IR 05000529/1985011

Forwards Rev 0 to 02-NS-110, 10CFR50,App R Safe Shutdown Evaluation,Outside Control Room Fire Spurious Actuation Study, for Use in Reviewing 10CFR50,App R Safe Shutdown Concern Noted in Audit Rept 50-529/85-11

ML17299A575
Person / Time
Site:	Palo Verde
Issue date:	08/30/1985
From:	VAN BRUNT E E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	KNIGHTON G W Office of Nuclear Reactor Regulation
Shared Package
ML17299A576	List: IR 05000529/1985011 ML17299A575 ML17299A577
References
ANPP-33307-EEVB, TAC-59247, NUDOCS 8509050206
Download: ML17299A575 (10)

Text

REGULATORYgNPORMATION DISTRIBUTION SQTEM (RIBS)ACCESSION NBR:8509050206 DOC~DATE: 85/08/30 NOTARIZED:

NO DOCKET FACIL:STN-50-529 Palo Verde Nuclear StationE Unit 2E Arizona Publ.i 05000529 AUTH BYNAME AUTHOR AFFILIATION VAN BRUNTEE.E.

Arizona Nuclear Power Pr oject (formerly Arizona Public Serv REC IP~NAME RECIPIENT AFFILIATION I KNIGHTONE G~N~Licensing Branch 3 SUBJECT: Forwards Rev 0 to 0?-ns-110<

"10CFRSO<App R Safe Shutdown Evaluation<Outside Control Room Fire Spurious Actuation Study'" for use in reviewing 10CFRSOEApp R safe shutdown concern noted in Audit Rept 50-529/8S-il, DISTRIBUTION CODE: BOO?D COPIES RECEIVED:LTR ENCL SL Eo., sl~/TITLE: Licensing Submittal:

Fire Protection NOTES:Standardized plant~050005?9 RECIPIENT ID CODE/NAME NRR LB3 BC COPIES LTTR ENCL'1 RECIPIENT ID CODE/NAME LI CITRATE E 01 COPIES LTTR ENCL 1 INTERNAL: ACRS ELD/HDS3 NRR/DSI/ASB RGN5 10 6 6 1 0 1 1 1 1 ADM/LFMB/CEB 06 EG F 04 1 0 2 2 1 1 EXTERNAL: 24X NRC PDR 02'1 1 1 LPDR NSIC 03 05 TOTAL NUMBER OF COPIES REQUIRED: LTTR 19 ENCL 17 I I'I II I 1'I Arizona Nuclear Power Project P.o.BOX 52034~PHOENIX, ARIZONA 85072-2034 Director of Nuclear Reactor Regulation Attention:

Mr.George W.Knighton, Chief Licensing Branch No.3 Division of Licensing U.S.Nuclear Regulatory Commission Washington, D.C.20555 August 30, 1985 ANPP-33307-EEVB/DKN Subject: Palo Verde Nuclear Generating Station (PVNGS)Unit 2 Appendix R Audit Open Item (50-529/85-11-01)-Docket No.STN 50-529 File: 85-056-026'.1.01.10 References:

1)Letter to G.W.Knighton, NRC, from E.E.Van Brunt, Jr., ANPP, dated November 13, 1984;Subject: 10CFR 50, Appendix R Spurious Actuation Analysis (ANPP-31101)

2)Letter to G.W.Knighton, NRC, from E.E.Van Brunt, Jr., ANPP, dated May 22, 1985;Subject: Appendix R Audit Open Items 50-529/85-11-01 and 50-530/85-08-01 (ANPP-32700)

(3)NUREG-0857,"Safety Evaluation Report Related to the Operation of the Palo Verde Nuclear Generating Station, Units 1, 2, and 3", Supplement No.7, dated December 1984.

Dear Mr.Knighton:

