ML17324B219

Review of App R Procedures for Post-Fire Remote Emergency Shutdown Outside Control Room,Dc Cook Nuclear Plant Units 1 & 2, Technical Evaluation Rept

ML17324B219
Person / Time
Site:	Cook
Issue date:	11/06/1986
From:	FRESCO A BROOKHAVEN NATIONAL LABORATORY
To:	Office of Nuclear Reactor Regulation
Shared Package
ML17324B217	List: ML17324B219
References
NUDOCS 8702030539
Download: ML17324B219 (15)

Text

BROOKHAVEN NATIONAL LABORATORY TECHNICAL EVALUATION REPORT FOR U S NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION

'PWR DIVISION OF LICENSING-GROUP A PLANT SYSTEMS BRANCH REVIEW OF APPENDIX R PROCEDURES FOR POST-PIRE REMOTE EMERGENCY SHUTDOWN OUTSIDE THE CONTROL ROOM LICENSEE: Indiana&Michigan Electric Company FACILITY: D.C.Cook Nuclear Plant, Units 1&2 REVEL CONDUCTED:

October 27-29'986 NRC REVIEWERS:

A.Singh, NRR D.Wigginton, NRR BNL TECHNICAL SPECIALIST:

Anth y Fresco (Mecha cal Systems)/I 0 ate BROOKHAVEN NATIONAL IABORATOR" lp gQ I ASSOCIATED UNIVERSITIES, INC.CI LI I 8702030539 870128 PDR ADOCK 05000315 F PDR

~~-ii-CONTENTS Section Page 1 GENERAL

SUMMARY

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~2~PERSONS CONTACTED~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~e e 2 3~DOCUMENTS REVIEWEDe~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~3.1 3~2 3.3 NRC Co rr capo nd enc e.~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~Licensee Documents.

