states that OPPD committed to respond to the incomplete item by June 1979.
OPPD submitted a Final Design Package of MR-73-057, "RC Pump Lube Oil Collection,"
(Attachment 3, dated 6/6/79) to the NRC for review snd approval prior to construction. The i purpose of the lube oil collection system proposed per this modification was "to collect and l contain RCP lubricating oil leaks in order to reduce the probability of a lube oil fire in the !
containment building." The modification package submittal documented the design basis of the lube oil collection system, including the information that the lower oil res:rvoir was not provided with an oil collection system. A key passage (Attachment 3, page 4) in this submittal is as p follows:
U The lower oil reservoir is not being collected since it contains onlyfour (4) gallons, has an internal oil cooler and there are no pressurized lines, sight glasses, etc. Also, the oil level
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i transmitter is not contained since the transmitter housing has a pressure rating of 500psig and it is only exposed to 17 inches ofoil.
NRC documented acceptance of the proposed configuration in Amendment 53 (Attachment 4, -
dated 11/17/80) to the Fort Calhoun Station (FCS) Operating License. The SER for Amendment 53 states:
The staff has reviewed this information andfind that our concern has been satisfactorily addressed. We consider this issue to be closed.
OPPD would like to clarify that the 17 inch level, stated in Attachment 3, as quoted above, was in error. The actual level, or static head, is 5 inches. (The change is not significant since it was in the conservative direction.)
The RCP lube oil collection system was subsequently reviewed by the NRC in 1988 during a triennial FP inspection. The results of this inspection (Attachment 5, dated 9/23/88) listed the oil collection system as an unresolved item. The following was taken from Section 4.c of attachment 5 in its entirety.
The NRC inspectors reviewed the design of the reactor coolant pump oil collection system.
The design appeared adequate with the exception of the capacity of the oil collection tanks.
Section 111.0 ofAppendix R requires that oil leakage be collected and drained to a vented closed container that can hold the entire lube oil system inventory. The licensee's design is for two collection tanks with a capacity of150 gallons each. Each of thefour reactor coolant pumps has an oil capacity of115 gallons. Thus, there is a total tank capacity of 300 gallons to collect a total oil supply of approximately 460 gallons. However, according to the FCSfire hazard analysis the largest oilleak has been determined to be less than 80 gallons total.
Since the oil collection system, including collection pans, drain lines, and collection tanks has enough capacity to hold all of the oilfrom the pumps, there appears not to be a safety concern. However, the present system does not comply with Section 111.0 ofAppendix R and an exemption is required. This will be considered an unresolved item pending the licensee's submittal and NRR's review and acceptance of the exemption requestfor the reactor coolant pump oil collection system. (285/8828-03) 1 No violations or deviations were identified.
OPPD would like to make a clarification to the last sentence in the first paragraph quoted. The p Fire llazards Analysis does not state the largest leak to be 80 gallons total. The exemption
() submittal, LIC-88-1066, assumed a " Maximum Expected Leak" of 110 gallons; where as, the 1976 program submittal is based on 150 gallons.
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U. S. Nuclear Regulatory Commission LIC-97-015 Page 5 l l
OPPD filed an exemption request to 10CFR50 Appendix R III.O (Attachment 6, dated l 11/28/88) with the NRC. The exemption was requested for Fire Area 30 from the requirements I that the lube oil collection system drain tank capacity be capable of holding the entire lube oil system inventory of the RCPs. The capacity of the drain tank is based on a maximum single )
4 failure (Upper Oil Reservoir) leak rather than the full lube oil inventory of two RCP motors (two i RCPs drain to each tank). The exemption request also responded to three questions raised l
. during a phone conversation held between D. Kubicki of NRR and OPPD staff on 11/25/88. !
The three questions and answers are as follows:
Question]
NRR was told by a RegionalInspector that the entire system tanks, piping etc. when taken
- . as an entity nould contain the totalinventory of allfourpumps. Is this a true statement? l
- Please provide an explanation. l l
Answer l Tne total volume ofone collection pan and its associated piping is approximately 120 gallons (110 gallon pan capacity + capacity of approximately 50 feet ofnonshared 2 inch
! drain piping of10 gallons). This gives a total two pump system capacity of approximately i 390 gallons (120 gallons + 120 gallons + 150 gallon tank). However, there is no G mechanism installed that wouldprevent the entire volume of oil collectedfrom draining into the collection tank and out of the overpow. Therefore,130 gallons of oil couldpotentially pow out of the overpowfor the worst case oilloss scenario.
Question 2 The system was seismically designed:
- a. Does this mean that the piping will notfail? or
- b. Is the piping designed to 2 over 1 criteria so that it canfail but notfall? Ifso, can we state that where ever the linefails, that the oilleakage will not contact a potential ignition source.
l Answer The system was designed withflexible couplings toprevent the pipingfrom leaking due to motion. The piping design criteria was to survive a SSE with its leak integrity intact. In the event the piping were to leak, the potential ignition sources in the area consist of reactor l coolant system components with surface temperatures above 500 'F. The scenario of a \
reactor cavity tube oilpre has been shown to have no adverse effects on safe shutdown.
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U. S. Nuclear Regulatory Commission LIC-97-015 Page 6 Question 3 OPPD states that the system will contain oilfrom pressurizedpoints. What about unpressurizedpoints?
Answer The oilpiping that is unpressurized is either internal to the motor bearing assembly or of such a high wasure rating that oilleakage is not considered a credible event. The total volume ofI u unpressurized oil system in the lower bearing assembly is onlyfour gallons perpump. ne entire upper bearing assembly is provided with collection capacity with the exception of the level transmitters which are rated at 500psig.
The NRC subsequently approved this exemption (Attachment 7, dated 12/20/88); section 3.0 of the SER states:
The staff was also concerned that all unpressurized leakage points were not encompassed by the oil collection system. The licensee indicated that oilpiping that is impressurized is either internal to the reactor coolant pump (RCP) motor bearing assembly or quahjied to withstand the elevatedpressures anticipated during a seismic event.
' As noted in an OPPD White Paper (.kichment 8, dated 8/9/96) this wording appears to be in error as a result of combining statements from question 2 and 3 above, and needs to be corrected.
However, it is clear that the NRC did approve OPPD's design that does not collect oil from piping that is unpressurized, including the lower bearing assembly.
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U. S. Nuclear Regulatory Commission x LIC-97-015 Page 7 Inreriew,_the_ design.andlicensing. basis _for_theJubewitcollectionsystentis sur unarized_below:
RCP motor lube oil license basis (various correspondence since 1978)
- 1. The RCP Oil Collection System installed per MR-78-057 was reviewed and approved by the NRC.
- 2. The NRC Appendix R audit report categorbni the FCS RCP oil collection system capacity deviations as "not safety signiF < ' but suggested that an exemption from the Appendix 'R' requirement was required. This was the only open item.
- 3. Containment has been analyzed for a 150 gallon lube oil fire in the RCP/Stea.n Generator Cavity and found not to impact safe shutdown capability of the station.
RCP motor lube oil design basis (per submitted modification package MR-FC-78-057)
- 1. Pressurized components and the (upper) reservoir are totally enclosed in " leak resistant" pans.
- 2. The lower bearing reservoir does not require collection due to no credible leak points external to the motor.
- 3. I10 gallons is the worst case single RCP motor lube oil failure (which is well within the 150 gallon fire hazards analysis assumption).
The NRC approved OPPD's exemption request to 10CFR50, Appendix R III.O
- 1. An exemption on the capacity of the drain tank, based on a maximum single failure (Upper Oil Reservoir) leak rather than the full lube oil inventory of RCP motors, was approved.
- 2. The oil collection system design that does not collect oil from piping that is unpressurized, including the lower bearing assembly was approved.
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- Recentliotor_ Replacement
- j During the 1996 Refueling Outage, OPPD replaced the RC-3B GE motor with an ABB motor of the same size. The motor was manufactured by ABB Ir.dustrial in Switzerland. The new motor lube oil collection system is designed to be equivalent to the existing GE motor lube oil collection system. j Prior to the 1996 refueling outage OPPD performed a fire protection interaction review for MR-95-022, RCP Motor Replacement for RC-3B. This review concluded that certain information relative to the 1988 exempaan should be updated. This was discussed with the NRC/NRR Project Manager in late August 1996. He agreed that, following the 1996 Refueling Outage, OPPD should update appropriate descriptions of the RCP lube oil system previously provided to the l NRC in support of the 1988 exemption, and propose corrections / updates to the exemption SER. l The requested submittal was to include the 50.59 evaluation addressing fire protection aspects of j the motor replacement, and a summary of the assessment showing that the lube oil capacity of the !
new RCP-3B pump motor will not place OPPD outside the bounds of the previous fire hazard ;
analysis. This information is included in the answer to question 2 below and contained in more i detailin Attachment 9.
Oilleakage.fromRCP-3D31otoc l i
An internal oil leak has developed on RCP-3D motor. It occurs following an oil fill of the upper oil reservoir. Oil is apparently being carried over the top of the internal stand pine in the upper reservoir by rotation of the motor thrust runner and then flows down along the motor shaft. As !
the oil level drops (less than 1/2") the leakage stops. Since this leakage path was not expected or anticipated in the original oil collection design, the current design is not in strict compliance with Appendix R. It is OPPD's view that this leak path should be repaired, or reduced as much as practical. A more complete description of the leakage path and the actions (short and long term) are provided by the response to question 3.
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U. S. Nuclear Regulatory Commission LIC-97-015 ;
Page 9 :
NRC_QuestioiL2. ;
"The white paper indicates that Omaha Public Power District has recently modified Reactor Coolant Pump B, which has resulted in a physical configuration of the lube oil system that is different from the other pumps. Provide a description of the new configuration of the lube oil system for Reactor Coolant Pump B and how Omaha Public Power District has addressed the differences as they relate to the applicability of the exemption request in LIC-88-1066."
OPPD Response A detailed description of the new RCP-3B motor, built by ABB Industrial, and a comparison with the other three RCPs is included in Section 2 of Attachment 9. The differences, as they pertain to the exemption request in LIC-88-1066, were addressed in Section 3, Fire Protection Evaluation, of Attachment 9.
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Comparing the fire hazard of the new pump motor to the old reveals that (1) the new RCP motor ;
configuration is within the postulated design basis fire burn time submitted to and approved by the l O
NRC, and (2) the baseline RCP Fire Hazard Analysis per the original FP program submittal (Ref.
V Fire Protection Program Submittal LIC-76-0180) is still valid since the postulated fire duration of l the new motor configuration is less than originally evaluated. The data used in original analysis is ;
based on 150 gallon RCP lube oil inventory. The new pump contains a nominal 82.4 gallons l which includes 11.6 gallons for the lower oil reservoir. Therefore the fire loading is less than !
before.
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p U. S. Nuclear Regulatory Commission 1 V LIC-97-015 Page 10 i
i The lube oil collection system is similar in design to the old system as indicated in the following
- tables
l UPPER OIL RESERVOIR NEW ABB MOTOR OLD GE MOTOR COMPARISON j' The oil lift pump, piping, oil The oil lift pump, piping, oil The new motor upper lube oil j level indicator, fill / drain, and level indicator, fill / drain, and system is simpler in design oil level transmitter piping oillevel transmitter piping and has less piping and joints external to the motor are external to the motor are that could potentially leak
- enclosed in two collection enclosed in three collection outside the motor housing.
i enclosures. The oil collection enclosures and are drained to The new motor upper lube oil enclosures are connected to retention tanks. The top collection system is designed 3
the existing oil drain system. enclosures are not leak tight, to maintain structural integrity The side and upper panels are but, they are designed and during a design basis not oil tight, but, they are constructed so that oil spray earthquake. Each enclosure designed and constructed to will be contained. The has a 1.75" diameter drain i contain leaks from pressurized enclosure panels are made of tied to a 2" existing lube oil oil lines and drain to the oil 0.06" thick stainless steel drain system. The existing collection system. The oil panels and are designed to lube oil system is a closed
) level indicator, fill and drain, maintain structural integrity system consisting of piping, and oil level transmitter piping during a design basis flexible hose and a vented
, are only subject to the earthquake. collection tank. A taller pressure head of the oillevel standpipe in the upper lube oil in the reservoir. The oil reservoir adjacent to the thrust enclosure panels are made of runner reduces the potential 0.079" thick stainless steel for the type ofleakage i panels and are designed to assumed to be occurring in
! maintain structural integrity RCP-3D.
j during a design basis 4 earthquake.
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p U. S. Nuclear Regulatory Commission j d LIC-97-015 Page 11
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LOWER OIL RESERVOIR NEW ABB MOTOR OLD GE MOTOR COMPARISON '
i The lower bearing lube oil The lower bearing oil The new and existing motor reservoir has a fill / drain. oil reservoir has the same basic oil cooler, oil piping and level indicator, vent, and oil components such as the instruments are basically the level transmitter external to fill / drain, level indicator, and same. The new motor oil i the motor housing. The oil level transmitter. level indicator has three 1" )
fill / drain and level indicator The lower reservoir is insi% diameter " Bull's Eyes" for oil j are inter-connected and can the motor housing and level reading (See pictures in l be considered a single unit. requires 4 gallons of oil. The Attachment 9). The " Bull's !
The lube oil reservoir has a oil level indicator does not Eyes" have no load bearing 11.6 gallon capacity. Oil have " Bull's Eyes" as with surfaces. The new motor oil f piping and instruments the new motor. The oil level level indicator unit is !
external to the motor are not is checked by opening the conservatively designed in I provided with a level indicator top cover, terms of construction and collection / drain system based The Foxboro oil level mounting.
on the following; transmitter has a pressure Based on the design and
/i 1.) Oil piping is un- rating of 500 psig. construction of the lower lube O pressurized (no pumps). oil reservoir, it is concluded 2.)The oil fill and drain is that the probability of an oil made from carbon steel bar leak is remote for both the stock and has three 1" new and existing motor, diameter " Bull's Eyes" for i oil level indication. Each
! " Bull's Eye" is rated at 256* F @23 psi.
The fill / drain and level indicator unit is attached to .
the motor housing by four 12 ,
mm or 0.47" diameter bolts.
3.)The Rosemount oil level transmitter has a pressure j limit of 2000 psig. i 4.)The oil level indicator and ;
transmitter are designed to maintain structural integrity during a design basis !
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i LIC-97-015 l
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- Summary _of Answer 104uestionl
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i- 1. The existing licensing basis for a safe shutdown fire in containment is not challenged by the .
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new RCP motor modification. FCS maintains the ability to be safely shutdown in the event !
[ of a design basis fi f
'2. The new pump motor lube oil system as evaluated in Attachment 9 does not present an !
- i. . additional fire hazard.
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- 3. The 10 CFR 50.59 safety evaluation determined that this modification did not involve an
- unreviewed safety question and the existing licensing basis for Safe Shutdown Fire in l Containment is not challenged.
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- 4. The standpipe in the ABB motor, being taller than those in the GE inotors, will have less 1 potential for the type of leakage assumed to be occuring in RCP-3D. i o
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( U. S. Nuclear Regulatory Commission LIC-97-015 Page 13 NRC_ Question 1 .
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" Describe the compensatory measures that Omaha Public Power District has taken (or plans I to take) to prevent any further lube oil leakage from the upper bearing of Reactor Coolant Pump D. In addition, provide a detailed description of the present fire hazard that exists in j this pump due to the previous uncollected lube oil leakage." j h
DEPAResponse '
An internal oil leak on RCP-3D motor was first identified in June of 1995. The oil leakage from RCP-3D is caused by an internal migration of non-pressurized oil from the upper oil reservoir.
Oil is apparently being carried over the top of the internal stand pipe in the upper reservoir by the rotation of the motor thrust runner. The standpipe is designed to keep upper reservoir oil from running down the motor shaft (see drawing, Attachment 13). The normal running oil level in FCS's motors is very close to the top of the standpipe because of the as-designed bearing configuration. Apparently, in the RCP-3D motor, the rotation of the thrust runner causes a small p quantity of oil, over several weeks, to be pushed over the top of the standpipe and down the
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motor shaft. As the oil level drops (less than 1/2") the leakage slows and then stops. Once over i the standpipe, the oil drips to an area above the rotor shaft air seal. This oil then drips out of ,
several air outlet ports and drains located on the outside of this part of the motor. This leak path }
is outside of the oil collection system.
Since the end of the refueling outage in November 1996, the motor has lost an estimated 2 to 3 !
gallons of oil. The majority of this leakage occurred within the first few weeks of operation of the !
pump motor. When the level dropped to the lower end of its operating range, the leak rate slowed or stopped. CurrentlyJLC-3D is_operatingavith3ery minimal leakage _(see_ trend. charts provided_inAttachmentll). The leakage results in some oil on internal motor components and on l the walkways and floors directly beneath the motor. During the plant startup the oil was observed to be dripping out of the air outlet ports and drains from the internal portions of the motor above the rotor shaft air seal. l An operability evaluation (Attachment 10) was performed for the oil leakage from the motor of ,
RCP-3D into the pump bay. The impact of oil leakage on the internals of the motor, hot insulated RCS components, and uninsulated or exposed blanket insulated RCS components was evaluated.
This evaluation determined that the amount of currently uncollected oil plus any minor unanticipated leakage of oil that is uncollected during the cycle, are not a significant fire hazard and are well within the assumptions of the previous fire hazards analysis. OPPD recognizes that
. oil leakage outside of the motor oil collection system, although within design basis, is undesirable (for details please see Attachment 10).
The existence of an internal to external unpressurized oil leakage path in RCP-3D is not a
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- V LIC-97-015 l Page 14 condition that was explicitly anticipated in the original design of the lube oil collection system.
Thus, while the current lube oil collection system will ensure safe shutdown in accordance with 10CFR50, Appendix R, consistent with the SER clarifications and approved exemptions noted in the attachments, the leakage in RCP-3D is not in strict compliance with Appendix R, and will be repaired or reduced as much as practical. As discussed in Attachment 10, RCP-3D and piping under and around the RCP-3D motor has a metal jacket over the insulation, so that oil soaking of this insulation from unpressurized leaks is minimized. The operability evaluation provided in Attachment 10 provides the mitigating measures OPPD has instituted to reduce the leakage.
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Short term compensatory actions include:
] 1. operation at reduced oil level in the upper reservoir, Special instructions and specific actions (OI-RC-9, Attachment 12, dated 1/28/97)
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4 have been proceduralized for RCP-3D to monitor motor bearing temperatures, j vibration, refilling the reservoir, and notification of the system engineer if an alarm
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or abnormal condition is indicated for the motor. OI-RC-9 was revised to include
] instructions from an Operations Memorandum which was issued earlier.
j 2. minimizing the amount of oil added during the operating cycle, The system engineer makes recommendations to maintenance personnel on how -
much oil should be added, based upon the upper oil reservoir leakage trend data, in order to provide adequate lubrication of the motor and minimize oil leakage.
- 3. clean-up and removal of oil as plant conditions permit, and
- 4. monitoring total oil usage to ensure only a minor fraction of the analyzed 150 gallon limit is allowed.
Long term actions:
- 1. RCP-3D motor will be replaced with the motor removed from RC-3B which is now being refurbished (unless emergent problems with another RCP motor require priority use of our one spare). If the motor is not replaced, the modification described in action 2 below will be completed on RCP-3D during the 1998 refueling outage. Repair of the leakage will be attempted when the RCP-3D motor is sent out for general refurbishment, currently scheduled for the 1998 refueling outage.
- 2. OPPD will evaluate the physical orientation, and configuration necessary for installation of a modification which would collect oil from the internal leakage path.
The modification would be designed, to the extent practical, to route leaking oil to
U. S. Nuclear Regulatory Commission ;
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Page 15 -l the collection system to minimize the potential for oil accumulation around the pump !
bay. Installation of the oil collection modification for the GE motors, if feasible.
l will be during the 1999 refueling outage. l
-3. Further, a study evaluathg the leakage from RCP-3A, C, and D GE motors will be
'l initiated in 1997. This study will evaluate alternatives to the modification of the oil collection system described in action 2 above, i.e. eleminating the source of leakage.
In. Summary: f
. While the current lube oil collection system will ensure safe shutdown in accordance with l 10CFR50, Appendix R, consistent with the SER clarifications and approved exemptions noted in the attachments, the leakage in RCP-3D is not in strict compliance with Appendix R, and j will be repaired or reduced as much as practical.
Short term actions have been implemented to minimize leakage. As of February 6,1997, l the motor appears to be running with very minimal leakage, j Long term correction is planned to eliminate the leakage problem and enhance the collection .
system by adding piping for collecting oil from major leak points. j l
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g! O R.% ca/g. FP ~ Sus ,, ,
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8 DOCKET NO. 50-285 FIRE PROTECTION PROGRAM REVIEW FORT CALHOUN
, UNIT I OMAHA PUBLIC POWER DISTRICT O
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December 31, 1976 i
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O L 5.2.2 Control of Combustibles Buildings and structures containing components and systems important to safety are of reinforced concrete construction.
This type construction has the advantages of noncombustibility of construction materials, and also of a high degree of resistance to the effects of fires which might occur from other sources.
