ML20236P980
| ML20236P980 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 03/12/1998 |
| From: | AFFILIATION NOT ASSIGNED |
| To: | |
| Shared Package | |
| ML20236P727 | List: |
| References | |
| 97FP02-DOC-01, 97FP02-DOC-01-R00, 97FP2-DOC-1, 97FP2-DOC-1-R, NUDOCS 9807170236 | |
| Download: ML20236P980 (41) | |
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Northern States Power Company Prairie Island Nuclear Generating Plant t
Compliance Review of 10 CFR 50, Appendix R, Section III.O RCP Lube Oil Collection System s
97FP02-DOC-01 February 15,1998 Rev.0 3
Originaton Date:
U V
Technical Review:
Date:
Approval:
Date:
Prepared By: Tri-En Corporation 97FP02-DOC-01, Rev. O Page 1 of 36 P
ADOC 282 F
N:rthern St-tes Psw:r Ccmp:ny l
Prairie Island Nuclear Generating Plant 4
Compliance Review of 10 CFR 50, Appendix R, Section IILO I
Reactor Coolant Pump Lube Oil Collection System i
TABLE OF CONTENTS Page
- 1. Introduction 3
- 2. Summary of Conclusion 3
- 3. Licensing Commitment 3
- 4. References 4
- 5. Assumptions 6
- 6. Methodology 6
- 7. Results 7
- 8. Observations 19
- 9. Conclusion 19 Appendix A - Results of Licensing Document Review Appendix B - Prairie Island Reactor Coolant Pump Lube Oil Collection System Inspection Procedure J
Prepared By: Tri-En Corporation 97FP02-DOC-01, Rev. 0 Page 2 of 36 i
Nerth:rn Strtes Pcwcr Ccmprny g
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Prairie Island Nuclear Generating Plant l
Compliance Review of 10 CFR 50, Appendix R, Section IILO Reactor Coolant Pump Lube Oil Collection System l
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1.
Introduction The purpose of this compliance review is to evaluate the as-built Reactor Coolant Pump (RCP) Lube Oil Collection System (LOCS) at Prairie Island Nuclear Generating Plant (PINGP) with respect to the licensing and design basis commitments relative to the requirements of 10 CFR 50, Section III.0, " Reactor Coolant Pump Lube Oil Collection Systems" 2.
Summary of Conclusion Upon installation of a stainless steel enclosure around the oil lift pump system, the RCP lube oil collection system at PINGP Units 1 and 2 will capture potential unpressurized and pressurized oil leaks and is in compliance with Section IILO and the approved exemption (Ref. 4.1.j). To ensure the integrity of the RCPLOCS is maintained, it is recommended that the design criteria credited in the seismic calculation be incorporated into maintenance procedures related to removing and reinstalling the LOCS, and that the design of the RCPLOCs be included in a design basis documents.
3.
Licensing Commitment 3.1 Section III.O of 10 CFR 50, Appendix R, delineates the requirements for an RCPLOCS. Specifically, III.O states that:
l "The reactor coolant pump shall be equipped with an oil collection system if the containment is not inerted during normal operation. The oil collection system shall be so designed, engineered, and installed that failure will not lead to fire during normal or design basis accident conditions and that there is reasonable assurance that the system will withstand the Safe Shutdown Earthquake.
"Such collection systems shall be capable of collecting lube oil from all potential pressurized and unpressurized leakage sites in reactor coolant pump lube oil systems. Leakage shall be collected and drained to a vented closed container that can hold the entire lube oil system inventory. A flame arrester is required in the vent if the flashpoint characteristics of the oil present the hazard of fire flashback.
Leakage points to be protected shall include lift pump and piping, overflow lines, j
lube oil cooler, oil fill and drain lines and plugs, flanged connections on oil lines, and lube oil reservoirs where such features exist on the reactor coolant pumps.
The drain line shall be large enough to accommodate the largest potential oil leak."
Prepared By: Tri-En Corporation 97FP02-DOC-01, Rev. O Page 3 of 36 j
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j N:rth:rn St:tes Power C:mp ny Prairie Island Nuclear Generating Plant L
Compliance Review of 10 CFR 50, Appendix R, Section III.O Reactor Coolant Pump Lube Oil Collection System l
l 3.2 PINGP is required to have an RCPLOCS to meet the requirements of 10 CFR 50, l
Appendix R,Section III.O. An exemption was approved in that oil leakages from the RCPs are not drained to a closed vented container in Containment. Instead, the RCPLOCS drains into the containment sump via a floor drain, which can then be pumped to a vented tanks in the adjacent Auxiliary Building 3.3 A list of documents related to RCPLOCS licensing basis and the excerpts from regulatory documents related to RCPLOCS is included in Appendix A.
l 4.
References 4.1 Licensing Basis Documents a) Northern States Power (NSP) Company to Nuclear Regulatory Commission (NRC) letter, dated 12/8/76,
Subject:
Appendix A to Branch Technical Position (BTP) Auxiliary Power and Chemical Systems Branch (APCSB) 9.5-1 b) NSP to NRC letter, dated 7/5/77,
Subject:
Completion of Fire Protection Review c) NSP to NRC letter, dated 7/26/78,
Subject:
Status of Fire Protection Items d) NRC to NSP letter, dated 9/6/79,
Subject:
Fire Protection Safety Evaluation
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Report i
e) NSP to NRC letter, dated 3/19/81,
Subject:
10 CFR 50.48 Compliance Plan f) NSP to NRC letter, dated 1/23/84,
Subject:
10 CFR 50, Appendix R Exemption Requests g) NSP to NRC letter, dated 4/5/84,
Subject:
10 CFR 50, Appendix R, Section III.O Exemption Request h) NSP to NRC letter, dated 5/22/84,
Subject:
Response to Additional Information for Section III.O Exemption Request (Seismic Qualification) i) NRC to NSP letter, dated 7/12/84,
Subject:
NRC Environmental Assessment of Section III.G.2 Exemption Request in Containment and Section III.O Exemption Request j) NRC to NSP letter, dated 7/31/84,
Subject:
NRC Approval ofExemption Request to Section III.G.2 in Containment and Section III.O k) NRC Inspection Report 50-282/87004 and 50-306/87004,
Subject:
NRC's Review of RCPLOCS
- 1) Updated Safety Analysis Report, Sections 4.3.3.1.1,7.8.4,10.3.1 and Appendix C
m) Regulatory Guide 1.29, Rev. 3, September 1978," Seismic Design Classification" 4.2 Design Basis Documents l
i Prepared By: Tri-En Corporation 97FP02-DOC-0l, Rev. O Page 4 of 36 l
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4 l-NtrthIrn States Power Campzny 1
Prairie Island Nuclear Generating Plant Compliance Review of 10 CFR 50, Appendix R, Section HLO Reactor Coolant Pump Lube Oil Collection System a) Design Basis Document (DBD) TOP-06, " Appendix R/ Fire Protection" L
b) DBD-SYS-04, " Reactor Coolant System" c) Operating Manual Section F5, Appendix E, Rev. 3, Section 5.2.1.2 d) Purchase Req, Pierre Aircon Corporation, RCPLOCS Designer e) Pierre Aircon Drawing OP-1, Layout Drawing of the RCP Lube Oil Collection System f) Fluor Power Services to NSP letter dated 6/25/81,
Subject:
Seismic Qualification of Oil Drain Pans g) Fluor Power Services to NSP Internal Correspondence dated 4/13/82,
Subject:
Submittal of Final Calculations, Design Criteria, Safety Evaluation Report ad All Pertinent Documentation h) Manufacturer's Data for Mobil SHC 824 Oil i) Operating Procedures for RCP lube oil systems j) Maintenance Procedure D15.1, Rev.19," Reactor Coolant Pump Seal Replacement" k) Preventive Maintenance Procedure (PM) ICPM l-360, Rev. 5, "11 & 12 RCP Motor Oil Sump Level and Oil Lift Pump Instmment Calibration"
- 1) Highlighted Cable Tray and Conduit Layout Drawing of Safe Shutdown Equipment and Circuits in Containment m) General Arrangement Drawings of the Containment Sump, AST and ADT Collection Tank (NF-39202,39203,39210,39212) n) Flow Diagram for Unit 1 and 2 Auxiliary ad Reactor Building, NF-39236 and NF-39248 o) Westinghouse Instruction Book, Reactor Coolant Pump, Model W-11001-B 1 (93-AS) for Northern States Power Company, Prairie Island Nuclear Generating Plant, Units 1 and 2 (Vendor File X-HIAW-1-1560) p) Westinghouse Drawing 636F490,618J850 q) Drawing X-HIAW-1-1252-2, General Assembly Shaft Seal Pump (RCP) r) Operating Experience Report 19940726, " Review ofIN 94-58, RCP Lube Oil '
L Fire", Issue: 1994219.
