ML20217C100
| ML20217C100 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 03/20/1990 |
| From: | Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Brach E Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20213E767 | List: |
| References | |
| FOIA-90-570 NUDOCS 9107090216 | |
| Download: ML20217C100 (17) | |
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[pa as cq#'o UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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WALNUT CRI.[ K. CALIF ORNIA 94f>96 6....
March 20, 1990
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Memorandum For:
E. W. Brach, Chief Vendor Inspection Branch, NRR From:
D. F. Kirsch, Chief Reactor Safety Branch
SUBJECT:
EMERGI-LITF AND EXIDE NX-400 EMERGENCY LIGHTING SYSTEMS INSTALLED AT PALO VERDE Per your request, in addition to the licensee's Engineering Evaluation Reports (EERs) and manufacturer's literature already provided, the following l
information regarding oualification of the cmergency lighting systems that were installed in the Palo Verde is submitted for your review and evaluation:
1.
The Emergi-Lite emergency lighting units were not approved for outdoor use by a testing laboratory as stated in the manufacturer's literature, and the licensee's EER No. 89-00-007. However, the units were installed outdoors in pathways to the MSSS.
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2.
The Emergi-Lite emergency lighting units were tested and approved for ordinary u% Dy Underwriters Laboratories (VL) Inc., with installation in ambient temperature environments of 77 degrees F.
Normal temperatures experienced at Palo Verde during summer months are between 120 and 130 degrees F.
During plant operations, the temperatures inside the MSSS can reach 130 to 140 degrees F. during summer months.
3.
The Emergi-Lite manufacturer's lite'rature show that the AC supply soltage to the lighting units is rated at 120VAC. This supply voltage at Palo Verde is 128VAC, which yields a 26.4VDC supply from the battery charger to batteries that have a rated input voltage of 24VDC. This has apparently contributed to lighting unit transformer and battery overheating (licensee EER Nos. 89-0D-015 and 034).
4.
The combination of excessive temperature from the environ::ent, unit operation, and constant cvervoltage conditiom has apparently contributed failure of the Imergi-Lite units to an extent that their performance has been demonstrated unreliable (failure rate in excess of 40 percent).
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5.
Throughout the remainder of the plant, Palo Ver5iinstalled Exide NX-400 emergency lighting units to meet the requirements of Appendix R to 10 CFR 50. These units were stated to be designed and tested to operate in ambient environtrental temperatures of 90 degrees F.
Palo Verde requested test data to confirne environmental qualifications for the Exide units from San Onofre, but San Oriofre did not have any of the qualification test reports. The highest environmental temperature exposure for the lighting units at San Onofre is stated to be where the idSIVs are housed. Temperatures there are expected to range from 85 to 110 degrees on the hottest summer days.
For the short duration of summer temperatures in excess of 90 degrees experienced at San Onofre, adverse environmental temperature exposure appears to be mininial. However, this is not supported by engineering evaluation or test data.
At Palo Verde, higher ambient outside environmental temperatures are experienced,'or longer durations during sumer months.
Table 9.4.2 (enclosure 1) of the Palo Verde FSAR show that the inside design temperatures of the Control Building, Containment, Cable Spreading Room Turbine Building and Diesel Generator Buildings are between 120 and 140 degrees F.
In an recent engineering evaluation (enclosure 2) associated with
{(g Plant Change Package (PCP) No. 89-01-00-002-00, Palo Verde recognized the pottntial environmental tenperature exposure problem for the lighting units. According to manufacturers contacted by Palo Verde, no one in the emergency lighting industry is producing a emergency lighting product that can withstand 120 degrees F environmental exposure. Palo Verde determined that the emergency lighting inoustry uses the UL standard for operation of electronics which is 105 degrees F., and well below the the summer and inside design temperatures at the Palo Verde site. Therefore, no suitable product was available for installation at Palo Verde.
6.
FSAR Sections 9.5.1.1.1, 9.5.3.1.3, Articles 100 and 410-4 of National Fire Protection Association (NFPA) Code No. 70-1975, and Sectior. B.4 of BTP APCSB 9.5-1, implementing the facility Operating License, requires Polo Verde to provide emergency lighting that is tested and accepted for specific purpose or application by a natior, ally recognized testing laboratory. However, Palo Verde has not requested a license aninendment on the basis of unavailability of suitable commercial products.
. The results of our inspection findings regarding these islu~es will be documented in inspection Report flo. 528/90-02.
Based on our findings to date, it has been shown that environmental conditions are cuality affecting parameters that have contributed to the unsatisfactory performance of mergency lighting units that are installed at P610 Verde in support of shfe shutdown, but these quality offecting parameters have not received appropriate consideration by the emergency lighting system manufacturers and/or the Palo Verde procurement and design implementation process.
These fects are for your consideration during your review / evaluation of this tiiattcr, or.d your consideration of the generic implicatior.s associated with each of the issues
- involved, i
This information has been discussed with Greg Cwalina, i
D. F. Kirsch,.hief Reactor Safety Franch cc:
G. Cwalina,liRR J. Martin, RV R. Zinmerman, RV
Enclosures:
1.
FSAR lable 9.4.2 2.
PCP 89-03-00-002-00 Engineering Evaluation
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U N LIM wa s /
PVNGS UPDATED FSAR AIR CONDITIONING. IIEATING. COOLING.
