ML20239A652

Advises That 870730 Meeting at Site Will Consider Routine Licensing Issues in NRC Plant Sys Area of Review.Draft Agenda for Fire Protection Portion of Meeting Encl

ML20239A652
Person / Time
Site:	Peach Bottom
Issue date:	07/27/1987
From:	Martin R Office of Nuclear Reactor Regulation
To:	Alden W PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
Shared Package
ML20239A640	List: IR 05000277/1985023 ML20239A652
References
NUDOCS 8709180054
Download: ML20239A652 (75)

Text

{{#Wiki_filter:______ - ENCL cSU A G.3 [ o UNITED STATES E' ~,, p, NUCLEAR FIEGULATORY COMMISSION 5 l WASHINGTON,! h, 20555 k. ,/ Jy( t i W Docket Nos.: 50-277 50-278 Mr. William M. Alden Engineer-In-Charge-Licensing Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101

Dear Mr. Alden:

Our meeting at the Peach Bottom Atomic Power Station Site on July 30, 1987 will consider routine licensing issues in the staff's plant systems area of review. Enclosed is a draft of the agenda for the fire protection portion of the meeting. f Ro ert E. Martin, Project Manager Project Directorate I-2 1 Division of Reactor Projects I/II

Enclosure:

As stated 3 I cc: NRC PDR Local PDR l l i 8709180054 870914 PDR ADOCK 05000277' F

PDR, l

I

l s I 10 CFR Part 50, Appendix R Review for Peach Bottom, Units 2 and 3 Docket Nos. 50-277/?78 l References I. Licensee's submittals on Appendix R compliance for Peach Bottom Nuclear Units 1. Fire Protection Program - September 30, 1986. 2. Compensatory Measures for Conditions of Non-Compliance with Appendix R l - October 24, 1986. 3. Justification for Continued Operation (JC0) of Peach Bottom Nuclear Units with conditions of Non-Conformance with Appendix R - November 28, 1986. 4. Fire Protection Program - January 8, 1987. II. Letter from Director, DRS, Region I to the Licensee 5. Status of compliance with Appendix R at Peach Bottom Nuclear Units - February 20, 1987. During our s'ite visit on July 30, 1987, we wish to discuss the following items relating to the Fire Protection Program at the Peach Bottom Nuclear Units: A. Conditions of Non-Compliance with Appendix R References 3, 4 and 5 have listed these conditions and the proposed Interim Compensatory Measures (ICMs) until the permanent modifications are completed. Reference 5 has concluded that the proposed ICMs are j acceptable. Our review of References 3 and 4 and our contractor's (Brookhaven National Laboratory) Technical Evaluation indicates that the information provided by the licensee on proposed permanent modifications is incomplete. So, we will seek descriptions of the modifications underlined and listed below during our site visit: 1. Power Source which survives an Appendix R fire, relocation or installation of instruments and protection of cables for preventing the adverse condition listed below: a. Loss of process and diagnostic monitoring instrumentation - Fire Areas (FAs) 2, 13N and 65. 1 2. Control Circuitry changes for preventing the adverse conditions listed: l a. Blown control power fuse for ESW-FAs 43, 44, 45 and 46. b. Blown control power fuse for ESW/ breaker lockup-FAs 37-39, 48 l and 50. c. No RHR minimum RHR flow protection - FAs 65 and 13N d. Closure of ESW discharge valve - FAs 2, 25, 34, 36 and 43.

I l g e -W ! l 3. Rerouting the applicable control cables for preventing the adverse conditions listed below: a. Loss of Unit 2 relief valve operability - FAs 6S and 6N b. Feedwater block valve closure - FA 25 ) 4 Installation of local controllers for preventing the adverse conditions listed below: a. Spurious closure of HPCI and RCIC steam line inboard l isolation valves - FAs 6S and 13N l b. RCIC isolation valve closure - FA 6N 5. New instrument loop to preventithe adverse condition listed below: I a. Loss of CST Water level indication - FA 50 l i 6. Installation of Trip Circuits to prevent the adverse condition listed; a. Inability to isolate HPCI - FA 13N b. Inability to isolate RCIC - FA 25 I 7. Sealing of man-hole covers to prevent the adverse condition listed-l ) a. Intrusion of combustible liquid caused by inadequate separation between redundant HPSW/ESW pumps - FAs 50, yard b. Same as above caused by inadequate separation between redundant diesel generator cables - FA yard, j i 8. Long-term air supply to prevent the adverse condition listed: a. Loss of Unit 2 relief valve operability - FA 65 9. Permanent backup nitrogen supply to prevent the adverse condition listed: a. Damage to parallel air headers for SRV operation - FA 13S 10. Electrical overcurrent coordination to prevent the adverse condition listed: a. Loss of HPCI MCC 20 D 11/ 20 0 11A coordination - FA 6S 11. Protection of applicable cables to prevent the adverse conditions listed: a. Trippling of RHR pump breaker - FAs 35, 36 and 37 - 3 cables b. Blown logic power fuse for core spray - FA 2 - 2 cables l

s v c. RHR pump breaker logic trip / lock up - FA 34 - 2 cables d. Spurious Co, injection in OG compartments - FAs 44, 45, 46 and 54 - 4 control cabies e. HPCI spurious isolation signal - FA 13S - 2 control cables ' i f. Operation of bus differential relay - FA 34, 35, 36 and 37 - 4 cables g. Loss of core spray flow indication - FA 2 - 1 instrumentation cable h. Loss of RHR/HPSW flow indication - FA 30 - 2 power cables 1. Loss of power for DG auxiliary MCC - FA 6N - 1 power cable J. . Loss of torus temperature indication - FA 13N - one instrumentation cable k. Loss of RHR flow indications'- FA 4 - 1 instrumentation cable 1. Loss of Process indication - FA 6N - all required instrumentation cables l We will be additionally seeking information regarding the following: 1. Availability of fire detectors and automatic fire suppression systems as required by Appendix R, Section III.G.2.C for all the areas listed under Modification 11. 2. Safety Analyses for all modifications listed above to demonstrate that these modifications will not adversely impact any safety-related system, equipment or component. B. Alternative Safe Shutdown Procedure SE-10 With regard to the above, we will discuss the following items: a. current status of SE-10 b. Identification of all the manual actions c. The time frames after scram for completing the various manual actions. The time-line manual actions may be identified in a separate document. d. Minimum time frame after scram before which a few manual actions may l require completion; number of such manual actions; brief descriptions l of such actions.

l b g ') -4 l l C. [ligh/ Low Pressure Interfaces Licensee's submittals exclude fire-induced breaches of some high/ low 4 presture interfaces as " incredible". We will seek supporting analyses performed taking into consideration the positions outlined in Generic j Letter 86-10, Section 5.3.1 for each of the omitted interfaces to demonstrate the validity of their exclusions. Alternately, we will seek i identification of the corrective measures for each of the omitted interfaces. D. Shutdown Method C We will discuss the following items with regard to the above: a. Compliance with NUREG-0783 for suppression pool local temperature limit during steam discharge into the pool. b. Adequacy of available NPSH for the RHR pump. E. Miscellaneous Our discussion may also include the following items: a. High Impedance concerns corrective measures for electrically-operated breakers associated with non-safe shutdown loads supplied by a comon bus that supplies power to safe shutdown loads, b. Electrical Isolation Deficiency corrective measures in case local and remote control circuits for hot shutdown equipment or component share a comon fuse (both interim and long-term measures) c. Hot and cold shutdown repairs Identification of such repairs if applicable. d. Man Power Needs Available on-site man power excluding fire brigade crew f I l 1

4 E~N C L o s M it.E 4-- 1 l .g_' L-f I CALCULATION SHEET

• ~ " * "

PHUDELPHI A ELECTRIC CO. NAME - 8AW /~ ZMA / M 5 fg LOCATION DATE 7 SHEET NO. ! SUBJECT M O JOS/CA NO.

k.)

e Q ... % g\\() w \\* b o- .1! G._. 9.!i e i lg I'y! i ! F ' m F~ ' < 'i ICL-n bB m!C i0i g i L.. ..T. ~ M g p 3. . A.. . _. - q. _.. q. _.. q.._..._ e >...sd _.._g _4 ._. ~ # _.x) ___ .q.g e ] . _ _q _. _.. 4 ..._q._... _ q__._._. __ % _ f _.. _ 9 ~ ~Q .r a v)._. _n a _... _. .q ......Q..-._......_... y... ..g .sp.. z .. _. g. \\ _. 4..-- n ~ .Q s, s 3 a *s s.._... s . 9.. ..T I

g. _-_

s s N \\., Q) )

k. t - _. & -._

s e_ I s

• 9.._3.f_.....)j....._p...

jp .....a i N. [ e e m .y .. e. e e m

CALCULATION SHEET ~"~ esitmocte s A cuccTaic co. NAME - 80W ~ i- .I A/N /6d"/ 777 M DATE I M 7 SHEET NO. LOCATION suene, </Inardk A 7??ods w,ica uo.. . N w.. # _ a _ l l s 2 4 s.*~ .k% 4 3 <t . 3 % S! l@ 102) 18l !s! I 19 ! Q l! 3 7 4, I "i i n 4' ! 1 Il to %l1Iq t i ; 1 j )..q._.Q._.x.9__.g O. (3 g 4 g ] ' b _.._h _...k.. __q._.. g.j._._......_.. __ _.,. D.... _....$ ___ _ q' _.h %. _. _.u. _..y._. f g .._.11 - G,, j N h v 'a S t n . \\,. . Q. _... L,.. .h .st t a. . q ......a.. N s s s w 3 = i .T....$ _....... R ..-s. %..._.g.....__. Q _ % 3 - 4 m g4 4 ..s N o .. a _. = 1 .F_.. E A s. ..1 T .. st....... + e q m u g 7 _ 5 _._ k ._.._'h,._e'._.. k. Y .k....p.. y. __, D h 9 e .. s.... Q x.__kj.. _7._~.. y

y.,_

c. .x.. .. _ s_ r. .q ~ S g. L 5 A w___ 4 D Q q". 3 (.____ D.7 h. S.. _ __.. _%.y..._ W..:.]__ D_.. _ q & { ( h f.~ f f [ ?g ~ h ( ~~ q _a_ . _g.. n 3 q m w y 7 y _ e_e.w. O( %q. d ... d _ _ _...d. _ -. . -O... 51 .g.M. .-c M. _. 4

n e*

M M M __. __M _d_. _'s .d b k.. l ) i 4

e FED.V CALCULATION SHEET -t "~.. PHILAOC LPHI A ELECTmc CO. NAME - M6MP / ?) MA AN M 5 DATE IM/' Y SHEET NO. LOCATION M 4 1' 8 N N 6 Jos/CA NO. sun;Ecr = __ t t h W __J . 50 tv W cn Rt 12 16 _! d I Ei 5, .!$! !M i l l i ^%! 3, ! % i ! T 1 99 19 I ird N ! Pa i l t j ~. ) g h _.... -._. _._ _.:.K. _ $ 4.......q Q.. ...-N_.... _ q. _. . h~ __ h, .q 3a_.. .._ M _. %.. N 3 s .y u w _.-y_..___..__.._. . q._. y_..._. . p..}._ __.t. .. b. k .. _ '.s- . _f. N~..._....... w.q. f .t ) m y . ~. ( 4.... E 3 _ _. 4 _. 3_.,. g _.... q T __. . s':}.. o 9 s ~_ . R._.. q. _. _ _%e .q. .n Q.. ....g ..t i@ w w q . _ _4.. s ._.o...........__.. ..,E N S a )- 3_.2.. -] .._._.8_ _. L. f' 1, i (. ___ ~~[T v N. hA t, %s x g o . %~ 4 m u e o _. 4 .9. M.___. Q.g. h D C n e Q A kR 4 4 4 4 4 g .g .g . y... __n . e._ 3 .w. x w v). w s,, >3 g .s 3 ~ c. 3 h .d... _a.a. .. \\. %. x .e b u .N Y... .,I ~ f s 1 I I l {

s [ U

• • • w-=

= = = - w.,.,... xM/D. i /MA ? hALU f..t62tlWdIA f. W% lib\\ . _j.MsA> -not_du / 950 MAta u_au _>Aaufsv i /Nk vno'g' A gaxxfaadsn ades neco' WSJ (Jo77 i ho 79 0 aord 1 ank? 06h"l DX2hox bcdr>JDx77c? l asV-J' _fsl/d b auW2 t'.szue In b' gax - 776 g'&a% Lalo!IN { a hA16,A l ? o6es-axe mod sopp ixmpw) - zo i } b aaOf QJihtbu6a ) 66N 6 aumiew 6 ee au.-

2870040850 .. v, s f ,,s

• ELECTRICAL ENGINEERING DIVISION N3-1, 2301 Market Street l

l is Date: April 29, 1987, Rev. 3 Safety Evaluatien fer Modification 1029E Peach Bottom APS Unit 2 l File: RES 5-3 (Mod 1029E) Doctype: 565

Subject:

r Modification 1029E provides process and diagnostic instrumentation to meet 10CFR50 Appendix R-Safe Shutdown instrumentation requirements at Peach Bottom APS Unit 2. The scope of this modification entails the rerouting of existing instrument and power cables, the change of power feeds and the addition of alternate power feeds to existing instrument locps, the relocatien of a reactor pressure transmitter, and the instal-latien of two complete reactor and CST water level instrument loops.

== Conclusion:== Although this modification does involve safety-related equipment no unreviewed safety questions are involved. This modifi-j and systems, cation does not involve a significant hazards consideration. Changes to the Technical Specifications are not required. This modification is a j and fire protection modification and affects fire protection equipment the capability to safely shut down the plant in the systems.

However, event of an Appendix R fire is improved.

An amendment to the operating license is not required. Discussion: l Modification 1029E has been installed in Unit 3. Any references to Unit 3 have been deleted from this document. The design, installation, ) and operation of modification 1029E, Un.it 3 is documented in Rev. O of this document (attached). The revision of this document'only reflects Peach the design, installation, and operation of modification 1029E at Bottom APS Unit 2. l A fire event used throughout this Cocument is described as an Appendix R fire for which the definition can be found in the Peach Bottom APS Units 2 and 3 Fire Protection Program (FPP). Safe Shutdown requirements require that process and Appendix R instrumentation be provided to assure safe shutdown of the diagnostic reactor in the event of a fire in any of the fire areas that have been l defined for the Peach Bottom APS Unit 2 and common areas except for the control recm, cable spreading room and remote shut down panel areas.

d .S

• s 2870040850 For these areas, alternate shut down instrumentation will be provided separately.

Diagnostic indication will be provided only for the systems associated with the safe ' shut dcwn methods (A, B, or c) which are described in the PBAPS Units 2 and 3 FPP. Process indication will be provided for reactor water level and p re s su re, drywell pressure and temperature, suppression pool level and temperature, and condensate stcrage tank (CST) water jevel for safe shut down metheds A, B and C. In certain fire areas, in the event of 'a fire, c7ntrol roem indicatien of some instrument loops is assumed to be lost because either pcwor and instrument cables cr components associated with the safe shut down inst ruments are assumed to be lost. The re fore, the Appendix R Task Force has identified the following work in order to bring Peach Bottom APS Unit 2 in compliance with Appendix R - Safe Shutdown instrumentation requirements: 1. Rercute the following instrument cables: a) 2Q14138, associated with instrument FI-2-10-139A, out of Fire Areas 2 and 4. b) 2I619J associated with drywell temperature element TE-2501-36B out of Fire Area 6N. c) 2I886A, associated with instrument LI-8027, out of Fire Areas 65 and 6N. d) 2Il30F, associated with instrument TRS-2-10-131, out of Fire Area 6S. j c) 2I130K and 2Q1615B, associated with instruments TI-2445 T\\ and PI-2-6-90A respectively, out of Fire Area 6N. 2. Provide alternate power feeds from distribution panel 20Y50 with automatic transfer capability to instrument loops FI-2-10-132B, FI-2-10-139B, PI-0236A, TI-2501, LI-8027, and power supply PS-2 which is located inside panel 20C144 for a fire in Fire Area 65. 3. For Fire Area 6S a) Install a new reactor water level transmitter on instru-mentation rack 2AC91 and conntet the transmitte r to existing level indicator LI-2-2-3-91A which will be disconnected from LIS-2-2-3-73A. b) Change power feed to instrument loop PT-4805 from the output of the 24 VDC ECCS power supplies to the 24 VDC power supplies within panel 20C144. The instrument and i the new 24 VDC power feed cables of PT-4805 will be rerouted to meet the Appendix R separation requirements. In addition, the 120 VAC power cable to PR-4805 will be reinstalled with a non-safeguard routing to accommodate the required alternate power feed from panel 20Y50.