s) Alarm Response Procedure C47012, Rev. 23, "12 RCP Oil Reservoir Hi/Lo Level" t) Alarm Response Procedure C47016, Rev. 27," Containment Sump A Hi Level" u) Tank Book, Rev.1, dated 10/31/94,
Subject:
Data for Aerated Sump Tank 121, ADT Collection Tank 121 & 122), and Waste Hold-up Tank 121 v) WCAP-13124, " Design Basis Document for the Reactor Coolant System", Rev.
O, dated 12/91 w)RCP Motor Cleaning Procedure D15.2, Rev.14, " Reactor Coolant Pump Motor Cleaning Procedure" x) Vendor Information (Diamond Power) for Mirror Insulation, Drwg ME-70213, y) Design Change Package #97FP02, RCP Lube Oil Collection System 5.
Assumptions J
Prepared By: Tri-En Corporation 97FP02-DOC-01, Rev. 0 Page 5 of 36 l
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Northern States Power Company Prairie Island Nuclear Generating Plant Compliance Review of 10 CFR 50, Appendix R, Section IILO Reactor Coolant Pump Lube Oil Collection System 5.1 The RCPLOCS is maintained in a manner consistent with sound operating and maintenance principles. The design inputs for the seismic qualification calculation for the RCPLOCS performed by Fluor Power Services was assumed to be maintained.
5.2 The piping and tubing associated with the lift oil system is regarded as the only credible source of a pressurized leak.
5.3 HVAC air flow is taken into consideration only if the air flow has the potential to influence a postulated leak.
5.4 Given that each lube oil reservoir is provided with a high and low level oil alarm, and -
given that these alarms are calibrated each refueling outage, it is assumed that the oil level in each reservoir will be maintained in the normal operating range in accordance with the operating procedures.
5.5 No record of changes to the RCP lube oil was found. Therefore, it is assumed that the original oil Mobil SHC 824 is still used.
5.6 It is assumed all drain lines are clear and free of any obstructions which may prevent the flow of oil to the containment sump "A" collection receptacle.
6.
Methodology 6.1 Determine the licensing and design basis for the RCPLOCS.
6.2 Review the drawings and calculations for the oil collection system to verify that all potential leakage points in the RCP lube oil system have been contained and the drain line(s) have been sized to accommodate the maximum leak rate.
6.3 Verify that the oil collection systems have been designed so that there is reasonable assurance that it would withstand the safe shutdown earthquake or that the RCP lube oil system and associated appurtenances are seismically designed to withstand the safe shutdown earthquake, or if an exemption has been approved for a non-seismically designed oil collection system.
6.4 Verify that either the oil has a sufficiently high flashpoint to prevent ignition of the oil by any equipment in the area or the tank vent has a flame arrester installed.
6.5 Verify adequacy of surveillance and/or maintenance procedures associated with the lube oil collection system and implementation of the procedures.
Prepared By: Tri-En Corporation 97FP02-DOC-01, Rev. O Page 6 of 36
b N:rth rn Strtes Pcwer CompIny l,
Prairie Island Nuclear Generating Plant Compliance Review of 10 CFR 50, Appendix R, Section IILO Reactor Coolant Pump Lube Oil Collection System 6.6 Verify that the collection tank is a closed, vented tank and has a capacity to simultaneously collect all the oil from the RCPs (upper and lower lube oil reservoirs),
or sufficient capacity to collect oil form one RCP and such design as to direct overflow to a location which does not present a fire hazard as described in approved exemptions from Section III.O requirements.
6.7 Determine if the RCP lube oil collection system was installed as indicated by drawings and design basis documents, including verifying the adequacy of the seismic design and pipe supports.
6.8 Identify pecific conditions and/or configurations which appear to not meet the specific requirements of Section III.O requirements and the NRC-approved exemption. New conditions which appear to be in non-conformance with the specific requirements of Section IILO shall be processed in accordance with NSP procedures.
7.
Results 7.1 The licensing and design documents were reviewed to determine the commitments made with respect to the RCPLOCS. Appendix A contains in chronological order, a listing of the correspondence between NSP and the NRC concerning the specific configuration of the RCPLOCS installed at the Prairie Island facility. NSP has installed a collection system which was designed to collect oil from potential unpressurized leakage sites. Oil collected in the drip pans will flow towards the floor drain which will eventually be drain to Containment Sump A, and which can subsequently be pumped into vented tanks in the adjacent Auxiliary Building.
Section III.O requires that a collection system shall be capable of collecting tube oil from all potential pressurized and unpressurized leakage sites and drain to a vented closed container that can hold the entire lube oil system inventory. NRC has approved an exemption from this specific portion of the requirement in that the RCPLOCS drains into a Containment floor drain which drains to Containment Sump A which can then be pumped into vented tanks in the adjacent Auxiliary Building.
Each tank will be able to accommodate the entire RCP lube oil inventory of 530 gallons. Section IILO also requires that the oil collection system shall be designed such that failure will not lead to a fire during normal or design basis accident conditions and that the LOCS is able to withstand a safe shutdown earthquake.
Sump A and associated piping is Seismic Category III with the exception of the portion between the first set of valves from the sump to the containment isolation valves which is Seismic Category I. The seismic qualification of the drain lines was previously reviewed and approved by the NRC.
Prepared By: Tri-En Corporation 97FP02-DOC-01, Rev. 0 Page 7 of 36
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N:rth:rn States P:wer Ccmp:ny Prairie Island Nuclear Generating Plant Compliance Review of 10 CFR 50, Appendix R Section HLO Reactor Coolant Pump Lube Oil Collection System 7.2 The RCPLOCS was designed and installed by Pierre Aircon Corp. Drawings were reviewed to determine the potentialleak sites. The potential pressurized and unpressurized leak sites were identified. In order to assess the adequacy of a lube oil collection system in general, certain definitions and criteria must be established beforehand. These may include, but are not limited to, the definition of potential leak sites and, more so, to the definition of pressurized leak sources. In general, potential leak sites are considered pressurized leak sites if the leaking fluid is under any mechanical induced pressure. However, before the leak can be considered a potential pressurized leak site, the entire piping and pressure boundary configuration must be evaluated. No clear regulatory guidance has been prescribed relative to pressurized vs. non-pressurized leak sites, since Appendix R,Section III.O was initially promulgated in 1980, and it is subject to a licensee's interpretation if the potential leak site would be under a pressurized or unpressurized condition.
