ML20198D900

Forwards Revised Pages to 850430 Request for Exemption from 10CFR50,App R,Section Iii.G Requirements Per 850911 & 1015 Telcons.Requests Re Neutron source-range Signal Cable in Vapor Container Unnecessary Due to Redundancy in Channels

ML20198D900
Person / Time
Site:	Yankee Rowe
Issue date:	11/07/1985
From:	Papanic G YANKEE ATOMIC ELECTRIC CO.
To:	Zwolinski J Office of Nuclear Reactor Regulation
References
FYR-85-128, NUDOCS 8511130055
Download: ML20198D900 (40)

Text

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Te'epho"c(6 ") 8' -*'00 YANKEE ATOMIC ELECTRIC COMPANY TM0( 710-380-7619

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j?y) 1671 Worcester Road, Framingham, Massachusetts 01701

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) 8 l28 November 7, 1985 United States Nuclear Regulatory Commission Washington, DC 20555 Attention: Mr. John A. Zwolinski, Chief Operating Reactors Branch No. 5 Division of Licensing

References:

(a) License No. DPR-3 (Docket No. 50-29)

(b) USNRC Letter to YAEC, dated November 14, 1983 (NYR 83-220)

(c) YAEC Letter to USNRC, dated December 28, 1984 (FYR 84-116)

(d) YAEC Letter to USNRC, dated April 30, 1985 (FYR 85-49)

Subject:

Revision to Appendix R Integrated System Design Details

Dear Sir:

Reference (c) provided a complete response to the information requested in Reference (b). During the design phase, some modifications were required to this information. Reference (d) forwarded a revised document to the staff outlining these changes.

Attachment C to Reference (d) contains Yankee's exemption requests for exemptions from the requirements of Section III.G of Appendix R to 10CFR50.

On September 4, 1985, the NRC staff reviewers and consultants responsible for the review of Yankee's exemption requests visited the plant site to discuss their questions on the exemption requests and inspect the affected plant areas. On both September 11 and October 15, 1985, telephone conferences were held with the staff to discuss additional questions and cor.cerns dealing with exemption requests. These discussions have resulted in the following recommendations from the staff:

1. Remove Exemption Requests No. 11, 16 and 17 dealing with neutron

, source range signal cable in the Vapor Container. These are not required due to the redundancy in channels and the backup sampling capability.

2. Remove Exemption Requests No. 4 and 5 dealing with main coolant loop isolation valves. The justification for these should be handled as an associated circuits concern and not as an exemption from the fire protection requirements of Section III.G.

8511130055 851107 PDR ADOCK 05000029 F PDR I (I

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- United States Nuclear Regulatory Comission November 7, 1985 Attention: Mr. John A. Zwolinski Page 2

3. Other minor modifications involving which specific Section of III.G the exemption is being requested from.

L Attachments A B and C of Reference (d) have been revised to incorporate these staff recommendations. (copies of revised pages of these attachments are included with this letter. Areas which have been revised are indicated wiU a vertical line in the right-hand margin. In addition,-to facilitate staff review, a summary description of these changes has been prepared and is attached.

If you have any questions on this revised information, please contact us.

Very truly yours, YANKEE ATOMIC ELECTRIC COMPANY m

Georg apanic, Jr.

Senior Project Engineer - Licensing GP/dps

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Sununary of Revisions

1. Exemption Request Nos. 4 and 5 have been deleted from Attachment C.

Exemption Request No. 4 had requested an exemption from the requirements of.Section:III.G.2.b of Appendix R to'10CFR50. Specifically, the request-for an exemption was from the requirement to have 20 feet of horizontal separation without intervening combustibles between the control cables and switches for the eight Main Coolant Loop Isolation Valves (McLIVs) in the Main Control Room. The control cables and switches for all eight valves come together in Section 5 of the Main Control Board.

Exemption Request <Wo.,5 requested an exemption from the requirements of Section III.G.2.b of Appendix R to 10CFR50. Specifically..the request for an exemption was from the requirement to have 20 feet horizontal separation without intervening combustibles between the control cables and the main and dual contactors for all eight MCLIVs in the Switchgear Room. The cables and contactors are spaced out along a 20-foot section of the south wall of the Switchgear Room. The dual contactors are located in two (2) motor control centers about 20 feet apart, but only four (4) feet away from the south wall. The control cables come together in the overhead before penetrating the Main Control Room floor into Section 5 of the Main Control Board.