2870040850 c) Relocate pressure transmitter PT-2-6-105 from instrumen-tation rack 2SC65 to 2AC91, d) Install a new cable associated with dryaell temperature elemene TI-2501-26, frem dr sell penetration ::1223 te cable spreading rcem panel 2SC172. 4 Change power feed to: a) Temperature Transmitter TT-24429 from distribution panel 20Y32 to 20Y50 for a fire in Fire Area 6N. b) Temperature Indicator TI-2501 frem distribution panel 20Y34 to 20Y33 for a fire in Fire Areas 34, 35, 36, 37, 40, 45 and 50. 5. Provide control room indication for CST water level by in-stalling a new instrument locp for a fire in Fire Area 50. The transmitter will be installed locally inside the vacuum breaker room on elevation 116'. 6. This modification also temporarily installs a local reactor water level indicator on instnimenta tion rack 2AC91. This temporary installation is required to provide justification for continued operation (JCO) as described in item 14 of the letter from R. J. Lees to R. S. Fleischmann II dated 11/12/96, " Appendix R Task Force, Justification for Continue'd Operation, Peach Bottom APS Units 2& 3." This local indicator will be removed when the full scope of modification 1029E is installed at Peach Botten APS Unit 2. This modification affects safety-related systems and components. l 1. The cables listed in item 1 will be rerouted so that control l room indication, for 1!he parameters associated with the l I 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 will not exceed the allowable loop impedence of each instru-ment loop. The rerouting of these cables will be in accor-dance with established design criteria for electrical 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 65 (plant general area elevations 135'

south, 165',

195' and 234') could cause the loss of all emergency load centers and therefore, all 480 and lower voltage AC pcwer except for 120 VAC power available through distribution panel 20Y50. This ' panel is normally fed from the 23001 and 2D001 batteries through distribution panel 2BD18, Icad center 20008 and static inverter 20037. To ensure that diagnectic and process instrumentation is available in the

4 D' l 4 _4_ 2870040850 e n control rcom in the event of a loss of power, this modifica-tion provides - alternate pcwer feeds frem distribution panel 20Y50, through auto. transfer switches, to. instrument locps - F2-2-10-1323, FI-2-10-1393, PI-0236A, TI-2501, LI-8027 and pcwer supply PS-2 which'is locaced inside panel 20C144. These. inscrument s are not Q-listed and ' do not perform any' safety-related function. The addition of alternate pcwer feeds will not adversely affect the ' function. or reliability o f. the instrument loops. The design and. Installation of the' auto transfer switches, including the routing of' cables-from and to the switches and the instntment loops, will be in accordance 1 with established design and installation criteria of Bechtel Specifications E-1315 and E-1317 and will. meet the ' fire protection requirements of Appendix R. Since the instrument loops are not safety-related, the auto transfer' switches need not-to be-environmentally or seismic qualified. However, environmental design-requirements for the auto transfer switches will be specified to ensure compliance with Regulato-ry Guide 1.97 (Accident Monitoring) commitments. 3 3. In addition to.. the loss of AC power, a fire in Fire Area 65 would cause loss' of contrcl ~ room indication for all the reac-tor water -level, rasetor pre ssure, drywell p re wure, and drywell temperature instrument loops. This condition exists because either the transmitters are located in Fire Area 65 or the cables associated with the transmitters are rcuted thrcugh this fire area. To ensure that control rocm. indication for reactor water level, reactor pressure, drywell pressure and drywell temperature 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 2AC91 which is located on elevation 135' in Fire Area l6N. Control room indication for the new reactor water level transmitter will be available through existing level indi,cator LI-2-2-3-91A which will be disconnected from LIS-2-2-3-73A and retagged as LI 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-2-6-105 and FT-2-2-3-63A, respectively, and the indicator scale -will be changed to -325 to +60 inches such that wide and reactor shroud ranges can be read. The new compensated reactor water level instrument loop will require the re-route of instrument cables associated with the reactor pressure and jet pump flow transmitters. The compensat-ing network function is not safety-related. The electron-ic nest, which will house the compensating network, need not be environmentally or seismically qualified.- However, the electronic nest, which will be installed inside a safety-related, Q-listed panel (20C722E) will be m:unted

i t r.< 3 2870040850." such that it will not damage any safety-related equipment nresent inside the panel during a seismic event. The 2ditienal weigh: lead,.the electronic nest, to the vC-listed panel wi:.1 net affe:: the seismi: qualification of the panel. The electronic nes; wi'.1 be powered by 120 VAC frem distribution panel 20Y50. The pcwer feeds of I, instrument icops PT-2-6-105 and FT-2-2-3-63A will be j l 4 changed so 'that both loeps wl.11 be fed frc= an existing single DC power supply fed also from distribution panel 20Y50. Level indicator LI+2-2-3-91A is not Q-listed. Disconnecting this indicator from level indicating switch LIS.2-2-3-73A, which is Q-listed, will not adversely [- affect the safety-related function of the level switch. .i Siirveillance test procedure ST-9.1-2X and contro l room annunciator will ensure control room operators that the level indicating switch is properly operating, b) Change the pcwer feed to instrument loop PT-1805 from the output of the 24 VCC ECCS power supplies to the 24 VDC power supplies within panel 20C144. In additi.on, the 120 VAC power cable to PR-4805 will be reinstalled with a non-safeguard routing to accommodate the required alter-nate power feed from panel 20YSO through an automatic transfer switch. The power and instrument cables to PT-4805 will be rerouted to meet the Appendix R separa-tion requirements. Instruments PT-4805 and. PR-4805 are Q-listed and only provide drywell pressare indication in the control room. Their safety-related function, post-accident monitoring of drywell pressure, was replaced by Q-listed drywell pressure locps PT-8102A, B, C and D and ) PR-8102A and B. Since the indicatian portion of the i instrument loop, PR-4805, 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-4805, will remain en the, Q-list for drywell pressure boundary 1 integrity consideration only. i c) Relocate pressure transmitter PT-2-6-105 from instrumen-tation rack 2BC65 to 2AC91. The transmitter is not Q-listed and does not perform any safety-related func-1 tion. Relocating the. transmitter will not affect its j function of providing the reactor pressure signal for , pressure recorder'PR-2-6-96. Relocation of the pressure transmitter will require cable 2Q1608B to be rerouted. d) Install a new cable between drywell temperature element TE-2501-26 and cable spreading room panel 2BC172. The temperature element is not Q-listed and does not perform any safety-related function. I' The cable routing and installation of the new reactor water level compensating network, including the new routing of the reactor water level loop and reroute cf instrument cables l l - ~ _ _. - -. _. _

2870040850 asscciated with transmitters PT-2-6-105 and FT-2-2-3-63A, the reroute of cable 2Q16083, the pcwer feed change to PR-4805, the reroute of power and instrument cables of PT-4805 and the inctallatien of the new cable between drywell temperature element TE-25Cl-26 and panel 2SC172 will meet the installa:ica and electrical separation requireme nts of Bechtel specifica-tions E-1315 and E-1317 and the fire protection separation requirements of Appendix R. All piping, tubing, fittings, instrument valves and supports associated with the new reactor water level and the relocated reactor pressure transmitters, 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 transmitte r will not be Q-listed because it will not perform any safety-related functicn. The relocated reactor pressure transmitter will remain non-Q-listed. The re fore, environmental or seismic qualification of the transmitter is not required. However, both transmitters and their associated piping, tubing, fittings, and instrument valves, will be seismically' mounted to maintain pressure boundary integrity. Maintaining pressure boundary integrity 4 is necessary to ensure operability of safety-related instru-ments connected to the same instrument line. These instru-ments are installed non-Q in accordance with the design criteria applicable to the original design. The continued viability of this criteria was examined and found acceptable based on industry experience with the loss of pressure integrity in safety-related and non-safety-related instrumen-tation components due to randem failures or seismic events. 4. This modification aisc changes the power feeds to the follcw-ing instruments: a) temperature indicator TI-2501 from distribution panel 20Y34 to 20Y33. 'The power feed is presently routed safeguard although the indicator is not Q-listed and does not perform any safety-related function; it monitors HVAC temperature for 66 variables. Therefore, the new feed can be routed non-safeguard. ( s I b) temperature transmitter TT-2442B from distribution panel 4 20Y32 to 20Y50. The existing power feed is presently ) routed non-safeguard. The transmitter is not Q-listed { i and does not perform a safety-related function; it only I l transmits a signal to indicate torus temperature. The power feed change to the above instruments will not affect their design function and will be made in accordance with i Bechtel Specifications E-1315 and E-1317. The power feed I cables will be routed in accordance with the fire protection l separation requirements of Appendix R. l l 1

) 28/0040850 e l 5. A fire in Fire Area 50, the Turbine Building, will cause the l f loss o f ' local and centrol room indication of the condensate storage tank level. To ensure control room indication, a new instrument loop will be installed. The CST water -level .j j transmi.:er - will be installed locany inside the vacuum breaker rocm on elevation 116', Fire Area 5, off an existing q vent line. All piping, tubing, fittings and supports associ-j ated with. the new CSI water; level transmitter, from the j 1 existing vent line up tc and including the seccnd valve off the ~ process line will b e. Q-listed. The remainder of the mechanical. work will be nc n-Q-1.is te d. The Q-portion of the piping / tubing, fittings and-valves will be seismically mount-ed. -The new CST instrument loop will be fed frcm the 24 VDC power supplies within panel 200144. The routing and installa-3 ) tien of the instrumenc signal and power cables will me. Bechtel Specifications E-1315 and E-1317 and the fire protec- ) tion separation. requirements of Appendix R. The new CST water level instrument loop will not be Q-listed since it does not i perform. a safety-related function, it will provide control ] l room indication of CST water level. 6. In order to meet NRC commitments for centinued cperation for a fire event in Fire Area 63, in which all control room reactor water level indication is lost, this modification temporarily j installs a local reactor water level indicstor en instruments-tien rack 2AC91. The local indicator will be installed j downstream of the normally closed drain valves of 'ex? sting instrument LT-2-2-3-73A. This temporary locsl reactor water { 1evel indicator is. net Q-listed and will not perform a safety-related function; it will indicate reactor water level locally in the event of fire in Fire. Area 65. All tubicq, fittings, instrument-valves and supports associated with the local indicator, from the normally closed drain valves of LT-2-2. 73A up to and including; the indicator will be non--Q-listed. However, the local -indicator and associated tubing, fittings and instrument valves will be installed seismically to main-tain pressure boundary ' integrity. Since the local indicstor will be installed downstream of the normally closed drain valves during the operation of the reactor, the installation will not jeopardize the normal operation of the reactor and w 21 not cause a reactor scram. The design, procu rement, installation, and testing of the Q por- ) tions of this modification will be in accordance with the Peach Bottom ') APS QA Plan, Vol. I. The design, procurement, installation, and testing j for the - remainder of work will be in accordance with Section 2.3 of the Peach Bottom APS QA Plan, Vol. I. Whenever this modification interfaces with an existing system, the design of this modification is in accor-dance with all the criteria applicable to that system including, but not limited to, quality assurance, environmental and seismic qualification. ] i The bus loading of the additional instrument loops, the transfer of j instrument loops to the alternate power source and the change of pr.ts: ]

l ? 1 \\ s , 2870040850 s I l feeds to instrument Iceps have been analy::ed and found to be acceptable. This mcdificatien is being installed to meet the fire protection instru-mencatien requirements of 10CFR50 Appendix R. Fire prctection ecmpo-nen s and cablas will be affected by this ecdif; cation. Hewever, the changes to these ccepenents and cables are being made in accordance wi-h l the 10CFR50 Appendix R requirements and the capability to safely shut dcwn the plant in the event of a fire is improved. The following Updated FSAR Sections are applicable to this modifi-l cation: 4.3, 4.8, 4.10, 5.2, 5.3, 6.4, 6.5, 7.1.6, 7.4, 7.0, 7.20, 10.7, 10.9, 10.14, Figures 4.8.2A&B, 5.2.6, 5.2.7, 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 1 changed by th: installatica cf this modification. The pl:nt decign changes are discussed in the UFSAR change control form. 10CFR50.59 Change s, Tests and Expe riments 1. This modification does not involve an unreviewed safety question because: a) The probability of occurrence or the consequences 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 safo:y-related systems and equipment, the original design criteria applicable to those systems and equipment have been appl.ed to this modification. The deletion of PR 4805 from the Q-list is acceptable since it no lenger performs a sa fe ty-rela ted function; its i safety-related function is now performed by fully quali-fled pressure recorders PR-8102A and B. These recorders are used to satisfy NRC Regulatory Guide 1.97 require-ments for drywell pressure monitoring. Therefore, the ope rability of the systems and equipment will not be compromised and the probability of an accident or mal-function will not be increased. b) The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report.is not created. The addition and relocation of instruments, the reroute and power feed changes, and the ' addition of alternate power sources to the instrument loops will not,af fect the cperation of any systems because the af fected instruments provide indica-i tien only. In addition, the reroute, power feed change, and the additle-of alternate power scurce to instru-ments, will not affect the separation of systems because applicable Becntel cable and raceway separation specifi-cations are being followed. Since the operation and j separation of any plant systems will not be affected by thi =cdi f;ca t;cn, the plant safety-related systems will perf:r t:-

• L r sa f e ty functica, therefore the possibility

) I i

2870040850 c ' ;l I for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created. c) The margin of safety as. defined in the basis for any Technical Specification is not reduced. Changes made by this modification will not affect or change the applic-able sections, bases and tables, listed belcw, of the i Technical Specifications. Pressure recorder PR-4805 is listed in Table 3.3.F, Surveillance Instrumentation. However, deletion of the recorder ficom the Q-list does not af feet the table because the pressure range of the q recorder will remain the same. ] 2. The following sections, tables and associated bases of the Technical Specifications have been reviewed and require no changes as a result of this modificat. ion: Sections Tables 3.2, 4.2 3.2.B, 4.2.B 3.7.A, 4.7.A 3.2.F, 4.2.F 3.6.A, 4.6.A 3.6.C, 4.6.C 3.6.E, 4.6.E 3. An amendment to the operating license is not required. 10CFR50.92 Significant fia:ards Determination A license amendment is not required for the design, insta11atien, and operation of this modification, therefore, a significant hazards i determination is not required. 4 [,,29/8 7 Prepared by: h dh W Date: [/Res nsible Engineer) / / 8/7[87 Reviewed by: M Date: (Lea'd Div. Independent Reviewer)

• 1f8~)

N. N Date: [ Lead Division (Branch or Section Head) A Lwo iWL Date: $ ll 89 Non-Lead vision FS ensible Enyineer h Date: 8-27-87 Non-L(ad Division Indep dent Reviewer l

n 2870040850 $ s cb Date: S'

2. /

Ff y t Ncn-Lead Divisdon ( '#anch'or Section Head) / / /, 'i, Date: Nuclear and Er. 2 ::onmental Section Head GT:ssh ssh4.55 M443 Attachment I Copy to: DISTRCCDE EE3E-2 J. W. Austin R. R. Hess M. J. Leahy H. D. Honan W. J. Brady H. W. Vollmer J. L. Clupp G. Termine DAC (NG-8) 4 i I

ATTACH MENT I ELECTRICAL ENGINEERING DIVISION e H3-1, 2301 Market Street 2870040850 May 9, 1985 Safety Evaluatien for Mcdificatien 1029E Peach Bettem APS Units 2 and 3 File: RES 5-3 (Med 1029E) Dcctyper 565

Subject:

Modification 1029E provides process and diagnostic instrumen-tation to meet 10CFR50 Appendix R-Safe Shutdown requirements at Peach Bottcm APS Units 2 and 3. 1

== Conclusion:== Although this modification does involve safety-related equipment and systems, no unreviewed safety questions are involved. Changes to the Technical Specifications are not required. This modification is a fire prctection modification. Discussion: Modification 1029E provides process and diagnostic instrumentation necessary 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 Units 2 and 3 and common areas except for the control room, cable spreading room and the remote shutdown panel area. Three shutdown methods (A, B, and C) have been defined to be used for safe shutdown; however, for each fire area only one method, either A, B, or C, will be used. The following diagnostic instrumentation indication for the systems associated with each respective shutdown method will be available in the control room: Method A 1) RCIC flow discharge 2) RHR Loop A flow discharge 3) HPSW Loop A flow discharge 4) ESW Pump B pressure discharge Method B 1) HPCI flow discharge 2) RRR Loop B flow discharge 3) EPSW Loop B flow discharge 4) ESW Pump A pressure discharge Method C 1) Core Spray flow discharge 2 )- RHR Loop A - Unit 2, Loep B - Unit 3 ficw discharge 3) HPSW Loop A - Unit 2, Loop B - Uni: 3 ficw discharge 4) ESW Pump B - Unit 2, Purp A - Unit 3 prc: ure discharge

2870040850 s I, , Safety Evaluation May 9, 1985 for Mod 1029E ] i p In addition, the following process instrumentation indicatien will be available for each fire area in the centrol. rect:

1) Reactor Water Level

2) Reactor Pressure

3) Drywell Pressure

4) Suppression Pool Water Level

5) Suppression Pool Temperature

6) Condensate Storage Tank Water Level.