The RCPs installed at Prairie Island were manufactured by the Westinghouse Corporation and represented a standard design used at many Westinghouse Pressurized Water Reactors (PWR) sites. Based upon the requirements at the time, these pumps and their appurtenances were designed to remain operable following a seismic event. All pumps were designed to ASME Code Class standards. Due to economic and performance factors the Westinghouse reactor coolant pumps were designed to run for extended periods without any maintenance. Thus, the RCPs were engineered, designed and assembled to exacting standards. Given this and the performance record of the Westinghouse PWR RCPs since the early 1970's, credible pressurized and non-pressurized leak sources can be readily identified. Specific discussion of the potential leak sites, and possible influences on a potential leak, are provided below:
Oil Lift Pump and Oil Lift Pumo PioinarTubin_g-The oillift pump system operates at approximately 1400 psi, and has a delivery of 6.2 gpm at 1800 RPM. Per discussion with the previous system engineer, the system has had a history of developing leaks either in the pump casing or the distribution piping. However due to prudent actions relative to the maintenance aspects of these pumps, the leakage has been effectively reduced to zero. The oil lift pump is a positive displacement pump and can be characterized as a low flow /high pressure pump which is typically utilized during the RCP startup evolution to lift the rotor and develop an oil layer between the shoe and bearing surface. The primary purpose of the lift pump system is to prevent wearing of the shoe and bearing surface during startup. In most cases, and consistent with the direction provided by the Westinghouse Corporation, the lift pump system is operated I minute prior to startup and 2 minute following startup. Given the pump characteristics in terms of pressure vs. flow, the pump would be unable to develop the pressure necessary to clear the Prepared By: Tri-En Corporation 97FP02-DOC-01, Rev. O Page 8 of 36
N:rth:rn St:tes P:w:r Ccmp:ny i
Prairie Island Nuclear Generating Plant Compliance Review of 10 CFR 50, Appendix R Section IILO Reactor Coolant Pump Lube Oil Collection System l
l stan interlock given a catastrophic failure of the lift oil pump or its distribution piping. Without the ability to clear the pressure interlock, the RCP could not be started and as such the problem would be promptly identified.
The primary concern with the oil lift pump and piping is that of a through-wall crack in the piping or a loose or damaged fitting. These types of failures present the greatest possibility for leak to go undetected as adequate pressure can be developed in the system while at the same time experiencing a loss of oil inventory, albeit small in terms of total quantity, through a damaged pipe or loose component. As mentioned previously, these pumps are characterized as low flow pumps at high pressure, and the characteristics are such that the flow is permitted to increase as the -
pressure decreases. Maximum pressure is developed when the vc,lume is at a minimum. Therefore, given that the maximum flow for the pump is on the order of j
6.2 gpm, the maximum anticipated loss over the 3-minute time duration would be 12 gallons. However this loss would be detected immediately as the interlock would fail
' to clear, and thus the pump would be prevented from starting.
It is concluded that given the pump characteristics and the nature of the failures typically encountered with these systems, the oil lift pump and piping should be treated as a potential pressurized leak source.
Due to the anticipated pressures associated with the oillift pump and the potential for the RCP lube oil to be projected out away from the RCP and/or transported by airflows due to the fine mist characteristic of pressurized tube oil, shielding of all lift pump components, with the exception of the drive motor itself, should be provided.
Lube Oil Cooler Flange Connections The lube oil cooler flange connections typically consist of a four bolt,400 to 600#,
j gasketed connection. The pressure in the system while the lube oil cooler or RCP is inservice is less than 20 psi. The lube cil cooler is an integral pan of the RCP and as such has been design and installed to remain available following a seismic event. The flange mating surfaces have been machined to ensure a high integrity is developed at assembly. To further enhance the long term integrity of the flange ;onnection, a gasket is provided. The bolts used to establish flange integrity are orovided with capable material lock washers which act to prevent the fasteners from becoming loose during operation and ultimately lead to a compromise in flange integrity. Given the nature of the flange connection and, if a the interface of the connection were to weaken, it is anticipated the 20 psi head would be dissipated through frictional loss across the flange face surface, and therefore would be reduced to zero upon exiting the flange connection. As a result, it is concluded the leak resulting from a flange leak would be a drip type leak rather than a spray or projected leak. Therefore, the flange leak shall be characterized as un-pressurized leak. The flanged connection should not require protection via shields as the leaks will not be projected away from Prepared By: Tri-En Corporation 97FP02-DOC-0l, Rev. O Page 9 of 36
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Prairie Island Nuclear Generating Plant Compliance Review of 10 CFR 50, Appendix R, Section 11LO Reactor Coolant Pump Lube Oil Collection System l
l the RCP but rather will crip vertically to drips pans below if so provided.
l Oil Por and Sight Glass Slide 1 of Appendix C illustrates the typical configuration of the oil pot and sight glass assembly. Flange-type connections are utilized to affix the oil pot canister to the RCP. Stainless steel tubing with swagelock type connections are utilized at the top of the oil sight glass assembly. These components are maintained in an unpressurized condition as the only pressure exerted is that of static pressures exerted due to the gravitational forces on the upper and lower reservoirs. Failures of any of 4
these components would result in a drip type leak that would be collected by the collection plans below if so provided. As with the lube oil cooler assembly, the oil pot, sight glass and all appunenances are designed to withstand a seismic event, and therefore, it is inconceivable to postulate a spontaneous failure olthe components associated with the oil pot or sight or sight glass assembly.
Given the typical configuration and the low pressures of the oil pot and sight glass assemblies, spray shields are not required as the postulated failures will produce a drip type leak which drip vertically to a collection system below, if so provided.
WeIded Connections Welded connections are commonly utilized in the Westinghouse-designed RCPs.
Welded connection are typically used to affix pipe segments with a flanged half at the opposite end to the RCP motor shell and for oil 511 and drain lines. These welds are not nibjected to large loads or pressures under normal operating condition and as with the flanged connections are qualified to withstand the forces associated with a seismic event. With the exception of the oillift pump, the typical component
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associated with the RCP lubricating oil system, does not experience pressure greater than 20 psi. Thermally induced failures are not credible, as the RCP motor is required to be maintained in an environment which is electrically conducive. Given these factors, it is considered highly incredible to postulate a spontaneous failure of any welded connection under normal or abnormal operating conditions.
1 Swanelock-tvoe Connections Swagelock type connection are utilized at various locations on the RCP motor. Oil lift pump connections, lube oil cooler instrumentation lines, and oil level sight glasses are typical uses of these types of connection. These types of connections are typically qualified to withstand pressures between 3000 and 6000 psi. For the applications typically observed with RCPs, the maximum pressure would be that of the Oil Lift Pump, approximately 1600 psi. For the oil reservoir connections, less than 20 psi is the normal observed pressure. The connections are maintained by frictional forces PreparedBy: Tri-En Corporation 97FP02-DOC-01, Rev. 0 Page 10 of 36 I
iy Narth:rn St:tes P:wer Ccmprny Prairie Island Nuclear Generating Plant Compliance Review of 10 CFR 50, Appendix R, Section IILO Reactor Coolant Pump Lube Oil Collection System and do not fail catastrophically, but will typically loosen and begin to develop slow drip type leaks. As a result drip shields can be utilized to collect leaking swagelock type leaks. Spray shields should not be required unless the pressure rating for the connection is exceeded.