AND VENTILATION SYSTEMS Table 9.4-2 INSIDE DESIGN CONDITIONS
~~
Space Temperatures Maximum Minimum HVAC System (F)
(F)
Control toom 80(a) 70 Computer area 80(a) 70 ESF switchgear 77 60 ESF equipment rooms 77 60 Battery rooms 85 60 Cable spreading 122 40 Auxiliary building (exclud-104(d) go ing ESF equipment room and access control area)
Access control area 80 70 II ESP pump room 104/120 50 II 50/70(c)
Containment building 120/100 Fuel building 104 50
,Radwaste building 104 50 Turbine building Below operating deck 122 50 Above operating deck 122 40 Diesel generator building 5
Diesel generator room ICs/120 ")
50 Diesel generator control room 122 50 Essential spray pond pump house 120 35 a.
Relative humidity 40s to 60s b.
104F for normal operation: 120F allowable for ",
su 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> followed by a decay to 104F over a 24-hour period c.
50-120F for normal operation: 70F-100F for refueling:
20 to 90% relative humidity d.
During a normal plant shutdown, the shutdown heat exchanger rooms and adjacent valve galleries shall be maintained at a maximum temperature of 122F e.
120F during normal operation and testing of the diesel generator: 140F during essential operation a
of the diesel generator.
l 9.4-3
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-Table 9.4-3 HVAC SYSTEMS -- SUIMARY. OF DESIGN PARAMETERS i-AND DESIGN DETAILS (Sheet 1 of 6) 4
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- ri 4% v<.c z ENGINEERING EVALUNr!ON SUDJECT: Altematives to emergency lighting units located in the stairs K, and in the MSSS building at elevation 140',
PROBLEM: The existing installed Emergi. Lite units have quest led to concerns about the lifespan of the unit in the PVNOS hig envirorunent.
SOLtmON 1: Replace the existing emergency lighting units with ne stand the jobsite envirotunent for the specified time.
EVALUATION OF SOLUTION Imds rolution is based on the specific Forty seven companies were considered of w emer-were interested in looking into producing such a product.
r Of these thirteen, only two were willing to back their product wit'
-tters of cenification.
Unfortunately, these let.
ters were not backed by suffient test d dicated that to their knowledge, no one everal ot the larger manufacturers have in-a product that can withstand one hundic.
e emergency lighting industry is producing the industry uses the UL standard for opudon of electronics whichent degrees Farenheit. This temperature is well below the aummer tem is one hundred five nix making their unita unacceptible for our application. There unit is not available to fit our needs.
SOLUTION 11: Place inverters in the Tuibine
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cy EVALUNrlON OF SOLimON II: If two inverters are used and the a imized. Funhennore, by placing the inveners g-building ;>revents the problem of high tempere:utes on the elect walkdown on d' /23/89 confirmed that ther; ts suffient space for the switchgear room ofil.e Turbine Build %g, RECOMMENDATION: Replac ine emergency lighting units located in way, Stairs K, and NSSS clevation 110' with fixtutes powered by inve reeze-above.
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A DRF. DOC F ALO VEIDE EM(RJE NCY L I GHT ! Pip - htR/PV Telecen 7/5/90 1.
Technttal Recuirements of Appendix R A.
Not Applicables (1)
Control Room / Remote Bhutdown Fanel fires - El?ctracal itolation/ transfer capability (a)
FLAR 7.4.1.1.7 (b)
EEF Supplement ~
9 1.6 (c)
RV 1R 528/05-0's, gege 9.
(2)
MSSS fites - Deviction (FFAP 9.B. -;23,:24,0:5 end EER Supplement No.
7, 9,5.1.5).
2.
Legal Requirement A.
Operating License NFF-41, Condition 1.C(7): Nff-51, Ec701tton 1.C(6) and NFF-74, Ctndition 1.F:
(1)
FSAR Table 9P 3-l(D.5).
(2)
F8ER IV-10.
(3)
FSAR T acl e 9. 5-5.
(4)
FEAR 99.2.12.4 and 5.
gr (5) 9/1/89 NOV, fages 3, 4 and 5 (ks
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D.
Commitment (1)
Attachment F of NOV Ferponse, Section !!!.A and 111.C (2)
Sitdc presentatton from 6/5/B9 meeting
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1/11/90 Restart Items (27, 32 and 70) 3.
Safety Concerns A.
Engineering evaluation of unqualified Appendtx R lights which have been demonstrated to be unrellaole.
D.
RV TIA to NPR regarding requirement other than Appencix R.
C.
FEAR 99,2-325 and SER Supplement No. 7 Cold Shutdown manual cctions for cold thutdown.
D.
March 1909 event demonttrated need ior lighting.
C.
Clarification cf FSAR litenting basis via submittal to NhR.
NRR can then request licentee to perf orm additional Appena1r R review l
of fit e at taDling power supply to redundant treins.
I 4.
M stk APS.
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pVNGS UPDATED FSAR SYSTEMS REQUIRED FOR SAFE SilUTDOWN valves are located outside the containment upstream of the main steam isolation valves.
The valves are used to remove decay heat from the steam generator in the event that the main condenser is unavailable for service for any reason, including a loss of ac power.
The decay heat is dissipated by venting steam to the atmosphere.
In this way, the reactor coolant system (RCS) can either be maintained at hot standby conditions or cooled down.
The system instrumentation and controls for the atmospheric dump valves are denctibed below und are shown on figura 10.3-1.
A.
Initiating Circuits and Logic There are no automatic initiating circuits for operation of the atmospheric dump valves.
The atmospheric dump valves are positioned manually by a controller (manual loading station) from either the main control room or the remote shutdown panel as part of the capability for emergency shutdown from outside the control room (see CESSAR Section 7.4.1.1.10).