~~.~~~~~~..~~.~~~~~~~~~~..~~~.~.Procedures.

~~~~~~~~~~~~~~~~~~~~~.~~~~~~~.~~..~~~...~~~~~~~~~~~~~e~~~~~~~3 3 3 4~POST FIRE SAFE SHUTDOWN e~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~'~~~~4.1 Systems Required for Safe Shutdown.~~~~~~~~.~~~~~~~4.2 Areas Requiring Alternative Shutdown.~~~~~~~~~~~~~~~~~~~~~~~~~~~~4 6~PR C DURFS~~~~~~~~~~~~~~~~~~~~~~~~~e~~~~~~~~~~~~~~~~~~~~~~~~~~~5.1 Procedure for Unit 1 Remote Emergency Shutdown.~~~~5.2 Repair Procedures Required to Achieve Cold Shutdown~~~~~~~~~~~~~~7 10 ee 1~GENERAL

SUMMARY

During the time period of October 27-29, 1986, a team of NRC personnel from the Office of Nuclear Reactor Regulation, Plant Systems Branch and the Division of Licensing personnel and A.Fresco of BNL conducted a special review and walk-down of the emergency remote shutdown and associated repair procedures as re-quired by the November 22, 1983 Safety Evaluation Report for the Alternate Shut-down Capability at the D.C.Cook Nuclear Power Plant, Units 1 6 2.The team members were assisted in the walkdown by the Senior Resident Inspector.

The results of this review will be transmitted to Region III Headquarters.

The review was not intended to address other Appendix R issues, such as separation of components required for safe shutdown, associated circuits, or fire protection features.In general, the licensee's procedures were found to be workable but certain steps require reorganization, revision, or amplification to provide additional guidance to the operators.

A potentially serious problem was identified to the licensee in a post-review conference call on November 5, 1986 concerning Attach-ment Nos.3 and 7 which relate to local manual de-energization of breakers in the Switch Gear Rooms to prevent spurious operation of pumps and valves.If a fire occurred in the Switch Gear Room, the alternative local operations were not'escribed in the procedure, and upon discussion with the licensee, appeared to involve pneumatic or electrical jumpering during Hot Standby or Hot Shutdown conditions.

See Section 5.1.1(d)for further discussion.

Possible problems were also identified with emergency lighting.The arrangement and usage of.the cross-ties'nd opposite unit equipment to achieve safe shutdown in the affected uni(required clarification and an overall analysis to justify the actions'aken in'"the procedures to achieve the perfor-mance goals of Appendix R, e.g., isolation of letdown flow, usage requirements for pressurizer PORVs and heaters, etc.was not available during the review.It was also recommended that the licensee provide a chart indicating the assignment of the personnel required to implement the procedure.

The licensee was advised that if any local operator actions are required to be performed in the yard area, e.g., verification that the flow path is available and there is a sufficient high pressure nitrogen supply for steam generator power-operated relief valve operation, that 8-hour battery powered emergency lighting is required for the access path or else an exemption request should be filed.Finally, the team provided guidance to the licensee on the conduct of a full scope Appendix R audit.

2.PERSONS CONTACTED NAME W.G.Smith, Jr.J.E.Rutkowski PE Jacques K.R.Baker M.Onken R.Heathcote W.Nelson D.Rumpf H.Rumser G.Tollas J.St.Amand J.Conrad J.Stubblefield C.Miles J.Feinstein A.Auvil R.L.Shoberg W.G.Sotos E.Brown G.Weber B.Jorgensen TITLE Plant Manager Ass't Plant Mgr.Quality Control/Fire Protection Coord.Operations Operations Operations Operations Operations Operations Operations Operations Operations Training I&C Planning Mgr.-Nuclear Safety Licensing NS&L...Asst.Section Mgr.-I&C I&C Electrical Engineer Section Manager S enior Resid ent Inspect.COMPANY Indiana&Michigan Electric Co.I&M I&M I&M I&M I&M I&M I&M I&M I&M I&M I&M I&M I&M American Electric Power Service Corp.AEPSC AEPSC AEPSC AEPSC Impell Corp.USNRC 3~DOClJMENTS REVIEWED 3.1 NRC Corres ondence 1.Letter to J.E.Dolan, Indiana and Michigan Electric Company (1&M)from Mr.C.E.Norelius, NRC Region III, dated September 22, 1982 transmit-ting the results of Appendix R audit conducted April 12-16, May 14, June 10, 1982 at D.C.Cook.2.Letter to Mr.J.E.Dolan, I&M, from Mr.S.A.Varga, Operating Reactors Branch No.1, Division of Licensing, dated November 22, 1983 transmit-ting the Safety Evaluation Report on Alternative Shutdown Capability at D.C.Cook.3.2 Licensee Documents 1.Indiana&Michigan Electric Company,"Nuclear Regulatory Commission-Appendix R Audit-October 27, 1986-Alternate Shutdown Capability-Donald C.Cook Nuclear Plant-Bridgman, Michigan." 3.3 Procedures ZD No.Title Rev.Effective Date l.**12WHP 4023.100.001

=Unit 1'Emergency Remote Shutdown 0 2.**1MHP2140.082.001 Maintenance Procedure for-1 Repowering an"kHR Pump 6/10/86 10/23/86 3.**1MHP2140

