ML20196J809
| ML20196J809 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 03/08/1988 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| GL-86-10, NUDOCS 8803150064 | |
| Download: ML20196J809 (95) | |
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TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 374o1 5N 157B Lookout Place
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MAR 08 FJ88 U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
20555 Gentlemen:
In the Matter of
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Docket Nos. 50-327 Tennessee Valley Authority
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50-328 SEQUOYAH NUCLEAR ?LANT (SQN) - APPENDIX R - REQUEST FOR ADDITIONAL INFORMATION
Reference:
TVA letter to NRC dated March 2, 1988 As requested in a telephone call with R. Pierson of your stafi, TVA is providing supp': mental information to support the responses provided in the referenced letter for questions 12 and 14.
If you have any question, please telephone M. R. Harding at (615) 870-6422.
Very truly yours, i
TENNESSEE VALLEY AUTHORITY i
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ridley, D ector l
Nuclear Licensing and Regulatory Affairs Enclosures cc: see page 2 r'
8803150064 880308 PDR ADOCK 0500 7
An Equal Opportunity Employer J
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Mr. K. P. Barr, Acting Assistant Director for Inspection Programs TVA Projects Division U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr. G. G. Zech, Assistant Director for Projects TVA Projects Division U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Sequoyah Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, Tennessee 37379 l
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SUPPLEMENTAL INFORMATION FOR QUESTION 12 TVA agreed to provide additional information to further address question 12 in a March 3, 1988 telephone conference call.
This response amends our previous response to TVA question 12,and the Appendix R Resolution Review Team final report response for issue A.10.
Specifically, TVA will address the following question:
Has TVA looked at the potential for single hot shorts on ungrounded DC circuits or common AC circuits in conformance with section 5.3.1 of G.L.86-10.
The March 2, 1988 response stated that cable-to-cable faults were not considered credible. That is an oversimplification of the analysis done for spurious (type II) interactions.
In fact, they were considered and dispasition was made by various methods.
Quality Information Release (QIR)
SQN EEB 84001R3 (pages 5 and 6) documents the type II associated circuits that require analysis and states TVA's position with respect to 3-phase hot shorts and ungrounded ac and de circuits.
This position was further incorporated into Design Criteria SQN-DC-V-10.7 (section 3.7).
Basically, these documents state that 3-phase and 2-wire ungrounded ac and de circuits, which require fire damage of two separate cables before a deenergized component can be spuriously actuated, are not associated circuits of concern. This directly conforms with Generic Letter (GL) 86-10, section 5.3.1, except for cases involving high/ low-pressure interfaces. This enclosure summarizes the evaluations that were performed and provides additional evaluation of the high/ low-pressure interfaces that may create a Loss of Coolant Accident (LOCA) if subject to spurious actuation.
In ecordance with the criteria of 10 CFR 50 Appendix R Section III.G.2, fire-induced failures causing spurious operation can occur in three ways:
hot shorts, open circuits, and shorts to ground.
Much of the SQN control circuit wiring is done with multiconductor cables. A hot short between any two or more conductors within a common cable jacket is considered credible. Consequently, if it was determined that such a short could cause unacceptable spurious operation, the cable is considered required for safe shutdown operation and must comply to the separation criteria of Appendix R,Section III.G.2.
Shorts between conductors of different cables are not considered credible except in the main control room, cable spreading room, and the auxiliary instrument room.
In these three areas, there is cable congestion as a result of numerous cables entering the main control board and I
the relay racks. Consequently, cable-to-cable shorts causing unacceptable spurious operation are considered credible.
For fires in these areas, alternate and dedicated shutdown capability is provided in accordance with Section III.L of Appendix R.
In other plant areas, cable congestion is not as great. Therefore, in random wir4 lay cable trays, it is considered highly unlikely that conductors of separa.e cables will cause spurious operation before shorting themselves out and tripping their respective breakers or fases.
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The issue of type II associated circuits has been the subject of considerable review by NRC. TVA provided additional information on the primary side interfacing system analysis for fire-induced spurious depressurization of the Reactor Coolant System (RCS) in a December 2, 1982 letter to NRC. A copy of that letter is included in attachment 1. provides a summary of the current evaluation fa-high/ low-pressure interfaces that may create a LOCA. Attachment 3 co.. ' h.~ a list of interactions related to the type II spurious analysis of high/ low-pressure interfaces. Attachment 4 contains portions of a IVA letter dated December 21, 1984, to NRC where TVA responded to NRC confirmation vf action letter dated August 10, 1984.,
"Interaction Identification," of that letter stated TVA's corrective actions for various type II associated circuit interactions. This December 21, 1984 letter also stated in Enclosure 1:
The spurious, type II, associated circuit analysis was performed by determining the components that must be prevented from spurious operation.
These components are listed in the Fire Shutdown Logic Diagram and Associated keys.
Cable separation was evaluated for these components on the color-coded l
drawings contained in enclosure 4.
Additional information is available in reference 3 with respect to RCS pressure b.undary isolation.
The interactions determined from this spurious evaluation are also included in enclosure 5.
Reference 3 mentioned above is the letter included in attachment 1.
The NRC inspected TVA's reevaluation of Appendix R from January 14-18, 1985, and documented the results in Inspection Report Nos. 50-327/85-01 and 50-328/85-01. With regard to the spurious signal concern, NRC stated:
A review of the licensee's spurious signal analysis was conducted to determine if the following conditions had been considered:
The false motor, control and instrument readings such as what occurred at the 1975 Browns Ferry Fire. These could be caused by fire initiated grounds, shorts or open circuits.
Spurious operation of safety-related or non-safety-related components that would adversely affect shutdown capability (e.g., RHR/RCS Isolation Valves).
The licensee's method for evaluation of fire induced spurious signals that could affect the circuits required to bring the plant to hot i
shutdown was reviewed.
The licensee has treated the spurious l
signal-affected circuits and circuits that could affect the shutdown logic path through spurious actuation due to fire damage as shutdown I
circuits. Therefore, these circuits were evaluated for interaction between redundant shutdown paths.
The circuits analyzed were control circuits that are powered f rom ungrounded ac or de power sources.
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The licensee intends to remove power and control voltages from several valves that could affect safe shutdown of a unit should they operate due to a fire induced spurious signal.
The impact of this action in relation to the operability of the unit has been assessed by the licensee and submitted to NRC.
The licensee's reevaluation and corrective action appears to adequately address the spurious signal ccnce rns.
These interactions were further reported in various Licensee Event Reports (LERs). NRC Inspection Report Nos. 50-327/87-41 and 50-328/87-41 closed variots items, including LER 327/84-49. The inspection report stated:
The Licensee in Enclosure 5 to their December 21, 1984, submittal analyzed the Appendix R discrepancies identified in the subject LER and identified the appropriate corrective actions to resolve these discrepancies in Interaction Study Nos. 2, 3, 4, 6, 10, 11, 12, 13, and
- 14. (underlined by TVA)
This inspection Report also closed LER 327/84-063 and stated:
In Enclosure 5 to the licensee's December 21, 1984 submittal, the licensee analyzed the Appendix R discrepancies identified in the subject LER and identified the appropriate corrective actions to resolve these discrepancies in Interaction Study Nos. 46, 47, 48, 49, 50, 51, 56, 58, and 59. (underlined by TVA)
Inspection Report Nos. 50-327/86-40 and 50-320/86-40 closed LER 327/84-074 and stated:
With respect to the above Appendix R discrepancies, the licensee, in tc their December 21, 1984 submittal, analyzed these discrepancies and identified the appropriate corrective actions to resolve them in interaction study Nos. 109, 110, 112, 113, 114, 115, 116, 117, 118, 119, and 120. (underlined by TVA) l Inspection Report Nos. 50-327/86-66 and 50-328/86-66 reclosed LER 327/84-074 l
and stated:
During normal plant operations, the subject valves are energized and
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upon a confirmed fire in the cable locations described in Interaction Study No. 120 the power to the subject valves will be removed.
The operator actions associated with this interaction study have been incorporated into the appropriate plant procedure. Therefore, this item remains. closed.
1 Collectively these inspections acknowledged that appropriate corrective actions had been taken associated with high/ low-pressure interface.
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NRC issued TVA a Notice of Violation on June 8, 1987, on the composite Appendix R deficiencies. TVA responded on July 10, 1987, to the Notice of Violation. NRC responded to our response on August 19, 1987, and stated:
We have evaluated your response of July 10, 1987, to our Notice of Violation, issued on June 8, 1987, concerning Appendix "R" deficiencies at your Sequoyah facility and found that it meets the requirements of 10 CFR 2.201.
With the exception of the 480-volt shutdown board room open head water spray system, your corrective actions have been verified through NRC inspection. We are in agreement that the open head water spray system modification must be completed prior to Mode 4.
Accordingly, this item will be examined during future inspections.
The open head water spray system modification was completed prior to SQN unit 2 entry into mode 4.
In sun: mary, it is importan t to note that the Appendix R reanalysis at SQN was done ir. the 1984/85 timeframe.
Corrective actions for identified interactions were submitted to NRC for approval and were subsequently approved and documented in various inspection reports. After the development of corrective actions and during the inspection process to close out these interactions, GL 86-10, "Implementation of Fire Protection Requirements," was issued and stated:
This package represents recent staff assessment of these questions and provides gJidance as to acceptable methods of satisfying Commission regulatory requirements.
Other methods proposed by licensees for complying with Commission regulations may also be satisfactory and will be considered'on their own merits.
(underlined by TVA)
TVA interpreted the generic letter to mean that the corrective actions previously submitted that were being approved by NRC were satisfactory. We believe that the intent of GL 86-10, has been met.
Section 8.14 of GL 86-10 stated that deviations are not needed to depart from guidance documents. TVA believes that the requirements of III.G.2 and III.L.7 have been met by considering hot shorts internal to a cable as credible and cable-to-cable hot shorts credible within the main control room, cable spreading room, and the auxiliary instrument room.
With respect to the specific guidance in GL 86-10, section 5.3.1, a preliminary evaluation was made of the Reactor Building and Auxiliary Building. This evaluation found only three areas where the cable-to-cable hot shorts scenario would have an impact on the analysis for unit 2.
- However, TVA's approach to resolution provides an acceptable level of protection that has been accepted by NRC.
See section IV of attachment 2 for additional information.
An additional question from NRC asked for the rationale behind the equipment selected for detailed separation analysis inside the Reactor Building.
This inforeation is provided in attachment 5.
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1 SUPPLEMENTAL INFORMATION FOR QUESTION 14 In response to NRC questions concerning fire dampers located in nonducted ventilation openings, TVA provides the following.
Three hour fire barriers that separate one path of safe shutdown components from its redundant path do not contain nonducted ventilation openings. All of the type ventilation openings of concern are located in 1-1/2-hour fire barriers and have one of the following features.
a.
Fire detection and automatic suppression exist on both sides of the barrier.
b.
Fire detection is on both sides; automatic suppression is on one side and manually actuated sprinkler system on one side.
c.
Fire detection and automatic suppression exist on one side.
The side without suppression or detection is either a tank room or a pipe chase.
Neither the tank room nor the pipe chase contains significant quantities of in situ combustibles.
d.
Neither side has suppression.
These rooms consist of tank rooms, pipe chases, or a nonrequired pump room.
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B ATTACHMENT 1 (A27 821202 013) 1 I
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A27 821202 013
':00 0:entnut."treet *cwor II December 2, 1982
'1 Dirtietor of Nucicar Reector Regulation Attentinn:
!S. E. Adensan, chief Licensing Brshch No. 4 Division of Licensing U.3. Nuclear Regulatory Cosaission Ve.shirgton, D.C.
20555
Dear !b. Adon5P.m:
In the Matter-of
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Docket Hos. 50-?27 Ter.nessee Val).e7 Authority
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50- W In resoonse to item 4 of your letter to it. G. Parris dated Nove.ber 1?,
1082, enclosed is additional infor=r. tion en ite-s esaoeint*d with the Secuoyah fire protection pr grats.