Both exemption requests were based on fire protection features as well as the control circuit design and system considerations. It was the staff's opinion that this request for an exemption from the requirements of

-Appendix R would be better suited for resolution as an associated circuits concern (i.e., based solely on circuit design and system considerations). Based on this, Exemption Request Bos. 4 and 5 have been deleted, and the text on the McLIVs in Attachment B (Associated Circuits of Concern) has been modified to discuss the circuit design and failure modes and the systems aspects of these valve failures in a more detailed manner.

2. -Exemption Request No. 11 has been deleted from Attachment C. Exemption Request No. 11 had requested an exemption from the requirements of Section III.G.2.d of Appendix R to 10CFR50. Specifically, the request

.for an exemption was from the requirement to have 20 feet of horizontal separation without intervening combustibles between the signsi cables from the four (4) neutron source range detectors in the reactor cavity of the vapor container. Due to the size of the reactor shield tank cavity, 20 feet of horizontal separation is not available.

The staff has stated that this exemption request is not required. With a loss of all four (4) neutron source range detectors, backup boron samples of the Main Coolant System are sufficient to meet the NRC criteria of Appendix R. -Therefore, Exemption Request No. 11 has been deleted.

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Summiary of Revisions

3. Exemption Request Nos. 16 and 17 have been deleted from Attachment C.

Exemption Request No. 16 requested an exemption from the requirements of Section III.G.2.d of Appendix R to.10CFR50. Specifically, the request for an exemption was from the requirement to have 20 feet of horizontal separation'between the signal cables for two (2) of the source range detectors in one (1) of two (2) loop compartments in the vapor container. Twos (2) signal cables are routed in a common conduit in Loop Compartment No. 2, while the other two (2) are routed through a conunon

conduit.in Loop Compartment No. 3. It is possible to be operating with

-the two (2) detectors with cables in a common conduit.providing the

~s ignal to the two (2) source range instrument channels in the Main Control Room. Exemption Request No. 17 was identical to Exemption

' Request No.16, except it dealt with the cable routing outside of. the biological shield'to the containment electrical penetrations.

The staff has stated'that this exemption request id~not required. If the two signal cables in one (1) conduit are in service to the Main Control Room channels and they are both lost in a fire, the remaining'two (2) signal cables will remain operable. One (1) is connected to the instrument channel of the Safe Shutdown System; the other is available in the Main Control Room, and can be connected to one (1) of the source range channels in place of a damaged cable. In addition, the backup boron sampling capability discussed above is also available. Therefore, Exemption Request Nos. 16 and 17 have been deleted.

4. The first sentence of Exemption Request No. 7 has been changed from "an automatic" to'"a fixed Fire Suppression System." This was missed when Reference (d) was issued. Reference (d) modified Exemption Request No. 7 to request an exemption from a fixed fire suppression system.

5. Exemption Request No. 12 has been revised to request an exemption from adding a fixed fire suppression system and fire detection throughout the Primary Auxiliary Building as required by Section III.G.3 of Appent a R.

Exemption Request No. 12 had previously requested an exemption from adding an automatic fire suppression system as required by Section III.G.2.c of Appendix R.

A fire in the Primary Auxiliary Building could cause a loss of all three charging pumps disabling normal primary water addition. This fire would I not prevent the Safety Injection System from being used for primary water addition.- Therefore, the loss of all three charging pumps from a fire is acceptable. However, Yankee did not consider the Safety Injection System as an alternative shutdown capability as defined by Section III.G.3 of Appendix R. " Alternative shutdown capability" is defined by Appendix R as being provided by rerouting, relocating or modification of existing j systems, and the Safety Injection System does not require any j modification to be used to back up the charging pumps.

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Summary of Revisions This situation has since been clarified by Enclosure 6 of Generic Letter 85-01, Appendix.R, " Questions and Answers." The response to Question 3.8.3 states "if the system is being used in lieu of the preferred system because the redundant components of the preferred system do not meet the separation criteria of Section III.G.2, the system is considered an alternative shutdown capability." jutis therefore means that the Safety Injection System does provide alternative shutdown

' capability for the charging pumps for a fire in the Primary Auxiliary Building.

This required changing Exemption Request No. 12 to request the exemption from installing a fixed fire suppression system as required by Section III.G.3 instead of an automatic fire suppression system as required by Section III.G.2.c. This also required additional information on the Primary Auxiliary Building fire assessment in Attachments A and B as well.