As shown in Table 5.2.l'and Figures 5.2.1 through 5.2.8,,the safety-related areas 'of the plant are divided into a large number of compartmen or rooms, and most equipment is housed in one of these. The walls and floors between compartments or rooms are also solid reinforced concrete construction. Their thicknesses are determined by a number of factors including radiation shielding. All but one are adequate to qualify them as fire barriers of three-hour or greater rating. Doors and electrical cable penetrations have also been evaluated. Door ratings have been compared to the contained fire load. Where ratings are inadequate, three-hour rated doors will be installed so that all doors, as a minimum, will have a rating in excess of the contained fire load. At locations where electrical cables in trays penetrcte a wall,. floor, or ceiling, the opening will be sealed to maintain barrier integrity
,. against fire spread, as described in Section 6.0.
Major combustibles in the plant are associated with the turbine generator (hydrogen and oil), the feedwater pumps (oil), electri-cal transformers (oil), the emergency diesel generators (fuel),
the diesel fire pump (fuel) , the plant auxiliary boiler (fuel) ,
the charcoal filters (charcoal), the reactor coolant pumps (oil),
and the charging pumps (oil). ,
Small amounts of oil are associated with otner pumps and components. Of the above listed 5-8
The plant auxiliary boiler is located in the basement of the service building, east of the turbine building. It is separated
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from the auxiliary building and containment by the intervening turbine. building. Its fuel is stored underground.
The four reactor coolant pumps are located in two compartments in the containment along with other reactor coolant loop components.
They are isolated from other components by the compartment walls.
Thus,, the overall plant layout provides for isolation of the major combustibles described above from safety-related components 3
and systems. The layout additionally provides for separation of l equipment in the auxiliary building. Separate fire areas are provided for the various systems and components as shown in Figures 5.2.1 through 5.2.8.
t 5.2.3 Electrical Cable, Cable Trays and Penetrations q
Particular attention was.given during the plant design and con- ..
struction phase to minimizing the combustibility of electrical cables. Cable insulation systems were specified, tested and i evaluated to ensure a high degree of fire resistance as well as l meet other safety requirements. Table 5.2.2 describes the cable insulation systems used in Fort Calhoun Unit 1. Cables have .
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- been certified by the manufacturer to be capable of passing the fire-resistance test requirements of IEEE-383. Cables were subjected to a qualification test program which included the 5-10
..I different sections of the yard loop so that isolation of any one -
section will not disable both the primary and backup fire pro- {'
.() tection systems.
As shown on the flow diagram, Figure 5.3.10, a connection has f been provided to flush and fill the. fire water system with treated water. Maintenance procedures require that, after f draining, the system be filled with treated water.
To provide additional fire-fighting capability in the auxiliary building, manual hose stations will be provided throughout.
Number, location and equipment to be provided will be in accord- !
l ance with BTP 9.5-1, based on the fire hazards analysis. Poten- l tial locations are shown on Figures 5.3.11 through 5.3.14. Stand-pipes serving these hose stations will be connected to an auxiliary building fire water header fed from each end by connections to the yard loop.
Halon extinguishing systems to protect the electrical switchgear O room and the cable spreading room will be installed to provi6c an j ( j additional measure of protection for these areas. The systems will be designed and installed in accord with the requirements of NFPA and BTP 9'.5-1.
Numerous portable extinguishers are located throughout the plant.
i Their type and location are shown on Figures 5.3.10 through 5.3.18.
Fire protection for the containment interior has been evaluated, taking into account the factors of type and location of combus-tible materials, potential effects of fires in containment, acces-
~
sibility of various areas of containment during oper.ation and e
during outages, and potential effects of misoperation of exting-4 uishing systems if installed.
Major combustibles include reactor coolant pump motor lube oil, charcoal filters and cable insulation. Shielding and thermal 5-32
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v 0
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insulation materials are noncombustible. Additional combustibles (plastics, paper, etc.) are brought in only for refueling and maintenance.
t 3
The two reactor coolant pumps, the steam generator and the piping associated with each reactor coolant loop are contained within a reinforced concrete compartment. Fire detectors are provided at each pump to detect a lube oil fire. The fire hazards analysis for this area, given in Section 5.5, shows that combustion of 1 the total amount of lubrication oil from a reactor coolant pump would result in a fire severity of less than 15 minutes. Detection of a lube oil fire would allow the pump and its oil system to be ;
shut down, possibly stopping the discharge of oil and lessening !
the severity of the fire.
! The pressure boundary of the reactor coolant system is heavily ,
insulated. A fire of 15 minute severity would have no effect. ,
l The support structures and members for the reactor coolant loop components consist of massive members which, although unprotected l from fire exposure, would also have a fire resistance rating to ;
withstand a fire of this severity. Electrical cables, instruments i and other light components in the area might be damaged by such a fire, but would not jeopardize safe shutdown.
l The need for a fire extinguishing system in this area has been evaluated, and such a system is not considered necessary. In addition to the considerations discussed above, problems asso-ciated with a sprinkler or deluge system were also considered.
Failure tr inadvertant opeTati~on of a water system would repre-sent a potential source of chlorides and other impurities which could initiate or promote corrosive attack of the reactor coolant sys-tem pressure boundary. Additionally, unborated water available in containment would represent a potential boron diluent in the 5-33 si
i 1
4 event' of a loss of coolant accident.
! Cab.l e fir.es in containment have also been considered, and are i
d.iscus. sed .in the fire hazards analysis section 5.5. Cable.insu-
~
-lat;io.n .ha.s been tes'ted and shown to be fire resistant, even in the .cpnfiguration in which it is installed in trays.
a
-If.a
- cable . fire .is p.o.stulated to occur -in containment, the numerous .
j detectpr.s. J.ns.talled would give early warning to allow manual l fire-f.$cjhti.ng scapu.res to be taken. Because cable fires are 1
slow burning (one to two inches per minute), time exists for l an orderly shutdown and bringing in fire hose from outside,
,1f necesspry. Becau.se of the redundancy and separation pro-t vided for the limited amount of safe shutdown equipment in 2
containment, safe shutdown would be possible in the event- of a postulated cable' fire.
i l
a Charcoal filters in containment are equipped with spray- systems jp which receive borated water from the containment spray system.
!O In the event of a loss-of-coolant accident, the spray system will be initiated, if required, to prevent ignition of the {
charcoal by adsorbed fission products. l w6a 6
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j FT. CALHOUN STATION UNIT I ,, ;
i > i j FIRE SAFETY EVALUATION i l
Fire Area 30 Containment
- Lu A (h
, L, c Controlled Access i1 g Safety Related f Area Description l The containment structure is located in the center of the ,
i auxiliary building. It is bordered on the east by the electri- !
I cal penetration area, on the west by the HVAC equipment and
! fuel handling area and on the north by the mechanical and pipe i penetration areas and the HVAC equipment and fuel handling j
} area. All walls separating this area from the other mentioned i i areas are 3-hr fire rated barriers. I l
l The containment consists of three floors, basement (989'), ground (1013'), and operating (1045'). These are connected by two !
, unenclosed stairwells. The reactor, two steam generators, pres- l 1 surizer and four primary coolant pumps are enclosed in concrete ;
i cells running vertically through all three floors. There are j i four safety related divisions of cables in the containment. These !
l are routed so that they meet the separation criteria as a minimum. !
- Much of the cabling is enclosed in conduit. l Safety Related Systems and Components
' A) Safety Injection System Safety Injection Tank SI 6A Safety Injection Tank FI-6B Safety Injection Tank SI-6C :
Safety Injection Tank SI-6D !
Safety Injection Control Panel AI-136-A,B,C,D, Low Pressure Safety Injection control Panel AI-140, A,B,C,D B) Chemical and Volume Control System
- Regenerative Heat Exchanger CH-6 .
C) Containment HVAC system
-- Containment Air Cooling and Filtering Unit VA-15A Containment Air Cooling and Filtering Unit VA-15B Detector well Air Cooling Unit VA-13A Detector well Air Cooling Unit VA-13B D) Component Cooling System Component Cooling Water Cooling Control Panel AI-138, A,B,C,D Component Cooling Lube Oil Cooling control Panel AI-139 A,B,C,D
Fire Area 30 (Continued)
Postulated Fire As a result of the large volume in the containment which is I divided into three floors with several cell-like compartmeints, it is moreconsequences potential informative to of postulate each. three fires and examine the j 4
Postulated Fire A: (Location Basement level) The lubrication oil for one of the primary coolant pumps is assumed to ignite M. as a result of a leak in the lubrication system. The location l is on the basement elevation within the concrete cell that encloses two primary coolant pumps and a steam generator.
E burning minute fire.of 150 gal of oil in this space is equivalent to a The 15 Postulated Fire B: (Location Ground level) A cable tray fire is assumed ground level.to occur in a cable tray at section 20c on the l
of cable trays This location at this location.is selected because of the number '
Postulated Fire C:
lated in the central(Location Operating level) A fir'e is postu-rack of filters in containment ventilation equipment VA-6A and VA-6B.(one half the total) lo 4
equivalent to a 7 minute fire. This is Consequences 9-vire Without Active Protection Postulated Fi.
j units monitoring each There reactorarecoolant flamepump.
sensitive fire detector W combustion would also be detected by the the containment. Early warning could allow the operator Any significant ionization detectors in time to accomplish an orderly reactor shutdown and to trip off that pumps of lubrication the burning oil.system which may serve to eliminate the source The insulation on the primary coolant
- boundary could be expected in thisit concrete would protect from the maximum cell. fire severity that The massive structural hangers of the primary a fire of this severity. coolant system would not be affected by of the cable trays on the basement level.This fire could not propogate to any E cables attached enclosed The i.nstrumentation to the primary coolant pipes near the pump are in conduit. Interruption of these cables would not prevent safe shutdown.
Postulated Fire B:
separation criteria. All cable runs in the containment meet the Since the only significant combustibles on this level are the cables a fire was postulated at a high density region of cable trays along the eastern perimeter of the containment structure. Assuming total involvement of O lE 18
.._._.m . . _ . . _ _ _ _ _ _ . _ . _ _ . _ _ . . _ . _ . _ _ _ . _ _ _ _ . _ . _ _ . . . . . ._.
l s
l Fire Area 30 (Continued) l the six cable trays (two of which are separated by 3 ft from 3 the other four). The maximum consequences would be the loss of, several safety related division D cables. This would not prevent safe shutdown since redundant divisions A,B and C are available.
Postulated Fire C: The primary source of combustibles on the i- ,
operating level are the charcoal filters. The postulated; fire may spread-from the initial location to a maximum of one-half i the total filters. The filter fire in itself would cause no
- . damage to safety related equipment, other than the ventilation system. A charcoal fire is relatively isolated by the structure I i
of the filter assembly. These are dampers, mist extractors, and .
absolute filters in front of the charcoal filters. After the filters there is a long section of ventilation ducting leading to I the ventilation fans. These features can be expected to contain
! the charcoal fire in the filter assembly. A deluge system which i l received containment spray water is installed in these filters.
.} The deluge system is manually initiated.
I l l
No safety related cable trays are at this evaluation. This postu-
- I lated fire would not prevent safe shutdown, nor cause radio-l activity release outside the containmen,t.
Consequences of Fire With Active Protection E Postulated fire A: Fire suppression is manual.
l Postulated fire B: Fire suppression is manual.
j Postulated fire C: Fire suppression is manual except in event l
of DBA when the charcoal filter deluge system is automatic. -
~
The automatic fire protection system will provide prompt alarm
.of a fire in this area. The plant fire origade has ample
- portable fire extinguishers to quickly extinguish a local fire.
'l s ! .
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[ Fire Area 30 (Continued)
O
~ Maximum combustible Material. Quantity Fire Load Fire Severity Basement Level - Steam Generator Cell A N00 SY00 2 Lubricating 011 -306 gals 2K S S Btu /ft '
T5~ Min Basement Level - Steam Generator Cell B Lubs-icat4ng Oil --3 0 0 -gals--3 6,' 680 Btv/f42* lb'!4!'.E
-20 Mir..
naman wh=t; eve, .
[1.EEO 3
2 Cable Insulation 9290 lbs 15,0007 Btu /ft .12 Mir.r Ground Level '
13,500 lbs 2 Cable Insulation 24,523 Bt.u/ft 19 Min.
i Operating Level -
Cable Insulation 1,000 lbs. 1200, Btu /ft 2
~
Charcoal Filters 11,500 lbs 16,000 Btu /ft 13 Min.
,- Fire Protection '.
'l The fire detection system in' containment includes. thirty-three j ionization type detectors; thirteen on the ground level, seven-l teen on the intermediate level and three on the operating floor.
3 There'are four flame type detectors on the intermediate level ,
and eight air duct detectors; six on the operating level and -
! two on the basement' level. All detectors provide alarm and
. annunciation locally as well as in the control ream.
1 ,
6 There are five 10 lb dry chemical extinguishers located in .
I containment. Four of these extinguishers are on the operating '
level (El. 1036'-0") at column's (5b,N), (3a,N), (5b,Q) and i (3a,Q). -The fifth is on the basement level (El. 994'-0") at column _ (2cyN) . There are also.five 20 lb dry chemical extin-guishers and two 15 lb CO extinguishers in containment. Three ofthedrychemicalextinhuishersareonthegroundfloor (El. 1013'-0").at columns (4a,N), (5b,N) and (2b,)P. Two others are on the basement floor (El. 9 9 4 '-0") ct LN1,Q) and (5b,Q) near e
the the' on reactor coolant pumps intermediate and the CO(.El~_1022'2 level . 0 ) at"xtinguishers (2b,L) , and are located (5b,L) .
A high temperature deluge system also exists for the charcoal .
HVAC filters.
O. :
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- 2. Control of Combustibles
- a. Isolation and Separation of Combustibles Isolation and separation of combustibles are discussed under Section 5.2 above, as related to fuel oil and lube oil systems, cable insulat:lon, etc. This requirement is met.
- b. Bulk Gas Storage Bulk hydrogen is stored out-of-doors, away from safety-related equipment. Hydrogen and nonflammable gases are required in certain areas for operation of hydrogen analyzers or other equip-ment. These gases are stored in minimal amounts and the cylinders are properly secured.
- c. Plastic Materials Plastic materials use has been minimized, except for use of cable insulation and jackets. Cables have been specified and tested to be fire retardant. To provide an extra degree of assurance that they will not be a fire hazard, flame retardant coatings will be applied to cables in the most important locations.
Fire detection and extinguishing capability are provided in areas of maximum cable. concentration. Therefore, it is concluded that the intent of this criterion is met.
- d. Storage of Flammable Liquids Storage of f1Ammable liquids complies with the requirements of NFPA 30, " Flammable and Combustible Liquids Code."
1 I 1 m
- l l
{l_
of . appropriate NFPA standards. Particular consideration will '
ba given to the topics listed for design of the systems. '
The criteria will be met. F 4 ,
- 5. Carbon Dioxide Suppression Systems No fixed carbon dioxide suppression systems are installed or planned. The criterion is not applicable.
- 6. Portable Extinguishers j Fire, extinguishers are provided in accordance with NFPA 10-1975.
- Whers the dry chemical type was selected, consideration was given
- to adverse effects on equipment and on cleanup problems. .
D. Guidelines for Specific Plant Areas j 1. Primary and Secondary Containment d
l Fire hazards in the containment have been ideicified and discussed ,
in this report (section S.3.2 and Section 5.5). These include i reactor coolant pump lube oil, cable insulation, and charcoal I
^
filters. The containment fire detection system, described in j Section 5.3.1, includes both general area detection and fire !
detection for specific locations. The analysis, as well as industry experience with circulating water pump lube oil fires,
~~
indicates tnat automatic extinguishment of these fires is not required to provide protection of the health and safety of the public. Sprays are installed in the charcoal filters in containment i
~
using containment spray water in the event of a loss-of-coolant accident and later ignition of the charcoal by heat from deposited fission products. Manual extinguishment is csed for other fires g{
if they occur in containment. The intent of the criterion is met.
J o- M i 6-20
.JU M ' @ "'"
3.2 Incomplete Itns '
~. - .
The licensee has ccmmitted to take action on incomplete items as noted -
below. The staff's review of the Ifcensee's response to.these items and O ., any further proposed changes to the fire protection program will be ad-dressed in a supplement to this report. The schedule for the completion 1 U of the licensee action on these incomplete items is given in Table 3.2.
The sections of this report which discuss these items are noted in parentheses.
3.2.1 . Rupture of Fire Water Piping (4.3.1.3)
The licensee will analyze the effects of rupture of the fire water piping, to be installed, on safety-related equipment. .
3.2.2 tt Testing Fire Detectors (4.2)
The licensee has agreed to provide the bases and criteria for the instal '
lation and testing of fire. detectors. . .. .
3.2.3
- Reactor Coolant Pump Lube Oil Collection System (5.20) i l
- The licensee has agreed to provide one of the following: .
(1)' A lube oil collection system to contain lube oil leakage and to '
drain leaked oil to a safe place.
(2) A fire suppression system to control a lube oil fire and to pro-tect the reactor components from that fire.
(3) A study for flRC consideration which includes, a detailed ~'"
evaluation of the installation of the lube oil collection system ar.d the lube oil fire suppression system, and a detailed analysis that shows the facility can be safely shutdown in the event of a - -
4 unmitigated lube oil fire. The unmitigated fire analysis will consider, but is not limited to, localized effects of the fire, t effects on containment filters and other combustibles in'the g r.cntainment, as well as pressure and temperature effects through-cut the containment building.
- 3. 2.4 . Cable Separation (4.10)
In all areas where both divisions of cables in systems required - -
for safe shutdown are routed in the same fire area, the licensee will describe the minimum separation between redundant cables, '
including interposing combustibles. ' Additional modifications will be accomplished as necessary to preserve safe shutdown capability.
.. . - - . . . - = = _ _ . - _ _ _ __ - -. . _ _ _ - - - _, _ _ , _ _ . , . __
f jf]6 DEL l
. . l TABLE 3.2 ,
3.2 1.icensee Submittal Dates f'or Incomplete Items.
Rupture of Fire Water Piping June 1979 3.2.1 3.2 2 Testing Fire Detectors In Progress for Existing Detectors 3.2.3 Reactor Coolant Pump Lube Oil Collection June 1979 Analysis, System June 1980 Modification if Needed g
3.2.4 Cable Separation (Completion of Analysis) September 1978 y
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i g w a- .-
fire in this area. Backup is availab10 by Lirculating raw water,in the .
comp:nent c:aling system.
19.4 Fire Protection Systeds -
q\'
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Fire detection is provided by ionization type smoke detectors, three of which are installed in the area and four of whjch are. installed in ventila-tion ducts serving the area. Eight portable extinguishers are distributed i
throughout the area to figh,t ,f, ire manual,1y.
5.19.5 Adequacy of Fire Protection ,
1 The protection for the area does not provide adequate assurance that component cooling will be maintained for shutdown following a fire in this area. The licensee has provided, however,,the capability to use raw river .
water in the component cooling system in the event that this arda is in-volved in an unsuppressed fire.
1 i 5.19.6 Modifications Ten ionization type detectors, two addition portable extinguisherr .nd five manual hose stations will be provided.
- We find that, because an alternate water source is a railable for component cooling, fire protection for the area satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
n '
! - . 20 Conta'.nment (Fire Area No. 30) . ,
5.20.1 Saist.-P.siated Eouiement .
l Component's associated with safety injection systems, the chemical and vole. s control system, the containment HVAC system, and the component coolirg system are in the area with the reactor and its associated auxil- i iaries and instrumentation. ,
5.20.2 Combustibles - l Combustibles in the area include a large quantity of lubricetion oil, cable insulation and charcoal in the filters., .
5.20.3 Consecuences if no Fire suporession A fire involving reactor coolant pump lubrication ~ oil could' produce a high temperature and release a large amount of heat within a short period of time. It has not been demonstrated that safe shutdown capability can be preserved under the effect of such a fire.
Cables from redundant divisions ar,e generally well separated within con- .
tainment. It is not credible that more than two out of four redundant channels of cables could be involved in a single fire.
A 5-18 l
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! C l20.4 Fire Protection System The detection system for the area consists of 33 ionization type smoke detectors and four flame detectors. , Eight more ionization type smoke l
l detectors are installed in the. ventilation ducts. Eleven portable extinguishers are distributed throughout. the area'. Containment HVAC charcoal filters are equipped with a deluge system supplied by the con-tainment spray system. Eight local alarm lights are now installed.
5.20.5 Adequacy of Fire Protection ,
Portable extinguishers are inadequate to suppress a fire involving reactor ,
coolant pump luhrication oil. Access for fire fightin'g would be difficult l due to smoke which may be produced by the fire and due to radioactivity
. associated with the arer. .
(
5.20.6 Modifications One ad litional portable extinguisher will be provided. e...,
The licensec has also . agreed to provide one of the following:
(i) A lube oil collection system to contain lube oil leakage and to drain leaked oil to a safe place:
C/ (2) A fire suppression system to control a l'ube oil fire and to protect
~
the reactor components.from that fire. i (3) A study for !!RC consideration which includes a detailed !
evaluation of the installation of the lube oil collection system ,
and the lube oil fire suppression system, and a detailed analysis !
that shows the facility can be safely shutdown in the event of an unmitigated lube oil fire. The unmitigated fire analysis will consider, but is not limited to, localized effects of the fire, effects on containment filters and other combustibles in the con-tainment, as well as pressure and temp,erature effects throuDh out the containment building.