Threaded Connections Threaded connections arc typically used for drain plugs and oil fill caps. These connection are not subjected to any forces which would cause a failure to occur during operation or maintenance activities. With the exception of the lift oil system, pressures as seen threaded connection are less than 20 psi and in most cases are maintained at static head consistent with gravity. As with the flanged and welded connections, the RCP and the lube oil system associated with the RCP are seismically qualified to withstand a seismic event. Threaded connections are in series with normally closed drain valves. I It is highly improbable that the isolation valve will fail, concurrent with a threaded connection, such that oil will flow freely from the drain pipe. Therefore, the worst case postulated leak from the threaded connection for drain plugs would be oil drips. Threaded connections associated with oil fill caps would not be expected to experience any leaks because the oil fill connection is above the oillevel of the reservoir.
HVAC and Miscellaneous Airflows When assessing the adequacy of a lube oil collection system it is important to factor in airflows and how airflows may influence the collection system's ability to collect all potential leaks. The worst case scenario involves a fine mist of atomized oil being drawn into an airstream and subsequently deposited on hot RCS piping. Small orifice leaks associated with the oil lift system are the most probable cases for a fine mist oil leak. Partial failure of RCP seals in which the postulated leaking oil is atomized by the motor circulating air currents and transported to the HVAC air flow currents.
Airflows directed at cr into the motor typically force oil droplets or mist to condense on the motor casing. If the motor is provided with a collection system, the oil will typically migrate to the collection system wher:it is then directed to a collection tank or holding facility.
i Air flows which impinge upon the motor casing tangentially typically result in oil droplets or mist being transported away from the collection system. In these cases, it is recommended that connections which lie within the tangential airflow path be provided with airflow shields which act to prevent the oil from being transported away from the collection system.
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i Mat-Tvoe vs Reflective-Mirror Tvoc Insulation Prepared By: Tri-En Corporation 97FP02-DOC-01, Rev. O Page11of36
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L Narth:rn St:tes P;wer Ccmprny Prairie Island Nuclear Generating Plant Compliance Review of 10 CFR 50, Appendix R, Section IILO Reactor Coolant Pump Lube Oil Collection System Several RCP lube oil fires have occurred over the past 20 years. Most notably of these was the October 1996 at the Arkansas Nuclear One facility. The cause of this event was determined to be oil soaked mat type insulation. Due to the " wicking" phenomenon commonly associated with the use of mat type insulation, the autoignition temperature of the RCP oil was reduced. This phenomenon is common in the petrochemical industry. A high firepoint liquid such as that commonly used in RCPs, can be easily ignited ifit is absorbed on to a wick, i.e. a pourous medium of low thermal conductivity such as mat type insulation. ' Application ofintense heat or flame to an oil soaked wick causes rapid local increase in temperature, not only because the layer ofliquid is too thin for connective dissipation of heat to occur, but also because the wick is an effective thermal insulator.
PINGP Units 1 and 2 utilize a mirror / reflective type insulation which can also be characterized as a non-absorbent type ofinsulation. This insulating medium does not use any fiber-type insulation which may act to absorb even minute quantities of oil.
Barring any mat type ir.sulation gives credence to the notion that a spontaneous fire cannot be initiated as the wicking phenomenon is not possible. Spontaneous ignition of the lubrication oil cannot occur if the autoignition temperature of the lubrication oil is not exceeded by the RCS piping. It is assumed that, by the general nature of the insulating medium, the oil is not permitted to accumulate in the insulation as it migrates to the lower portions of the insulating systems. This is beneficial as the bottom side of the insulating system is cooler than that of the upper portion due to the rising convective heat of the RCS system. Additionally, with the oil migrating down to the lower elevation ensures the oil will not be permitted to accumulate in the insulation as it will be discharged at the insulation section interfaces. As a result, barring the use of mat type insulations significantly reduces the fire risk associated reactor coolant pumps lubricating systems.
7.3 An instmetion procedure was prepared to assist during the walkdown (Appendix B).A walkdown for Unit 1 RCPLOCS was performed on November 8,1997, and a i
walddown of Unit 2 RCPLOCS was peformed on January 27,1998. A detailed discussion of the walkdown results is provided below. The walkdown for both Units I and 2 determined that the LOCS for both units were installed as designed by Pierre Aircon to protect against unpressurized oilleaks, but would not adequately collect a postulated pressurized leak from the oillift pump and piping. This deficiency was subsequently evaluated by PINGP and corrected by a design modification to install a steel enclosure around the oillift pump and piping which would adequately shield a pressurized oil leak onto the drip pan below (Ref. Design Change #97FP02). This L
design modification was installed subsequent to the walkdown. The details of the walkdown reflect conditions prior to installation of the design modification.
Collection pans are provided around the perimeter at the based of each pump. They Prepared By:' Tri-En Corporation 97FP02-DOC-01, Rev. 0 Page 12 of 36
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N:rth:rn St:tes Pcwar Ccmp=y Prairie Island Nuclear Generating Plant Compliance Review of 10 CFR 50, Appendix R, Section IH.O Reactor Coolant Pump Lube Oil Collection System are located in a manner which ensures all drips will be collected provided the drips of oil are allowed to fall without influence from external forces such as HVAC flows.
By inspection, postulated unpressurized leak sites will be adequately collected the drip pans below. Because the postulated leaks are expected to be drips or slow leaks, the pans and drain lines would be able to accommodate a postulated leak.
November & I997 - llnit i RCPLOCS Walkdown Results RCP 11 The orientation of RCP !I relative to other equipment and piping in the area differs from that of RCP 12. For RCP 11, the lube oil cooler, oil pot and level sight glass is I
located directly in front of and within 12 inches of the HVAC cooling duct. By inspection, it is concluded that any leaking fluid originating from this location would be forced back and impinged upon the RCP motor casing. Once in contact with the motor casing, the fluid would migrate by gravity to the collection pans, located approximately 10 feet below.
Given the orientation of the tube oil cooler, oil pot and level sight glass assembly relative to the HVAC cooling duct, it is concluded that additional shielding is not required at this location as all potential leaks would be collected by the collection assembly.
f The oil lift pump is located approximately 160 degrees clockwise from the HVAC l-
' cooling ~ duct. Only a small corner of the lift oil pump skid is subjected to cooling air flows from the HVAC duct. The lift pump skid is positioned in the back corner of L
the RCP cubicle. Concrete walls bound two sides of the triangular area in which the l
pump skid is positioned with the third being that of the RCP Motor itself. By inspection it can be concluded that any potential pressurized leaks would be directed to any one of the three bounding surfaces. If the leak were to be directed at the wall, the oil would migrate to the area below pump and motor assembly. Inspection of these areas concluded the oil would not accumulate in any appreciable amounts and would eventually migrate to the floor drain system and eventually to the containment sump A tank. This is the normally credited tank to receive lube oil from i
the RCP Lube oil collection system. There are no hot surfaces in which the oil could come in contact with while migrating to the collection receptacle. Therefore, there are no apparent fire concerns created as a result of the scenano.
If the oil were directed upwards and over the top of the RCP, the oil is expected to be forced back and impinged onto the concrete wall and again migrate to the area below the pump and motor assembly.
Although it is regarded as highly improbable that a fire scenario could be created as a result of an oil lift pump or piping failure, it can be concluded that the oil resulting Prepared By: Tri-En Corporation 97FP02-DOC-01, Rev. O Page 13 of 36
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N:rthern St:tes P;wer Ccmp ty Prairie Island Nuclear Generating Plant j
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Compliance Review of10 CFR 50, Appendix R, Section HLO Reactor Coolant Pump Lube Oil Collection System from such a leak would not be collected by the collection system and would j
ultimately migrate to the area below the pump and motor assembly.
