ML20202F052

Forwards Valve Position & Alignment Justification & Revs to App R Repts 1 & 3 Incorporating Manual Pressurization Sys for Helium Circulator Brake & Seal Sys Into Shutdown Model, Per 860314 Commitment

ML20202F052
Person / Time
Site:	Fort Saint Vrain
Issue date:	04/04/1986
From:	Walker R PUBLIC SERVICE CO. OF COLORADO
To:	Berkow H Office of Nuclear Reactor Regulation
References
P-86266, TAC-54373, NUDOCS 8604140096
Download: ML20202F052 (17)

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P.O. Box 840 Denver, Co 80201-0840 R. F. WALKER PRESIDENT April 4, 1986 Fort St. Vrain Unit No. 1 P-86266 Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington D.C. 20555 Attn: Mr. H. N. Berkow, Project Director Standardization and Special Projects Directorate Docket No. 50-267

SUBJECT:

Appendix R Evaluation

REFERENCE:

PSC Letter, Walker to Berkow dated 3-14-86 (P-86209)

Dear Mr. Berkow,

As comitted to in the above referenced letter, PSC now submits the:

1) Justification of the va?ve position and alignment based on in from plant operation s representatives (see attachment "A")

2) put the page changes to Reports 1 and 3 to incorporate the manual pressurization system for the Helium Circulator Brake and Seal System into the shutdown model (20 copies of page changes included as attachment "B".

Please incorporate these pages into the previously transmitted reports.) The committment to provide the " manual actions and timing" details will be delayed until the early part of May.

This is required because PSC is in the midst of labor negotiations which may affect the manpower available on back shifts.

In addition, PSC is continuing to develop an alternate design regarding the portable turbine water removal pump committed to in report No. 4 of our Appendix R Evaluation; future correspondence will detail that design to the commission.

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1 P-86266 April 4,1986 If you have any questions please contact M. H. Holmes at (303) 480-6960.

Very truly yours, AdWaL/8 L J R. F. Walker, President RFW:FT:bt l -

Attachments ~

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O ATTACHMENT A

F VALVE POSITION AND ALIGNMENT The following information is provided to supplement statements made in the December 20,1985 letter to the NRC (P-85488), response to. questions 2a/2b. A commitment for this follow-up was contained in the letter of March 14,1986 (P-86209). Valve alignment for manual volves is controlled at two levels. The first level includes those controls required to monitor realignments during plant operation. The second level controls system / valve alignment offer plant outages or major maintenance.

Level I controls (plant procedure P-2) require the Shif t Supervisor to sign-off on all proposed valve realignments, using one of two valve / equipment tagging forms. These are the Standard Clearance Form and the Operations Deviation Form, controlled through SMAP-19. Procedures require use of the forms to change valve position / equipment status prior to and offer maintenance / repairs, and for the valve to be appropriately tagged. Copies of issued forms are kept in the Shif t Supervisors office and the control room. Prior to close out of the form, an independent verification is performed by operations or other qualified individuals (e.g., health physics, etc.) independent of maintenance personnel.

Following satisfactory independent verification, Shif t Supervisor approval is required for the clearance to acknowledge work completion and removal of status tags. Therefore, a system /volve which is not in its normal plant operating position is identified on the referenced forms, tagged, easily identified by plant operators, and controlled to assure it is restored to its proper position.

The second level of control is for major maintenance or outages. For this case, complete system clignment checks are performed in accordance with the plant standard operating procedures (SOP's). These alignment checks are performed prior to declaring that the system has been restored to " operable" status.

The above are judged to be adequate to assure that valve position is properly controlled during and following maintenance activities, and is consistent with the DC-86-77 i

opproach applied to other Ft. St. Vrain emergency procedures. Outage times of systems are minimized in order to meet Technical Specification limits. Controls over non-Technical Specification systems / components will be incorporated in the Fire Protection Program Plan.

Additionally, the fire protection shutdown model incorporates system monitoring instrumentation so that proper system operation con be verified.

System verification was included (through reference to the appropriate instrumentation) in the staffing assessment for local manual operations.