If you have any questiens concerning this matter, please get in touch with Charlie Mills at FTS B58-2694 Very tr017 yours,
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T!NMESSLT VALLET AUTHORITY
-L. H.' Mills, M nager
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Nuc1 car Licensing
-! 3;.. Sworn to n.d subscribed before toe
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U.G. Nuclear Regulatory Comission (Enclosure)
Perion II Atta: Mr. Jnnas P. O'Reilly Adninintrator 101 Marietta Street, Suite 3100 Atlanta, Georgin 30303 cc: See page 2
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Director of Nuclear Reactor Regulation Dece'Aer 2, 1982 cc (Enclosure):
ARM.9, 640 CS',2-C J. W. Anderson, 902 HBB-K H. N. Culver, 249A HBB-K E. J. Ford, Sequoyah-NRC H. J. Green, 1790 CST 2-C R. L. Lumpkin, 401 UBB-C J. A. Raulston, W10C126 C-K H. S. Sanger, Jr., E11B33 C-K F. A. Szczepanski, !!17 UBB-C COORDINATED: DiHeatheriv/EN DES, BErickson/NUC PR 4
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ENCLOSURE 4.
In many instances, one control / actuation signal will cause the
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actuation of several functional components. Verify that the
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depressurization of the primary side via interfacing system will not occur due to the actuation of system components resulting from the fire induced generation of spurious signals from associated circuitry. Your discussion should include the means of preventing RHR isolation valve actuation, uncontrolled letdown, pressurizer PORV actuation, or operation of any valve or comoonent which unuld prevent the system (s) from performinr, its functionni ob.jectives.
TVA Remoonse The following discunalons ident.ify potent.ini iteprmusurtant. inn guitha nn.1 address how each path is protected from fire generated spurious signals.
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Reactor Vessel Head Vent System Letdown The reactor vessel head vent systems (RVMVS) may become a RCS leakage path in the event of undesirable actuations of system components resulting from the fire-induced generation of spurious signals from associated circuitry. This path is blocked by normally-closed solenoid valves. However, if the valves were to spuriously open, due to the postulated fire, a 3/8-inch flow restrictor in the system piping would limit the flow to within the
~~ charging capability of the chemical volume control system (CVCS) see FSAR Section 15 3 1.1.
In the long term, flow may be - - - ~
terminated through the RVHVS by manually removing power from the valve solenoids. This action can be accomplished from outside containment.
CVCS charging'is assured ff either thn positive displacemant
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charging pump or one of the redundant centrifugal charging. pumps and the associated charging flow control valve,2 FCV-62-93 is available to allow flow to the RCS. Protective measures to assuro these functions in the event of fire are discussed in TVA's response to NRC ASB question 1 (see RCS inventory control discussicn) submitted to the NRC by letter from L. M. Mills to L.
S. Rubenstein dated October 23, 1979.
Hence, TVA is taking credit for the CVCS charging units to be l
available for making up the loss of reactor coolant by the RVHVS,
. Thus, depressurization of the RCS would not occur.
II.
RHR Letdown Path The RHR letdown line has motor-onerated flow control valves FCV-74-1 I
and FCV-74-2 arranged in series. If both of these isolation valves were to spuriously open due to signals produced by the postulated fire at power operations, the RCS, cou,ld depressurize through the RHR system.
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.l (Continued) b TVA's operating instructions and 20-foot separation crita La Tor the circuits of these isolation' <alves will prevent this path from depressurizing the RCS. When the plant starts up from a shutdown condition, existing procedures call for the operator to closs FCV-74-1 and FCV-74-2. The operator will then open the circuit breaker located between the motor starter and the valve :otor 480 volt circuit. This breaker will be locked in the open positien with a pad lock at any ti=e the unit is operating at power. The circuit breaker will not be reclosed until the.RHR system is required for use. Therefore, during times when the RHR system is not to be used, the valves will be protected against spurious actuat.ons in the control circuit, motor control station, junction box, 480V supply and the manual control switches in the MCR or ACR.
Also the power cables to the isolation ' valves meet the 20 feet separation criteria for.their routing between the locked-out circuit breakers and the valve motors. Consequently, both valves cannot be arrected by any single fire cVent.-
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Therefore, it is not credible to assu=e depressuri:ition of the RCS by this path.
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III. RCS Letdown Paths The RCS nor=al and excess letdown paths potentially could become depressurizatien paths due to undesirable openings of various cocbinations of letdown valves resulting from fire-induced generation of spuricus signals in associated circuitry. Flow within each letdown path is regulated by a series of air-operated flow control valves. An investigation was i=plemented to determine if' RCS depressurization could occur within either or both letdown paths by a single fire. The investigation indicated areas do exist where combinations of letdown valves may be affected by the postulated fire resulting in reacter coolant loss through one letdown path.
TVA considers that it is very unlikely for =ultiple spurious valve openings t.o occur in those pathn an a renuit of fire-induced shorts.
In the circutt for any particular valve there are two or three possible single shorts that would cause the valve to open, whereas there are at least twice as msny possible single shorts that would dinable thn circuit regardless or any other shorta and very many other single shorts that do nothing. Considering the relatively small number of single shorts and cc binations of shorts that cause valve opening in relation to the relatively large number of single shorts and combinations of shorts that prevent valve opening, it is unlikely that any particular valve will spuriously open and even less l
likely for a particular group of fail-closed type of valves to all l
spuriously open due to a common fire.
In reference to particular l
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possible depressurization paths, either the normal RCS or eibess letdown path must have at'least three separate valves to be opened simultaneously. ~ It is therefore very unlikely that either of these RCS letdown paths will become open due to' fire-caused spurious actuations.
IIcwever, should this unlikely event occur", adequate RCS makeup will be available. A single fire cannot cause the loss of RCS makeup (using the CVCS centrifugal charging pumps) and spuriously rpen a RCS letdown path. The charging of one centrifugal charging pump (CCP) is capable of limiting RCS depressurization for one open letdown path. (Neither letdown path, in the worst case, will pass more than about 200 gpm; from FSAR Figure 15.? 41, one CCP will maintain the RCS nese normal pressure for this flow rate. )
Addi tional makeup capablJ ity will bo penvided by I.hn redundant.
centrifugal charging pump or the CVCS poultivo displacement pump.
A discussion with regard to RCS makeup, RWST suction, and ECCS charging paths has been provided in the SCN safe. shutdown submittal dated October 1, 1981. In the longer term, flev =ay be terminated in the letdown paths following manual actions by the operators.
Therefore, it is not credible for significant RCS decressurization to _
occur through the letdown paths.
. IV.
RCP Seal Integrity In the event of loss of RCP seal cooling, rupture of the seals could occur and result in depressurization of the RCS through,the seals.
Maintaining the RCP seal's integrity is identified as a necessary function on the~ fire shutdown logie diagram (FSLD). Therefore, TVA is assuring that the RCP seal's integrity will be maintained by way or the chemical voluma control nystem (CVC31 or _the component cooling wa ter tiynt on (CC") na demor t bevt b.> t ow.
RCP seal integrity is maintained by the CVCS if either the positive displacement charging pump or one of the redundant centrifugal charging pumps and the associated charging flow control valve, FCV 62-91 is available to provide coolant to the seals. This arrangement will assure adequate coolant to the seals during normal operations..'. discussion of CVCS ceal cooling is provided in TVA response to NRC ASB Question 1 - submitted to the NRC by letter from L. H. Mills to R. S. Rubenstein dated October 23,147n.
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An alternate method of maintaining the RCP seal's integrity can be accomplished by providing coolant to the RCP thermal barriers with the CCS. The CCS supplies coolant to the RCP's thermal barriers during normal operation with the redundant set of thermal barrier booster pumps. Each booster pump is capable of supplying adequate flow to the RCP thermal barriers to maintain the integrity of the seals. A discussion of RCP thermal barrier cooling is provided in TVA's response to NRC ASB Question 1.
The components and their associated circuitry for the CVCS and CCS seal cooling paths discussed above, are located in the plant in a manner which will prevent one fire from terminating the function of both RCP seal cooling paths. Consequently, it is not credible to lose RCP seal cooling due to the postulated fire, thus preventing RCS depressurization by this path.
Note: The CVCS's and CCS's RCP seal cooling subsystems both function during normal operations of the plant.
V.
Pressurizer Relief Paths l
The pressurizer power-operated relief valves (PORVs) potentially could open RCS depressurization paths in the event of undesirable opening of these components resulting from fire-induced generation of spurious signals in associated circuitry. The pressurizer has two parallel, power-operated relief paths. Each path has a nor= ally closed, PORV and an upstream, normally open flow control valve (FCV).
Should a PORV open due to the effects,of a fire, the operator can terminate the event if either valve in the path is capable of being closed.
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l An investigation was implemented to determine if_the controls and wiring for the valves in each relief path comply with the 20-foot fire separation criteria. Unacceptable interactions were found to exist between the PORV and FCV in each letdown path. TVA will correct thit cond ition by corouting the portionn of wiring that do not comply to the 20-foot sepnration criteria, so no firo affecting this path will be encable of causing a RCS depressurization which cannot be isolated.
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ATTACHMENT 2 Evaluation of High/ Low-Pressure Interf aces That May Result in a LOCA I. Reactor Vessel Head Vent System (RVHVS)
The RVHVS consists of four parallel / series, 1-inch, solenoid-operated (fail closed /normally diosed) valves that are de powered from a 2-wire ungrounded circuit.
If the valves were to spuriously.open due to the postulated fire, a 3/8-inch flow restrictor in the piping will restrict the flow to within the makeup capability of the centrifugal charging pumps (CCP) and therefore will not result in a LOCA. Charging flow is ensured by the shutdown logic separation analysis. An analysis was done to evaluate III.G.2 separation of the paths necessary to isolate the RVHV path.
Interactions listed in Attachment 3 identify where there was inadequate separation and identified the corrective action necessary to disposition each interaction.
This corrective action relied upon the December 2, 1982 letter in attachment 1.
Further evaluation shows that only interactions 73 and 86 did not have a III.G.2 separated path.
In interaction 73 and 86, cables for all four RVHV valves interact.
If the spurious opening is due to internal hot shorts, the appropriate power supply fuse can be pulled by the operator to isolate the flow path.
With both positive and negative fuses pulled, it requires multiple cable-to-cable shorts of proper polarity are required to result in spurious operstion of both valves.
TVA determined that spurious actuations with the fuses pulled would be incredible.
Even if spurious operation did occur, it will not result in depressurization of the RCS because the shutdown logic separation analysis ensures a CCP is available for makeup.
Because two valves are in series, a single set of two hot shorts on this ungrounded de circuit from an external cable would not result in a loss of the high/ low-pressure interface.
This meets the intent of GL 86-10, section 5.3.1.
II. Residual Heat Removal (RHR) Letdown Path The 14-inch RHR letdown line from the RCS has two motor-operated valves, l
FCV-74-1 and -2, arranged in series.
When the RCS is at pressure such that a high/ low-pressure interface exists, operating instructions (GOI-1, part V.B. revision 71) call for these valves to be closed, deenergized, l
and the breaker padlocked.
Therefore, during the time a high/ low-pressure interface exists, the valves are protected from spurious operations.
Because two valves are in series, even a single 3-phase hot short will not result in a loss of the high/ low-pressure interface.
This mrits the intent of GL 86-10, section 5.3.1.
l III. RCS Normal and Excess Letdown The RCS normal letdown path consists of three boundary isolation valves in series to protect the high/ low-pressure interface. All of these valves are fail closed, ungrounded, de 2-wire circuits.
The normal letdown line has letdown orifices that limit the flow rate.
The excess letdown path has three similar isolation valves in series plus a 3/8-inch flow restrictor.
This flow restrictor, like that in the head vent system, limits the flow such that the CCP can supply the necessary makeup and the RCS will not depressurize and result in a LOCA. A CCP has been guaranteed by the safe shutdown separation analysis. Because three boundary isolation paths are available in each letdown line TVA considers it incredible for the high/ low-pressure interface to be defeated.
It would take two hot shorts of the proper polarity without grounding in each of these three boundary isolation paths to defeat the high/ low-pressure interface.
In addition, isolation of control air to containment would cause these valves to fail closed regardless of the number of hot shorts. This meets the intent of GL 86-10, section 5.3.1.
