ML20195F665
| ML20195F665 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/14/1988 |
| From: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| C311-88-2152, GL-81-12, NUDOCS 8811220102 | |
| Download: ML20195F665 (11) | |
Text
g GPU Nuclear Corporation ggg7 Post Office Box 480 Route 441 South Middletown, Pennsylvania 17057 0191 717 944 7621 TELEX 84 7386 Writer's Oltect Olal Number:
Nov & r 14, 1988 C311 2152 U.S. Nuclear Regulatory Commission Attn:
Docunent Control Desk Washington, DC 20555 Gentlenen:
Three Mile Island Nuclear Station, Unit 1 (TMI-1)
Operating License No. OPR-50 Docket No. 50-289 Response to NRC Request for Additional Information 10CFR50 Appendix R NRC letter dated September 7,1988. Enclosure 4 requested additional information concerning Thl-1 10CFR50 Appendix R letters 5?ll-87-20?8 and 5211-87-2034, both dated February 10, 1987 This letter provides the TMI-l response to each specific NRC question (see Attachnent).
We trust this additional information satisfactorily resolves the reruining noen items regarding NRC's review of the THI-l associated circuits studies (as identified in NRC Inspection Report 50-289/86-23 ) and alternate shutdown capability.
Sincerely, r
e
- . D. H kill Vice President & Director, THI-l H0H/0JD/ t Attachnent cc:
J. Stolz, USNRC R. Hernan, USNRC W. Russell, USNRC, Regio, !
R. Conte, USNRC, THI-l D. Kutiicki, USNRC (h
Ga11220102 5?1114 PLIR ADOCK 0 5 0 0 0.: 39 8
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PDC GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation
Attachment Ouestion 1 This submittal refers to Revision 26 of procedure EP 1202-31 and Revision 7 of the TPI-1 FHAR. GPUN has since submitted Revision L
27 of EP 1702-31 and Revision 9 of the TMI-1 FHAR.
Discuss the effect that these latest revisions have on this submitta! on Generic Letter 81-12 and alternate safe shutdown,
Response
The THI-1 Fire Hazards Analysis Report (FHAR) is currently I
Revision 10, submitted via GPUN letter C311-88-2084 dated i
July 22,1988 The following discussion addresses the effect of i
that revision on the TPI-1 response to NRC Generic Letter 81-12 submitted to NRC via CPUN letter 5211-87-2028 dated February 10, l
1987.
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- 1. Health Physics and Lab f.rea (CB-FA-1) has been identified as an additional area of the plant where alternate shutdown capability is used to achieve safe shutdown.
The only function for which CB-FA-1 is designated as a "renote shutdown area" is the control of IC-Y-3 and IC-Y-4 from the remote shutdown panels during a fire in CB-FA-1.
This change was transmitted to NRC via GPUN letter G211 2095 dated May 7,1987 and found acceptable by NRC in i
the letter dated September 7, 1988
- 2. GPUN analysis of fire induced loss of HVAC has shown that there is no adverse effect on safe shutdown capability, j
)
subject to several manual actions which have been proceduralized. This concluston was accepted by NPC in the i
I letter dated September 7,1988.
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- 3. The plant emergency procedures which describe the tasks to be performed to effect the shutdown independent of the relay 2
room, control roon, ESAS room and Her.lth Physics and Lab Area p
(CB-FA-1) have been revised (and are consistent with the TMI-1 a
FHAR Pev.10) as follows:
EP 1202-31 Rev.34 "Fire" Section: CB-FA-1 and CB-FA-3c
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EP 1202-37 Rev. 36 "Cooldown from outside the control room" (for fire in CB-FA-3d or CB-FA-4b).
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- 4. Remote shutdown systen repairs a*e not affected by any of the f
changes incorporated in Revision 10 of the THI-1 FHAR.
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- 5. The letdown line has bee 1 added to the list of high-low pressure interfaces.
One of the followin', required to be available for isolating the flow to the low p essure portion of the letdown system:
- a. MU-Y-2A and 2B or,
- b. MU-Y-3 or
- c. PU-Y-4 and 5.
L Exemption request for AB-FZ-4 and FH-FZ-1 submitted to NRC by GPUN letter 0311-83-2057 dated May 21, 1988 has been reviewed and found acceptable by NRC per NPC letter dated Septerber 7, l
1988.
- 6. Due to instrumentation upgrade modifications, Table 2 of t5e THI-1 response to Generic Letter 81-12 should be revised as per attached marked-up sheets. This change does not affect the alternate shutdown instrunentation availability.
