ML20149M478

Forwards marked-up 871201 & 11 Safety Evaluations Re App R Compliance & 880222-25 Audit.Portions of Evaluation W/Util Comments Clearly Marked.Table Containing Comment & Evaluation Page Numbers & Justification for Change Encl

ML20149M478
Person / Time
Site:	Quad Cities
Issue date:	02/19/1988
From:	Johnson I COMMONWEALTH EDISON CO.
To:	Murley T Office of Nuclear Reactor Regulation
Shared Package
ML20149M480	List: ML20149M478 ML20149M511 ML20149M530
References
NUDOCS 8802260071
Download: ML20149M478 (8)

Text

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j'^N - Commonwealth Edison a

)7 One First National Plaza, Chicago, lHinois

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Address Reply to: Post Office Box 767 (j Chicago, Ilknois 60690 0767 s

i February 19, 1988 Mr. Thomas E. Murley, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Quad Cities Station Units 1 and 2 Comments on NRC Safety Evaluations Pertaining to 10 CPR Part 50, Appendix R NRC Docket Nos. 50-254 and 50-265____

Peferences (a): Letter from T.M. Ross to L.D. Butterfield dated December 1, 1987, transmitting NRC Safety Evaluation for Interim Compensatory Measures and Request for Exemption from 10 CFR 50, Appendix R.

(b): Letter from T.M. Ross to L.D. Butterfield dated December 11, 1987, transmitting NRC Safety Evaluation for Exemptions from the Fire Protection Requirements of 10 CFR Part 50, Appendix R, Section 3.g.

Dear Mr. Murley:

Commonwealth Edison has reviewed the above referenced Safety Evaluation Reports pertaining to Appendix R compliance at the Quad Cities Station. In anticipation of the Appendix R compliance audit (currently scheduled for February 22-25, 1988), we wish to offer the following comments on the above referenced documents. contains a marked up copy of Referenced (a). The-portions of the SER for wich we are providing connents are clearly marked on the referenced document and a table is provided containing the comment number, the respective SER page number, as well as the justification for change in the Safety Evaluation Report text.

T kNEf0@CK05000254 71 800219

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i T.E. Murley February 19, 1988

. Attachment 2 contains our comments in Reference (b). Our comments-are documented here in the same manner as they were on the earlier SER.

J Please direct any questions you may have regarding this matter, to this office.

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I. M. Joh so Nuclear Licensing dministrator im Attachments cc:

T. Ross - NRR (w/Att.).

A. B. Davis - RIII (w/Att.)

Region III Inspector - QC (w/o Att.)

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ATTACHMEhT l' Ceco Comments on NRC Safety-Hvaluation for Interim Compensatory Measures _and Request for-Exemption from 10 CFR 50, Appendix R

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'omment' SER Justification:for change-C No.

'Page No.-

in SER text 1

2 Typographical error.

2 3

The exemption request was for the pulling of fuses only.

The discussion'of manual actions'was provided as back-ground information.

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~ This-was not in the most recent revision of the exemption request; i.e., Revision.1, dated November 1987.

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The needed manpower is not provided in the areas on a permanent basis.

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See Comment 2, 6

2 Quad Cities has separate safety and relief valves.

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Tu-fuses need to'be replaced per circuit;.therefore, a maximum of 4 fuses may need to be replaced for-a fire in Fire Area SB-I.

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UNITED STATES i

NUCLE AR REGUL ATORY COMMISSION e<

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'ackets hos. 50-254 and 50-265 Mr. L.D. Butterfield, Jr.

Nuclear Licensing Manager Comonwealth Edison Company Post Office Box 767 j

Chicago, Illinois 60690

Dear Mr. Butterfield:

INTERIM COMPENSATORY MEASURES AhD REQUEST FOP EXEMPTION

SUBJECT:

FROM 10 CFR PART 50. APPEh0IX R, SECTION !!!.G.1 REGARDING HOT SHUTDOWN REPAIRS (TACN05,57284,57295,64493AND64494)

18. 1984 Cournenwealth Edison Comeany (CECO, the By letter dated December licensee ) yubmitted a reevaluation report certaining to 10 CFR Part 50, Appendix R_ LFire Protection Program) for Quad Cities Nuclear Power Station (QCNPS) in response to NRC staff positions prescribed in Generic Letter 83-33, h t.ed October 19. 1953.