IV. Pressurizer (PRZ) Relief Paths The PRZ has two par'allel, power-operated relief paths. Each path has a normally closed power-operated relief valve (PORV) and an upstream, normally open, flow control valve (FCV). Should a PORV open because of the effects of a fire, the operator can terminate the event if either valve in the path is capable of being closed.
A III.G.2 separation analysis was conducted to ensure that for each credible fire scenario that could cause a PRZ PORV to spuriously open, the block valve would be available to isolate and terminate the blowdown.
Interactions were identified and are listed in attachment 3.
Inte' actions 112 and 113 were protected from spurious operation of the r
PORV by rerouting and wrapping. A further evaluation of interaction 109 (unit 1) determined that the PORV block valve could be closed from the remote shutdown panel by placing the transfer switch in auxiliary and closing the block.
Interaction 110 (unit 2) is the power feed to the PORV, and no hot shorts will cause spurious operation.
Interaction 111 was reevaluated, and it was found that 24 feet 10 inches existed between the redundant paths.
Intervening combustibles were addressed by an approved deviation request.
Interaction 114 (unit 2) was further evaluated and, along with two similar interaction in the Reactor Building annulus (reference attachment 5), were found to be the only three examples (excluding unit 1 annulus) where cable-to-cable hot shorts impactad the safe shutdown analysis.
Because these three examples are not in the main control room, cable spreading room, and auxiliary instrument room, they comply with our previously stated position on external hot shorts. This approach provides an acceptable level of protection that has been accepted by NRC.
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ATTACHMENT 3 Interactions Involving High/ Low-Pressure' Interfaces INTERACTION #
Components 13 Letdown (L)-
19
-48 L
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60
'L 63-L 65 L
73-L and Head Vents (HV) 74 '
HV 75
-L, HV
'77 L
85 L
86 L HV 87 HV 100 HV 101 L, HV 109 PRZ PORVS (PP) 110 PP 111 PP 112 PP 113 PP 114 PP 117 SG PORV, (SGP)
(note 1) 118 SGP (note 1) 120 VCT Outlet Valves (note 2)
NOTE 1: This interaction does not involve high/ low LOCA pressure interfaces but does involve type II spurious circuits. Additionally, as an enhancement, System Operating Instruction 26.2 will be revised to have fuses pulled or the transfer switch placed in auxiliary to reclose any spurious opened steam generator PORV.
NOTE 2: This interaction does not involve high/ low LOCA pressure interface but does involve type II spurious circuits.
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December 21, 1984 U.S. Nuclear Regulatory Commission Region II Attnt Mr. James P. O'Reilly, Regioral Administrator 101 Marietta Street, NW, Suite 2900 t
Atlanta, Georgia 30323 Dear Mr. O'Reilly
,. -m In acccedance with'.itou.,,, a t.
the Aus dt
~ 1084 Confi. nation of Action Lotter (COA) to H. G. Parris from you, we are submitting by the following molosures, information on implementation of Appendix A to 10 CFR Part 50 at the Sequoyah Ntelear Plant. The following enclosures complete the COA reporting mquiremerits:
, - Overview of Appendix R - Fire Shutdown Logio Diagrams and Associated Keys (4 copies) - Electrical Equipment Block Diagrams (4 copies)
' - Color-Coded Cable Location Drawings (4 copios) x - Interaction Identifiestion (4 copies) - Associated Circuit Analysis (4 copies) - Additional Deviations (4 copies) - Impicmontation Schedule If you have any questions, please get in touch with R. H. Shell at FTS 858-2688.
To the best of my knowledge I doolare the atatoments containcd herein are complete and true.
l Very truly yours, TE'iNESSSR VALLEY AUTHORITY J. A. Domer Nuolear Engineer Enclosures (3)
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Mr. Rictiard C. DeYoung, Director (Enclosures 1 and 8 only)
Office of Inspection and 3nforoceerst U.S. Nuclear Regulatory Comr.ission Washington, D.C.
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SEQUOYAH NUCLEAR PLANT AP?END1X R
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December 20, 1984 ENCLOSURE 1
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ACRONDS AB Auxiliary Building f.FW Auxiliary Feed Water AOI Abnormal Operating Instruction ATWS Anticipated Transient Without SCRAM AUX Auxiliary BD RM Board Room CCP Centrifugal Charging Pump CCS Component Cooling System C0A Confirmation of Action CRD Control Rod Drive CS Containment Spray DC Direct Current DCR Design Change Request DG Diesel Generator FCN Fngineering Change Notice N
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- .wential Raw Cooling Water FCR Field Change Request FCV Flow Control Valve HVAC Heating, Ventilation &. Air Conditioning HX Heat Exchanger DiST Instrument LCV Level Control Valve LO Lube Oil MOV Motor Operated Valve RCP Reactor Coolant Pump RCS Reactor Coolant System RHR Residual Heat Removal SCRAM Safety Control Rod Axe Man S/D Shu tdown S.G.
Steam Generator S.G. DIV CONT Steam Generator Inventory Control TBBP Thermal Barrier Booster Pump UL Underwriter's Laboratories WP Workplan This enclosure provides a brief overview of the Appendix-R project at Sequoyah Nuclear Plant and refers to additiomi enclosures in crder to coordinate the input from the numerous disciplines and organizations involved in this project.
References 1.
Letter from L. M. Mill a to E. Adensam dated October 1,1981 2.
Letter from L. M. Mills to E. Adensam da ted March 3,1982 3
Letter from L. M. Mills to E. Adensam dated December 2,1982 4.
Letter from L. M. Mills to E. Adensam dated May 27, 1983 5.
Letter from you to H. G. Parris dated August 10, 1984 6.
Letter s' rom L. M. Mills to you dated August 20, 1984 7.
Letter from Richard C. Lewis to H. G. Parris da ted August 28, 1984 8.
Letter from L. M. Mills to you dated September 14, 1984 9
Letter reem L. M. Mills to you dated September 20, 1984 10.
Letter from Richard C. Lewis to H. G. Parris dated September 25, 1984 11.
Letter from L. M. Mills to you dated October 15, 1984 f
12.
Letter from J. A. Do=er to you dated November 9,1984
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13 Letter from John A. Olshie. ski to H. G. Parris da ted November 14, 1984
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- 14. Letter from J. A. Do=er to E. Admsam dated December 18, 1984 y
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Ovxrview Sequoyah unit 2 lic nsa condition 2.C(13)c, requires compliance with ssetion III.0, III.J, III.L, and III.0 of 10 CFR 50 Appendix R.
On October 1,1981, TVA submitted a report (reference 1) to NRC as mquired by the license condition.
Subsequent mquests by NRC resulted in additioml information being supplied in-references 2, 3, and 4 As a result of additiomi clarifications by NRC (in the form of workshops, generic letters, etc.) and TVA findings at Watts Bar Nuclear Plant before that inspection, Sequoyah Nuclear Plant assigned an Appendix R Project Marager (ARPM) to I:nnage the Sequoyah effort and attend the Watts Bar inspection (week of July 16, 1934).
Following the Watts Bar inspection, the ARPM met with Sequoyah Mamgement on July 23, 1984, and presented a methodology for evaluating Sequoyah's compliance with Apnendix R and the specific Watts Bar deficiencies.
On July 26, 1984, NRC requested a meeting with TVA in Atlanta to discuss the
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status of compliance with Appendix R at Sequoyah. This led _to,the COA letter (reference 5) and. an excedited myiew if sequoyah '.* compliance wi tt Appendix R, Requirements of the COA letter-were a oy rsferenues 6, 8,. 9,- 11,
.2, and this report completes the reporting mquired by the COA letter.
Section ITI.G Separation of cables and equipment of redundant divisions to msure one division necessary for hot standby is free of fire damage is the bulk of the amlysis requirements for Sequoyah. Systems. mquired for cold shutdown will be either free of fire damage or capable of being mpaimd within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Operating procedures will address manual operation of all valves for cold shutdown and casualty procedures will address mpair of cabling to the RHR pumps, room coolers and various cold shutdown valves. The fire shutdown logic (SDL) was developed to define safety functions and sets of equipment mquired to a:hieve' safe shutdown conditions under postulated fire conditions. The logic diagram is assisted by keys detailing the redundant paths / equipment mquired to achieve safe shutdown and is includd as Enclosure 2, "Fire Shutdown Logic Diagram and Associated Keys".
Cable identification for equip =ent listed in the keys contained in enclosure 2 are includd in block diagram form as Enclosum 3. "Electrical Equipment Block Diagrams ". Physical cable location drawings were prepamd and evaluated. These drawings are included as Enclosum 4, "Color-Coded Cable Location Drawings".
Field verification of actual equipment location was performed where necessary to assure separation. Specific cable interaction identification sheets were prepared for locations where redundant divisions were tot separated in accordance with section III.G.2 requirements. These specific cable interaction idmtification sheets are included as Enclosure 5, "Interaction Idmtificati 6".
When the corrective action for an interaction specifies wrapping in a fire barrier, TVA shall utilize an approved barrier such as Thermal Science, Inc.,
Thermo-lag 330-1.
The spurious, type II, associated circuit analysis was performed by determining t
the components that must be prevented from spurious operation. These components are listed in the Fire Shutdown Logic Diagram and Associated keys (Enclosum 2).
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C1blo s2paration was ovaluated for thasa components on the color-codM drawings If contained in onclosure 4.
Additiomi information is available in refcrenes 3 with respset to RCS pressure boundry isolation.
The interactions determined from this spurious evaluation are also included in enclosure 5.
<j The type I common power supply ard type III common (nclosure associated circuit arnlysis is su=marized in Enclosum 6, "Common Power Supply (Type I) and Co : mon Enclosure (Type III) Associated, Circuit Analysis."
Additiorni deviation were submitted to NRC-NFR by reference 14 and are. included as enclosure 7.
These deviations mvised and supplemented nferences 1, 2, 3, and 4.
Doors in the auxiliary building were walked down and inspected to the Underwriter's Laboratories (UL) configuration using the guidelines from the Watts Bar 01, inspection. Approxi=ately 37 doors were found to be ron-functiomi --
and others deviated. fro:n NFPA-80 and UL guidelines.
,. e The existing sprinkler system in the auxiliary builC_ug has been walked down it, areas containing both mdundant divisions and evaluated against specific NFPA-13 criteria and an intervening criteria (reference 14). TVA has idmtified approximately 770 sprinklers that will require minor relocation, plugging, etc.
and approxi=ately 220 sprinklers that must be added to address obstructions to floor coverage and the intervening combustible criteria.
Section III.J
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The new expanded Fire Shutdown Logic has identified additiorni plant areas where operator action is mquired.
Consequently, additiorni emergency lights will be required in these areas and in access / egress routes. Some of the emergency lights were found to have 25 watt lamps; 10 watt lamps are required in crder to obtain an eight hour capacity. Design Change Request (DCR) 2075 will handle the changeout of 25 watt lamps with 10 watt lamps and will add over fifty additiomi light packs in various plant areas.
As an 12.terim measure, portable lanterns have been suppliM to the operations staff for use in the event the rormal lighting, standby lighting (onsite powered) and DC lighting (station batt ries) syste=s fail.
After installation of the additiornl lights, adequate lighuing levels will be verified.
Section III.0 The drain piping located between the oil collection basins (around the pu=p) and the containment floor (oil drains to the auxiliary mactor building sump), is des'gned to category I(L) require =ents so the piping will not c 11 during a safe shu ;down earthquake and damage nuclear safety-related equipmenu The drain pip.ng has not been designM to cnintain its pressure boundtry integrity after a safe shutdown earthquake. The reactor coolant pump (RCP) lubricating oil syste=s are designed with the capability for withstarding a safe shutdown ear thquake.
The RCP cotors, the lubricating oil syste=3, and the containment su=p are all designM to seis=ic category I requirecents so they will not fail during a safe shutdown earthquake. Therefore, random oil leaks are rot assumed to occua uiraaltaneously with a seis=ic event.
