ML20211A983

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Resubmits 860722 & 870202 Exemption Requests & Adds Two New Exemption Requests Re Loss of Ventilation Sys,Per 10CFR App R.Review & Approval Requested Prior to Scheduled Restart in mid-Mar 1987.Related Info Encl
ML20211A983
Person / Time
Site: Crane Constellation icon.png
Issue date: 02/11/1987
From: Hukill H
GENERAL PUBLIC UTILITIES CORP.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
5211-87-2033, NUDOCS 8702190278
Download: ML20211A983 (26)
v • d • e


Text

{{#Wiki_filter:_. GPU Nuclear Corporation NQQIg7 Post Office Box 480 Route 441 South Middletown, Pennsylvania 17057 0191 717 944 7621 TELEX 84 2386 Writer's Direct Dial Number: February 11, 1987 5211-87-2033 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555

Dear Sir:

Three Mile Nuclear Station Unit 1 (TMI-1) Operating License No. DPR-50 Docket No. 50-289 10 CFR 50 Appendix R - Ventilation Exemptions GPUN letter to NRC, dated February 2, 1987 (5211-87-2021), stated that additional technical information to support the existing Appendix R exemption requests for loss of emergency feedwater pump room ventilation and loss of diesel generator building ventilation would be provided separately. This letter hereby resubmits our exemption requests for the two areas above together with additional technical information required for NRC review of these exemptions requests (see Attachment I). This re-submittal supercedes previous discussions related to loss of emergency feedwater pump rocm ventilation and diesel generator building ventilation contained in GPUN letters to NRC dated July 22, 1986 (5211-86-2124) and February 2,1987 (5211-87-2021). In addition, we are hereby submitting two (2) new exemption requests for loss of ventilation systems in the Screen Water Pumpiscuse, and Decay Heat Removal and Nuclear Service Closed Cycle Cooling Pump Room, together with the appropriate technical justification (see Attachment II). NRC review and approval of these exemption requests is desired prior to scheduled re-start of TMI-1 in Mid-March,1987. GPUN is prepared to meet with appropriate NRC representatives, if necessary, at your earliest convenience to discuss any of these exemption requests. 0702190270 070211 DR ADOCK 050002G9 h PDR 0 GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation

i. 5211-87-2033 February 11, 1987 If any additional information is required, please contact us. Si

rely,

-~~ N H. Hukill Vice President and Director, TMI-1 HDH/GG/dk 19289/0791A Attachments cc: J. Stolz, USNRC T. Thoma, USNRC T. Murley, USNRC Region I F. Young, USNRC, TMI-1 Site D. Kubicki, USNRC PEISCB A. Krasopoulos, USNRC Region I iei is i

/ a ATTACHMENT I 1 l l

1. EMERGENCY FEEDWATER PUMP ROOM VENTILATION Exemption Requested Exemption is requested from the requirements of 10 CFR 50 Appendix R, Section III.G.2 to allow manual actions to establish portable ventilation in IB-FZ-2 and IB-FZ-3 as required to ensure the operability of the emergency feedwater system, in lieu of fire protection of the emergency feedwater pump room ventilation system. The manual actions are required within 2 hours for a fire in IB-FZ-3 and CB-FA-1.

Justification There are two areas in the plant where a fire could affect the emergency feedwater (EF) pump room ventilation. These areas are CB-FA-1 (Control Building EL 306') and IB-FZ-3 (Intermediate Building - Motor Driven EF Pump Room). The ventilation requirements for the EF Pump Rooms are different for each area. For the fire in CB-FA-1, ventilation will be sufficient to support manual actions to locally control valves impacted by the loss of instrument air and the operation of one train of the motor driven emergency feedwater system because decay heat removal is being achieved -