- 7. Makeup flow transmitters and in-core thermocouples required for HPI cooling which have been added in Revision 10 of the THI-1 FHAR, are not required in any of the areas which rely on i
the rerote shutdown system during a fire, t
- 8. Due to typographical errors in Table 2, page 8 and Table 3 of the THI-1 response to Generic Letter 81-12, opening of switch
- 17 at panel EH-DPES-1C to open valve IC-Y-3 should be revised to switch #15. Also, in Table 2, page 12 Decay Heat River i
Water System components should be revised to DR-P-1 A, DR-P-18, OR-Y-1A, DR-V-1B, respectively.
- 9. Due to plant modifications, the following drawings submitted I
to NPC for review via GPUH letter 5211-87-2028 dated February 10,1987 (Table 4) have been deleted:
(OD) 210-489 Rev. IA-0 for N!-9 D-600-507 Rev. 2 for dPT-02 B-600-511 Rev. 2 for dPT-03 L
(CC) 210-616 Rev.18-0 for LT-809 l
In summary, the effect of these changes on alternate shutdown as described in the GL-81-12 submittal is:
- a. A fourth area where alternate shutdown is used (item 1),
- b. An instrumentation change (item 6.)
- c. typographical correction (item 8.)
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TABLE 2 p
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e NORM A L SNL*TDOWN C A OLES AN D COM PON ENT5 IN REMOTE sHLTDOWN SYSTEM RSD ARCAS SHLTDOn%
E Q L if'M E N T REMARAR isMeuen Centree C B F A o<
C 5 F A 34 CB FA 46 Equipment
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RC4A TEl X
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RC4 A Tte X
X X
RC 45.Tr i X
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RC4B Tre
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X TE.954 X
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Tt 954 EG-DP Yb A CB F A 34 CE F A.!:
testated. Nu evenable for CB-FA h.
TE No X
X TE M0 EG-OP VBS C8 FA h CB.F A le lastated RC Inlet Temp-RC3 A Tt2 X
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RCSA T14 X
X X
RC33.TE2 X
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RC35 Tid X
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TE 959 X
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Question 2.
In TMI-1 EP 1202-37 Revision 28 page 5.0 item 9d, quantitatively defines a "sustained loss of seal injection" in terms of actual time.
Who will make the decision to trip the RCPs? Also, on
.c
'page 6.0 of this procedure item lim, what is the physical indication that RC-V-1 has failed open?
I
Response
Item 9d on the loss of seal injection and tripping the RCP's has been removed from the procedure based on the ability to maintain or immediately restore seal injection. This change was made in a subsequent revision of EP 1202-37.
A "sustained loss of seal injection" meant the inability to immediately restore flow from the Remote Shutdown Panels.
The ability to restore thermal barrier cooling by reopening intermediate cooling valves IC-Y-3 and IC-Y-4 from the Remote Shutdown Panels was provided by a modification implemented during the 7R refueling outage. The Shift Supervisor or Shift Foreman would make the decision to trip the RCP 's.
In the latest revision of EP-1202-37, Item 11m referenced in the above question is now Item 13.K, however there is no change to the action. The primary indication that RC-Y-1 has failed open would be a rapid depressurization of the RCS.
RC-V-3, which is normally open, would have been closed prior to this step in the procedure to mitigate RCS depressurization.
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Question 3.
In your submittal 5211-87-2028 dated February 10,1987 (page 7 in your response to item 8G) provide a schedule for performing adequate acceptance tests of alternate shutdown capability.
Response
The remote shutdown integrated test was performed at THI-1 prior to criticality for Cycle 6 operation on March 22, 1987. The test description was previously submitted via GPUN letter 5211-87-2025, dated February 19, 1987.
The objective of the test was to demonstrate the ability of Operations personnel to transfer plant cooldown control from the Control Room to the Remote Shutdown Panel and maintain stable hot shutdown conditions at approximately 532*F. Reactor Coolant System temperature was then reduced arproximately 30*F and maintained for 30 minutes using remote shutdown system controls.
Prior to the integrated test, the following tests were perforned:
- remote shutdown comtunication system test
- adequacy of energency lighting to conduct remote scutdown activities
- individual control circuit tests for components t'
The test procedure and results are available for your review at the site. Acceptance of the test performed is documented in NRC Inspection Report 87-09, dated June 23, 1987 (5211-87-3135).
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Question 4.
In Table 3 of 5211-87-2028, for fire area CB-FA-3c, two manual actions are identified es required within 30 and 45 minutes.
These are open IC-Y-3 in area CB-FA-2d and close OH-V-5A in area AB-FZ-5. These two areas are the Control Building 322' East Inverter Room and the Auxiliary Building 281' General Area.
Provide a manpower-time study to show that sufficient manpower is available to perform these two manual valve actions within the required time limit for a fire in CB-FA-3c.
Response
On February 5,1987, a presentation was made to NRC showing results of actual walkdowns of worst-case manual actions.
Slides used for the presentation are attached.
Note that a single operator was able to perform the actions with a considerable margin of safety.
Exemptions for the manual actions were subsequently granted by NRC in their letter dated 3/19/87.