Ints report toentified Interim compensatory Measures rtoo luntt1 (ICMs) _that were beine conducted at OCNPY for an interim po completion of Appendix R required hardware modifications) lo ensure safe thutdrwn canability of Unitt 1 of 2 for Dostulated fire events. BestWn i

a review of the aforementioned report, _the NRC staff has detennined that the_

orevious staff safety evaluation (SE) and approval of safe and alternative-shutdown capabilities at QCNPS. issued December Ju. Iyne, remains valid.

1 However. durino the staff's review. additional information was requested from CECO concernina the affect of fire-induced high impedance faults and electrical isolation deficiencies upon safe shutdown capability at QCMP5 for certain fire These issues were not expiio dy add v..W in Ce r;;i.de

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events.

Additional infonnation was also sought on the ICMs.

30. 1986, CECO responded to the staff's inouiries with letters dated December and October 9. L987. In these submittals, March L3, 1987 July 15, 1987, 1

CECO orooosed conducting certain manual operatlons, includi_no hot shuthn recairs (i.e.. Dulling out fuses and/or replacing blown fuses), to resolve the_

maM :--m e tn f ire-incucea spurious operations that_

issues above mad were subsequently self-identified. In general,Section III.G.1 requirements have been interpreted to pron 101t hot shutdown repairs. Consecueely; errn i

30. 1987 October 1. 1987, gbmitted letters dated January !?.1987. Septemberrequesting approval for several hw W r 20, 1987, and hovember 30,1987, exemptions from Appendix R, section III.G.1 which would allow sucn repairs i_n order to achieve and maintain not snutdown.

In the March 13, 1987 letter, Ceco stated that because all the required safe shutdown hardware modifications had been completed, their ccrresponding ICNs Also, in a July 17, 1987 letter, several l

would no longer be necessary.

l deviations between the present safe shutdown procram, and what was aproved a

l in the previous NRC SE (dated December 30,1982), were described by.tco anc~

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. 10A7 erro Futhermore, ir the letter read Nnvamhar 70 tachrically iustified.

10.0 "Hot Shutdown that a cortion of an ereertion recuest.

notiftec the st6'f in the September 30. 19E7 letter. was no lonaer Rep 6 irs (Fuse Replacements)"

necessery due to a non-Appendix R plant modification to be accorelished durinc Consequently, that part of the exemptien request The Unit I refuelinc cutaae.

applicable to tre Unit 1 Reactor Core Isolation Coclino Syster, inboard steajr.

supply isolation valve was withdrawn, of this letter centains the NDC staff $L which enCocpasses all the aforement1cned CECO submittals except for two sutdect requests described It was the staff's conclusion that the manual actions, includino hot shutdown __

l Tsniation deficiencies end sourtous operations were a exemptions requests (for performing hot shutdown repairs) should be granted.

it, tve/ jetter The staf f also conclucec that ceviations aescr1Dec ey Ine uuty igld not compromise the safe shutdown capability at QCNP5 a.:i therefoN ar accepta_le.

Furthermore, the start recogr.izes 6iis6 iZs7pec'ifted II 16, i C.

nv t eog r_ of the reevaluation report cateo veceu.LerIt shou recuired.

23,1987 l

not previously mentioned, dated July were provided to the staf f for information purposes only, as such no forma evaluation was perfonned.

ifI_C. of Anoendir R. enntained in Technical eremDtion reouests f err tactinnreevaluation reoort. related to fire

18. 1984 of tne December h

t ff in protection features for selected plant areas will be evaluated by t e s aA sch a separate SE to be issued lator.etter dated November 20.198L This subiect_

L 10 CFR 50.48 was reauested by issued later. T_he leoal reculatory_

will also be evaluate 6 senaratelv and f roc) enmoliance_

"Exemotion". that exerrots certain het shutdown reoairs at OCNPS with requirements of 10 CFR 50. Acoendix R. Section Ill.G.1 will be issued to_

CFcn and oublished in the Federal Reaister by other separate correspondences which should be forthcoming, w

hierry M. Ross, Project Manager Prcject Directorate III-2 Division of Reactor Projects - 111, i

IV, V and Special Projects i

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Enclosures:

1. Safety Evaluation ec w/ enclosures:

See next page i

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6 Quad Cities Nuclear Pcwer Station Mr. L. D. Butterfield, Jr.