The staff's_ evaluation of the licensee's analysis or proposed modifi-cation will be addressed in a supplement to this report. . .
5.21 Intake Structure (Fire Area No. 31) ,
5.21.1 Safety-Related Equipment The safety-related equipment in tiis area includes the four raw water pumps.
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- 5-19
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omana Public rower nistrict .... -
O 1833 HARNEY a OMAHA. NESMASMA 88103 m TELEPHONE S36 4000 AREA CODE 402 June 6, 1979 -
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/NC '/9-0059 e
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,/
Director of Nuclear Reactor Regulation * .
ATTN: Mr. Robert W. Reid, Chief Operating Reactors Branch No. k U. S. Nuclear Regulatory Commission Washington, D. C. 20555 .
Reference:
Docket No. 50-285 4
Gentlemen:
- Alte. ~14 - v e 44 l
, In accordance with Section 3.2.3 of the Fort' Calhoun Station Fire Protection Safety Evaluation Report (SER), issued by the Commission on August 23, 1978, the Omaha Public Power District here.rith submits five (5) copies of the attached design description for review. The design ,asc description proposes a modification to collect and contain reactor z j coolant pu=p lubricating oil leaks in order to reduce the probability -
of a lube oil fire in the containment building.
As indicated in the SER, the Co=nission must review and approve f this modification. As such, it is respectfully requested that a timely ;
review be performed in order that a final design can be accomplished l and modifications can proceed on schedule. The District's staff re-mains available to provide assistance to expedite your review.
I Sine rely, f
i h(10.1 e
2 .$ T. Ej Short Assistant General Manager
- TES/KJM/BJH:jmm REVIE71 RECORD 2
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. DME CODE Attach. _
cc: IeBoeuf, Iamb, Leiby #s MacRae .,_..,.,7~~
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' 1333 New Hampshire Avenue Suite 1100 "~ ' N i
Washington, D..C. 20036 C"~ ~" "~ ~ ~"' ]
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PREPARED BY 8'f/ #M'M 7 frel5minary De$ign 5e$cription
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CHECKED BY', U < gg, 1 CONT. ON SH. 2 ;
APPROVED REV~ O oATE A v 25 yy OMAHA PUBLIC POWER DISTRICT FC-78-57 / ' )
(').
q ILLEGIBLE c(di-27-0057 \
i FORT CALHOUN STATION 1 RCP LUBE OIL COLLECTION MR-FC-78-57 PRELIMINARY DESIGN
.)
. DESIGN DESCRIPTION A. DESIGN BASIS - REQUIREMENTS B. TECHNICAL DESCRIPTION C. ANALYSIS D. SAFETY EVALUATION
. 1 ATTACHMENTS
- 1. ATTACHMENT 1: DRAWING SHOWING THE EXISTING CONFIGURATION OF THE RCP MOTORS
- 2. ATTACHMENT 2: DRAWINGS SHOWING THE PROPOSED l LUBE OIL COLLECTION SYSTEM ATTACHED TO THE RCP MOTOR
~
- a. HUS Drawing 1928-L-011
- b. NUS Drawing 1928-L-012
- c. HUS Drawing 1928-L-013
- d. NUS Drawing 1928-L-014 O
REV. 1/79
nt,r i.uoe v i a t.o a s e c u on GSE-B-2 2 FORM d PREPARED BY . .- J Preliminary Design Description
, CHECKEDBY'?'A-'~~ gg, 2 CONT. ON SH.
APPROVED fh5 FC-78-57 REV' O DATE A a<79 OMAHA PUBLIC POWER DISTRICT MR 110. <
GENERATING STA. ENG.
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.: C.' .?. :<.a A. DESIGit BASIS In accordance with the Safety Evaluation Report by the Office of fluclear Reactor
- Regulation, U. S. tiuclear Regulatory Commission. Docket tio. 50-285, paragraph 3.2.3, page 3-1, a modification will be made to the reactor coolant pump motors to contain a potential lube oil leak and drain the leaked oil to a safe place.
This will reduce the probability of a lube oil fire in the Containment Building.
B. TECHitICAL DESCRIPTI0t1 Omaha Public Power District is performing the design and the fabrication and instal-lation supervision for the oil collection system for the four (4) reactor coolant p' ump motors for Fort Calhoun Station Unit I. The oil collection system is designed to meet the following criteria:
'"These systems would collect oil leaks from the lift pump, oil cooler (if external to reservoir), flanged or gasketed oil connections, oil level sight glasses, drain and fill connection points and oil reservoirs."
g3
('~ ) Also,'the system is designed to contain a pressurized oil leak from a crack in any part of the lubrication oil system external to the pump. The collection system con-sists of three sealed pans (12-in deep) connected together with a three piece cover and completely encloses the pressurized oil containing components. The predominan t material is 16 gauge, Type 304 stainless steel. Each pan has a 2-in. drain to a collection tank located in the basement. There wi'll be one drain tank for each pair of motors in a RCP/ steam generator cavity. The field installed drain piping will have a flexible coupling to the collection system to allow for motor movement.
The design philosophy was to design leakproof bottom pans so they would hold the maximum amount of oil that could leak out even if the pan drains were plugged.
~
The tops are designed to contain leaks from pressurized line to prevent oil from being sprayed outside the collection system. The top portion is not leak proof, but seams are designed so that oil sprayed on, them will stay inside the collection system. The following additional design criteria are applicable:
~
- 1. The following will be performed to assure a satisfact'ory system:
Critical dimensions will be, field measured, documented and e independently verified.
Design reviews will be conducted at various stages of the design. .
The original designer will follow the system through installation.
( Leak checking of the system will be performed.
V] '
Fabrication and installation will be supervised by the responsible design engineer.
REV. 1/79
,, g g,.g.2-Z FOHM '",r Luoe U): Lo l l ec ti on I PREPARED BY M g # W a' Preliminary Design Description l bz pry?T CHECKED 8Y' ** ' i '~
~ - - - *p 4
SH. 3 CONT. ON SH.
APPROVED *M4C FL-18-b/ REV. O DATE /%v24 75 .
OMAHA PUBLIC POWER DISTRICT !
- 2. The collection system will contain more than 110 gallons of oil in the !
leakproof pans even if all drains to the basement drain tanks are '
plugged. One-hundred and ten (110) gallons is the most oil that can leak into the system for any single failure.
- 3. ' Adequate ventilation will be provided for the oil-lift pump motor. *
- 4. The following items will be incorporated for convenience'for motor maintenance:
Quick access ports for oil cooler tube bundle inspection.
Quick access latch for fill, level gage, and drain.
Top and side can be easily removed for access to pressure switches, lift pump, etc.
Seals will be standard, readily available types.
~
The collection system drains can be used for routine draining of'
- oil for maintenance. .
2 5. The collection system will be designed such that a failure of a water pipe to the oil cooler inside the system will not flood inside the
' 6O motor or cause a structural failure of the system.
- 6. Large pieces of the system will have lifting lugs for crane attachment.
i 7. Collection system pieces must be small enough to go into containment through the personnel air lock.
~
. 8. The following are applicable to the collection system drain tanks:
1
- will be located on the basement floor at Elevation 994'. (The oil cooler is at Elevation 1022.5'.)
. j
- - Capacity will be 150 gallons., j
! - Will have a drain and vent with the <lrain located such that over-flow for one pump motor failure is impossible. -
{
- One drain tank for two pump motors or two 150 gallon tanks total l l e will be provided. l 1
- 9. The predominant material will be 16 gauge, Type 30? stainless steel. .
i i 10. The system can be removed 50 that the motor can be removed through an !
l eight (8) foot-diameter opening. ,
- 11. The largest piece will weigh less than 180 pounds.
REV. 1/79 I
GSE- B-2-2 TORM a'u~ -" RCP Lube Oli Lollection PREPARED BY. ;p 7 Preliminary Design Description
( CHECKED BY' '! --
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GENER ATING STA. ENG.
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- 12. The following oil system failures will be collected: 1
- oil cooler housing, drains, inlet and outlet lines.
- lift pump and its inlet and outlet lines. -
- - drain, fill and level gauge.
oil cooler tu.be motor shaft oil dam.
1 The lower oil reservoir is not being collected since it contains only four (4) i gallons, has an internal oil cooler and there are no pressurized lines, sight glasses, etc. Also, the oil level transmitter is not contained since the trans-mitter housing has a pressure rating of 500 psig and it is exposed to only 17 inches of oil.
The preliminary design for the oil collection system is presented by NUS Orawing Numbers 1928-L-011, -012, -013 and -014 (Attachment 2). There will be some minor variations to this basic design for each of the four motors to acconnodate inter-ferences in the RCP cavities. Attachment 1 shows the existing motor configuration.
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C. ANALYSIS i
The following reviews, analyses or calculations will be performed to insure the adequacy of the system: I
- 1. A seismic analysis will be perfonned to assure the system will not fall on a safety-related item during a safe shutdown earthquake.
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- 2. The collection system will be reviewed for each pump motor /RCP cavity for adequate ventilation of the pump motor. .
- 3. A calculation will be performed to show the inpingement of 1000 psig oil wi.ll not penetrate the collection system.
- 4. An analysis will be performed to show the collection system does not cause motor vibrations. ,
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1 REV. 1/79
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PREPARED BY_ Preliminary Design Description f
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d APPROVED FC-78-57 REV. O DATE Aul4 19 OMAHA PUBLIC POWER DISTRICT MR NO. / '
GENERATING STA. ENG.
W/6- 794059 ,
D. UNREVIEWED SAFETY OUESTION EVALUATION (10 CFR 50.59)
Procedure / Procedure Change / Modification MR-FC-78-57 I. The probability of occurrence or the consequences of an accident or mal-function of equipment important to safety previously evaluated in the ,
safety analysis report may be increased: !
No. The installation of this system reduces the probability of occurrence of a lube oil fire. It does not have an adverse affect on the operation of I any other safety related components. The system will be seismically designed and supported.
'II. Possibility for an accident or malfunction of a different type than any - !
evaluated previously in the safety analysis report may be created:
. No. It reduces the probability of fire. The possible. effects of its installation on the performance of other equipment indicates that it will not create any adverse circumstances which weren't previously evaluated in the safety analysis report. !
III. The margin of safety as defined in the basis for any technical specifi-cation is reduced. -
No. It is a passive system with no moving part.s. It has been shown not to interfere with or reduce any safety related equipment's function. It reduces the probability of fire and thus could only contribute to increasing the margin of safety.
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! EXISTING RCP MOTOR CONFIGijRATION t
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ATTACHMENT 2 LUBE OIL COLLECTION SYSTEM DRAWINGS A. NUS DRAWING'1928-L-011 B. HUS DRAWING 19?8-L-012 C. HUS DRAWING 1928-L-013 D. NUS DRAWING 1928-L-01'4 0 .
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,f; . ,og UNITED STATES y g NUCLEAR REGULATORY COMMISSION
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- SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO. 53 TO FACIk.ITY OPERATING LICENSE NO. DPR-40 OMAHA PUBLIC POWER DISTRICT l FORT CALHOUN STATION, UNIT NO.1 DOCKET NO. 50-285 Introduction ,
. On February 14, 1978 the NRC issued Amendment No. 38 to the Fort Calhoun Station, Unit 1 Operating License which incorporated into the Facility
- Technical Specifications the elements of the then existing fire protection systems and administrative controls. Following. further evaluation of the fire protection program at the Fort Calhoun Station, the staff issued Amendment No. 40 on August 23, 1978, which incorporated a license condition
- related to the completion and implementation of fire protection modifications.
Subsequent to August 23, 1978, the licensee has submitted additional informa-tion and proposed revisions to the fire protection program. The staff has
. reviewed this additional information and has made the following findings
.which are presented in the order of, and with the same numerical designations as, the items listed in the August 23,1979 SER. This SER supplements the August 23,1978 SER.
- Dis ~cussion and Evaluation Item 3.1.4 - Fuel Tank for Diesel Driven Fire Pump
- SER Section 3.k.4 indicates that a modification will be made to prevent i structural steel framing in the vicinity of the fuel storage tank, supplying the diesel engine-driven fire water pump, from being damaged by a fire at the tank. -
By 1'etter dated August 23,1978, the licensee proposed to provide a reinforced concrete block enclosure around the diesel fuel tank, and fill the space between the tank and the enclosure walls with sand and/or limestone.
The proposed modification effectively buries the tank and eliminates it as a possible fire hazard. However, the proposed arrangement of liquid level indicator and drain line does not sufficiently eliminate the possibility of a diesel fuel leak which could present a fire hazard to the intake structure. Therefore, the staff recommends the following modifications
[]- or equivalent alternatives be incorporated:
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Item 3.2.3 - Reactor Coolant Pump 011 Collection System /-
SER Section 3.2.3 indicates that the licensee will provide one of the following: .
- 1) A lube oil collection system to contain lube oil leakage and to drain leaked oil to a safe place. I
- 2) A fire suppression system to control a lube oil fire and to protect the 'l reactor components from that fire. !
- 3) The results of a study demonstrating that safe shutdown will not be ,
l impaired in the event of an unmitigated reactor coolant pump lobe oil I fire. ,
By letter dated June 6,1979, the licensee proposed to install lube oil collection systems and provided the design description and drawings for the proposed systems. .
The staff has reviewed this information and find that'our concern has been l satisfactorily addressed. We consider this issue to be closed. !
l Item 3.2.4 - Cable Separation (See item 3.1.15) '
{
Technical Specifications The revisions to the Technical Specifications issued' with.this License Amendment are, for the most part, additions to incorporate the various modifications which were required by the staff. A number of separate applications had been submitted to incorporate added fire detection and suppression systems, these applications were combined and the entire section of fire protec+, ion Technical Specifications was updated to the currently l approved version of the Standard Technical Specifications with the agreement l of the licensee. Since the changes to the Technical Specifications incorporate l
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additional NRC requirements and are in accordance with these currently
- approved, ue find the Technical Specifications to be acceptable. .
Summary The staff has completed the review of all fire protection infonnation submitted to date, except for Alternate Shutdo en Capability, and, as ,-
discussed above, has reached satisfactory resolution on all items listed in Tables 3.1 and 3.2 of our August 23, 1978 SIR with the exception of the following:
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. 7590-01 ;
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1 UNITED STATES NUCLEAR REGULATORY COMMISSION l DOCKET NO. 50-285 l
{ OMAHA PUBLIC* POWER DISTRICT NOTICE OF ISSUANCE OF' AMENDMENT TO FACILITY l OPERATING LICENSE l
The U. S. Nuclear Regulatory Comission (the Comission) has issued Amendment f.o. 53 to Facility Operating License No. DPR-40 issued to Omaha -
l Public Power District (the licensee), which revised the Technical Specifications !
for operation of the Fort Calhoun Station, Unit No.1, located in Washington County, Nebraska. The amendment is effective as of its date of issuance, t
This amendment changes the Technical Specifications to incorporate O
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additionai fire Pretectien reauirements.
The applications for the amendment comply with the standards and requirements of' the Atomic Energy Act of 1954, as amended (the Act), and 4
l the Comission's rules and regulations. The Comission has made appropriate findings as required by the Act, and the Comission's rules and regulations in 10 CFR Chapter I, which are set forth in the license amendment. Prior j public notice of this amendment was not required since the amendment does not involve a significant hazards consideration.
The Comission has determined that the issuance of this amendment will l not result in any significant environmental impact and that pursuant to 10 CFR 551.5(d)(4) an environmental impact statement, or negative declaration and environmental impact appraisal need not be prepared in connection with the issuance of this amendment.
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l , 'nV For further details with respect to this action, see (1) the licensee's submittals dated October 4,1978, January 22, May 30, and October 9,1979, and August 20, 1980, as supplemented. (2) Amendment No. 53 to License No.
DPR-40, and (3) the Comission's related Safety Evaluation. All of these items are available for public inspection at the Comission's Public Document
, Room, lil7 H Street, H. W., Washington, D. C., and at the W. Dale Clark i . - -
Library, 215 South 15th Street, Omaha, Nebraska. A copy of. items (2) and ,
-(3) may be obtained upon request addressed to the U. S. Nuclear Regulatory Commission, Washington, D. C. 20555, Attention: Director, Division of Licensing. '
I Dated at Bethesda, Maryland, this 17th day of November 1980.
FOR THE NUCLEAR REGULATORY COMMISSION s
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- Robe u.v A. Clar , Chief Operating Reactors Branch f3 Division of Licensing j e i <
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[. NUCLEAR REGULATORY COMMISSION -
RE!I!N IV 5 = x,- yg 011 RYAN PLAZA DRIVE. SUITE 1000
,%, ARLINGTON. TEXAS 78011 In Reply Refer To:
Docket: 50-285/88-28 Omaha Public Power District ATTN: Kenneth J. Morris, Division Manager Nuclear Operations 1623 Harney Street >
Omaha, Nebraska 68102 I Gentlemen:
This refers 'to.the inspection conducted.by Messrs. M. . E. Murphy, R. P. Mullikin, and C. E. Johnson of this office during~ the period August 22-26,.1988, of activities authorized by NRC Operating License DPR-40
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for the Fort Calhoun Station, and to the discussion of our findings with Mr. W. G.- Gates and other members of your staff at the conclusion of the inspection.
Areas examined during the inspection included the fire protection / prevention program, the triennial postfire safe shutdown capability reverification, and O followup on previously identified items. Within these areas, the inspection consisted of selective examination of procedures and representative records, interviews with personnel ~, and observations by the NRC inspectors. The l inspection findings are documented in the enclosed inspection report. ,
t During this inspection, it was found that certain of your activities were in violation of NRC requirements. Consequently,-you'are required to respond to !'
these violations, in writing, in accordance with the provisions of Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations. Your response should be based on the specifics contained
_ in the Notice of Violation enclosed with this-letter.
Two unresolved items are identified in paragraphs 4 and 5 of the enclosed inspection report.
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We have also examined actions you have taNen with regard to previ~ously 1 identified inspection findings. The status of these items is identified in ;
paragraph 2 of the enclosed report.
The response directed by this letter and the accompanying Notice is not subject to the clearance procedures of the Office of Management and Budget as required f by the Paperwork Reduction Act of 1980, PL 96-511. !
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HNT, BC, RKB, JS, RCD, JM, LLZ, FFF, KET LLG, RGE, CFS, SARC, RDP 10/3,
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o FC87-026, " Transfer of the P250 Computer Functions to the MODCOMP Computer" l
o FC87-037, " Diesel Generator Electrical Modifications" o FC88-060, " Diesel Exhaust Seismic Supports" .
The NRC inspectors reviewed the OPPD Generating Station Engineering Guides GEG-3, " Preparation of Design Packages " and GEG-4, " Fire 1 Protection System Interaction" which instructs the reviewer on possible safe shutdown effects due to plant modifications. These l
procedures appeared adequate to perform their intended functions.
l No violations or deviations were identified.
- b. Emeroency Lichting ;
A review was performed of the adequacy of emergency lighting required to perform the safe shutdown functions when a fire requires the
! evacuation of the control room.
l In a previous NRC inspection in January 1988, it was noted that when l exiting the control room, after a fire, the operators must travel 1
j l /' along a corridor to the stairway leading down to the alternate i shutdown panel and the switchgear rooms. The operators would have had to rely on the use of hand-held lights and battery powered exit f NRC Region IV requested signs for illumination in this corridor.
l from NRC Headquarters a clarification of the adequacy of this emergency lighting. Their response on June 23, 1988, stated that the l
i reliance on hand-held lights and exit signs for illumination does not satisfy the technical requirements of Section III.J of Appendix R to j
Section III.J of Appendix R states that " Emergency lighting units with at least an 8-hour battery power supply shall be provided in all areas needed for operation of safe shutdown equipment and in access and egress routes thereto." Thus, the licensee does not satisfy this requirement. This is an apparent violation. (285/8828-02) l ~
The licensee, at the exit interview, committed to performing l compensatory measures for the lack of adequate emergency lighting in the control room corridor. They have subsequently installed, as verified by the senior resident inspector, aThe battery unit has powered two lamps l
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emergency lighting unit in the corridor.
which are directed in such a direction to allow for adequate emergency illumination for operators travelling this corridor.
- c. Reactor Coolant Pump Of Collection System l
The NRC inspectors reviewed the design of the reactor coolant pump oil collection system. The design appeared adequate with the l
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2 C- i exception of the capacity of the oil collection tanks. Section !!!.0 of Appendix R requires that oil leakage be collected and drained to a vented closed container that can hold the entire lube oil system ;
. inventory. The licensee's design is for two collection tanks with a capacity of 150 gallons each. Each of the four reactor coolant pumps i has an oil capacity of less than 115 gallons. Thus, there is a total l tank capacity of 300 gallons to collect a total oil supply of '
approximately 460 gallons. However, according to the FCS Fire Hazard Analysis the largest oil leak has been determined to be less than i 80 gallons total. i Since the oil collection system, including collection pans, drain
- lines, and collection tanks has enough capacity to hold all of the oil from the pumps, there api'ars to not be a safety concern.
However, the present system does not comply with Section !!I.0 of Appendix R and an exemption is required. This will be considered an unresolved item pending the licensee's submittal and NRR's review and .
P acceptance of the exemption request for the reactor coolant pump oil l
. collection system. (285/8828-03)
No violations or deviations were identified.
- 5. Prestressina Post-Tensionina System (61701)
. During the inspection of the fire area barrier in the upper electrical penetration room, tendon grease was observed on the fire barrier seal.
