ML20207A828
| ML20207A828 | |
| Person / Time | |
|---|---|
| Issue date: | 11/05/1986 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20207A791 | List: |
| References | |
| NUDOCS 8611110313 | |
| Download: ML20207A828 (22) | |
Text
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Enclosure Safety Evaluation By The Office Of Nuclear Reactor Regulation For Combustion Engineering Emergency Procedure Guidelines
.l.0 INTRODUCTION In the Safety Evaluation Report (SER) of July 29, 1983, (Reference 1) covering Revision 01 of CEN-152, " Combustion Engineering Emergency P.rocedure Guidelines" (EPG), the staff identified a number of items that required further consideration by the Combustion Engineering Owners group (CE0G). Some of the items identified in our July 29, 1983 SER have been addressed in Revision 02, and Submittal 1 of Revision 03 to CEN-152. Re-vision 02 to CEN-152 was transmitted to us by References 2 and 3, and the results of our review of these submittals was provided in Reference 4.
Submittal 1 of Revision 03 to CEN-152 was transmitted to us by Reference 5, j
and the results of our review of this submittal was provided in Referenc,e 6.
L A new submittal, Submittal 2 of Revision 03 to CEN-152, was transmitted to us by letter dated August 6, 1986. Submittal 2, Revision 03 Guidelines proposed changes which addressed the following July 29, 1983 SER items (each item is identified by the paragraph numbers from the SER):
Charging Pump Operation in Loss of Coolant Accident A.
3.4.2.2 (LOCA) Optimum Recovery Guidelines (0RG)
Safety Injection System (SIS) in Loss of Off-site B.
3.8.2 Power (LOOP) ORG*
LOOP previously entitled Loss of Forced Circulation (LOFC).
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3.9.1.2.1 -
Multiple Failure in Functional Recovery Guide-lines (FRG)
D.
3.9.3.2 Reactor Vessel Upper Head Voids in Reactor Coolant Control System (RCS) Inventory Control FRG E.
4.3.1.2 Pressure-Temperature Limits in ORG and FRG i.
The staff has reviewed the technica changes incorporated in Submittal 2, Revision 03 of CEN-152, and the evaluation of these changes is contained in Section 2.0.
Bracketed [-] items signify that plant-specific confirmation is expected by each utility.
2.0 EVALUATION 2.1 Item 3.4.2.2 - Charging Pump Operation in LOCA ORG In Revision 01 to CEN-152, the use of all charging pumps was indicated early in the LOCA ORG. The staff's July 29, 1983 SER indicated that these pu,mps should also be used later during a LOCA under some cir-cumstances.
For example, only one pump was required in the Safety Function Status Check (SFSC) when all may have been needed at high RCS pressure, which may be above the high pressure injection shut-off head. Also, the July 29, 1983 SER indicated that a restart j
instruction may be appropriate for those plants when charging pumps must be manually restarted upon LOOP. This issue was also an open item in the FRG.
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By letter dated May 8, 1984, the CE0G transmitted Revision 02 to CEN-152 which changed the Gu'delines to require the use of all available charging pumps when necessary. The staff reviewed these s
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3 changes, and in their April 16, 1985 Supplement 1 SER, concluded that these changes addressed a portion of our concern in the July 29, 1983 SER, but did not resolve the restart instruction for plants where charging pumps must be manus 11y restarted upon LOOP. Submit-tal 2 of CEN-152, Revision 03 provided guidance for those plants that require the chargina pumps to be manually restarted upon LOOP.
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In particular, the following statement has been added to the Guide-lines:
"[ Charging pump (s) may have to be manually restarted if an interruption of electrical power to the charging pump bus (es) has occurred]."
This statement appears in the bases section of the following ORG and the FRG Success Paths:
1.
LOCA ORG; 2.
Excess Steam Demand Event (ESDE) ORG;
' 3.
LOOP ORG; 4.
Station Black-out (SB) ORG; 5.
Reactivity Control Success Path; 6.
RCS Inventory Control Success Path (2 places);
7.
RCS Pressure Control Success Path (3 places); and, 8.
RCS and Core Heat Removal Success Path (3 places).
The inclusion of the above statement in EPG provides adequate restart instruction for plants where charging pumps must be manually restarted upon LOOP. We, therefore, conclude that these changes
- are acceptable, and address our concerns in our Supplement 1 SER.