It is TVA's position that the total system provides more than reasornble assurance that a RCP lubricating oil fire will not occur as a result of a seiscio event. Assuming only a single
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failure, the oil collection system would only be required to hold the oil' 73
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retrulting from the largest spill due to a single failure. The largest singlo fcilure is assumed to bs tha rupture of tho upper bsaring oil system of ona RCP, which contains 240 gallons of oil.
Sinca ths initial design of the RCP oil colle.ction system, modifications have been cnde due to other commitments and safety issues which mduced the volume available for oil collection. As a re sult, the auxiliary mactor building sump does not have adequate capacity to hold the oil from all four RCPs. The sump hold approximately 200 gallons and the connecting embedded piping systems hold approximately 140 gallons for a total of 340 gallons of capacity. Annunciator response instructions have been revised and a night Tder issued to requim the operator to pump the sump down in the event of a RCP high/ low reservoir alarm in mder to msure adequate capacity is available for oil collection.
In the unlikely 'evmt that the sump is fbil of water, no core than 100 gallons of oil would backup through floor drains. This quantity of oil on the containment floor will mt come in contact with hot piping e other ignition sources.
The sump vents do not require the installation of flame arresters because the high flashpoin' *ihrac tt. StSs MO degrees F) of the reactor coolant pm b^e oil preclude the liazard a rire fiashback.
A deviation has been submitted based upon the existing system, as described above, providing equivalent protection.
Modification Imolementation Schedule An implementation schedule guideline. is included in Enclosum 8, "Implementation Schedule." The dite given for each modification category is the anticipated completion dite and is subject to change without mtice; however, the final deadline of June 30, 1986 will not be extended without rutifying NRC. These cates are subject to cnterial deliver" schedules and may mquire revision if vmdors slip their delivery da tes.
Installation of nuclear instrumenttion will be subject to the Regulatory Guide 1.97 Revision 2 cor.mitments.
This implementation schedule has been carefully developed consistent with other safety requirements in & der to cnke all modifications as expeditiously and safely as possible.
It has been coordinated tc preclude affected component operabilir,y, technical specification conflicts, ard access lic:itations.
Compensatory Measures Three roving, and one fixed firewatch, continue surveillance of selected areas l
in the auxiliary building, control building, turbine building (station air i
compressors), diesel gmerator building, and essential raw cooling water pumping station.
The roving firewatch is required to cover all his assigned areas at u
least once per hour, and documents it in accordance with OSLA-73 Physical e
Security Instruction (PHYSI) 13 controls the introduc tion of transient fire loads into any safety-related areaa. The safety staff reviews, specifies controls and authorizes introduction of transient fire loads into all safety-I related areas and r:Linimizes these transient Tim loads at locations of cable l
interac tions.
The firewatches cover areas of the plant containing items of l
known noncompliance plus areas containing items of potential rencompliance.
No areas have been found containing interactions that were rot already covered by an existing fim-watch.
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Twslvs ble lanterns have been provided in cabinats outside the auxiliary control room and outsido the shift engineer's offico for use as smergency lighting until additiorni 8-hour battery pack lights are added and existing battery packs are upgraded in specific plant areas idattified by the new shutdt.,wn logic as mquiring operator action /cgress/ access.
_ Conclusion Ihis mport concludes the reporting mquimd by the Confircation of Accion letter (reference 5).
Upon completion of the corrective actions defined by this report ard approval of applicable deviations, Sequoyah Nuclear Plant will be in co:spliance with sections III.0, III.J, III.L, and III.0 of 10 CFR 50 Appendix R.
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1 SEQUOYAH NUCLEAR PLANT
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APPENDIX R Implementation Schedule e
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Interaction Number:
13 Safety Function / Unit:
Onsite Electrical Supply / Unit 2
.RCS Inventory Control / Unit 2 As'sociated Interaction No(s):
NA Associated Safe *.y Function (s):
NA Location:
Auxiliary Building, El. 759, Unit 2 CRD Equipment Roon
==
Description:==
Train A 480V cables.2PL4975A and 2PL4978A from the 2Al-A and 2A2-A 480V S/D BDs to the diesel generator auxiliary boards and RCS inventory Control normal letdown valve cables 2V2782A, 2V2780A, 2V4425A, 2V4437A,.2V4477A, 2V4492A, and 2V4509A.
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Interact with: Train B 480V cables 2PL4982B rad 2PL4985B from the 2B1-B and 2B2-B 480V S/D BDS to the Diesel Gen Aux BdS sad the 6900V cables PP590B, PP591B, PP710B, PP711B, IPP820B, 2PP820B to Diesel Generators IB and 2B and pressurizer heater transformers IB-B and 2B-B.
Corrective Action: TVA will reroute the cables in conduit and wrap the train l
l A cables (2PL4975A and 2PL4978A) as they traverse this room. The cables will be wrapped in a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> fire barrier.
DCR 2133 will handle this modification.
Isolation of the RCS pressure boundry was addressed in a December 2, 1982 letter from L. M. Mills to E. Adensam. An additional 1
review of these paths verified that RCS depressurization is not credible through normal letdown since three paths are available for isolation.
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Interaction Number:
19 F
I(J Safety Function / Unit:
RCS Inventory Control / Unit 1 Associated Interaction No(s):
None Associated Safety Func* tion (s):
None I
Location:
Area l':
Auxiliary Building, El 714, Common Area (A6/Q line)
Area 2: Auxiliary Nuilding, El 734, Aux. Control Inst. Raos Area 3: Auxiliary Building, El 734, Aux. Control Roon
==
Description:==
An interaction exists at the above three locations for all paths identified to accomplish isolation of normal letdown. This is neces,sary for RCS pressure boundary s/
isolation. The following cables interact at the above locations.
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(1) Elevation 714, Common Area (A6/Q Line)
Path 1: FCV-62 IV4423A Path 2: FCV-62 IV4435A Path 3: FCV-62 IV4473A FCV-62 IV4488A FCV-62 IV4503A Cables routed from 714 up into panel 1-L-11A in A x. Cont.
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19 (Continued) l((m -
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Description:==
(Continued)
(2) Elevation 73,4, Auxiliary Control Instrument Room 1A
> Path 1: FCV-62-69 -154420A,IV442kA, IV4425A, IV4423A
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Path 2: FCV-62 IV4432A, IV4433, IV4437A,.1V4435A Path 3r FCV-62 IV4470A, IV4471A, IV4473A, IV4477A, IV4472A FCV-62 IV4486A, IV4487A, IV4488A, IV4485A, IV4492A FCV-62 IV4500A, IV4501A, IV4502A, IV4503A, IV4507A Cables routed from the 1-L-11A panel into the auxiliary control.
room (3) Elevation 734, Auxiliary control room Path 1: FCV-62 IV4420A, IV4421A, IV4425A Path 2: FCV-62 IV4432A, IV4433A, IV4437A Path 3: FCV-62 IV4470A, IV4471A, IV4472A*, IV4477A
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FCV-62 IV4486A, IV4487A*, IV4485A, IV4492A FCV-62 IV4500A, IV4501A, IV4502A*, IV4507A Cables are routed from the auxiliary control instrument room into the 6.9 kV shutdown board room A, except for those marked with an asterick. The cables marked with an asterick are routed from the auxiliary control instrument room into the 1-L-10 panel.
Corrective Action:
Isolation of the RCS pressure boundry was addressed in a December 2, 1982 letter from L. M. Mills to E. Adensam.
An additional review of these paths verified that RCS depressurization in not credible through normal letdown since three paths are available for isolation. This
's item is closed.
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Interaction Number:
48 Safety Function / Unit:
RCS Inventory Control / Unit. 2 Associated Interaction No(s):
None Associated Safety Function (s):
None Location:
Auxiliary Building, Elevation 749, 480-V Transformer, Room 2A.
==
Description:==
The B train cables 2V2240B, 2241B (2-FCV-62-99);
2V2100B, 2?.01B (2-LCV-62-136); 2V2320B (2-FCV-63-6);
2V4934B (2-FCV-63-24); 2V2840B, 2842B (2-FCV-74-2);
f 2V4371B (2-FCV-62-55); 2PM132 (2-FCV-62-56) interact with A train 480-V Transformer and associated circuits.
t Corrective Action:
(1) Cables associated with 2-FCV-62-99 will have power removed per ECN 6253.'
(2) Cables associated with 2-LCV-62-136, 2-FCV-63-6 requires no protection. Manual operation of i
l 2-LCV-135, -136 is available.
(?T Cables associated with 2-FCV-63-24 require no p ro t e c t. ion.
They are not needed in this 1
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Interaction Number:
48 (Continued)
Corrective Action: -(Continued)
(4) Cables associated with 2-FCV-74-2 do not
'a-require protection.
Power is removed from 2-FCV-74-2 per GOI-1. '
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(5) Cables associated with 2-FCV-62-35, -56, do not require protection. 2-FCV-62-54 is still,
available to satisfy excess letdown isolation.
In conclusion, removing of power from FCV-62-99 will resolve this interaction.
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Interaction Number:
60 I,,.
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Safety Function / Unit:
RCS Inventory Control / Unit 1 4
Associated Interaction No(s):
None Associated Safety Function (s):
None Location:
Area 1: Aux Bldg El 714, common area (AS-A8/Q-R)
Area 2: Aux Bldg, El 734, Auxiliary control room Area 3: Aux Blds, El 734, Auxiliary Control Instrument Room
==
Description:==
Cables for all three identified paths to isolate excess letdown interact at the above locations. This is necessary C
to achieve RCS pressure boundary control. The following
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cables interact at the above lopations.
1)
Elevation 714, condon area (AS-A8/Q-R)
Path 1: FCV-62 IV4414 Path 2: FCV-62-55
'1V4370 Path 3: FCV-62 IPV56 2)
Elevation 734, Auxiliary Control Room
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Path 1: FCV-62 IV4413 Path 2: FCV-62 IV4367 Path 3: FCV-62 1PM133 3)
Elevation 734, Auxiliary Control Instrement Room Path 1: FCV-62 IV4411, IV4412, IV4413, IV4415 Path 2: FCV-62 IV4369 Path 3: FCV-62 1PM132, IPM133, IPM134 l
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,s-Interaction Number:
60 (Continued) lF k
Corrective Action:
Isolation of the RCS pressure boundry was addressed in,
a December 2, 1982 letter from L. M. Mills to E. Adensam.
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' tan additional review of these paths verified that RCS depressurization is not credible through excess letdown
<since three paths are available for isolation. This item ic closed.
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4 Interaction Number:
63 Safety Function / Unit:
RCS Inv Cont / Unit 1 Associated Interaction No(s):
78 Associated Safety Function (s):
Onsite Electrical Supply Location:
Auxiliary Building, El. 734, 6900V Shutdown Board Room A,
==
Description:==
An interact. ion exists at the above location for all paths identified to accomplish isolation of normal letdown. This is necessary to achieve RCS Pressure Boundary Isolation The following cables interact:
)
Path 1 - IV4420A, 4421A, 4425A (FCV-62-69)
Path 2 - IV4432A, 4433A, 4437A (FCV-62-70)
Path 3 - IV4470A, 4471A, 4477A (FCV-62-72)
IV4485A, 4486A, 4492A 'FCV-62-73)
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IV4500A, 4501A, 4507A (FCV-62-74)
The cables are ro ated from the auxiliary control instrument room through the auxiliary control room and into the 6.9 kV shutdown board room A.
This interaction is for the shutdown board room only. Other rooms are addressed in different interrations.
Corrective Action: ' Isolation of the RCS pressure boundry was addressed in a December 2, 1982 letter from L. M. hills to E. Adensam. An additional review of these paths verified that RCS depressurization is not credible through normal letdown since three paths are available for isolation. This item is closed.
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65 C
Ik Safety Function / Unit:
RCS Inv Cont / Unit 1
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Associated Interaction No(s):
None Associated Safety Function (s):
None _
Location:
Auxiliary Building, El. 734, 480V Shutdown board rm IB-2B, A3-A4/Q-R line and elevation 734, 125V vital battery board room I
==
Description:==
An interaction exists of the above location for all paths identified to accomplish isolation of normal letdown. This is necessary to achieve RCS pressure boundary isolation. The following cables interact:
Path 1:
IV4420A, 4421A (FCV-62-69)
Path 2:
IV4433A, 4432A (FCV-62-70)
Path 3:
IV4470A, 4471A (FCV-62-72)
IV4485A, 4486A (FCV-62-73)
IV4500A, 4501A (FCV-62-74),
, These cables are routed from the auxiliary control instrument room through the auxiliary control room, 6.9 kV shutdown board room A 480V shutdown board room IB-2, and into the l
125V vital battery board room I.