6. Attachment B, Associated Circuits of Concern, has been revised to reflect that theLeevisions proposed"to the Reactor Coolant System vent valves require a change to plant Technical Specifications. A copy of the

. proposed change, No. 195,-is added to Attachment B.

7. Exemption Request No. 15 has been deleted from Attachment C. An exemption was requested from the 20-foot separation criteria of Section III.G.2.d of Appendix R. An exemption was required since the

. proposed rerouting for the signal cable from PR-LT-8 did not provide the required 20-foot separation from the signal cable for PR-LT-705 outside of the biological shield. Both are pressurizer-level transmitters.

The plant is shut down for refueling, and these modifications are in

-progress. Problems occurred with the proposed rerouting that required issuing this exemption request. As a result, both signal cables for PR-LT-8 and 705 are being rerouted such that 20-foot horizontal separation will be provided outside of the biological shield. Therefore,-

Exemption Request No. 15 is no longer required.

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ATTACHNENT A APPENDIK R REASSESSMENT DESIGN INFORMATION Enclosure 2 of April 28, 1982 MRC Letter

, Rewrite of Section 8 of G.L.81-12. Request for Additional Information Question '

1. Identify those areas of the plant that will not meet the requirements of Section.III.G.2 of Appendix R and, thus alternative shutdown will be

.provided or an exemption from the requirements of Section III.G.2 of Appendix R will be provided. Additionally provide a statement that all other areas ~of the plant are or will be in compliance with Section III.G.2 of Appendix R.

Response

1. The Yankee Plant has been broken down into the following nine fire areas, each of which contains safe shutdown equipment:

o Vapor Container o Primary Auxiliary Building o Diesel Generator Building o Nonceturn Valve Enclosure o Screenwell Pump House o Main Control Room o 'Switchgear Room o Cable Spreading Room o- Turbine Building Of these nine fire areas, alternative or dedicated shutdown capability mest be provided for the following five areas:

o Diesel Generator Building o . Main Control Room o ~ Switchgear Room o Cable Spreading Room o Turbine Building oL Primary Auxiliary Building The Vapor Container will require exemptions to the requirements of Section III.G.2.

. The Screenwell Pump House area contains cold shutdown equipment only, and therefore, does not fall under the requirements of Sections III.C.2 and 3

'of Appendix R. However, repair procedures and materials will be required to restore this equipment to operation within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> as required by Section III.G.I.b'of Appendix R. A fire in the noneeturn valve enclosure will not prevent safe shutdown of the plant.

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o- Primary Auxiliary Buildina Question

a. List the system (s) or portions thereof used to provide the shutdown capability with the loss of off-site power.

Response

The Primary Auxiliary Building (PAB) contains the following portions of systems used for shutdorn with a loss of off-site power:

1. Charging System o All three charging pumps o All four water supply suction MOVs o Discharge header isolation MOV o Water supply tank level indication

2. Emergency Feedwater System o Both motor-operated emergency feedwater pumps o All three discharge header MOVs o one water supply tank level indication Question

b. For those systems identified in "la" for which alternative or dedicated shutdown capability must be provided, list the equipment and components of the normal shutdown system in the fire area and identify the functions of the circuits of the normal shutdown system in the fire area (power to what equipment, control of what components and instrumentation).

Describe the system (s) or portions thereof used to provide the alternative shutdown capability for the fire area and provide a table that lists the equipment and components of the alternative shutdown system for the fire area. For each alternative system, identify the function of the new circuits being provided.

Identify the location (fire zone) of the alternative shutdown equipment and/or circuits that bypass the fire area and verify

.that the alternative shutdown equipment and/or circuits are separated from the fire area in accordance with Section III.G.2.

Response

Alternative shutdown capability is required for the charging system. Table XIII provides s listing of charging' system components in the PAB..

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-Alternate shutdown for the charging system'will be provided by the safety Injection System. Specifically, the safety injection pumps will.be used taking a suction from the safety injection tank and discharging.through the safety injection discharge

. header connections to each main coolant loop. Table XIV lists all of the safety injection equipment that will be used to provide alternative shutdown for the charging system.