These changes along with the changes in Revision 02 to CEN-152 resolve the concerns identified in Reference 1 regarding Charging Pump Operation.
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- 2.2 Item 3.8.2 - Safety Injection System In Loss of Off-site Power Optimum Recovery Guidelines
- The guidance for LOOP was found acceptable for preparation of Plant-Specific Guidelines in our July 29, 1933 SER. However, it was recommended that consideration be given to providing instructions pertinent to SIS operation since the system could be actuated in various ways. Revision 02 to CEN-152 modified the LOOP Guidelines by providing criteria for throttling or stopping the SIS, and by providing SIS restart instructions if these criteria cannot be maintained or met.
In our April 16, 1985 Supplement 1 SER for Revision 02 for this item, the staff recommended that the SIS termination criterion in this Guideline (and other ORG and FRG),
be further evaluated since one of the criteria for throttling or
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stopping the SIS is that "[The RVLMS indicate the core is covered]."
The SIS termination criterion regarding the reactor vessel level monitoring system (RVLMS) has been reevaluated and changed in sub-mittal 2, Revision 03 of CEN-152.
Instead,of requiring that "[The RVLMS indicates the core is covered]," the new criterion states
"[The RVLMS indicates a minimum level at the top of the hot leg nozzles]." The effect of this change will increase the RCS water inventory margin. The staff does not anticipate any operational disadvantage if the reactor vessel is~ filled to the top of the hot leg. The RVLMS heated junction thermocouple (HJTC) level probe design includes a sensor that will allow the operator M determine if the hot legs are full of water. This change appears it. the following ORG and FRG Success Paths where the SIS termination criteria are provided:
LOOP previously entitled Loss of Forced Circulation (LOFC).
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. 1.
LOCA ORG; 2.
Steam Generator Tube Rupture (SGTR) ORG; a
3 '.
ESDE ORG; 4.
Loss of Feedwater (LOF) ORG; 5.
LOOP ORG; 6.
SB ORG; 7.
Reactivity Control Success Path; 8.
RCS Inventory Control Success Path; 9.
RCS Pressure Control Success Path; and,
- 10. RCS and Core Heat Removal Success Path (2 places).
The staff has reviewed these changes. associated with SIS termination criterion regarding the reactor vessel level. Based upon the above discussions, we find these changes acceptable, and they address our.-
concern in Supplement 1 SER. These changes along with the changes i
in Revision 02 to CEN l52 resolve the concerns identified in Refer-ence 1 regarding SIS in LOOP ORG.
2.3 Item 3.9.1.2.1 - Multipje Failures in FRG In our July 29, 1983'SER, the staff stated that the FRG should provide guidance for monitoring safety functions for cases of SGTR, SGTR in both steam generators (SG)', and when other simul-taneous or sequential failures occur (such as steam line break (SLB), LOOP, station blackout (loss -of all AC), SG overfill, and core damage).
Submittal 2 to'CEN-152, Revision 03 partially addresses this open item by significantly expanding the Guidelines to account for malfunction in the plant electrical distribution system. Sub-mittal 2 changed the Guidelines by:
(1) expanding the LOFC ORG to
a include LOOP, and changed the title of the LOFC ORG to LOOP, (2) added to CEN-152 a new ORG for SB, and (3) revised the FRG' success path to account for LOOP-AND SB.
The new guidance on multiple failures did not provide guidance for monitoring safety functions for cases of SGTR, SGTR in both SGs, and when other simultaneous or sequential failures occur (such as SLB, SG overfill, and core damage). The CE00 has committed to address this issue in a future' submittal.
2.3.1 Loss of Offsite Power ORG
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The LOOP Guidelines provide operator actions which should be accomplished in the event of a LOOP including the actions required to mitigate the LOFC. The goal of the LOOP ORG is to maintain control of RCS heat removal by establishing and maintaining natural circulation RCS flow until. nonvital
[e.g., 6.9 kV] AC power can be restored, and reactor coolant pumps (RCP) can be restarted.
Tne LOOP ORG consists of the following sections:
1.
Instructions for operator actions; 2.
Bases for operator actions; 3.