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This condition is not consistent with the requirements of Section III.O of Appendix R. It is therefore recommended that a shield be provided for the oil lift pump and all associated piping. The shield should be designed and installed such that all potential oil leaks are deflected back to the oil lift pump collection tray and ultimately to the i
lube oil collection system. (Note: A metal shroud was subsequently installed to cover the oil lift pump and piping to adequately shield a postulated pressurized leak and divert the leak to the collection pan below.)
L RCP 12 l
The orientation of RCP 12 differs from that of RCP 11 in that the oil lift pump is l
located approximately 30 degrees off center from the front of the oil lift pump l
assembly. The back side of the oillift pump assembly opens to the steam generator area, it can therefore be theorized that any potential leak from the lift pump or lift pump piping will be transported via air currents to the hot surfaces associated with the steam generator assembly. This conclusion is evident by inspection.
The lube oil cooler, oil pot and level sight glass assembly is located on the back side of the RCP motor and away from any potential air currents. There are no other air currents which would prevent a potential oil leak from migrating to the collection pans below.
It is therefore concluded that both oil lift pumps should be provided with shields to deflect any potential pressurized leaks down to the local collection pan and ultimately to the collection system. The shield should be sufficient to eliminate potential air flow influences from the nearby HVAC supply duct. No other shielding is required. (Note: A metal shroud was subsequently installed to cover the oil lift l
pump and piping to adequately shield a postulated pressurized leak and divert the i_
leak to the collection pan below.)
Reflective Mirror Insulation l
In both Units 1 and 2, Reflective Mirror type insulation is used as the insulating medium for high temperature RCS pipes. Mat type insulation is not used for RCS piping. All insulating sections are well fit with gaps between sections minimized and for the most part eliminated with the use collars adjoining the sections. Valve e
bonnets are provided with specially form insulating top which are designed to preclude oil from accumulating on or within the valve bonnet area.
Reservoir Vent Lines PreparedBy: Tri-En Corporation 97FP02-DOC-01, Rev. 0 Page 14 of 36
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Ncrthern St tes Pow:r Ccmp ny I1 Prairie Island Nuclear Generating Plant Compliance Review of 10 CFR 50, Appendix R, Section ID.O Reactor Coolant Pump Lube Oil Collection System Upper reservoir vents are provided with reverse bends and the oil level is maintained approximately 8 inches below the bottom edge of the vent line. Upper and lower level alarms are provided for each RCP motor. These alarms are designed to annunciate in the control room and are calibrated and verified functional by procedure ICPM l-360. The alarms are calibrated to annuciate when the level of the reservoir is overfilled 1.25" above normal. As a result, procedural controls are sufficient to eliminate the vent lines as potentialleak sites. Furthermore given that they are regarded as vent lines, as pressurized leak is not a credible scenario.
Therefore, they are not required to have spray shields installed. Drip pans are provided however in the highly unlikely event that condensed oil may migrate out of 1
]
the vents.
Oil Pot and Level Sight Glasses By inspection the oil collection pans extend away from the oil pot and level sight glasses such that all potential leaks will be collected. Neither the flange, swagelock, or threaded connections are provided with local spray or drip shields. However given the anticipated nature of the leaks at these locations, local spray and drip shields are not required.
Lube Oil Cooler The lube oil cooler extends out away from the RCP such that the centerpoint of the cooler is approximately 18 inches from the perimeter of the RCP. Given that the oil collection pans extend out approximately the same distance, the potential exist for oilleak occurring on the outside edge of the cooler to fall vertically and miss the oil collection pans. Therefore a local oil collection tray has been provided for the tube oil cooler. The design is similar to that of a funnel whereas leak oil is funneled to the piping system and subsequently drained to the containment sump A receptacle.
Connection to the tube oil cooler are of a flange type configuration and therefore leaks from the locations are postulated to the drip type rather than the projected spray type. Thus, spray shields are not required for this location.
Oil Fill and Drain Lines The oil fill ar.d drain line are not regarded as pressurized leak sources and therefore
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are not provided with local spray shields. They are located directly above the collection pans and therefore any leaks will be collected and routed to the sump A collection facility. The RCPs at Prairie Island are not provided with remote oil fill lines and therefore there is not possible ofleaking oil onto the containment floor or hot surfaces during a oil addition evolution.
i Oil Lift Pumo Skid Prepared By: Tri-En Corporation 97FP02-DOC-01, Rev. 0 Page 15 of 36
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/j Ntrth:rn St tes Pawer Ccmpany Prairie Island Nuclear Generating Plant Compliance Review of 10 CFR 50, Appendix R, Section III.O Reactor Coolant Pump Lube Oil Collection System As noted previously, oillin pumps are required du ing RCP stanup to protect the bearing shoes and bearings from unnecessary wear. The are typically operated 1 minute prior to starting of the RCP motor and I minute following a motor start.
I Due to the nature of the function they perform significant pressure (1200 to 1600 psi) are required to perform the " lifting" function. Given the pressure requirements, the oil lift pump and piping are regarded as significant pressurized leak sites and thus are required to be provide with spray shields. Inspection of the Prairie Island configuration revealed that although there was a drip pan provided approximately 12 L
inches below the oillin pump skid, the lift pump and piping was not provided with p
any shield to preclude the spraying of oil out and away from the confines of the RCP collection system. It was noted in the case ofRCP 11 that the lift pump was located in the front of and within 18 inches of the high flow RCP HVAC cooling duct. The flow frem this duct would act to transport any leaked to the containment l
environment. As a result, the lift pump and all equipment, instrumentation, and i
piping with the exception of the lift pump motor be provided with a spray shield housing to direct the oil on to the pan directly below and subsequently to the oil collection system.
January 27.1998 Unit 2 RCPLOCS Walkdown Results The RCPLOCs for RCPs 21 and 22 were installed as designed by Pierre Aircon.
The configuration in the Unit 2 containment was essentially similar to Unit 1. In anticipation of a design change which would be installed over the oil lift pump l
system, the walkdown concentrated on other potential leak sites and the ability of l
the exisitng drip pans to collect postulated unpressurized leaksites.
1 1
RCP 21 At the upper reservoir, the HVAC supply duct is directed towards the oil lift pump i
and piping. However, the design modification to enclose the oillift pump should adequately ensure that a postulated leak from the oillift pump and piping would be shielded and drain to the drip pan below. In addition, oilleaks from the level sight l
glass and dra'm plugs for the upper oil reservoir would not be influenced by the HVAC supply duct because it is 170 from the supply duct. Postulated l
unpressurized oil leaks from the level sight glass and drain valves / plugs would be L
adequately collected by the drip pans located below.
Postulated oil leaks from the lube oil cooler piping and drain valves are would be either collected by the drip pan or drip bucket installed under the lube oil cooler pipng. Postulated oilleaks from the flange connections would either drip to the l
collection pan below or run down the vertical piping and collect onto the drip pan
. Prepared By: Tri-En Corporation 97FP02-DOC-01, Rev. 0 Page 16 of 36 l
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Ncrth:rn St:tes P:w:r Ccmp:ny I
Prairie Island Nuclear Generating Plant Compliance Review of10 CFR 50, Appendix R, Section IB.O Reactor Coolant Pump Lube Oil Collection System l
l l
below the piping. The condition of the collection pans was adequate and no damage was noted.
1 RCP 22 Similar to RCP 21, the HVAC supply duct was located at the upper reservoir level and was directed towards the oil liR pump and piping. The planned design modification which will install a metal shroud around the oil lin pump and piping will adequately shield a postulated oil leak from the oil lin pump and piping and direct the oil to the drip pan below. The metal shroud around the lift pump will also deflect any HVAC influence on a postulated leak. The drain valves and level sight.
glass is also approximately 160* from the supply duct and would not be influenced by air flows. A postulated leak from the level sight glass and drain valves / plugs will be collected by the drip pans below.