Indication of the above instrument parameters are available at i present in the control room by existing indicators. The indications will be available regardless of the area of the plant in which the fire ec:ur=, with the exception of fire area Sn. In the event c f a fire in the turbine building (fire area 50) indication for the conden-sate storage tank (CST) water level and high pressure service water (HPSW) flow discharge wculd net be available in the control rcom because the transmitters and the associated instrument and power cables are located in the same fire area. In addition, indication for the emergency service water (ESW) discharge pressure would not be available since the instrument and power cables pass through fire area 50. To ensure indication for the CST water level and ESW discharge pressure in the control roem for fire area 50, two complete instrument loops will be installed as follows: 1) CST water level will be monitored by installing a transmi,tter on an existing 3/4" vent line located on piping from the CST. The transmitter will be wall mcunted locally inside the vacuum breaker reca. The additien of the transmitter will not compremise the ability to vent the system through this line. 2) ESW pre:ssure will be monitored by installing a transmitter on an existing 3/4" vent line from the ESW piping associated with the OBP57 pump. The transmitter will be mounted locally on an instrument stand inside the unit 2 cooling water equipment room on e'levation,116'. ESW pump OBP57 will be required for safe shutdown for both units 2 and 3, therefore, only one transmitter will be installed. The addition of the transmitter will not compromise the ability to vent the system through this line. Indication of HP5W/RHR differential pressure will be used as an alternate indication cf the HPSW system availability in the event of a fire in fire area 50. To ensure availability of the existing instrument loops during fires, some cables will require rerouting and/or encapsulation. In addition, new AC feeds will be added to some existing instrument loops. The new AC feeds will be ade'ed in parallel to the existing feeds through manual transfer switches.

2870040850 S'fety Evaluation May 9, 1985 7 a 3 for Mcd 1029E This mcdificatien effects safety-related systems and compenents. All piping and supports asscelated with the CST water level and ESW pressure discharge transmitters, frc= the existing vent line up te and including the second valve off the process line will be Q-listed. The remainder of the mechanical work will be non-Q-listed. The re cuting and encapsulation of cables will meet the requirements of 10CFP30 A;pendix R. In addition, rerouting of safeguard and Q-listed cables will meet the applicable electrical separation criteria and will be installed in accordance with the Peach Bottom APS QA Plan. i The addition of AC feeds to existing RER and HPSW ficw loops A and B, Core Spray flow loop B, ESW pressure loops A and B, and CST and torus water level instruments are necassary since the power cables asseciated with these instrument loops, due to physical constraints l and/or cost consideration, cannot be either rerouted or encapsulated. l The electrical functions of the existing instr _ments to be connected l in parallel with the new AC feeds do not perform any control function j and are not essential to safety. Therefore, the alternate AC feeds for these instruments can be frem any cn-site pcwer source available for i the mothed of shutdown for which the instruments are required. Manual transfer switches will be installed to transfer and isolate the alternative feeds from the normal AC feeds. Since the instrument loops are not safety-related, the manual transfer switches need not be i environmentally and/or seismically qualified. Ecwever, the transfer switches will be installed seismically to prevent the switches frem a falling dcwn in case of a seismic event and, hence, da.maging any-I safety-related equipment present inside the panels. The installation of the manual transfer switches and the remainder of the electrical work will be in accordance with Secticn 2.3 of the Peach Bettc= APS QA Plan. i Whenever this modification interfaces with an existing system, 3 the design of this modification is in accordance with all the criteria applicable to that system including, but not limited to, quality j assurance and environmental and seismic qualification. The bus loading of the additional' instrumentation loops has been analyzed and found to be acceptable. The following Technical Specifi-cations are applicable to this modification: 3.2, 3.5A, 3.5B, 3.5C, 3.5D, 3.7A, 3.9C, 3.14, 4. 2, 4. 5 A, 4. 5B, 4. 5C, 4. 50, 4. 7. A, 4. 9C, 4.14 and their associated bases. They have been reviewed and require no j changes as a result of this modification. This modification is being installed to meet the fire protection require =ents of 10CFR50 Appendix R. The following Updated FSAR Sections are applicable to this modification: 4.7, 4.8, 5. 2, 6. 4.1, 7.1. 6, 7. 4. 3. 2, 7. 4. 3. 4, 10. 7, and 10.9; figure 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 will be datalled in the UFSAR change control form. o

2870040850 . Safety Evaluation May 9,1985 s., for Mod 1029E 4 Based en the above discussions, it is concluded that: 1) The probability of.cccurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report is not ) increased. 2) The -possibility for an accident or malfunction of a different type than any evaluated previously in the safety j analysis report is not created. i 3) The margin of safety as defined in the basis for the j Technical Specifications is not reduced. ] Hence, this modification does not involve an unreviewed safety question. 10CFR50.59 Changes, Tests, and Experiments 1) No changes to the Technical Specifications are required. 2) An unreviewed safety question is not involved. 1 3) An application for amendment to the license is not required. 1 f { g e 6!7 4' Prepared by: b.L<.w' Date: (/ (Re$onsible E: gineer) Reviewed by: [Zf,... d Date: 6-9-86 (LeadDiv.gndepepntReviewer) $~ft.e/W Date: ~ Lead Division ranc. or Sec+ on Head) '/ I Dater /[ [f6 Non-Lead Divisio g esponsible Engineer / l ~ D Date: 6-lfo- %G Non-Lead' Division (Independent]teviewer i y&sl Date: 3 Wh[ Non-Lead Division (Brali h or Section Head) fNW ).usYul $ 2.? k.5" Date: Nucledr and Envir ental Se ion IIead /' / GT/da::/4260501 l Copy to: DISTRCODE EESE-2 l l J. W. Austin j T. E. Shannon J. W. Cornell J. L. Clupp G. Termine

.c

• a -

FEB 2 5 ECD ~ EtECTaICAt tscInzEaIna DIvISIcn N3-1, 2301 MARKET STREET 5. j / Safety Evaluation fer Mod 1351D Peach Bottom Atomic Power Station - Unit 2 File Safety 2 (Fire Protection) DOCTYPE 565 Rev. O I.

SUBJECT:

Mod 1351D establishes an Alternative Control Station (ACS) for the OAP57 Emergency Service Water (ESW) Pump at its 4kV circuit breaker compartment, 20A1603. Alternative control of the pump is necessary.to supply cooling water to the diesel generators for a fire in Fire Area 25, which includes the Main. Control Room, the Cable Spreading Room and the Emergency Shutdown Panel Area. In addition, circuit changes for both OAP57 and OBP57 ESW pumps are necessary to prevent spurious operation of the pumps for fires in fire areas outside Fire Area 25. This modification is necessary to meet the requirements of Appendix R to 10CFR Part 50. II. CONCLUSION: This modification affects safety-related equipment. This modification does not involve an unreviewed safety question. Technical Specifications changes are not required, therefore neither a license amendment nor prior NRC approval is required. Alternative Shutdown modifications are described in the PBAPS Fire Protection Program which will be incorporated into the UFSAR. This modification maintains the capability to safely shut down the plant in the event of a fire. A significant hazards consideration is not involved. Changes are required to the UFSAR P & ID's. III. DISCUSSION: This work is being done to bring Peach Bottom into compliance with the requirements of Appendix R to lOCF R50. This modification provides an alternative control station (ACS) for the ESW system to provide cooling water to the diesel generators for safe shutdown, method D (Alternative Shutdown). The ESW ACS is located at the 20A1603 4kV emergency switchgear compartment. The ACS allows the A ESW pump to be manually controlled from the breaker cubicle. A three position transfer / isolation switch, installed on the compartment door isolates all control circuits subject to fire damace and transfars bree %r control from the Main Control Room to the i.cb. The safety,relat m transfer / isolation switches have three modes: Normal, Test, and Emergency. Normal control cables and operational logic are isolated only when the switch is in the Emergency mode. The Test position enables the alternative control switches (breaker test switch) and the alternative indicators while maintaining main control room control, indication and operational logic. The existing breaker test switch on the cubicle door is enabled to perform the ESW pump bcaaker alternative control function for the A ESW pump when the three-position i transfer / isolation switch is placed in the Test or Emergency positions.

~I~ d6 OaGl) s i Red and green breaker status indicating lights and motor current indication are provided at the switchgear cubicle for. alternative shutdown, and the 150/151 and 150G protective relays are maintained for the 20A1603 breaker for alternative shutdown. 'q The transfer / isolation. switch f'or the pump motor ammeter is a two-position switch (Normal and Emergency). The transfer / isolation switches are. keylocked and Test and Emergency Switch positions are individually annunciated in the Main. Control Room. Safety-related equipment criteria applies to i the new transfer / isolation switches as well as to new cable routings to these switches that are part of normal operating circuits and systems. Since it is not necessary to consider a LOCA 6 or seismic event coincident with a fire and the coincident loss of offsite power in any plant area, the alternative controls, { instrumentation, indication, and circuitry are not required to be safety-related, provided that these new installations do not adversely affect any Q-listed component for a design basis event. However, this is a fire protection modification, and Section 2.3 j of the Peach Bottom QA Plan shall be followed. A condition exists for the OAP57 and OBP57 ESW pumps whereby a spurious close signal to a pump breaker concurrent with no voltage on the emergency bus could result in the inability to close the breaker due to an internal anti-pump feature in the 4kV breaker. This modification prevents a close signal to the i breakers if there is no voltage on the emergency buses. These persnisolve interlocks pertain to all modes of breaker control - Normal, Test and Emaigcrey. They are only bypassed to allow I breaker control from the test switch whcc the breaker is disconnected from the bus. f i In addition to the above changes, control logic changes and fusing ] for both A and B ESW pumps are necessary to prevent spurious J operations that could result from fires in various fire areas. In Fire Areas 38, 39, 43, 44, 45, and 46, failure of control cables l ZB2A1603R, ZB2A1603N, or cables to any of the four diesel i generator low speed relays could disable the "A" ESW pump. In Fire Areas 37, 43, 44, 45, 46, and 50, failure of control cables ZC2A1706R, ZC2A1706N or cables to any of the four diesel generator low speed relays could disable the "B" ESW pump. i ) This modification corrects these problems as follows: l 1 1) An auxiliary control circun is provided by separately fusing j from the existing >. v..'.t ol circuit the automatic logic that l starts an ESW pu up from either the low speed relays, the MCA relay or the automatic backup pump start logic. The J fuses, sized at 10 amps, will blow before the 35 amp control power fuses for the pump breaker. This will isolate fire induced f aults and still allow the ESW pump to be manually operated without losing indication or relay protection, t l l \\

c y - og \\ rY, 2) The backup start capability for each of the ESW. pumps is maintained; however, control.. cables.and auxiliary. relays. used to provide this capability are reconfigure to resolve cable routing problems for an Appendix R firer Presently, if the primary pump motor (e.g., A) reejives a start signal but fails to achieve discharge pressure within 25 seconds, the backup (B) pump motor starts automatically. The ZC2A1706R cable routed between the A and B pump motor switchgear to provide this automatic backup start logic is removed from the control circuit. Similarly for the B pump motor, as pri-mary and the A pump motor as backup, the ZC2A1603R cable is removed. j The ZC2A1706N cable is relocated from the B pump pressure switch to the A pump pressure switch. The ZC2A1603N cable is relocated from the A pump pressure switch to the B pump l pressure switch. The effect of these relocations is to l provide the automatic backup start capability while i eliminating the ZC2A1706R and ZB2A1603R interconnecting cables i between the A and B ESW pump motor switchgear compartments. Consequently, the auxiliary time delay relays installed in the switchgear compartments will start the pump motor powered ^ from that compartment rather than providing the start signal to the other ESW pump motor breaker. With this modification, the 163-1603 relay which is located in the A pump breaker cubicle starts the A pump. However the signal that energizes this relay comes from the B pump backup start logic. Similarly, the 163-1706 relay, located in the B pump breaker cubi-a cle will start the B pump, and the signal to energize this relay l comes from the A pump backup start logic. Channel separation for the A pump (ZB channel) and B pump (ZC ) channel) is maintained in the emergency shutdown panel (AC43 and j BC43) by installing a metal barrier enclosing the 152-1603/CSR j emergency shutdown control switch for the B pump and the i 152-1703/CSR emergency shutdown control switch for the A pump. j To maintain electrical channel separation in the emergency 1 shutdown panel, control wiring between the AC43 and BC43 panel compartments will be routed for the A and B pump controls in separate j metal conduit. i. The pump automatic operational logie is fusco ;cparately by the 10 6 amp fuses described previously in 1 above. No single failure in j the AC43 or BC43 compartments could disable the ESW system because any failure in either compartment would be limited to blowing the 10 amp control fuse of the ESW pump in the alternate control l j circuit compartment. In this case, the alternate ESW pump could 1 still be manually controlled from its control switch. l ThjNmodification results in no additional load requirements on ) the plant electrical system. ,i i I 'l ) I

'1 l *, -, I i ) <, i [. ~ i l Since this modification does not affect any radwaste system, i the criteria contained in I. E. Circular 80-18 is not applicable. f I The plant as described in the CFSAR is unchanged by this modification when all transfer / isolation switches are in the Normal and Test modes. UFSAR P&ID's will be revised to reflect the new transfer / isolation switches. Section 10.9, Emergency Servica Water System, has been reviewed in making this determination. For the alternative shutdown mode, the effects on the plant systems are described in the Peach Bottom Atomic Power Station Fire Protection Program (F.P.P.). 'IV. 10CFR50.59 CHANGES, TESTS, AND EXPERIMENTS: The following conclusions can be made regarding this modification: 1. Technical Specification Sections 3.9C and 4.9C and the bases for these sections have been reviewed. Technical Specification changes are not required because this modification does not change the Emergency Service Water System as described in the Technical Specifications when the transfer / isolation switches are in the " Test" or " Normal" modes. Changes to the Technical Specifications are also not required when the transfer / isolation switch is in the alternative position, since even though this would cause a departure from the Technical Specifications, 10CFR50.54 (x) q allows said departure in an emergency. Since an Appendix R I fire would be considered an emergency, 10CFR50.54 (x) allows the use of the transfer / isolation switch and departure from i the Technical Specifications. i I 2. An unreviewed safety question is not involved because of the l following reasons: l a) The probability of occurrence or the consequences of an l accident or malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased. The safety objective of the ESW system is to provide a reliable supply of cooling water to diesel-engines and selected equipment coolers during a loss of offsite power. Appendix R to 10CFR50 excludes ) the requirements to postulate the occurrence of a LOCA I or seismic event coincident with an Appendix R fire. Therefore, defeating the autcmatic initiation of the A ESW pump for a fire in Fire Area 25 does not pose an un-l reviewed safety question because the time available to i manually operate the A pump is sufficient to establish { cooling water to the diesel generators for shutdown us- { ing Alternative Shutdown method D. 1 i i l

s f b) The possibility for an accident or malfunction of a I different type than any previously. evaluated in the safety analysis report is not created. This modification does not change ESW pump operations as described in the UFSAR when all transfer / isolation switches are in the " Normal" or " Test" modes. The " Emergency" and " Test" switch positions are individually alarmed in the main control room, c) The margin of safety as defined in the basis for any Technical Specification is not reduced. Since the safety function of the ESW system is not affected by adding safety-related transfer / isolation switches and all automatic start and trip features of the ESW pumps are maintained when the transfer switches are in the " Normal" and " Test" position, this modification does not reduce the margin of safety. This modification ensures control of the A ESW pump for a fire in the Main Control Room, the Cable Spreading Room, or the Emergency Shutdown Panel areas for an Appendix R fire. l V. 10CFR50.92 SIGNIFICANT HAZARDS DETERMINATION: This determination is not applicable because a license amendment l is not required.

r * ~ l L. l '.; a l i I j a g VI. APPROVALS: a Prepared By: kb Date /2* 3/* 88 y (Responsi le Bhgineer) 1 Reviewed By: N5 Date:}Id!~M (Le d Division Independent Reviewer) \\..k /** c -c $ d Date : Il-3 / - E{ ad Division (B nch Head) j h '-J Date: 1 23f67 Non-Lead Division Responsible Engineer //Js).R WAI Date: I "5 ) Non-Leadpivis n Independent Reviewer Dater /*2/* 07 w Non-Lead Division (Branch Head or Section Head) f h/ 30 5M Nuclear & Environmental Section Head _T, tti Date: 4 l l I l JJH/la lal2186m300 Copy to: DISTRCODE EESE-1 DAC (NG-8) J. J. McCawley M. Reitmeyer l' l l l l 1 l l I l l l C l l l l

t FEB 2 5 ECT \\ 3;. h. [ q v ELECTRICAL ENGINEERING DIVISION { . \\. N3-1, 2301 MARKET STREET l a Safety Evaluation for. Mod 1352A and 1353A f Peach Bottom Atomic Power Station - Units 2 and 3 Revision.3 - Incorporates Unit 2 Design l File: SAFETY 2 (Fire Protection) Doctype 565 I