In response to NRC Appendix R audit open item 50-529/85-11-01 requesting plant differences between Unit 2 and Unit 1[Reference (2)], we advised that the results of the Unit 2 safe shutdown, spurious actuation and cable routing differences from Unit 1 would be submitted to the staff for review by October 1, 1985.Enclosed is the Unit 2 Outside Control Room Fire, Spurious Actuation Study for your use in reviewing the 10CFR 50 Appendix R spurious actuation concerns.This evaluation has been performed based on the methodology discussed in Reference (1).The results indicate that the operator will be able to identify and mitigate the consequences of spurious control action/interactions to achieve and maintain a safe cold shutdown of Unit 2 as was demonstrated for Unit 1.Please note that the Control Room Fire Spurious Actuation Study was previously completed for all three units and submitted with Reference (1).In section 3.1, General Operational Considerations, (page 8)of the study, subitem 3 repeats three plant changes or operational considerations completed for Unit 1 which must be implemented in Unit 2.9p>p>pb Bspmp ABQCg pgppp~>9 PDR l 0~~r i'W g'!(1 G.L4.Knighton t Appendix R Open Item ANPP-33307 Page 2 I The first item requires placing the breaker for shutdown cooling (SDC)suction valves J-SIC-UV-653 and J-SID-UV-654 in the open position during normal plant operating conditions when Reactor Coolant System (RCS)pressure is greater than the SDC system suction isolation interlock setpoint.This has been accomplished by incorporating this operating condition into Procedure No.420P2SI02 for Unit 2 as it was in Procedure 410P1SI02 for Unit l.The second item pertains to pressure switch J-CHA-PSL-216.

The switch has been relocated in all three units by, DCP 10JCH 190 (Unit 1)completed and closed March 26, 1985;DCP 2SJCH190 (Unit 2 completed and closed March 20, 1985;and 3CJCH 190 (Unit 3)completed and closed July 17, 1985.This design change for all three units relocated the Train A charging pump pressure switch from the adjacent corridor containing Train B circuits to the Train A charging pump room and resolves the separation concerns regarding this switch.The third item pertains to the atmospheric dump valve (ADV)nitrogen supply.This is addressed in FSAR Section 9B.2.12.1.C2,Section III.G, Deviations from 10CFR 50, Appendix R, Section III.G for the Main Steam Support Structure Fire Area XII Zones 74A and 74B.This deviation was reviewed and evaluated by the NRC staff as documented in Reference (3), Page 9-13 and found to be in"...accordance with the technical requirements of Section III.G of Appendix R and is, therefore, acceptable." Therefore, this item has also been satisfactorily resolved.The evalu-ation applies to all three units.The results of the Unit 2 Outside Control Room Fire, Spurious Actuation Study will be incorporated into the Pre-Fire Strategies Book for Unit 2 as was done for Unit 1.It will include the Evaluation Findings, Key Monitorable Parameters, Time Constraints, Operational Considerations and Compensatory Measures for fires in each fire zone.These will be the same as for Unit 1 with the exception of those zones outlined in the enclosed summary and will be done by fuel load.The Unit 2 Appendix R Separation Evaluation was also performed and the results indicate that Units 1 and 2 have basically identical circuit routings.One significant routing difference and a few minor circuitry differences were found to exist between Units 1 and 2.Circuits affected by the minor routing differences are located within the same fire zones as their Unit 1 counterparts and have no impact on train separation.

The only significant routing difference found is for the shutdown cooling containment Isolation Valve J-SIC-UV-653.

In Unit"1, a Train A safe shutdown circuit going to Valve J-SICUV-653 is routed in a cable tray that circles the charging pump rooms.The tray is located"in fire zone 42C, which is predominately Train B, and is protected by a 1-hour fire rated wrapping.In Unit 2, the same shutdown circuit has been routed in Conduit EZA1DCRK07 through fire zone 42D (Train A), with a small portion of conduit passing through fire zone 42C..That portion of the conduit passing through fire zone 42C is protected by a 1-hour fire rated wrapping, with detection and cable tray water suppression.

That portion passing through 42D does not need any wrapping since zone 42D contains Train A raceways.

r~~~II al C.W.Knighton'ppendix R A'udit Open Ite ANPP-33307 Page 3 This letter and the enclosed study should provide the necessary information for your review and closure of the referenced audit open item.Please contact Mr.W.F.Quinn of my staff if you have any questions.

Very truly our EEVB/DKN/slh E.E.Van Brunt, Jr.Executive Vice President Project Director ceo E.A.Licitra D.J.Kubicki R.P.Zimmerman A.C.Gehr (all w/a)

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George W.'nighton, Chief~Appendix R Audit Open Iten~ANPP-33307 Page 4 bcc: D.B.Karner A.C.Rogers W.F.Quinn T.F.Quan J.T.Barrow S.R.Frost T.J.Bloom LCTS Coordinator K.W.Gross J.M.Allen J.R.Bynum W.F.Fernow J.W.Rowland D.K.Neal C.N.Russo W.H.Wilson S.Shepherd C.F.Ferguson M.Barnoski 4055 6075 6130 6125 6130 4053 6330 3F6 3F6 r f