ML20212F146

Submits Evaluation of Fire Protection Program Issues, Safe Shutdown Methodology & Analysis of Associated Circuits for Units 1 & 2

ML20212F146
Person / Time
Site:	Susquehanna
Issue date:	10/21/1997
From:	Poslusny C NRC (Affiliation Not Assigned)
To:	Byram R PENNSYLVANIA POWER & LIGHT CO.
Shared Package
ML20212F151	List: ML20212F146 ML20212F192
References
TAC-M90600, TAC-M90601, NUDOCS 9711040196
Download: ML20212F146 (5)

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UNITE 3 STATES NUCLEAR REGULATORY COMMISSION ww gy WASHINGTON, D.C. 30006 4 001

,,,,, October 21, 1997 Mr. Robert G. Byram Senior Vice President-Nuclear Pennsylvania Power sr.:1 Light ,

Company 2 North Ninth Street Allentown, PA 18101

SUBJECT:

EVALUATION OF FIRE PROTECTION PROGRAM ISSUES, SAFE SHUTDOWN METHODOLOGY AND ANALYSIS OF ASSOCIATED CIRCUITS, SUSQUEHANNA STEAM ELECTRIC STATION (SSES), UNITS 1 AND 2 (TAC NOS. M90600 AND M90601)

Dear Mr. Byram:

On December 29, 1989, Pennsylvania Power & Light Ccmpany (PP&L) submitted Revision 4 to the SSES Fire Protection Review Report'(FPRR). Due to an administrative oversight, it was determined that the NRC staff had not evaluated the portion of this submittal that dealt with the safe shutdown analysis. Accordingly, Region I staff requested Office of Nuclear Reactor Regulation (NRR) staff to conduct this review in an internal memorandum dated October 14, 1992. On another ffre protection issue, in a letter dated June 21, 1993 PP&L requested a deviation from Sections III G, J, and L of Ap)endix R to 10 CFR Part 50, with respect to demonstration of the ability to ac11 eve and maintain stable shutdown conditions in the event of a control room fire which dealt with the protection of associated circuits. Subsequently, after a decision was made to modify a number of control circuits in the control room, PP&L, in a submittal dated April 23, 1996, withdrew the deviation request.

Under contract with the NRC, Brookhaven National Laboratory (BNL) provided technical assistance to NRR, Division of Systems Safety and Analysis (DSSA),

Plant Systems Branch (SPLB), Fire Protection Engineering Section (FPES), with the review of Revision 4 to the SSES FPRR and a number of licensee submittals related to the deviation request discussed above. Enclosed is BNL's Technical

- Evaluation Report (TER) of the post-fire safe shutdown methodology and analysis of associated circuits documented in Rovision 4 of the SSES FPRR.

The staff concurs with the conclusions BNL made regarding the acceptability of the licensee alternative post fire safe shutdown methodology and, therefore, this TER constitutes the staff's Safety Evaluation and the approval' of PP&L's safe shutdown methodology included in the FPRR.

On the basis of the BNL review, the staff concludes that the licensee's post-fire alternative safe-shutdown methodology and analysis of associated circuits 01q/

is acceptable except for the lack of analysis for inadvertent condensate ,

injection. During c September 4, 1996, telephone conference, the licensee '

stated that mitigating inadvertent condensate injection is not time critical '  !

(approximately I hour would be available to take mitigating action) and could i be addressed procedurally by incorporating manual operator actions into

, existing procedures. By letter dated June 6, 1997, the licensee confirmed i

' that it had revised Off Normal Procedur3 ON-100/200-009, " Control Room Evacuation," to advise the operators that a fire could cause spurious jT# nn m8!'7 h E. . M. , I.H.II. EE ME MIdITR **l

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R. Byram condensate injection and that, if the postulated event did occur, the safety

-relief-valve (SRV) discharge piping'would remain intact if liquid was discharged through the SRVs. The licensee's analysis concluded that the pipe  ;

loads associated with the postulated fire event causing this condition and the .

-resulting piping loads were lower than the current design basis loads associated with high pressure steam blowdown through an open SRV. The staff finds that the licensee's procedure as revised provides reasonable assurance-that-the spurious condensate injection would be appropriately mitigated.