Each valve has two separate permissive control circuits.
Valve position indica-tion,is provided at each remote control station.
A handwheel is also provided with the atmospheric dump valve for hand operation.
B.
Dypasses. Interlocks. and Sequencing No bypasses, interlocks, or sequencing are provided for the atmospheric dump valves.
C.
Redundancy Atmospheric dump valves are provided to maintain the reactot at hot standby or to initiate a plant cool-down.
Two redundant atmospheric dump valves are provided for each steam generator, one per main steam 7.4-7
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SYSTEMS REQUIRED FOR
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i SAFB SHUTDOWN i
line.
I!owever, in the event of failure of these valves, reactor decay heat will be removed through the main steam linc safety valves, which will be opened
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when pressure in the steam generator reaches the pressure relief setpoint.
Steam release will continue i
until the pressure is reduced to the safety valve reset pressure.
The safety valves will continue to j
cycle in this manner as steam generator pressure rises and is relieved.
The RCS will remain at hot standby conditions during this pressure relief cycling.
Cool-down of the reactor coolant can be accomplished through remote manual operation of the atmospheric dump valves.
Each valve has a handwheel that can be operated locally.
D.
Design Bases 1.
Peter to section 10.3 for design bases for the atmospheric dump valves.
2.
The two separate permissive control circuits are designed to IEEE Standards 279-1971 and 300-1974.
This ensures that no r, ingle failure of the con-trol circuits will cause a spurious opening of a valve or prevent the operation of at least one atmospheric dump valve on each steam generator.
3.
The operation of the atmospheric dump valves is considered in determining the release of iodine due to steam escaping from the dumps during cooldown.
7.4.1.1.0 Shutdown Cooling System Refer to CESSAR Section 7.4.1.1.9.
7.4-0
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PVNGS UPDATED FSAR SYSTEMS REQUIRED FOR SAFE SHUTDOWN
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Table 7.4-1
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REMOTE SHUTDOWN PANEL INSTRUMENTATION AND CONTROLS (Sheet 2 of 2)
Controls 1.
SG atmospheric dump valve permissive controls (8) 2.
Auxiliary FW regulating valve controls (4) 3.
Auxiliary FW isolation valve controls (4) 4.
SG ctmospheric steam dump modulating controllers (4)
NOTE:
The tripping of RCPs can be perform 9d at the switchgear.
5.
Auxiliary FW turbine steam supply valve control (2) 6.
Auxiliary FW turbine speed control transfer switch (1) 7.
Auxiliary FW turbine speed control potentiometer (1)
/
8.
Auxiliary FW turbine trip valve control (1) 16 9.
Auxiliary FW turbine trip puchbutton (1) 10.
All channels of M31S actuation pushbuttons (4) 11.
Channel A and B auxiliary pressurizer spray valve controls (2) 12.
RCP controlled bleedoff containment isolation valve controls (2) 13.
RCP controlled and bleedoff relief isolation valve control (1) 14.
Letdown isolation valve controls (2) 15.
Backup heater groups 1 and 2 controls (2) 16.
Safety injection tank vent valve control and power disconnect switch (10) 17 Shutdown cooling pumps recirculation valve controls (2) 18.
Steam generator pressure variable setpoint reset (4) 19.
Pressurizer pressure variable setpoint reset (4) 20.
Low pressurizer pressure bypass (4) 7.4-11
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9.5.1.6 Fire Protection for Safe Shutdown Capability l(r l
In Section 9.5.1.6 of the SER, the staff stated that the applicant had conducted a study of the safe shutdown capability for PVNGS 3-3. -In addition, the staff stated that the entire alternate shutdown system was under review.
Subsequently, the applicant provided additional information in those two areas.
The following discussion provides the staf f's 6 valuation of the information submitted.
Safe Shutdown Capability l
In Amendment 3 to the Fire Protection Evaluation Report, the applicant provided information concerning fire protection for the safe shutdown capability in accordance with the requirements of Appendix R.
I The applicant's safe shutdown analysis states that systems needed for hot shutdown and cold shutdown consist of redundant trains, and that one of the.
redundant trains needed for safe shutdown would be free of fire damago-hy providing separation, fire barriers, and/or alternative shutdown capability.
For hot ~ shutdown, at least one train from each of the following shutdown systems would be available: _ (1) the auxiliary feedwater system, and (2) the main steam atmospheric dump valves.
For cooldown/ cold shutdown, at least one train from each of the following shutdown systems would be available:
(1) pressurizer auxiliary spray valves, (2) charging system, and (3) low pressure safety injection system.
The safe shutdown analysis considered components, cabling and support equipment for systems identified above which are needed to achieve shutdown.
The support equipment included the diesel generators, the essential spray pond. system, essential cooling water system, essential chilled water system, and necessary ventilation systems.
The applicant performed an electrical train and channel separation study as part-of the safe: shutdown analysis in order to ensure that at least one train of this equipment is available in the event of a fire in areas which might affect these components.
Safe shutdown equipment and cabling was identified and traced through each fire area from the components to the_ power source.
Additional equipment and electrical circuitry considered as related _either because of a shared common power supply or common enclosure, or whose fire induced spurious operation could affect shutdown, were also identified.
The above identified circuits were then sorted by computer into their corresponding electrical division and raceway.
Raceway drawings were then color coded in order to permit identification and verification of adequate separation of redundant trains-of safe shutdown systems within the same fire area.
In addition, field walkdowns were performed as a check on the above method.