Supplmentary information consisting of additional information on natural circulation flow, shutdown boron concentrations, pressurizer level indication, pressurizer spray cycles, RVLMS indications, RCS Voiding, and hot and cold leg resistance temperature detectors (RTD) temperature indications;
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7-4.
Safety Function Status Check Acceptance. Criteria and bases which includes vital auxiliary accep--
tance criteria to improve the acceptable electri -
cal distribution configurations; and, 5.-
Strategy chart for LOOP.
The guidance'for dealing with a LOOP is summarized in a
Figure 2-1.
The operator instructions are directed at:
(1) establishing, maintaining, and verifying natural cir-L culation conditions in the RCS if all RCP are stopped,
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-(2) restoring the nonvital [e.g., 6.9 kV] AC buse','and
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s (3) if necessary, performing a cooldown to the shutdown f
cooling system (SCS) entry conditions..Th'e guidance identifies entry conditions which include alarms, indica-jy tions, and other plant-specific symptoms indicating that a LOOP or a SB event has occurred, and at least one vital k*
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[e.g., 4.16 kV] AC bus has been restored. The Guidelines also identify the exit conditions which include: (1)non-g conformanceofLOOPdiagnosis,(2)concurrenteventsuch as break in the. primary or secondary system or a loss of.
all feedwater, (3) LOOP Safety Function Status Check Accep-H) tance Criteria not met, (4) no vital AC or DC bus' energi-1 zation, and (5) LOOP Guideline is accomplished. The in-structions are generally as follows:
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1.
Ensure stindard post trip actions, a
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- 2.
Verify Safety Function Status Check Acceptance Criteria.
If not met, then exit to either appropriate ORG or I
FRG.**
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If concurrent LOCA, SGTR, Excess Steam Demand Event, or Loss of Feedwater has occurred, in addition to LOOP, then exit to appropriate ORG.**
4.
Verify at least one train of vital AC powered components are available.
If not, then exit to SB OPG.
5.
Verify at least one vital DC bus is energized.
If not, then exit to FRG.
6.
Ensure that all appropriate breakers on the deenergized buses are open.
7.
[ Restore RCP seal cooling if it has been lost (steps provided)].
8.
Ensure at least one SG has normal band fluid level, feedwater flow supply capability from main or auxiliary feedwater system, and pressure control.**
9.
Ensure RCS Inventory Control is maintained.**
10.
Ensure that the pressurizer pressure control system maintains or restores pressure within the l'
'f post-accident pressure-temperature limit figure."
- 11. Attempt to restore off-site AC power.**
Instruction performed continuously.
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- 12. Restore AC power to plant distribution and station loads per plant-specifics, if it is available, and proceed to instruction 13. Otherwise, continue to attempt to restore power and exit to Instruction 19.**
13., 14., and 15.
These instructions provide RCP restart criteria.
If restart criteria is not met, then exit to Instruction 19.**
16., 17., and 1.
These instructions provide the SIS 8
termination criteria.**
19.
Verify natural circulation flow in at least one RCS loop (steps provided), and ensure proper control of SG feeding and steaming.**
- 20. thru 25.
These instructions address the controlled cooldown.
p 26.
Ensure condensate inventory.**
- 27. Bypass or lower auto initiation setpoints.
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- 28. This instruction addresses the' inadvertent nitrogen e
discharge into RCS through SIS tanks.**
29.
[ Initiate low temperature over pressurization protec-tion].
- 30. Monitor RCS Voiding (steps provided), and continue
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controlled cooldown to the shutdown cooling system (SCS) entry conditions.
Instruction performed continuously.
. 31.
Exit to plant-specific procedures for SCS initiation.
This LOOP ORG contains sufficient guidance for the restoration of deenergized buses, LOFC, concurrent event mitigation, RCS pressure and inventory control, RCP restart, SIS ternin-ation criteria, natural circulation coo,ldown, SG cooling, RCS Voiding and controlled cooldown, and, therefore, we find it acceptable for implementation of plant-specific guidelines.
2.3.2 Station Blackout ORG The new SB ORG addresses extremely unlikely events which include a loss of all vital and nonvital AC power (other "
than that provided by the batteries through the inverters).
The SB ORG consists of the following sections:
u 1.
Instruction for operation actions for restoration of deenergized buses, SG cooling, RCS leakage control, single phase natural circulation cooldown, controlled cooldown, RCS inventory and pressure control, SIS ter-mination criteria, and plant cooling water and ventil-ation systems; 2.
