ML20214P338

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Rev 3 to App R Evaluation - Fort St Vrain Nuclear Generation Station Rept 4, Exemptions & Mods
ML20214P338
Person / Time
Site: Fort Saint Vrain Xcel Energy icon.png
Issue date: 04/30/1987
From:
PUBLIC SERVICE CO. OF COLORADO
To:
Shared Package
ML20214P275 List:
References
NUDOCS 8706030321
Download: ML20214P338 (14)


Text

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.s II APPENDIX R EVALUATION -

FORT ST. VRAIN NUCLEAR GENERATION STATION REPORT N0. 4

EXEMPTIONS AND MODIFICATIONS Public Service Compan of Colorado

. O. Box 840 Denver, Colorado 80201 April,1987 (Rev. 3)

Rev. 1 page changes = submitted

.by. letters dated August 30, 1985 and

' September 26, 1985, and Rev. 2 page changes as of

. March, 1986, and-Rev. 3 page changes as of April,1987 60gg((${880267.,

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s TABLE OF CONTENTS

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SECTION PAGE

4.0 PROPOSED CHANGE

S AND MODIFICATIONS 4-1 Sumary Listing 4-1 4.1 Fire Doors 4-1 4.2 Penetration Seals 4-2 4.3 Fire Damper 4-2 4.4 Emergency Lighting 4-2 4.5 Fire Detection 4-3 4.6 ACM Backfeed to Three-Room Complex Switchgear 4-4 4.7 Ventilation Damper Air Bottle 4-4 4.8 Portable Ventilation Fans 4-4 4.9 Portable Turbine Water Removal Pump 4-4 4.10 Cable Re-Routes 4-5 4.11 Valve Operability 4-7 4.12 Service Water Return Pump Controls 4-7 4.13 ACM Diesel Technical Specifications 4-8 4.14 Shutdown Procedures 4-8 4.15 Main Steam 6" Vent Installation 4-8 l

Schedule for Proposed Modifications 4-8 Interim Measures 4-9 Appendix A - Page Changes, Report No. 1 A-1 Appendix B - Page Changes, Report No. 2 B-1 Appendix C - Page Changes, Report No. 3 C-1

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-O 2.11 INSTRUMENT AIR SYSTEM (4.7)

Potential concerns relative to locotton of redundant instrument air compressors

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and cables in proximity to each other in the Turbine Building have been eliminated through: changes to the shutdown model to remove the instrument air compressers; and propcsed modifications to provide air bottles and local control stations for certain valves os described in Sections 4.7 and 4.11.b. These changes to the shutdown model have been incorporated into Reports I and 2.

This change to the shutdown model is also referenced in Appendix C.

I O. 2.12 SWITCHGEAR ROOM FANS (4.8)

Potential concerns relative to location of switchgear room exhoust and vent booster fans and associated cables located within the Turbine Building have been eliminated through proposed modifications to provide portable ventilation fans for switchgear room cooling, as noted in Section 4.8.

2.13 TURBINE WATER REMOVAL PUMPS (4.9)

To resolve potential deficiencies relative to location of turbine water removal pumps in proximity to each other within the Reactor Building, a modification has been proposed as described in Section 4.9 to provide a portoble turbine water removal pump that con be piped-in to bypass the present turbine water removal pumps, and to receive power through a portable cable and transfer switch.

l Exemption Request 3.10 oddresses the resulting separation and protection of lO 2-4 Rev. 3

required. Exernption Request 3.8, Emergency Lights-Facility Wide, addresses

) the proposed approach for emergency lighting, including the use of portable lights for access to out-buildings where yard lighting is not otherwise ovcilable.

2.28 VALVE ACCESSIBILITY / OPERABILITY (Section 6.0)

Pages 6-2 and 6-3 of Report No. 3 Identify various potential deficiencies relative to accessibility and operability of certain volves that may be required to effect shutdown following a fire. Modificottons have been proposed as described in Section 4.1 I to resolve these potentici deficiencies.

2.29 ELECTRIC FIRE WATER PUMP ROOM The Electric Motor Driven Fire Water Pump Room will be separated from the adjacent Diesel Driven Fire Water Pump Room and outside exposure fires by a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated structure. All exterior and interior penetrations are provided with 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated seals including internal conduit seals.

The modifications to the Electric Motor Driven Fire Water Pump Room will p include: The existing door will be upgraded to a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated door 1 assembly. The ventilation damper above this door will be replaced with a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated assembly. Removable hatches provided for equipment Jnaintenance will be upgraded to provide a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated barrier. The transfer switch between normal power and the ACM power for the Diesel Driven Fire Water Pump Room ventilation equipment will be relocated to the Diesel Driven Fire Water Pump Room.