Tendon grease was also observed on the outer perimeter of the tendon
. buttress. The NRC inspectors asked the licensee two questions: (1)has the tendon grease been isolated to a specific location; and (2) is the i tendon grease leakage within acceptable limits.
The licensee could not address the issue at the time; however, they did inform the NRC inspectors that,Inryco performed the surveillance requirements for the prestress tendon system as required by TS and found no significant problems.
Prior to the exit interview the licensee gave the NRC inspector the surveillance report perfonned by Inryco. The NRC inspector reviewed the results of The report. The results-indicated that the tendons were observed for tendon grease volume and were within the acceptance criteria.
Even though the results of the lan :urveillance requirements were acceptable, the NRC inspector noted that since the surveillance report only included a sampling of the tendons, there may be tendons that were not included in the sample selection performed by Inryco. These tendons may not have an adequate volume of grease which could leave insufficient corrosion protection. This issue was discussed with licensee personnel at which time the NRC inspector stated that a determination of what tendons Op are leaking grease and if this grease leakage has affected tendon operability needs to be conducted.
This is considered to be an Unresolved Item (50-285/8828-04).
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- LIC-ss-lo66 .
[~ f Omaha Public Power District 1623 Harney Omaha. Nebraska 68102 2247 402/536 4000 A (/
November 28, 1988 '
LIC-88-1066 o Il2-.O 6yent11oA epuese i
U. S. Nuclear Regulatory Comission Attn: Document Control Desk
. Hall Station PI-137 l Washington, DC 20555 i
References:
- 1. Docket No. 50-285 i 2. Amendment No. 40 to OPPD Operating License No. DPR-40 dated August 23, 1978. .
- 3. Letter to NRC (R. W. Reid) from OPPD (T. E. Sbrt) dated !
June 6, 1979 l
DPR-40 dated November 17, 1980 .
Gentlemen:
SUBJECT:
Exemption Request from 10 CFR 50 Appendix R, Secticn 111.0,
'011 Collection System for Reactor Coolant Pumps" l Omaha Public Power District (OPPD) is requesting an exemption pursuant to i 10 CFR 50.12 from the requirements of section 111.0 of Appendix R to 10 CFR 50
- for the reactor coolant pump oil collection tank holdup capacity. The NRC has l reviewed and approved the current tank capacity (Reference 4) which was based
! on Appendix A to Branch Technical Position 9.5-1, prior to the issuance of j - Appendix R.
f . Attachment 1 to this letter provides the detailed description and justification for this exemption request. Attachment 2 )rovides answers to questions raised l 4 during a November 25, 1988 telephone call )etween D. Kubicki of htR and rny
! staff. Attachment 3 provides a description of the fire area as contained in
) the Updated Fire Hazards Analysis.
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LIC-88-1066 Page 2 l }
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As discussed in a telephone conference on November 23, 1988, between P. D. l Milano of the HRC and members of my staff, it is requested that this exemption be approved prior to startup which is currently scheduled for December 25, 1988. Accordingly, please find attached a check in the amount of $150.00 pursuant to 10 CFR Part 170. If you have any questions, please contact us.
Sincer ly, ,
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. Morr s l Division Hanager l Huclear Operations Attachments KJH/sa c: LeBoeuf, tamb, Leiby & MacRae
.R. D. Martin, HRC Regional Administrator P. D. Hilano, HRC Project Manager P. H. Harrell, NRC Senior Resident Inspector l I
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l UNITED STATES OF AMERICA flVCLEAR REGULATORY C0fEISS10N V I l
l In the Hatter of
)l Omaha Public Power District h Docket No. 50-285
, (FortCalhounStatica j -
! Unit No.1) J l
AFF10AVli l K. J. Horris, being duly sworn, hereby deposes and says that he is the Division Hanager - Huclear Operations of the Omaha Public Power District; that as such i he is culy authorized to sign and file with the Nuclear Regulatory Comission !
the attached information concerning t:1e Exemption Request from 10 CFR 50 l Appendix R,Section III.0, '011 Collection System for Reactor Coolant Pumps";
that he is familiar with the content thereof; and that the matters set forth l therein are true and correct to the best of his knowledge, information, and belief.
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KLT.BoYris Division Hanager Nuclear Operations STATE Of HEBRASKA mman:a v wm ss LPAT10C3 CWA 111NQ COUNTY Of DOUGLAS 81onahmtm Subscribed and sworn to before me, a Hotary Public in and for .th'e. State of Hebraska on this ~~.8*~ d.ay of November,1988.
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' i I I A. Backoround in 1978, OPPD was issued Amendment 40 to the Fort Calhoun Station Unit I l Operating License which contained a license condition related to the completion of several fire protection modifications. SER section 3.2.3 indicated that OPPD would provide one of the following:
- 1) A reactor coolant pump lube oil collection system to contain lube oil leakage and to drain leaked oil to a safe place. .
- 2) A fire suppression system to control a lube oil fire and to protect the reactor components from that fire.
- 3) The results of a study demonstrating that safe shutdown will not be impaired in the event of an unmitigated reactor coolant pump lube oil fire. ,
By a letter dated June 6,1979, OPPD proposed to install lube oil collection systems and provided the design description and drawings for the i proposed systems. The NRC, in the SER for Amendment 53 to the Fort Calhoun !
Station Unit 1 Operation License dated November 17, 1980, stated that "the
, staff has reviewed this information and find that our concern has been satisfactorily addressed. We consider this issue to be closed."
Subsequent to this,10 CFR 50 Appendix R Section 111.0 which requires a collection system be provided for each reactor coolant pump, the leakage from which "shall be collected and drained to a vented closed container that can hold the entire lube oil system inventory" was issued and applied to facilities licensed prior to January 1,1979.
q 4 8. Description Each of the four reactor coolant pumps at fort Calhoun Station contains 140 gallons of lube oil. The previously accepted lube oil collection system was designed to contain " oil leaks from the lif t pumps, oil coolers, i flanged or gasketed oil connection, oil level sig1t glasses, drain and fill connection points, and oil reservoirs." The system consists of three sealed pans and covers which enclose the pressurized oil containing
! components of each reactor coolant pump with a two inch drain line routed
- -- to one of two 150 gallon collection tanks, one for each pair of reactor coolant pumps. The collection tank capacity was based on a maxicum expected leak of 110 gallons for any single failure as opposed to a two pump inventory of 280 gallons for each of the two collection tanks.
Each horizontally positioned tank is equipped with an overflest drain located at the top of the tank drains to the floor. The tanks are located between and below the reactor coolant pump cavities at basement elevation 994 ft., approximately 23 f t. below the collection pans. Assuming a simultaneous f ailure of all four lubricating oil systems, the entire inventory of oil will be discharged to the. collection systec. This would result in a maximum of 130 gallons of lube oil overflowing onto the containment basement floor at each tank location from the oserflow drains, and into the nearest 4 inch floor drain. The basement floor in the area of S
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~ the collection tPnk for reactor coolant pumps RC-3C and RC-30, and within 4 feet of the collection tank for pumps RC-3A and RC-3B. In each area oil
, would temporarily pool.and would be contained by the floor drain. ,.,
O V A walkdown was done to determine if any potential ignition sources are located in the vicinity of the tanks and floor drains. Based on the
, results of this walkdown, no potential ignition sources were identified at or below the level of the tank. The maximum overflow of oil resulting~ from the loss of the entire oil system inventory from all four reactor coolant pumps does not pose a hazard to the ability of the facility to safely '{,
4 shutdown or represent a significant exposure hazard to the fire area '
itself. Additionally, the most recent revision of the Fire P.azards Analysis [ Paragraph (b), page 119 as arovided in Attachment 3) describes the evaluation of the effects of a lu>e oil fire in the reactor coolant pump cavities and shows it to have no adverse effect on safe shutdown. The fire area is also equipped with an area wide fire detection system to give prompt notification to plant staff so that manual fire fighting may be ,
, initiated. '
i C. Exemption Reouest The District requests an exemption, pursuant to Sections 50.12(a) and 50.48(c) of 10 CFR, from the requirements of Section 111.0 of Appendix R.
5)ecifically, exemption is requested for Fire Area 30 from the requirements
- t1at the lube oil collection system drain tank ca >acity be capable of holding the entire lube oli system inventory of tie reactor coolant > umps.
. This requirement is unnecessary to assure the capability to safely slutdown i the plant in the event of any credible fire for the reasons listed above. (
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The following are questions raised about the Reactor Coolaat Pump Oil Collection System by D. Kubicki in a telephone communication dated Rovember 25, 1988.
Question 1 HRR was told by a Regional Inspector that the entire system tanks, piping, etc.
when taken as an entity would contain the total inventory of all fwr pwnps.
Is this a true statement? Please provide an explanation.
i Answer The total volume of one collection pan and its associated piping is 7 approximately120 gallons (110gallonpancapacity+capacityofapproximately 50feetofnonshared2inchdrainpipingof10 gallons). This gives a total twu pump system capacity of approximately 390 gallons (120 gallons + 120 gallons + 150 gallon tank). However, there is no mechanism installed that would prevent the entire volume of oil collected from draining into the collection tank and out of the overflow. Therefore 130 gallons of oil could potentially flow out of the overflow for the worst case oil loss scenario. ,
Ouestion 2 The system was seismically designed:
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- a. Does this mean that the piping will not fail?
- or
- b. Is the piping designed to 2 over 1 criteria so that it can fail but not
- O fall? If so, can we state that where ever the line falls, that the oil leakage will not contact a potential ignition source?
j Answer The system was designed with flexible couplings to prevent the pipir.g from
- leaking due to motion. The piping design criteria was to survive ar. SSE with j its leak integrity intact. In the event the piping were to leu, the potential ignition sources in the area consist of reactor coolant system com;:nents with surface temperatures above 500'F. The scenario of a reactor cavity lube oil f fire has been shown to have no adverse effects on safe shutdown (Attachment 3,
_ attached).
Ouestion 3 OPPD states that the system will contain oil from pressurized points. What about unpressurtie.d points?. -
Answer . . . ;,d u n e s ->
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The oil piping that is.un)ressurized .is eithEr internal to the motor bearing
- assembly or of such a higi pressure rating that oil leakage is not considered a t credible event. The total volume of the unpressurized oil system in the lower y bearing assembly is only four gallons per pump. The entire upper tearing y assembly is provided with collection capacity with the exception of the level <
trarsmitters which are rated at 500 psig. i 3
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i 'a Attachment 3 !
MRI CA120tDI SIATION O FIRE R17ARn ANALTSIS 4
Fire Area 30 Containment-Elevation 989', 1013', and 1045' controlled Access i Safety Felated i
Location. Exoosures. and construction The containment structure is located in the center of the auxiliary building.
It is bordered on the east by the electrical penetration area (Fire Areas 34A and 34B), valve area II (Fire Area 16), and the condensate and service vater tank area (Fire Area 43); on the north by the basement level general area (Fire Area 6), the mechanical penetration area (Fire Area 13), the ground floor general area (Fire Area 20), the pipe penetration area (Fire Area 23), the I sampling roon (Fire Area 24), the vork area (Fire Area 28) and the HVAC Equipment and Fuel Handling Area (Fire Zone 20.7); on the vest by the BVAC Equipment and Fuel Bandling Area (Fire Zone 20.7), the ground floor general area (Fire Area 6); and on the south by exterior valls, diesel generator room 2 -
(Fire Area 35B) and the equipment hatch enclosure (Fire Area 40).
All valls separating this area from the other mentioned areas are 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated barriers, although penetration seals are not specifically fire rated.
- Access hatches are located in Fire Areas 20 and 40. Penetrations are sealed.
(The 42" ducts from Fire Area 30 to Fire Zone 20.7 are not provided with rated fire dampers.)
The containment consists of three floors: basement (989'), around (1013'), and operating (1045'). These are connected by two unenclosed stairvells. The reac*or, two steam generators, pressurizer and four primary coolant pumps are enclosed in concrete cells running vertically through all three floors. The area per floor is approximately 4860 square feet. Ceiling heights vary from 19 feet to 62 feet.
Haior Safety Related/ Safe Shutdovn Ecotoment and Cabline A) Safety Injection System , " ', . [. . .,
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- Safety Injection, Tank..SI-6A . . , , , . . . , , ,
Safety Injection Tank SI-6B ... T ' *.. " -
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- Sefety Injection,fa$k SI-6C 'W ^',_".'.'. .
- Safety Injection Tank JI .6D t ., ,.; ,'.p, J' *'
Safety Injection Control Fane,1 AI-136-A,B.C.D,~,; ,l,. ;,, ' ,P
- Lov Fressure Safety Injec. tion control Panel AI-140, A,B C.D
~ Fire Area 30 115 REY. )
4 9/88
G i Q PORT CA120DN STATICE PI1g pA71mn ANALYSIS B) Chemical and Volume Control Systea
- Regenerative Heat Exchanger CH-6 ,
C) Containment HVAC system 1
- Containment Air Cooling and Piltering Unit VA 15A j
- Containment Air Cooling and Piltering Unit VA-15B '
- Detector Vell Air Cooling Unit VA-13A !
- Detector Vell Air Cooling Unit VA-13B !
D) Component Cooling System ,
- Component Cooling Vater Cooling instrument racks .
l AI-138, A,B.C.D l
- Component Cooling Lube Oil Cooling instrument racks ,
AI-139, A,B,C.D j
- E) Reactivity Control ,
- Control Rod Drive motors, cables, and associated cables P) RCS Pressure Control System
- PORV85 PCV-102-1 and PCV-102-2
- Pressurizer Heaters
- Auxiliary Pressurizer Spray Valves BCV-240 and BCV-249
. - Pressurizer level transmitters LT-101X, LT-10lT, and LT-106 1 - High range (A,B.C, and D P-102), lov range (P-ll8), and vide range (P-105
- and P-il5) channels of pressure indication. -
)
i C) Auxiliary Peedvater System ;
- Isolation Valves HCV-1107A and RCV-Il08A and associated cables B) Steam Generator System
- Pressure and level instruments, as follovs: l
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l Steam Cenerator Steam Generator 'l i RC-2A RC-2B l A/L-90), A/L-911 A/L-904, A/L 912 l B/L-901, B/L-911 B/L-904, B/L-912 '
- . 'l C/L-901, C/L-911 C/L-904, C/L-912 -
D/L-901 D/L-911 D/L-904 D/L-912 .., .i., .:,.--
A/P-902, A/P-913 A/P-905, A/P-914 ,. - -
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B/P-902, B/P-913 B/P-905, B/P-914 4
C/P-902, C/P-913 D/P-902, D/P-913 C/P-905, C/P-914 D/P-905, D/P 914
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L-903X, L-903Y L-906X, L-906Y l r
P-907 P-908 ') ,
Fire Area 30 116 5 2 5 REY. J 9/88 ;,
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a, A FORT CAIR0t!N STATION b FIRE RA7 Ann ANALYSIS 1
I I) Reactor Coolant System t
- Hot and Cold leg temperature instrumentation i
J) Neutron Flux Monitoring System l
- Vide-range excore neutron flux detectors l K) Charging System 1
- Isolation valves HCV-238, HCV-239, HCV-247, and BCV-248. I
, There are four safety related divisions of cables in the containment. Much of the cabling is enclosed in conduit. (See the Safe Shutdovn Analysis for Additional Detail on cabling.)
Combuetible Haterial Quantity Combustible Load
! Basement Level - Steam Generator Cell A I None (lube oil drain tank is normally empty) k Basement tevel - Steam cenerator Cell B
- ' None (lube oil drain tank is normally empty) t Ground Level
' 620 gal.
Lubricant 6592 btu /ft2 Operating Level Lubricant 56 gal. 595 btu /f t2 Transient materials are provided during cutages only when the plant is in a
. safe cold shutdovn condition.
Total cable insulation in Fire Area 30 is 19,500 lbs. This yields a combustible loading for cable insulation of 16,049 btu /f t2 ,
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Fire Detection The fire detection system in containment includes thirty-three ionization type detectors located as follows: .
I a) Thirteen (13) high voltage pyrotronics detectors are located on the bottom [
face of the beam at floor elevation 1013'-O". The detectors are located in the immediate area of concentrations of combustibles, betveen the combus- ,
tibles (i.e. cable trays) and the grating. Any fire generated vould be f c detected, since the detectors are in the path of the fire ple:e. ,
k Fire Area 30
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l ) FORT CALB005 STAIION FIRE Pay. Ann ANALYSIS I
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(b) Thirteen (13) detectors are*In located addition, on the threebettom face of the (3) detectors artbeam locatedat '
floor clevation 1045'-0".
belov a partial landing at elevation 1060'-0". All the detectors are located in the immediate area of the concentrations of combustibles ,
providing adequete coverage.
in the (c) One (1) flame detector and one (1) ionization detector are located
' cavity above each main coolant pump on the intermediate level for coverage against a lube oil fire which is the major fire loading in this area. .
(d) Eight (8) duct detectors are located throughout the containment EVAC
, system.
l All detectors provide alarm and annunciation locally via eight alarm lights as ,l l
vell as in the control room.
J Fire Suporession i
A vater spray system using the borated containment spray vater supply is Extinguishers are located
! available inside the HVAC charcoal There are no filter units.hose manual stations in this area, throughout containment.
Ij I however, in the event hose is called for it could be brought in through the containment airlock from Fire Area 20.
I Ef fect of Desf ar-Basis Fire on Safe Shutdovn I Safe plant shutdown is assured during a fire in containment (Fire Area 30) by satisfying the requirements of Appendix R or NRC approved exemption requests for equivaleat protection.
4 Vhere two redundate trains of cable are routed within 20 feet of each other, or
' vhere redundant components are located less than 20 feet apart, radiant energy shields have been erected between the two trains. Vhere shielding methods vere impractical, an exemption from the NRC vith respect to 10 CFR 50 Appendix R, I Section III.G. reqtairements vas requerted. The areas of noncompliance where
, exemptions vere requested include
~
redundant (a) Directly beneath the pressurizcr vessel at elevationThis 1014' vhere area is completely trains of pressurizer heater cables converge.
inside the pressurizer bay where the only combustibles are :hese cables, the insulation of which is qualified to a test comparable to IEEE-383. Due l
to the intermixing of the redundant cables as they lead to the individual pressur'lzer h'eatet i, no possible physical ceans exist to provide addition-al physical separa ion or protection.
i 4
Fire Area 30 118 i
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(O'j FORT CALBOUN STATION FIRE RA7ARD AltaTSIS (b) Other cases vhere there exists at least 20 feet of separation between ! J redundant cables, but some intervening combustibles may be present (typi- F
, cally IEEE-383 qualified cable.)
The exemption was granted by the NRC on July 3, 1985.
Due to the large volume in the containment (which is divided into 'three floors with several cell-like compartments) it is more informative to examine the consequences of a fire on each of the three floor levels.
Postulated Fire At (Basement level) The lubrication oil for one of the i
primary coolant pumps is assumed to ignite as a result of a leak in the lubrication system. The location is on the basement elevation within the concrete cell that encloses tvo primary coolant pumps and a steam geneator.
Either the flame or the ionization detectors vould give an alarm to the control r:om if the postulated fire occurs. The brigade vould then be dispatched to effect manual fire suppression.
j Early varning could allov the operator time to accomplish an orderly reactor p shutdovn and to trip off that pumps lubrication system which may serve to r i eliminate the source of the burning oil. The insulation on the pricary coolant V boundary vould protect it from the maxiram fire severity that could be expected i in this concrete cell. The massive structural hangers of the primary coolant system vould not be affected by a fire of this severity.
The four reactor coolant pump motors (less than 115 gallons each) have been provided with an oil collection system designed to contain a lube oil leak and drain the leaked oil to a safe location. 011 leaks from the lif t pump, (including inlet and outlet lines), oil cooler housing (including drains. Anlet and outlet lines), gages (drain, fill. and level), oil cooler tube, and motor shaf t oil dam are collected by the system. The system consists of sealed metal pans and covers with drains to a ISO-gallon collection tank in the basement for each pair of pumps.
The postulated oil fire could not propagate to any of the cable trays on the basement levela The instrumentation cables attached to the primary coolant pipes near the pump are enclosed in conduit. Damage to these cables vould not prevent safe shutdovn.
Postulated Fire B: (Ground level) A cable tray fire is assueed to occur in a cable tray at section 20e on the ground level. This location is selected because of the large number of cable trays at this location.
T k Fire Area 30 -
119 REV. 1 0 N88 -
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FORI CALB011N STATION k
FIRE HA7ARD ANALYSIS All cable runs in the containment meet the separation criteria except where an i 1 exemption from 10 CFR 50 Appendix R Section III. G. has been granted or radiant I energy shields installed. Since the only significant combustibles on this !
level are the cables a' fire vas postulated at a high density region of cable g trays along the eastern perimeter of the containment structure. Assuming total
- involvement of the six cable trays (tvo of which are separated by 3 feet from j the other four), the maximum consequences vould be the loss of several safety related division D cables. This vould not prevent safe shutdovn since redun-I dant divisions A,B and C are available.
i i Fostulated Fire C: (operating level) A fire is postulated in the central rack of filters (one half of the total) locatd it. containment ventilation equipment VA 6A and VA-6B.