Similar to RCP 21, postulated oil leaks from the lube oil cooler piping and drain valves are would be either collected by the drip pan or drip bucket installed under the lube oil cooler piping. Postulated oilleaks from the flange connections would either drip to the collection pan below or run down the vertical piping and collect onto the drip pan below the piping. The condition of the collection pans for RCP 22 was also adequate and no damage was noted.
7.4 A seismic analysis was performed on the RCPLOCS by Fluor Power Services. The seismic qualification of the LOCS appears to have been adequately performed.
Certain input parameters (e.g., minimum clamp torque) were utilized to conclude the seismic qualification of the LOCS. However, upon review of the maintenance procedure D15.1 (Reactor Coolant Pump Seal Replacement) which would require LOCS removal and reinstallation, did not include a criteria for re-installing the lube oil collection pans (i.e., the seismic analysis assumes a minimum clamping force in the C-clamp of 350 lb.). To ensure that the conclusions of the seismic analysis are not affected, it is recommended Procedure MP D15.1 be revised to include an acceptance criteria for reinstalling the collection pans.
7.5 Mobile SHC 824 oil is used for the RCP lube oil system and has a sufficiently high flashpoim temperature (480 F) and fire point temperature (520 F). The flashpoint temperature is sufficiently high such that flame arresters would not be necessary for the tank vents. Although not provided in the vendor data information, the autoignition temperature is typically much higher in the 700 degree range for substance of this nature. In addition, the flash and flame point both require an initiator such as a open flame or spark before either become a concern. There are no ignition sources near the RCPLOCS or the postulated leak sites.
Prepared By: Tri-En Corporation 97FP02-DOC-0l, Rev. O Page 17 of 36 s
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N:rth:rn Strtes P:wer Camp =y i
Prairie Island Nuclear Generating Plant Compliance Review of10 CFR 50, Appendix R,Section III.O Reactor Coolant Pump Lube Oil Collection System 7.6 A review was performed on the operating and surveillance procedure for the level indicators for upper and lower oil resenairs, and Sump A relative to sump pump operation, as well as a review of the associated alarm response procedures. These I
procedures were determined to be adequate.
7.7 The drain lines for the RCP lube oil collection systems were identified and determined to drain to a sloped-grade at the ground level of the Containment building which leads directly to a floor drain, and subsequently drains into Sump A.
This configuration was adequately described in the exemption request and the SER.
Because postulated unpressurized leaks are expected to either be slow leaks or drips, c
the drain lines for the collection pans are determined to be adequate.
The worst case leak from the oil lift pump piping would be when a leak occurred during operation of the oillift pump. Because operation is of the pump is approximately 2 minutes, the amount oil postulated to leak would be at most 12 gallons. However, because, the leak would be expected from a through wall crack in the piping or a loose / damaged fitting, the amount of oil postulated to leak would be shielded by the metal shroud and adequately collect onto the drip pan below and drain via gravity to the floor drain below.
7.8 Tank inventory data was reviewed for Sump A, the AST 121, ADT collection tank (121 and 122), and waste holdup tank 121. The inventory for each tank is greater than the total lube oil inventory of 530 gallons (265 gal /RCP). The RCPLOCS design which drains to the containment sump and vented tanks outside Containment has been accepted by the NRC in an approved exemption. The piping associated with Sump A and drain lines to the AST and ADT collection tank is Seismic Cat III (with the exception of the piping between the outside containment vessel and the containment isolation valves which is Seismic Cat I). The seismic qualification was described in an NRC submittal and appears to have been accepted by the NRC in the approved exemption.
8.
Obsenations 8.1 At the time of the walkdown, only drip pans for RCP 1I were installed under the lube oil cooler and oil lift. The drip pans located at the lower reservoir area were still disassembled. For RCP 12, all the drip pans were disassembled. However, the drip pans were installed for both RCPs 21 and 22. Based on the Unit 2 walkdown, the width of the drip pans are adequate to collect unpressurized leaks.
8.2 The HVAC system was not operating during the walkdowns. Therefore, potential 4
oil leakages which may be influenced by air flow were based on engineering judgment.
Prepared By: Tri-En Corporation 97FP02-DOC-01, Rev. O Page 18 of 36 1
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N rth:rn St:tes Power Ccmpany Prairic Island Nuclear Generating Plant Compliance Review of 10 CFR 50, Appendix R, Section IILO Reactor Coolant Pump Lube Oil Collection System 9.
Conclusion Based on the installation of a metal shroud around the oil lift pump and piping, the RCP lube oil collection system at Prairie Island for Units land 2 would adequately collect oil from postulated pressurized and unpressudzed leak sites, as required by Section III.O.
Postulated unpressurized oil leaks collected by the LOCS are expected to be slow leaks or drips and would adequately drain to the containment floor to Sump A, and subsequently into the AST in the adjacent Auxiliary Building, as described in the approved exemption.-
In addition, a postulated pressurized oilleak from the oil lift pump and piping would be '
adequately shielded by the metal shroud and would also adequately drain to the Containment floor, and subsequently to Containment Sump A and adjacent tanks in the Auxilianj Building.
L l
Prepared By: Tri-En Corporation 97FP02-DOC-01, Rev. 0 Page 19 of 36
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Prairie Island Nuclear Generating Plant l
Compliance Review of 10 CFR 50, Appendix R, Section III.O Reactor Coolant Pump Lube Oil Collection System l
Appendix A Results of Licensing Document Review I
Rerulatorv Requirements and Guidance Documents Appendix A to Branch Techmcal Position (BTP), Auxdiary Power and Chemical Systems Branch (APCSB), 9.31, Section D.2.(a) (3):
" Safety related systems should be isolated from combustib!c materials. When this is not possible because of the nature of the safety system or the combustible material, special protection should be provided to prevent a fire from defeating the safety system function. Such protection may involve a combination of automatic fire suppression, and construction capable of withstanding i
and containing a fire that consumes all combustibles present. Examples of such combustible materials that may not be separable from the remainder ofits system are:...(3) Reactor coolant pump lube oil system."
10 CFR 50, Appendix R, Section 111.0 "The reactor coolant pump shall be equipped with an oil collecen system if the containment is not inened during normal operation. The oil collection systen shall be so designed, engmeered, and installed that failure will not lead to fire during normal or design basis accident conditions and that there is reasonable assurance that the system will wittar.J the Safe Shutdown Eanhquake.
"Such collection systems shall be capabic of collecting tube oil from all potential pressurized and unpressurized leakage sites in reactor coolant pump lube oil systems. Leakage shall be collected and drained to a vented closed container that can hold the entire lube oil system inventory. A flame arrester is required in the vent if the flashpoint characteristics of the oil present the hazard of fire flashback. Leakage points to be protected shall include lift pump and piping, overflow lines, lube oil cooler, oil fill and drain lines and plugs, flanged connections on oil lines, and lube oil reservoirs where such features exist on the reactor coolant pumps. The drain line shall be large enough to accommodate the largest potential oil leak."
NRCInternalMemorandafrom J.A. Olshinski to D.G. Eisenhut dated 3/13/83 andR.H. Vollmer to D.G.
s Eisenhut dated.1/1/83,
Subject:
Oil Collection Systemfor Reactor Coolant Pumps, Florida Power and Light Company, St. Lucie Unit 2-Docket No. 50-389 The oil collection system provided for the RCPs in St. Lucie Unit 2 is connected to a drainage system which discharges into a tank sized to accommodate the quantity of oil from a single coolant pump. This was approved by the NRC in an SER dated October 1981. Because Section III.O requires that the oil collection system accommodate the oil from all primary coolant pumps, the failure to provide a system with sufficient capacity was an NRC inspection finding (Region III Report Nos. 50-315/82 08 and 50-316/82-08) for Davis-Besse. These inconsistencies prompted an NRC re-review of the lube oil collection system. The results of the resiew are re-iterated in Information Notice 84-09 (see below).