Units 1 and 2 Connonwealth Edison Company CC:

Mr. Stephen E. Shelton Vice President towa-Illinois Gas and Electri: Company P.O. Box 4350 Davenport, Iowa 52808 Mr. Michael Miller Isham, Lincoln & Beale Three First National Plaza Suite 5200 Chicago, Illinois 60602 Mr. Richard Bax Station Manager Quad Cities Nuclear Power Station 22710 206th Avenue North Cordova, Illinois 61242 Resident inspector U.S. Nuclear Regulatory Commission 22712 206th Avenue North Cordova, Illinois 61242 Chairman Rock Island County Board of Supervisors 1504 3rd Avenue Rock Island County Office Bldg.

Rock Island, Illinois 61201 l

Mr. Michael C. Parker, Chief Division of Engineering Illinois Department of Nuclear Safety 1035 Octer Park Drive

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Springfield, Illinois 62704 Regional Administrator, Region til U.S. Nuclear Regulatory Comniission 799 Roosevelt Road Glen Ellyn, Illinois 60137 i

SAFETY E MLUATICS EY THE OFFICE OF NUCLEA I

PL XT SYSTEMS BRANCH IhTERIM COMPEhSATOR1 HEASURES AND RE0L'E FROM 10 CFR PART 50, AFFENDIX R. SECTION ll!.G REQUIREM REGARDING HOT ShUTOOWN REFA!RS FOR A F QUAD CITIES, UNITS 1 AND 2 DOCKET h05. 50-254 and 50-265 1.0 INTRCDUCTIC'!

) relatirg the NRC issued a safety Evaluation Report (SERR (alternative to Sections ll!.G.3 and !!!.L of 10 CFR Part 50, Appendix 30, 1982, On December l t) for shutdown capability for a reactor following a fire event in the p an h

l Quad Cities, Units 1 and 2, wherein the staff concluded that t h tdown capability.

j requirements of the above sections with regard to alternative s ucomo 18, 1984, i

Subsequently, by letter dated Decemberlicensee for the plant, s b

19, 1983 which that it was necessitated by Generic Letter 83-33, dated Octo er In the above defined NRC staff positions on certain Appendix R (ICM3) fire event in nesded to ensure safe shutdown of the plant follow hardware i

for exemption from specific lli.G requirements relating to fi modifications are completed).

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i shutdown detennined that the safe shutdown capabilty including the alternat v features for select areas.

described capability at the plant continues to be essentially the same as 30,1982 SER) rema ns valid.

by the licensee in their earlier submittals.

i detemined that its earlier acceptance (December impedance The staff, however, sought information relating i

d in the safe shutdown capability, since these were not explici i

riod. By letters required to ensure sate shutdown capability in the inter m pe reevaluation.

5 1987 12, 1987 March 13, 1987. July 1,

1987, i

October 1,1987, October 9,1987, and Novee6er 2 l

January dated December 30,1986, 30, 1987, Septamber i

to eliminate the licensee provided their responses.

proposed some manual operations including hot shutdown repa rs d high fire-induced electrical isolation deficiencies, spurious operations h Appendix R.

irpedance f aults. Also, the licensee requested exemptions f rom i t ining Section !!!.G.1 requirement for perfonning repairs for achiev 1

h epairs. In hot shutdown, in so f ar as it is interpreted as disallowing suc r d that since all the submittal, the licensee further state l

d their needed safe shutdown hardware modifications had been comp ete,

the March 13, 1987 Also, by the July 17,1987 submittal, h

lant safe shutdown corresponding ICMs would not be needed.

the licensee identifieo a few differences relating to t e p h earlier SER configuration as it exists now from what has been describ 30,1982).

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relating to differences from the earlier SER and the licensee's re rns and (December fire-induced electrical deficiency concerns, spurious operations Another SER, to be provided at a later d high irpedance faults concerns.

will address technical exemptions requested intc fire MddOT Dng 5 pp, N -----.