SUBJECT:

i j I This safety evaluation covers the design and installation of an alternative control station (ACS) for the HPCI system to meet the requirements of Appendix R to 10CFR50. This safety evaluation applies j to both Unit 2 and Unit 3. I II CONCLUSION: This modification involves rerouting safety-related' circuits to an ACS, where a safety-related transfer / isolation switch will transfer the control location of safety-related equipment from its normal control panel to an ACS and isolate safety-related system circuits that could adversely affect safe shutdown due to an Appendix R fire. An unreviewed safety question is not created. Technical Specification l changes are not required, therefore a license amendment or prior NRC approval is not required. This modification maintains the capability to safely shutdown the plant in the event of a fire. A significant i hazards consideration is not involved. UFSAR changes are required. III DISCUSSION: This modification provides an alternative control station (ACS) for the HPCI system to supply water to maintain reactor vessel water level and to provide a mechanism for removing energy from the reactor vessel for alternative shutdown. The work is being done to bring Peach Bottom into compliance with requirements of Appendix R to 10CFR50. The ACS will be established outside of the three areas of concern j Main Control Room, Cable Spreading Room, and Emergency Shutdown Panel area. HPCI circuits routed in any of these three areas are subject to fire damage which could adversely affect the safe shutdown and will be f isolated at the HPCI ACS for a fire in these areas. A HPCI ACS is { located in each unit's F'Mrculaeden M-G Set Room on Elevation 135' of tb Radwaste Bulliiini.' 3 Alternative control capability and indication is provided for the motor operated valves listed below: i \\

'{. s g MOV' Description 2/3-23-014 Steam to turbine 2/3-23-015 Steam supply isolation (inboard) 2/3-23-016 Steam supply isolation (outboard) 2/3-23-017 Pump suction from CST 2/3-23-019 Pump discharge (from 020 valve) 2/3-23-020 Pump discharge 2/3-23-021 Test bypass to CST 2/3-23-024 Shutoff to CST 2/3-23-025 Minimum flow bypass to torus 2/3-23-031 Flushline shutoff to torus 2/3-23-057 Pump suction from torus (from 058 valve) 2/3-23-058 Pump suction from torus 2/3-02-29A Feedwater Stop Valve 4245/5245 Turbine exhaust Note that as identified by Note 2 on P&ID M-365, Rev. 25, MO-4244A and MO-5244A are electrically identified as MO-4245 and MO-5245. The HPCI ACS is capable of isolating necessary HPCI circuits subject to fire damage and transferring control of these components from the Main. Control Room to the HPCI ACS. This mod provides the HPCI .ACS panel, isolation and transfer capabilities for HPCI motor-operated valves which are required to maintain position or change position for alternative shutdown. The modification also provides isolation and transfer capabilities for necessary auxiliary HPCI equipment, minimal alternative logic for necessary equipment interlocks, and isolation capabilities for other HPCI circuits that'are subject to fire damage. Transfer,and isolation functions are provided by safety-related trans-fer/ isolation switches, one for each component requiring alternative control. The controls and indication at the HPCI ACS, like the existing circuitry and equipment, are arranged to allow for remote-manual startup, operation, and shutdown of HPCI. Logic to support required j automatic operations for the minimum flow bypass valve, the auxiliary oil pump, the gland seal condenser blower, the gland seal condenser condensate pump, and the turbine stop and control valves are reestab-lished at the HPCI ACS for alternative shutdown. Auxiliary relays to support required component operations are testable via test lamps. Other automatic operations of the HPCI system, including PCIS func-nions, are not required for alternative shutdown; consequently, such logic is not re-established at the HPCI ACS. The HPCI ACS also ec 1. w a s ..c i swicches for three safety relief valves (SRV's) and two backup solenoid valves which supply l nitrogen to the SRV'*r, process parameter, instrumentation, diagnostic {. instrumentation for the HPC1, RHR, HPSW and ESW systems, and trans-fer/ isolation and control switches for RHR and HPSW valves needed to establish torus cooling. These alternative shutdown capabilities are provided by Mods 1352(3)G, 1352(3)H, 135 2 ( 3) B, 1352(3)C and 1352(3)D respectively. A separate Safety Evaluation is written for each of these modifications. i

r.. i , ~ 2-4 I s 5 A transfer / isolation switch and a. turbine trip pushbutton are provided to tr,1p the RCIC turbine should it be. running during an alternative shutdown,. Safety-relatedeghipmentcriteriaisappliedtothenewtransfer/ isolation switches as well as to new cable routings to these switches that are part of normal operating circuits and systems. Since it is not necessary to consider another event or accident coincident with a fire in any plant area, the alternative controls, instrumentation, indication,_ and circuitry are not required. to.be safety-related,.- provided that these new installations do not adversely affect any Q-listed component for a design basis event. However, this is a fire protection modification and Section 2. 3 of the Peach Bottom QA Plan applies. The safety-related transfer / isolation switches are three position switches: one for normal operations, one for alternative operation, and - one for periodic testing. Normal interlocks and operational logic that are subject to fire damage are only bypassed when the switch is in j the alternative position. The test position enables the new controls and indication without bypassing main control room control or indica-l tion, or operational logic. Access to the ACS is via a locked roll-up door covering the face of the panel. Test and alternative transfer / isolation switch positions as well as an open door condition are annunicated in the Main Plant Control Room. Single failure and common mode failure design criteria have been incorporated into the design of this modification. The load of the HPCI ACS is approximately 4 amps. The B and D emergency batteries have sufficient capacity to accept this additional load and still support their DC loads during a LOCA. UFSAR P and ID's will be changed to reflect the new transfer / isolation switches and alternative controls. Sections 6, 7.3, 7.4 and 4. 7 were - reviewed to make this determination. This modification is described in the Peach Bottom Atomic Power Station Fire Protection Program (FPP) which will be incorporated into the UFSAR. This modification does not involve radwaste systems, therefore, the guidance provided in IE Circular 30-18 is not applicable. IV 10CFR50.59 Changes, Tests, and Experiments 1 ) The following conclusions can be made regarding this niodification: 1. Technical Specification Sections 2.1. I, J > n,

3. 5,C,

3.5.D, 4.5.C, 4.5.D and the bases for these sections ave been reviewed. Technical Specification changes are not required because this modification does not change the design or performance characteristic of the HFCI or RCIC systems when the transfer / isolation switches are in the " Normal" or " Test" modes. t

'l ,0 _4 l n ..i: 1 i1 g - ' 9-The use of - this HPCI ACS panel (i.e. when the transfer / isolation switches are 'in the alternative. mode); to respond to' an". Appendix R fire is/ required to" ensure safe; -) R shutdown. The Appendix R fire will. create a need for temporary departure from the Technical L Specification s in order.-to mitigate the consequences of the fire. 10CFR50. 54 (x) allows departure from' the Technical Specification in an emergency such as an Appendix R fire.- q 2. An unreviewed safety question is not involved because of the l following reasons: -- j a) The probability of occurrence or the. consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report is -{ not increased. The safety objective of HPCI is to provide high pressure coolant makeup to the reactor following loss of feedwater or a small LOCA. The safety objective of PCIS is to protect, in a timely ' manner, j against ~ the onset and consequences of accidents ' involving the gross release of radioactive material from j l the fuel and nuclear system process barrier. Appendix R l to 10CFR50 excludes the requirements to postulate the I occurrence of a LOCA or seismic event coincident with a J fire and a concurrent loss of offsite power. Therefore, j defeating the automatic initiation of the HPCI system and PCIS interface functions during a fire scenario does not pose an unreviewed safety question because the time available for manual operation of HPCI is sufficient to keep. the core covered and the design for alternative ] shutdown does not require : postulating a coincident occurrence "which would result in the gross release of radioactive material beyond the nuclear system process barrier. b) The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created. This modification does not change the operation of the RPCI and RCIC systems as described in the UFSAR when all of j the transfer / isolation switches are in the " Normal" or l " Test" position. Test and Emergency switch positions are annunciated in the Main Control Room to alert the ) operator of these abnonnal conditions so that the system can be restored to normal if there is nn fire. l c) The margin of safety as defined in the basis for any ) Technical Specification - is not reduced. Since the l safety function of the HPCI and RCIC systems are not I affected by the rerouting of circuits and the addition of a safety-related transfer / isolation switches, and the automatic initiation and trip features of the system are not affected when the transfer switches are in the 4 I

1 ' o: s. .=

g

" Normal" or " Test"; positions, this modification does not ~ 'i . reduce. safety.or raise'an unreviewed safety question. . The ; u se of this HPCI ACS. panel - (1.e.. when the ), . transfer / isolation switches are in the alternative mode). l to respond to an Appendix. R fire is ' required to ensure safe shutdown, The Appendix R fire will create a need { -for temporary departure from the Technical Specifications in order to mitigate the consequences of the ' fire. 10CFR50.54 (x) - allows departure from the Technical Specifications in.an emergency such as an- . Appendix R fire.. ._V 10CFR50.92 Significant Hazards Determination 1 This determination is not applicable because a license amendment is not required. i l e l i k 3 'l 1 l i i l l l l l 1 i k i i

C / ;.:.,

• l, 7 ' -

V VI Approvals i Prepared by: 9 c., Oates / ~ 1 d I ( Ksqfonsible Engineer) Reviewed byt 3, ' 'I Date: _//.2/I[ .(Lead Division Independent Reviewer) ? Date s' ifs *f97' ^ ' ~ ' ~ " - ~ ~ ~ ~ Lead Divisio (Braneg Head) Nl1 (k A - -[5 E Date: \\ -N -Fl ' No -Lea,'Tivisio ' espons le \\ Engineer h Date l-[I-[7 Non-Lead Division [1 dependent Reviewer I!28/8 7 Date: Non-Lead Division (B nch Head or Section Head) h A Jj, Dates U Nucl' ear & 1ronmen'ta ection Head DMS/la la6684m145 Copy to Distreode EESE-1 J. J. McCawley DAC (NG-8) ) M. Reitmeyer l i i I i l

i O 1 ELECTRICAL ENGINEERING DIVISION N3-1, 2301 MARKET STREET Rev. 1 July 13, 1987 h Safety Evaluation for Mod #1950 Peach 300 tem APS - Units 2 0 3 DOCTYPE 565 I

SUBJECT:

Th'i s modification will relocate the control cables for three Unit 2 Safety Relief Valves (SRV) RV2-02-071E,H&J, and will provide a backup nitrogen supply to the Unit 2 and to the Unit 3 'B' instrument nitrogen headers. These headers supply SRV's j RV2-02-071 E,H&J and RV3-02-071E, H&J re spectively. This modification is necessary to fulfill the requirements of Section III.G of Appendix R to 10CFR, Part 50 for two Fire Areas, 6S and 13S. The mechanical portion of this modification incorporates Mod 1950A. 4 i II CONCLUSION: This modification involves relocating cables connecting safety related equipment and providing a backup nitrogen supply to one Unit 2 and one Unit 3 instrument nitrogen header. The portion of the instrument nitrogen system being modified is safety related. However, the safety related function of the affected equipment I will not be changed. This modification does not involve an unreviewed safety question. A change to the Technical Specifica-1 l tions is recommended but is not required (see Section V below). l This modification maintains the capability to safely shut down the plant in the event of a fire. Neither an amendment to the operat-ing license nor prior NRC approval of this modification is required. A significant hazard consideration is not involved. Sections 4.4 and 10.17 of the PBAPS UFSAR must be changed to l include the description and function of the bac,kup nitrogen supply l systems. The instrument nitrogen P&ID must also be revised. III DISCUSSION:- n The Safety Evaluation for this edification has been revised to 1) incorporate design changes for the mechanical portion of this modification (Mod 1950A) and 2) to expand the significant hazards determination section. No design changes have been made to the electrica.1 portions of this modification. { This modification is required to bring Peach Bottom into compliance with the requirements of Appendix R to NRC Regulation i f 10CFR, Part 50. Appendix R requires that, "One train of equipment l necessary to achieve hot shutdown from either the control room or emergency control station (s) must be maintained free of fire l l

7, l ^ l .i rv. damage by a single fire, including an exposure fire." An exposure fire., or' an Appendix R fire, is assumed to destroy or fail all equipme'ht and cable in a given fire area. At present, the control cables for all eleven Unit 2 SRV's are rautad thr: ugh a cceren fire area and subject to damage frc a single fire. Failure of these cables could prevent reactor pressure vessel depressurization which is necessary,to safely shut down. This i situation does not exist on Unit 3 due to an earlier Safe Shutdown modification. In addition, a single fire can cause the failure of the pneumatic supply for the Unit 2 or Unit 3 SRV's. Modification-1950 provides the required separation by relocating l the centrol cables for three Unit 2 SRV's to a different fire ares j and by installing a backup instrument nitrogen supply for the Unit ] 2 and Unit 3 'B' drywell headers. The new backup nitrogen system provides the capacity to operate the three SRV's for 72 hours following an Appendix R fire in Fire Areas 6S (' Unit 2) or 13S j (Unit 3). g. db The electrical portion of this modification relocates the control cables for threo Unit 2 SRV's to provide the physical separation required by Appendix R and to provide electrical separation. The safety function of the SRV's is not affected by the relocation of cables because the relocated cables are installed in accordance with approved installation specifications which implement requirements for physical arrangement and electrical separation (Drawings E-1315 & E-1317). Relocating the control cables for the three SRV's shortens the cable length, and hence reduces voltage drop. Electrical separation will be provided by changing the safeguard channel designation of the relocated cables from "ZA" to "ZB". The portion of the SRV control circuitry that is not affected by this modification will remain "ZA". This predesignation will be accomplished in panel 20C32, ECCS-Division I relay cabinet, by installing interposing relays and separately fusing the circuits. The interposing relays provide coil-to-contact separation. The safety function of the SRV's is not affected by the addition of the fuses or relays. The mechanical portion of this mod consists of the following: 1) Installation of a tee to tap into the nitrogen supply for the Safety Grade Instrument Gas (SGIG) system (Mod 1316). 2) Installation of 3/4" Stainlest. Steel piping and 1" stainless ]h steel piping (with appropriate valves and fittings as necessary) in both units to connect the nitrogen supply to the existing Instrument Nitrogen 'B' headers. The backup nitrogen system will be installed as a Q-listed seismic j system. The Q boundary of the system will extend from the tap O___ __ _

+.. i. Q. into-the 'B' header up to but not including the pressure reducing j valve.. The Q boundary will extend frem the other side of the pressure. geducing valve back to the CAD tank. The intent of the NRC in requiring modifications to address Appendix R concerns was not to require' installation of Q equipment in systems that were _L_ originally non-Q. The Q beundaries defined above accurately

p:22:n: thic inten: due t the fat; tha: the 0.10 system is 1 and the containment isolation beundary part of the instrur.ent nitregen system is Q.