The primary source of combustibles on the operating level are the charcoal filters. The postulated fire may spread from the initial location to a maximum of one-half of the total filters. The filter fire in itself vould cause no damage to safety related equipment, other' than the ventilation system. A charcoal fire is relatively isolate:i by the structure of the filter assembly.
There are dampers, mist extractors, and absolute filters in front of the charcoal filters. Af ter the filters there is a lenl; section of ventilation ducting leading to the ventilation fans. These. tc.tures can be expected to l I contain the charcoal fire in the filter assembly.
No safety related cable trays are at this elevation. This postulated fire vould not prevent safe shutdovn, nor cause radio activity release outside the containment.
Fire Suppression Effects No automatic fire suppression systems are installed in Fire Area 30. Failure or inadvertent operation of a vater system or use of manual hose vould re-present a potential source of chlorides and other impurities which could initiate or promote corrosive attack of the reactor coolant system pressure boundary. Aside from these factors, release of vater in Fire Area 30 vould have no effects vorse than the design-basis fire.
As previously discussed, the RCP's have installed oil leak collection systems.
Any vater released in this fire area vould flov to a pump in the lovest level of containment, from which it could be pumped out as conditions allov.
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I I PORT CAIROUlf STATION FIng n m an ANALYSIS
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i Aeolicable References SER Section 5.20 Safe Shutdown Cable Separation Analysis (Rev. 0 - September 28,1978) .
OPPD Reactor Coolant Pump Lube 011. Collection Preliminary Design (June 6,1979)
Fort Calhoun Fire Protection Reviev, telecopied from the NRC to OPPD on April I 16, 1980. to I
NKC Amendment No. 53 to Facility Operating Li. nse No. DPR-40 (Supplement SER) -
Letter from NRC to OPPD granting exemptions poly 3,1985) !
Safety Evaluation by the NRC related to Appendix R Hodifications (July 1,1986)
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UNITED STATES g NUCLEAR h 'GULATORY COMMISSION af'
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%p4p December 10,1988 smcmiviin/ o i Docket No. 50-285
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- ) Mr. Kenneth J. Morris Division Hanager - Nuclear Operations
! ! Omaha Public Power District i i 1623 Harney Street Omaha, Nebraska 68102 l I
Dear Mr. Morris:
)
SUBJECT:
FORT.CALHOUN STATION, UNIT 1 - EXEMPTION FROM THE REQUIREMENTS
! j OFAPPENDIXRTO10CFRPART50(SECTION111.0)
L t l -j The Commission has issued the enclosed exemption from the fire protection
- requirements of Appendix R,Section II,I.0, to 10 CFR Part 50 for the Fort
' Calhoun Station, Unit 1. This section requires that the reactor coolant pump 9-l{ } (RCP) oil collection system be capable of collecting lube oil from all i pressurized and unpressurized leakage sites in the RCP lube oil system and i ,
that the leakage shall be collected in a vented enclosed container capable of j ! holding the entire lube oil system inventory. ,
l kt By letter dated November 28, 1988, Omaha Public Power District (OPPD) requested approval of an exemption from the technical requirements of Section 111.0 of
) Appendix R to 10 CFR Part 50 in that the installed lube oil holdup tank capacity i : is 150 gallons, based on a maximum expected leak from a single failure, rather l l than a two pump inventory of 280 gallons.
Based on the staff's review and evaluation of the request, the Comission has
} 1evel of safety to that achieved by compliance with Appendix R. Therefore, i the exemption request as described in the enclosed Exemption has been granted.
7 Our Safety Evaluation is also enclosed.
! i i 1 i
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- 3 [ WCJ, M0G, JS, RCD, RLA, JM, LLZ, KET,KJM, KCH, RGE, CFS, SARC,RCK,RDP, HMT, JJF, PRB,JMW, JGK, RRL, JBK, FCS BRH, RB, DJM, FI 12/30/88
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Hr. Kenneth J. Morris .
- ' A copy of the " Environmental Assessment and Finding of No Significant Impact" i'
- was sent Federal to youonby Register letter dated December 20,1988 Decentber (53 FR51174 13,1988,)and published in the .,
I-I The Exemption is being filed with the Office of the Federal Register for !,
- publication. I'
- a. Sincerely, j'
&. 6dm
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[Project Jose A. Calvo Director Directorate IV ;
Division of Reactor Projects - III, IV, V and Special Projects 1 Office of Nuclear Reactor Regulation
- l
Enclosure:
j ] As stated '
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cc w/ enclosure:
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See next page
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I I Hr. Kenneth J. Horris Fort Calhoun Station i
I Omaha Public Power District Unit No. 1
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i 4 Harry H. Yofgt Esq.
l dJ LeBoeuf Lamb, Leiby & MacRae i
[ f 1333 New Hampshire Avenue, NW Washington, D.C. 20036
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1 a ' Mr. Jack Jensen, Chairman j , Washington County Board of Supervisors
} Blair, Nebraska 68008
)'
! 'i. Mr. Phillip Harrell, Resident Inspector l1 '
3 U.S. Nuclear Regulatory Comission j P. O. Box 309 j f Fort Calhoun, Nebraska 68023 i 4 i
l Mr. Charles B. Brinkman, Hanager
+
- Washington Nuclear Operations C-E Power Systems 7910 Woodmont Avenue j ; Bethesda, Maryland. 20814 .
I i
j Regional Administrator, Region IV
)
! U.S. Nuclear Regulatory Comission Office of Executive Director for Operations i : 611 Ryan Plaza Drive Suite 1000 l : Arlington, Texas 76011 l i i .
' Harold Borchert Director i Division of Radiological Health Department of Health 301 Centennial Hall, South P.O. Box 95007 Lincoln, Nebraska 68509
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j W. G. Gates, Manager Fort Calhoun Station j P. C. Box 399- ~
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., Fort Calhoun, Nebraska 68023 u.
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- NUCLEAR REGULATORY COMMISSION In the Matter of Omaha Public Power District Docket No. 50-285 (Fort Calhoun Station, Unit 1) i
(
EXEMPTION I.
Omaha Public Power District (OPPD or the licensee) is the holder of Facility Operating License No. DPR-40 which authorizes the operation of Fort Calhoun Station, Unit 1 (the facility), at a steady state power level not in excess of 1500 megawatts thermal. The license provides, among other things, I I that the facility is subject to all rules, regulations, and orders of the Nuclear Regulatory Comission (the Comission or the staff) now or hereafter in effect. The frcility is a pressurized water reactor (PWR) located at the f
. licensee's site in Washington County, Nebraska.
1 II.
)
10 CFR 50.48, " Fire Protection", and Appendix R to 10 CFR Part 50, j " Fire Protection Program for Nuclear Facilities Operating Prior to January 1,
- i. 1979" set forth certain fire protection features required to satisfy the i General Design Criterion related to fire protection (Criterion 3. Appendix A 1
to 10 CFR Part 50).
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? Section III.0 of Appendix R requires that facilities have a reactor i
l coolant pump oil collection system if the containment is not inerted during I
normal operation. This system must be designed, engineered, and installed so that failure during normal or design basis accident conditions will not lead to fire, and that there is reasonable assurance that the system will withstand 2
j a Safe Shutdown Earthquake. Additionally, the system must drain to a vented J
j closed container that can hold the entire lube oil system inventory,
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III.
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By letter dated November 28,1988, the licensee requested approval of an j exemption from Appendix R Section III.0 to the extent that it requires the 1
, installation of a reactor coolant pump (RCP) oil collection system sized to 1
I acconinodate the entire lube oil system inventory.
1 Exemption Reouested The licensee requested an exemption from the specific requirements of
! Section III.0 that would require the reactor coolant pump oil collection
] system drain tank capacity to be capable of containing the entire reactor i '
1
] coolant pump lube oil inventory. l 3 The licensee stated in a letter dated November 28, 1988 that the reactor 3
coolant pump oil collection system capacity was designed such that oil leaks )
h from the RCP b ft pumps, oil coolers, fianged or gasketed oil connections, oil 4
sight glasses, drain and fill connection points, and oil reservoir points
?
j would be contained. The system consists of sealed pans and covers enclosing the F
pressurized oil containing portions of each RCP and drain piping routed to one y'1 of two ISO gallon collection tanks. One tank is associated with each pair of W
i RCPs. The collection tank capacity was based on a maximum expected leak of 110 gallons for any single failure as opposed to'a two pu4 inventory of 280 gallons for each tank.
II
>1 IV.
. Accordingly, the Comission has determined that, pursuant to 10 CFR 50.12, 3 this Exemption is authorized by law, will not present an undue risk to the l, public health and safety, and is cor.sistent with the comon defense and security. The Comission has further determined that special circumstances, as set forth in 10 CFR 50.12(a)(2)(ii), are present justifying the Exemption, namely that the application of the regulation in the particular circumstances t
,.l ) is not necessary to achieve the underlying purpose of the rule. In general, l' the underlying purpose of the rule is to accomplish safe shutdown in the event
- of a single fire and maintain the plant in a safe condition. Under a worst case scenario, reactor coolant pump lube oil would overflow from the collection J.
$ tanks, due to the limited storage capacity, and will be channeled to the floor
'i drains. Since no ignition sources are present in the area, no fire is likely lE
'9 to occur. Therefore, the limited lube oil collection system capacity does not 5
'j pose a significant hazard to safe shutdown systems. Further, the Fort Calhoun Station Fire Hazards Analysis has evaluated the effect of a lube oil fire in V
g the reactor coolant pump cavities and has shown that sufficient undamaged lf equipment would remain available to support safe shutdown.
!h
- N Accordingly, the Comission hereby grants the exemption from the 1@
requirements of 10 CFR 50, Appendix R, as described in Section III above.
1 1
Pursuant to 10 CFR 51.32, the Comiscion has determined that the granting 4 of this Exemption will have no significant impact on the environment
.hl i (53 FR 51174 Q
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l ; The Safety Evaluation concurrently issued and related to this action and l .f the above referenced submittals by the licensee are available for public
! l, inspection at the Commission's Public Document Room, 2120 L Street, H.W.,
i-; Washington, D.C., and at the local public document room located at the W.
1 V Dale Clark Library. 215 South 15th Street, Omaha, Nebraska 68102.
lf j .i j j: This Exemption is effective upon issuance.
i .
i :j FOR THE NUCLEAR REGULATORY COMMISSION
! t N M
- e Gary H. Holahan, Acting Director p Division of Reactor Projects - III, i y IV, V and Special Projecte
! Office of Nuclear Reactor Regulation
!l I 4 y Dated at Rockville, Maryland 5 this 20th day of December,1988
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UNITED STATES.
f, , [ g NUCLEAR REGULATORY COMMISSION WASHINGTON,0.C.20555 3 l
\.....l SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION EVALUATION OF FIRE PROTECTION EXEHPTION RE0 DEST FACILITY OPERATING LICENSE NO. DPR-40 OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION, UNIT 1 DOCKET NO. 50-285
)
1.0 INTRODUCTION
By letter dated November 28, 1988, the licensee requested approval of an exemption from the technical requirements of Section III.O. of Appendix R to
~1 10 CFR Part 50 to the extent that it requires the installation of a reactor coolant pump (RCP) oil collection system sized to accommodate the entire lube cil system inventory.
q 2.0 DISCUSSION i Each of the four reactor coolant pumps at Fort Calhoun Station contain 140 gallons of lube oil. The lube oil collection system is designed to contain
- i i
.N oil leaks from the lift pumps, oil coolers, flanged or gasketed oil
- 6 connections, oil level sight glasses, drain and fill connection points, and d, oil reservoirs. The system consists of three sealed pans and covers that lj enclose the pressurized oil containing components of each reactor coolant pump with a two inch drain line routed to one of the two 150 gallon collection tanks, one for each pair of reactor coolant pumps. The collection tank M
E y capacity is bbsed on a maximum expected leak of 110 gallons for any single fj failure as opposed to a total system inventory of 280 gallons for each tank.
P Each horizontally positioned tank is equipped with an overflow drain located d at the top of the tank which drains to the floor. The tanks are located h between and b~elow the reactor coolant pump cavities at basement elevation F
il 994 ft. approximately 23 f t, below the collection pans. Assuming a simultaneous failure of all four lubricating oil systems, the entire inventory
~
9 of oil is assumed to be discharged to the collection system. This would h
g result in a maximum of 130 gallens of lobe oil overflowing onto the 4
M containment basement floor at each tank location from the overflow drains and M into the nearest 4 inch floor drain. The basement floor in the area of each
< E tank is sloped to the nearest floor drain, which is within 12 feet of the collection tank for reactor coolant pumps RC-3C and RC-3D, and within 4 feet of the collection tank for pumps RC-3A and RC-38. In each area oil would 4
temporarily pool and would be contained by the floor drain.
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- . The licensee conducted a walkdown of the area to determine if any potential l
. ignition sources are located in the vicinity of the tanks and floor drains. ,
Based on the results of this walkdown, no potential ignition sources were l identified at or below the level of the tank.
i L The licensee justified the exemption on the basis of the design of the existing lube oil system and the absence of sources of ignition in the area where potential lube oil overflow would occur.
3.0 EVALUATION
, The technical requirements of Section III.0 of Appendix R to 10 CFR Part 50 are ;
i . not met because the existing oil collection system is not designed to hold the j lube oil inventory from all four of the reactor coolant pumps.
1 i The staff initially had several concerns with the existing system. The first
- was that during a seismic event, the lube oil collection system might lose its i
integrity, resulting in oil leaking onto hot surfaces and causing a fire. The licensee, however, affirmed in the November 28, 1988 letter that the system ,
i was designed to survive a safe shutdown earthquake (SSE) with its leak integrity 1 intact.
The staff was also concerned that all unpressurized leakage points were not encompassed by the oil collection system. The licensee indicated that oil ipin p(RCP)g that is unpressu:ized is either internal to the reactor coolant pumpm anticipated during a seismic event.
The staff was also concerned that there may be hot surfaces or other potential sources of ignition in proximity to where lube oil overflow would likely occur. The licensee affirmed that on the basis of a walkdown of the system, no such ignition sources exist in the vicinity of the tanks and four drains.
Under the worse-case scenario, lube oil will drain into the two holding tanks. Because of the limited storage capacity, the oil will overflow onto the floor and will be channeled to the floor drains. Since no ignition sources are present in the area, no fire is likely to occur. The staff, therefore, agrees with the licensee's analysis that the pumps do not pose a !
significant fiazard to safe shutdown systems. -
4.0 CONCLUSION
I Based on the above evaluation, the staff concludes that the existing RCP lube oil collection system provides an equivalent level of safety to that achieved l by compliance with the requirement of Section III.0 of Appendix R to 10 CFR Part 50. Therefore, the licensee's request for exemption should be granted. l l
\
Dated: December 20, 1988 D. Kubicki 1PrincipleContributor:
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10CFR50, APPENDIX R, SECTION III.O I WHITE PAPER REVIEW Ttx August 9,1996 l (Revision 1,2/6/97) !
Issue _ Statement j While performing a fire protection interaction review for MR-95-022, RCP Motor Replacement,
! existing FP license basis documents were examined for impact. SER (LIC88-0457, dated l 12/20/88) regarding an exemption to 10CFR50, Appendix R, Section III.O (RCP Lube Oil l Collection) appears to contain an error. An excerpt from section 3.0 of the Safety Evaluation reads:
"The licensee indicated that oil piping that is unpressurized is either iaternal to the reactor l'
, coolant pump (RCP) motor bearing assembly or qualified to withstand the clevated i pressures anticipated during a seismic event."
This appears to be a read back combination of OPPD responses to Staff concerns regarding the ;
exemption request. The purpcse of this document is to determine the current status of RCP Lube !
Oil design basis and any impacts due to MR-95-022. l Scope Thi.e document will be limited to the following: l
! e investigate and summarize the original RCP Lube Oil Collection configuration e summarize the current design basis on the existing RCP's i l
e evaluate MR-95-022 impacts to the existing configuration / exemption basis e recommend a course of action regarding 10CFR50, Appendix R section III.O
-existing design basis
-MR-95-022 impacts Actions Taken Reference Documents Reviewed:
- 1) 10CFR50, Appendix R, Section III.O
- 2) Original FP Program Submittal, LIC-76-0180, dated 12/31/76
- 3) Original Program SER, LIC-78-0104, dated 8/23/78
- 4) Design Package Submittal, LIC-79-0059, dated 6/6/79
- 5) NRC Triennial Inspection Report, LIC-88-880, dated 9/23/88
- 6) OPPD Exemption Request, LIC-88-1066, dated 11/28/88
- 7) NRC Exemption to Appendix R,III.0, LIC88-457, dated 12/20/88
- 8) MR-95-022," Reactor Coolant Pump Motor Replacement" O ,
I l
Discussion RCP motor lube oil collection requirements date back at least to the NRC's Fire Protection
(~' Guidelines of Appendix A to APCSB 9.5-1 (1976). OPPD's original FP program submittal l l\ (12/31/76) acknowledges RCP lube oil as a ' major combustible'. The submittal goes on to '
evaluate a 15 minute fire bum in Containment resulting from the combustion of the total inventory of lube oil from one RCP (150 gal.). The evaluation concludes that a bum of this l, magnitude would notjeopardize safe shutdown. This evaluation is referenced by OPPD as meeting the Appendix A, ' Control of Combustibles' mandate {per section D.2(a)].
)
! The SER granted to OPPD in regard to the 1976 submittal, dated 8/23/78, lists the RCP Lube Oil l Collection System as an ' Incomplete Item'. The SER went on to document that OPPD committed to respond to the issue by June 1979. It is assumed that correspondence between OPPD and the NRC took place between the 1976 submittal and the 1978 SER. Documentation ,
of this communication has not been retrieved. '
l OPPD submitted a Final Design Package of MR-78-057, "RC Pump Lube Oil Collection" to the l NRC 6/6/79 (LIC-79-0059). The key passage in this submittal is as follows: l "The lower oil reservoir is not being collected since it contains only four (4) gallons, has an internal oil cooler and there are no pressurized lines, sight glasses, etc. Also, the oil level transmitter is not contained since the transmitter housing has a pressure rating of 500 psig and it is only exposed to 17 inches of oil."
l The cover letter to this submittal indicates the NRC was to review and approve the modification (3 prior to installation. The NRC documented acceptance of this configuration in Amendment # 53 V to the FCS license dated 11/17/80.
I The RCP Lube Oil Collection System was again reviewed by the NRC in 1988 during a triennial FP inspection. The results of this inspection (LIC-88-880) once again listed the oil collection system as an " unresolved item". The following excerpt was taken from Section 4. of the report:
"Since the oil collection system, including collection pans, drain lines, and collection tanks has enough capacity to hold all of the oil from the pumps, there appears to not be a safety concem. However, the present system does not comply with Section III.O of Appendix R and an exemption is required."
OPPD filed an exemption request with the NRC 11/28/88 (LIC-88-1066). Attachment 2 to the exemption request responded to three questions raised during a phone conversation held 11/25/88. The third question / answer is as follows:
"OPPD states that the system v/ill contain oil from pressurized points. What about unpressurized points? I l Answer The oil piping that is unpressurized is either internal to the motor bearing assembly a af 1 i such a high pressure rating that oil leakage is not considered a credible event. The total O volume of the unpressurized oil system in the lower bearing assembly is only four gallons V per pump. The entire upper bearing assembly is provided with collection capacity with the exception of the level transmitters which are rated at 500 psig."
l 2
i I
It should be noted that question # 2 regarded seismic design capability of the collection system.
The responding NRC exemption SER contained the read back error as discussed in the L introduction of this document.
Evaluation Key Points
~
e RCP Oil Collection System installed per MR-78-057 was reviewed and approved by the NRC l e NRC Appendix R audit report categorized the FCS RCP oil collection system configuration deviations as 'not safety significant' e The new pump has a larger lower bearing lube oil reservoir (11 gallons vs 4 gallons). .
The new pump contains less lube oil (total) than existing pumps.
e The new pump configuration has a sight glass on the lower motor bearing reservoir.
Conclusions
- 2) The new pump motor lube oil system differs in capacity and fittings (sight glass) from the current exempted configuration.
Recommendations e removal of the new motor lower bearing sight glass if possible to more closely emulate
(^
\
the existing pump configuration and verify fill / drain piping and level transmitter as equivalent Currently, OPPD is not planning on removing the sight glasses.
e perfonn FP evaluation regarding the remaining configuration differences as ;
" insignificant" 1
l The fire protection evaluation for the remaining configuration differences are addressed in Attachment 9, Section 3 " Fire Protection Evaluation" of LIC-97-015, Letter to NRC from OPPD (S. K. Gambhir) dated February 7, 1997.
The evaluation shows that the tube oil capacity of the new RCP-3B pump motor will not place OPPD outside the bounds ofpreviousfire hazard analysis. ,
1 e conduct NRC notification of configuration change (including documentation as not fire safety significant) and request clarification / update of the SER This information is documented in LIC-97-015, Letter to NRC from OPPD l (S. K. Gambhir) dated February 7,1997.
Ken Erdman Nuclear Design Engineer 3
.. . . _ = _ - - - _
l DATE: Daccabar 12, 1996 !
FROM: K. A. Erdman .
)
SUBJECT:
CID960584/01, " Reactor Coolant Pump Motor Repla'ement c '
l(
l Modification MRFC95-022"
REFERENCE:
- 1) OPPD Memo, Matthews to Van Sant, dated August 30, l l 1996 (LIM-96-0124) !