O 2-10 Rev. 3

a beams, and plant personnel could carry hand held lights os a supplement, olthough these are not required to meet minimum lighting requirements. Figure 8 in Section 4.0 depicts o conceptual arrangement of lighting circuits for the new emergency lighting system.

In addition to the above described new lightning system for the Reactor and Turbine Building,8-hour bottery pack lights will be installed in the following out-buildings:

l. Circulating Water Pump Pit
2. 4kV Switchgear Enclosure (Bus I,2, & 3)
3. 4kV Switchgear Enclosure (HVAC)
4. ACM 4kV Switchgear Enclosure
5. Evaporative Cooling Building 2
6. Electric and Diesel Driven Fire Water Pump Rooms l 3.8.4 Conclusion l

The proposal of designing and installing the above described emergency lighting system and 8-hour bottery pack lights would provide emergency illumination equivalent to the requirements of Section lil.J. An exemption from complete compliance with the provisions of Section Ill.J is, therefore, requested.

3.9 COMMON WALL-TURBINE / REACTOR BUILDING 3.9.1 Exemption Requested An exemption is requested from Section Ill.G.2 to the extent that it requires a 3-hour fire rated barrier between contiguous fire creos.

3.9.2 Discussion The Turbine Building and Reactor Building have been selected as two separate fire areas for the purpose of analysis in response to Section Ill G of Appendix R.

The common wall between these areas at all three Turbine Building elevations Rev. 3 3-21

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3 Doors in the "G" wall of Three-Room Complex are addressed in on exemption request (2.6.1, 3.1).

Entrance door to the Electric Motor Driven Fire Water Pump Room.

l 4.2 PENETRATION SEALS Penetration seals to the following oreos will be upgraded to a 3-hour fire rated design:

o West wall of the Three-Room Control Complex o Diesel-Generator Rooms i o Auxiliary Boiler Room o Turbine Lube Oil Reservoir Room o Turbine Lube Oil Storage Room o Hydrogen Storage Room.

Penetration seals in the "J" and "G" walls of 'the Three-Room Complex are addressed in on exemption request (2.6.2, 3.1).

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4.3 FIRE DAMPER j Fire dampers in the diesel generator rooms that are not presently installed at the wall would be relocated to the wall (2.6.3,3.12).

4.4 EMERGENCY LIGHTING The following upgrades to emergency lighting will be provided:

(a) Reactor Building and Turbine Building - The new emer-gency lighting system will provide multiple physically separate systems in each building, with separate and independent power feeds. Electrical power will be pro-vided by the ACM diesel. Lighting systems and circuits will be widely separated to minimize lighting loss due to a fire. Figure 8 depicts the conceptual arrangement of O lighting circuits for the new emergency lighting system.

4-2 Rev. 3

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s Refer to Exemption Request 3.8 for further details and

.O criteria (2.27, 3.8).

(b) Three-Room Complex - The present DC-powered emer-gency lighting system within the Three-Room Complex

. will be modified so that all power feeds remain inside the CCA. With this change, the lighting system will not be offected by a fire outside of the Three-Room Complex.

(c) Out-Buildings - Eight-hour battery pack lights will be installed in the following out-buildings:

Electric Motor Driven Fire Water Pump Room l 4kV switchgear enclosure (Bus I,2, and 3)

Diesel Driven Fire Water Pumo Rnnm 1 ACM 4kV switchgear Turbine evaporative cooling building (d) Access to Out-8uildings - Portable hand-held lights will i be mode available to provide lighting for access to out-buildings.

O 4.5 FIRE DETECTION The following fire detection system upgrades will be made:

(a) Reactor Building Fire Area - Complete fire detection coverage below elevation 4881' and at 4756' will be provided. Other elevctions will have spot or portial coverage in areas of cable concentration or where required due to location of fire protection safe shutdown components or cabling.

(b) Turbine Building Fire Area - Areo-wide fire detection coverage will be provided at the grade and mezzonine levels of the Turbine Building. (3.3)

(c) Turbine Building Access Control Boy - Fire detection coverage will be provided in the Reactor Plant Exhaust Fon room at elevation 4846'-6". (3.5) l Figures I through 7 depict the locations to be provided coverage with fire

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'V detection devices.

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4-3 Rev. 3 l

N (k) Turbine Water Removal Pumps- As noted in 4.9 above, 5 the Train B power cable feeding the transfer switch

, will be re-routed to provide a horizontal separation g of greater than 30 feet.

(1) Electric Fire Pump Room - The existing door and ventilation damper above it will be replaced with 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated assemblies.

Removable equipment hatches will be upgraded to 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire ratings.

The transfer switch for P-450lS will be relocated.