Cables routed through the i
auxiliary control room, auxiliary control instrument room, and 6.9-kV shutdown board room are addressed in other interactions.
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Interaction Number:
65 (Continued)
Corrective Action:
Isolation of the RCS pressure boundry was addressed in a December 2, 1982 letter from L. H. Mills to E. Adensas.
An additional review of these paths ve'rified that RCS depressurization is not credible through normal letdown since three paths are available for isolation. This item is closed.
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- .s Interaction Number:
73 o(
Safety Function / Unit:
RCS Inventory Control / Unit 2
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Associated Interaction No(s):
None Associated Safety Function (s):
None Location:
Auxiliary building, Elevation 734, EGTS Room.
==
Description:==
The following B-Train cables 2V4934(2-FCV-63-24);
2V5131(2-FCV-63-174); 2V2840B, 2842B(2-FCV-74-2);
2V5661B(2-FSV-68-395); 2V5665B (2-FSV-68-396);
2PM132(2-FCV-62-56); 2V4371 (2-FCV-62-55);
2V4461(2-FCV-62-85) interact with the following A-Train cables 2V5681A(2-FSV-68-394); 2V5685A (2-FSV-68-397).
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Corrective Action:
1, Cables associated with 2"-ECV-63-24 and 174 i
and 2-FCV-62-85 do not require protection.
These cables are not necessary te satisfy RCS Inventory Control in this interaction zone. Cables associated with FCV-63-24
^
and 174 have been deleted from Shutdown Logic.
l l
2.
Cables associated with 2-FCV-74-2 do not l
l require protection; 2-FCV-74-2 is deenergized i
per GOI-1.
i t
.s
a s
E so
.. w Interaction Number:
73 (Continued) x 3.
Cables associated with 2-FSV-68-395,-394,-397
.do not require protection.
Isolation of the RCS pressure boundry was addressed in a December 2, 1982 letter from L. M. Mills to E. Adensas. An additional review of these paths verified that
..RCS depressurization is not possible thro 23h the, reactor head vent system.
1 4... Cables associated with 2-FCV-62-55, 56 do not require protection. 2-FCV-62-54 is still available to isolate excess letdown.
i In conclusion, no modifications are. required to resolve this interaction. This item is closed.
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Interaction Number:
74
(
Safety Function / Unit:
' RCS' Inventory 'Contirol/ Unit 2
.~
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n.
.i.n Associated Interaction No(s):
23, 2
.,,.v.
s.
Associated Safety Function (s): ~
ERCW,'Onsite Electrical Supply Location:
Auxiliary, Elevation 734, 6900-V Shutdown Board Room Train B.
==
Description:==
The following A Train cables: 2PL3003A (CCP Rm Cooler A-A); 2PL6145A (CCPA-A Aux. Oil Pap): 2PL6148A, 6149A (CCP A-A Aax. Oil Pap); 2V2235A (2-FCV-62-98); 2V2422A, 2423A, 2425A (2-FCV-67-146); 2V2073A (2-LCV-62-135);
2V2329A (2-FCV-63-7); 2V2787A (2-FCV-74-1); 2V5681A (2-FSV-68-394); 2V5685A (2-FSV-68-397); 2PL6123A (RCP TBBP A-A); 2V2295A (2-FCV-70-143) interact with i
the "B" 6900-V Shutdown Boards and associated cables.
Corrective Action:
1.
Cable (2PL3003A) associated with CCP Re Cooler A-A will be rerouted.
2.
Cables associated with the CCP Aux. Lube Oil pump do not require protection. A bypass switch will be installed allowing the CCP to be started without the CCP Aux. Lube Oil 3
pump running.
T*
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Interaction Number:
74 (Continued)
Corrective Action:
(Continued) 3.
Cables associated with 2-FCV-67-146 do not not require protection, because it may be manually operated.
4.
Power will be removed from cables associated with 2-FCV-62-98.
5.
Cables associated with 2-LCV-62-135 and 2-FCV-63-7 require no protection. 2-LCV-62-135.
-136 can be manually operated, if required.
6.
Cables associated with 2-FCV-74-1 require no protection. Power is removed per GOI-1.
C, 7.
Cables'asso,ciated.with 2-FSV-68-394, -397 do not require protection.
Isolation of the RCS Pressure Boundry was addressed in a December 2, 1982 letter from L. M.' Mills to E. Adensas.
r.
An additienal review of these paths verified that RCS depressurization is not possible through the reactor head' vent system.
8.
Cables associated with RCP TBBP A-A and 2-FCV-70-143 require no protection. They are not necessary in this interaction zone to
' satisfy RCS Inventory Control.
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Interaction Number:
75 Safety = Function / Unit:
RCS Inventory Control / Unit 2 v.....
... -..n. :c <...
o.,
.. c As'sociated Interaction No(s): -
. 23p 79.
..o
-..h.
.u Associated Safety Function (s):
ERCW,-Onsite> Electrical Supply.-
Location:
Auxiliary Building, Elevation 734, 480-V Shutdown Board
~
Room 2A2-A.
==
Description:==
B train cables 2PL3013B (CCP B-B Pop Cir); 2PL6152B (CCP B-B Aux. Lube Oil Puep); 2PL6155B, 6156B (CCP B-B Aux. Lube Oil Pump); 2PP562B (CCP B-B); 2PPS64B, 566B, 568B (CCP B-B); 2V2243B (2-FCV-62-99); 2PM108, 110 (2-FCV-62-93); 2V2103B (2-LCV-62-136); 2V2323B (2-LCV-63-6);
2V2690B (2-FCV-63-25); 2V2706B (2-TCV-63-40); 2V4793B, 4794B,'(2-FCV-63-41); 2V2847B (2-FCV-74-2); 2V5661B (2-FSV-68-395); 2PM134 (2-FCV-62-56); 2V4411 (2-FCV-62-54);
2V4412 (2-FCV-62-54); 2V4367, 4368 (2-FCV-62-55); 2PL6131B, 6133B, 6134B (RCP TBBP B-B); 2V4757B, 4458B (2-FCV-62-85) interact with 480-V Shutdown Boards (A Train) and associated A train cables.
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Interaction Number:
75 (Continued)
Corrective Action:
1.
Cables associated with the CCP Aux. Lube Oil pump do not require protection. A bypass switch will be installed allowing the CCB to be started without the CCP Aux. Lube 011 pump running.
, 2.* CCP 2B-B cables and room cooler esbles must be protected. The modification required for interaction No. 23 part I will provide the necessary separation.
~
3.
Cables for valves 2-FCV-62-54, -55, -56 do not require protection. Isolation of the RC3 pressure boundry was addressed in a December 2, 1982 letter from L. M. Mills to E. Adensam.
(s/
An additional review of these paths verified that RCS depressurization is not credible for excess letdown since three paths are available for isolation.
4.
Cables for TBBP 2B-B are not required to satisfy l
this safety function at this location.
5.
Cables for 2-FCV-63-25, '-40, -41 are not required to satisfy this safety function at this location.
l 6.
Cables for 2-FCV-74-2 do not require protection.
l Power is removed per GOI-1.
l 7.
Cables for 2-FCV-62-85 are not required to satisfy this safety function at this locati.>a.
' * ^
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Interaction Number:
75 (Continued)
,,.,..,-..c....
.g.-
8.
Cables'.'for 2-FSV-68-395 do not, require. protection, 2-FSV-68-396 and -397 are available, to provide isolation. _ Isolation of:the RCS, pressure boundry was. addressed in a December 2,,1982. letter from L. M. Mills to E. Adensam. An additional review of these paths verified that RCS depressurization is not possible through the reactor head vent system.
- 9. Cables associated with 2-FCV-62-99 will have power removed.
- 10. Cables associated with.2-FCV-62-93 do not require protection. 2-FCV-62-526, -534 can be manually operated to provide an alternate flow path.
- 11. Cables associated with 2-LCV-62-136 and 2-FCV-63-6 do not require protection.
2-LCV-62-135, -136 can be manually operated, if necessary.
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s Intert: tion No:
77 s
Safety Function / Unit:
Unit 2 RCS Inv. Control e.
Associated Interaction No(s):
97 Associated Safety Func* tion (s):
Onsite Elec. Supply Location:
Aux Bldg.'Elev. 734; (1) Battery Board Rm III, (2) Aux Control
~
Room, (3) Aux Control Room Inst Rm 2A, (4) 6.9 kV S/D Bd Rm Train A.
Aux Blds, Elev 749; (5) 480V Rx Mov Bd 2A, (6) 460V Rx ifov Bds IA.
Aux Blds, Elev 759; (6) CRDM Room.
==
Description:==
The foliowing cables 2V4413 (2-FCV-62-54); 2V4369 (2-FCV-62-55);
2V4420A, 4421A, 4422A, 4423A, 4425A (2-FCV-62-69); 2V4432A, 4433A, 4434A, 4435A, 4437A (2-FCV-62-70)'; 2V4470A, 4471A, l
4472A, 4473A, 4477A (2-FCV-62-72); 2V4485A, 4486A, 4487A, 4488A, 4492A (2-FCV-62-73); 2V4500A, 4501A, 4502A, 4503A, 4507A, (2-TCV-62-74); 2PM133 ((2-FCV-62-56); 2PL6123A (RCPTBBPAA);2PV409;2V2075A(2-LCV-b2-135)interactin the above locations.
Corrective Actions:
- 1) Isolation of the RCS pressure boundry was addressed in a December 2, 1982 letter from L. M. Mills to E. Adensam. An additional review of these paths verified that RCS depressurization is not credible through normal letdown since three paths are available for isolation.
- 2) All other cables are not necessary to insure RCS Inventory Control in these interaction zones.
This item is closed.
1 l
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Interaction Number:
85 l((e-s Safety Function / Unit:
RCS Inventory Control Associated Interaction No(s):
None Associated Safety Function (s):
None r
Location:
Auxiliary' Building Elev 734,
- 1) 6.9-kV S/D Bd Rm Tr B
- 2) ACR Inst Rm 2B
~
==
Description:==
Cables 2V4411, 2V4412, 2V4414 (2-FCV-62-54), 2V4367, 2V4368, 2V4370 (2-FCV-62-55) and 2PM133, 2PM134 (2-FCV-62-56) all interact.s.n the above locations.
These valves malfunctioning could prevent isolation of the excess letdown line.
. Corrective Action: Isolation of the RCS pressure boundry was addressed in a December 2, 1982 letter from L. M. Mills to E. Adensam. Aa additional review of these paths verified that RCS depressurization is not credible through excess letdown since three paths are available for isolation. No modification is required to resolve this interaction.
This item is closed.