Corrective measures were taken as necessary to assure proper separation and/or barriers.
The staff has reviewed the applicant's method and audited several arrangement drawings to verify correct opplication of the methodology.
Based on this review, the staff concludes that the appiteant has provided an acceptable means of demonstrating that separation and/or barriers exist between redundant safe shutdown system trains.
Palo Verde SSER S 9-6 w
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/i n c t) ce) and reactor coolant system; and, local operation of various valves and circuit breakers.
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Alternative shutdown capability is provided for one division ci safe shutdown systems (Train B). Remote shutdown capability is provided for Train "A".
However, this p'B" is electrically isolated from the anel is not electrically isolated from the control room.
Train control room. Disconnect / transfer switches are provided on Train "B" which are properly fused to provided true isolation as is discussed in Information Notice No. 85-09.
Given a contrt>l room fire that damages both redundant safe shutdown trains inside the control room, Train "A" could be lost in the control room and at the Train "A" remote shutdown panel.
Because of the electrical
. l isolation features, the disconnect / transfer switches provided on Train "B" would be used to mitigate the consequences of circuit failures inside the control room and enable local control of equipment required for hot shutdown from the "B" remote shutdown i
panel and other local control stations. All remote shutdown panel Oj instrumentation and disconnect / transfer switches are contained in b
plant technical specification No. 3.3.3.5.
t The "B" remote shutdown panel provides the capability to control the auxiliary feedwater system including atmospheric dump valves.
{
Instrumentation monitoring pressurizer pressure and level, reactor coolant system hot and cold leg temperatures, steam generator pressure and level, auxiliary feedwater flow and condensate storage tank level.sempanaMed. The5 control room alternative shutdown capability was detennined to be satisfactory. However, some minor deficiencies were identified and-afe discussed below.
No violations or deviations were identified.
(1) Hot Shutdown Procedures I
Based on the control room alternative shutdown mechodology used i
by the licensee, a supplemental safe shutdown procedure was developed and implemented for Unit 1 on March 2, 1985 (Procedure No. 41AO-1ZZ44, Revision 1) in accordance with Section III.L. of Appendix R.
The inspectors evaluated the procedure to verify the feasibility of required operator actions that provide control of process variables such as reactivity control, reactor coolant makeup, decay heat removal, process monitoring and support functions when offsite power is available and when offsite power is unavailable.
The procedure review resulted in the inspectors concluding that the performance goals for the shutdown functions could be 8,et within the minimum threshold criteria specified in the FSAR, SER and plan.t technical specifications if all required operator actions were achievable.
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pVMGS UPDATED PSAH PittE ltAZARDS ANALYSIS C.
Deviations from 10CFH50 Appendix R, Section 111.0 1.
A deviation is requested from Section Ill.G.2 to the extent that it requires a 3-hout rated barrier between adjacent fire areas ceparating circuits of redundant traino.
Diseunnion The mechanical penetrations in the containment boundary are not rated.
Mechanical containment penetrations are fitted with flued heads constructed of steel with a minimum thickness of 1/0 inch.
Tho special construction of the flued heads was designed to maintain the integrity of the containment building, gn.nclunion
(
The existir.g design provides equivalent protec-tion to that required by Section 111.G.2.
The design in utandard within the industry.
2.
A deviation in requested from Section Ill.G.2 to the extent that it requires a 1-hour fire barrier between redundant cafe shutdown equipment
- 1. n addition to fire detection and automatic fire suppression.
Dincucalon The MSSS is a single fire area provided with fire detection and automatic suppression throughout, except in Zone 73 which is provided with fire l0 detection only.
The MSSS above elevation 100 feet 0 inch contains redundant safe shutdown components and conduit in both Zone 74A and Zone 74B-In order to meet interface requirements set by the NSSS vendor (to natisfy single failure criteria),
Zone 74A contains both train A and train B valves 9B.2-323
I
- 79 (1) pVNGS UPDATED FSAR FIRE !!AZAHDS ANALYSIS which service the north (No. 1) steam generator, and Zone 74B contains both train A and train U valves which service the south (No. 2) steam generator.
Within the MSSS, there is a contral wall of reinforced concrete construction separating Zones 74A and 74B.
This wall is not rated, but piping and conduit penetrations are sealed.
The wall contains a nonrated door at elevation 100 feet 0 inch.
The door has been certified by the manufacturer to be constructed to 3-hout fire door standards, but is not labeled since it is slightly oversized and has a removable transom.
There is also an 0.5-foot high opening between the top of the wall (elevation 156 feet 0 inch) and the bottom of the missile shleid which allows the structure to vent pressures developed during postulated high energy line breaks.
(Note:
Thi3 opening extends about the entire perimeter of Area XII at elevation 156 feet 0 inch.)
Closure of the MSSS would be detrimental to overall facility safety, operability of any one atmosphere dump valve (ADV) from the control room or remote shutdown panel is sufficient to obtain and maintain hot standby.
However, the capability to control one ADV for each steam generator is required to obtain a cold shutdown.
Zone 74B containn the electrical circuits associated with all'four ADVs.
To ensure that at least one of the Zone 74A ADVs is operable under a postulated Zone 74B fire, the conduit containing the Zone 74A train A ADV are wrapped with Thermo-Lag, thereby ensuring the capability i
to obtain and maintain hot standby.
9B.2-324
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ks gf FIRE HAZARDS ANALYSIS A postulated fire in either zone can result in the loss of operability of both ADVs associated with one steam generator due to actuator, solenoid valve, or pneumatic supply accumulator damage.
