ML20236D127

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Rev 0 to Safety Evaluation for Mod 2085,Peach Bottom Unit 3
ML20236D127
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 09/03/1987
From:
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
Shared Package
ML20236D095 List:
References
NUDOCS 8710280030
Download: ML20236D127 (9)


Text

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?870079540

' Attachnent I ELECTRICAL ENGINEERING DIVISION N3-1, 2301 Market Street August 17, 1987, Rev. O I

Safety Evaluation for Modificatan 2085 Peach Bottom APS Unit 3 Files RES 5-3 (Mod 2085) -

Doctype 565

. Subjects Modification 20 ' upgrades process and diagnostic instrumentation to meet 10CFR50 Appt x R-Safe Shutdown instrumentation requirements at Peach Bottom APS Unit 3. The scope of this modification entails the rerouting of existing instrument and power cables, the change of powerg, feeds and the addition of alternate power feeds to existing instrument loops, the replacement of a -CST water level transmitter and the installation of a complete reactor water level instrument loop.

Conclusion _:

Although this modification does involve safety-related equipment and systems, no unreviewed safety questions are involved. This modification does not involve a significant hazards consideration.

Changes to the Technical Specifications are not required. This ,

modification is a fire protection modification and affects fire protection equipment and systems. However, the capability to safelyAn shutdown the plant in the event of an Appendix R ' fire is improved.

amendment to the operating license or NRC approval prior to installation is not required.

Discussion:

A fire event used throughout this document is described as an i 1

Appendix R fire for which the definition can be found in the Peach Bottom APS Units 2 and 3 Fire Protection Program (FPP).

Appendix . R - Safe Shutdown requirements require that process and diagnostic instrumentation be provided to assure safe shutdown of the reactor in the event of a fire in any of the fire areas that have been defined for the Peach Bottom APS Unit 3 and common areas except for the j i

control room, cable spreading room and remote shutdown panel areas. For these areas, alternate shutdown instrumentation will be provided I separately. Diagnostic indication will be provided only for the systems associated with the safe shutdown methods (A, B, or C) which are described in the PBAPS Units 2 and 3 PPP. Process indication will be provided for reactor water level and pressure, d:,(well pressure and tempe ra tu re , suppression pool level and temperature, and condensate In I

storage tank (CST) water level for safe shutdown methods A, B and C.

certain fire arcar,, in the event of a fire, control room indication of some instrument loops is assumed to be lost because either power and 9710200030 871016 PDR ADOCK 05000277 a F PDR j_

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. 2870079540 Attachment I Page 2 of 15 q instrument cables or components associated with the safe shutdown instruments are assumed to be lost. Therefore, the Appendix R Task Force has identified the following work in order to bring Peach Bottom APS Unit 3 in compliance with Appendix R-Safe Shutdown instrumentation requirements:

1. Reroute the following instrument cables:

a) 3Q1243H associated with instrument FI-3-14-50B, out of 1

-Fire Area 2.  !

b) 3Il30F associated with instrument TRS-3-10-131, out of Fire Area 13N.

2. Provide alternate power feeds from distribution panel 30Y50 with automatic transfer capability to instrument loops FI-3-10-132A, FI-3-10-139A, TR-5805, LI-9027, and 24 VDC '5- ,

power supply PS-2 which is located inside panel 30C144. In addition, these loops along with instruments PR-3-6-105,  !

E/S-3-6-91, TRS-3-10-131 and the new reactor water level instrument loop, including the compensating network, will be i fed from u second alternate feed from panel 20Y33. The feeds from panel 20Y33 to the instruments will be through a removable keylock manual transfer switch.

3. For Fire Area 13N:

a) Install a new reactor water level transmitter on instrumentation rack 3BC91 and connect the transmitter to  !

existing level indicator LI-3-2-3-91B which will be disconnected from LIS-3-2-3-73B.

b) Change power feed to instrument loop PT-5805 from the output of the 24 VDC ECCS power supplies to the 24 VDC power supplies within panel 30Cl44. The instrument and the new 24 VDC power feed cables of PT-5805 will be rerouted to meet the Appendix R separation requirements.