Bases for operator action; 3
3.
Sdpplementary information consisting of additional information on natural circulation flow, shutdown boron concentration, pressurizer level indication, pressurizer spray cycles, RVLMS indication, RCS Voiding, DC power, and hot and cold leg RTD tempera-ture indications;
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.. 4.
Safety Function Status Check Acceptance Criteria and bases which includes vital auxiliary accep-tance criteria to improve the acceptable electri-cal distribution configurations; and, 5.
Strategy chart for SB.
The guidance for dealing with a SB is summarized in Figure 2-2.
The operator actions are directed at:
1.
Establishing a source of electrical AC power and restoring, as a minimum. the plant's vital [e.g.,
4.16 kV] electrical distribution; and 2.
maintaining single phase natural circulation for as long as possible, in order to simplify control of the NSSS, while efforts are directed towards restoring b
vital [e.g., 4.16 kV] AC power.
The Guidelines identify entry conditions which include alarms and other plant-specific symptoms indicating that a SB has occurred. Also, the SB ORG will be exited if SB Safety Function Status Check Acceptance Criteria are not being satisfied or that SB Guidelines have accomplished their purpose.
The instructions are generally as follows:
1.
Ensure standard Post Trip Actions.
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2.
Confirm SB diagnosis by verifying Safety Function Status Check Acceptance Criteria.
If not satisfied, then exit to either appropriate ORG or FRG.**
3.
Ensure at least one SG has normal fluid level, feed-water flow supply capability from auxiliary feedwater system, and pressure control (steps provided).**
4.
Ensure all appropriate breakers on deenergized buses are open.
5.
Continue efforts to make AC power available.
If AC power available from diesel generators (DGs) or alter-nate sources, then restore at least one vital AC bus and one nonvital AC bus, and exit to step'll.**
6.
Open the DC supply breakers (per plant-specific instructions).
7.
Minimize RCS leakage-(steps provided).
8.
Verify natural circulation flow in at least one RCS loop (steps provided).
Ensure SG feeding and steaming per step 3 (steps provided).**
9.
Cooldown RCS as necessary.**
- 10. Bypass and lower the automatic initiation setpoints.
. Instruction performed continuously.
., 11.
Ensure vital AC and DC power supply, when at least c
one vital AC bus is energized.
If no vital AC bus is energized then continue with the instructions from step 5 through 10.
- 12. Maintain pressurizer pressure (steps provided).**
- 13. Verify adequate RCS inventory control (steps provided).
14., 15., and 16.
These instructions provide the SIS termination criteria.**
- 17. Maintain pressurizer. level within desired band (steps provided).**
18.
[ Ensure cooling systems restored].
- 19. Ensure proper operation of heating / ventilation air conditioning (HVAC) in containment, control room, and applicable building systems.
- 20. Exit to LOOP ORG or exit to plant-specific procedure.
This SB ORG contains sufficient guidance to ensure that the plant is placed in a stable, safe condition after res-toring the availability of a full complement of vital components, when at least one vital bus is energized, and therefore, we find it is acceptable for implementation of plant-specific guidelines.
Instruction performed continuously.
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. Although this guideline has addressed (excluding plant-specific items) NRC Generic Letter 81-04 concerns regarding SB to include additional failures in conjunction with,.a SB event, Unresolved Safety Issue (USI) A-44, SB, is still under review by the, staff. Therefore, our conclusion that the SB ORG is acceptable is subject to any recour.endations from the resolution of USI A-44, SB.
2.3.3 FRG Revisions In addition to the changes made to the LOOP ORG and the inclusion of the new SB ORG, the FRG was changed to provide guidance for malfunction in the plant electrical distribution system. The new guidance contains steps for restoring vital
[4.16kV], and nonvital [6.9kV] power to address LOOP and SB from an electrical point of view. Changes were made in the Maintenance of Vital Auxiliaries (AC and DC power) success paths, the Maintenance of Vital Auxiliaries Safety Function S;a'as Check, and the SFCS acceptance criteria. We have raviewed these changes and have concluded they are acceptable.
y 2.4 Item 3.9.3.2 - Reactor Vessel Upper Head Void in RCS Inventory Control FRG Our July 29, 1983 SER stated that treatment for upper head voiding I
in the RCS Inventory Control FRG should be addressed with respect to when a void should be eliminated versus when it may be tolerated.