OPPD Memo, Van Sant to Tills, dated August 13,1996 i
2)
(PED-DEN-96-0383) j'
- 3) White Paper Review of 10CFR50, Appendix R, Sec.
IIIO, dated August 9, 1996 l
l ASSUMPTIONS: As stated throughout the document. l Task Description The stated task of the subject CID is as follows:
" Provide updated description, 50.59, and assessment.of RCP motor replacement and fire protection aspects regarding MR95-022 for NRC."
Resolution of this task will be performed in the following activities:
)
Section 1 Establish RCP Lube Oil Collection Design / License Basis Section 2 Document MR95-022 FP Related Configuration Changes Section 3 Fire Protection Evaluation of MR95-022 Activities Section 4 Document FP Impact Acceptability per 10CFR50.59 Section 5 Document Revisions for NRC/FP Program l l
SECTION 1 Establish RCP Motor Lube Oil Collection System l Design / License Basis Reference Documents: !
l
- 1) 10CFR50, Appendix R, Section III.O !
- 2) OPPD Fire Protection Program Submittal, LIC !
0180, dated 12/31/76 i
- 3) Program SER, LIC-78-0104, dated 8/23/78
- 79-0059, dated 6/6/79 l 5) NRC Triennial Inspection Report, LIC-88-880, dated
! 9/23/88
( 6) OPPD Exemption Request, LIC-88-1066, dated 11/28/88
) 7) NRC Exemption to Appendix R, III.0, LIC88-457, l( dated 12/20/88 1
-- . - - - . - .. -. .. .. . . . _ _ - ~ . - . .. _ - - - -
- 8) USAR Section 9.11, " Fire Protection"
- 9) -MR-95-022, "RSactor Coolant Pump Motor Replacement" n.. .
Discussion 1
RCP motor lube oil collection requirements date back to the NRC's Fire Protection Guidelines of Appendix A to APCSB 9.5-1 (1976).
OPPD's original FP program submittal (12/31/76) acknowledges RCP '
lube oil as a ' major combustible' . The submittal goes on to j_ evaluate a 15 minute fire burn in Containment resulting from L combustion of the total lube oil inventory from one RCP motor (150 gallons was used for the appraisal). The evaluation concludes that a burn of this magnitude spread throughout a steam generator bay would not prevent safe shutdown of the Plant. This l evaluation is referenced by OPPD as meeting the Appendix A, L ' Control of Combustib.'.es' mandate (per section D.2 (a)) without a RCP motor lube oil collection system. l The SER granted to OPPD in regard to the above submittal, dated 8/23/78, lists the RCP Lube Oil Collection System as an j ' Incomplete Item' . The SER went on to document that OPPD l committed to respond to the issue by June 1979. It is assumed that additional correspondence between OPPD and the NRC took place between the 1976 submittal and the 1978 SER. Documentation ,
of this communication has not been retrieved. I l OPPD submitted a Final Design Package of MR-78-057, "RC Pump Lube Oil Collection" to the NRC 6/6/79 (LIC-79-0059) for review and i approval prior to construction. A key passage in this submittal L is as follows:
! "The lower oil reservoir is not being collected since it contains only four (4) gallons, has an internal oil cooler and there are no pressurized lines, sight glasses, etc.
Also, the oil level transmitter is-not contained since the transmitter housing has a pressure rating of 500 psig and it is only exposed to 17 inches of oil.". ;
i
! The modification package sdomittal documented design basis of the ,
lube oil. collection system. NRC staff documented acceptance of !
l the proposed configuration in Amendment #53 to the FCS Operating License dated 11/17/80.
l The RCP Lube Oil Collection System was again reviewed by the NRC !
in 1988 during a triennial FP inspection. The results of this inspection (LIC-88-880) once again listed the oil collection system as an ' unresolved item'. The following excerpt was taken l .
from Section 4. of the report: !
} l "Since the oil collection system, including collection pans, ;
i 2 ,
l i
l drain linoa, cnd collection tanks hcs enough capscity to hold all of ths oil from tha pumps, tharo cppears to not be l a safety concern. However, the present system does not j g- comply with Section III.O of Appendix R and an exemption is ;
(j required."
g, l
OPPD filed an exemption request with the NRC 11/28/88 (LIC 1066). The exemption request contained resolution to three questions asked by the NRC during a follow up phone call a'fter j the inspection. An SER was issued to OPPD granting the exemption i
to Appendix R-12/20/88.
Conclusions RCP Motor Lube Oil License Basis (Various Correspondence since 1978)
- RCP Oil Collection System installed per MR-79-057 was reviewed and approved by the NRC
- NRC Appendix R audit report categorized the FCS RCP oil collection system configuration deviations as 'not safety significant'
- Containment has been analyzed for a 150 gallon lube oil fire in the RCP/ Steam Generator Cavity and found not to impact SSD
[
RCP Lube Oil Design Basis (Per Submitted Modification Package FC78-057) e Pressurized components (upper) reservoir is totally enclosed in ' leak resistant' pans e 1000 PSI oil leak is evaluated for retention in collection system o Lower bearing reservoir does not require collection due to no credible leak points external to the motor e 110 gallons is the worst case single failure RCP motor lube oil failure Current Exemptions to 10CFR50, App. R III.0 as follows (OPPD submittal and subsequent Exemption SER):
- Capacity of drain tank is based on maximum single failure l (upper reservoir) leak rather than the full lube oil inventory of two RCP motors (two RCP's drain to each tank) i e Collection / Drain system is seismically mounted (per response i to questions in attachment 2 to exemption request) i e RCP Oil collection system on GE motors is equivalent to l Appendix R III.0 0
j 3
i CECTION 2 MR95-022, "RCP-3B Motor Rtplectmtnt", FP Ralated l Configuration Changes
(*3 The new reactor coolant pump, RC-3B, motor was installed during !
() the 1996 refueling outage. The motor, Squirrel Cage Motor QOVG 900 FA 6, was manufactured by ABB Industries in Switzerland 7 The l
new motor lube oil collection system is designed to be equivalent to the existing GE motor lube oil collection system. Design differences between the ABB and GE motors are outlined below.
Description ABB Motor - New GE Motor - Remarks Existing Upper lube The upper lube oil The upper lube oil The new motor lube oil cooler cooler is built cooler is located oil cooler design inside the motor outside the motor is superior in housing. housing. terms of reducing
References:
References:
the amount of HTAM125322, R D 791E610, R9 external piping that contains oil.
External piping is piping that is located outside the motor housing which could potentially leak oil. The reduction in external oil piping
- f. reduces potential s
[j N,
oil leak points.
superior.
Oil lift The new motor has The existing motor The new motor oil pump (s) for one oil lift pump has high and low lift pump is in
, upper lube for the guide and pressure oil lift operation only oil system thrust bearings, pumps. The low during the RC pump and anti-reverse pressure pump is startup and rotation device on when the motor shutdown.
(ARRD). The pump is running and Therefore, there is is turned on when supplies oil to no pressurized oil the motor speed is the ARRD. The piping when the 90% or less. At high pressure oil motor is running at full operating lift pump is full speed.
speed, the oil lift turned on when the Existing motor has pump is shutoff. motor speed is about 0.6 gpm The nominal pump 90% or less. The flowing to the ARRD flow rate is 2.55 combined flow rate when the motor is gpm. of both pump is running.
References:
1.3 gpm. superior.
Dwg.HTAM327980, R A
References:
Calc. FC06596, R 0 Dwg. Il5D7604, R1 O
V 4
4 l Dascription ABB Motor - Nr.w GE Motor - Remarks Existing ;
Upper lube oil level alarm and 011 level alarm Instruments may be ,
oil transmitter, flow and transmitter, different but both, instruments and pressure flow and pressure motors have the switches are switches are same level of .
provided. provided, alarm, transmitter, ,
References:
References:
and flow detection !
7 Dwg. Dwg. 115D7590, R7 capabilities. ;
- - HTAM242833, R F Vendor Manual '
- HTAM125322, R D TM F180.0570 !
4 HTAM125322L, RD .
I ,
, Upper lube The oil lift pump, The oil lift The new motor. upper ,
- oil piping, oil level pumps, piping, oil lube' oil system is
, collection indicator, level indicator, simpler in design ;
and drain fill / drain, and fill / drain, and' and has i system oil level oil level significantly less
- transmitter piping transmitter piping piping and joints .
ll external to the external to the that could motor are enclosed motor are enclosed potentially leak i
! in two collection in three outside the motor
- enclosures. The collection housing.
! oil collection enclosures and are The new motor upper
- enclosures are drained to lube oil ecliection connected to the retention tenks. system is designed
- q. existing oil drain The top enclosures to maintain-
- system. The side are not leak tight structural i* and upper panels but they are integrity during a-4 are not oil tight designed and design basis ;
- j. but they are constructed so earthquake, i i desigr.ed and that oil spray. each enclosure has .
i .
constructed to will be contained. a 1 3/4" diameter contain leaks from The enclosure drain tied to a 2"
- pressurized oil panels are made of existing lube oil lines and drain to 16 gauge (0.06" drain system.
i the oil collection thick) stainless The existing oil system. The oil steel panels and drain system is a level. indicator, are designed to closed system
- fill and drain, and maintain consisting of 4 oil level structural piping,-flexible 4 transmitter piping integrity during a hose and a vented I are only subject to design basis collection tank.
i the pressure head earthquake. Equivalent.
i of the oil level in
References:
the reservoir. The HR-FC-78-057 oil enclosure NUS Dwgs
- panels are made of file # Dwg.
i 2 mm thick or For RC-3A
- 0.079" stainless 001689 1928-M-037 i steel panels and 001690 1928-M-036 i are designed to 001691 1928-M-035 i maintain structural- 001694 1928-M-032 integrity during a 001695 1928-M-031 I
- design basis 001696 1928-M-030 l
- earthquake. 001699 1928-M-025 l
References:
001707 1928-M-015 l i Dwg:
1 HTAM242884,Shtl, RA '
j HTAM242884,Sht2, RA
. Calc. FC06606, R 1R E
5 ;
i, >
E
,w. ,,
w +c +- -w = .m -- g ,y-,y
i Description ABB Motor - New GE Motor - Remarks Existing
('~ ' Lower lube The lower bearing The lower bearing The new and
\ oil system lube oil reservoir oil reservoir has existing motor oil and has a fill / drain, the same basic cooler, oil piping instruments oil level components such as and instruments are indicator, vent, the fill / drain, basically the same.
, and oil level level indicator, The new motor oil transmitter and oil level level indicator has external to the transmitter. three 1" diameter motor housing. The The oil cooler is " Bulls Eye's" for ,
fill / drain and inside the motor oil level reading.
7evel indicator are housing and The " Bull's Eyes" j inter-connected and requires 4 gallons have no load can be considered a of oil. The oil bearing surfaces.
single unit. level indicator The new motor oil i The reservoir has a does not have level indicator 11.6 gallon " Bulls Eye's" as unit is capacity. Oil with the new conservatively piping and motor. The oil designed in terms instruments level is checked of construction and external to the by opening the mounting.
motor are not level indicator Based on the provided with an top cover. The design and collection / drain Foxboro oil level construction of the system based on the transmitter has a lower lube oil following; pressure rating of piping and 1.) oil piping is 500 psig. instrumentation, it ,
un-pressurized (no
References:
is concluded that !
f)
(_,/
pumps).
2.)The oil fill and Dwgs.
115D7590, Rev 7 probability of an oil leak is remote l
drain is made from 791E610, Rev 9 for both the new carbon steel bar and existing motor.
stock and has three Equivalent.
1" diameter glass
" Bulls Eye's" for oil level indication. Each
- Bulls Eye's" is rated at 256*F
@23 psi. The fill / drain and level indicator unit is attached to the motor housing by four 12 mm or 0.47" diameter bolts. 3.)The Rosemount oil level trans-mitter has a pressure limit of 2000 psig. 4.)The oil level indicator and transmitter are designed to main-tain structural
[\ integrity during a L_,) design basis earthquake.
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i 3 RCP Motor Lube. Oil System Statistic Comparison
?
- Lube Oil System ABB (NEW) GE (OLD)
I k
Lube Oil Type Mobil SHC-626 Mobil
, i l Capacity (GAL) 82.4 115 ,
- Upper Res. 70.8 111 Lowr;r Res. 11.6 4 r
- Operating Press.
Upper Res. 1500 PSI */2. 5GPM 950 PSI'/1. 3GPM !
.j
^
Oil Level Indicator r j ' Upper Res. Yes Yes -
.. Lower Res. Yes No ,
l !
4
- Rated Discharge Pressure of the Lift Pump i
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4 CECTION 3 Firo Protection Evaluntion 1
- l Assumptions-
- Original Evaluation ,
--~
! e " Maximum Expected Leak" = 110 gallons (Exemption Submittal
- LIC-8 8-1066) - Assume this is derived from the upper reservoir capacity of approximately 111 gallons
- e The 15 minute fire discussed in the 1976 program submittal.
is based on: '
- 1) 150' Gallon of Lubricant
{ 2) 155,000 BTU / Gallon combustible load for lubricant j 3) 80,000 BTU /FT2 loading equates to a 60 minute fire i
The combustible load and burn time factor listed'above
~
NOTE:
are from the combustible loading analysis, FC05814.
i' I. Verify original postulated fire site to establish estimated combustion time calculation parameter.
Given:. A 1 HR Fire involving 150 gallons of oil @ 155 kBTU/ Gal.
1 .
I
- Therefore the fire site would be limited by the following l
. expression: 1 Hr = [ 150 Gal X 155.000 BTU f PT) / Gal )= (X) Ft8 80,000 ~ BTU /Ft (Hr)
[)
! A 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> fire site would be approximately = 291 Ft 2 i
This implies a 15 minute burn site would be 4 X 290 = 1111 FT 2, This fire site corresponds to the steam generator bay floor area (ref. Drwg. S-18,19, and M-14) and is reasonable.
II. Check Impact of Lower Reservoir Contribution.
) Given: Using the above fire model, the lower reservoir (4
) gallons) burn time contribution is less than .4 minutes j =* TRIVIAL.
1 a
l III. MR95-022 Evaluation Maximum new motor (ABB) burn due to single failure (i.e. upper reservoir inventory only) :
1-l Burn Time (hr) =
[ 71 X 155,000 ) = .12 (Hr) = 7 minutes
- 1165 X 80,000
() Burn Time of lower reservoir (11.6 gallon) = 1.2 minutes 8
_...._.__.__._._.._._._._.__~______.-..._.__-m_m. . _ _ . . _
Burn tina es&4mmte of new motor is enveloM by existina motors.
O .
Comparative Fire Hazard of'the New Pump Motor
- The new RCP motor configuration is within the postulated design. basis fire burn time submitted and approved by.the NRC.-
e' . Baseline RCP Fire Hazard Analysis per'the original FP program submittal,(Ref. Fire Protection Program Submittal LIC-76-0180) is'still valid since the postulated fire-duration.of the new motor configuration isLless than originally _ evaluated.
The data used in original analysis is based on 150 gallon RCP lube oil inventory. ..The new pump is nominal 82.4' gallon.
Therefore the fire loading'is less than before .OK.
The. lube oil collection system is similar in design to the old-system as follows:
e ; collection system uses~ component enclosures which will-catch.
and drain pressurized-leaks e entirely encapsulate external, pressurized oil system components.
e the collection. system will survive DBD seismic events intact e -the system is drained to an existing retention tank remote from ignition sources j l
I The new RCP motor lower bearing lube oil reservoir is not' pressurized and therefore 'is not a credible leak path (sene. as ,
existing _ pumps). The new pump reservoir is larger than the !
existing pumps (11.6 gallon vs 4 gallon) . However, since the .
l l'ower reservoir does not present a viable leak path no~ additional !
fire hazard is considered.
Conclusions i
- 1) Existing = License Basis for SSD fire in Containment is not challenged by the modification. FCS Station maintains the ability to be. safely-shutdown in-the event of a design basis fire.
() 2) The new pump motor lube oil' system as evaluated in section 2 does not present an additional fire hazard.
9
i i'
s.
3 i -
- j. SECTION 4 10CFR50.59 SAFETY EVALUATION l t i i
- lf Fire.~ Protection Safe Shutdown is not-impacted by MR95-022, "RCP- j 3B Motor Replacement". 10CFR50.59 did not involve an unreviewed
[ safety question. ;
3 i 4-
, SEE ATTACHED FORMS ,
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- - . . ~ . - . . - _ - - . . - - _ _ , . - . - ,
J CECTION 5 FP Docum:nt Rtviews/ Updates Appendix R
~ I) e Er.amption SER -
SER (LIC88-0457, dated 12/20/88) regardinganexemptiob'to 10CFR50, Appendix R, Section III.O (RCP Lube Oil Collection) l appears to contain an error. An excerpt from section 3.0 of 1 the Safety Evaluation reads: l l
"The licensee indicated that oil piping that is !
unpressurized is either internal to the reactor coolant pump (RCP) motor bearing assembly or qualified to withstand the elevated pressures anticipated during a seismic event."
! This appears to be a read back combination of OPPD responses to l Staff concerns regarding the exemption request. This document should be resubmitted to update the NRC regarding the current status of RCP Lube Oil design basis due to MR-95-022.
e SSD Analysis EA89-055 - Appendix R III.O will be updated during the next revision to reflect the new configuration of RCP Lube Oil documentLtion post MR95-022. The lower
. combustible load in Fire Area 30 is trivial. Fire Area 30 {'
analysis update is not required.
(~)
\J rire Hazards Analysis e Combustible Loading Calculation FC05814 - no markup is necessary. The change in combustible load is trivial.
> e Compliance Matrix - update after receipt of new SER e Fire Area 30 Evaluation - update with discussion on new ABB pump and caneral reference to DBD-115 discussion.
Design Basis Document DBD-ll5 o General discussion of the modification and impact activities l post MR95-022.
USAR Section 9.11 e Update revision will be limited to listing the new SER when received, see section IV evaluation.
Fire protection Design Basis and Fire Protection Safe Shutdown are not degraded or placed in an unanalyzed configuration by 10195-022.
DEN-M recommends closure of this CID.
I 11
._ . . _ . . .. - - -- . - -. . - - - = . . -. .-
Ar-di. fC2 FCC CC i3TRU;'ny C45-022 W. O ;
FMT CALHOUN STATION FC-154 :
(] ERAL FORM NUCLEAR SAFETY EVALUATION R16 C/ SEE NOD-QP-3 FOR INSTRUCTIONS 9 .
SECTION A- Design Page i of 2g 10 CFR 50.59 Applicability Screening ATTACH OR REFERENCE OTHER DOCUMENTS AS NECESSARY.
i !
8.1 Activity identification
- Procedure Change No.
- affecting Procedure: '
Modification quest No.: 95-022 Design (X] installation [ ] Testing ( )
& FDCR. 9/,- o276 (Check each phase of Mod. being evaluated)
Temp Mod No.: ECN No.: Other:
Document
Title:
Reactor Coolant Pump Motor Replacement 8.2 What (specifically)is being done?
Existing GE Reactor Coolant Pump (RCP), RC-38, motor vdil be replaced with a motor manufactured by ABB Industries. i O I' l
8.3 Whyis this being done?
NOTE: PROVIDE AN ANSWER FOR EACH ITEM LISTED IN 8.2.
Tests performed by CHAR Services and GE indicated that RC-3B motor has the greatest potential for winding insulation failure and may cause significant plant downtime if the motor had to be replaced.
Q.>
e =
mo
x,,... ..J FOR CONSTRUCTION \!
MR-FC-95-022 REV. O FMT CALHOUN STATION FC 154
(~' NUCLEAR SAFETY EVALUATION b ERAL FORM SEE NOD-QP-3 FOR INSTRUCTIONS i R16 SECTION A- Design Page 2 of_2/
10 CFR 50.59 Applicability Screening ATTACH OR REFERENCE OTHER DOCUMENTS AS NECESSARY.
8.4 Does the activity involve a change to the Technical Specifications other than the Basis Sections?- [ ] YES EXIT .
If the Technical Specifications must be revised prior to performing this FC-154 j activity the answer is YES. Exit FC-154 and go to NOD-QP-7.
STOP l If the activity meets the requirements of current Technical GO TO l Specifications the answer is NO. NOD-QP-7 The following Technical Specification Sections / Figures are applicable: [X] NO 3.3, Table 3-6 GO TO 8.5 The flywheel inspection frequency, RC-3B motor only, per RG 1.14 does not need to be updated in Technical Specifications for this modification. The initial flywheelinspection will be completed prior to motor installation.
l
[)
t ,
8.5 Does the activity involve a change in the facility, procedures, tests, or [X) YES experiments as described in the USAR?
1 GO TO l If the activity is inconsistent with the USAR and the USAR must be 8.6 i revised, the answer is YES. '
SECTION B i If the activity is not described in the USAR, OR the activityis REQUIRED i consistent with or bounded by the USAR, and the USAR does not require a revision, the answeris NO.
The following USAR Sections / Figures are applicable:
4.3.5 Fig. 4.3-6,4.3-13, 4.3-14
[]NO 14.6.1 and 2 GO TO 14.24 8.6
.I L
a
i i s.... . . . . ..
ON3TRUCTK , MR-FC-95-022 REV. 0
) FnRT CALHOUN STATION .