The backup nitrogen supply system will be tied into the 'B' header of the existing instrument nitrogen systems. This tie-in point will be downstream of the check valve which is immediately downstream of valve No. AO-2 ( 3 ) 969B. The tie-in will be outside of containment. l The backup nitrogen supply system for each unit will be tied int the SGIG system. The source of nitrogen for this system shall not depend upon the availability of any electrical or air-operated j equipment of the SGIG system or CAD system. An evaluation has determined that the tie-in of the backup nitrogen supply to the SGIG system will have no detrimental ef fects on the designed 4 function of the SGIG system. This is due to the fact that'the 4D backup nitrogen supply system will only be put into service g. following a fire in Fire Areas 6S (Unit 2) and 135 (Unit 3). An .l Appendix R fire is not postulated to occur immediately prior to, af ter or concurrent with a LOCA. Therefore, since the CAD system would not be in operation during.the use of the backup instrument i nitrogen system its function would not be affected. Although the SGIG system _ will operate upon loss of instrument air, it is essentially a stagnant system requiring minimal flow and l therefore its function would not be affected. The SGIG system will tie into the vapor space of the 6000 gallon j liquid nitrogen tank which supplies the CAD system. The liquid j nitrogen tank has the safety function of providing containment ( atmosphere dilution in the event of a LOCA. The total volume of l gas required for this dilution for the first seven days after a LOCA is 200,000 SCF. The tank is required to maintain a 3000 gallon inventory to achieve the seven day dilution criteria. The backun, nitrogen supply system will be used only in the event of a fire in fire areas 6S (Unit 2) or 13S (Unit 3) and will not deplete the tank below the seven day dilution criteria for the CAD l system. As mentioned above, it is assumed that the CAD system is not required af ter an Appendix R fire and it is a fact that the SGIG system is a low flow system. Furthermore, replenishment of nitrogen supply can be made via an outside fill connection from a nitrogen truck. At the time that the backup nitrogen supply system is in use the i flow path will tie in between PCV-6529 and PCV-6528 after the pressure building coil. The nitrogen gas will then pass through a l pressure reducing station then into secondary containment. A relief valve is provided to prevent overpre:suri:2ti:n of the [

j V instrument nitrogen system and connected equipment due to a failure of the pressure reducing valve. This piping is then connected to the instrument nitrogen 'B' header via a locked closed globe valve, a check valve, and a normally open globe valve. The check valve and the locked closed globe valve form part of the primary containment isolatic'n boundary for penetration N-52F. The containment isolation valves for Unit 2 are located in the CAD tank room. The containment isolation valves for Unit 3 ] will be located in the non-combustibles zone near the TIP room in Unit 3 reactor building. Appropriate test taps will be included so that a Local Leak Rate Test (LLRT) may be performed. In the event of an Appendix R fire (in fire areas 65 or 13S), unlocking and opening the outboard containment isolation valve to initiate operation of the backup instrument nitrogen system has been reviewed and found to be acceptable. This is justified by the following: 1) An Appendix R fire is considered a discrete event (i.e., independent c f a LOC A), 2) the isolation valve is administratively controlled such that it will only be opened after an Appendix R fire and closed when other necessary systems have been restored and 3) the requirements of 10CFR50.54(x) are g satisfied. O 8 The system, as designed, complies with 10CFR5U, Appendix A, Criterion 56 primary containment isolation requirements, as elaborated upon in Reg. Guide 1.141 and SRP 6.2.4. In addition, the backup nitrogen supply system design allows for proper implementation of 10CFR50, Appendix J requirements for leak testing of systems. The ILRT program for penetrations N-52F (on Units 2 & 3) must be changed to include these valves in the program. ] l s capability to shut down the plant in the event of a fire is The j not reduced by this modification. This determination is based on the findings of the attached Fire Protection Review Checklist. i This modification does not change the function of the affected systems as described in Sections 6.4.2, 5.2.3.9 and 7.4.3.3.3 of ld the PBAPS UFSAR. Changes to PBAPS UFSAR Sections 4.4 and 10.17 must be made as a result of this mod. These changes will be to j include the description and function of the backup nitrogen supply j system. The cable and raceway separation requirements are presented in Section 7.1.6 of the UFSAR. This modification is consistent with those requirements. An UFCCF has been prepared to implement the changes to Sections 10.17 and 4.4. The instrument nitrogen P&ID must also be revised. The plant electrical load will not be increased by this modification. The guidance in IE Circular 60-18 is not applicable because no radwaste r ;tems are involved.

V IV 10CFR50.59 CHANGES, TESTS AND EXPERIMENTS: An unreviewed safety question is not created since: The probability of the occurrence or the consequences of l a. f an accident or malfunction of equipment important to safety previcusly evaluated in the safety analysis report is not increased. Circuit relocation does not change the function of the affected circuits. The backup nitrogen system complies with the design criteria of the existing instrument nitrogen, CAD and SGIG g systems. The safety-related function of the systems 4.L1 that are being modified are not changed from the description provided in the PBAPS UFSAR. b. The possibility of ' an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created. The operation of the plant as described in the PBAPS UFSAR will not be changed by this modification since the design of the backup nitrogen system complies with all applicable safety-related criteria and the adequacy of the power g supply characteristics to safe shutdown equipment has been verified for the cables affected by this 8 modification. c. The margin of safety as defined in the basis of any Technical Specification is not reduced. Sections 3.5.E, 3.6.D, 3.7.A, 3.7.C, 3.7.D, 4.5.E, 4.6.D, 4.7.A, 4.7.C and 4.7.D, and their respective bases, of the PBAPS Technical Specifications were reviewed in making this determination. This modification will increase the reliability and operability of the SRV's. V TECHNICAL SPECIFICATIONS: A change to the Technical Specifications is not required. The sections and bases that were reviewed in making this determination are listed in the answer to question c) in' ' the 10CTR50.59 determination. However, we recommend that Table 3.7.4 entitled " Primary Containment Testable Isolation Valves" (which is included in the Technical Specifications in an "information only" capacity) be updated to include the isolation valves in the backup nitrogen supply system. VI 10CFR50.92 SIGNIFICANT HAZARDS DETERMINATION: Although a Technical Specification change is recommended, this modification does not involve a significant hazards consideration. In support of this determination, example (1) is cited from the Federal Register (51FR, pgs. 7750-7751) dated March 6, 1986 which states in part: "...a proposed amendment to an operating license...will likely be found to involve no significant hazards

l.- -i i consideration, if operation of the facility in accordance with the f proposed amendment involves only...a purely administrative change l to technical specifications...". This modification involves a change to the technical specifications (see Section V of this l Safety Evaluation) which is accurately represented by the above 3 example. I In addition, the operation of the plant once this modification is l complete will not: I ' 1) Involve a significant increase in the probability or l consequences of an accident previously evaluated. In the event the backup nitrogen system were to leak and I depressurize the instrument nitrogen header, it has been ) demonstrated that this pressure loss condition would not l increase the probability or consequences of any accident previously evaluated since all pneumatic users of instrument nitrogen have been previously demonstrated to fail in the safe pcsition. A failure of this backup nitrogen system will not affect the safety-related ADS pneumatic supply since the two systems are separated by redundant check valves. The 3 design of the backup instrument nitrogen system includes j g i provisions to preclude possible failures of this system which I may effect the CAD or SGIG systems. The system is designed to be seismic and Q and includes locked closed valves such that it can only be put into service by specific operator action. In addition, the backup instrument nitrogen supply system has .j been designed (in accordance with 10CFR50, Appendix A, 1 Criterion 56) to provide for containment isolation in the event of a LOCA. Furthermore, the backup instrument nitrogen supply system's design allows for the proper implementation of 10CFR50, Appendix J requirements for leak testing of i I containment penetrations. l 2) Create the possibility of a new or different kind of accident from any accident previously evaluated. The justification { for this conclusion is that the backup nitrogen supply as designed does not affect the function of the existing nitrogen system. A failure of this backup nitrogen system will not affect the safety-related ADS pneumatic supply since the two systems are separated by redundant check valves. The j design of the backup instrument nitrogen system includes provisions to preclude possible failures of this system which j may effect the CAD or SGIG systems. The system is designed to be seismic and Q and includes locked closed valves such that it can only be put into service by specific operator action.

I 3) Involve : a : significant decrease in a margin of ' safety. The justification for this conclusion is that the backup nitrogen ~ supply system is '. designed. as a Q-listed, safety-related.- system whose function is to supply.' r.itrogen to SRV's in containment following a - fire which ~ disables the existing -instrument nitrogen / instrument air systems. Hence, this system will improve the margin of safety in the plant design. i 9 i I i 4. i O-e i 9 I

), p. ] q .I l l APPROVALS: l i .j' ..f ~ ^ ./ Prepared By: ' :' 9. ' #1. Date T'. i i ~ C-I) Reviewed By: Date U l l l Date: I Lead Division (Bra KHeadpr.SectionHead) I d f l/$l/h m $M Date: Nori-Lead DivisJr6n Responsible Engineer e h M Dates j Non-Lead Division Independent Reviewer I q A Y W Date: 7WO Non-Lead Division (Branch Head or Section Head) 0 L

page, Nuclear and Environment Section Head MWL/la la121286m235 Copy to:

DISTRCODE EESE-1 DAC (NG-1) /

) nECTRICAt ENcINEER2No D m SIcN 287004860'0 i c. N3-1, 2301 MARKET STREET November 18, 1986 y-Revision 3: March 20, 1987 l l Revision 4: April 8, 1987 j Revision 5: June 30, 1987 l 1 Safety Evaluation for Mod #2078 Revision 5 I Peach Bottom APS - Units 2 and 3 DOCTYPE 565

SUBJECT:

{ I This modification will provide 3-hour fire rated separation for safe shutdown cables and equipment as required by Appendix R to 10CFR, Part 50. The cables being protected were identified by the Appendix R Task Force. The separation will be accomplished by 1) encapsulating the raceways containing the specified safe shutdown cables within 3-hour rated fire barriers or by 2) relocating the cables out of the areas of concern. Cable pull boxes and various supports will also be l encapsulated as part of this modification. In addition, the embedded l raceways that are open to the manholes being encapsulated can act as a conduit for the products of combustion (smoke and hot gas) generated by certain interior fires and therefore will be sealed with I smoke and hot gas barriers at the manholes. Revision 5 of this safety evaluation adds an inspect' ion of the encapsulation installed prior to 1987. This increase in scope excludes inspection of the encapsulation installed under Mod 2078 and includes only those encapsulations which were installed under Mods 1029A and 1351C. These encapsulation installations will be inspected for compliance with acceptance criteria for encapsulation installations. The inspections shall be limited to those aspects of the installations which are observable without disassembly. These inspections may result in some enhancements or repair work to meet the acceptance criteria. CONCLUSION This modification involves encapsulating raceways that contain cables connected to safety-related equipment, rerouting such cables and inspecting the encapsulation installed prior to 1987. These inspections may result in some enhancements or repair. In all caces, the safety-related function of the affected equipment will not be changed. This modification does not involve an unreviewed safety question. A change to the Technical specifications ir not required. This modification is required to comply with the requirements of Appendix R to 10CFR, Part 50. Neither an amendment to the operating licens, nor paoa Nm; approval of this modification is required. A significant hazard consideration is not involved. ] DISCUSSION: This modification is required to bring Peach Bottom into compliance with criteria outlined in Appendix R to NRC regulation 10CFR50. Appendix R establishes separation requirements for equipment t and cables required for safe shutdown of nuclear power plants in the event of a fire. An Appendix R fire is -assumed to destroy all equipment and cable in a given fire area. 1 m-y- _.-, w .a 7"-"

F7 i ~ ~ 2870048600 l The purpose of Mod 2078 is to provide the required separation for i safe shutdown cables by encapsulating particular raceways in 3-hour tire barriers throughout the plant and/or by yerouting specific cables outside the fire area. The raceways are being encapsulated to protect the cables within by inctalling a subliming material on the exterior of the raceway. This work provides ahe separation necessary for safe shutdown in the event of an Appendix R fire. This action will increase the safety of the plant. l l The cables requiring encapsulation or reroute are part of the q diesel generator, RHR, HPSW, ESW, CS, emergency AC or the DG cardox J l syn m. The cables that are being encapsulated are listed on Attachniert I. Attachment II lists the cables that are being rerouted. l Attachment III lists the cables that are being rerouted and l encapsulated. The encapsulation installations that-are being inspected under Rev. 5 of this Safety Evaluation were previously evaluated under Mods 1029A and 13510. Therefore, the cable / systems that will l'e af fected will not be listed. No new encapsulations or reroutes will result from this inspection. As stated previously, the safety-related function of the systems containing r,trouted cables or encapsulated raceways is not changed. Therefore, the safety concerns associated with encapsulation,are:

1) derating c.ible ampacity, 2) detemining the adequacy of the existing supports, and 3) reviewing the seismic requirements of the installation.

The safety concerns associated with rerouting are limited to verifying the acceptability of the voltage drop that will be caused if rerotting the cable increases its length. The encapsulated cables must be derated (reduce the theoretical current carrying capacity of the cables) because encapsulation will reduce heat transfer thereby increasing the operating temperature of the cable. If the theoretical current carrying capacity (ampacity) of the cable were not reduced, the insulation life may be reduced. I The smoke and hot gas barriers will be installed in accordance l with Specification M-610, Rev. 2A, and will not cause cable derating. The existing cable full-load current and voltage requirements have f been compared with the calculated allowable values to assure that the affected cables are adequately sized. The comparison has shown that i the existing full load current and voltage requirements will not exceed j the calculated allowable derated values. The existi: ; rupports have been evaluated to determine whether th y are eduquat to suppo'rt the extra weight of encapsulation and the seismic acceleration forces. Each proposed encapsulation design, as necessary, includes modification to existing supports and/or the addition of new supports. The evaluation of the final design concludes that the supports are adequate te support the extra weight of encapsulation and meet seismic requirements. The encapsulation enhancements and repairs which are a result of the inspections will be performed in accordance with approved criteria. Fire watches will not be required based on the present plant status, Units 2 and 3 in cold shutdown. Any change in plant status will I l require station review of this direction. _.~. - -. _ -

-J- ' ~ i } 2870048600 1 This modification does not change the function of the affected i systems as described in the UFSAR. Sections 4.8, 6.4, 6.5, 8.4, 8.5, 10.9 and 10.12 were reviewed in making this. determination. Section l 7.1.6, " Redundant System Wiring Independence, Protection, and Marking", will be revised to include the cable separation requirements of Appendix R. The plant electrical load will not be increased by this i modification. 10CFR50.59 CHANGES, TESTS AND EXPERIMENTS An unreviewed safety question is not created since The probability of the occurrence or the consequences of a. an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased. Raceway encapsulation and circuit reroutes do not change the function of the affected circuits. The safety-related function of the l systems that are associated with the affected cables are l not changed, as they are described in the PBAPS UFSAR. I b. The possibility of an accident or malfunction of a i different type than any evaluated previously in the safety analysis report is not created. The operation of the plant as desctibed in the PBAPS UFSAR will not be changed by this modification since the operation of systems is not affected. In addition, the adequacy of the power supply characteristics to safe shutdown 1 equipment has been verified for the cables affected by this modification, c. The margin of safety as defined in the basis of any i Technical Specification is not reduced. Sections 3.5.A, 4 5.A, 3.5.B, 4.5.B, 3.5.F, 4.5.F, 3.9.A.1, 3.9.A.2, 3.9.C & 4.9 C, and their respective bases, of the PBAPS Technical Specifications were reviewed in making this determination. TECHNICAL SPECIFICATIONS: I ~ A change to the Technical Specifications is not required because j raceways and circuits are not listed in the Technical Specifications. The sections and bases that were reviewed in making this determination are li ste6 in the answer to ~.. v. i w c) in the 10CFR50.59 de'ermination. 10CFR50.92 SIGNIFICANT HAZARDS DETERMINATION: I 1 A significant hazards determination is not applicable because a license amendment is not required. l t _... _ _ ~ _ -.- - - _- - - _ _ _ - - - -

-l i 2870048600 't APPROVALS: e Prepared By: M 7//((I Date (Responsible Engineer) Reviewed Sys \\ DatesD-(-b s (L4dd Div ~I ~ ependent Reviewer) /b 7// '[ Date Lead Division (Bran /h had @r Section Head) 0 6LLAfn Date: ~l f l f b7 Non-Lead Div. Resp'edsible Engiraer 4t<,) b/de// _7f4/O 7 Date: N n-Lead Div. Independent Re' Viewer i R _ l0i k Date N Non'-had 61v. (Brapch Head or Section Head)

• )/

o_ m - - Data 'Nbclear and Environmental Section Head 'g 1 MWL/la la4687m315 Copy to DISTRCODE EESE-1 DAC (NG-8) 4 I

~- ~ 2870048600 ATTACHMENT I TO SE FOR MOD 2078 CABLES BEING ENCAPSULATED Deficiency List _ Cable No. System Item ZA3A15D Diesel Gen. 15 ZC3A17A Diesel Gen. 16 ZA2A1506J RHR 17 ZC2A1702J RHR 18 ZA3A1506J RHR 19 ZA2B1021A Emer. AC 20 (enc. in Fire Area 40) ZA2B1014A Emer. AC 21 (enc. in Fire Area 02) ZB3B1114A Emer. AC 22 (enc. in F. A. 92, Rms. 262 & 258) ZA2A1507A HPSW 34 (ene. in MH#001) ZC2A1706A ESW 34 (enc. in MH#001) ZC3A1707A HPSW 34 (enc. in MH#002) ZA3A1505A Emer. AC 11,12 & 31 ZA3B1014A Emer. AC 11,12 & 31

• Note:

The cables listed above will be encapsulated to provide th' 3-hour separation required by Appendix R. Due to physical restraints, portions of additiont.1 cables will be encapsulated. The additional cables will not be listed. i MWLimjS ~ MJS111886M755