Rulemaking issue Injbrmation dated 7/5183,
Subject:
Fire Protection Rulejbr Future Plants (SECY)32-267 This report is a summary oflicensee fire protection exemption requested and the safety Prepared By: Tri-En Corporation 97FP02-DOC-01, Rev. 0 Page 25 of 36
l l
N:rthern St-tes P:wer Ccmpmy
!j Prairie Island Nuclear Generating Plant Compliance Review of 10 CFR 50, Appendix R Section IILO Reactor Coolant Pump Lube Oil Collection System Appendix A Results of Licensing Document Review sigmficance of the requests. The report also provides a summary of research results and a discussion of the impact these results have on the stairs view of fire protection requirements.
Section 1.6: Section III.O requires an oil collection system to prevent oil leaks from causing an extensive fire inside containment. Where oil collection systems were not provided, exemptions were granted for the following alternatives:
a) The oil is entirely contained within the electric motor housing; or b) The oil inventory was reduced to 15 gallons per pump or replaced with a nonflammable fluid
'4 Each of these alternatives mitigates the potential hazards to an equivalent extent as the collectioh system.
Information Notice 84-09, Lessons learnedfrom NRCInspections ofFire Protection Safe Shutdown i
systems (10 CFR 30, Appendix R), Attachment 1,Section XII. RCP Oil collection Systems At some facilities, the lube oil collection systems for the reactor coolant pumps were not sized to accept the entire lube oil inventory from all reactor coolant pumps without overflow. This does not protect against the consequences of simultaneous failure of more than one lube oil system during a seismic event.
Section III.0, Oil Collection Systems for Reactor Coolant Pumps, is written for a single pump.
The collection container is required to hold the entire inventory of the oil system of the pump. It follows that if additional pumps are present they would each be provided full co!!cetion capacity.
there are usually from 2 to 4 reactor coolant pumps in a plant. The oil inventory of one large pump is approximately 275 gallons. Some licensees have provided several containers connected in parallel for each pump.
The NRC stafTposition on the capacity of a reactor coolant pump oil collection system which meetsSection III.O of Appendix R to 10 CFR 50 is:
One or more tanks need to be provided with sufficient capacity to collect the total lube oil inventory from all reactor coolant pumps draining to the container.
Alternatives which have been found acceptable under the exemption process are:
1.
One or more tanks need to be provided with sufficient capacity to hold the total lube oil inventory of one reactor coolant pump with margin if the tank (s) is/are located such that overflow from the tank (s) will be drained to a safe location where the lube oil will not present an exposure fire hazard to or otherwise endanger safety-related equipment; or 2.
Where the RCP lube oil system is shown, by analysis, to be capable of withstanding the l
safe shutdown earthquake (SSE) (eliminating the consideration of simultaneous tube oil system ruptures from a seismic event), protection is required for random leaks at f
mechanicaljoints in the lube oil system (e.g., flanges, RTD connections, sightglasses).
I Alternative methods of protection may be deemed acceptab!c for such designs. In RCP lube oil collection systems of such designs, one or more tanks need to be presided with sufficient capacity to hold the total lube oil inventory of one reactor coolant pump with l
Prepared By: Tri-En Corporation 97FP02-DOC-01, Rev. 0 Page 26 of 36 l
N:rth:rn St:tes Powzr Ccmpx:y _
Prairie Island Nuclear Generating Plant Compliance Review of 10 CFR 50, Appendix R. Section m.O Reactor Coolant Pump Lube Oil Collection System Appendix A l
Results of Licensing Document Review margin. Because protection is required only against possible leakage resulting from random leaks from the one pump at a time, any overflow from the tanks need not be l
considered; or l
J.
For those pumps where the lube oil is contained entirely within the pump casing, an oil collection system may not be required, provided it can be shown that there are no potentially significant leakage points.
Generic Letter 86-10. " Implementation ofFire Protection Requirements", Enclosure 2. Section 6.0 Question 6.1:
"Ifthe reactor coolant pump lube oil system and associated appurtenances are seismically designed, does the lube oil collection system also require seismic design?
Is an exemption required?"
Where the RCP lube oil system is capable of withstanding the safe shutdown earthquake (SSE),
the analysis should assume that only random oil leaks from the joints could occur during the lifetime of the plant. The oil collection system, therefore, should be designed to safely channel the quantity of oil from one pump to a vented closed container. Under this set of circumstances, the oil collection system would not have to be seismically designed.
An exemption is required for a non-seismically designed collection system. The basis for this exemption would be that rardom leaks are not assumed to occur simultaneously with the seismic event, since the lube oil system is designed to withstand the seismic event. However, the Rule, as written, does not make this allowance."
Question 6.2:
"It would appear that a literal reading ofSection 111.0 regarding the oil collection systemfor the reactor coolant pump could be met by a combination ofseismically designed splash shields and a sump with su.]Icient capacity to contain the entire tube oil system inventory. Ifthe reactor coolantpump is seismically designed and the nearbypiping hot surfaces are protected by seismically designedsplash chields such that any spilled tube oil would contact only cold surfaces, does this design concept conform to the requirements ofthe rule?"
If the reactor coolant pump, including the oil system, is seismically designed and the nearby hot surfaces of piping are protected by seismically designed splash shields such that any spilled lube oil l
a culd contact only cold surfaces, and it could be demonstrated by engineering analysis that sump and splash shields would be capable of preventing a fire during normal and design basis accident l
i conditions, the safety objective of Section III.O would be achieved. Such a design concept would have to be evaluated under the exemption process. Thejustification for the exemption should provide reasonable assurance that oil from all potential pressurized and unpressurized leakage points would be safely collected and dained to the sump. The sump should be shown capable of safely containing all the anticipated oil leakage. The analysis should verify that there are no electric sources ofignition.
Prepared By: Tri-En Corporation 97FP02-DOC-01, Rev. O Page 27 of 36
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l N:rthern States Power C:mp=y Prairie Island Nuclear Generating Plant I
Compliance Review of 10 CFR 50, Appendix R, Section IH.O l
Reactor Coolant Pump Lube Oil Collection System I
l Appendix A Results of Licensing Document Review information Notice 94-58, " Reactor Coolant Pump Lube Oil Fire "
The NRC issued this Info Notice to notify licensees of fire incidents involving RCP lube oil in Haddam Neck Plant and Millstone Nuclear Power Station. In both events, the NRC observed that tube oil had leaked from the piping and was not collected in the lube oil collection system. In PWRs, each RCP motor typically contains between 530 and 830 liters (140 and 220 gallons) of oil. Oil leaking from the lube oil system may come in contact with either (1) surfaces that are hot enough.
to ignite the oil, or (2) an electrical source ofignition. An adequately designed, installed, and maintained oil collection system is necessary to contain any oil released because ofleakage or failure of the lubrication system and to minimize fire hazards by draining the oil to a safe location.
i Prepared By: Tri-En Corporation 97FP02-DOC-01, Rev. 0 Page 28 of 36
L-N:rthern Setes P:wer Ccmpsy J
Prairie Island Nuclear Generating Plant Compliance Review of 10 CFR 50, Appendix R, Section III.O Reactor Coolant Pump Lube Oil Collection System Appendix B l
Prairie Island RCPLOCS Walkdown Guide 1'
Purmone l
The purpose of this procedure is intended to provide the necessary guidance to effectively inspect the RCPLOCS and identify any deficiencies in the design and installation of the collecuon systems. A procedure is necessary in order to establish a systematic method in which to perform the inspection while acknowledging the ALARA concerns associated with the Reactor Coolant Pumps (RCP).