' FC-154 NUCLEAR SAFETY EVALUATION R16 O IERAL FORM SEE NOD-QP-3 FOR INSTRUCTIONS 9 j
SECTION A- Design Page'5 ofSp[_
10 CFR 50.59 Applicability Screening ATTACH OR REFERENCE OTHER DOCUMENTS AS NECESSARY.
1 8.6 Does the activity conduct Tests or Experiments (STs, cps and Special
^
YES(l .
Procedures, etc.) not described in the USAR that could degrade the ;
margins of safety during normai operation or anticipated transients; or could degrade the adequacy of structures, systems or components (SSC) GO TO 8.7 to prevent accidents or mitigate accident conditions?
SECTION B ,
- if the activity could potentially degrade margins of ssfety or the REQUIRED adequacy of SSCs to prevent or mitigate accidents, the answer is YES. NO[X}
if the activity is not a test or experiment, OR the activity could not GO TO 8.7-degrade margins of safety or the adequacy of SSCs to prevent ur mitigate accidents, the answeris NO.
8.7 Could the activity adversely affect nuclear safety? YES [ ]
O- consiosa svsrem isrea^crions ^"o austiFv wav Taeae is NO DEGRADATION CF ANY MARGIN OF SAFETY.
Explain: The new motor will be of the same nominal dimensions, weight, and operational characteristics as the existing motor. The new motor will mount on the existing . GO TO 8.8 driver mount, and existing mechanical and electrical connections will be modified to
'3-fit the new motor. "The RN mbb. M An diC&dt. If PNtMe^k foe Rt. e.vi@v A.tp mehr, RC-3& . SECTION B Continued on Attachment. REQUIRED I
i N o [X] ;
GO TO 8.8
+ _ "-
w . . ,5 ~C .7 ."..' .G U C 7 ; u MR-FC-95-022 REV. O FORT CALHOUN STATION O GENERAL FORM FC-154 NUCLEAR SAFEW EVALUATION - Design O R16 SEE NOD-QP-3 FOR INSTRUCTIONS Page _.4 _ of 2 ATTACHMENT SHEET Section 8.7 continued.
The replacement motor basically has the same performance and features as the existing motor, Differences between the new and existing motor are discussed below.
Flywheel: The new motor flywheelis a single piece design made from forged ASTM A508 4/5 steel. The flywheells shrink fit to an intergig motor shaft sleeve and the sleeve is shrink fit to the journal of the motor. The flywheel meets the design %......cr.tc of Reg. Guide 1.14 R 1. Reactor Coolant Pump Flywheelintegrity. The lowest calculated critical fracture speed exceeds the calculated LOCA Overspeed,3697 rpm, of the motor. Based on design, material, manufacturing, and pre-operational test performed at the factory, a flywheel failure is not a credible event and a flywheel shroud is not required. RG 1.14 does not require a shroud if the flywheel design, material quality, and inspections are adequately considered. R.4. 1 t,t4 n. used a.s a omcbnce. Jamed 4hd sedu h necesM bcMccJ memed! to aswa. Proper hheet Mb Anti-Reverse Rotation Devir 3 (ARRD): The original ARRD is supplied by Formsprag and replacement by Ringspann.
The basic components of ARh0 such as sprags, inner and outer race are same. The new motor ARRD design does not require continuous oil supply and oil pump is stopped at approximately 90% of full speed. Oillift pump supplies both the ARRD and bearings. The ARRD is designed to withstand the locked rotor torque of the motor with 100 %
voltage applied in case of reverse phase rotation and the torque resulting from startup reverse flow.
V Compor ent Cooling Water (CCW): The combined CCW flow rate to both the upper and lower lube oil coolers and bypass piping is 39 gpm which is same as the existing motor. CCW piping / fitting attached to the motor is similar to existing motor. Minor piping changes and the use of 3" slip-on flanges over the weld neck flanges do not adversely ;
affect seismic qualificat%ns. The motor bearings are designed to continuously operate without cooling water for 3 to 5 j minutes.
l Oil Coolers: The new motor has the upper lube oil cooler built in to the motor and does not require a separate oil collection system. Current' motor has extemal oil cooler and an oil collection system was built to comply with 10CFR50 Appendix R, Section 111.0. The new motor lube oil pump, piping and instruments extemal to the motor will be provided
{
with oil co!!ection system similar to the existing motor. The new motor upper lube oil cooler oil capacity is approximately l 71 gallons and the existing motor upper lube oil cooler and piping oil capacity is approximately 140 gallons.
Both the new and existing motors have the lower lube oil cooler, unpressurized, internal to the motor. The existing oil cooler contains 4 gallons of oil and the new motor oil cooler has 12 gallons. Since the oil co^1er is internal to the motor, only the fill and drain piping and oillevelinstruments are sources of an oilleak. On current GE motor, the NRC has granted an exemption (LIC88-457,12-20-88) to 10CFR50 Appendix R, Section 111.0, I. e. having an oil collection system for external oil piping and oil level instruments that could potentially leak oil. The new motor lower lobe oil cooler external piping and instruments are similar to the existing motor. Therefore, consequences of an ollleak for the new motor and existing motor are basically the same. A written evaluation of ti:e new and existing lube oil system will be forwarded to the NRC.
In conclusion, both the new motor and existing motor are adequately designed to prevent fires due to oilleaks. See 3
[G. attached Section B *USQ Determination" for further discussion of system interaction analysis.
1-5
Arr ~ JD FC.7 CC G ; , ., MR-FC-95-022 REV. O PRT CALHOUN STATION FC-154 :
t NUCLEAR SAFETY EVALUATION R16
'd^ 4ERAL FORM SEE NOD-OP-3 FOR INSTRUCTIONS i SECTION A - Design 10 CFR 50.59 Applicability Screening Page 5' of g ATTACH OR REFERENCE OTHER DOCUMENTS AS NECESSARY.
8.8 10 CFR 50.59 Applicability Screening Conclusion IF ANY QUESTION (8.4-8.7)IS ANSWERED YES, THE ACTIVITY REQUIRES FURTHER !
EVALUTION. IF 8.4 (TECH SPEC CHANGE)IS ANSWERED YES FOLLOW NOD-QP-7. IF 8.5, 8.6, OR 8.7 IS ANSWERED YES, CONTINUE WITH FC-154 SECTION B. IF 8.4-8.7 ARE ALL ANSWERED NO, THE ACTIVITY is NOT A 10 CFR 50.59 ACTIVITY.
[] This activity is not a 10 CFR 50.59 activity.
[X] This activity requires further evaluation, FC-154 Section B is required.
We hereby certify that this Screening is complete and accurate to the best of our .
knowledge. I 3pr 91 as i ,
Preparer (Print Name): Erick Jun Extension: 6772 i Signature: fuld b Date: 9-19-96 Reviewer (Print Name): [Joh f,[ jays Extension: (28//f Signature: b hr. Date: Q -Jd- 96 mAh-o!%
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FORT CALHOUN STATION FC-154 !
/"4 3ENERAL FORM O NUCLEAR SAFETY EVALUATION SEE NOD-QP-3 FOR INSTRUCTIONS '?
R16 SECTION B - Design Unreviewed Safety Question Determination Pagelof 2d '
ATTACH OR REFERENCE OTHER DOCUMENTS AS NECESSARY. j 9.1.1 Identify Plant Specific Design, Operating and Technical Documents (Write NONE f none identified)
Document Title ID Number Revision Reactor Coolant Pumps USAR 4.3.5,14.6, Varies 14.24 Reactor Coolant PLDBD-RC-128, Att 15 Rev.1 Reactor Coolant Pump Operation Ol-RC-9 23 l l
See Attached page
{
9.1.2 Identify Applicable NRC Documents / industry Standards (Write NONE if none identified) l Title ID Number Revision Reactor Coolant Pump FlywheelIntegrity Reg. Guide 1.14 1 I Control of Heavy Loads NUREG 0612 1980 Seismic Qualification of Class 1E Equip for NPGS IEEE 344 1975 Oil Collection System for Reactor Coolant Pumps 10CFR50 App. R ,
111. 0 9.1.3 Identify Related Drawings (Write NONE if none identified)
I,i Title ID Number Revision GE Motor-Vertical Induction Motor Outline 531E500 11 l
ABB Motor-Outline HTAM125293 B See Modification Section 5.3 for additional dwg list .
9.2 List s'afety functions the affected structures or components perform:(V/ rite NONE if none identified)
The motor flywheel reduces the rate of flow decay upon loss of power (Ref. USAR 4.3.5,14.6.1,14.6.2).
The motor must tie designed to completely contain the largest conceivable missile in the event of a flywheel failure (w in4.3.5). ,
n List applicaLu accidents for which these safety functions are required:(Write NONE if
(), none identified)
Loss of Coolant Flow Event (Ref. USAR 14.6.1).
MFfi?&D FOR CONSTRUC7;._, MR-FC-95-022 REV. O FORT CALHOUN STATION FC-154 ,
- NUCLEAR SAFETY EVALUATION - Design R16
) 3ENERAL FORM SEE NOD-QP-3 FOR INSTRUCTIONS Page 7 of z,6 ;
l ATTACHMENT SHEET Section 9.1.1 Continued.
Docurnent Title ID Number Revision Heavy Loads PLDBD-CS-52, Sect 4 1 l
. Heavy Loads Review PED-gel-17 2 Reactor Coolant Pump Motor Removal EM-RR-RC-1003 0 l
Internal Missile & HELB PLDBD-ME-11, Sect 5.1 4
- Exemption From the Requirements of App. R LICB8-457,12-20-88 -
Seismic Qualification of Motor Structure HTAM622596 3 FE-Analysis of the Lift Load Path HTAM622628 0 i
.- Design Slings for Four Lifting Operations FC06576 A ;
- CAS-45/WDS-186 Support Qualification FC06586 A I
RC-3B Pump Snubbers' Plate Attachment FC06580 A See modification Section 5.1 for additional calculations. '
GE Vendor Manual (Exist. Motor) TM G080.2220 1
, ABB Squirrel Cage Motor Manua! OOVG900 FA6 -
RcP Mob Speofi d e cahd Iqn o loaf,.f )
A
&65 h;d N:. SA:LT W,'m4L DedlCdien t/c M6 Pif Mcder 1%5 fedi. No. SAIC-11&-p 2ew. o 4 A b V
4,
/
L________
/ l 3ENERAL FORM NUCLEAR SAFETY EVALUATION R16 I C/ SEE NOD-QP-3 FOR INSTRUC.TIONS 9 SECTION B - Design Page B of_2d Unreviewed Safety Question Determination ATTACH OR REFERENCE OTHER DOCUMENTS AS NECESSARY.
9.7, System Interactions Analyses Criteria Applicable Criteria Applicable Fire Protection X StructuralImpact X Electrical Equipment Separation Criteria Qualification
. High Energy Line Break Single Failure Criteria I Review Seismic interaction and X Possibility of Operator Error l Qualification Electrical Systems Analysis X Heavy Loads X Human Factors Review impact on HVAC l Security Review q)
(
System / Component Performance X
i Environment Radiological Natural Phenomena Release l Materials Compatibility X Missile Protection X Containment Integrity Control Room Habitability Other.
Discussion of Applicable Systems Interactions Analyses (include Attachment Sheet as needed, write NONE if none identified) .
Fire Protectiom The replacement motor oil collection system is designed to meet 10CFR50, Appendix R Section 111.0, except for the lower oil cooler piping and instruments external to the oil cooler. As with current motors, an exemption for the lower oil cooter extemal piping and instruments will be requested based on similarity of the two motors. The replacement motor requires less total oil, both the upper and lower oil reservoirs combined, than the existing motor. The o station Fire Hazards Analysis or fire detection or suppression systems are not affected.
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,s. . . ._ F03 CON 3TRUCTION MR-FC-95-022 REV. O i
a FORT CALHOUN STATION FC-154 O3ENERALFORM 4 V NUCLEAR SAFETY EVALUATION - Design R16 4 1 SEE NOD-QP-3 FOR INSTRUCTIONS Page 9 -
ofg
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ATTACHMENT SHEET Section 9.3 continued.
Selsmic Interaction and Qualification: Nominal weight of the existing motor and replacement is approximately 64,000 4
lbs. Overall size and shape is nearly the same for motors. The replacement motor has center of gravity at 66.9" from the bottom of the motor mount flange while the existing motor center of gravityis 72". Also, the replacement motoris designed to maintain structurat integrity under the normal eperating conditions concurrent with Design Basis Earthquake (ref. Calcs HTAM622596, Rev. 3). The replacement motor does not adversely impact the reactor coolant pump or the r: actor coolant system piping and support system.
ilanger WDH-317 provides dead load support for 4" diameter waste disposal piping in containment above the equipment hatch. Currently, WDH-317 prevents full opening of the equipment hatch. Adjacent to this supportis a seismic restraint WDS 186 which is more rigidly built and capable of taking additional pipe dead load currently provided by WDH-317 (ref. Calc. FC06586, Rev. A). Therefore, WDH-317 will be removed or abandoned in-place. ,
s l
The existing four horizontal snubber attachments do not fit on the new motor. New snubber attachments will be fabricated from A-36 steel plates with attachment accessories. Calculation FC06580 concluded that the snubber ratings are not affected by the changes.
Electrical Systems Analysis: The new motor will be powered by the same circuit breaker (Bus 1 A2, Breaker 5) and existing cables will be used to feed the new motor. The 480 V feeds and control circuitry for the oillift pump motor and l
the motor space headr will also be unaffected by this modifiution. The new motor has the same horsepower, voltage, end current rating as tre. existing motor.
The instruments for the new motor will be like the existing instrumentadon. The vibration monitoring system will be the 4
same equipment that is currently on the existing motor. Oil reservoir levelindication remains an analog signal to the ERF Computer, and alarms on low lube oil level.
i Materials Compatibility: The replacement motor has basically the same materials as the existing motor. The motor i housing is carbon steel, copper winding, and stainless steel on various motor sub-components such as the oil collection i system.
d Structural impact: The new and replacement motor weigh approximately 64,000 lbs. There is no adverse impact on the motor supporting structures.
Heavy Loads: The new and existing motor weigh approximately 64,000 lbs. The moter lifting lugs are designed such that two adjacentlugs 60 degrees apart are capable of lifting the motor. A safety factor of 5 was builtinto the motor lug 1
design (Calc. HTAM622628, Rev. 0). Calculation FC06576. Rev. A, evaluated the three motor lifting operations and has designed the slings with a minimum safety factor of 5. The motor lifting lugs and lifting devices are adequately designed. See Installation FC-154 for capacity of the lifting devices.
Continued on attached page.
J
,A 08%
r . . . . . D FCR CC.NSTFiUC*i.v.,
MR-FC-95-022 REV. O !
FORT CALHOUN STATION FC-154 i 3ENERAL FORM NUCLEAR SAFETY EVALUATION - Design R16 -
SEE NOD-QP-3 FOR INSTRUCTIONS Page i o of _ ed
, ATTACHMENT SHEET Section 9.3 continued.
l 4
System 1 Component Performance: The new motor performance is basically the same as the existing motor except the new motor fullload speed will be approximately 1193 rpm compared to 1191 rpm for the existing .m.otor. The nominal GE motor speed is 1185 rpm and the actual measured speed is approximately 1191 rpm. This will result in l
cpproximately 0.17% flow increasu in the pump. Increase in pump flow rate is considereJ inconsequential on fuel rod !
I fretting wear and failure and has no rneasurable impact on USAR Chapter 14 Safety Aialysis.
The new rnotor coast down time is same as the existing motor sinec both motors have 70,000 lbs-ft rotational energy. I 2
The 70,000 lbs-ft rotational energy is from the motor and rotational energy of the pump is not included. Therefore, the minimum DNBR of 1.18 will be rnaintained as described in USAR Chapter 14.6.1. Also, the probability of a seized rotor
. eventis not changed.
I
! The COE components of the motor are the flywheel, CCW piping, and oil cooters. Se rnodification section 3.2 for 1
quality class designations.
Misslie Protection: Current GE motors have a shroud around the flywheel to contain flywheel fragments in case of a flywheel failure. As previously stated in Section 8.7, the new motor flywheelis designed such that a flywheel failure is
'( not a credible event, ther efore, a shroud is not included.
l O l l
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,,. . . ._ . .:D FOR CONSTRUCTIOi, MR-FC-95-022 REV. 0 l FORT CALHOUN STATION
/^N3ENERAL FORM FC-154 NUCLEAR SAFETY EVALUATION R16 C) SEE NOD-QP-3 FOR INSTRUCTIONS T SECTION B - Design Unreviewed Safety Question Determination Page lf of M/
ATTACH OR REFERENCE OTHER DOCUMENTS AS NECESSARY.
i 9.4 Could the proposed activityincrease the probability of occurrence of an accident previously evaluated in the USAR? YES(] !
Explain: The new motor does not affect overall Reactor Coolant System (RCS) or pump NO(X]
performance. The new motor monitoring instrumentation is equivalent ta the existing motor. The motor design, material, fabrication, and construction standards meet the motor Contract 1977 and it will have equivalent or better reliability as compared to the existing motor. No increase in the probability of an RCP related USAR accidentis credited.
9.5 Could the proposed activityincrease the consequences of an accident previously evaluated in the USAR?
YES[]
Explain: Loss of power and seized rotor events evaluated in USAR 14.6 are not impacted by this modification. On loss of power, the motor flywheel, as with the original motor, reduces the rate of flow NO [X] '
decay as credited in the USAR. Consequences of a seized rotor or mechanical failure is not
,, increased since the new motor has mechanical and electrical controls that are equivalent to the I ;
original motor. Operational characteristics of the motor are not significantly changed.
LA I
I 9.6 Could the proposed activity increase the probability of occurrence of a YES(]
malfunction of equipment important to safety previously evaluated in the USAR?
Explain: The new motor does not adversely affect the Reactor Coolant Pump (RCP) or the RCS NO [X]
piping and supports. Both the new and existing motor weigh apptoximately 64,000 lbs. The new motor is designed to maintain structural integrity under the normal operational conditions concurrent with a safe shutdown earthquake. The motor flywheelis a forged single piece design which is shrink fit to the motorjoumal and a flywheel failure is not considered to be a credible event.
9.7 Could the proposed activityincrease the consequences of a malfunction of YES()
equipment important to safety previously evaluated in the USAR?
Explain: The new motor design, material, and construction are equivalent to the existing motor. A NO (X]
failure of the new motor does not increase the consequences of malfunctions of equipments important to safety since it is an equivalent substitute mechanically and electrically. A failure of the new motor does not create a new failure mechanism for equipment important to safety.
m u
q ._ /1
l x, r..JMD FOR CONSTRUCTiL:, MR-FC-95-022 REV, O'. !
FORT.CALHOUN STATION
)n 3ENERAL FORM _
NUCLEAR SAFETY EVALUATION FC+.4 R13 iV i
SEE NOD-QP-3 FOR INSTRUCTIONS T t
SECTION B - Design Page /2. of zg'
. Unreviewed Safety Question Determination '
i ATTACH OR REFERENCE OTHER DOCUMENTS AS NECESSARY. ;
I 9.8 Could the proposed activity create the possibility of an accident of a hfferent type than any previously evaluated in the USAR?
YES( }
t.
Explain: This modification does not change the RCS configuration other than replacing a RCP motor
- with an equivalent motor. No new accident scenarios are applicable since the new motor does not
)~
j NO [X ]
change the operational characteristics of the RCS or RCP. The possibility of a flywheel failure and i generating missiles in containment is not a credible event for the new motor. Therefore, a shroud I
around the flywheells not included in the motor design.
I i
! 9.9 - Could the proposed activity create the possibility of a malfunction of l YES [ ]
- equipment important to safety of a different type than any previously evaluated in the USAR?
ib
- V . Explain
- The new motor is an equivalent replacement for the existing motor. Mechanical and NO [X )
electrical controls are same for the new motor. The new motor does not create a new failure 5- mechanism for safety related equipment.
4
?
9.10 Does the proposed activity reduce the margin of safety as defined in the YES [ ]
basis for any Technical Specification?
Explain: Reactor Coolant System performance, operations, or Limiting Conditions for Operation as NO [X]
described in the Technical Specifications are not affected. Therefore, Technical Specification margins of safety are not affected by this modification.
O.,
1 -13 -- _
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.. MR-FC-95-022 REV. 0 i' FORT CALHOUN STATION FC-154
!~ 3ENERAL FORM . NUCLEAR SAFETY EVALUATION i
i O See nod.oe.3 FOR instructions SECTION B - Design Page la of Zd e
-R16 Unreviewed Safety Question Determination '
ATTACH OR REFERENCE OTHER DOCUMENTS AS NECESSARY.
IF ANY QUESTION (9.4 9.10)IS ANSWERED YES, THE ACTIVITY INVOLVES AN UNREVIEWED SAFETY QUESTION AND CAN NOT BE PERFORMED WITHOUT PRIOR NRC APPROVAL. DO NOT COMPLETE THIS PAGE. SEE NOD-QP-3 FOR INSTRUCTIONS.