In addition, the 120 VAC power source to PR-5805 will be ,

modified to provide alternate power from panels 30Y50 and 20Y33, through an auto and a manual transfer switch respectively. The new power cable to PR-5805 from panel 30Y34 will be installed non-safeguard.

4. Change power feed of CST instrument loop LT-9453 from distribution panel 00YO3 to the 24 VDC power supplies within panel 300144, and replace transmitter LT-9453 for a fire in Fire Area 50.
5. Change power feed to temperature indicator TI-3501 from distribution panel 30Y34 to 30Y33 for a fire in Fire Areas 13S, 26, 30, 34, 35, 36, 37, 40, 45 and 50.
6. Install a new cable from temperature transmitter TT-3442B to distribution panel 30Y32 for a fire in Fire Area 12.

L 2870079540 d '

Page 3 of 15 j Attachment I 4 l,

7. Remove the manual transfer switches from panels 30C19 and ,

j 30C144, which were installed as part of Modification 1029E.

This modification affects safety-related systems and components.

1. The cables listed in item 1 will be rerouted so that control
  • room indication, for the parameters associated with the {

cables, is maintained during a fire in the fire areas through which the cables are presently routed. The cables are non-Q-listed. The change in loop impedence of the instrument loops associated with the cables, caused by the new routing l will not exceed the allowable loop impedence of each instrument loop. The rerouting of these cables will be in i accordance with established design criteria for electrical,5 separation (i . e . , Bechtel Specifications E-1315 and E-1317) and will meet fire protection separation requirements of Appendix R.

2. A fire in Fire Area 13N (plant general area elevations 135' north, 165', 195' and 234') could cause the loss of all emergency load centers and therefore, all 480 and lower voltage AC power except for 120 VAC power available temporarily through distribution panel 30Y50. To ensure that diagnostic and process instrumentation is available in the control room in the event of a loss of power, this modification provides alternate power feeds from distribution panel 30Y50, through auto transfer switches, to instrument loops FI-3-10-132A, FI-3-10-139A, TR-5805, LI-9027 and power i supply PS-2 which is located inside panel 30C144. These instruments are not Q-listed and do not perform any safety-related function. The addition of alternate power feeds will not adversely affect the function or reliability of the instrument loops.

Distribution panel 30Y50 is normally fed from the 3BD01 and 3DD01 batteries through distribution panel 3BD18, load center 30D08 and static inverter 30D37. The batteries do not have recharging capability because of the loss of all 480 and lower voltage AC power, therefore, the temporary 120 VAC power available through panel 30Y50 will be lost when the batteries discharge. To restore power to the above instrument loops and to instruments P '-3-6-105, E/S-3-6-91 and TRS-3-10-131, which are normally fed from panel 30Y50 and are also required for safe shutdown in the event of a fire, alternate power feeds from Unit 2 distribution panel 20Y33 will be installed to these instrument loops through a removable keylock manual transfer switch. This switch will insure that the alternate feeds from Unit 2 distribution panel to the above Unit 3 instrument loops will be transferred only when an Appendix R fire occurs because a manual operation is required to operate the switch.

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, l 2870079540.

U .:- -Attachment I: Page 4 of 15 l i The .. design . and installation of . the auto and manual transfer i

switches,; including the routing of cables fromuand to the L switches and the ' instrument loops, will be in'accordance with established design and installation criteria . of Bechtel Specifications E-1315 and E-1317 and will meet the fire -

> protection requirements of Appendiv R. Since the instrument loops are not safety-related, the. auto and manual transfer switches need not be environmentally or seismically. qualified. .

. However, environmental.-design. requirements for the auto- and -

manual transfer switches will be specified to ' ensure

" compliance with Regulatory ' Guide 1.97 (Accident Monitoring Instrumentation) ' commitments.

3. In addition to.the' loss of.AC power, a fire in Fire. Area 13N. j

.w ould cause loss of control room indication for all the reactor water level and drywell: pressure instrument loops.

This condition exists because either.the transmitters are

  • located in Fire ? Area 13N or the cables associated with the-

. transmitters are routed, through' this fire area. To ensure

- that : control room indication for reactor water level and N drywell pressure is available should a fire occur in this fire area, this modification will:

a) Install a new reactor water level transmitter on jet pump instrumentation rack 3BC91 which is located on elevation 135' . in Fire Area 13S.