Also, the SER stated the effect of starting an RCP on RCS behavior, particularly upper head stress, should be considered.
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- Revision 02 added guidance to CEN-152 regarding when upper head voids must be eliminated versus when they mcy be tolerated, but did not address the effect. of starting an RCP on the kCS -behavior. Our April 16,1985 Supplement 1 SER for Revision 02 noted that the guidance-on.when to eliminate voiding can be interpreted to mean voiding could be tolerated until natural circulation is lost, which
. was not-the intent of the guidance.
- Submittal 2 of CEN-152, Revision 03 has revised the guidance for void elimination to clarify that voids are to be eliminated before natural circulation heat removal is lost. The new guidance states that steps are to be taken to eliminate voiding any time voiding Ljeopardizes or threatens RCS heat removal via natural circulation.
This new guidance appears in the following ORGs and FRG Success Paths:
1.
LCCA ORG; 2.
SGTR ORG; 3.
Ef0E ORG; 4.
LOOP ORG;
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5.
SB ORG; 6.
RCS Inventory Control Success Path; 7.
RCS Pressure Control Success Path (2 places); and, 8.
RCS and Core Heat Removal Success Path (4 places).
The staff has reviewed these changes associated with reactor vessel
' upper head void elimination, and find them acceptable. The new gui-dance provides instructions to the operators to take action to esta-blish RCS and core heat removal before natural circulation is lost.
These changes along with the changes in Revision 02 to CEN-152 par-
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16-1) tially resolve the concerns identified in Reference 1 regarding reactor vessel upper head void in the RCS Inventory Control FRG.
The CE0G has committed to address the effect of starting an RCP on RCS behavior, particularly upper head stress, in a future submittal.
?.5 Item 4.3.12 - Pressure-Temperature Limits (PTL) in ORG and FRG Our July 29, 1983 SER stated that guidance should be provided in the ORG and FRG for thh cases where PTL have been exceeded.
Submittal 2 of Revision 03 to CEN-152 provides guidance to the
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operators to reduce the RCS pressure when the RCS subcooling is greater than a preset subcooling margin. The operator actions I
are specified as follows:
i.
1.
Stop the cooldown; 2.
Depressurize the plant using spray system to restore RCS pressure to within the cooldown PTL; m
3.
Attempt to maintain the plant in a stable pressure-temperature 9
configuration as conditions pennit or continue to cooldown within the cooldown PTL; and, 4.
If overpressurization is due to HPSI/ charging flow, then throttle or secure flow and manually control letdown.
The new guidance on PTL was added to:
1.
ESDE ORG;
. 2.
RCS Pressure Control Success Path in the FRG (2 places); and 3.
The RCS and Core Heat Removal Success Path in the FRG (3 places).
Also, guidance was provided in various supplementary information sections to specify the priority when a conflict occurred between maintaining the PTL, and maintaining adequate core cooling. The sections in which the guidance was included are as follows:
1.
ESDE ORG; 2.'
RCS Pressure Control Success Path in FRG (6 places); and, 3.
RCSandCoreHeatRemovalSuccessPathinFRG(3piaces).
The new guidance will reduce the RCS pressure to maintain the preset subcooling margin required,to address the pressurized thermal shock 3
concern, and avoid the conflict between maintaining the cooldown PTL, and maintaining adequate cooling. Therefore, the staff concludes that the guidance is' acceptable for the ESDE ORG, and those Success.
Paths in the FRG where it is included. The CE0G has committed to include this guidance in other appropriate ORG and Success Paths in the FRG, in a future submittal. We will address this issue in a future supplement.
3.0. CONCLUSIONS Based on our review of the August 16, 1986 Submittal 2 of Revision 03 to CEN-152, " Combustion Engineering Emergency Procedure Guidelines,"
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=. the staff concludes that the following items identified in.our July 29, 1983 SER, and our April _16,' 1985 Supplement 1 SER have been resolved as described in Section 2 of this Safety Evaluation.
A.
Item 3.4.2.2 - Charging Pump Operation in LOCA ORG B.