' All of . the safety injection equipment and components listed in Table XIV are in the DGB. . The control and ammeter cables are routed back to the NCR. These cables are separated;from the PAB-in accordance with Section III.G.2. The fire door between the

'- PAB and DGB is rated for 1 1/2 hours. This will be replaced

.with a 3-hour fire rated door, which will provide separation in accordance with Section III.G.2.a.

Ouestion

c. Provide' drawings of the alternative shutdown system (s) which

,- highlight any connections to the normal shutdown systems (P& ids.

-for piping and components, elementary wiring diagrams of -

electrical cabling). Show the electrical location of all o breakers for power cables, and isolation devices for control and instrumentation circuits for the alternative shutdown systems for that fire area.

Response

. The Safety Injection System is a normal plant system; 1.e. ,

nothing is being added to provide alternative shutdown. The

] Safety Injection System has' connections to all main coolant-loops.

r Electrical power is provided to the Safety Injection System from

,the emergency diesel generators and the 480 volt emergency.

busses. This system is a normal plant system. It is being1used in this application to perform the charging system shutdown-function.

The Safety Injection and Emergency Power Systoms are described in the Yankee FSAR. Additional drawings can be provided if required for staff review.

Question

-d. Verify that changes to safety systems will not degrade safety L systems (e.g.. new isolation owitches and control switches

• ' should meet design criteria and standards in the FSAR for w electrical equipment'in the system that the switch is to be installed; cabinets that the switches are to be mounted in i should also meet the same criteria (FSAR) as other

\ ' safety-related cabinets and panels; to avoid inadvertent isolation from the Control Room, the isolation switches should i ';. i be keylocked or alarmed in the Control Room if in the " local" or I

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" isolated" position; periodic checks should be made to verify.

that the switch is in the proper position for normal operation; and a single transfer switch'or_other new device should not be~a source of a failure Which causes loss of redundant safety systems).

Response

There are no changes required to the Safety Injection System.

-It was specifically designed to provide water to the Main Coolant System.

Question

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e.- Verify that licensee procedures have been or will be developed which describe the tasks to be performed to effect the shutdown method. Provide a summary of these procedures outlining

[ operator actions.

Response -;

Following a fire in the PAB, the plant will be shutdown using-OP-3000, Emergency Shutdown From Power. One of the subsequent operator actions in this procedure is to restore normal pressurizer-level. If all three charging pumps are inoperable as a result of the fire, the safety injection pumps will be used to provide primary makeup.

A procedure is being' developed to outline the operator actions required. The following is a summary of these operator actions:

1. All lines off of the Main Coolant System are isolated; i.e. , the bleed line is isolated, any primary sampling is

, stopped, and all evolutions that require draining of primary coolant are prohibited.

2. All pressurizer heaters are de-energized. It is necessary

, to lower primary system pressure below the shut-off head of l the safety injection pumps, approximately 1550 psig.

Therefore, pressurizer heaters are secured to stop adding heat to the pressurizer.

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3. The emergency atmospheric steam dump valves are throttled to reduce primary temperature. This results in system shrink causing a lowering of pressurizer level. As the level is lowered, more water flashes to steam to fill the void, and the steam bubble in the pressurizer expands.

Both of these occuerences result in a reduction of main coolant pressure.

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4. Cooldown is stopped when the pressure drops to 1500 psig, or pressurizer level drops to the low end of the indicated

, range.

I S. If low pressurizer level is reached before the pressure drops to 1500 psig, the cooldown is stopped by throttling closed the emergency atmospheric steam dump vales. These L vales are adjusted to maintain a constant main coolant j' temperature; i.e... adjusted to remove decay heat only.

L Primary pressure is then allowed to drift down to 1500 psig by pressurizer heat losses to ambient.

I 6. When 1500 psig is reached, one train of safety injection-3 ' pumps consisting of one high pressure and one low pressure F pump are started for primary water addition. The pumps are operated as required for primary water addition.

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~0uestion I

f. Verify that the manpower required to perform the shutdown functions using the peccedures of Item e as well as to provide

-fire brigade members to fight the fire is available as required by the fire brigade Technical Specifications.

Responsa l / Technical Specification Section 6.2.2 delineates the number of 1 on-duty shift personnel on-site and the minimum fire brigade k manning. There are eight personnel required on-site, and the l minimum fire brigade manning is five. -Three licensed operators i' are available to perform the operations discussed in Item e.

The fire brigade consists of four on-shift personnel with one security guard. The Shift Technical Adviser is not used for L plant operations or the fire brigade. All-of the operations described above in Item e are performed'from the MCR.