Control room indication for the l

g. new reactor water level transmitter .will be available through existing level indicator LI-3-2-3-918 which will be disconnected from LIS-3-2-3-73B and retagged as LI-3-2-3-113. This indicator now reads reactor shroud level. In order to ensure indication of' all reactor water level ranges during a postulated fire, the signal from the new transmitter will be compensated for reactor pressure and jet pump flow, with signals from  ;

transmitters PT-3-6-105 and PT-3-2-3-630, respectively, and the indicator scale will be changed to -325 to +60 incht.s such that wide range and reactor shroud range can be read. The new compensated reactor water level instrument loop will require ~ the reroute of instrument cables associated with the reactor pressure and jet pump flow transmitters. The compensating network function is not safety-related. The electronic nest, which will house the cor % sating network, need not be environmentally or seismically qualified. However, the electronic nest, which will be installed inside a safety-related, Q-listed panel (30C722B) , will be mounted such that it will not demage any safety-related equipment present inside the panel during a seismic event. The additional weight load of the electronic nest will not j affect the seismic qualification of the panel. The j U, electronic nest will be powered by 120 VAC from distribution panel 30Y50. The power feeds of instrument l

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' Attachment I Page 5 of.15-loops PT-3-6-105iand PT-3-2-3-63C will be changed'so that both loops 'will be fed. from an' existing single DC power Le supply fed also from ' distribution' panel 30YSO.- Level L indicator LI-3-2-3-91B is - not .Q-listed. Disconnecting

, this indicator from level ' indicating switch LIS-3-2-3-73B, which is Q-listed, will not adversely affect the safety-related function of the level switch.

,- Surveillance test' procedure ST-9.1-3X and a control room ,

, annunciator will ensure control room operators that the level indicating switch is properly operating.

b) Change the power feed to instrument loop PT-5805.from the

-output of the 24 VDC ECCS power supplies to the '24 VDC

' power' supplies within panel 30C144. In addition, the 120 VAC power source to PR-5805 will be modified to provide alternate power from panel 30Y50 through an automatic  !

transfer switch. The new power cable to PR-5805 will b@ I installed non-safeguard. The power and instrument cables to PT-5805 will- be rerouted to ~ meet . . the Appendix R separation requirements. Instruments PT-5805 and PR-5805' are Q-listed and only provide drywell pressure indication in . the control room. Their safety-related function, post-accident monitoring of drywell pressure, was replaced by Q-listed drywell. pressure loops PT-9102A, B, C and D and PR-9102A and B. Since the indication portion of the instrument loop, PR-5805, is no longer safety-related, it can be deleted from the Q-list and the changes described above can be made. The pressure transmitter, PT-5805, will remain. on the Q-list for drywell pressure boundary integrity consideration only.

The cab e rsating and installation of the new reactor water level comp nsating network, including the new routing of the reactor w .ter . level loop and reroute of instrument cables associated with transmitters PT-3-6-105 and FT-3-2-3-63C, the power feed change to PR-5805 and the reroute of power and instrument cables of PT-5805 will meet the installation and electrical separation requirements of Bechtel Specifications E-1315 and E-1317 and the t' ire protection separation requirements of Appendix R. All piping, tubing, fittings, instrument valves and supports associated with the new reactor water level transmitter, from the existing instrument sensing lines up to and including the first new instrument shutoff valve will be Q-listed. The remainder of the mechanical work will not be Q-listed. The new reactor water level transmitter will not be Q-listed because it will not perform any safety-related function. Therefore, environmental or seismic qualification of the transmitter is not required. However, the transmitter and its associated piping, tubing , fittings, and instrument valves, will be seismically mounted te maintain pressure boundary integrity. Maintaining pressure boundary integrity is necessary to ensure operability of safety-related

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. 2870079540 Attachment I Page 6 of 15 i

inst ruments connected to the same instrument line. This instrument is installed nen-Q in accordance with the design criteria applicable to the original design.  !