Item 3.8.2 - SIS in LOOP ORG The following items have been partially resolved as described in Section 2:
A.
Item 3.9.1.2.1 - Multiple Failures in FRG B.
Item 3.9.3.2 - Reactor Vessel Upper Head Void in RCS Inventory Control FRG
- C:
Item 4.3.12 - Pressure-Temperature Limits in ORG and FRG.
We also conclude that Submittal 2 to Revision 03 of CEN-152 is acceptable for implementation, and will provide improved guidance for emergency operation procedure development. Resolution of the remaining areas identified in this safety evalution, as well as the issues remaining in the July 29, 1983 SER, will be addressed in future supplements.
4.0 RfFERENCES 1.
Letter, D.G. Eisenhut (NRC) to R.W. Wells (CE0G), " Safety Evaluation of Emergency Procedure Guidelines," dated July 29, 1983.
2.
Letter, R.W. Wells (CE0G) to D.G. Eisenhut (NRC), " Transmittal of 8
CEN-152, Revision 02, ' Combustion Engineering Emergency Procedure Guidelines'," dated May 8, 1984.
4
. 3.
Letter, R.W. Wells (CE0G) to D.G. Eisenhut (NRC), " Transmittal.of.
Appendix A to CEN-152, " Revision 02, ' Response to NRC Core Perfor'-
mance Branch Questions on CEN-152, Pevision 02'," dated November 26, 1984.
4.
Letter, J. Zwolinski (NRC) tc R.W. Wells (CEOG), " Supplement I to Safety Evaluation for CEN-152, ' Combustion Engineering Emergency Procedure Guidelines'," dated April 16, 1985.
5.
Letter, R.W. Wells (CE0G) to H.L. Thompson (NRC), "CEN-152, Revision l
03, Combustion Engineering Emergency Procedure Guidelines," dated l
July 1, 1985.
6.
Letter, J. Zwolinski (NRC) to R.W. Wells (CE0G), " Supplement 2 to Safety Evaluation for CEN-152," Combustion Engineering Emergency i
Procedure Guidelines," dated December 2, 1985.
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2 Mr. Edward Sterling-Mr. G. Douglas Whittier ARIZONA PUBLIC SERVICE C0.-
MAINE YANKEE ATOMIC POWER COMPANY l'
11226 N, 23 Avenue Edison Drive'
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Phoenix, AZ 85029 Augusta, ME 04336 Mr. Thomas H. Cogburn.
Dr. Joseph K. Gasper ARKANSAS POWER & LIGHT COMPANY OMAHA PUBLIC POWER' DISTRICT First Commerical Bank Building 1623 Harney Street
. Capitol-and Broadway Omaha, NE 68102 Little Rock, AR 72203 Mr -Ralph L Phelps
'Mr. Robert F. Ash SOUTHERN CALIFORNIA EDIS0N COMPANY BALTIM0RE GAS & ELECTRIC COMPANY 2244 Walnut Grove Avenue Room 922 - Gas & Electric Bldg.
Rosemead, CA 91770
. Charles Center M,
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1 Baltimore, MD 21203 Mr. Dewey I Hulbert WASHINGTON-PUBLIC SUPPLY SYSTEM 9;
Mr. Kenneth Berry Workman's Creek Road '
CONSUMERS POWER COMPANY Elma, WA 98541 1945 W. Parnall Road eI Jackson, MI 49201 Mr. Peter R. Nelson 6-COMBUSTION ENGINEERING 1
Mr. Donald K. James, Jr.
1000 Prospect Hill Road FLORIDA POWER & LIGHT COMPANY P.O. Box 500.
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9250 West Flager Street Windsor, CT 06095-0500 Miami,'FL 33102 ej,
Mr. John Becker
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Mr. Michael Meisner NORTHEAST NUCLEAR ENERGY C0.
LOUISIANA POWER & LIGHT COMPANY Millstone Nuclear Power. Station 317 Barronna Street Waterford, CT 06385 New Orleans, LA 70160 Mr. Walter Windecker Mr. Joseph Tata (Trailer N51)-
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~ FLORIDA POWER & LIGHT COMPANY SOUTHERN CALIFORNIA EDISON P.O. Box 128 SONGS Hutchinson Island P.O. Box 128 Ft. Pierce, FL 33450 San Clemente, CA 92672 t
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