4.11 VALVE OPERABILITY i

h following changes and modifications will be made to provide operability of valves whose controls could be adversely affected due to a fire, and to improve

valve accessibility

(a) Disconnect Switches - Disconnect switches will be pro-vided for valves FV-2205 and FV-2206. The disconnect switches will be provided to interrupt potential faults that could cause valves FV-2205 or FV-2206 to close. The disconnect switches and associated cables will be located to maintain greater than 50-foot horizontal separation.

(2.28, 3.1I)

(b) Valve Operator Air Bottles - Air bottles will be provided to allow local manual operation of valves TV-22153, TV-22154, LV-21303, and LV-21304. (2.28)

(c) Local Control Valve - The air isolation and bleed valve for TV-2227-3 will be relocated to a more readily acces-

sible location. (2.28)

(d) Manual Bypass - Manual bypass volves will be provided around HV-21191 -I and -3, HV-21192-1 and -3, HV-21203-1 and -3, HV-21204-1 and -3. (2.28) l (e) Ladders - Ladders have been provided for valves that I were identified to be not readily accessible. The ladders will be secured nearby to the volve location. (2.28) l (f) Valve Tagging - Large readable tags will be provided for valves requiring local manual operations.

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p .'4.13 ACM DIESEL TECHNICAL SPECIFICATIONS Technical Specifications < for the ACM diesel' will be revised to

improve the surveillance tests and-inspections in order to . result in ,

increased ACM diesel reliabili.ty and availability.. (1.6)

. 4.14: SHUTDOWN PROCEDURES Plant ' procedures will' be prepared or revised to' incorporate the

> shutdown operations relied.on for the Appendix R shutdown model.

4.15 MAIN STEAM 6" VENT INSTALLATION h Two 6" vent ' lines with .two unpowered motor operated valves, a temperature indicator between each set of valves and a separate-4 . pressure indicator on each Main-Steam loop has been installed on each 1

Main Steam loop. This will . permit discharge of Fire Protection-

. Shutdown / Cooling to atmosphere for five hours after initiation'of

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secondary cooling in the steam generators.

4.16 CONDENSATE STORAGE TANK FIRE HOSE ADAPTER AND LEVEL INDICATION ~

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A four valve header will be installed on a spare flange near the top

-of each Condensate Storage Tank, to accept four 1 1/2" fire hoses for j use in Train A Fire Protection Shutdown /Cooldown. Local level y indicators will be installed on each Condensate Storage Tank.

SCHEDULE FOR PROPOSED MODIFICATIONS Table 4-1 provides the schedule forf proposed modifications and changes.. The table indicates the date on which material is available on-site for- installation 'of the;. modification -or change, and the i . length of required plant shutdown for those modifications requiring a h plant shutdown. Modifications requiring a shutdown will be completed

within.the first plant shutdown of sufficient time period following
- the material availability dates. Modification'or changes that do not
- require an outage.will be completed in accordance with the completion date schedule reflected in- Table 4-1. Design of the emergency lighting system will be proceeding in parallel with NRC review and approval;- final design and procurement of materials will await NRC

! approval, with completion in accordance with the schedule reflected i 4

- in Table 4-1.

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o Disconnect Switches - A special repair procedure will be prepared to identify octions to be taken to allow these volves to go to their failed position.

o Valve Operator Air Bottle - The LV's are required for high pressure drain of the required circulator. Local manual operations of these LVs would only be required if l .

loss of steam drive capability to all circulators occurs, closing of the LV were to occur for the required circula-l tor, and loss of function of all three of the other circulators occurs. it is extremely unlikely that all of these events would occur and thus require local operation of an LV. The PV's are each associated with a steam generator loop. For the steam generator loop being used, any one of three valves is required to be opened to use the EES section to flow through the decay heat removal heat exchanger. It is unlikely that a fire would cause loss of all three valves in each steam generator loop. The extremely low likelihood of the occurrence of events requiring local manual operation of these valves in the relatively short time period until availability of the air bottle provides reasonable assurance that shutdown opera-tions will be performed.

o Local Control Valve - Valve TV-2227-3 presently has air isolation and bleed volves. The modification is an f enhancement to better facilitate operability. Accord-ingly, adequate interim capability is provided by the present air isolation and bleed volves, o Manual Bypass (HVs) - A special repair procedure will be prepared to identify required operations should the HVs (requiring manual bypass) spuriously change position.

o Ladders - Other ladders are presently available and could be used in the interim period until additional ladders are provided. The new ladders will facilitate performance of required manual operation. With the availability of other ladders and the short time period until availability

of additional ladders, odequate capability is available in t

the Interim period.

i o Valve Tagging - Valves are presently tagged with stamped metal togs. The large togs are on enhancement to facilitate location and operation of valves. With the short time period until completion of the retagging and the present tagging that is available, sufficient measures are available in the interim period.

F 4-13 Rev. 3

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o ACM Diesel Technical Specification - Technical specifi-cottons are presently issued for the ACM diesel, and the ACM diesel generator is presently installed and operable.