~082.003 Maintenance Procedure for Repowering Pressurizer Backup Heat ers 10/23/86 4~**1MHP2140.

082.005 Maintenance Procedure for Repowering Containment Valves 10/23/86 6.**1 THP 6030 IMP.305 Appendix R Post-Fire Repowering 1 of In-Containment Valves 5.**1 THP 6030 IMP.304 Pressurizer PORV Cable Repair 1 8/14/86 10/23/86 4.POST FIRE SAFE SHUTDOWN 4.1 S stems R uired for Safe Shutdown The licensee provided a brief presentation of the systems required for safe shutdown.The team reviewed this within the time available as background infor-mation 5ustifying the actions to be taken in the procedures.

4.1.1 Reactivity

Control Initial reactivity control is provided by tripping the reactor control rods using the scram switches in the main control room.The reactor can also be scrammed by tripping the turbin'e at the front standard and also at other unspecified locations'dditional negative reactivity to achieve the required boration margin is'rovided by the borated water in the Refueling Water Storage Tank utilizing the opposite unit's charging pumps discharging into the reactor coolant pump seal infection lines.The licensee was advised to have available, for the full scope Appendix R audit, an analysis showing that the RWST alone does provide sufficient negative reactivity capability to achieve and maintain cold shutdown.4.1.2 Reactor Coolant Makeup (Inventory and Pressure Control)Inventory control of the reactor coolant system is provided by the reactor coolant pump seal infection pines.and charging system.For alternative shutdown outside of the affected urii't.'.s control room, seal infection is provided by the opposite unit's charging'pump'via a discharge header unit crosstie to RCP seals.Charging through the normal charging line can be provided by the oppo-site unit's Boron Infection flow path.The system alignments are summarized in the licensee's introductory presentation on alternate shutdown capability (Ref.3.2-1)as follows: Borated Cooling Water Source: Opposite Unit's RWST or Affected Unit's RWST (via unit crosstie)Opposite Unit's CVCS Auxiliary Systems: Opposite Unit's Emergency Power System Opposite Unit's HVAC Opposite Unit's CCW Control: Normal valve and pump control on opposite unit Local manual control of valves on af f ected unit Instrumentation:

Local shutdown panel powered from opposite unit Other local self-powered indict6rs Pressurizer level is controlled by supplying sufficient volume flow to support a 25'F/hour cooldown rate.The licensee's position on pressurizer pressure and use of the pressurizer PORVs during hot standby and hot shutdown is that the heat losses from the pressurizer are such that pressure will be rehuced within a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> period to allow use of the residual heat removal (RHR)system without use of the pressurizer PORVs and that the PORVs are not required to maintain hot shutdown.The licensee did not provide the analysis to)ustify this but was advised that the analysis should be available for the full scope Appendix R audit.The cables to the PORVs can be repaired to allow pressure control during the transition to cold shutdown.4.1.3 Decay Heat Removal For loss of offsite power conditions, natural circulation is established by dumping steam from'at least two of the four steam generators via the atmospheric steam generator PORVs with makeup to the steam generators provided by the Auxil-iary Feedwater System from the Condensate Storage Tank to support a 25'F/hour cooldown rate.Ref.3.2-1 describes the system alignments as follows: Auxiliary Feedwater is provided by either the affected Unit's turbine-driven pump via the normal flow path or either of the opposite Unit's motor-driven pumps via a discharge header unit crosstie to the normal flow path.Cooling Water Source: Auxiliary Systems: Opposite Unit's CST.Affected Unit's CST Lake Michigan via opposite Unit's essential service ,water Opposite Unit's Emergency Power System (MDAFP use)Opposite Unit's HVAC (applies only to one of the opposite Unit's MDAFP)Control: Local control panel for TDAFP Normal valve and pump control for opposite Unit's MDAFPs Local manual control of valves on affected unit Instrumentation:

Local TDAFP Panel (Turbine Speed)The steam generator PORVs are powered from the alternate source which is the backup nitrogen supply located in the yard area.Control is at either local control panels or as a backup by local manual operation of the valves'andwheels.

Instrumentation is at a local shutdown panel powered from the opposite unit and at other local self powered indicators for the N2 supply.4.1.4 Support Systems and Process Monitoring Instrumentation The front-line systems are supported by the systems described in 4.1.1 to 4.1.3 while process monitoring is provided at local control panels within the plant.Neither of these aspects were reviewed in any detail due to time con-straints.