However, cold shutdown can be obtained by manual operation (via handwheel) of one of the affected ADVC.
Alternately, there are two otner flow paths (i.e.,
through SGA-UV-134 or SCE-UV-16? far steam generator No.
1, or through SGA-UV-138 or SCE-UV-103 k
for steam generator No. 2) that could also restore a heat removal mechanism to allow the operator to achieve cold shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
The equivalent fire severity in each zone is less than 45 minutes.
Since detection and automatic water suppression is provided, full development of the fire is not expected.
Addi-tionally, fire brigade response is expected within 10 minutes.
The MSSS is accessible via stairwells from the yard and from the turbine building.
Conclusion The existing design assures that one train of equipment necessary to achieve hot shutdown is free of fire damage.
Fire damage to valve actuating equipment required to reach cold shutdown is limited such that an ADV can be manually operated within a reasonable time.
Additionally, to meet complete fire barrier separation per Section 111.G ? requires modifi-cations which would be detrimental to overall facility safety and would not enhance the current level of protcetion.
3.
A deviation is requested from Section III.G.2 to the extent that it requires a 3-hour rated barrier to separate circuits of redundant trains.
March 1989 9B.2-325 Revision 1
l
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i to maintain the plant at safe shutdown.
The staff, therefore, concludes that this condition represents an acceptable deviation from Section 0.4(c) of Appen-dix A to BTP APCSB 9. 5-1.
In AT,endment No.13 to the FSAR, the applicant identified a potential deviation from Section F.16 of the staff guidelines to the extent that they require port-able fire extinguishers and local standpipe outlets for locations that contain tanks supplying water for safe shutdown.
The locations the applicant identified are all outdoor locations with no unmitigated fire hazard within 50 f t.
Manual firefighting equipment is available from the hose houses described in Sec-tion 9.5.1.2.
The staff, therefore, concludes that no deviation exists.
Amendment No. 13 to the FSAR identifies a number of locations where small quan-tities of isolated combustible materials, such as cables, are located above suspended ceilings.
This represents a deviation from Section D.I.f of Appendix A to BTP APCSB 9.5-1, which stipulates that concealed space 5 be devoid of com-bustibles.
In non-safety-related areas, the presence of these combustibles represent no significant fire hazard because of the limited amount and because if they caught fire they would not threaten safety related equipment.
In safety-related areas, at most, only one shutdown division would be exposed to l
damage, and the applicant has committed to install fire detectors in the con-cealed space (refer to Section 9.5.1.2 of this supplement for the evaluation of this commitment).
Therefore, there is reasonable assurance that if these com-bustibles were ignited, the fire would be detected and suppressed at an early stage before significant damage occurs.
The staff concludes, therefore, that this condition represents an acceptable deviation f rom Section D.1. f of the guidelines.
e Q(
in Amendment No.13 to the FSAR, the applicant provided a revised safe shutdown analysis for the main steam support structure (MSSS).
On the basis of this
}
re-analysis, the applicant indicated that a postulated fire in either Zone 74A or 74B of the MSSS can result in the loss of operability of both atmospheric dump valves (ADVs) associated with one steam generator due to actuator, solenoid valve, or pneumatic supply accumulator damage.
However, cold shutdown can be obtained by manual operation (via a handwheel) of one of the affected ADVs.
Alternately, there are two other flowpaths which could also restore a heat-removal mechanism to allow the operator to achieve cold shutdown within
'72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
This is accordance with the technical requirements of Section Ill.G of Appendix R and is, therefore, acceptable.
The applicant also requested approval for a deviation in the condensate storage tank pump house from the technical requirements of Section Ill.G to the extent that it requires a 3-hour-rated fire wall between redundant shutdown divisions.
The concrete wall between the two condensate transfer pumps does not completely separate the pumps.
The wall extends from the pumphouse west wall to a point just past the pump foundation.
However, the applicant has identified an alter-nate makeup path for the cooling water system and has developed procedures to make repairs on fire-damaged systems such that cold shutdown can be achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
This conforms to the requirements of Section Ill.G of Appendix R.
Palo Verde SSER 7 9-13
i 2.
Legal Requirement A.
Operating License NFF-41, Conattion 1.C(7)1 NPF-51, Condi t i on 1.C(6) and NPF-74, Condition 1.F:
(1)
FSAR Table 9P 3-1(D.5).
(2)
FFEE IV-10.
(3)
F5AR Table 9.5-5.
(4)
FEAR 9B.2.12.4 and 5.
(b) 9/1/09 NOV, Fages 3, 4 and 3 B.
Commitment (1)
Attachment F of NOV Response, Eection Ill.A anc Il!.C (2)
Slide presentation from 6/5/69 meeting (3) 1/11/00 Restart Items (27, :2 and 701 i
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3 p engjg UNITED STATES 8
) g 'O 8h NUCLEAR REGULATORY COMMISSION 5\\
4 hem 0N V
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1450 MARIA L ANE, SulTE 210 wAuvuf cattn.cAuronmA S4as September I,1989 Docket Nos.
50-528, 50-529 and 50-530 License Nos.
NPF-41, NPF-51 and NPF-74 EA 89-88 Arizona Nuclear Power Project ATTN:
Mr. W. F. Conway Executive Vice President Post Office Box 52034 Phoenix, Arizona 85072-2034 i
Gentlemen:
SUBJECT:
$250,000 (Inspection Report Hos. NOTICE OF VIOLATIO 50-528/89-13, 50-529/89-13 50-530/09-13 and Licensee Event Report (LER) 50-530/89-001),and This letter refers to inspections conducted from March at your Palo Verde Nuclear Generating Station. events reported 4-31, 1989 concerning The results of these inspections were reported in the referenced NRC inspection reports.
violations of NRC requirements were identified by these inspections.Severa g
4(.
with you during an NRC/ANPP management meetin In general, e
March 3, jection, and loss of non class IE electri safety in 1989.