[ 2870048600 ATTACHMENT II TO SE FOR MOD.2078 l > CABLES BEING REROUTED Deficiency List Cable No. System Item Z.12B1021A Emer. AC 20 (Reroute in F.* 's 6N, 65 &25) i l ZA2B1014A Emer. AC 21 (Reroute in F. A. 9 2) l DG Cardox Cable DG Cardox 26 (not scheduled) ZD2Q1207A & B CS 37 ZD3Q1207A & B CS 37, ZD3Q1314D & RHR 56 ZD3Q1427B The following cables must be relocated to allow for the encapsulation of ZB3B1114A in F.A. 94. The cables will not be removed from F.A. 92. All of these cables are associated with the Unit 3 "A" & "B" Recire. MG Sets: 3Q1454A, 3Q22D, 3Q22E, 3Q22F, 3Q22G, 3Q27J, 3Q27L, 3Q27M, 3Q28H, 3Q28J, 3Q28L, 3Q28M, 3Q28K & 3Q28R. MWL/mjs MJS111886m755 I ' - ~ ~~ ~

' *1 2870048600 l M ATTACHMENT III TO SE FOR MOD 2078 CABLES BEING REROUTED AND ENC. Deficiency List Cable No. System Item ZA2B1021A Emer. AC 20 (Reroute & enc. in F.A. 92) ZB3Q1844A & B RHR 43 (Reroute & enc.'in' F.A. 135) 4 l MWLimjs MJS111886M755 I s' =>e-ew=~~ so e o = w .,,m ..*n nmn_. - ~ - - + ~ - - -~~.-~-- __

FEB t s wcv ~ .[ ELECTRICAL ENGINEERING DIVISICN N3-1, 2301 MARY.ET STREET 7 \\ Safety Evaluation for Mod #2079 Peach Bottom Atomic Power Station - Units 2 and 3 l ', /' File: SAFETY 2 (Fire Protection) l D';CTYPE 265 I

SUBJECT:

This modification corrects problems with five motor-operated valve circuits which are not in compliance with Appendix R to 10CFR50. In each case, spurious operation of the valves could occur for a fire in areas through which valve control cables are routed and in which operation of the valves is relied upon for safe shutdown. This modification corrects these problems by either relocating valve controls to f.1re Treas in which operation of the valves is not relied upon for si shutdown or by making logic changes in the control circuits to prevent spurious operations. II CONCLUSION: HPCI, RCIC and ESW are safety-related systems. An unreviewed safety question is not involved. A change to the Technical Specifications is not required. The capability to safely shut down the plant in the event of a fire is maintained. This modification does not require a license amendment or prior NRC approval. A significant hazards consideration is not involved. A revision to the UFSAR is required. III DISCUSSION: MO-2-23-15: HPCI INBOARD STEAM SUPPLY ISOLA"' ION VALVE Failure of control cables in Fire Area 25 and 6 South could spuriously close this valve and disable HPCI operation for Unit 2. The power and control cables for this valve are from MCC 20B36 (A channel emergency power) located in Fire Area 6 South. The control cablas and reversing motor starter, for this valve will be relocated to a new control bcx in the Unit 2 M-G set room of the Radwaste Building. The power feed remains from compartment 14 of MCC 20B36. Power to the valve for alternative shutdown is supplied from the B channel of the Unit 2 emergency 4kV system through a power transfer switch. In the normal mode, power to the valve vill be from PCC.2GB36. t N

Sr van 2079 4 M ( y The transfer switch will be annunciated when in the alternative shutdown position. MO-3-23-15: HPCIINBOARDSTEAMSUPP}YISOLATIONVALVE Failure of control cables in Fire Area 25 could close this valve and disable the HPCI system for Unit 3. The power and control cables for this valve are from MCC 30B36 (A channel emergency power). The control cables and reversing motor starter for this valve will be relocated to a new control box in the Unit 3 MG set room of the Radwaste Building.. The power feed remains from compartment 14 of MCC 30836. To provide power to the valve for alternative shutdown, a feed from the B channel Unit 3 emergency 4kV system will power l the valve. To provide this capability, a power transfer switch will be installed to feed the new control box. In the normal mode, power to the valve will be from the 30836 MCC. In the alternative shutdown mode, power to the valve will be from the B channel emergency 4kV system. The transfer switch will be annunci-ated when in the alternative shutdown position. MO-2-13-15: RCIC STEAM LINE ISOLATION VALVE Failure of control cables in Fire Area 6 North could spuriously close this valve and disable RCIC operation for Unit 2. The power and control cables for this valve are from compartment 21 of MCC 20B37 located in Fire Area 6 North. The control cable and reversing motor starter for this valve will be relocated to a new control box in the Unit 2 MG set room of the Radwaste Building. The power feed will remain from its present source for both normal and alternative shutdown eperation. MO-3-13-15: RCIC STEAM LINE ISOLATION VALVE Failure of control cables in Fire Area 13 North could spuriously close this valve and disable RCIC operation for Unit 3. The power and control cables for this valve are from compartment 21 of MCC 30837 located in Fire Area 13 North. The control cable and reversing motor starter for this valve will be relocated to a new control box in the Unit 3 MG set room of the Radwaste Building. The power feed will remain from its present source for both normal and alternative shutdown operation. MO-0498: EMERGENCY SERVICE WATER DISCHARGE VALVE The ESW reservoir isolation valve MO-0498 provides a flowpath back to the discharge pond during ESW operations whenever the ESW pumps and normal heat sink, the ~or- . age und, are available. MO-0498 o is closed only when use of the emergency heat sink is required. The Peach Bottom Appendix R Shutdown Analysis identified a condition that a hot short of one of the conductors in either control cable ZDOB5643D or ZDOB5643E could cause MO-0498 to close. Closure of MO-0498 could cause the emergency diesel generators to trip unless the valve is opened within three minutes. Recognition of the need to open and manual operation of the valve within three minutes is not possible, f

, 3 i e. 9 8' y-This modification provides a pushbutton on the C123 panel which { prevents energizing the "close" contactor coil when a time-delay { control relay is de-energized. To stroke MO-0498 closed, the { pushbutton is depressed which energizes the time. delay relay and. permits a close signal' to energize the close contactor. The l timer is set for a period greater than the stroke time for MO-0498 to allow adequate time to stroke the valve. After this I time period, a seal-in which shunts the pushbutton contact drops out and the close contactor coil is isolated. l 1 A review of the two affected design basis events indicates that { sufficient time exists to allow manual repositioning of MO-0498 - prior to establishing cooling using the emergency heat sink. First, for the probable maximum flood, Peach Bottom FSAR Question 2.4.C states that about 2 hours are needed to raise the river level elevation from '+113 '-0" to +115 '0" (conowingo Datum) when the predicted river flow is greater than 840,000 CFS. This is a ] limiting condition for operation which requires the reactors be i placed in cold _ shutdown using normal operating procedures. I Second, following an uncontrolled water release from Conowingo Dam, Peach Bottom FSAR Question 2.4.C ctates that approximately 1.5 hours exist before the water level at the intake structure drops to the plant low water design level. This time frame is conservative since it assumes the Pond is at its minimum level at the initiation of the event and, there is no inflow to the Pond I from the Susquehanna River. I By changing the remote manual capability of closing the valve . from panel C123 to. include a second pushbuttoe,.two logic signals j which cause automatic closure are eliminated by this modification. q In the pre-mod state, the first close signal results from an emergency diesel generator start signal which starts the emergency ] cooling water (ECW) pump (OOP186) after a time delay. If either j ESW pump has sufficient discharge pressure, the ECW pump will shut l down. However, if both CSW pump discharge pressures are low, the logic signal opens the ECW pump discharge valve, MO-0841, and closes MO-0498. The ESW booster pumps (OAP163 and OBP163) start l and closed loop cooling is initiated. The second automatic close { signal results from both service water pump structure sluice gates I closing for either unit. The logic in turn closes MO-0498 and starts the ESW booster pumps. Cooling is established using an { ESW pump and an ESW booster pump which discharges back to the j emergency cooling tower. The water is cooled in the tower and I returned by gravity feed to the service water pump structure. I This modification eliminates automatically establishing either one of these closed loop cooling paths. However annunciation in the main control roor tv w./ 2 'to. to manualM close the .. c MO-0498 valve is provided by t m readification for each of the automatic logic c..nc'itions which are being eliminated. In addition to the above events, a loss of both ESW pumps was ( evaluated since heat rejection would then be provided by closed loop cooling using the emergency cooling water pump l i \\ \\ l i )

SE Mod 2C79 s s ) (OOP186) and emergency heat sink. This accident is not considered credible since it requires a double active failure. However, if this situation should occur, closed loop cooling can be established by manually shutting MO-0498 and starting one of the two emergency service water booster pumps (OAP163 or OBP163). Cooling of safeguard equipment commences immediately with the establishment of emergency cooling water pump flow, however the water inventory in the emergency heat sink is dumped to the discharge pond until MO-0498 is shut. If MO-0498 is shut by plant personnel within 1 hour of initiating emergency cooling, only 16 percent of the consumable inventory will be lost. Section 10.24 of the UFSAR states that the inventory of water within the tower is adequate for 1 week of operation without makeup. Based on continuous cooling tower operation at the rated flow condition, the total water consumed after 7 days is 3,000,000 gallons. Since sufficient time exists for an operator to reposition MO-0498 manually before establishing cooling using the emergency heat sink, the impact of this modification on the safe shutdown of the plant is negligible. There are no new electrical load requirements as a result of this modification. Powering MO-2-23-15 and MO-3-23-15 from the B safe-guard bus for alternative shutdown is acceptable because the five horse power load from each valve motor loads the bus only during the valve stroke time. Also, similar valve loads on the B bus will not be used during alternative shutdown. UESAR. Single line drawings and P and ids will be updated to reflect this modification. Sections 5.4.2, 4.7, 6.4, 10.9 and 10.24 have been reviewed in making this determination. Since this modification does not involve any radwaste systems, IE Circular 80-18 is not applicable. IV 10CFR50.59 CHANGES TESTS AND EXPERIMENTS: The following conclusions can be made regarding this modification: 1. Technical Specification Sections 3.5C, 4.5C, 3.2,4.2, 3.5D, 3.9C 4.9C 3.11B, 4.11B, 3.12, 4.12 and the associated bases for these sections have been reviewed. Changes are not required because this modification does not change the HPCI, RCIC or ESW systems as described in the Technical Specifica-tions. The MO 2-23-15 and MO 3-23-15 valves are normally powered from safeguard channel A power and c.harnel separation is maintained by this modification.

. E.cMod " m - t i ) 2. An unreviewed safety. question is not' involved because of the following reasons: a) The probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased. This modification relocates motor con-tro1P for M(r-2-13-15, MO-3-13-15, MO-2-23-15 and MO-3-23-15. Por the MO-2-23-15 and MO-3-23-15 valves, the A channel emergency power supply is maintained for the new transfer switch in its normal condition. In the alternative shutdown mode, the abnormal condition is annunciated in the main control room. Since it is not necessary to consider a design basis accident or seismic event coincident with a design basis fire and the con-current loss of offsite power, the alternate source of safeguard power to the valves with the transfer switch in'the emergency mode does not violate safeguard channel-separation criteria. The function of the HPCI and RCIC systems are unchanged by relocating the controls for the steam line isolation valves. Annunciation of conditions which require MO-0498 to be closed will provide the operators with sufficient time .to close this valve. Therefore, eliminating the automatic closing capabilities for MO-0498 does not reduce the mar-gin of safety. b) The possibility foi an accident or malfunction of a different type than any evaluated previously in the safety analysis report is_not created. The operability of the HPCI, RCIC and ESW systems are unchanged by these modifications. Although automatic operation is removed frne MO-0498, annunciation is provided and sufficient time exists for an operator to recognize the need to close MO-0498 and establish closed loop cooling. c) The margin of safety as defined in the basis for any Technical Specification is not reduced. This modifica-tion improves the margin of safety by providing a means I of supporting HPCI, RCIC and ESW operation for those ] fire areas,where they are relied u on for safe shutdown. ., " !- df/ Tesi.n; ss t spe e f, s e, tion.sec tion s J. s % v. Sc 2 4, v. L, 3. 0, 3. t c, s 9 c, giy ) f,,' p 3.11 0, Vits 3.12 4,ol,u d +Le:r w ssl<,F d kres us,.e revi e w ed. V 10CFR50.92 SIGNIFICANT IIAZARDS DETEPJ4INATION: /'lf' g M \\kD This determination is not applicable because a license amendment 'M is not required. g y kg P1 p,, i

3 g.g m e, i j _g ~j VI APPROVALS.: Prepared bys f !'d 7 Dates (Responsible Engineer) j i Dates f ~ ~b Reviewed by: (Leadfiv'ision'IndependentReviewer) / /h~/ 7 83-Dater g, ggy L4ad i ision ranch Head)- / . 45/ccr.5 GdLy U '*1 /[7/fg7 M x h_L.- k \\h k 1 '/^ Date: t-uE( N n-Lead DSy' pion Responsible Engineer ~ "10*' <,',,1 h,.9, .} ypt , g., L, s, e.43 **e '} /*$w l ' 30YCsQ / r Date: l~Si~D? Non-Lead Diyision Independent Reviewer . g tlb 64M t.Ih \\fiAf8] m OJ -Date: .yv Non-Lead' Division /'anchorSectionHead) / /91/r Date: 2/ U l Nuclear & Environmen al Section Head d / / 1 l JJM/la la10786m800 Copy to: Distreode ECSE-1 J. J. McCawley DAC (NG-8) j j M. Reitmeyer l 1 l I l 1 J

s,.* O i o. {-' ( ^ ' I ELECTRICAL ENGINEERING DIVISION r.-- t p,j N3-1, 2301 MARKET STREET Y c) JUN ~ -]E7 Safety Evaluation for Mod 2080, Rev. I h[j., ,.;;l Peach Bottom APS Unit 2 < a 9 File: SAFETY 2 (Mod 2080) Ud DOCTYPE 565 I

SUBJECT:

This modification provides the ability 1) to trip HPCI frem control room panel 20C04B due to an Appendix R fire in Fire Areas 6 North or 6 South and 2) to isolate a close signal to MO 2-23-24 frem cables terminating in cable spreading room panel 20C39 due to an Appendix R fire in Fire Area 6 South. II COMCLUSION: This modification affects safety-related equipment. It does not involve an unreviewed safety question. A change to the Technical Specifications is not required. This modification does involve safe shutdown equipment, however safe shutdown capability in the event of a fire is maintained. Safe Shutdown control of HPCI is described in the PBAPS Fire Protection Program which will be incorporated into the UFSAR. Neither a license amendment nor prior NRC approval is required. A significant hazards considera-tion is not involved. I, III DISCUSSION: As a result of the analysis of safe shutdewn capability in compli-ance with 10CFR50, Appendix R, a modification to the HPCI control circuitry is required. The analysis shows that a fire in Fire i Arsa 6 North or 6 South affects HPCI operation when required for safe shutdown. ~ A fire in Fire Area 6 North, where Method A (RCIC) is the safe shutdown method relied upon, could cause the HPCI pump to inadver-tently start due to spurious signals from cables routed through this fire area. In addition, a fire-induced short circuit may occur in HPCI control logic cables which are also routed in this fire area. This short circuit could blow the HPCI control logic fuses, thus disabling the HPCI trip circuit which is powered from the same set of fuses. Consequently, the reactor vessel could -s, overfill if HPCI were unable to be tripped. Therefore, a means to

2.,

trip HPCI nmst be provided independent of power tn the HP i i control logic. 4 j This modification provides the capability to manually trip the f HPCI turbine from the control room if power is lost to the control logic which includes the existing turbine trip circuit. This is I l accomplished by replacing the existing HPCI trip pushbutton switch tj ) in the control room with one having an additional normally open l This additional contact will be wired in parallel with contact. the 23A-K14 relay contact that energizes the turbine trip solenoid ( I I l

t-l s (.[

o valve.