9.11' Summarize USAR changes which are needed m attach marked-up copy of affected pages:
NOTE: ASSUMPTIONS, OPERATING OR ADMINISTRATIVE RESTRICTIONS REQUIRED TO JUSTlFY THAT THE ACTIVITY IS NOT AN UNREVIEWED SAFETY QUESTION MUST BE INCORPORATED INTO THE USAR.
new a:id4A Specific RCP motor flywheel design, fabrication, and testing information for the e96; moter will be re-eved
, b fremCSAR Section 4.3.5.c'c"; yd'" r!;. 4.3 * ??,13 :nd " r!r;t::! Sfer=S: for : n:;; nd cut:n; }
.r.eter .;": bc :n d;;;;. S 4205 and 912^*. The USA . 5;=: v "! bc v !!:b!: 2: OPPO drev'n;: but net -
'neded !a 'he U** See attached markups.
1 O 9.12 Report of 10 CFR 50.59 changes, tests and experiments.
Provide a brief description of the activity: This modification replaces GE Reactor Coolant Pump, RC-3B, mctor with a ABB motor. The new motor is basically the same as the existing motor except that it does not have a shroud around the flywheet This configuration is acceptable based on low probability of a flywheel failure due to the design, material, and fabrication controlsi The new motor complies with RG 1.14, Rev.1, Reactor Coolant Pump Flywheel integrity, and is an acceptable replacement Summarize the safety evaluation:
RCP motor replacement does not create unreviewed safety concerns and it is within the USAR Chapter 14 SafetyAnalysis.
OO 1-I$
APPROVED FOR CONSTRUC' MR-FC-95-022 REV. O CORT CALHOUN STATION 3ENERAL FORM FC-154 NUCLEAR SAFETY EVALUATION - Design R16 Nuclear Safety Evaluation Conclusion Page /4 of Ed l
IF ANY QUESTION (9.4-9.10)IS ANSWERED YES, THE ACTIVITY INVOLVES AN UNREVIEWED SAFETY QUESTION AND CANNOT BE PERFORMED WITHOUT PRIOR NRC APPROVAL.
l
[X] This activity is being done pursuant to 10 CFR 50.59. This activity MUST be approved by the PRC.
e This safety evaluation must be reviewed by SARC; ref Tech. Spec. 5.5.2.7.
This activity must be reported in the 10 CFR 50.59 report; ref 10 CFR 50.59, item b, Paragraph 2.
[] This activity involves an Unreviewed Safety Question. The activity must be canceled, or revised and re-evaluated, or NRC authorization is required prior to implementation; ref 10 CFR 50.59, item c.
, j I
We hereby certify that this Nuclear Safety Evaluation is complete and accurate to the best of our
- knowledge.
I n Preparer (Print Name): Erick Jun Extension: 6772 Signature: Q% Date: 9-19-96 Reviewer (Prin(Name):U M [,[ L , Extension: 6&/V Signature: k h bg Date: 9 70-94
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NUCLEAR OPERATIONS DIVISION NOD-QP-31 '
QUALITY PROCEDURE PAGE 21 OF 22 i
Attachment B - Operability Evaluation Form CR No. 199 C o o 1(,W Initiating Event: Dd lea & c1 N C-3 D P4Ar Date: il N[9 7 (Maint., $urveillance, etc.)
- 1. Affected item (SSC): Equipment Tag No. RC-3 D- M l
l
- 11. Describe the operabl//t/ concern associated with the affected item, including a discussion of '
the requirement or commitment established for the item and why the requirement or commitment may not be met:
'Ie e.
A $ a.cLeh i
l 111. Describe the intended safety funcilon(s) of the affected item (See Section 6.4.2):
. Sc A- Ac t A IV. List references used (See Section 6.4.3):
l S e e_ duke es
_ V. Based on a review of the intended safety function (s) of the affected item and the operability concern (See Section 6.3.2):
l
/The. item is OPERABLE, or The item is INOPERABLE (IMMEDIATELY NOTIFY THE SHl'FT SUPERVISOR)
...... OPTIONAL"""
Preliminary determination is as above. Further determination / evaluation must be made by the Production Engineering Division. EAR # has been issued.
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{0 1
NUCLEAR OPERATIONS DIVISION NOD-QP-31 QUALITY PROCEDURE PAGE 22 OF 22 Attachment B CR No. 9960 oI6W VI. Justification of Decision (See Section 6.4.4):
$e< A4 bel.d Vll. List any recommended corrective actions to correct the initial operability concem.
6 EE. C L Y l'i % O O I bd 4
- b hNu Date: //84 f* 9 ~7 Time: Id3b
- Prepared by: / 110 CFR 50.59 Preparer Qualified)
Reviewed b i s- O EduJ Date: )ItslV)
Tin,s. I S o o
, , . ~ . . . . . . . . . . . . _ . . . . . , - -
~E".'v7C"n'y*"* O/a kl. [4 CAM Dat.: ///5[9'1 rime. /s25 (10 CFR 50.59 Reviewer Qualified)
O r i inie,di.ci iinary P review ,e .i,ed. conciusions of review attached.'
t ISI Coordinator: 4A Date: /<r/,7 Time: / 5':ro
( '
Date: / 15 f 7 Time: J.238 Concurrence:
(Licensepenior Operator)
Concurrence: - r- '
Date: MJ~' O Time: 22M C "( hift Sprvisor) 1
\
Concurrence: i A JNE- Date: /// t,/f1 Time: of.:rs'
' (Plant Mdnager/ Manager Operations)
NOTE: All Operability Evaluations REQUIRE PRC Review. l
" The independent Reviewer shall detonnine the need for an interdisciplinary review and t
lead the review if one is required. The conclusions of the interdisciplinary review shall '
t be documented, signed by the members of the interdisciplinary review team and attach
- to this NOD-QP-31 form.
Ot isi c , din i ion *=,e oa'v , n i, a < r isi-,si ted ==c.
R11
___-__.___.-_.m._ . _ _ _ - - . _ _ . _ . . . _ _ _ _ _ _ . _ , - . _ - _ _ _ _ . ,
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l OP-31 Evaluation continuation O CR No. 1996001624 ;
II. Description of operability concern !
The < Reactor Coolant pump (RCP) Motor RC-3D-M oportbility concern is with the ,
excessive amount of oil usage and leakage outside of the oil collection system :
during startup following the 96 refueling outage. This loss of oil is caused ;
by an internal leak of non-pressurized oil from the upper oil reservoir. With i the leak path outside of the oil collection system, the lost oil increases the i RCP bay fire loading. This oil leak has also resulted in some oil on internal motor components. *l As a brief history, following the replacement of the RCP motor lube oil coolers.in May of 95, RC-3D has had a history of excessive oil leakage when !
the upper. oil reservoir is filled to normal operational levels. This problem !
had been noted before on RC-3D. However, the prior problem had been limited l to when the upper reservoir was over-filled. Once the oil level returned to normal levels the leakage stopped and oil usage rates returned to normal.
In comparison, since May of 95, RC-3D has lost oil until the reservoir level J reaches a level at the low and of its operating range. Last cycle the motor l was operated at a reduced reservoir level to minimize oil usage. This in turn resulted in an increase in the number of times oil was added to RC-3D. With ]
the start of cycle 17, RC-3D will again be operated at a reduced oil level.
Initial indications are that the number of times oil will be added to RC-3D should be greatly reduced compared to cycle 16. RC-3D is currentiv oneratina with almost no oil usaaeg Since the end of the RFO in November, the motor has lost an estimated 2 to 3 O gallons of oil. Most of this oil leakage was not collected in the oil collection system. Oil was observed on the walkways and floor directly below the motor. Oil had also wetted internal portions of the motor. The floor and walkways around RC-3D were re-cleaned prior to taking the plant-critical. No further inspections have been performed with the Plant in power operations, l
however, from oil reservoir level indication some leakage has continued after this final cleanup.
As previously mentioned, the oil leak is an internal motor leak that is not collected by the oil collection system. During plant startup in November 96, oil was observed to be dripping out of several ports and drains from the internal portions of the motor above the rotor shaf t air seal. This leakage path bypasses the oil collection system. The leakage has been quantified as 2 to 3 gallons over a several week period. Leakage can be seen coming out of the several drains as a drip every several minutes when the motor is leaking '
at its maximum rate (during initial motor startup) .
l To summarise the following are the specific motor operability, concerns:
The fire hazard associated with oil outside of the oil collection system. Some additional leakage outside of collection system is anticipated when ever the upper-reservoir is refilled during the cycle.
The additional fire loading in the bay with oil on adjacent )
- equipment and floor / walkways. l 1
operation of RC-3D with reduced oil levels in the upper reservoir. !
Operation of RC-3D with oil on the internal motor components.
i l
l, __
I i
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- I
-s III. Description of intended sefety function (s)ef affected itema
\s ,/ 1) The RCP motor lube oil collection system's safety function per the j requirements of Appendix R is to "be so designed, engineered, and !
installed that failure will not lead to fire during normal or design !
basis accident conditions and that there is reasonable assurance that
! the system will withstand the Safe Shutdown Earthquake."
1 I
Per a review of the RCP oil collection system DBD reference, the RCP oil I collection system is designed to contain a pressurized oil leak from a crack in any part of the' lubrication system external to the RCP. ;
- 2) Affected portions of the motor have a significant impact on plant reliability, however, this equipment does not perform a safety function.
l The only safety related motor components on the motor are structural components and the fly wheel hese safety related components / functions are unaffe ted by the oil leaka aA ggg c*mnMg )$$ /ec)p
- 3) A number of RCS related components in close approximation to the motor are required to perform a safety function and could potentially be affected from a fire.
IV. References '
- 2) 10CFR50, Appendix R, Section III.0
- 3) OPPD Fire Protection Program Submittal, LIC-76-0180, dated 12/31/76
- 4) EAR 95-086 evaluation on the increases in fire loading
- 5) Program SER, LIC-78-0104, dated 8/23/78
- 7) SER Supporting Amendment #53, dated 11/17/80
- 8) NRC Triennial Inspection Report, LIC-88-880, dated 9/23/88 l l 9) OPPD Exemption Request, LIC-88-1066, dated 11/28/88
- 10) NRC Exemption to Appendix R, III.0, LIC-88-457, dated 12/20/88 VI. Justification of Decision l A. Justification of oil Leakaae outside of collection System The RCP motor lube oil collection system configuration is in conformance with the SER approved design. The Fire Hazards Analysis Design Basis '
Fire in containment assumes a 150 gallon lube oil burn in an RCP bay. l The nominal capacity of single RCP motor lube oil inventog is approximately 115 gallons. With the current lost of oil plus any further anticipated loss of oil during the cycle, the oil inventory in !
the bay (including the oil in the motors) is still within the 150 gallon I assumption. Compensatory actions will be taken to ensure that during '
the cycle oil added to the motor does not challenge the 150 gallon fire loading.~
To evaluate the fire risk concern of oil leakage outside of the oil collection system the leakage needs to be characterized. This includes where and what surfaces the oil will contact and why this oil leakage does not affect equipment operability.
l 1) Oil Leakage to the Floor and Walkways Most of the oil that leaks outside of the collection system comes l from the various motor drains and inspection ports above the rotor shaft air seal. This oil drips to the floor and walkways under
- the motor, i
I
)
1 1
, i l
1 l
The oil on the floor and walkways is considered a minimal fire
[~'h hazard with no ignition source near the puddles of oil. In x ,/ addition the high air flow rates from the motor and the containment ventilation prevent any possible buildup of a i potentially flammable vapor. This small quantity of oil is within !
the previously analyzed fire loading for the bay. j
- 2) Oil Leakage on Hot Insulated RCS Components i
Some of the oil that has leaked outside of the collection system ;
may come into contact with hot RCS components. The oil used in !
the RCP motors when in contact with hot RCS components has the potential to be combustible under certain conditions. Arkansas Nuclear One (ANO) had a recent event where a idrge quantity of oil from a leak in a pressurized lube oil system soaked RCS insulation during cold shutdown conditions. Upon plant heatup, the wicking l
action of the oil in the insulation next to the hot RCS ignited '
the oil. The ANO collection system was not enclosed which allowed direct impingement of lube oil on to the RCS from a pressurized source. FCS collection system is enclosed, thus this condition does not exist at FCS.
The RCP and piping under and around the RC-3D motor has a metal jacket over the insulation which prevents oil soaked insulation.
With the insulation covered and the FCS's collection system, minor leakage that reaches the piping / pump below continues running to the floor (994* elevation). The impact therefore of oil dripping on surrounding piping / pump is of minima) concern.
- 3) Oil Leakage on Hot Un-Insulated and Exposed Blanket Insulated RCS
/7 Components A small quantity of oil coming in contact with un-insulated hot RCS components or RCS components covered with exposed blanket insulation has been considered. This oil is transported either directly from oil blown through the motor or carried by the containment ventilation system. To address this concern an evaluation performed to address the previously described ANO event 4 has been summarized.
An exposed section of blanket insulation on RC-3A (unlike the jacket insulation on RC-3D) was sampled and evaluated during the 96 RFO. This was performed to determine if over
, the years (approximately 10 years) oil had soaked into the insulation as a result of a number of small leaks on the above motor. The insulation was found to be completely dry (non-flammable) . The only indication of previous oil leakage was a brown residue left on the surface of blankets.
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This brown residue was the remaining oil components after all the flammable components have been driven-off the insulation from the high RCS temperatures.
With no mechanism to allow the buildup of oil on hot exposed RCS surfaces or vaporized combustibles to accumulate, the fire hazard concern with the small quantities of oil impinging on these surfaces is considered minimal. Therefore the amount of oil impinging on RCS surfaces from the small RC-3D leak has no significance.
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I 3 -
' l B. Justification of Onaration with 011 on Internal Motor Componentst
) 1) Motor reliability
+
Internal oil leakage has no effect on motor operability or.
! reliability. This. conclusion is based on FCS operating experience and similar motors in the industry. The motor manufacturer (GE)
+
concurs that oil on various internal motor components does not directly affect motor operation. As further justification, RC-3B motor is currently being refurbished with no indication that after 23 years of service internal lube oil leakage has caused any degradation. Internal oil leakage has been observed at times in all of the motors (usually associated with over filling the upper reservoir) .
The RC-3D motor will continue to be operated with reduced oil level in the upper reservoir to minimize leakage. Appropriate compensatory actions including additional operational guidance (OI-RC-9) have been taken to ensure the motor can be operated reliably with the reduced oil level to control the amount of oil usage during the cycle.
- 2) Fire Hazard of 011 on Internal Motor Surfaces A concern has also been identified regarding the fire hazard of oil on internal motor surfaces. This small amount of oil on internal motor surfaces provides no additional significant fire loading versus the 115 gallons already in the motor. In addition,
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all of the oi1 in the motor is subject to the same ipition sources. A major motor failure (ie, major mechanical failure or major electrical fault) could potentially ignite a number of motor components including the oil.in the motor. The addition of the O small quantity of oil on internal motor surfaces does not provide.
any significant additional fire hazard then what~has already been previously evaluated for the complete motor oil collection assembly.
C.
Conclusions:
Although oil leakage outside of'the motor cil collection system is undesirable, the minimal increase in fire hazard risk is acceptable and within design basis and can be managed with the following compensatory actions:
- RC-3D motor oil usage is monitored and controlled to ensure ,
.. compliance with 150 gallon total fire loading assumption. The I clean up and removal of the oil, as plant operation conditions l permit, will be factored into the 150 gallon limit. i
- Operation of RC-3D at reduced oil levels to minimize oil usage. j TN4 amount of oil added during the cycle will be minimized to limit leakage.
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O
O O O RC-3D Motor Reservoir Levels 85 84 83 82 81 80 0 79 "
3 78 77 76 x 75 = =
== = =
74 73 72 j j i j j j i : j i ! ; ; ! ! ; ; ! !* ! !
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- Month / Day 11/96 to 2/98
Fort Calhoun Station Unit No.1 OI-RC-9^
OPERATING INSTRUCTION
Title:
REACTOR COOLANT PUMP OPERATION FC-68 Number: 46921 Reason for Change: Incorporated OPS Memo 96-06 into appropriate sections of OI-RC-9.-
Revised Data Table 2, incorporating normal parameters specific to RC-3B.
Contact Person: S. Clayton O ISSUED: 01-28-97 9:30 am R30
i FORT CALHOUN STATION OI-RC-9 I
OPERATING INSTRUCTION PAGE 3 OF 57 PRECAUTIONS (Continued)
- 17. WHEN the RCS pressure is <425 psia, THEN the Pressurizer pressure indication is less
- accurate. Steam Tables shall be used to determine actual pressurizer pressure by comparing Pressurizer liquid temperature with the saturation pressure to determine
- - adequate Reactor Coolant Pump Net Positive Suction Head (NPSH).
L I 18. A Reactor Coolant Pump shall NOT be operated without controlled bleedoff flow
[ established. Normally, Reactor Coolant Pump controlled bleedoff is established whenever, the RCS is pressurized (does not apply to an uncoupled RCP).-
1 i 19. IF Component Cooling Water is lost to the pump motors, THEN the Reactor Coolant Pump l Motor (s) shall NOT be operated for more than five minutes, follow guidance of AOP-11. ,
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- 21. During RCP operation, if a valid temperature indication for the motor radial or thrust bearing
! shoes exceeds 203*F for RC-3A,3C and 3D or 230*F for RC-38, OR if an abnormal j temperature rise of 10*F per minute is noticed during steady state pump operation, the i
Reactor shall be SHUTDOWN, and the RCP shall be immediately stopped and the affected bearing (s) inspected.
i 22.- While the RCP(s) are running, if the lower seal temperature exceeds 200* F, the Reactor
} shall be SHUTDOWN and the RCP shall be immediately stopped. Restad shall NOT be i permitted until all O-rings, seal faces and U-cups have been inspected or replaced. Before i starting, the RCP Seal Cavity temperature usually exceeds 200* F, but should cooldown >
- shortly after RCP has been started.
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- 23. Due to the present inadequate lube oil flow monitoring capability of the ARRD Lube Oil Flow Pressure Switches for RC-3A, RC-3C and RC-3D when these pumps are running (i.e., the oil lift pump is "OFF"), compensatory measures are warranted to monitor for adequate flow to the ARRD. Therefore, vibration trends of the RCP motor upper guide bearing should be taken each shift for all four RCPs and the results recorded in the Turbine Building Log (FC-78). If any of the thso vibration trend lines (max, average, min) on the RCP motor upper guide bearing has increased or decreased by more than 2 mils over a one week (or less) time frame, the responsible System Engineer shall immediately be notified and the trend evaluated.
- 24. IF the Vibration Alarm on an operating RCP is IN ALARM, THEN action shall be taken in accordance with the ARP and Ol-RC-13. OI-RC-13 provides guidance for operation of the Vibration Monitoring System (Al-270) including response to alarms for both normal RCP operation and pump starts.
- 25. Any deviations or discrepancies shall be immediately reported to the Shift Supervisor. j O
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O FOR. JALHOUN STATION O '
Ovi-RC-9 OPERATING INSTRUCTION PAGE 57 OF 57 .
Table 4 Page 2 of 2 -
~ REACTOR COOLANT PUMP RC-3D NORMAL OPERATING PARAMETERS EXPECTED VALUE AT -
lNDICATION DESCRIPTION 532'F/2100 PSIA ALARM VALUE F1-453 Seal Cool Out-Flow (CCW)(Al-45) 40 gpm (25-55 gpm) N/A F1-457 Lube Oil Cool Out-Flow (CCW) (Al-45) 30 gpm (20-40 gpm) N/A TI-461 Seal Cool Out-Temp (CCW)(CB-1) 80* F (60-100* F) 120'F TI-465 Lube Oil Cool Out-Temp (CCW) 120'F f (CB-1) 80* F (60-100* F)
I TI-2800 Disch-y Header Temp (CCW) 120*F (CB-1) 70*F (55-90*F)
F3191 Lube Oil Low Flow Normal Low "*
F3190 Oil Flow to ARRD Alarm Normal **"" Lo Flow *** ;
P3189 Oil Filter Delta-P Normal High *"
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, Utilize the Upper Guide Bearing Temperatures, Upper Thrust Bearing Tav,miatures and RCP Vibration (Al-270) indications to i
"" ensure the pump / motor combination is performing as expected, then contact System Engineering for further guid,anc,e.
The ERF level alarm setpoint may be lowered to 73%. Maintenance personnel shall be tasked to fill the reservoir pnor to ,
reaching a upper oil reservoir level of 73%. The upper guide bearing temperature should also be monitored for increasing ,
tem mratures. An increase in bearing temperature of 5 to 10 degrees over several days with no concurrent change in CCW ;
coo er flow or temperature is an indication that adding oil is required and the System Engineer be notified. !
An increasing trend is of much greater significance than the actual bearing temperatures, however a bearing temperature 4 above 170* F is clearly above expected values (even during the summer months). As an additional aid to identify an increase in upper guide bearing temperature, the difference between the upper guide bearing and lower thrust bearing temperatures
, can be calculated. The nominal temperature difference is 20* F DELTA T, regardless of changes in CCW temperature or flow.
If the temperature difference increases above a delta T of 30*F, the bearing is outside of the expected temperatures and i should be evaluated by System Engineering.
3 Due to the present inaequate lube oil flow monitoring capability of the ARRD Lube Oil Flow Pressure Switches for RC-3A, i RC-3C and RC-3D when these pumps are running (i.e., the oil lift pump is "OFF"), the expected value is Low Flow when the l RCP Oil Lift Pump is NOT running.
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