N I
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k
e Interaction Number:
86 s
Safety Function / Unit:
RCS Inventory Control / Unit 2 Associated Interaction No(s):
34 Associated Safety Function (s):
ERCW, Auxiliary Power Location:
Auxiliary Building, Elevation 714, Common Area i
Descriptian:
PATH 1 PATH 2 Cable Component Key Cable Component Key 2PL3001A CCP Ad Clr 1
2PL30llB CCP BB Clr 1
2PL3013B CCP BB Clr 1
IPL4735S CCS Pmp C-S 1PL4736S CCS Pop C-S 2PL4725A CCS Pop AA, 1+9 2PL4738B CCS Pmp C-S 1
2PL4726A CCS Pop AA 1+9 2PL4739B CCS Pop C-S 1
2PL4727A CCS Pop AA 1+9 2PL4742B CbSPopBB 1+9 2PL4731A CCS Pop AA 1+9 2PL4743B CCS Pop BB 1+9 2PL4732A CCS Pap AA 1+9 2PL4744B CCS Pop BB 1+9 2PL6145A CCP AA ALOP 1
2PL4748B CCS Pop BB 1+9 2PL6148A CCP AA ALOP 1
2PL4749B CCS Pop BB 1+9 2PL6149A CCP AA ALOP 1
2PL6152B CCP BB ALOP 1
2PM1041I 2-LI-68-339 1
2PL6155B CCP BB ALOP 1
2PM1046 2 'LI-68-339 1
2PL6156B CCP BB ALOP 1
2PM1053 2-LI-68-339 1
2PM1070II 2-LI-68-335 1
1 2P 1
2 2
9 4
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---,,,,g y,, - -, - - -, - -, -
Interaction Number:
86 (Continued)
==
Description:==
(Continued)
PATH 1 PATH 2 Cable Component Xeg Cable Comp'nent Key o
2PV386 2-LI-70-90 1
2PP562B CCP BB 1
2PP564B CCP BB 1
2PV16I 2-LI-68-339 1
2PP568B CCP BB 1
2PV255III 2-LI-68-320 1
2V2243B 2-FCV-62-99 1
2V2235A 2-FCV-62-98 1
2PM108 2-FCV-62-93 2
2V2422A 2-FCV-67-146 1+19 2PMllo 2-FCV-62-93 2
2V2423A 2-FCV-67-146 1+19 2PM111 2-FCV-62-93 2
2V2424A 2-FCV-67-146 1+19 2PM112 2-FCV-62-93 2
2V2425A 2-FCV-67-146 1+19 2PM115 7 FCV-62-93 2
2PV56 2-FCV-62-93 2
2VS130B 2-FCV-62-85 34 2V2073A 2-LCV-62-135 5
2V2103B 2-LCV-62-136 5
2V2329A 2-FCV-63-7 5
2V2321B 2-FCV-63-6 5
2V4828A 2-FCV-63-42 6
2V2323B 2-FCV-63-6 5
2V4830A 2-FCV-63-42 6
2V2690B 2-FCV-63-25 6
2PV43A 2-FSV-68-397 7
2V2706B 2-FCV-63-40 6
2V2787A 2-FCV-74-1 7
2V4796B 2-FCV-63-41 6
2V4423A 2-FCV-62-69 7
2V4798B 2-FCV-63-41 6
2V4435A 2-FCV-62-70 7
2V4933 2-FCV-63-24 6
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e s
Interaction Number:
86 (Continued)
==
Description:==
(Continued)
PATH 1 PATH 2 Cable Component Key Cable Component' Key 2V4473A 2-FCV-62-72 7
2V5130 2-FCV-63-174 6
2V4488A 2-FCV-62-73 7
2V5131 2-FCV-63-174 6
2V4503A 2-FCV-62-74 7
2PV1638 2-FSV-68-396 7
2V5680A 2-FSV-68-394 7
2V2847B 2-FCV-74-2 7
2V5681A 2-FSV-68-394 7
2V5660L 2-FS'V-68-395 7
2V5685A 2-FSV-68-397 7
2V5661B 2-FSV-68-395 7
2V5690A 2-FSV-68-397
'7 2V5670B 2-FSV-68-396 7
2V5691A 2-FSV-68-397 7
2V5671B 2-FSV-68-396 7
)
)
2V5695A 2-FSV-68-397 7
2V5675B 2-FSV 68-396 7
2V5696A 2-FSV-68-397 7
2V5676B 2-FSV-68-396 7
2PMi34 2-FCV-62-56 8
2PV56 2-FCV-62-56 8-2PL6123A RCP TBBP AA 9
2V4370 2-FCV-62-55.
8 2V2295A 2-FCV-70-143 9
2V4414 2-FCV-62-54 8
2V4448A 2-FCV-62-86 34 2PL6131B RCP TBEP BB 9
2V4596A 2-FCV-62-84 34 2PL6133B RCP TBBP BB 9
2V5743B 2-FCV-70-85 9
2V5745B 2-FCV-70-85 9
i 2PV56 2-FCV-62-89 34 2V5130B 2-FCV-62-85 34
)
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.s Interaction Number:
86 (Continued)
Corrective Action:
1.
Cables for CCP2A room cooler.will, be rerouted and/or wrapped to provide adequate separation from its redundant division.
2.
Cables associated with the C'CP aux lube oil pumps do not require protection. A bypass switch will be installed allowing the CCP's to be started without the CCP aux lube oil pumps running.
3.
Cables associated with 1-FCV-67-146, 2-FCV-67-146, and 0-FCV-67-151 do not require protection because these valves can be operated manually. TVA plans to submit a deviation request to justify operating the valves manually after a fire at the valves.
4.
Cables for CCP2A will be rerouted to provide adequate separation from its redundant division.
f a
5.
Cables 2PL4725A, 2PL4726A, 2PL4727A, nd 2PL4732A for CCS pump 2A-A will be rerouted to provide adequate separation from cables for CCS pumps 2B-B and C-S and train-B auxiliary power. CCS pump C-S cables are adequately ceperated from Train A auxiliary power.
6.
Protect cable 2PV255III by wrapping to ensure one pressurizer level instrument operable.
7.
Cables associated with 2-FCV-62-99 and 2-FCV-62-98 l
do not require protection. Power will be removed per ECN 6258.
I 8.
2PV386 (2-LI-70-99A) is not required and will be deleted from shutdown logic.
l r.
T Interaction Number:
86 (Continued)
Corrective Action:
(Continued)
~
9.
Cables associated with 2-FCV-62-93 do not require protection.
2-FCV-62-526, 534 can be manually operated, if necessary.
10.
Cables associated with 2-LCV-62-135, 136 and 2-FCV-63-6-7 do not require protection. 2-LCV-62-135, 136 can be manually operated, if necessary.
11.
Cables associated with 2-FCV-62-25, 40, 41, 42;
{(
RCP TBBP AA; RCP TBBP BB; 2-FCV-62-84, 85, 86, k
89; do not requite peotection. These components are not necessary to satisfy RCS Inventory Control in this interaction zone.
12.IrolationoftheRCSpressureSoundrywasaddressedin a December 2, 1982 letter from L. M. Mills to E. Adensam.
s An additional review of these paths verified that RCS depressurization is not possible through the reactor head vent system.
- 13. Cables associated with 2-FCV-74-1, 2 do not require protection. These valves are deenergized per GOI-1.
e 9
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Interaction Number:
86 (Continued)
Corrective Action:
(Continued)
- 14. Cables associated with 2-FCV-62-54, -55, -56 (excess letdown) and 2-FCV-62-69, -7'0, -72, -73. -74 (normal letdown) do not need to be protected. Isolation of the RCS pressure boundry was addressed in a December 2,1982 letter from L. M. Mills to E. Adensas. An additional review of these paths verified that RCS depressurization is not credible through normal or excess letdown since three paths are available for isolation.
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Interaction Number:
87
~
I((
Safety Function / Unit:
RCS Inventory Control / Unit 2 Associated Interaction No(s):
None Associated Safety Function (s): None Location:
Auxiliary Building, Elevation 714, H & V
,Eq'uipment Room (unit 2).
==
Description:==
The following Path 1 A-train cables 2PL4725A, 2PL4726A, 2PL4727A, 2PL4731A, 2PL4732A(CCS Pump AA);
2V5685A, 2V5690A, 2V5691A, 2V5695A, 2V5696A (2-FSV-68-397); interact with the following B-train cables 2PL4738B, 2PL4739B(CCS Pump C-S); 2PL4742B, 2PL4743B, 2PL4744B, 2PL474SB, 2PL4749B(CCS Pump BB);
2V5676B, 2V5670B, 2V5671B, 2V5675B (2-FSV-68-396).
Corrective Action:
1.
Cables associated with CCS pump A-A were determined to have greater than 20 feet separation from the redundant train (CCS Pump C-S) 'ith both detection w
and suppression in the region. This item requires no further action.
i 2.
Cables associated with 2-FSV-68-396, 397 do not require protection.
2-FSV-68-394, 395 are not in this interaction zone.
In additton, further evaluation has 7:evealed I
that 2-FSV-68-396, -397 will remain closed, following any postulated damage caused by a fire.
This interaction is closed.
y
Interaction Number:
100 Safety Function /L' nit:
RCS INV
't 2 Associated Interaction No(s):
34 Associated Safety Function (s):
ERCW Location:
Aux. Bldg.; El 669, 690, 714; Area 20' around elevator, stairwell, ar.d hatch
~
~
..n Lescription:
Path 1 (Tr A)
Elev 669 Path 2 (Tr B)
Cable Component key cable component key 2PM115 2-FCV-62-93 2 2V2321B 2-FCV-63-6 5 E12v.690 2V2240B 2-FCV-62-99 1 2V2241B 2-FCV-62-99 1
~
2-FCV-63-6 5 2V2320B 2V2687B 2-FCV-63-25 6 2V2688B 2-FCV-63-25 6 2V2703B 2-FCV-63-40 6 2V2704B 2-FCV-63-40 6 2V4798B 2-FCV-63-41 6 Elev.714 2PL6120A RCP TBBP AA 9
2PL6131B RCP TBBP BB 9 2PL6122A RCP TBBP AA 9
2PL6133B RC? TBBP BB 9 275691A 2-FCV-68-397 7
2V5671B 2-FSV-68-396 7 2V5696A 2-FCV-68-397 7
2V5676B 2-FSV-68-396 7 e.
y -
n
Interaction Number:
100 (Continued)
\\s Corrective Action:
1)
Cables associated with 2-FCV-62-99 do n.ot require protection. Power will be removed per ECN6258, 2)'
Cables associated with 2-FCV-62-9) do not require protection.
2-FCV-526, 534'can be manually operated, if necessary.
3) c bles associated with 2-FCV-63-6 do not require a
protection. 2-LCV-62-135,.136 are still operational.
4)
Cables associated with-2-FCV-63-25, 40,41, RCP IBB A-A, RCP TBBP B-B do n'ot require protection. These components are not neederi te.atisfy FCS inventory control in this interaction zone.
5)
Cables associated with 1-FSV-63-394, 395 do not.1guire
{ (L. -
\\
protection.
2-FSV-68-396, 397 are still a railable.
t
~
In conclusion, removing power from FCV-62-99 is the only modification required to resolve this interaction.
~
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+
Interaction Number:
101 Safety Function / Unit:
RCS INV CONT / Unit 2 Associated Interaction No(s)-
None Associated Safety Function (s):
None Location:
Aux. Bldg., El's 669, 690, 714; Area 20' around U-2
~
stairwell area.
==
Description:==
Path 1 (Tr A)
Elev 669 Path 2 (Tr D)
Cable Component key cable component key 2PL3001A CCP AA Rm Clr 1A 2PL3011B CCP BB Rm Clr 1B 2PL6145A CCP AA Aux LOP 1 A 2PL3013&
CCP,BB Rm Clr 1B 2PM1053 2-LI-68-339 1C 2PL3014B CCP BB Rm Clr 1B 2PP550A CCP A-A
'1A 2PL6152B CCP B>B Aux LOP 1B 2PP552A CCP A-A 1A 2PL6156B CCP B-B Aux LOP 1B 2PM1076K -'
2-LI-68-335 1C 2PP562B CCP BB 1R s
2PP564B CCP 3B 1R 2PM108 2-FCV-62-93 2E l
2PM111 2-FCV-62-93 2 E-2PM112 2-FCV-62-93 2E 2PM115 2-FCV-62-93 2E 1
,spe sb' w' 4
..~,,,,
,-,,,n cv
i 4
c, Interaction No:
101
- (Cont'inued) lI k
==
Description:==
(Continued)
'Elev. 690 Part 1 (Tr A)
~
, Path 2 (Tr B)
Cable Component Key Cable Component Key 2PL4731A CCS Pop AA 1,9 B 2PL3011B CCP BB Rm Clr 1B 2PM1041I 2-LI-68-339 1C 2PL3013B CCP BB Rm Clr 1B 2PM1046 2-LI-68-339 1C 2P1,4734B CCS Pmp CS 1B 2PM1053 2-LI-68-339 1C 2PL4742B CCS Pmp BB 1,9 B 2P'L4743B CCS Pmp BB 1,9 B 2PL4748B CCS Pmp BB 1,9 B 2PL6152B CCP BB Aux LO Pmp 1 B 2PL6156B CCP BB Aux L0 Pmp 1.B 2PM1076K 2-LI-68-335 1C 2RP562B CCP BB 1B 2PP564B CCP BB 1B 2V2240B 2-FCV-62-99 1D
~
2V2241B $
2-FCV-62-99 1D i
2V2320B 2-FCV-63-6 5F 2V2687B 2-FCV-63-25 6G 2V2688B 2-FCV-63-25 6G 2V2703B 2-FCV-63-40 6G l
2V2704P 2-FCV-63-40 6G 2V4798B 2-FCV-63-41 6G l
1 l
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' 6%D vm..