This solenoid valve is fused separately frem the control logic. l At present, when the HPCI turbine is automatically or manually l tripped, Min-Flow Bypass to Torus Valve MO-2-23-25, receives both a close initiation and an interlock to prevent it from cpening. HPCI Turbine Exhaust condensate Drain valve A0-4248 also receives a close signal. This modification permits the HPCI turbine to be manually tripped if the HPCI control logic is disabled, however, these valves will not operate automatically if power is lost to the HPCI control logic. The valves can still be operated from i their centrol switches. In the event that an Appendix R fire would require the HPCI turbine to be tripped manually, suf ficient time would be available for the operators to close the minimum flow bypass valve and condensate drain valve. A fire in Fire Area 6 South, where Method B (HPCI) is the safe shutdown method relied upon, could cause fire-induced shorts to occur in the cables associated with the HPCI automatic initiation on high drywell pressure. Failure of these cables could cause an automatic HPCI start and could sustain this signal througheut the fire scenstio. This sustained signal will maintain Redundant Shut-Off to CST valve MO 2-23-24 and Flush Line Shut-off to Torus valve MO 2-23-31 in the closed position, thus preventing HPCI _J recirculation flow. This modification provides the capability to isolate this sus-tained close signal to MO 2-23-24 by the installation of an isolation switch in cable spreading room panel 20C39. This two-position, maintained contact switch will be keylocked in the " Normal" position with all automatic close signals to MO 2-23-24 remaining in place.' When the switch is placed in the " Emergency" position all autematic close signals to MO 2-23-24 will be isolat-ed. The valve will remain manually operable from the control room. HPCI turbine trip capability could also be disabled due to cable damage from an Appendix R fire in Fire Area 6S. However, the turbine trip circuit modification as previously discussed for Fire Area 6N will provide the required trip capability for a fire in Fire Area 6S. The trip pushbutton and isolation switches are seismically quali-fled and their installation will not affect.G.a sessmic qualifi-cation of the panels they are mounted on. f The " Emergency" position of the isolation switch will be annunciated in the control room. Administrative procedures will control access to the isolation switch key. ?. i YN Since this modification does not affect any radwaste system, the guidance provided in IE Circular 80-18 is not applicable.

\\ f .Q There is no increase in load en the plant electrical systems as a result of this modification. The plant es described in the UFSAR is being changed by this modific tion. Appropriate Functional Control Diagrams will be updated to reflect the new isolation switch. Sections 6.1-6.6 and 7.4 were reviewed to make this determination. The operation of the HPCI system in the safe shutdown mode is described in the PBAPS Fire Protection Program (FPP) which will be incorporated in-to.the UFSAR. IV 10CFR50.59 CHANCES, TESTS, AND EXPERIMENTS: l l 1. This modification does not involve an unreviewed safety questien because of the following: a) The probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased. The new trip pushbutton is a two-stage versien of the existing one. The present HPCI turbine trip logic will be maintained using one contact. The other contact will energize the turbine trip solenoid in an independent parallel path without interfering with the present trip logic. This ensures a method to (q/ manually trip the turbine in the event of a power loss i to the existing trip circuit due to cable damage in Fire Areas 6N cr 65. This modification additionally provides the capability to isolate a sustained close signal to MO 2-23-24 due to damage to cables in Fire Area 6S. The safety objective of the HPCI system is maintained when the isolation switch is placed in the " Normal" position. Although' placing the isolation switch in the " Emergency" position will disable the auto-close logic to MO 2-23-24, this condition will be annunciated in the control room and the valve can be manually operated from the control room. The probability of occurrence of an accident or malfunction of equipment important to safety is not increased because this modification will be designed and constructed in accordance with criteria applicable to the safety-related HPCI system and be-cause the accident-initiating events discussed in UFSAR Section 14.6.3 will remain unaffected. b) The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created. The present autcmatic and manual HPCI turbine trip capabilities are maintained. HPCI valve MO 2-23-24 functions normally when the new isolation switch is in the " Normal" posi-tion. Although placing the isolation switch in the t- " Emergency" position will bypass the auto-close logic to MO 2-23-24, the valve can still be operated manually i f rom the control rocm. The new pushbutten switch, isolation switch, and associated wiring changes will be

'h

~s designed and constructed in accordance with criteria applicable to safety-related systems.

Failure of this new equipment will not create an accident of a new or different type or an accident more severe than any accident provicusly evaluated in the UFSAR because the HFCI system is not presently single-failure proof. c) This modification does not reduce the margin of safety as defined in the basis for any Technical Specification. The HPCI system's initiation and operability require-ments as described in the Technical Specification Sections 2.1.J and 3/4.5C are unchanged by this modifi-l cation with the new trip pushbutton and when the isola-l tion switch is in the " Normal" position. Placing the isolation switch in the " Emergency" position is acceptable,because, as discussed in IV.2 be. _ ow, 10CFR50. 54 (X) allows a departure from the Technical Specifications in an emergency such as an Appendix R fire. 2. No changes to the Technical Specifications are required based on the review of Sections 2.1.J and 3/4.5C. Changes are not required because the isolation switch does not affect the HPCI system when placed in the *' N o rma l" position. The operation of placing the isolation switch in the " Emergency' positien will be incorporated into the T-300 Rev. O procedures which will only be used in the event of a fire as appropriate. The use of the T-3OO and CN-114 Rev. O procedures to respond to an Appendix R fire will ensure the operability of the minimum required equipment to achieve and maintain safe shutdown. 100FR50. 54 (x) allows departure from the Technical Specifications in an emergency. Since an Appendix R fire event would be considered an emergency, 10CTR50. 54 (x) allows the T-300 procedures to depart from the Technical Specifications as required. V 10CFR50.92 SIGNIFICANT HAZARDS DETERMINATION: A license amendment is not required therefore this section is not applicable. .-7 P [

1 at f- -Q VI APPROVALS: $M~) Frepared By: T Date: esponsible Engineer) t/ ace 7 Reviewed By: O. P."A J e Date: (Lead D4v. Independent Reviewer) / Ohf Date: (Lead Division Branch Hpd or Section liead) ) /- ki !.: \\, k\\'NL.. st'- Date: ' [ I- [- ( (Non-Le-d Divis'icn 'asponsible Engineer) /e Date: 8-28-b7 (N6n-I.,ead Divisio'n Ind6 endent Reviewer) s/z.t!6 '? Date: . (Non-Lead Div. BrancK)(ead cfr Section Head) f/ 'I ~ 6 =# **e Date: / (Nuclear & Environmental Sectiori Head) ,) JDK/la la51187m230 Copy to: DISTR CODE EESE-1 W. J. Brady I ??$ i

I rm w - 1 60079 ' RecEvod TPS R. S. Fleiechmann - T Date: //9N7 D !GPCI CPMORIG Desi I 1 J8CJ j JE

• J i i

JFM I / SRR i Atri l SAFETY EVALUATION FOR MOD 2082 Peach Bo t t ora Atornic Power St at ion - Unit O 1 i FILE : SAFETY 2 (Fire Protect ion) gp Doctype 565 p39 , c. ASC \\ j E2 \\ 0 I. SUBJECY: FILE

• PORC

SUMMARY

The Appendix R Task Force has deterrnined that a nVM CI NO C associated circuits pro b l ern exists for the 20D11 Unit 2 D. C. tootor control center. The bus work for this MCC crosses two fire areas resulting in an electrical fault isolation pro b l e rn. At present, there are no electrical devices to isolate fire induced faults frorn safe shutdown equiprnent required to safely shut down the plant in the event of a fire. II. CONCLUSION: 3 This rood i f i ca t i on involves routing safety-related power cablen frorn a fused disconnect located in a corapartroent of the 20D11 d.c. power MCC to provide power to the 20D11A auxiliary MCC. The 20D11 and 20D11A MCCs are safety-related and provide power for safety-related eq u i prnent. Th i s raod i ficat ion does not involve an unreviewed safety question. This rnod i ficat ion rnai ntai ns the capability to. safely shut down the plant in the event of a fire. Changes to the l Technical Specifications are not required, therefore a license ardendrne nt or prior NRC approval is not required. A significant ha:ards consideration is not involved. III. DISCUSSION: f Presently,

d. c.

MCC 20D11, located in the Unit 2 reactor building on elevation 135 feet (fire area 6 North), l shares a 250 volt

d. c.

bus with the 20D11A MCC. 20D11A is l located in the Unit 2 reactor building on elevation 165 feet ) (fire

• area 6 South).

A fire in fire area 6 South requires roethod B (HPCI) to shutdown the plant. This roodification will route cables to feed 20D11A f rorn a f used evrnpaet tne. - in 20D11. This fuse will provide electrical irolation to prevent a fire-initiated fault on the 20D11A bus frorn tripping the feeder breaker that powers the 20011 i MCC. Losing the 20D11 MCC would disable safe shutdown equiprnent required for roethod B. 4 1

2860079860 { / l Safety-t' elated eq u i prae n t criter ia will apply tc the new cable routing and to all w o r-k done on the 20D11 and 20D11A MCCs. There are no new load req ui r ernent s as a result of this rnod i f i c a t i on. The plant as described in the UFSAR is not being changed by this rood i f i ca t i on. Sections 6.O and 8. 7 were reviewed in raaking this d e t errn i nat i o n. Changes to the single line drawings in the UFSAR will reflect the work done for this rnod i f i c at i on. IV. 10CFR50.59 CHANGES, TESTS AND EXPERIMENTS The following conclusions can be rnade regarding this rnod i f i ca t i on : 1. Technical Specification sections 3.SC,

4. SC,

3. 9,E & -

4.9 and the associated bases for these sections have been reviewed. Changes are not required because this rnod i f i ca t i on does not effect the HPCI or ernergency d. c. power sy st erns as they are described in the Technical Specifications. N 2. An unreviewed safety question is not involved because of the following reasons: a) The probability of occurrence or the consequences of an accident or rnal f unct ion of eq u i prne nt i ro port a nt to safety previously evaluated in the safety analysis report is not increased. This rnod i f i c a t i on raa i n t a i ns the Division II erne r g ency safeguard d.c. power supply to MO-4245 (identified as MO-4244A on P&ID M-365), the HPCI turbine exhaust valve. This valve is the only load on the 20D11A MCC. b) The probability of an accident or rnal funct ion of a different type than previously evaluated in the safety analysis report is not created. The ernergency safeguard

d. c.

power or HPCI s ys t erns are unchanged as described in the UFSAR. The new cable frorn 20D11 to 20D11A is sized to a ccernrnod a t e the load of the MO-4245 rnot er operator, the only load on the 20D11A MCC. Also, the length of this cable route has been considered in si:ing the cable to avoid significant voltage drops and to assure adequate voltage levels at the MO-4245 rnot or operator. The fuse at the 20D11 coropa r t roe nt powering 20D11A is si:ed to protect the new* cable against fault currents and to provide proper coordination with the breaker that powers the 20D11 MCC. c) The rnargin of safety as defined in the basis of any Technical Specification is not reduced by this roodification. This rnodi ficat ion does not change the ernergency safeguard i

d. c.

power or HPCI sy s t erns as described in the Technical Specifications.

1 1 2860079860 I l ~ k l l u. 10CFR50. 92 9 L ON [ ?? iC;..".:' 5% Um D~ Oi! 9 H,. -. ' i-l 1 i bi-U ; i.. :. r o. ' <.,. I t or. 1. r i. t- .Fi-1 l .~ isie., d :wr i t i t-i ! a t. r e.a u.t r ie. l /I. Appro.4 ts: Preper ed bv :

1. 4 T.e'-

I7-I ries p 6n a i b i e En <g Nee _'- ) f

r. 2 v i ewed.

,_y,___ Dete. J[. 5 - % uy (' ad Diviilen .! n <iep ='nd e n t FW vi ew p :' / ef.. -.. #.... b. b.. Dete : !!..../" -4 Lead D'v sien (Bran h Hgsd) d 4.i ? ._.... M. #4 uc l e,e r 3 Environe. ital _. _ _ Date : o Section Raad Copy to : distrcode EE5E-1 J. J. McCawley DAC (NG-8) l 11. Rettmeyer d i st c f i l e 1352A.SE l 5 L

a

• P-
• M ary q 7 -. _ _ _

- - ~ - - , ~...,,, ,s. I NRkS 1 1 t 1 m 1 2870013370 7,.jg.;.p t y g: rNG1HrrM NG 01Vinif'N g).), 2301 Market Street l for Hodsficatson 2004 Safety Evaluat10n RHD Puep Mintmum Flow Pypass Valves b. Peach Bettom APS l' nits 2 and 3 ritei Rzss-3 <xod foe 41 g Doc t ype : 565 Revi sion 0 g Suhteet: Modi f teat ion 20a4 replaces the AC motors in the actuators for t' the minimum flow valves f or Residual Mo 3 16A and PO2 16D, N purpose 4 pumps 3AP35 and 2DP15, wit.h DC ectors.these valves fol-valves / j Heat Paseval (RHR) to provide motive power for of this modification is y in Fire Area 13N or 65, respectively. f lowing a ftre of equipment for the (tnit 2 1991 ( Because of the unavailability valve Mo?-10-160 will be installed. for This interte fix changes the valve from nor1na lly closed to normally an interim logie change 2 outage. l t I open. I

== Conclusion:== j e The proposed modif trat ion s { (a) af f ect s safety rela *ai agitirme nt j f involve an unreviewed safety question f (b) does not i' require a Technical Specification change I te) does not down the plant in the 9 i maintains the caph ill*y to safely shut l.\\ i ..(d) I event of a fire 5 aswndment or prior trRC approval (e) does not require a license ~

_ + y, involve a e!qnificant hasards consideration

( l doeo not g 'd > - f.. ,. ( f ) ) f y - Q 7. Discussions j. to recover f rom a fire f in shuthewn method. relled upon least The safe lenit 2) requires operat, ion of at is running Fire Areas 13N (Unit. 3) and 6S trhen RRR Pump 3AP 35 or 2DP 3 5 Bypass Valve one RNR loop f. r each unit, path. RNA Minimum Flow a danage to discharge is required to be open to prevent sufficient without a (?nde r the present control schose, the valve is normally I M no3-10-16A or M02-10-16D h dif f erential pres-closed and opens af ter a ten second delay when higha postulated fire in these the pump. l Howe ve r, the pump. l ince the fire areas eculo cause loss of power to the respective va ve, s j eure is sensed across The pt'.'t eculd be l meu located in the fire area. damaged if operated with the minimum flev v ol'. a s clesed. Emergency load Center is l l 1

1 i . --- _ ~ _ _ _ - - - t i J NRMS r i e p F l r, 2870013370 l The available time la cenoidsted to be tw shcrt for the ope r a t o r to roccanate tne estuatson and to take riar ua l action to se cu r e the pump, l. 1 W ie potential condition will be j the valve actuator motor free ra rw e e. > arsected by changing { 1 AC to DC, thus reinov iM it fr03 the af-I i foetad load center. A fire would therefore not prevent minimum flow l through the pusy. At Unit 3, valve M03-10-16A will be removed from NCC30536 (emergency channel ZAl and connected to 250 VDC bus 30012 tenergoney channel EA). At Unit 2, va l ve M02 16D wi ll be from MCC 20839 (emergency channel ZD) and connected to 250 VDC bus removed ) 20011 (emergency channel EBl. Since the'eontrols for M02-10-16D will roomin in channel F.D. ralay will te innalled for sociatton. j a ( As an interim fin, logie chance will be installed at a t ha t valve M02-10-160 is normally open. N valve would be closed un. Unit 2'so der only three ccaditions (1) RHR pump flow above setpoint as deteet-ed by DPIS-2* 141)lDe (2) valve MC2-10-11 the operator. Note that because of logic arrangement, valve 102-10-16D opens (3) manual closino by i cannot be opened manually if closed by interlock with M02-10-17 j 'De consequences of a f ailure of M02-10-160 lowing an RNR pusy ECCS ' initiation has been addressed and it has been failing to close fol-concluded that the flow diversion through this line would not 3 j j the RER systee free providing adequat e cere cooling. ), prevent the Osneral Electrie Company report,

• Safety tvaluation of Modification i

t to lock Open RNE Minimum Flow Valve for Peach Bottee 2/3, DRF CG!- i q j 00045,* concludes that even when a 10t reduction in RNR flow rate is i assumed, the system can still provide adequate make up to the vessel in the event of a 14CA. Although the,,reduet inr-flow to the ve s sel i could result in a slight increase in' peak clad temperature, there would still esist a substantial margin with respect to the peak clad tempera-f ture limit. It is further noted that this ningle faalute is bounded I by the failure of a' single RHR loop. A second consequence of M02-10-16D remaining normally open is the i possibility of establishing a drainsoa rath fr

• the res:t 1.

h in-advertent Drain Path Review psepared 1/84 i determined that a potential drain path esisted through valves M02-10-18, M02-10-17, j Im2-10-16D. This wee judged acceptable since MM 10-160 is now M02-10-140 arid locked to be open only when the sesociated RM1 pump as running tooether inter-i with high differential pressure. 'i Changing the 2D 3K5 pump to normally open wirt reeute the number of valvaathe minimusdlow valre most be open to drain the vessel throuch the minimum flow line.. which 'ever in shutdown cooling ande. M02-10J160 will be closed under admini-When-I

• etrative control.