Question

g. l Provide a commitment to perform adequate acceptance tests of the alternative shutdown capability. These tests should verify that: equipment operates from the local control station when the transfer or isolation switch is placed in the " local" position and that the equipment cannot be operated-from the Control Room; and that equipment operates from the Control Room but cannot he operated at the local control station when the transfer isolation switch is in the " remote" position.

Response

- The Safety Injection System is an emergency plant system that undergoes surveillance testing per the plant-Technical Specifications. No additional testing is required.

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,g U Question

h. Provide Technical Specifications of the surveillance p requirementsoand limiting conditions for operation for that

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equipment not already' covered by existing Technical Specifications. For example, if new isolation and control

. switches are added to a shutdown system, the existing Technical Specification surveillance requirements should be supplemented to verify system / equipment functions from the alternate shutdown station at testing intervals consistent with the guidelines of L Regulatory Guide 1.22 and IEEE 338. Credit may be taken for L other_-existing tests using group overlap test concepts.

-Response The Safety Injection System is already covered under existing-f plant Technical Specifications. No new surveillance

-requirements or limiting conditions for operation are required.

It Ouestion

[' i. For new equipment _ comprising the alternative shutdown capability, verify that the systems available are adequate to perform the necessary shutdown function. The functions required

-should be based on previous analyses, if.possible (e.g., in the FSAR), such.as a loss of normal ac power or shutdown on Group 1 l iisolation (BWR). The equipment required for the alternative.

L capability should be the same or equivalent to that relied on'in the above analysis.

Response

I There is no new equipment being added for the alternative h

l shutdown capability.' The safety injection equipment is existing plant equipment which is capable of exceeding.the design flow of the charging system.

Question J. Verify that' repair procedures-for cold shutdown. systems are developed and material for repairs is maintained on-site.

Provide a summary of-these procedure and a list of the material needed for repairs.

Response

Both component cooling pumps (P-20-1 and 2) and the shutdown coolant and LPST cooling pumps (P-19 and 23) are located in the PAB. 'Following a fire in the PAB, one of each of these pumps is required for cold shutdown. The fire damage postulated is to the power cables to the pump motors.

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Repair procedures are being prepared essentially to run new power cable from the pump motors.to outside of the PAB fire area. The new cables will be run from the pump motors to a manhole-outcide of the fire area. In the manhole, the replacement cable will be spliced into the existing pump power cable, essentially removing =the damage length of cable. The repair materials required include connectors for the terminals at the motor, an adequate length of power cable and splicing ,

materials. These materials will be maintained on-site.

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TABLE XIII Nomal Shutdown Components in the PAB Cable / Component Function 15PL96 Power to CH-MOV-521 15PL97 Position indication for CH-MOV-521.

15PL100 Control of CH-MOV-521 Motor Operator. -Actuator for CH-MOV-521

' Contactor Provides power to CH-MOV-521 through control switch-operator' 15FL95' Provides power from 480 V bus to CH-MOV-521, DW-MOV-655, CS-MOV-540 ,

Air Circuit Breaker Provides power from NCC 4 Bus 2 to CH-MOV-521,.

7 DW-MOV-655, CS-MOV-540

-15PL114 Power to CS-MOV-529.

-15PL115 Position indication for CS-MOV-529

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15PL118 Control of CS-MOV-529 15PL Provides power from MCC-4, Bus 1 to CS-MOV-529 Air Circuit Breaker Provides power to CS-MOV-529 from NCC 4, Bus 1 Motor Operator Actuator for CS-MOV-529 Contactor- Provides power to CS-MOV-529 through control switch operation 15PL132 Power to CS-MOV-540 1

15PL133 Position indication for CS-MOV-540

-15PL134 Control of CS-MOV-540 Motor Operator Actuator for CS-MOV-540 Contactor Provides power to CS-MOV-540 through control switch operation i-I. 2 e

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l LCable/ Component Function .)

15PL137 RPower to DW-MOV-655 15PL138 Position indication for DW-MOV-655-

'15PL139 Control of DW-MOV-655 Contactor Provides power to DW-MOV-655 through control switch operation Motor Operator Actuator for DW-MOV-655 9PL66 Power to P-15-1

.9PL68. 10PL434 Control of P-15-1 Air Circuit Breaker Power to P-15-1 from MCC-4 -Bus 1 Contactor Provides power to P-15-1 through control switch operation.