4.1.5 Cold Shutdown The RHR system is used to achieve and maintain cold shutdown.RHR is pro-vided by either train of normal RHR powered from the opposite uniE.Ref.3.2-1 describes the system" alignments as follows: Auxiliary Systems: Opposite Unit's Emergency Power System Opposite Unit's ESW (via unit crosstie)Opposite Unit's CCW (via unit crosstie)Control: Temporary RHR pump control from opposite unit, Normal ESW and CCW pump and valve control from op-posite unit Local manual control of RHR, ESW, and CCW valves on affected unit Instrumentation.

RHR pump load from temporary RHR pump control station in opposite Unit's control room (Valve operation coordinated with indications provided at local shut-down panel at another location)The licensee has developed repair procedures for repowering an RHR pump, pres-surizer backup heaters, pressurizer PORV cables, and in-containment valves'nly repair of the RHR pumps and pressurizer heaters was discussed in the Safety Evaluation Report (Ref.3'1-.2)~No mention is made in the SER concerning the use of the pressurizer PORVs.;IC was suggested to the licensee that their use be..clarified for the full-scope'.audit as mentioned in 4.1.2 above.I 4.2 Areas R uiri Alternative Shutdown There are four areas in each unit which require implementation of the remote shutdown procedure in the event of a fire:~Control Room Cable Vault Auxiliary Cable Vault~Switch Gear Room~Control Room Since there is a 3-hour rated fire barrier between each unit's control room and there is significant crosstie capability between systems required for safe shutdown, the Shift Supervisor directs operations from the opposite unit's con-trol room.The hot shutdown panels located within each control room were not designed to meet the demands of a fire as postulated by Appendix R.

5~PROCEDURES The procedure reviewed in detail and walked though during this plant visit was:**12-OHP 4023 100 001,"Unit 1 Emergency Remote Shutdown," Rev 0, 6/10/86 This procedure is structured with a main body and eight attachments'ttachment No.1 relates to the establishment of the charging header crosstie from the op-posite unit while No.2 provides for the initiation of Auxiliary Feedwater flow.ttachment No.3 concerns isolation of the Reactor Coolant S stem and th enerators g ors and No.4 pertains to control of the steam generator PORVs~Attach-ment Nos~5&6 describe the steps to provide RHR cooling using Unit 2 Essential Service Water and Component Cooling Water Pumper'ttachment No.7 instructs the e-energization of'quipment from the switch gear rooms to prevent spurious actuations and No.8 provides for the restoration of offsite power.The repair procedures were also reviewed but in less detail.5.1 Procedure for Unit 1 Remote Emer enc Shutdown The licensee personnel explained, by means of a hand-drawn chart, the reas-signment of the normal plant operating staff to form the fire brigade and to implement the procedure.

The results was that four operations personnel are required to implement the procedure, three from the affected unit and one from t e unaffected unit.The licensee was advised to provide a simplified staffing assignment chart'for the full;+cope Appendix R audit.Comments generated during the review and walkthrough will be provided s eparat ely below: 5.1.1 Review a)'ain Portion Step 4.2.2-It was recommended that this step, which directs the operator to locally trip the reactor, include the locations of other f tri i o er means o r pp ng the reactor outside the control room.These other loca-tions should be reviewed to determine their suitability under the conditions of a f ire requiring control room evacuation.

It was also recommended that the step include a statement instructing the operator to verify the control rod positions, if at all possible, before evacuating the control room.Step 4.2-3-This step directs the personnel to rapidly accomplish certain of the attachments with priority being given to Attachment Nos.1 and in e 2.Since Attachment No.1 concerns establishment f RCP 1 RCS n)ection flow to cool the seals and also to provide makeu t th the time available to perform these actions is typically at ma eup o e least one hour unless a pr essuriz er PORV has spuribusly opened.There are typically only 30 minutes available to provide AFW flow to the steam generators before boil dry so that performance of Attachment No.2 is usually more time limited.It was recommended that this be indicated in the procedure.