A number of significant system perturbations followed the main generator full load rejection due to the unexplained operation of an elect protection relay.
This load rejection challenged the reactor power cutback and steam bypass control systems (58CS), which failed to operate properl faulty electronic control system timer card.
The SBCS failure resulted in a reactor trip actuation, an,d a containment isolation actuation.a main steam isolati Electrical power was then completely lost to the non-class IE busses due to the design of the aut transfer control circuitry of the electrical distribution system With the MSIVs closed and power lost to the equip safe-shutdown decay heat removal by bleedin through the atmaspheric dump valves (ADVs).g steam from the steam generators The ADVs failed to open when operated from the control room and later when a non-licensed auxiliary op (AO) attempted to open the valves by using the controls at the remote s panel.
A0s were then dispatched to operate the ADVs manually.
own A0s were eventually able to open two ADVs and thereby commence a Although the their efforts were significantly hampered by inadequa written procedures for the manual operation of the ADVs, inadequ
, poorly CERTIFIED MAIL RETURN RECEIPT REQUESTED c
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Notice of Violatiot. meets or exceeds the requirements and recommendations of Section 5 of ANS 3.1-1978 and Appendix A of 10 CFR Part 55.
ANS 3.1-1978, Section b.3, requires, in part, the~ establishment of a training program for non-licensed operators to properly prepare them for assignments.
1.
Contrary to the above, on March 3, 1989, a non-licensed operator was directed to perform manipulations at the Remote Shutdown Panel.
The manipulation involved an attempt to open atmospheric dump valve SG-HV-178, a task for which the operator had not been trained.
2.
Contrary to the above, as of March 3, 1989, non-licensed operators had not received adequate training to operate the ADVs as evidenced by the problems encountered when attempting to manually operate the ADVs to eaablish decay heat removal af ter a loss of of fsite power, even though the Emergency Operating Procedures required operation of the ADVs.
B.
10 CFR Part 50, Appendix B, Criterion V, provides that " activities affecting quality shall be prescribed by documented instructions, procedures or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with those instructions, procedures or drawings".
Contrary to the above, on March 3, 1989, the procedure posted at the valves for manual operation of ADVs SG-HV-178, SG-HV-179, SG-HV-184, and SG-HV-185 was inadequate for the circumstances, in that it lacked the necessary specificity and detail to ensure thet the specified actions were sufficient to accomplish manual valve operation.
Additional actions not specified in the posted procedure were necessary before the ADVs could be used.
Violations II A.1, 2 and 0 have been categorized in.the aggregate as a Severity Level III problem (Suppler.. ant I).
Civil Penalty - $50,000 (assessed equally among the three violations).
III. Emergency Lighting License NPF-74 for the Palo Verde Unit 3 Nuclear Generating Station, Condition F, reads in part, "APS shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report (FSAR) for the facility, as supplemented and amended, and as approved in the SER through Supplement 11, subject to the following provision:
"APS may make changes to the approved fire protection program without approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire."
A.
FSAR Section 9.5.1.1.R, Safety Design Basis Eighteen, states in part that an emergency lighting system shall be provided in areas
"2,d (f)
Notice of Violation needed for operation of safe shutdown equipment.
Batteries for emergency lights shall be rated for a minimum of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> in areas needed for operation of safe shutdown equipmente _
FSAR Table 9.5-5 and Figure 9.B-40 identify the main steam isolation and dump valve areas in the Main Steam Support (MSS) Structure as g
)
areas needed for the operation of safe shutdown equipment.
Contrary to the above, as of March 3, 1989, the licensee failed to provide an adequate emergency lighting system in the MSS Structure to support the manual operation of the Atmospheric Dump Valves (ADVs).
This is evidenced by the near total darkness the auxiliary operators found in the north and south rooms of the MSS Structure, where the ADVs are located.
Af ter the loss of offsite power, it took about 30 minutes to restore lighting tn the north room and about 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> to restore lighting in the south room.
lights were provided in the immediate area of the ADVs. No emergency This lack of adequate emergency lighting adversely affects the ability to achieve and maintain safe shutdown in the event of a fire, 1
i B.
FSAR Section 9.5.3.4, Inspection and Testing Requirements, states in part, "The emergency de lighting system...[is) inspected and tested periodically to ensure operability of the automatic switches and other components in the system."
FSAR Table 9B.3-1, Section C (Quality Assurance Program), requires the licensee to establish and adheta to documented instructions and administrative controls that gcv m the fire protection program.
Preventive Maintenance (PM) Task 058655 for Unit 3 requires a quarterly walkdown of the emergency lighting system in the MSS structure to verify oparability of battery pack emergency lighting units.
Contrary to the above, as of March ?., 1989, the licensee failed to perform.a quarterly walkdown of the emergency de lighting system per PM Task 058655 in Unit 3 since September 23, 1987, waiving the inspection requirements for 5 consecutive quarters.
C.
FSAR Table 98.3-1, Section C (Quality Assurance Program), Item 5, requires the licensee to establish and implement a test program to assure that testing is performed to demonstrate conformance with design and system readiness requirements.