The staff will review and inspect the following issues / concerns during the

. upcoming fire protection functional inspection scheduled for the weeks of

. October 20, 1997,. and November 3, 1997:

1. PP&L has stated in its May 22, 1995, response to a staff Request for Additional Information achieve either (RA!)hutdown hot or cold s conditions.that no repair However, activities are required as discussed in Section 2.3.1.4 of the BNL TER, a review of alternative shutdown-procedures ON-100-0M and ON-200-009 identified i,teps directing the ,

installation of tcaporary reactor level and temperature indication by Instrument and Ontrol (I&C) technicians. PP&L stated that the use of this temporary instrumentation is only necessary to support the accomplishment of cold shutdown and is not required to achieve and maintain hot shi,tdown conditions. The FPFI follup will verify: (a) the

, availability of required I&C technicians; (b) specific, detailed procedures for installing the temporary instrumentation have been developed and are available for use; (c) dedicated repair parts are available onsite; (d)-the feasibility of required actions; and (e) time required to make the repairs is in accord with the shutdown scenario.

! 2. Section III.L.2(b) of Ap>endix R to 10 CFR 50 specifies that the reactor coolant makeup function >e capable of maintaining the reactor coolant level above the to) of the core for BWR reactors. PP&L has developed three shutdown metlods, designated Paths 1, 2 and 3, which are capable of bringing the plant to a cold shutdown condition in the event of ' we, Paths 1 and 3 consist of the Automatic Depressurization System (A%) and Core Spray System (CSS), Divisions I and II respectively. In' general, Paths 1 and 3 (ADS /CS) are used in the event of fire in areas in which

-habitability and control from the Control Room are assured (i.e., fire

-areas other than Fire Area CS-9). Since use of ADS /CS would allow reactor coolant process variables to vary from those normally predicted for a loss of normal a.c. power, the licensee requested a deviation from the requirements of Sections III.G and III.L of Appendix R to 10 CFR 50 (Deviation Request No. 33). This request was approved by the staff in a l

Safety Evaluation dated August 9, 1989. The basis for staff acceptance I of this deviation was predicated on licensee assertions that its safe i l

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R. Byram . ,

shutdown analysis had demonstrated that during implementation of this shutdown methodology (i.e., ADS /CS) there would be no fuel clad damage, no rupture of any primary coolant or containment boundary, and the level of coolant will always be maintained above the top of the core. 'It is recommended that the capability to maintain the reactor coolant level sbove the top of the core using shutdown Paths 1 and 3 (ADS /CS) be verified during a future inspection.

In a letter dated March 12, 1997 PP&L committed to install circuit modifications to resolve the Appendix R fire-induced spurious motor-operated valve during(MOV) operation the spring 1997 Unit/ damage 2 refuelingconcerns outage and(refer to NRC the spring 1998 Information Unit I Notice 92-1 refueling outage. The staff finds this schedule timely with respect to resolving this safety issue and, therefore, acceptable.

On Unit 1, until the circuit modifications can be made to resolve the MOV spurious actuation concerns, the licensee, as a compensatory measure, has procedurally addressed actions to be taken in the event of a main control room fire. These actions have focused on identifying a number of independent paths that are potentially available for mitigating the effects of multiple hot shorts and spurtes actions resulting from a control room fire. With respect to a control room tire. Opernions has been briefed with respect to the consequence and the potential that a fire can lead to firs-induced circuit failures that can result in damage to valves needed for safe shutdown from the remote shutdown panel. The adequacy of these co 7 nsatory actions for mitigating the consequence of potential spurious acmations and damage to critical safe shutdown valves will be verified durins an inspection by the Region.

Based on the above, the staff has determined that PP&L does not require a l deviation from Sections III G, J, and I of Appendix R to 10 CFR Part 50.