Note prior to Step 5.3.5 This note states that pressurizer PORV use is limited by the air bottle (N2)backup capability and that the Pressurizer Relief Tank (PRT)has no quench or drain capability and has been'receiving RCP seal leakof f.Further, it tells the operator to"Plan it care-fully." Upon discussion with licensee personnel, it was stated that there is adequate N2 supply to provide over 70 operations of the PORVs and that rupture.of the PRT rupture disks is not of con-cern except that extensive cleanup of the containment would be required.Again, it was recommended to the licensee that an analy-sis 5ustifying the N2 supply, the number of PORV operations requir-ed to depressurize, the assumptions regarding the rupture disk, and the overall usage of the PORVs be available for the full scope Appendix R audit.The licensee was also advised that if local operator actions are required in the yard area to assure adequate N2 supply to the PORVs that 8-hour emergency lights be provided for the access path or an exemption request should be filed.The licensee agreed with the team's concern over the use of the term"Plan it carefully", and indicated that the procedure would be re-vised accordingly to provide clearer instructions to the operator.b)Attachment No.1 There were no significant comments during the review process'~c)Attachment No.2\Caution-The caution states"Since core cooling mode is natural circula-tion, do not over f eed or overs team." The team express ed the concern that this appears to provide a rigid mindset to the operators that the procedure is only applicable for loss of uff-site power.There is a separate procedure for remote shutdown in the event of a fire with offsite power available.

However, there is no direct provision for the operator to return to that procedure in the event that offsite power is restored without onsite operator actions~The licensee agreed to revise the pro-cedure to address this concern.Steps 2.6, 3-6&4'-These steps instruct the operators to manually operate the handwheels on the AFW pump discharge lines to establish and maintain level in the steam generators without indicating a minimum recommended level.The team recommended that the licensee revise the procedure to recommend maintaining level at a point providing sufficient con-tingency.d)Attachment Nos.3 and 7 There were no significant comments on these attachments during the review but they were the subject of a conference call between the review team and the licensee on November 5, 1986.Specifically, No.3 concerns electrical isolation of the Reactor Coolant System and the Steam Generators to prevent spurious O e operation and No.7 electrical isolation of pumps and valves from the Switch Gear Rooms.BNL expressed the concern that the actions described in the Switch Gear Rooms, such as manually tripping the breakers, could not bg performed if the postulated fire occurred in the Switch Gear Rooms~The licensee's response was that the situation of a fire in the Switch Gear Room is covered by another procedure for remote emergency shutdown when offsite power is available.

This alternate procedure was not cross referenced nor was it reviewed by the team.Upon further discussion,'t appeared that it calls f or 3umpering of valves and/or breakers during the hot standby or hot shutdown conditions to prevent spurious operations.

The licensee was strongly advised that any jumpering is considered a repair and as such is not allowed during hot standby or hot shut-down conditions

~Also, it can not be stated that the two procedures are in par-allel since the procedure under review, i.e., for the case of loss of offsite power, does not cover a fire in the Switch Gear Rooms, which requires evacuation of the affected u'nits control room.Adequate and proper cross ref erencing, which the team felt is essential, did not exist in the reviewed procedure.

The licensee agreed to review the procedural response and methodology accordingly in preparation for a full scope Appendix R audit.e)Attachment Nos~4, 5, 6, and 8 There were no significant comments during the review phase except for any actions to be taken in the yard area to assure N2 supply and the provision of emergency lighting, as previously noted in (a)above (pertaining to Attachment No.4)~5.1~2 Walkdown a)Main Portion Some of the team members found the quality of the operators communicatioris skills to be poor at times.It should also be noted that hand-held radios are the only communications means available under loss of offsite power.In addi-tion, there are only two channels available, F-1 and F-2, and only one of those channels, F-l, is backed up by a repeater station.The repeater station is located in the Unit 2 Switchgear Room so that in the event of a fire in that Switch Gear Room, only the F-2 channel is available, which the licensee