FSAR Section 9.5.1.1.R, Safety Design Basis Eighteen, states in part that batteries for emergency lights shall be rated for a minimum of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> in areas needed for operations of safe shutdown equipment.
1.
Contrary to the above, test procedure 93GT-0ZZ47, Pre-operational Generic Test Package, Unit 1, 2, and 3, performed during October, 1984, demonstrated operability of various emergency light battery l
- 2. a w >
}
packs located in the MS5 Structure for only 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> instead of the design basis 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
2.
Contrary to the above, as of March 3, 198[,
he 18 month PM Task 055795 for Unit 3 prescribed a 1.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> discharge test of the battery pack emergency lighting units at the 140 foot elevation in the MSS structure, instead of the design basis 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
Violations III A, B, and C have been categorized in aggregate as a Severity Level III problem (Supplement 1).
Civil Penalty - $100,000 (assessed equally among the four violations).
Pursuant to the provisions of 10 CFR 2.201, Arizona Public the Director, Office of Enforcement, U.S. Nuclear 2egulatory Commission within 30 days of the date of this Notice.
marked as a " Reply to a Notice of Violation" and should include for eachThis reply sh d ieged violation:
(1) admission or denial of the alleged violation (2) the reasons for the violation if admitted. (3) the corrective steps that have been taken and the result achieved, (4) avoid further violations, and (5) the date when full compliance will bethe correctiv achieved.
this Notice, an order may be issued to show cause why the licens be modified, suspended, or revoked or why such other action as may be proper should not be taken.
time for good cause shown. Consideration may be given to extending the response
(
U.S.C. 2232, this response shall be submitted under oath or affirmationUnde Within the same time as provided for the response required above under Office of Enforcement, U.S. Nuclear Regulatory Commission, w or money order payable to the Treasurer of the United States in the cumulative
, draft, amount of the civil penalty proposed, or may protest imposition of the civil penalty in whole or in part by a written answer addressed to the Director Office of Enforcement, U.S. Nuclear Regulatory Commission.
fail to answer within the time specified, an order imposing the civil penalty Should the Licensee will be issued.
Should the Licensee elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalty, in whole or in part, such answer should be clearly marked as an " Answer to a Notice af Violation" and may:
(1) deny the violations listed in the Notice in whole or in part, (2) demonstrate extenuating circumstances, (3) show error in the Notice, or (4) show other reasons why the penalty should not be imposed.
In addition to protesting the civil penalty, such answer may request remission or mitigation of the penalty.
Section V.B of 10 CFR Part 2, Appendix C should be addressed.In answer in accordance with 10 CFR 2.205 should be set forth separately from the Any written statement or explanation in reply pursuant to 10 CFR 2.201 parts of the 10 CFR 2.201 reply by specific reference (e.g.,,but may incorporate citing page and paragraph numbers) to avoid repetition.
The attention of the Licensee is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing a civil penalty,
- 2. A W Nctice of Violation packs located in the MSS Structure for only 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> instead of the design basis 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, j
i 2.
Contrary to the above, as of March 3, 1989, the 18 month PM Task 1
055795 for Unit 3 prescribed a 1.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> discharge test of the i
battery pack emergency lighting units at the 140 foot elevation j
in the MSS structure, instead of the design basis 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br />.
Violations III A, B, and C have been categorized in aggregate as a Seve Level 111 problem (Supplement I).
Civil Penalty - $100,000 (assessed equally among the four violations).
pursuant to the provisions of 10 CFR 2.201, Arizona Pu the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission within 30 days of the date of this Notice.
marked as a " Reply to a Notice of Violation" and should include for eachThis re alleged violation:
(1) admission or denial of the alleged violation, (2) the reasons for the violction if admitted (3) the corrective steps that have been taken and the result achieved, (4) avoid further violations, and (5) the date when tull compliance will bethe corre achieved.
this Notice, an order may be issued to show cause why the lic be modified, suspended, or revoked or why such other action as may be prope should not be taken.
/
time for good cause shown. Consideration may be given to extending the response
-U.S.C. 2232, this response shall be submitted under oath or af firmatio
(
Within the same time as provided for the resnonse required above under Office of Enforcement, U.S. Nuclear Regulatory Commissio or money order payable to the Treasurer of the United States in the cumulative
, draft, amount of the civil penalty proposed, or may protest imposition of the civil penalty in whole or in part by a written answer addressed to the Director Office of Enforcement, U.S. Nuclear Regulatory Commission.
fail to answer within the time specified, an order imposing the civil penalty Should the Licensee will be issued.
Should the Licensee elect to file an answer in accordance wi 10 CFR 2.205 protesting the civil penalty, in whole or in part, such answer should be clearly marked as an " Answer to a Notice of Violation" and may:
extenuating circumstances, (3) show error in the Notice, o reasons why the penalty should not be imposed, in addition to protesting the civil penalty, such answer may request remission or mitigation of the penalty.
Section V.B of 10 CFR Part 2, Appendix C should be addressed Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201 parts of the 10 CFR 2.201 reply by specific reference (e.g.,, citing page andbut may in paragraph numbers) to avoid repetition.
The attention of the Licensee is directed to the other provisions of 10 CfR 2.205, regarding the procedure for imposing a civil penalty.
i 2,8 (//
o ATTACHMENT F REPLY TO A NOTICE OF VIOLATION
\\
VIOLATION fil.
111.