Sincerely, ,

Chester Poslusny, Senior Project Manager Project Directorate I-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Docket Nos. 50-387/388

Enclosure:

As stated cc w/ encl: See next page DISTR!BUTION Docket File CPoslusny PUBLIC M0'Brien PDI-2 Reading OGC 2 l

BBoger ACRS JStolz CAnderson, RGN-I

• SEE PREVIOUS CONCURRENCE OFFICE PDI-2/PM N I-2/LA PDI-2/D* SPLB/BC NAME CPoslusny$rb _M0'Brien N JStolz/& wolinsk FOR TMarsh DATE 'O /12/97 /c/fl /97 10/17/97 09/30/97 0FFICIAL RECORD COPY DOCUMENT NAME: SU90600. GEN-

i R. Byram shutdown analysis had' demonstrated that during implementation of this i

- shutdown methodology (i.e., ADS /CS) there would be no fuel clad damage, no rupture of any primary coolant or containment boundary, and the level of coolant will always be maintained above-the top of the core. The capability to maintain the reactor coolant level above the top of the core using shutdown Paths 1 and 3 (ADS /CS) will be verified during the FPFI inspection.

In a letter dated March 12, 1997, PP&L committed to install circuit modifications to resolve the Appendix R fire-induced spurious motor-operated valve (MOV) operation / damage concerns (refer to NRC Information Notice 92-18) during the. spring 1997 Unit 2 refueling outage and the spring 1998 Unit 1

refue ing outage. The staff finds this schedule timely with respect to

. resolving this_ safety issue and, therefore, acceptable.

0n Unit 1, until the circuit modifications can be made to resolve the MOV spurious actuation concerns, the licensee, as a compensatory measure, has procedurally addressed actions to be taken in the event of a main control room fire. These actions have focused on identifying a number of independent paths that are potentially available for mitigating the effects of multiple hot shorts and spurious actions resulting from a control room fire. With respect to a control room fire, Operations has been briefed with respect to the consequence and the potential that a fire can lead to fire-induced circuit failures that can result in damage to valves needed for safe shutdown from the remote shutdown panel. The adequacy of these compensatory actions for mitigating the consequenci of potential spurious actuations and damage to critical' safe shutdown va' ves will also be verified during the FPFI inspection.

Based on the above, the staff has determined that PP&L does not require a deviation from Sections III G J. and L of Appendix R to 10 CFR Part 50.

Sincerely, lh W Chester Poslusny, Sdnior Project Manager-Project Directorate I-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Docket Nos. 50-387/388 i

Enclosure:

As stated cc w/ encl: See next page

.. o Mr. Robert G. Byram Susquehanna Steam Electric Station, Pennsylvania Power & Light Company Units 1 & 2 cc:-

Jay Silberg, Esq. Regional-Administrator, Region I ,

Shaw, Pittman, Potts & Trowbridge U.S. Nuclear Regulatory Commission 2300 N Street N.W. 475 Allendale Road Washington, D.C. 20037 King of Prussia, Pennsylvania 19406 Bryan A. Snapp, Esq.

Assistant Corporate Counsel General Manager Pennsylvani'a Power & Light Company Susquehanna Steam Electric Station 2 North Ninth Street Pennsylvania Power and Light Company Allentown, Pennsylvania 18101 Box 467 Berwick, Pennsylvania 18603 Licensing Group Supervisor Mr. Herbert D. Woodeshick Pennsylvania Power & Light Company Special Office of the President 2 North Ninth Street Pennsylvania Power and Light Company Allentown, Pennsylvania 18101 Rural Route 1, Box 1797 Berwick, Pennsylvania 18603 Senior Resident Inspector George T. Jones U. S. Nuclear Regulatory Commission Vice President-Nuclear Operations P.O. Box 35 Pennsylvania Power and Light Company Berwick, Pennsylvania 18603-0035 2 North Ninth Street Allentown, Pennsylvania 18101 Di ector-Bureau of Radiation Protection Dr. Judith Johnsrud Pennsylvania Department of National Energy Committee Environmental Resources Sierra Club P. O. Box 8469 433 Orlando Avenue Harrisburg, Pennsylvania 17105-8469 State College, PA 16803 Mr. Jesse C. Tilton, III Chairman Allegheny Elec. Cooperative, Inc. Board of Supervisors ,

212 Locust Street 738 East Third Street P.O. Box 1266 Berwick, PA 18603 Harrisburg, Pennsylvania 17108-1266 l

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