conceded has some difficult areas between which the communication is poor or non-.existent.There were no other significant comments noted during the walkdown.b)Attachment No.1 Step 1.1-'here appeared to be inadequate emergency lighting for the operator to check closed valves 1-CS-536 and 1-CS-534.Step 2.1-The sequence of actions to de-energize the breakers ag MCC 1-AZV-A and 1-AM-D appeared to be reversed.That is, it was more time effi-cient for the operator to perform the actions required at MCC 1-AM-D before MCC 1-AZV-A particularly since they ar'e at different eleva-tions~ Step 2.2-A similar problems exists in Step 2.2 in that it is easier to isolate control air to 1-RV-251, 1-RV-252, and 1-RV-255 near the Batch Tank before entering the Boron Injection Tank (BIT)Room to verify 1-IMO-255 and 1-IMO-256 closed so that it appears the order of the steps should be reversed.Emergency lighting at the Batch Tank" area was not available to perform the required functions while the emergency lighting in the BIT Room was inadequate being on only one side of the BIT, which is a very large and tall tank, while actions are required on both sides of the tank.Step 2.3-Since entry'into the BIT Room, as required by Step 2', and into the BIT Outlet Valve Room, as required by Step 2.3, necessitates the use of anti-contamination clothing, it is much less time consuming if the procedure included a note directing the operator to gather an extra set of anti-C's when performing Step 2.2 in preparation for Step 2.3.In summary, allowing for the inherent difficulties of performing this attachment with an inspector tagging along, it appears that the implementation is exces-sively long and can be'streamlined.

c)Attachment No.2 This attachment, which provides for initiation of Auxiliary Feedwater flow, was walked through by the Senior Resident Inspector whose comments follow: p General Comments~~'$1.The licensee should walk through each person on.each intended function.2.The licensee should assure independence of activities by various agents, i.e., which steps require prior communication and authoriza-tion.Step 2.0-In the event that the affected units turbine-driven AFW pump, (TDAFP)should fail to start or fail to run after starting, it required ap-proximately 10 minutes to simulate the initiation of AFM flow using the opposite unit's motor-driven AFV pumps.The licensee should determine if this time interval can be reduced.Steps 2.6, 3.6, and 4.5-The procedure should specify a quantitative throttle position for the operator to locally manually operate the handwheels of the AFW pump discharge control valves to maintain steam generator levels.(This comment is similar to the comment by the team on this step noted during the review process.)5.2 Re air Procedures Re uired to Achieve Cold Shutdown The procedures listed in Section 3.3, Nos.2 through 6 were briefly review-ed and appeared to be substantially detailed to facilitate implementation.

No walkthrough was conducted but a check was made of whether the tools and equip-ment required to implement the procedures were available onsite.This equipment was found to be in separately stored and labeled containers in areas readily accessible to plant maintenance personnel.

January 27 98.'i.DOCKET NO(S).~0->>5 and~0->>6 Hr.John Dolan, Vice president Indiana and Michigan Electric Company c/ooAmericanAElectric Power Service Corporation 1 Riverside Plaza Columbus, Ohio 43216

SUBJECT:

D.C.Cook Nuclear Plant, Units I and 2 DI STRIBDIION:

Docket Pile LocelPDR NRC PDR PWRf34 Reading BJYoungblood:

Reading MDuncan DWigginton ACRS(10)NThompson EJordan JPartlow BGrimes Notice of Receipt of Application, dated Draft/Final Environmental Statement, dated Notice of Availability of Draft/Final Environmental Statement, dated Safety Evaluation Report, or Supplement No.dated Environmental Assessment and Finding of No Significant Impact, dated Notice of Consideration of Issuance of Facility Operating License or Amendment to Faci 1 i ty Operating Li cense, dated Q Bi-Weekly Notice;Applications and Amendments to Operating Licenses Involving No ceded d*d d dd d.d d~d el3 Exemption, dated Construction Permit No.CPPR-, Amendment No.dated Facility Operating License No., Amendment No.Order Extending Construction Completion Date, dated Monthly Operating Report for transmitted by letter dated Annual/Semi-Annual Report-dated transmitted by letter dated The following documents concerning our review of the subject facility are transmitted for your information.

Enclosures:

As stated Office of Nuclear Reactor Regulation CC: See next page OFFICE/SURNAME)DATE I3 PWR$/4/PWR-~~~~~~~~~~~~~~~~~no an/.ra 01////87~~~~/(Pe~~~~~~~~~-A.DVa.gga.ntan....

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