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)
Interaction No:
101 (Continued) r I(
==
Description:==
(Continued)
Elev. 714 Part 1 (Tr A)
. Path 2 (Tr B)
Cable Component Key Cable Component Key 2PL4725A CCS Pmp AA 1,9 A 2PL3011B CCP BB Rm Clr 1B 2PL4726A CCS Pmp AA 1,9 A 2PL3013B CCP BB Rm Clr 1-B 2PL4732A CCS Pmp AA 1,9 A 2PL4742B CCS Pmp BB 1,9 B 2PM1041 2-LI-68-339 1C 2PL4743B CCS Pmp BB 1,9,B 2PM1086III 2-LI-68-320 1C 2P'L4744B CCS Pmp BB 1,9 B 2PL4748B CCE Pmp BB 1,9 B 2V2422A 2-FCV-67-146 1,19A 2PL4749B CCP Pmp BB 1,9 B 2V2423A 2-FCV-67-146 1,19A 2PL4738B CCS Pmp CS 1A 2PL4739B CCS Pnp CS 1A 2V2424A 2-FCV-67-146 1,19A 2PL6152B CCP BB Aux Lo Pmp 1 B 2V4830 2-FCV-63-42
'6G 2PL6155B CCP BB Aux Lo Pmp 1 B 2PV43A 2-FSV-68-397 7H 2PL6156B CCP BB Aux Lo Pmp 1 R 2V5690A 2-FSV-68-397 7H 2PP562B CCP BB 1B 2V5691A 2-FSV-68-397 7H 2PP564B CCP BB 1B 2V5795A 2-FSV-68-397 7H 2PP566B CCP BB 1B 2V5696A 2-FSV-68-397 7H 2PP568B CCP BB 1B 2PM110 2-FCV-62-93 2E 2PM111 2-FCV-62-93 2E 2PM112 2-FCV-62-93 2E 2V2103B 2-LCV-62-136 5F 2V4798B 2-FCV-63-41 6G j
2PV163B 2-FSV-68-396 7H pf, 3p3 e
o Interaction No:
101 (Continued) 1 Description- (Continued)
Elev. 714 Part 1 (Tr A)
Path 2 (Tr B)
Cable Component Key 775670B 2-FSV-68-396 7H 2V5675B 2-FSV-68-396 7H 2PM134 2-FCV-62-56 8I 2PL6131B RCP TBBP BB 9J 2P'L6133B RCP TBBP BB 9J 2V5745B 2-FCV-70-85 9J 2V4460B 2-FCV-62-85 34 K l(k-Corrective Action:
1}
Cables associated with CCP A-A and B-B will be rerouted to resolve other interactions.
Cables (2PL30d1A, 2PL3011B, and 2PL3013)) associated with CCP A-A and B-B room cooler will be rerouted to resolve other interactions.
In addition, cable 2PL3014B will be disconnected in junction box 1192.
2)
Cables associated with che CCP Aux Lube Oil Pump do not require protection.
s A bypass switch will be installed to allow starting a CCP without the auxiliary oil pump.
l 3) 2-FCV-67-146 can be operated manually, i
l 4)
Component cooling water pump A-A must be protected (separated) from l
l pump C-S.
(Pump B-B is not required).
5)
Cable 2PM1076K will be protected.
6)
Cables associated with 2-FCV-62-99 will be deenergized and do not I
require protection (see ECN 6258).
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- - ~ - -
- - = - - - -
s Interaction No..
101 (Continued)
N Corrective Action:
(Continued)
~
- 7). Cables associated with 2-FCV-62-93 do not require protection. Cables associated with 2-FCV-63-42 do not require pro'tection,since the manual inline valve can be closed (63-574). This will' insure a charging path.
RCP seals can be protected by A train RCP TBBP and CCS pump AA.
8)
Cables associated with 2-FCV-63-6 and 2-LCV-62-136 do not require protection. 2-LCV-62-135 is still available, 9)
Cables associated with 2-FSV-68-395 and -397 do ac* require protection.
2-FSV-68-394 and -395 are still available.
10)
Cables asscoiated with 2-FCV-62-56 do not require protection.
2-FCV-62-54,55 are still operational.
11)
Cables associated with 2-FCV-62-85 do not require protection. This h-valve is not necessary to satisfy RCS inventory control in this interaction zone.
In conclusion, the corrective action described in Interaction No. 57 will provide the resolutions to the above cable interactions.
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e Interaction Number:
109 Safety Function / Unit:
RCS Pressure Control, Unit 1 Associated Interaction No(s):
NA Associated Safety Function (s):
NA Location:
Auxiliary Building Elevation 734, S/D Board Room A, A3-6/R-S'line.
==
Description:==
FCV-68-332 cable IV2449B interacts with PCV-68-340A cable IV56125 at the above location.
< = :.
Corrective Action: Corrective action is not required. Schematic diagrsm
~
45W668-1 shows that PCV-68-340A will spuriously open only if wires RBCP1 and RBC6 or RDC3 are shorted.
Cable IV5612A does not carry these pair combinations; therefore, the PORV will not spuriously open.
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Interaction No.
109 (Continued)
An external fault was not considered. The control power source for each of these valves-is from a fused 480-V - 120-V ac ungrounded transformer. Before a component supplied by a two-wire, ungrounded ac circuit could spuriou=ly operate and adversely affect safe shutdown of the plan't, two circuits (one. energized
'~
and one deenergized) would have to be damaged by a fire and then shorted together in such a manner that power would be supplied to the deenergized circuit.
For this to occur, either two pairs of conductors would have to short together or two conductors short
(((
to ground and the other two conductors short together without faulting across the line. A similar sequence of events would have to occur for two wire ungrounded de circuits.
c-This interaction is closed.
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Interaction Number:
110
~
Safety Function / Unit:
RCS Pressure Control, Unic 2 Associated Interaction No(s):
NA n.,
s Associated Safety Function (s):
NA Location:
Auxiliary Building Elevation 734, 6.9kV S/D Room B, All-13/
R line.
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==
Description:==
FCV-68-333 cable 2V2455A interacts with PCV-68-334 cables 2V5593B and 2V5594B at the above location.
o.
1 Corrective Action: Corrective action is not required. Schematic diagram
~
45N668-1 shows that PCV-68-334 will only spuriously open if wires RBDP1 and RBD6 or RBD3 are shorted.
Cables 2V5593B and 2V5594B do not carry these pair combinations; therefore, the PORV will not spuriously operate. Refer to Interaction No. 109 for more information. This interaction is closed.
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4 Interaction Number:
111
~
SafetyFunction/ Unit:
RCS Pressure Control, Unit 1 Associated Irteraction No(s)':
NA Associated Safe'~ty Function (s):
Auxiliary Power Location:
Auxiliary Building Elevations 749, 480-V Transformer Room LA, A3/S-V line.
==
Description:==
PCV-68-334 cable IV5598B is routed through the above location.
A fire at this location may cause the loss of cable IV5598B and train A power to TCV-68-333.
Corrective Action:
Corrective action is not required. Schematic diagram 45N668-1 shows that PCV-68-334 will spuriously open only if wires RBDP1 and RBD6 or RBD3 are shorted.
Cable IV5598B does not carry this combination of wires; therefore, the PORV will not spuriously open. Refer to Interaction No. 109 for more information. This inter-action is closed.
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Interaction Number:
~112 f
Ik Safety Function / Unit:
RCS Pressure Control, Unit 2 Associated Interaction *No(s):
NA Associated Safety Function (s):
Auxiliary Power
~
Loca tior.:
Auxiliary Building Elevation 714, A8/Q-line.
f IL/
==
Description:==
PCV-68-340A cable 2V5610A interacts with cables associated with train B auxiliary power at the above location.
If train B power is lost, (due to auxiliary power train B v..
at this location) block valve FCV-68-332 will not be operable to close and isolate line.
(
e Corrective Action: Reroute cable 2V5610A such that it is located north of A-8 line when penetrating down to elevation 714.
Another option is to reroute in conduit from the l
bottom of panel 2-L-llA and wrap until the proposed fire wall at the A-8 line or until it penetrates
~
Q-line (i.e. keep 2V5610 north of A8 wall or protect when south of A8 wall).
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Interaction Number:
113
/
SafetyFunction/ Unit:
RcS Pressure Control, Unit 1 Associated Interaction No(s):
NA Associated Safety Function (s):
Auxiliary Power Location:
Auxiliary Building Elevation 714, A6-8/Q-R Line.
==
Description:==
scV-68-334 cable IV5596B interacts with. cables associated with train A auxiliary power at the above location.
If train A power is lost, (due to auxili,ary power train A at this location) block valve FCV-68-333 will not be
. operable to close and isolate line.
Corrective Action: Reroute cable IV5596B such that it is located south of A-8 line when penetrating d'own to elevation 714.
Another option would be to reroute in conduit from l
the bottom of panel 1-L -llB and wrap until the i
i proposed fire wall at the A-8 line or until it penetrates Q-line.
(i.e. keep cable IV5596 south of A-8 wall or protect when north of A-8).
4 1
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Interaction Number:
114 Safety Function / Unit:
RCS Pressure Control, Unit 2 Associated Interaction No(s):
NA Associated Safety Function (s):
Auxiliary Power Location:
Auxiliary Building Elevations 759, CRD Equipment Room, A12-13/U-V line.
==
Description:==
PCV-68-340A cable 2V5612A is routed through the CRD equipment room to the reactor building penetration.
C As the cable 'transverset the room, it crosses train B auxiliary power cables. A fire at this-location would cause failure of the 2V5612A cable and power to the FCV-68-332 block valve.
<a Corrective Action:
Corrective action is not required. On schematic diagram 45W668-1, it can be seen that PCV-68-340A w.41 spuriously open if wires BBCPl and RBC6 or RBC3 are shorted.
Cable 2V5612A does not carry this combination; therefore, the PORV will not spuriously open. Refer to Interaction No. 109 for more information.
This item is closed.
6
s-e Interaction Number:
117 I((
Safety Function / Unit:
Secondary Side. Pressure Control Unit 1 Associated Interaction No(s):
NA Associated Safety Function (s):
- NA Location:
Auxiliary Building El.evations 734/714, A3-A6/Q-R.
(
==
Description:==
The shutdown logic requires that'l-PCV-1-5, -12, -23, -30 must not spuriously operate.
Cables for these valves run throughout the auxiliary building.
An evaluation revealed that cables IV7521A, IV7568B, IV7537A,'lV7582B contain the pair combination of wires which could possibly cause the valves to spuriously operate.
Corrective Action: Further evaluation har shown that this spurious operation is not credible.
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Interactica Number:
117 (Continued) lF k.
An evaluation identified cables which, if involved in a fire, could cause the val've's opening solenoid to energize.
Schematic diagra's 45N601-4 shows that PCV-1-5 could spuriously operate if wires IS3AP and IS3A30 or IS3A5 are shorted and energizes the "A" solenoid. Cable IV7521A carries this pair-combination of wires. A similar cable exists for all of the above listed PCV's:
IV7568B for PCV-1-12, IV7537A for PCV-1-23, IV7582 for PCV-1-30.
Further evaluation revealed that since the PCV has two solenoid valves (one for closing and one for opening), the operator may, if the valve spuriously opens, place the HS in the closed position and energize the "B" solenoid to close the valve. The "B"
closing solenoid is in series.with the "A!' opening solencrid and overrides the opening signal keeping the valve closed with both solenoids energized.