by the OTSG's with makeup provided by the emergency feedwater system. For a fire in IB-FZ-3, ventilation will be sufficient to support manual actions to initiate the turbine driven EF pump before 2 hours since decay heat removal during the first 2 hours is being achieved by HPI cooling, as previously approved in the December 30, 1986 NRC SER, and the operation of the turbine driven emergency feedwater system after 2 hours. A conservative transient analysis was performed for each fire scenario above to determine when or if ambient temperatures increase to levels which would impact the operation of the emergency feedwater system. The calculation was conservative in that it did not consider passive heat sinks such as structural steel, steel conduit / tray and natural convective air flow through open passageways. Also the motors are assumed to warm up in ten (10) minutes. The initial ambient room temperatures for the motor and turbine driven EF pump rooms were calculated for these areas when the ventilation system was operating,104*F and 107*F, respectively. All heat sources such as steam piping / equipment and electric motors and lighting were considered in the calculation. The electric motors reach their heat dissipation linearly over ten minutes from zero to full load. Hot piping assumes to warm up linearly over five minutes. For the fire in IB-FZ-3, any fire related heat input during the first two hours was considered negligible when considering the low fire loading, fire detection system, and fire fighting activities for the area. _

For the fire in CB-FA-1, a transient analysis was performed for HVAC failure in IB-FZ-3 using expected heat loads in the areas for the shutdown path (i.e., two motor driven pumps are operating for the first five minutes and one motor driven pump is operating throughout the remainder of the transient in IB-FZ-3 and the heat load in IB-FZ-2 is for when the turbine driven pump is not in operation). For the fire in IB-FZ-3, a transient analysis of IB-FZ-2 was performed for HVAC failure using expected heat loads in the area for the shutdown path (i.e., both motor driven pumps are not operating in IB-FZ-3 during this transient; the only heat load in IB-FZ-2 during the first 2 hours is when the turbine driven pump is not in operation, and af ter 2 hours, the heat load increases to represent all the hot piping when the turbine driven pump is operating). The total failure of EF ventilation system due to the fire in CB-FA-1 or IE-FZ-3 will neither result in unacceptably high ambient room temperatures nor jeopardize the operation of safe shutdown equipment nor impair the performance of the plant operators if manual action is taken within two hours to provide portable ventilation. Results for the fire in CB-FA-1 indicate that on loss of HVAC, (1) ambient room temperatures in IB-FZ-2 will increase from 107'F to a maximum of 132*F in 2 hours, and (2) ambient room temperatures in IB-FZ-3 will increase from 104*F to a maximum of 163.4*F in 2 hours (see attached Figures 1 and 2). Since manual actions are required in these areas, ventilation requirements are based on access to these areas for the local control of EF valves and operability of the motor driven emergency feedwater system. Results for the fire in IB-FZ-3, indicate that on a loss of HVAC, ambient room temperatures in IB-FZ-2 will increase from 197*F to a maximum of 132*F in 2 hours and 143.l*F in 4 hours (see attached Figure 1). Access into IB-FZ-3 is assured within the time required (within 2 hours) for manual actions required to establish portable ventilation. Manual actions are required in these areas within two hours to manually initiate the turbine driven EF pump by opening main steam valves in IB-FZ-3. In addition, the EF flow control valves, EF-V-30 A, B, C, D, require manual control at the valves in IB-FZ-3. Therefore, the ventilation requirements were based on access into this area for manual valve actions and operability of the turbine driven emergency feedwater systems. Based on the maximum temperature calculated during the first 2 hours of this event, access into these areas to manually initiate the turbine driven EF pump is deemed achievable for this emergency condition. The maximum temperature of 132*F which is experienced during the first 2 hours is within the operating parameters of the turbine driven EF system. Previous investigations made in response to 10 CFR 50.49 " Environmental Qualification of Electrical Equipment Important to Safety," indicate that the motor driven emergency feedwater system is qualified to function throughout a design basis accident (DBA). This DBA is a main steam line break in the area. The maximum temperature calculated for the area is well below the temperatures expected during the design basis accident transient. Since manual actions are required in IB-FZ-2 and IB-FZ-3 in the event of a fire in CB-FA-1 due to the loss of instrument air, portabic ventilation will be provided to maintain temperatures at acceptable e levels. Results indicate that portable ventilation should be provided within two hours to achieve and maintain comfortable area temperature. Time is available (withir. 2 hours) to perform such manual actions. Safe shutdown for the CB-FA-1 or IB-FZ-3 fire will be achieved with or without the emergency feedwater pump room ventilation system, when the manual actions are taken to provich portable ventilation. Dedicated portable ventilation equipment will be provided and maintained to accomplish these actions. The underlying purpose of the rule is to ensure the safe shutdown capability during and after any postulated fire in the plant. The rule requires fire protection of circuits and components for safe shutdown systems. Protection of supporting systems, their components and circuits is required if the support is essential for the operability of a safe shutdown system. It has been demonstrated that in the event of fire in CB-FA-1 or IB-FZ-3 the operation of the emergency feedwater pump room ventilation system is not required to maintain acceptable ambient temperatures in the emergency feedwater pump rooms, when manual actions are taken to provich portable ventilation. Sufficient time and available personnel exist to allow these manual actions and maintain the plant in a safe shutdown condition, in lieu of providing fire protection for the emergeecy feedwater pump room ventilation system components. Thus, the underlying purpose of the rule is satisfied by allowing manual actions to establish portable ventilation. Therefore, the exemption being requested I meets the special circumstances delineated in 10 CFR 50.12(a) (2)(ii), in that application of the regulation in this particular circumstance is not i _