DC-86-77 2

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ATTACHMENT B 1

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• .s APPENDIX R EVALUATION -

FORT ST. VRAIN NUCLEAR GEERATING STATION REPORT NO. I SHUTDOWN MODEL

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Public Service of Colorado

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P. O. Box 840 Denver, Colorado 80201 April,1986 (Rev. 6) includes Rev. I page changes from Report No. 2, Rev. 2 page changes from Report No. 3, Rev. 3 page changes from Report No. 4, Rev. 4 page changes submitted by letter TENERA CORPORATION dated August 30,1985, Rev. 5 page changes 7101 WscWn Amnue as of March,1986, and Be m. W o M 20814 168E Rev. 6 page changes as of April,1986 O

DC-84-21 OTEMeA CompO8AfsCPs 1985

pressure boundary consideration. Other sections of this report summarize 7

the related evaluations that were performed. The end result of these C

shutdown evaluations is a listing of minimum required fire protection shutdown components as contained in Section 3.0 of this report.

Primary System Pressure Boundary:

For a forced circulation cooldown of Fort St. Vrain, primary system integrity is important to assure that a fire will not cause loss of suf ficient helium inventory such that the core heat removal function would not be satisfactority accomplished. The accident analysis relied on for Fort St.

Vrain for shutdown under post fire conditions justifies a forced circulation cooldown following a 1-1/2 hour interruption of circulator operation; however, that accident analysis does not assume helium depressurization.

Accordingly, an evaluation was performed to identify potential pathways for loss of helium from the PCRV, and to determine the potential for a fire to cause inadvertent loss of helium through any of these flow paths.

All penetrations through the primary system boundary were identified and tabulated.

An evaluation was then made for each primary system penetration and a conclusion stated regarding whether each primary system boundary penetration could be compromised, giver, a fire, such that on inadnrtent depressurization with a loss of He would result. In addition, leakage paths associated with the circulators (i.e., along the shaft) have been evaluated.

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DC-84-21 2-3 Rev.6

HV2401) prior to the ventilation system take off line location, it is not considered credible that the 3

primary system integrity would be compromised (Q

through this path.

Based on the above, a fire would not cause a loss of helium from the two helium purification system penetrations, the helium purification pump down line, the ventilation system piping, or the storage system.

c.

Access Some as for refueling penetration closures. A fire would not cause a loss of helium from the top head access penetration.

B.

Bottom Head Penetrations Steam Generator (NOTE: primary closure is within o.

PCRV liner boundary.)

Since the primary closure is built within the PCRV penetration and the secondary closure is a welded plate on the liner, then fire effects would not cause a loss of helium, b.

Helium Circulator Structure (NOTE: total of four

[O3 penetrations).

Since there are no parts of these penetration assem-blies that would be spuriously operated or degraded because of fire, no helium leaks would result.

(NOTE: Helium circulator penetrations such as the buffer lines, static seal actuation system, "O" Ring, and the circulator broke system were evaluated and found not to be a potential primary system leakage path.

Leakage along the shaft of non-operating circulators is eliminated by actuation of the associated circulator broke and seal system.

The bearing water system prevents leakage along the shaft for the operating circulator.)

C.

Sidewall Penetrations a.

Instrumentation (NOTE: Total of 18 penetrations and all have primary and secondary closures that consists of welds, steel pipe, flanges and bolts, and are within the concrete of the PCRV.)

Since there are no leak paths through valves on the instrument lines or other penetrations, no leakage of helium would result because of a fire.

DC-84-21 2-5 Rev.6

i

-TABLE 3.1 (continued)

F.P. Shutdown Train A F.P. Shutdown Train B -

Volves - Manual Only Continued):

Volves - Manual Only (Continued):

Toble2.1-6 Sht 6 Volve V-4229 Table 2.I-6 Sht 7 Volve V-42374.

2.1-6 Sht 6 Volve V-4236 2.1-6 Sht 8 Volve V-75263

• 2.1-6 Sht 6 Volve V-42390 2.1-6 Sht 8 Valve V-4217 2.1-6 Sht 7

.Volve V-4234 2.1-6 Sht 8 Volve V-4218 2.1-6 Sht 7 Volve V-42817 CN-2205 3/ Volve V-211943.