Emeroency Liahtina License NPF 74 for the Palo Verde Unit 3 Huclear Generating Statio Condition F. reads in part. "APS shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report supplemented and amended, and as a(pprov)ed in the SER FSAR for the facility, as 11, subject to the following provision:
"APS may make changes to the approved fire protection program withou approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire. "
t A.
FSAR Section 9.5.1.1.R Safety Design Basis Eighteen, states in part that an eergency, lighting system shall be provided in areas i
needed for operation of safe shutdown equipment.
Batteries for needed for operation of safe shutdown equipment. emer i
l L
i FSAR Table 9.5 5 and Figure 9.B-40 identify the main steam l
isolation and dump valve areas in the Main Steam Support
. (I Structure,as areas needed for the operation of safe shutdo(wn )
HSS equipment..
Contrary to the above. as of March 3,1989, the licensee failed to 1
provide.an adequate emergency lighting system in the MSS Structure to support the manual operation of the Atmospheric Dump Valves 1
(ADVs). This is evidenced by the near total darkness the l
Structure, where the ADVs are located. auxiliary operators f L
After the loss of 9ffsite poweri it took :. bout 30 minutes to restore lighting in th9 south No emergency lights were provided in the immediate area of room.
the ADVs.
This lack of adequate emergency lighting adversely 4
affects the ability to achieve and maintain safe shutdown in the j
j event of a fire.
B.
FSAR Section 9.5.3.4. Inspection and Testing Requirements, states In part. "The emergency de lighting system... [is and tested periodically to ensure operability of the) automatic inspected l
switches and other components in the system."
FSAR Table 98.341, Section C (Quality Assurance Program), requires g
the licensee to establish and adhere to documented instructi i
and administrative controls that govern the fire protection program.
l 1
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- 1. 3 I')
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Preventive Maintenance (PM) Task 058655 for Unit 3 requires a I (.
quarterly walkdown of the emergency lighting system in the MSS structure to verify operability of battery pack emergency lighting
(
units.
Contrary to the above, as of March 3, 1989 the licensee failed to
~
perform a quarterly walkdown of the emergen,cy de lighting system per PM Task 058655 in Unit 3 since September 23, 1987, waiving the inspection requirements for 5 consecutive quarters.
C.
FSAR Table 98.3-1. Section C (Quality Assurance Program), Item 5 requires the licensee to establish and implement a test program to ass' re that testing is performed to demonstrate conformance with design and system readiness requirements.
FSAR Section 9.5.1.1.R, Safety Design Basis Eighteen, states in part that batteries for emergency lights shall be rated for a minimum of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> in areas needed for operation of safe shutdown enuipment.
1.
Contrary to the above, testing procedure 93GT 0ZZ47, Unit 1, 2, and 3, performed during October, 1984, demonstrated operability of various emergency light battery packs located basis 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.in the' MSS Structure for only 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> instead of the design 2.
Contrary to the above, as of March 3, 1989, the 18 month PM Task 055795 for Unit 3 prescribed a 1.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> discharge test of the battery pack emergency lighting units at the 140 foot elevation in the MSS structure, instead of the design basis 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />..
N E
.g s
3 fluorescent emergr. cy lights in the Auxiliary Building and Control Buildingt (2) ten Exide Electronics, Model 3CC5, lead-calcium batteries supplying power to Control Room emergency lighting; (3) sixteen Saf t America Inc., Model Nicad 406601, Type F, batteries supplying power to the Pain Steam Suppert Structure (MSSS) and in access and egress pathways thereto; and (4) approximately four hundred-fifty Dual Lite Model, EDE-30, wet cell nickel cadmium, batteries supplying power to 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and 1.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> emergency lighting in the remainer of the plant.
(1) DesignandRegulatorvRequiremera License No. NPF-41, Condition 2.C(7) for Palo Verde Unit 1, License No. NPF-51 Condition 2.C(6) for Palo Verde Unit 2 and p.,
License No. NPF-74, Cor.dition No. 1.F for Palo Verde Unit 3, reads in part, "APS shall implement and maintain in effect all previsions of the approved fire protection program as described in the Final Safety Analysis Report (FSAR) for the f6cility, as supplemented and amended, and as apprc.ed in the SER through Supplement 11. subject to the following provision:
APS may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of fire.
SER Suppies nt No. 7 documents the NRC staf"s review of the licensee ( 2purious actuation studies, item No. 15 of the licensee's November 6, 3984, "Outside Control Room Fire
' ', ~
Spurious Actuation Study" (Studies 01-NS-110, 02-NS-110 and 03-NS-110) reads " Postulated fires in each FSAR Table 9B fire zone of the Auxiliary Building, Control Building and Main Steam Support Structure will be evaluated for their impact on the ability to achieve SSD."
Regarding emergency lighting, Section 9.5.1.4 of SER Supplement No. 8 reads in part "The SER stated that 8-hour battery-powered emergency lights are provided in all areas of the plant necessary for safe shutdown.
By letter dated April 15, 1985, the applicant confirmed that this design concept includes the access and egress routes to these areas".
FSAR Table 98.3-1(C.3) requires implementation of a quality assurance program to ensure that purchased materials, equipment p.3 and services conform to Code Compliance Documents, Performance Test Verification Reports, Pressure Test Verification Reports, Certificates of Compliance for shipment and Material Certificates of Compliance.
Operations Quality Assurance Manual, Revision 5, Criterion 3, implements the provisions of FSAR Table 98.3-1(C.3).
FSAR Table 98.3-1(D.5) requires fixed emergency lighting with 8 3-V hour minimum battery power supplies be provided for safe shutdown equipment and in access and egress routes thereto, q
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