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2.0 EVALUATION Spuricus Operau cns and hi e lepedance Faults e

-l 2.1 any one of certai In their submittels, the licensee stated that a fire teo with safe plant areas could damage RHR system logic cables as ious operations F

shutdown equipnent which, in turn, could result in nt fsafety relief i

RHR purps and valves, diesel generators auxiliary e Additionally, a fire vent ' n an on M valves (SRVs) ano 4 kv breakers.

, ir certain plant areas could damage the circuits for SRVsTo eliminate these s spurious operations.

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.g has proposed to deenergize applicable circuits by opening (respectiveFA) TB-1 and breakers at de distribution panels located in Fire Areas For a fire, TB-lil (Turbine Building horthern and Southern Zone Groups).

in either FA TB-1 or TB-III, the licensce has proposed to deenergize these circuits by pulling out control power fuses located in the applicable two of four panels in a timely manner (8 fuses within 3 minutes after scram for handling the SRVs concern).

which two of the panels (one for each unit) contain 8 fuses each and the i

other two panels (one for each unit) contain 10 fuses each, ar a fire event in either FA TB-! or TB-!!!,

l Regarding fire-induced high impedance f aults (faults in circuits supplying power to non-safe shutdown loads from a comon power source f

that supplies power also to safe shutdown loads) which can affect power to safe shutdown loads, the licensee stated that plant safe recedures require the operator to shed all non-safe shutdown

.on power buses by tripping manually the associated breakers j

shutd 4

Additionally, these procedures require pulling out loads from j

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iga tirnely ontrol power fuses for electrically operated breakers nner.

the @ d h non-safe shutdown loads that are supplied power by 480 V de as t,ociate This task will be perforu d prior to chgear connon buses.

applicable breakers as a precaution against their possib or 4 kv S _- af spurious closures.be perfomed either within 30 minutes or 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> af ter scra upon whether such actions are required Defore initiating) reactor water makeup (30 minutes) or suppression pool cooling (3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.

With regard to the fuse pulling operations mentioned above, the licensee st.ated that applicable control power fuses are easily The their removal would not involve any significant operator h operator instructi9ns to perform the above tasks in a timely manner.

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in.u a Based or. the above. tre staf f fir-s the licersee's propose pulling u the acti6ns, i.e. Frirrine the ac t i t cabielreeters JanIpurious operation and ap;11 cable fuses iri a ticieiy manner tur r.erm n,ccactab ultafi fu the The i

ns, be e r.

x R, JiMp,ejacca mu k c.pnc cr exemptWns fivn cue xhot shutccwn re s.

Section 111.G.

requirerent for perforr.ing the above rentioned recorrends thar.he Ticense i

hot shutcown, be repair, i.e., fuse pulling for achieving anc eaintain ng g

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granted,

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Electrical Isolation Deficiency ficiency (i.e., a fault i

j 2.2 Regarcing the fire-induced ele.r,trical isolati oth local and remote control on a remote circuit blowing a fuse comon ot shutdown circuit), that can A

circuits, prior to isolation of the nee eded hot shutdown circuit to

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r rol, the licensethAi_{dfntihedMin~ cwa i

th ccepr his is because thWe ~cKDres~wnicn 1

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this design problem.ry for four breakers at the 480V buses, are ntrol power jMEQrcuThe i n.;-'** stated that, in the event the ced and additionally

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j fuses associated witII"tria ; b aakers are fi reakers are nortnally closed fused.

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n procedures

,.and may not require any ranval)these breakers are fou

, the p 0 minutes) y closed in a tirely me f

ocated in a cabinet in the vicinity oThe license p

'will require them to be l

lusingajackingh ina 2+

=a iapp11cableumber of breakers that may require such manual c1Beside

, switchgears.

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is three m ssociated with engines @

tire due.to a fire avant i

b 7mmrntep threeM control circu ts, a starting controls for tme Unit 1. Unit 2 and swing diesel gene

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Inerable to electrical isolation defic Anu

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rd ow9 s.7 a timely manner (within 30 minutes) m, e

any one tirre, would require such rep hhan ce ers h j

controls f or the diesel gengligs, to maintain replacement fuses a proximity of the engine star andneededmanpowergnthesearea0tol ine ncensee fur h and provide energency light iktimely manner.

and facilitate fuse replacemen less claimed that the circuits inthou h rated at 15 am eres, will actually ca

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the fuses ue e

v ine the licensee's Based on the above, the sta f has dete snutco=n repairs. ~

curre o s e'd tha ngAl_c t o s in o 'o f ' a p pl i c &tTe~t re au rrTn? h d.

haz po

., fuse replacement) meet the intent and purPost-fire Shutdown p

ble. The

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and are, therefore, accepta i

from No i 31, 1985, Capabitity", dated Januarystaff further rec i

d hot d maintaining shutdows, repairs (i.e., fuse replacement) for acheiving an hot shutdewn, be granted.