2.1-6 Sht 7 Volve V-4256

'CN-2205 3/ Volve V-211941 2.1-6 Sht 7 Volve V-4239 CN-2205 7/ Valve V-211939 2.1-6 Sht 7 Volve V-4264 CN-2205 7/ Valve V-211937 2.1-6 Sht 7 Volve V-42374 CN-2205 3/ Valve V-211959 2.1-6 Sht 8 Volve V-4217 CN-2205 7/ Volve V-211957 2.1-6 Sht 8 Volve V-75263 CN-2205 7/ Volve V-211955 2.l-6 Sht 8 Volve V-4218 CN-2205 3/ Volve V-211953 CN-2205 3/ Volve V-211959 CN-2205 7/ Valve V-211958 CN-2205 7/ Valve V-211957 CN-2205 7/ Volve V-211956 CN-2205 7/ Valve V-211955 CN-2205 3/ Volve V-211954 i

CN-2205 7/ Valve V-211953 CN-2205 7/ Valve V-211952 CN-2205 7/ Volve V-211942 6.3-1 Sht 4 (Rpt.3)

Valve V-4571 CN-2205 7/ Valve V-211940 6.3-1 Sht 5 (Rpt.3)

Volve V-32102 CN-2205 7/ Volve V-711938 6.3-1 Sht 7 (Rpt.3)

Volve V-21755 CN-2205 3/ Volve V-211936 6.3-1 Sht 7 (Rpt.3)

Volve V-21556 CN-2205 3/ Valve V-211958 6.3-1 Sht 7 (Rpt.3)

Valve V-21622 L

CN-2205 7/ Volve V-211956 6.3-l Sht i I (Rpt.3) Volve V-4625l CN-2205 7/ Volve V-211954 CN-2205 7/ Volve V-211952 i

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CN-2205 (installed in association with the EQ re-onalysis) provides the capability to manually actuate each circulator i

broke and seal system from the Helium Storage Building. The CN to install these volves is listed to document the reference for volve identification and location. Permanent Pi and other drawing details are under development.

DC-84-21 12 Rev. 6 Y

TABLE 3.2 REQUIRED ACM FIRE PROTECTION SHUTDOWN COMPOENTS (Continued)

Component ID Helium Purification P-4701 or Cooling Water Pump P-4702 Selected Plant Lighting Firewater Pump House C-7521 or Vent Fans & Louvers C-7522 Motor Operated Valves (2)

HV-2301 or HV-2302 Reserve Shutdown Rocks I-21 A, System I-21B,1-2iC, I-2lD Startup Battery for Diesel Generator and D.C. Control O

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Liner Cooling Water TI-4629 and Temperature Indicators TI-4630

- Helium Purification PI-23162 System, Het Pressure Indicator Reactor Building Exhaust PDI-7323-1 &

Fan Delta P PDI-7339-l Liner Cooling Pump PI-46334, Discharge Pressure PI-46335, PI-4663, &

PI-4664 Service Water PI-4214, instruments PI-4216, PDIS-4226, PI-4204 &

PI-4206 Circulator Broke and See Table 3.1 page 12 for Seal System Valves CN-2205 Valves.

• Several ID numbers; one for each transfer switch.

DC-84-21 Rev.6

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SELECTED CRC. WATER PLANT SYSTEM LIGHTEC 41 MAKE-UP WATER BREATHtC AIR COMPRESSORS

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ACM SYSTEM INTERRELATIONSHIPS Rev. 6

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O APPEtolX R EVALUATION -

FORT ST. VRAIN NUCLEAR GEPERATING STATION l

REPORT NO. 3 FIRE PROTECTION REVIEWS l

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Public Service of Colorado O

P. O. Box 840 Denver, Colorado 80201 April,1986 (Rev. 4) includes Rev. I page changes from Report No. 4, Rev. 2 page changes TENERA h CORPORATION submitted by letter dated September 26,1985, 7101 Wisconsin Awnue Rev. 3 page changes Bethesda. Mcryland 20814 os of March,1986, and 301 654 8960 Rev. 4 page chenges as of April,1986 DC-84-26 a

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BUILDING (nm CONTROL BLDG.10 L

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ROOM (TR)

TURBIFE BUILDING (Tm Aux.

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MAKE.UP PUMP BUILDING (CW) 0 i

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8U OO FIRE PUMP SERVICE WATER BUILDING BUILDING (SW)

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CIRCULATING WATER PUMP HOUSE & BASIN (CM O

HEllUM STORACE BUILDING (H5)

REACTOR BUILDING (RB) l BUILDING 10 (T)

TUR8IE BUILDING N

ACM CONTROL BUILDING (AC)

EVAPORATING COOLING BUILDING (EB)

ACM DIESEL (AD)

FIGURE 2.2 EXTERIOR FIRE AREAS GRADE ELEVATION Rev. 4