With the short time for submittal and anticipated approval, further interim measures are not judged to be required.

o Shutdown Procedures - The Appendix R shutdown model relies on approved and demonstrated methods for accom-plishing shutdown functions. Present procedures address the opproved methods, and therefore provide guidance to operators in identifying required actions and timing.

Special operational or repair action will be covered as interim procedures as identified elsewhere in this interim measures section. These provide oppropriate guidance in the interim period until completion of modifications and issuance of any required changes to shutdown procedures.

o Fire Water Pump Room Modifications - Present proce-dures call for the use of only the Diesel Driven Fire Water Pump, whereas, the revised models submit-p/

s ted in this revision rely uoan both Fire Water Pumps.

Prior to dependence upon the revised models, if the modifications are not complete, interim compensatory measures of an hourly fire watch will be established to observe the condition of the Fire llater Pump Rooms.

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4-14 Rev. 3

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TABLE 4-1 i

, SCHEDULE FOR PROPOSED MODIFICATIONS Length of Required Change Notice and Plant Shutdown

Item Description Material On Site (Days)* Status i

) 4.1 Fire Doors Aug. 15, 1985 0 Modification complete 4.2 Penetration Seals June 1, 1985 0 Modification complete

4.3 Fire Damper Aug. 1, 1985 0 Modification complete 4.4 Emergency Lighting Feb. 26, 1987 0 To be completed by 08/26/87 l 4.5 Fire Detection Sept. 1, 1985 0 Modification complete.

4 Training to be completed i

by 05/15/87 1

4.6 ACM Backfeed to Three-Room 2 Install by startup l Complex following 4th refueling l 4.7 Ventilation Damper Air Bottle June 1, 1985 0 Modification complete j 4.8 Portable Ventilation Fans June 1, 1985 0 Modification complete 1

4.9 Third-Full Sized Turbine Water Aug. 1, 1987 14 Install by startup ,

i Removal Pump Installation following 4th refueling 4.10 Cable Re-Routes 1 (a) Reactor Plant Exhaust Fan Dec. 1, 1985 14 Modification completed

) 03/06/87 1

(b) Bearing Water Makeup Feb. 24, 1986 14 Modification completed 01/30/87 (c) Surge Tank Level Instrumentation Nov. 1, 1985 14 Modification completed

.l 12/22/87 i

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-TABLE 4-1

(continued)

Length of Required Change Notice and Plant Shutdown Item Description Material On Site (Days) Status.

4.10(d) Feedwater Flow Monitoring Oct. 15, 1985 .14 Modification completed 01/07/87 (e) Feedwater Flow Associated Cables Oct. 1, 1985 14 Modification completed 12/12/86 (f) ACM Fuel Oil Transfer Pisap Dec. 15, 1985 14 Modification completed 02/24/87 -

(g) Helium Flow Instrument Cables Dec. 30, 1985 14 Modification complete (g.1) Helium Flow Instrument Flow Modification complete (h) Main Steam Temperature Indication Jan. 15, 1986 14 Modification completed 08/12/86 (i) Bearing Water Pumps Feb. 15, 1986 14 Podification completed 03/06/87 (j) . Emergency Water Booster Pump Mar. 15, 1986 14 Modification completed 11/09/86 (1) Fire Water Pump Room Upgrade 0 ' Install by Aug. 15, 1987 4.11 Valve Operability (a) Accumulator / Actuator Modification May 1, 1986 14 Modification completed 03/07/87 (b) Valve Operator Air Bottles June 1, 1985 14 Modification complete (c) Local Control Valve June 1, 1985 14 . Modification complete  !

(d) Manual Bypass July 1, 1985 14 Modification complete (e) Ladders June 1, 1985 0 Installed by Aug. 15. 1987 (f) Valves Tagging June 1, 1985 0 Modification complete Rev 3

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TABLE 4-1 (continued)

Length of Required Change Notice and Plant Shutdown Item Description -Material On Site (Days) Status

.1 4.13 ACM Diesel Tech. Specs ----

April 1, 1985 (draft to NRC) 4.14 a) Shutdown Procedures (Original ----

Model)

Complete b) Shutdown Procedures (Revised Models) Will be completed prior to reliance Special Repair Procedures ----

on revised models (including fire watch)

Complete 4.15 Main Steam 6" Vent Installation Loop 1 Jan. 19, 1987 --

Modification complete

. Loop 2 Jan. 26, 1987 --

4.16 Condensate Storage Tank Fire Hose ----

0 Install by August 15, 1987 Adapter and Level Indication Table 4-1 identifies numerous modifications requiring at least a 14-day scheduled plant shi udwn for installation. PSC will make every effort to install as many as possible during each scheduled shutdown, but it should not be inferred that all modifications for which material is on-site will be installed during the first scheduled shutdown.

Rev 3