r necessary to achieve the underlying purpose of the rule. In addition, the special circumstances of 10 CFR 50 (a) (2)(111) apply in that providing additional protection features, required by the regulations, would not result in a significant increase in the level of protection provided and would result in undue hardship and cost significantly in excess of those incurred by others similarly situated. These costs consist of engineering, procurement of materials, fabrication and installation costs. The analysis and emergency fire procedures incorporating these manual actions will be available for NRC review. l l l l l _ ~ - ~

2. DIESEL GENERATOR BUILDING VENTILATION Exemption Requested Exemption is requested from the requirements of 10 CFR 50 Appendix R, Section III.G.2 to allow door alignment manual actions in the diesel generator building for the purpose of establishing alternate ventilation,

), in lieu of fire protection of the diesel generator building ventilation ) system components. The manual actions are required within 25 minutes for fires in CB-FA-1, CB-FA-2d, CB-FA-2f, CB-FA-3d, and CB-FA-4b to assure the operation of emergency diesel generator 1B, IB-FZ-3 and IB-FZ-4 to assure the operation of emergency diesel generator l A or 1B, and DG-FA-2 to assure the operation of emergency diesel generator l A. 1 Justification i l Fires in various areas of the plant could affect the emergency diesel. generator (EDG) building ventilation system due to fire damage of power and control cables. A transient analysis has been performed which i demonstrates that under a worst case condition of 95'F outsich air i l temperature, the loss of EDG ventilation concurrecu with diesel initiation l will result in temperatures increasing in the area of the safe shutdown equipment to unacceptable levels. These levels per design values are when the ambient room temperatures exceed 122*F. The transient analysis i considered only one of the EDG areas since the redundant room is identical in design and configuration. An inventory of heat sources was developed l l

for the fire area. Heat sources considered the generator and diesel engine under an FSAR load profile, uninsulated exhaust pipe, and area lighting. Under the FSAR load profile, the generator load is stepped from 69% of full load at the start; to 96% load after 40 minutes. The heat attributed to the EDG ventilation unit fan was assumed to be negligible since the ventilation system is considered lost during the fire scenario. The heat loads into the area were ramped during the initial startup period because the design heat loads identified for each component represented steady state values for when the components are fully warmed up. Engine block temperature was ramped up to its steady state value over a 12-minute interval and engine exhaust manifold and exhaust duct temperatures were ramped over 2 and 3-minute intervals, respectively. Heat loss from the generator was calculated considering the heat capacity of the generator mass and the forced cooling characteristics of the generator design. An inventory of heat sinks was developed for the fire area. Heat sinks considered the reinforced concrete floor, walls, and roof and metal from the air start reservoirs, duct work, electrical equipment, conduit, diesel generator day tank and backup instrument air tanks. i l No ventilation was considered in the evaluation, because it was assumed that with the EDG ventilation unit off, and all area doors closed the diesel generator fan could not provide adequate air flow in the diesel j generator room and control room. The analysis did not consider thermal stratification. The room temperature in the vicinity of the electrical components was considered to be an average room temperature. Credit was -