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.4 2.3 01'ferencee >ith Oe:emter 30. 1982 SER_

in the July 17, 19E7 submittal, the licensee toentifiec the differences in the safe shutcown configuration as it exists now at the plant from 30, 1982.

what has been describec in the earlier SER dateo December The licensee additionally provided supporting justification These differences are listed below:

this SER.

Backup water supply source for the safe shutdown makeup purp will be provided by the Fire Water System (FWS) instead of the Service Water 1.

System as originally indicated in the earlier SER Se licensee has concluded that the system can simultaneously meet the maximum fire demano and supply cooling water to the safe shutdown rakeup pump room cooler, ano also provide backup water supply source for the 56fe shutdown makeup pump at later times when needed.

RHR flow indication instrumentation included as being available during a fire event, in Section 3.1.5 of the earlier SER, is not considered 2.

However, during torus as necessary diagnostic instrumentation.

cooling, the needeo d a g et*1c instrumentation will be provided by suppression pool temperature indication and RHR pump discharge pressure indication.

Earlier SER Section 3.3 indicated there will be no need for hot o cold shutdown repairs for achieving and maintaining safe shutdown.

3.

However, as inoicated in Sections 2.1 and 2.2 of this SER, there may be hot shutdown repairs (i.e., fuse pulling and/or fust replacerent)

Cold shutdown repairs may also be depending upon the fire event.needed for certain fire events (these ar of the licensee's December 18, 1984 submittal).

The plant does not have documentation for break 4.

However, plant safe shutdown procedures include SER Section 3.4.1.

operator instructions for shedding non. safe shutdo high impedance faults associated with certain connon l

i fire inouced faults whenever the bus is utilized to power safe shutdown leads.

1 the above, the staff has determined there is reasonable assurance f

these differences will not compromise the safe shutdown capability of the Based o:

f plant and are, therefore, acceptable, d

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3.0 CONCLUSION

N-s Thestaffcondli/255,thatthe11hensee' spi *oposedastroachesforresolving the fire-inasce: concerns (i.e.g.spuricus hperations identified in this SER, high impecance faults, ar.c electrice) isolation ceficiency requests te allow conducting aforerent'ioned het shutdown repairs (i.e., fuse acceptable.

pulling anc/or f'use replacennt),for achieving and raintaining hot shutdown, be granted.-Futhermore, the sts'+ toncludes that the cifferences between the present safe shutdown configuyation at the plant from what has b in the December 30, 1982 of this. SER, are acceptable.

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ATTACHMENT 2 i

CBCo Comments on NRC Safety Evaluation for J.

Exemptions from the Fire Protection Requirements of 10 CFR Part 50, Appendix R, Section 3.g l

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Comment-

.SER'-

Justification for change No.

Page No, in $ER text 1

3 Typographical error.

2 3

Typographical error.

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3 The ceiling height is about 38 feet (basement floor eleva-tion f s 554'-0" and the ground floor elevation is 595'-0").

4 4

See Appendix B, Figure B-2 in the June-1986 exemption request submittal for the locatior, of detection and suppression systems.

5 4

Typographical errors.

6 4

See Coment 4.

7 4

Typographical error.

8 4

Typographical error.

9 4

The cables are routed throught the Northeast corner room and into Fire Zone 1.1.1.2.

Thus, the word "in" is probably more appropriate.

10 4

See Section 3.2.4.3 (p. 3.2-4) of the June 1986 exemption request submittal.

j 11 5

Unit 2 does not have a stairwe.y from Fire Zone 1.1.2.2 to j

Fire Zone 11.3.2.

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12 5

The change is a clarification that is not provided in the exemption request submittals.

i 13 5

Typographical error.

l 14 5

Station clarification of the proper equipment names.