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4. CST water level loop LT/LI-9453 is presently fed from 120 VAC from distribution. panel 00YO3. If a firc should occur in Fire I

Area 50, distribution panel 00YO3 will be lost and CST water .

level indication through this loop will not be available. No I other CST water level indication will be available for a fire in this fire area, because existing CST transmitter and local indicators are located in the fire area. To bring back CST water level indication, the power feed to LT/LI-9453 will be changed from distribution panel 00YO3 to the 24 VDC power supplies within panel 30C144. To accommodate the new power feed, the transmitter will be replaced. The mechanical work associated with the replacement of the transmitter will be '*

non-Q, because the transmitter is not Q. The power feed change to the loop will be routed non-safeguard and will be made in accordance with Bechtel Specifications E-1315 and E-1317 The new power feed cables will be routed in accordance with the fire protection separation requirements of l

j Appendix R. J

5. This modification also changes the power feeds to temperature indicator TI-3501 from distribution panel 30Y34 to 30Y33. The power feed is presently routed safeguard although the indicator is not Q-listed and does not perform any safety-related functions it monitors lfVAC temperature for 66 variables. Therefore, the new feed can be routed non-safeguard. The power feed change to the above instruments will not affect their design function and will be made in accordance with Bechtel Specifications E-1315 and E-1317. The power feed cables will be routed in accordance with the fire protection separation requirements of Appendix R.
6. Existing cable 3Y3230, from temperature transmitter TT-3442B to distribution panel 30Y32 is not scheduled, and its routing cannot be identified. To insure proper routing, this cable will be left as a spare and a new ble will be installed between the temperature transmitter and the distribution panel. The temperature transmitter is not Q-listed and does not perform any safety-related function. It only provides a suppression pool temperature signal to temperature indicators TI-3442B and TI-3445. The new cabic can be, therefore, routed non-sa feguard. The installation of the cable will be in accordance with Bechtel Specifications E-1315 and E-1317 and the Appendix R separation requirements.

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                                                                                               -Attachment I                     Page 7 of 15 7 .' ' This modification. alsb removes the manual transfer switches                                         !

installed on panels 30C19 and 30C144 by Modification ~ 1029E. The switches, because of the nature of this modification,' are s no longer required to meetLthe' instrumentation requirements of ' ( Appendix R, and,'therefore,.cdn be removed. U; v The ' design, procurement,- ' installation, and testing of- the ' ' ' c "> Q ' portions 'of this modification will' be in accordance twith the Peach. .

                                                                                                                                                                 .u                   -{
                                                       -Bottom APS.QA Plan, Vol.'I. The design, procurement, installation, and                                                         j testing for the remainder of work will be in accordance with section 2.3-                           $(f
                                                                                                                                                             %             c of the Peach Bottom APS QA Plan, Vol.              I. Whenever this modification                                   - '

interfaces with an existing system, the. design of this modification.is- ' 7  !

                                                      !in accordance with all the criteria applicable;to that system including,                                         4
                                                      ' but not -limited s to, , quality # assurance , . environmental and . seirjaic qualification.                    ,'                                            "
i The' bus loading of the additional instrument'~ 1 oops, th(transfer
  • 4 of instrument loops te the 11 ternate power source , and the. change of <

fpower feeds .to ~ instrument > loops have. been analyzed and found to' be 'I' acceptable. ' This modification ~. is being installed to meet 'tihe fire ' protection instrumentation requirements of 10CFR50 Appendix R. Fire.

                                                     ; protection components and cables'will be affected by this modification.

However, the changes to those components and cables are being. made in accordance .with the ' 10CFR50 ' Appendix R requirements and the capability ' to safely shutdown the plant in0th event of a fire is improved. 8(, The follow v, Updated FSAR Sections . are . applicable to this modification: 4.10, 5l. 2, 57,6.4, 6.5, 's

                                                                            .4?,   4.8,                                7.1.6,    7.4 , 17. 8,
                                                     '7.20,.10.7,.10.9, 10.14, Figures.4.8.2A)M, 5.2.6, 5.2.7 q                                                                         !

7.3.1, 7.4.1A, /  ! 7.4.6A&B, 10.7.1, and Appendix A. They have been reviewed and it has been determined that the plant design as described in.the UFSAR has been '

                                                     . changed by the installation of / this modification.            The plant design
                                                     " changes are discussed in the UFSAR change control form.