taken for the fact that sensitive electronic equipment contained in a control box would be protected because there is a time lag before the temperature inside the box is fully affected by a change in the ambient room temperature. The analysis for the worst case conditions indicate that the room air reaches maximum continuous operating temperature for the equipment contained within this area (i.e., design temperature 122*F) in 27 minutes (see attached Figure 3). In the most vulnerable of the control boxes, the temperature of the panel on which the electrical equipment of concern is mounted reaches 122*F in 35 minutes. Based on this calculation, corrective measures would be required to provide ventilation in this area. A second calculation was performed to determine if adequate ventilation could be established in the diesel generator area by opening doors so that the diesel radiator fan could move outside air through the area. Normally, the diesel radiator fan draws outside air from a screened opening adjacent to the fan and air from within the diesel generator room provided by the EDG ventilation system. The scraed opening has an approximate area of 168 ft and distance from the fan of 12 f t. The flow into the diesel generator room as provided by the ventilation system is 30,000 CFM from outside air and 6,400 CFM from the diesel generator control room return. The calculation modeled the diesel generator area to identify all openings including the screens, doors, and fire dampers. Door alignment configurations were developed to provide the maximum air flow through the area. The analysis calculated the differential pressure through each door and damper opening. The differential pressures developed were in terms of velocity and pressure (f.e., dP = 1.5 VP). By equating flow in and flow out and differential pressure for openings on _g _

the same boundary, velocities at openings could be determined with respect to velocities at other openings. The available CFM through the diesel generator room and control room was calculated by equating the CFM through the screen and the diesel generator room with the known capacity of the fan. Results indicate that the available air flow (CFM) through the diesel generator room and control room with doors open and the EDG ventilation system off was 19,700 CFM. Based on the available air flow and heat sources in the area, a temperature rise in the diesel generator control room, at the diesel generator near the temperature sensitive equipment and in the diesel generator room near the diesel generator radiator, was conservatively calculated at 0.65'F,19.97*F and 36.29'F, respectively. For these areas, the worst case condition of 95'F outside air temperature would result in maximum steady state temperature of 95.65"F, ll5'F and 132*F, respectively. Due to the air movement in the diesel generator room from east to west, a temperature gradient will occur such that the area at the east wall will have lower temperatures than the west wall where the hot air exits the radiators room. This results in the sensitive electronic equipment located in the control room and east portion of the diesel generator room being subjected to a maximum temperature of Il5*F which has been determined to be acceptable for this emergency condition. The 132*F and 115*F values are conservative because the temperature analysis did not consider passive heat sinks contained in the area. Additional conservatism exists in that heat loads utilized represent full load values which are higher than the values expected for an Appendix R event. __

During the majority of the calendar year the outside air is below 85*F. The diesel generator room and control room are thermostatically controlled at 70-75*F when outside temperatures are less than these values. Temperatures above this setting are governed by outside air temperatures with the maximum design equal to 95'F. For the worst case condition we therefore conclude, through fire area manual action walkdowns, that opening doors in the diesel generator area within 25 minutes can be accomplished for all applicable fire scenarios and that analysis indicates that ambient temperatures will not jeopardize the operation of the safe shutdown equipment contained in the area. Consistent with our previous commitment on 30-minute issues as documented in GPUN letter 5211-87-2034 dated February 10, 1987, emergency fire procedures will instruct the operator to immediately dispatch personnel to begin manual actions to align diesel generator room doors once a fire has been confirmed in one of the above zones. The underlying purpose of the rule is to ensure the safe shutdown capability during and after any postulated fire in the plant. The rule requires fire protection of circuits and components for safe shutdown systems. Protection of supporting systems, their components and circuits is required if the support is essential for the operability of a safe shutdown system. It has been demonstrated that for fires affecting the emergency diesel generator ventilation system, operation of this system is not required to maintain acceptable ambient room temperatures in the emergency diesel generator rooms, when manual actions are taken to open EDG room doors to provide alternate ventilation to the area. Sufficient time and available personnel exist to allow these manual actions and maintain the plant in a safe shutdown condition, in lieu of providing fire protection for the EDG ventilation system components. Thus the underlying purpose of the rule is satisfied by allowing manual actions to establish alternate ventilation to the area. Therefore, the exemption being requested meets the special circumstances delineated in 10 CFR 50.12 (a)(2)(ii), in that application of the regulation in this particular circumstance is not necessary to achieve the underlying purpose of the rule. In addition, the special circumstance of 10 CFR 50 (a)(2)(fii) apply in that providing additional protection features, required by the regulations, would not result in a significant increase in the level of protection provided and would result in undue hardship and cost significantly in excess of those incurred by others similarly situated. The costs consist of engineering, procurement of materials, fabrication and installation costs. The analysis and emergency fire procedures incorporating these manual actions will be available for NRC review. i 1 - _~ _