$t995 il The scope of this inspection shall encompass the entire Lube Oil Collection System (LOCS). This shall include any area in which oil may be present or projected from a pressurized source on the RCP. These areas typically include the are at the top of the motors in the vicinity of the oil lift pump and piping, pan level in the area of the lube oil coolers, oil level sight glasses, oil vent line, oil temperature and pressure transmitter connections, and the lower pedestal area in the vicinity of the oil collection pan drain lines.
This inspection shall also include all remote oil fill lines if any and the a!! piping which is responsible for transporting leaked oil from one temporary collection receptacle to another. Particular attention shall be focused on the areas immediately adjacent to the RCP for any signs of oil residue.
The scope of this inspection shall be limited to the oil collection system up to the Sump A collection receptacle. The remainder of the system from the sump to the aerated drain tank, located in the Auxiliary Building, is a Seismic Class III which has been approved by the NRC via the exemption process and is documented in a letter dated July 31,1984 from James R. Miller, NRC to D.M. Musolf, NSP.
1 Prepared By: Tri-En Corporation 97FP02-DOC-01, Rev. O Page 29 of 36
N:rthern St:tes P:wer Ccmp :y Prairie Island Nuclear Genecting Plant Compliance Review of 10 CFR 50, Appendix R, Section IILO Reactor Coolant Pump Lube Oil Collection System Appendix B Prairie Island RCPLOCS Walkdown Guide Eauipment Reanired Tape Measures Flashlight Instant and Digital Camera Notepad and pencil RCP Walkdown Checklist Method Note 1:
Drawing No. X-HIAW 1 1252 2, provides a graphic desenption of the RCP assemblies in senice at Prairie Island. All potential leak sites have been annotated on these drawings.
These drawings will be used to identify those leak sites in the field.
Note 2:
As noted in the Scepe section, the purpose of the Adequacy Analysis and walkdown is intended ascertain the overall condition of the RCPLOCS.
This includes evaluating the condition of the system as it relates to the original design and configuration as well as the overall maintenance of the system by the cogmzant maintenance organization. As such, the scope of the walkdown will include a general assessment of the overall condition of the RCPLOCS. Noted should be any components of the system which appear to be in disrepair. These noted deficiencies should be recorded on the walkdown data sheets.
Note 3:
Photographs will be taken of all identified deficient conditions. Number all photographs and correlate them on the walkdown data sheets.
1.
Prior to entering containment become familiar with the containment layout relative to the RCP locations by reviewing the equipment location drawings. If possible, perform an inspection of the spare RCP which is located on turbine deck. Become familiar with the potential leaks site as depicted on the drawings and annotate the drawings accordingly.
2.
Prior to entering the RCP area make note of the walls and structural members for any oil residue or signs of past oil residues (staining).
3.
Ascend to the top portion of the RCP motor in the vicinity of the Oil Lift Pump. Inspect the oil lift pump and piping.
Observe the area directly below to assess the potential for leaks to be collected and directed to the sump.
Make note of any ventilation registers in the area which may impact the directly in the oil is carried.
Complete Attachment I for the observations made at the Lift Oil Pump and make any additional notes uhich may be pertinent to the conclusions of Adequacy Analysis.
Prior to descending the top clevation, inspect the lower section of the motor for fittings, components, or configurations which may be obscured from inspections below. Make note of any unusual configurations.
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N:rthern St:tes P wer Cempny Prairie Isl=d N:cle:r Gen:rati:g Pl nt Compliance Review of 10 CFR 50, Appendix R, Section IILO Reactor Coolant Pump Lube Oil Collection System Appendix B Prairie Island RCPLOCS Walkdown Guide l
4.
At the pan Icvel inspect all appurtenances associated with the RCP. T!us shall include but is not limited to; lube oil cooler, oil level sight glasses, oil fill lines, remote oil fill lines, instrument transmitter connecuons, and drain lines.
1 5.
For each identified potentialleak site make note of the following and record the results on the walkdown data sheet as necessary, Material type i
e type of connection (i.e. flanged, threaded, swagelock, etc.)
e shields around potentialleak sites e
pans provided to catch allleads e
any potential HVAC flow which may alter the path of the oil to the collection pan e
6.
Inspect all adjacent piping and structural members for sign of oily residue and note any finding with particular attention to the location (i.e. coordinates and RCP location).
7.
At locations where oil spray or splashing is a potential, inspect all piping insulation and overlays. Idenufied if possible the type ofinsulation and any openings in which oil may nugrate to the interface between pipe and insulation..
8.
Inspect contents of floor sump, estimate quanuty and type of contents in the tank.
9.
Perform an inspection below the pedestal of all LOCS drain lines if possible from the pans to the collection sump (Sump A), from sump A to the containment wall, and in the Auxiliary Building from the containment wa!! to the closei vented collection tank (reference Dwg
- NF 39248). Make note of the following features associated with these drain lines; type of connections (wc!ded, threaded, flanged, swagelock, etc.)
l e
structural supports e
leaking connections e
broken, bent or otherwise damaged piping e
10.
Inspect the floor area beneath all piping for signs of oil 11.
Inspect contents of floor sump, estimate quantity and type of contents in the tank.
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Ncrthern St:tes Pow:r Ccmpsy l
Prairie Isla:d Nrclear G= err.tirg Pla:t 1.
Compliance Review of 10 CFR 50, Appendix R, Section IILO Reactor Coolant Pump Lube Oil Collection System Appendix B Prairie Island RCPLOCS Walkdown Guide RCP Thread Flange Steel PVC Shields Air Tubing Ins Notes l-Flow (Swage-ula lock) tion Lube Oil Cooler Lift Pump Piping Site Glasses Oil Fill Connectio ns Remote Oil Fill Lines Ventilation Lines Demisters Drain Lines Instmment Connectio ns Overflow Lines Other Notes:
l Prepared By: Tri-En Corporation 97FP02-DOC-01, Rev, 0 Page 32 of 36
Northern States Power Company i
Prairie Island Nuclear Generating Plant Compliance Review of 10 CFR 50, Appendix R, Section 111.0 l
Reactor Coolant Pump Lube Oil Collection System Slide 1 RCPil Lube Oil Cooler and Lower Pot Sight Glass
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Northern States Power Company i
Prairie Island Nuclear Generating Plant Compliance Review of 10 CFR 50..tppendix R.Section III.0 Reactor Coolant Pump Lube Oil Collection System Slide 2 RCP 11 OIL LIFT PtlMP l
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1 Northern States Power Company t
l Prairie Island Nuclear Generatim: Plant Compliance Review of 10 CFR 50.. Appendix R. Section 111.0 Reactor Coolant Pump Lube Oil Collection Svstem l
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e Prepared by: Tri-En Corporation 97FP02-DOC-01, Rev.0
Northern States Power Company 1
Prairie Island Nuclear Generating Plant Compliance Review of 10 CFR 50.. Appendix R.Section III.0 Reactor Coolant Pump Lube Oil Collection System Slide 4 RCP 11 Below 011 Lift Pump Drip Pan 1
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1 Prepared by: Tri-En Corporation 97FP02-DOC-01, Rev. O
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Tri-En Corporation:
Prairie Island Nuclear Generating Plant Configuration Management and Administrative Controls Process Review Fire Protection Program l
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