15 6

Typographical error.

16 6

The wall for Fire Zone 1.1.1.3 is not a 3-hour fire barrier due to the existence of a 4-kV bus duct penetration. An exemption request was originally submitted; however, it was i

withdrawn at the request of Mr. J. Stang at the April 8,1986 meeting using the independence argument.

l 17 7

See Comment 4.

1 18 7

RCIC safe shutdown valves are located in the steam chase, f

19 7

All of the interfacing fire zones should be listed.

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The concern is comunication of the fire in either direction, i

not just from the Turbine Building to the Reactor Building.

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Comment SER.

Justification for change-No.

Page No.

in SER text.

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The Turbine Building does not have complete detection and suppression as discussed in other exemption requests.

However, detection and/or suppression is provided near the Reactor Building / Turbine Building wall.

22 8

There is no automatic suppression system in the safe shut-down makeup pump room.

See Figure'B-2 of the June 1986 exemption request submittal.

23 8

There is not an absence. of combustibles 'in.the steam chase.

12 4 9

Typographical error. The correct elevation is 554'-0".

25 9

Fire Zone 1.1.2.6 does not exist.

26 9

These are clarifications that were not explicitly spelled out in the exemption request submittals.

27 10 The south and east walls are not 3-hour rated fire barriers..

28 10 See Figure B-2 of the June 1986 exemption request submittal.

3 29 10 See Comnent 16.

30 10 See Comnent 16 and Section 3.2.1 of this SER.

31 11 This sentence was misworded.

32 11 Only one unit is located below Fire Zone 1.1.1.5.

33 12 See Connent 11.

34 12 Discussion of the bus duct is provided in Section 6.0 of i

this SER.

35 12 Fire Zone 1.1.2.6 does not exist.

36 13 There are eleven sections in the SER discussing twenty-one fire zones in the Reactor Building, l

37 13 Fire Zone 1.1.2.6 does not exist.

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38 14 This sentence was misworded.

39 15 These statements are not correct.

40 15 The bus duct penetrates the Unit 1/2 Reactor Building wall of the mezzanine level.

41 16 See Section 4.4.4.3 of the June 1986 exemption request submittal.

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. Comment.

SER Justification for change No.

Page No, in SER text 42 16 Fire Zone 8.2.7.0 is not completely covered by automatic sprinklers; however, automatic sprinklers are provided in Fire Zone 8.2.7.0 below Fire Zone 8.2.8.0.

43 17 Fire dttection arid suppression is not always located on both sides of the wall.

See the figures in Appendix B of the June 1986 exemption request submittal for automatic.

suppression and detection system locations.

44 18 See Comment 43.

45 19 Clarification supported by past exemption request submittals.

The items.specified are t_e only safe shutdown components h

46 19 that could be effected by a fire. Other safe shutdown components would not be affected by a fire, q

47 20 See the June 1986 exemption request submittal Section 8.2.

i 48 21 Typographical error.

49 22 There are some safe shutdown cables routed through the corridor; however, they are not required by the southern or central zone group shutdown paths.

'50 22 See Table 5.1-3 of the June 1986 exemption request submittal.

51 22 The boundary is penetrated by a manlift and a pipe chase in addition to the stairway.

52 23 There are RCIC cables in this zone group but none required to operate the safe shutdown path.

53 24 There are sealed penetrations to Fire Zones 8.2.6.A and 8.2.6.B.

i 54 25 Typographical error; "fire" is not needed.

55 27 The phrase "onto the switchgear" is clearer than "of the switchgear."

56 27 The 3-hour barrier does not surround'the switchgear.

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only exists in the area between the switchgear.

i 57 28 The suppression system is for the turbine bearing, not for all of the turbine.

58 29 The watertight door contains a small glass portal.

Comment SER Justification fer change No.

Page No.

in SER text 59 29 The 1-hour fire rated wrap for the reserve feed for the 1/2 diesel cooling water pump is also provided in Fire Zone ll.1.1.A.

60 29 Fire Zone 11.1.1. A also contains complete area coverage by automatic fire suppression and fire detection.

61 31 See Section 5.10.2.2 of the June 1986 exemption request submittal.

62 31 The last two sentences are confusing. The proposed changes should clarify them.

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