GPUN considers the two manual actions identified above to be bounded by the previously evaluated manual actions since:
- 1. For a fire in CB-FA-3c, the ESAS Room (Elev. 338'-6") does not have to be entered. The IS Swgr. Room (Elev. 322 ') and the Technical Support Center (Elev. 322') will be used to establish remote shutdown "B" train availability.
- 2. The East Battery Charger Area (Elev. 322'), which is Fire Area CB-FA-2d is entered to open IC-V-3 using switch No.15 at panel EH-DPES-1E, and the operator then proceeds to AB-FZ-5 to close OH-Y-5A.
The previous walkdown demonstrated the ability of a single operator to leave the Control Room and perform operations in one area of Elevation 338'-6" and three areas of Elevation 322' in the Control Building, and complete an operation on Elevation 271' of the Auxiliary Building, all within 30 minutes. Actual walkdown time was 6.4 minutes.
The fire scenario for Fire Area CB-FA-3c may require leaving the Control Room, performing operations in three areas of Elevation 322' within 30 minutes and complete an operation on Elevation 281' of the Auxiliary Building in 45 minutes.
Thus, the time required for the manual actions simulated during the previous walkdown bound the scenario of manual actions required for a j
i fire in CB-FA-3c.
i In our letter 5211-87-2028 we indicated that for a fire in CB-FA-3c, the Control Room will not be abandoned. A senior l
reactor operator will remain in the Control Room, while operators are dispatched to the remote shutdown control stations.
Therefore, with one operator in the Control Room, and one at the I
remote shutdown panel, one operator can perform the manual operations in CB-FA-2d and AB-FZ-5.
This is within the existing Technical Specification manning requirements and the remote shutdown procedure based on the availability of five (5) operators (letter 5211-87-2028, response to Section 8, Item F).
Therefore, sufficient ranpower is available to provide the required manual actions for a fire in CB-FA-3c,
FH-F7-1 MANUAL ACTIONS (FUEL HANDLING BLDG. - GENERAL AREA - ELEV. 281')
i START: CONTROL Room (ELEV. 355')
PANEL ACTION TIME To ESAS ROOM (ELEV. 338'-6")
RSTSP A IC SYSTEM TRANSFER SWITCH 1.1 MIN.
To IS SWGR ROOM (ELEV. 322')
RSTSP B IC SYSTEM TRANSFFR SWITCH 480V ES BREAKFR FOR SWGR 480V ESVCC-1C POWER j
B TRAIN 1.8 MIN.
To IP SWGR ROOM (ELEv. 322')
480V ES BREAKER FOR
.3 MIN.
SWGR 480V ESVCC-1C POWER A TRAIN To TECH. SUPPORT CENTER RSP A IC-V-3 OPEN PUSHBUTTON (ELEV. 322')
AUX. RSP B IC-V-2 OPEN PuSHBUTTON IC-V-4 OPEN PUSHBUTTON
.7 MIN.
I To AUXILIARY BLDG. -
NR-V-18 OPERATE HANDWHEEL FOR NR-V-38 2.5 MIN.
HEAT EXCHANGER VAULT (ELEV. 271')
TOTAL TIME:
6.4 MIN.
-m m,
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i WORST CASE MANUAL ACTIONS ACTUAL WALK 00NN TIMES TIME FH-FZ-5 FH-Fi!1 REQUIRED A&B B&C
's.
,s '
s
,, /
A. EF-V-30s 20 MIN.
6.0 MINUTES B. IC-V-2,3,4 30 MIN.
6.4 MINUTES C. NR-V-18 30 MIN A & 8 REQUIRED FOR FIRE IN FH-FZ-5 8 & C REQUIRE 0 FOR FIRE IN FH-FZ-1
m Question 5.
On Page 11 of 5211-87-2028, item Id refers to three GPUN letters to the NRC. The folluwing questions apply to these letters.
GPUN letter 5211-87-2013 states that an overcurrent protection study of the B train of the 1E buses is applicable to the A train "be:ause both trains were designed, installed, and maintained to the same standards for identical loads."
In comparing these two trains, was the identical equipment (i.e. model, manufacturer, response characteristics, etc.) used for the same functions, l'
not, evaluate any effects on train similarity of such differenses.
Response
The Train A and Train B safety related 4160 volt and 480 volt distribution systems are comprised of similar equipment with respect to model, manufacturer, and rating. These two fully redundant auxiliary power systems serve the same functional mechanical component power demands.
The electrical auxiliary system characteristics and response to fault and overcurrent conditions are essentially the same for both A Train and B Train. The two additional studies mentioned in the referenced letter, which provide a conprehensive short circuit and coordination review of all TMI-1 unit cuses, demonstrate this fact. The results of the studies were provided to the USNRC by GPUN letter 5211-87-2070, dated March P0, 1987, t
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