~
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In the event both solenoids are deenergized (fuses blown in circuit), the PCV would be allowed to modulate via a pressure
~
controller. The control system for the PORV's consist of a
~
transmitter located in the valve room, a controller located in the main control room, and an I/P c'onverter located in the valve roon.
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Interaction Number:
117 (Continued)
If a fire were to short the cable from t_he transmitter to the ccatroller and cause the control system to open"the valve, the operator can place the controller in manual and run'the valve closed. Should the cable from the transmitter open, the control system would keep the valve closed. If the fire ~should short or open the cable from the controller to the I/P converter, the converter would see the same result in both cases, no current, and the valve would remain closed. Therefore, based on this full evaluation, it is not credible for the SG PORV's to spuriously operate. Operating procedures will address placing the valve han'dswitch in the closed position and the concroller
..in manual-closed in the event the PCV spuriously opens.
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Interaction Number:
118 I(~
ks Safety Function / Unit:
Secondary Side. Pressure Control Unit 2 Associated Interaction No(s):
NA Associated Safety Function (s):
NA Location:
At'xiliary Building El.evations 734/714 A3-A13/Q-S.
==
Description:==
The shutdown logic requires that 2-PCV-1.-5, -12, -23, ~30 must not spuriously operate.
Cables for these valves run throughout the auxiliary building.
An. initial evaluation revealed that cables 2V7521A, 2V7568B, 2V7537A, 2V7582B contain the pair combination of wires which could possibly cause the valves to spuriously operate.
Corrective Action: Further evaluation has shown that this spurious operation is not credible. Refer to Interaction No. 11*/ for a complete evaluation.
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a <> r Interaction Nwnber:
120 Safety Function / Unit:
RCS Inventory Control Keys 4 & 5, Unit 1 & 2
~
Associated Interaction No(s):
NA Associated Safety Function (s):
NA Location:
Auxiliary Building multiple elevations
==
Description:==
Cables for valve 1-LCV-62-132 and 1-LCV-62-133 exists at multiple locations. Spurious operation of either valve could be caused by a fire along the pai.h of cables IV2761A, IV2764A, and IV2765A for valve 1-LCV-62-132 or cables IV2771B, IV2774B, and IV2775B for valve 1-LCV-62-133. The same applies to unit 2.
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<*'v Interaction Number:
120 (Continued)
~
Corrective Action: Cables IV2761A, IV2764A, and'lV2765A for valve
~
1-LCV-62-132 are routed from panel 1-M-5 in the control room to the LAl-A 480-V Reactor MOV board.
From the reactor MOV board they are routed in conduit to the U line wall. They are embedded in the wall down to elevation 690. On elevation 690 they are routed from the U line wall to the valve.
A fire anywhere along the exposed cable path could cause LCV-62-132 to spuriously close by short circuiting any of the following wire pairs:
' X1 and 3EC2
(
3E 3EX1 and 3Ecli 3E1 and 3EC2 Ref Drawing 45N779-ll 3F1 and 3ECll 3E? and 3EC2
.3E3 and 3ECll A fire at either the Reactor MOV board or VCT room labyrinth could cause the same situation to occur.
Cables IV2771B, IV2774B, and IV2775B for valve 1-LCV-62-133 are routed from panel 1-M-5 in the control room to the 1B1-B Reactor MOV board. From i
the MOV board the cables are routed down through the various floors in cable trays and conduit until 1
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L Interaction Number:
120 (Continued) reaching the valve room on elevation 690. A fire anywhere along the path could cause LCV-62-133 to spuriously close by short circuiting any of the following wire pairs in the cable:
8BX1 and 8BC2 8BX1 and 8BCil
~
8B1 and 8BC2 Ref. Drawing 45N779-11 8B1 and 8BC11
_ 8B3 and 8BC2 8B3 and BBC11 A f' ire at either the 1B1-B MOV board or VCT room
(
labyrinth could cause the same spurious operation.
An external fault was not considered. The control power source for each of these valves is from a fused 480-V - 120-V ac ungroundad transdormer. Before a component supplied by a two wire, ungrounded ac circuit could spuriously operate and adversely affect safe shut-down of the plant, two circuits (one energized and one deenergized) would have to be damaged by a fire and then shorted together in such a manner that power would be supplied to the deenergized circuit. For this to occur, either two pair of conductors would have to short
(
together or two conductors short to ground and the other wa...
a.-
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O Interaction Number:
120 (Continued) two conductors short together,without faulting across the line. A similar sequence of evenEs would have to occur for two wire ungrounded de circuits.
During, normal plant operation only one' charging pump is running. Since both LCV-62-132 and LCV-62-133 are in series from the Volume Control Tank to the centri-8 fugal charging pumps, the spurious closing of either valve would cause the loss of suction to the pump and the loss of.the pump itself.
Our corrective action is to remove power from these two valves (62-132, 133) or switch over suction to the RWST by opening valves 1-LCV-62-135 and 1-LCV-l 62-136 during a confirmed fire in the cable locations described above. With power removed, these valves cannot spuriously operate. Manual operation would still be possible. The Fire Shutdown Logic will be l
I revised to incorporate the above corrective action.
Operating procedures will address thic item.
0 l
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4.
r-Interaction Number:
120 (Continued)
(
For normal operation and for a safety injection signal valves 1-LCV-62-135 or 1-LCV-62-136 must open before 1-LCV-62-132 or 1-LCV-62-133 closes. "Valves62-135 and 62-136 are in parallel from the RWST to the charging pumps. This valve movement could be defeated during a fire The two following examples are the most simple combinations that could cause this event to occur:
1.
A fire must cause a short circuit between wires 3EC3 and 3EC2 in cable IV2763A, must cause a short circuit between wires 8BC2 and 8BC3 in cable IV1773B, and a Volume Control Tank lo-lo
(
level signal must be present from level control loop 62-129A or 62-130A. -
2.
A fire must cause a short circuit between wires 3EC3 and 3EC2 in cable IV2767A, must cause a short circuit between wires 8BC2 and 8BC3 in cable IV2777B, and a Volume Control Tank lo-lo level signal must be present from level control loop 62-129A or 62-130A.
Multiple and simultaneous failures that could cause the defeat of this particular safety function are considered incredible.
The above evaluation also applies to Unit 2 (change valve and cable number' prefix from 1 to 2).
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ATTACHMENT 5 Inside Containment Analysis A review was performed and documented in S01 850430 834 (included in attachment 6) that determined which cables penetrating the Reactor Building will require III.G.2. evaluation for separation inside the Reactor Building.
That analysis not identify the PRZ PORVs, PORV blocks valves, head vent valves, letdown valves, or excess letdown valves as require'B components requiring separation inside the Reactor Building. Therefore, these valves were not analyzed.
The rationale behind that decision follows:
1.
High/ low-interface position documented to NRC in the Dccember 2, 1982 letter.
2.
The PORVs and head vents did not have to operate.
They only had to be prevented from spurious operation, and the interaction evaluations / dispositions that had been generated for these same cables outside containment determined that spurious opening of the PORV or head vents was not credible f rom internal cable f aults.
External cable faults were not considered credible because of the position taken on ungrounded de faults and the confined / restricted access controls on the Reactor Building.
3.
The PRZ PORVs and PORV block valves are obviously not separated because they must both be physically located at the top of the pressurizer to satisfy reactor pressure vessel boundary considerations.
4.
The RVHV valves are obviously not separated because they are physically located together near the reactor vessel head to satisfy reactor pressure vessel boundary considerations.
5.
The low fire loading inside containment.
6.
The routing of the PRZ PORV and PORV block valve cables are inside conduit embedded in concrete inside primary containment except at the containment penetration and the valves.
7.
The routing of all other cables.
1 side conduit while inside containment.
In addition, a fire hazard analysis was performed in January 1988 for the PRZ area. Refer to our response to question 15.
Further analysis is being performed that will result in an RCS letdown path.
This analysis further evaluated the annulus area fcr spurious PORV operation.
This preliminary analysis will be finalized and made available to NRC for review.
2476h/dmm
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ATTACHMENT 6 m
(s01 850430 834) t 2476h/dnun
A Troc a a r 6 E
TES GOVERNMENT S01 8504S0 034 UNYp is.
Memorandum TENNESSEE VALLEY AUTHORITY
~
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- Appendix R Project File:,, Regulatory Engineering, NUC PR, Sequoyah
~~
.__Nu cle ar._ Plant.
/
FROM J. H. Sullivan, Appendix R Project Manager, NUC PR, Sequoyah Nuclear Plant APR3 0 935 DATE
SUBJECT:
SEQUOYAH NUCLEAR PLANT - APPEt' DIX R - INSIDE CONTAINMENT EVALUATION A review was performed of all. cables which penetrate the reactor building shield wall (attached). From this review, the following list of equipment and cables required to shutdown the plant for an Appendix R postulated fire within the reactor building was produced. The annulus is connidered a part of the reactor building (inside containment). This is the list of equipment that will be considered for the inside containment Appendix R efaluation.
RCS Temperature Indication T-68-1 (T -Loop 1) - 1,2PM590I; 1,2PM5911 g
T-68-18 (T
-I.
P 1) - 1,2PM7771; 1,2PM778I C
f T-68-24 (T -Lo P 2) - 1,2PM6851; 1,2PM6861 H
T-68-41 (T -L P 2) - 1,2PM870I; 1,2PM871I C
T-68-43 (T -L P 3) - 1,2PM594II; 1,2PM5951I H
T-68-60 (T -Loop 3) - 1,2PM783II; 1,2PM78411 C
T-68-65 (T -Loop 4) - 1,2PM690II; 1,2PM691II H
T-68-83 (T -L P 4) - 1.2PM875II; 1,2PMS7611 C
e Pressurizer Levels L-68-335 - 1,2PM1071II L-68-320 - 1,2PM10861II L-68-339 - 1,2PM10411 l
Steam Generator Level Indication Loop 1 L-3-43 (wide range) - 1,2PM1222K; 1,2PM1223K L-3-39 (alt. narrow range) - 1,2PM1400III; 1,2PM1401III L-3-164 (MD, AFWP LCV's) - 1,2PM4475A; 1,2PM4476A L-3-174 (TD AFWP LCV's) - 1,2PM4500B; 1,2PM4501B Loop 2 l
L-3-56 (wide range) - 1,2PM1231K; 1,2PM1232K l
L-3-52 (alt. narrow range) - 1,2PM1520III; '1,2PM1521III L-3-156 (MD AWP LCV's) - 1,2PM4465A; 1,2PM4466A L-3-173 (TD A NP LCV's) - 1,2PM4495B; 1,2PM4496A Buy U.S. Savines Bonds Regularly on the Payroll Savines Plan
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Appendix R Project Files APR 3 01985 SEQUOYAM NUCLEAR PLANT - APPENDIX R - INSIDE CONTAINMENT EVALUATION Loop 3 L-3-98 (wide range) - 1,2PM1240K; 1,2PM1241K L-3-94 (alt. narrow range) 1,2PM1640III; 1,2PM1641III L-3-148 (MD AFWP LCV's) - 1,2PM4455B; 1,2PM44565 L-3-172 (TD AWP LCV's) - 1,2PM4490A; 1,2PM4491A Loop 4 L-3-111 (wide range) - 1,2PM1250K; 1,2PM1251K L-3-107 (alt. narrow range) - 1,2PM1755III; 1,2PM1756III L-3-171 (MD AFW? LCV's) - 1,2PM4485B; 1,2PM4486B L-3-175 (TD AFWP LCV's) - 1,2PM4505A; 1,2PM4506A S.G. Press Indication (Annulus only)
Loop 2 P-1-9A, 1,2PM1474I P-1-9B, 1,2PM1480II P-1-12, 1,2PM1490III
~
Loop 3 P-1-20A, 1,2PM1595I i
P-1-20B, 1,2PM1607II P-1-23, 1,2PM161311I The results of cl.e evaluation of these cables inside containment will be documented in a separate safety function position statement.
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l J. H. Suflivan
~
MAP:SFH Attachment cc (Attachment):
NUC PR RIMS, 1520 CST 2-C H. B. Rankin, NUC PR, Sequoyah (Attention:
B. K. Williams)
This was prcpared principally by M. A. Purcell.
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