9 ATTACHMENT II

3. Intake Screen and Pump House Ventilation System Exemption Requested Exemption is requested from the requirements of 10 CFR 50 Appendix R, Section III.G.2 to allow manual actions to establish portable ventilation as required to ensure the operability of safe shutdown components contained within ISPH-FZ-1 and ISPH-FZ-2 of the Intake Screen and Pumphouse. The manual actions are required within four hours for fires in CB-FA-3d, CB-FA-4b, FH-FZ-1, ISPH-FZ-1, ISPH-FZ-2, and ISPH-FZ-3.

Justification Fires in various areas of the plant could affect the operation of the Intake Screen and Pump House Ventilation System (ISPH) due to fire damage of power and control cables. An analysis has been performed which demonstrates that under a worst case condition of 95*F outside air temperature, the loss of ISPH ventilation concurrent with normal operating conditions, will result in t. lowly increasing temperatures in the area. An inventory of heat sources was developed for the fire area. Heat sources considered in the calculation were one (1) Reactor Building Emergency Cooling Pump (RR-Pl A/B), two (2) Nuclear Services River Water Pumps (NR-Pl A/B/C), one (1) Decay Heat River Water Pumps (DR-Pl A/B), two (2) Secondary Services River Water Pumps (SR-Pl A/B/C) and six (6) lube water pumps. -The heat load attributed to these components is deemed conservative for the Appendix R fire because many of the components are not relied upon for an Appendix R safe shutdown (i.e., RR-Pl A/B, SR-P1 A/B/C and lube water pumps). Heat attributed to other electrical equipment in this area (f.e., lighting, SWGR, MCC, panels) was small when compared to the major heat loads and was not considered in the analysis. The only heat sink considered in tne analysis is the concrete walls. The heat transfer through the concrete walls was assuned to occur after 67 hours. Based on the design flow, the normal heat loads and the design cooling capacity of the ISPH ventilation system, the initial temperature in the area for the worst case condition of 95*F outside air was calculated to be 108'F. The analysis consisted of a heat balance equation in which heat generated in the area was equal to the heat absorbed by the concrete walls. The room temperatures were determined for the first 48 hours, therefore, the heat transfer through the walls was not considered. Heat balance equatio:s were developed and the equations were solved for room temperature in terms of time. Results of the analyses indicate that for the worst case condition, the temperature in the ISPH will increase from 108'F to 111*F in 4 hours and to 120*F in 16 hours. Since this temperature is well within the maximum operating temperature for the safe shutdown equipment in the area (i.e. approximately 120*F), portable ventilation will be provided for ISPH-FZ-1 and ISPH-FZ-2 within 4 hours. Safe shutdown will be achieved with or without the ISPH ventilation system, when manual action is taken to provide portable ventilation. Dedicated portable ventilation equipment will be provided and maintained to accomplish these actions. -. --.-

The underlying purpose of the rule is to ensure the safe shutdown capability during and after any postulated fires in the plant. The rule requires fire protection of circuits and components for safe shutdown systems. Protection of supporting systems, their components and circuits is required if the support is essential for the operability of a safe shutdown system. It has been demonstrated for fires affecting the intake screen and pump house ventilation system, operation of this system is not required to maintain acceptable ambient temperatures in the area, when manual actions are taken to provide portable ventilation. Sufficient time and available personnel exist to allow these manual actions and maintain the plant in a safe shutdown condition, in lieu of providing fire protection for the intake screen and pump house ventilation system components. Thus, the underlying purpose of the rule is satisfied by allowing manual actions to establish portable ventilation. Therefore, the exen.ption being requested meets the special circumstances delineated in 10 CFR 50.12 (a)(2)(fi), in that application of the regulation in this particular circumstance is not necessary to achieve the underlying purpose of the rule. In addition, the special circumstances of 10 CFR 50 (a) (2)(111) apply in that providing additional protection features, required by the regulations, would not result in a significant increase in the level of protection provided and would result in undue hardship and cost significantly in excess of those incurred by others similarly l situated. The costs consist of engineering, procurement of materials, i fabrication and installation costs. The analysis and emergency fire procedures incorporating these manual l actions will be available for your review..- -