Bowever, to provide e W ittenal safeguard against { jurtantially draining the vessel through the minimum flow lines, valve ~~ n02-10-16D will be Laterlocked to elese wha **ver is:lat un valve 802-10-17 is cyon. - (. { T1ms interim 'aolution ( at Unit 2 will require a chance to Section 7.4 of the trFSAR. Sections 4.0, 8.4 and 6.I do not require changes. i yhe permanent eclution will require changes to sections e.4 and P.7 Section 7.4 will require revision to rescre the change made for the

I i l NRMS t w I'g ~ l t 3-1 2870013370 an

• r i:a soluti.n.

te e. a n e r, srs requir d t: :;o et wa 4.3. Th3 "7 n .n 'u.. v.! . ;,,,: u > J :,, ' :.. ',; a -- :. n, da-

• No p.s tm e se -.

tanei '3;,,. uj gp gn g,., g 3 7 3 [. 2 'Z M h"/1 ** sien unneca ssor'/. I This modification rencves 0.82 hp from the 480 VAC emergency bus and adds approutmately the same amount to the 25C VDc emergency bus per t,ni t. This additional DC ioed is in the "one-minute" category for which ) suf fielent eueens capacity is available. The interim eolution at Unit 2 l' adds approximately 16 watts to a vital bus, which is not significant. As concluded in the LTSARPthe probability of DC power loss is very low. N

• aga e mp : - J rer Nt 2 inta*1a f!? vill ha tafaty-ralttad and seismically qualified. The DC motors and associated switchgear will be environment ally and seismically qualified.

i r The valve controls incorporate a manual open-elose switch for the valve. No special test features are planned for the Unit 2 interim. solution. f This modification is designed in accorda' ee with all criteria ar-n plicabic te sa fety-related circuits, including physical and electrical i independence, quality a s surance, testability (no change from present installation), operator indication, and carironmental and emismie quali-ficatAcer The chanael 2:B/2D c.mtiel interconnection will be in accer-dancewithaklicablacriteria. 10CFR$0.59 char:ges, Tests and Experiments 1. An unreviewed safety ;ue st ira is not involved sinees i (a) The preposed modification does, not increase the probability of l '4 occu r rence or the consequences

• of an accident or malfunction j

of equipment important to safety previously evaluated in the sa f e t y analysis report. The per=snent modification leaves the plant uncharged except for the source of electrical' power for one valve in each unit, with no decrease in reliability. At t'- i t 2. t 'a t-t-tim modificat ten adds two new qualified relays and changes valve operation from normally eloaed to normally i open., Aa' discussed above, failure of the valve to close does not significantly affect RHR operation, and administrative l codtrole and interlocks are provided to prevent inadve rtent ~ i reactor vessel drainage. 1 tb) The re is no possibility for, an accident or' asifunction of a t fferent type than evaluated previously in the safety analy-l { sis report as a result of this modification. The pe rnanent l eMi fi est lea leaves the plant unchanged except.for the source f.- of olcetriesl pcwor for ene valve in each ** a 4

• w t
• h.; h -

crea se in reliability. At t7 nit 2, the interim. modification f adds two new qualified relsys and changes valve operation from normally clescJ to noras11y open. a= M =-s eed abeve, the f

4

L I

NRMS t *. ..a ~ ~.. l 2870013370

.n

.7 f. m

r = > -

.. m i:: v: = ct c;:o atien. 2nd schantatrative cont: 1.s acJ i.-tarice;a are providad to prevent inadvertent reactor vans *1 d ra ina:;e. u (c' W.: pr;pd as>di ficat ion doe s not reduca the cargin of safety as defined in the basis of the Technical Speelfications. Se e-tions 3.$.A.3, 4.5.A.3 and their associated bases were re-i viewed., The bypass valves are not addressed. ) 2.* A change to Technical Specifications is not required. Sections 3.5. A 3, 4.5. A.3 and their associated bepes were reviewed and found to contaan no requaramense perte..ia9 to L.'.it :;,p:: tal.::. i 10CFR 50.92 81cnificant Hasards Determination to unroviewed safety question suists and no license amendment is required. Therefore, a significant hasards consideration evaluation is not applicable. d O e t

• • )g,

1 ) s' i I C i \\\\[ \\ s 9 I g-b j t we g 1 6 9

J. NRMS I wy ~ '- v 5-2870013370 4 Proparod by // h C Oste: " 1. II b b { / (Itosponsibig Engineer) moviewed by r$ ifI 5 Dater (Lead Div. Independent Re viewer ) O sca. L >Ha r I .t., lead Diviolon (Branch Need or section Sead) W\\ b H zkla 7 o.te, Ison-id Di elon penethle Engineer

1. fd Dater

/ [ / 1Boe=Imad.DiviWloh pendant, Reviewer t_ W d1 AJ ar t wi c _ Dates t/s e/sy 7_ eM / / ace-Lad. tigeitio (Brancty%ead or section Road) Date 8F poclear a p rironment etion kaad / / = 4 o ~

e..

' '.. e ' +. ^ ' cv . e.,. ~.., e }'^=.,. _r E!J/ds Ds101686n1254 cci sass-2 3, Skwirut (M3-%) F. Nascite111 F5 G 9 9 ,f 6 seine h M**. + 4

I e W NRMS a i e;n.e; ~ -..... n

w...

1 S. E. M O D 2084 2870013370 i A T T A C H M f. 4 r l ^ CU-Cal-CC34S 1 November 1984 2 8 b I i SAFITY EVALUATION OF MODIFICATION 1D 14CE OPEN t. 1 EE2 MIiEAUM F1DW VALVE I i FOR FIACE tofftM 2/3 4 l' 1 Q. ~~ '^' Propered by: F73.'v P.T. Tran, thsineer t }. . Applicatico Englasertag Services I Verified by: [ M Vf d ,U.C. Serena, Senior Engineer , Application Engineering Servicae -{s l e J I Approv.d 6 : dA4+.. ' a 7 y CfL[Sessi, d r 1 1 t ~ Applicat tori Engineering Services r' = p p -1 .s Q. Biller AL $ ELECTRIC 4 -7'.- ..=. w__m_

g Mm W ~.-. m. J i i ... m = .t 2,.u. c.... v.

1.,~

h.a. ~...

.~g.

2870013370 t SAFETT ETA 1MT1W W IEBIFICAT1t3110 8m WWI RER MINDUt F1Anf V&1.VI PW_FRM3 IINT9L1/J IEF C41 00045 November 15)6 The fire hasard analysis for Peach Bottos 2/3 identif 6ed a potential for the EER p a y to start with the sintaus flow valves not able to open. To address ) this potential eeneere, an interim modification to lock the sint== flow valve { eyes has hoek. identified.1The sind flow is typically about lot of rated -~ a,.' :c flow. This has the potential for reducing the Imv Pressure Coolant Injection (1.PCI) ande flow rate to a value less than that assumed in the current licensing hemis. b refore, the et of the reduced LPC2 flow rate on the 1imiting taas of Coolant Acciden JtACA) pipe breaks and single f ailursa was investigated. M ~^ 5. . '~ 'The most limiting taCa far Peach Betten 2/3 is a large recirculation ' discharge .,+, -T' 'line break with a single failure of the LPCI-injection valve in the tet,soken

.r s

t # uscircu1Atten laep.: The temstains toergency Core Cooltag (BCC) systems, e 4+ a._,. 'ing Peak Cladding Temperature (PCT) and Manimus Avere;e Planar m I I "A, Lemmat Best. Generation Rats (MAPIER) fer this event are shown in gable 1. A _, y m,. .;.,.. redeetten la rated LPCI tajection would have as impact on this event since these la me eredit for LPCI. core cooling. ' l. 'd. ,, g. The east most 18mittag laCA is a large recirculation discharge 1ine break with

..$^'

'K i'- t ~ v. g,;.' -. a fa11ere of a diesel stor and inelades credit for LPCI. coo 11., An .r/' f,,.i,./..'.analysishasbeen'perfo to evaluate the impact of reducing KER floe e x r .. J.i v ' eenservatively assentas that the estad LPCI flow is reduced by 101. The PCT m.c::ep.h. far this event increasee.by 40*F (as shown in Table 1),but is still well below '.p;;:rg,g[the 11mittag breek fCT.J.!Therefore,' reducing the LPCI flow by 101 of rated has ~. ...e m.... -.4 gf.g j ?% p1,...'.as' tapeet se 7 mach Betta 1/3 MAP 13GR limits. f dQ 3 NKrlD,ffTC.;.p$, dig.i.b j'.f.A. .... e : a.. .w, &' 'v#.%- Adeltiemally the other

• andes of the RER system are onaffected by the l

{ em.:.:-,anelficatiek a~1ae all et$r Needas are manually eetested and have ~ [f relatteely lang regetr' ed operator response times. Therefore, there is i - time for the eperates to diagnose and correct the situation if the valves are open. f.hf.MEhj,3 C j}QM.vg.- a. ;.x:;.u....a g$.,... o ' m.w g l }' ,7. i i 4p' U *

• e*8 7 Q,.F,,.

. V.

c..

2 ,/. .= w %. " ' 'thmadJ" pte. h.. l.t. %.ema l.es* +.a.-M..., g g',.4., 8

• .4

~ * * - j

.lg h ^., F s N ".u , y %.

.c g.

tp. 287001337.0 a T/ .y s RISLA.T5 OF TEI ANA1YSIS FOR PROPOSED MODIFICATION AT PEACR BOTTOM 2/3 I d_ FEAE CIADDING TEMPERATURE ( F) l' i s i 1.IMI SING 1.5 ,J4 'l 1., 8YSTEMS 33P0t1 AFTER s ~.,} / ' IEH MEL.Em liramam AVAllABl.I ' MOD M CATION M gp m gA ygqqq i - _ b 2 ' 1.27 FT2

• 3

'I.PCI-IV. 2Cs g7CI tw$ g (661 DBA) f . c. :' c ,, d 9.,, 1.27 FT DG 1CS+11.,PCI+ 1608 1648 2 t RPCI tp,g 'a - 1.,..- . r. >~

, 4)[ s

,,l ) n bi * *.**'* 2. )., e., y:.. k. n. _y. 1.27 1 7.PCI-IV, 2CS+EPCI 1954 1954 4.%., r, s .?,; > ~ w a;, - ft ..g gr..t.n. m 4 ~%. @h,;. @.,..'...5 {.2 7 M,.,7 . - DG,.. ' 1CS+11.PCI+' 1597 1637 3-f y +1 ~ ' .,,{...s3 1 4 u.. .e.~. .g. 8 3d.fEi. ,,c=, 4r '. 5 g g.,..,9 ' *,L.f # - Af 'e l Q[,,... : ,..;.... -Q,;o; /, T ys :m.0 ' ..,. Q.'.. ',.. .g. 17 A . r.

l l

, u ',e r .r, .,.es~" . q. t. - ** s \\ ,d, ~.,' '" d, a ;

• ' Y. 4.'a,yr s.. -r s,a.J.fi -sb '. e
• *l

.) M,k$ b, 2* '.U,,. t...,. ~ "Nd AD$'d !.]., d.. y:,.r g - c. .r- , *4nc W,, a% J.,,,.q A y-.s - )'.. a- , pil:nf r

• Wa,-. M,3 g.p: ; $,,;p,;4,7!.Tf p3ee,,

wa A.. w. gr. wa s ,.s M. ~ ~, % % pf..,u n % ' k.* M. h n;21~7'?;.',R4l, Q ul, &..' W & '.. nfJt '1 * ^' s ' h&,2rY& 50.Wf.2 : y $4Y. \\ .~

r. -

9.-

.- m '*f y g"AfWW gw s -u - s * ,n,. .,e ~ Os 4' N a.a%w. e . _a -,sn.w' n;m . 3 s v%. r if w:r w. [ g, g D '.. 4.wg' f g e.v .o - ?

[j.

l E Y.Ni, / y,y a l r 1 ' *-==,,4 7' . //.3, I ) ae .,/ 3 O s Th*4.g-gk t k. V b.% M' W%. '.M.c.'?hM.'. f ? - Y! or 'v' E m.au : ~me P.,.s N.$ WNUWAV5?D.WY f.~n n '". Y udc , b., Y., :r:. ~ a &..mv.e.>%3d.uL.W 8*h,W- * :* n x-u t J~ ~ .h+ wg. y l U" l l = -. _ _ % mm.=r gg %w 4... wws-. se s.. e. I' a

't (J s Safety'Evaluailon for Med 2091. /' Peach Bottom Atonic Power Station y <7

1) nits 2 & 3 1

Revision 0 I. SUBJECT t This modification provides fire protection for electrical menholes located in the plant yard area which, if affected by a fire, could adversely affect safe shutdown capability required by Appendix R to l 10CFR50. Canbustible liquid will be prevented fran flowing into the electrical manholes. II. CONCLUSION This modification does not affect safety-related equipment. The modification does not involve any unreviewed safety qusstion. The modification does not require a change to the Technical Specifications. The modification nelntains safe shutdown capability in the event of a fire. The modification does not require a licensa anendment-nor does it. involve a significant hazard detennination. III. DISCUSSION Electrical' manholes (EMH) 016,017,018,025,026,040 and 090 contain safe shutdown cables. Safe shutdown capability could be adversely affected'by an external fire in the vicinity of the manholes which involves more than one manhole or more than one compartment i for ENH 025 and 026. An Internally generated fire contained within a single nenhole for EMH 016,017,018,040 and 090 or contained within a single compart.nent for Ett 025 and 026 (four compartments per manhole) will not jeopardize safe shutdown. There is no fixed combustible noterial in the innediate vicinity of any of the manholes containing safe shutdown cables. Canbust ibl e 11 auld from a transient source, If ignited and allowed to enter selected manholes simultaneously, could have an adverse impact on safe shutdown. EMH 025 and 026 are located near the diesel fuel oil connection for the diesel fire punp. Concrete walls around the perineter of the manholes and between manhole conpartme5ts will be raised 6 inches above grade. Existing, 3/8 inch steel checker plate manhole covers, which no longer provide a tight seal, will be replaced with new gasketed checker plate covers. Open pipe penetrations between compartments within the manholes will be sealed with an approved fire stop. EMH 016,017,018 and 040 are separated from each other by concrete walls and covered with 1 1/2 inch thick steel menhole covers. The I f '- covers are of substantial enough construction to withstand a fire fran spilled combustible Ilquid. Covers will be gasketed to ensure that combustible 11ould will not enter the nenholes. Open pipe penetrations between menholes will be sealed with an approved fire }- stop. l.

l (: (: .e f i EMH 090 is separated from other manholes by concrete walls and two side by side 1 1/2 Inch thick steel covers. A sna11 gap between the covers will be sealed with 1 1/2 Inches of penetration sealing noterial to provide a continuous cover which wl11 be of substantial i enough construction to withstand a fire from spilled combustible 11guld. The cover will be gasketed-to ensure that combustible ' liquid will not enter the manhole. j The modification does not affect the plant as described in the UFSAR, Section 10.12. The protection provided for the manholes will assure that safe shutdaan capability is nelntained during a fire as described in Section 6.3 of the Peach Bottom Fire Protection Program report. The modification ensures that the capability to safety shutdown the plant in the event of a fire is maintained. IV. 10CFR50.59 Changes, Tests and Experiments 1. This modification does not involve any unreviewed safety question because: a. The modification will not increase the probability of occurrence or the consequences of an accident or mal function of equipment important to safety as previously evaluated in the UFSAR. The modification will enhance fire protection capability reducing the effects of a fire on the plant, b. This modification does not create a possibility for an accident or malfunction of a different type than previously evaluated in the UFSAR. The installation of penetration seals between internal manhole canpartments for EMH 025 and 026, the sealing of penetration between menholes, the gasketing of manhole covers, and the raising of concrete perimeter curbing around EMH 025 and 026 does not affect the function of any safety-related equipment. Therefore, the plant as described in the UFSAR is not affected. c. ~in.... modification does not reduce the mergin of safety as defined in the basis for any Technical 1 Specifications. Technical Specification 3.14 was 1 reviewed in making this detennination. l 2. A change to the plant Technical Specifications is not i required. Technical Specification 3.14 was reviewed in { ( neking this detennination. L V. 10CFR50.92 Significant Hazards Detennination A license anendnent is not required; therefore this section is not applicable. I

( ~3-l. I VI..)PPROVALS: Prepared by ( Date: _t 13 0] / (Responsible Engineer) e Reviewed by b fr Date: l 4 &T (Lead Div. Independent Reviewer) l llNfR7 'Date: Lead Division (BFan Head or Section Head) '/ f: - $b Date: I 23kW Non-Lead sion Responsible Engineer i U' Yi111Cf ll2Al97 Date: Non-Lead DJ(/Tsion Independent Reviewer //' //d/c!P7 dh Date: i N.n-Lead Divis n/(BrangiHeadorSectionHead) ? Il Date: 2 7 i ' Ndclear and En ronmental Sec ion Head / CJG/pms/10298601 Copy to: DISTRICODE MESE-PBAPS DAC (NG-8) 3 i _}}