10CFR50.59 Changes, Tests and Experiments  ;

1. This modification does not involve an unreviewed safety ;c question because:

a) The probability of occurren'ce or the conser;uences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased. Where this modification interfaces with existing safety-related systems and equipment, the  ! original design criteria applicable to those sytems and equipment have been applied to this modification. The deletion of PR-5805 from the Q-list is acceptable since

                                                                           .it no longer performs a safety-related function; its safetypelated, function is now performed by fully                                                           1 qualified pressure recorders PR-9102A and B.             These                            ,

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                                                                           ,                                              ;2870079549 t1                  Page 8 of 15.

A 4 recorders are used to satisfy NRC Regulatory Guide 1.97 n requirements for dryeell pressure monitoring. Therefore,

                                                                        'the operability'of the systems and equipment will not.be.

compromised and the ? probability of an accident or f malfunction will1not-be increased.

                 , , ,                                 .b) ', The l possibility for an accident or malfunction of a -

3i '

                                                                 , gldifferent type, than: any evaluated previously in the                  .
                                                                        ' safety analysis' report is. not created.'. The addition and
        ~jf['              '                                             relccation' of. Instruments, the reroute and power feed changes, and the addition of alternate power. sources to-the instrument loops will not affect.the. operation of any 1

systems .because the . affect'ed instruments provide O g g indication only. In . additir/n, the reroute, power feed - p ' 'e change, and the addition of alternate power source to

  'M                                                                   . instruments, will,not affect the ~ separation of systems .

because. applicabib Buchtel cable and raceway separation

  • specifications are/Ebet.ng followed. Since the operation and-separationAyL any plant. systems will not be affected Qp "

by this modification, the . plant safety -related systems

                                                             ; will perform their safety ' function, therefore the 9p,                                                       ',.           possibility for an accident or malfunction of a different h                                                      ~i type than any evaluate 6 previcusly in the safety analysis report is not created, "'          +     ,
                                                      .c)            _ The margin -of safety as defined in the basis for any Technical Specification % s not reduced.         Changes made by s                ,

this modification - will not affect or change the

                                                                     applicable sections, ha.ses pnd tables, listed below, of 5

the Technical Specifice,ionsi ' Pressure recorder PR-5805

                             ,y    >

is ' listed in Table 3.2; F, Surveillance' Instrumentation.

                                                  /[

However, deletion of the recorder from the Q-list does

                                   \'

not affect the table because the pressure range of the recorder will remain the same. , Pressure ranges for

                              ,.                                     pressure recorders PR-9102A and 'tr are also listed in Table 3.2.F.

gj e( l, y R1 4 2. The following sections, tables and associated bases of the [h.,yj Technical Specifications , have been reviewed and require no '4N

                          ,                           changes is a result of this modification.

s 4- ,

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Sections Tables 3.2, 4.2 3.2.B, 4.2.B fg 3.7.A, 4.7.A 7 3.2.F, 4.2.F 3.6.A, 4.6.A 3.6.C, 4.6.C 3.6.E, 4.6.E e d

                                            '3/       An amendment to the operating license is not required.
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                               , ,.10CFR50.92 Significant ' Hazards Otterranation .

w , -) s L. . g A licen,th amendment)1l; jot required for the design, installation, 'I and;operatioM of this modf fidation, therefore, a significant hazards ditsmint. tion-is not-require O 4 4 4 7 l . .. I Prepared;bys 50' )xw :A Date: 8//ff07 , i //(Responsible Engineer) / t Reviewed u r, gi Date: U / l .'E / I 7

                                                                                   - ^*'lL'4'c(1 Div.' Inc epsnoe nt Reviewer)                        .                                            i g                                                                                   *.

I , th /k! 't~ C w Date: 8 ,YI1 1 SD Lead Division (Bratich or Section Head)

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                                                   .Non-Lead Divikion Responsible Engineer                                         'g         s 1

I b , Date: h"fb"S? 3- on-Lead Divi'31on Ir. endent Reviewer O Date: O - d'7 Non-Leau Division (Brarr5A or Section Head) W' ,, l

                             .O                                                                       t- h                                    tb                 Date:   5h Nuclear and Environmental Section Head 3                                                     Y                                                                                                                  j N.                                                                                                      l
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