4. Decay Heat Removal and Nuclear Services Closed Cycle Cooling Pump Room Exemption Requested Exemption is requested from the requirements of 10 CFR 50 Appendix R, Section III.G.2 to allow manual actions to establish portable ventilation as required to ensure the operability of the safe shutdown components contained within the area. The manual actions are required within 2 hours for fires in the AB-FZ-7, CB-FA-1, CB-FA-2d, CB-FA-3b, CB-FA-3c, CB-FA-3d, and CB-FA-4b.

Justification Fires in various areas of the plant could affect the operation of the decay heat and nuclear services closed cycle cooling pump room ventilation system due to fire damage of power and control cables. An analysis has been performed which demonstrates that under a worst case condition of 95*F outside air temperature, the loss of this ventilation system concurrent with Appendix R shutdown condition will result in slowly increasing temperatures in the area. An inventory of heat sources was developed for the area. Heat sources considered to establish the initial temperature of the area were lighting, electric motors for two nuclear services pumps and one intermediate cooling pump, switchgear, and MCC. The transient analysis considered one NS pump, one IC pump and lighting as heat sources. For the localized fire in this area, any fire related heat input during the first two hours was considered negligible when considering the law fire loading, fire detection system and fire fighting activities for the area..

The initial temperature for the area was based on normal operating heat -loads under worst case ambient condition. This temperature was calculated to be 109.7*F. An inventory of heat sinks was developed for the area. Heat sinks considered were the concrete surfaces, water filled piping and HVAC duct. Thermal stratification was not considered in the evaluation. The transient analysis duration was performed for 2 hours. Results of the analysis indicate that for the worst case condition, the temperature in the decay heat and nuclear services pump room area will gradually increase from 109.7*F to 122.3*F in 2 hours (see attached Figure 4). Since no sensitive electronics are located in this area and the temperature during this period is within the emergency operating temperature for the safe shutdown equipment in the area, time is available (within 2 hours) to provide portable ventilation to the area. Therefore, safe shutdown will be achieved with or without the decay heat and nuclear services pump room ventilation system when manual action is taken to provide portable ventilation. Dedicated portable ventilation equipment will be provided and maintained to accomplish these actions. l l The underlying purpose of the rule is to ensure the safe shutdown capability during and after any postulated fires in the plant. The rule requires fire protection of circuits and components for safe shutdown systems. Protection of supporting systems, their components and circuits i-.

is required if the support is essential for the operability of a safe shutdown system. It has been demonstrated that in the event of fire in areas identified above including a fire in AB-FZ-7, the operation of the Decay Heat Removal and Nuclear Services Closed Cycle Cooling Pump Room air handling units is not required to maintain acceptable ambient temperature in the room, when manual actions are taken to provide portable ventilation w' thin two (2) hours. Sufficient time and available personnel exist to allow these manual actions and maintain the plant in a safe shutdown condition, in lieu of protecting the ventilation system components for AB-FZ-7 air handling units. Thus, the underlying purpose of the rule is satisfied by allowing manual actions to establish portable ventilation in this area. Therefore, the exemption being requested meets the special circumstances delineated in 10 CFR 50.12 (a)(2)(ii), in that application of the rule in this particular circumstance is not needed to achieve the underlying purpose of the regulation. In addition, the special circumstance of 10 CFR 50.12 (a)(2)(iii) apply in that providing additional protection features, required by the rule, would not result in an significant increase in the level of protection provided and would result in undue hardship and cost significantly in excess of those incurred by others similarly situated. The costs consist of engineering, procurement of materials, fabrication and installation costs. l l The analysis and emergency fire procedures incorporating these manual actions will be available for NRC review. i. _ _ _ _ _ _

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