Motor Driver for P-15-1 15PL21, 29PL30- Power to P-15-2 Motor Driver for P-15-2 15PL41 Power to P-15-3 15PL43, 10PL434 Control of P-15-3

' Air Circuit Breaker Foster to P-15-3 from McC4, Bus 2 Contactor Provides power to P-15-3 through control switch operation Motor Driver for P-15-3 l

15PL108, 140 Power to CH-MOV-523

'15PL112 ' Control of CH-MOV-523 l

15PL109 Position indication for CH-MOV-523 l

'10PL431 Control power for CH-MOV-523 Motor Operator Actuator for CH-MOV-523 Contactor Provides power to.CH-MOV-523 from EMCC-1 A-67

.~ - -. . -, ,. - - - . . . -

Cable / Component Function

-- Motor Control Center MCC-4, Bus 1 and 2 provides power to CH-MOV-521, DW-MOV-655, CS-MOV-529 and 540, P-15-1 and 3 IT20 Signal from DW-LT-200

- IT92 Signal from CH-LT-1

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Transmitter Levol transmitter for CH-LT-1 l

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TABLE IIV

-Alternative Shutdown Components for the PAB Fire Cabis/ Component Function.

41PL1 and 2 Power to LPSI Pump P-48-1 Motor Drive for P-48-1 51PL1-and 2' Power to LPSI Pump P-48-2 Motor Driver for P-48-2 61PL1 and 2 Power'to LPSI Pump P-48-3

-Motor Driver for P-48-3 42PL1 . Power to HPSI Pump P-49-1 Motor Driver for P-49-1 52PL1 Power to HPSI Pump P-49-2 Motor Driver for P-49-2 Power to HPSI Pump P-49-3

.62PL1 Motor Driver for P-49-3 Switchgear Power to all LPSI and HPSI pumps 41PL3 Amneter leads for P-48-1 41PL4 Control of P-48-1 51PL3 Ammeter leads for P-48-2 51PL4 Control of P-48-2 61PL3 Ammeter leads for P-48-3 61PL4 Control of P-48-3 IT142 Signal cable from SI tank level transmitter

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Transmitter Level transmitter for SI-LT-1 i

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c ATTACHNENT B ASSOCIATED CIRCUITS OF CONCERN

-Ouestion Fire Area Approach

1. For each fire area ~where an alternative or dedicated shutdown method, in accordance with Section III.G.3 of Appendix R is.provided, the following infoemation is required to demonstrate that associated circuits will not prevent operation or cause maloperation of the alternative or dedicated shutdown method:

Response

The Yankee plant has been divided into nine fire areas. The following five areas require a dedicated or alternative shutdown method:

o Main Control Room o Switchgear Room

-o Cable Spreading Room o -Turbine Building o Diesel Generator Building

o Primary Auxiliary Building A' separate set of responses to Items a through e will be prepared for each'of these fire areas.

o Main Control Room

-Ouestion

a. Provide a table that lists all the power cables in the fire area that connect to the same power supply of the alternative or dedicated shutdown method'and the function of each power cable listed (i.e.,

power for RHR pump).

Response

t The SSS provides a dedicated shutdown method for a fire in the MCR.

The SSS contains its own dedicated power supply etnsisting of an electrical ~ diesel generator set and a motor control center to provide electrical power to all of the SSS loads.

The SSS electrical power system will have only one connection to the normal plant electrical distribution system. A power feed will be-provided from an MCC in the PAB to the MCC in the SSS Building. This power. feed will provide electricity for normal building services, and is not required for operation of the SSS. The design of the SSS assumes this power feed is lost at the start of the fire, and this assumption does not prevent SSS operation. Also, the cables

.providing this power feed are routed completely outside of the MCR fire arna.

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could provide power to the solenoid and open the valve.

PR-SOV-90:could be isolated by closing PR-MOV-512. . However, the control cable for this valve is run in close_ proximity to the power cable for PR-SOV-90. A fire causing-PR-SOV-90 to open couldfalso be postulated.to prevent PR-MOV-512 from being-

. closed. The present arrangement is unacceptable and modifications are required.

For an inadvertent signal causing PR-SOV-90 to open, all that is

required is to remove power from the circuit. On a loss of power, the valve closes. Yankee will therefore reroute the

_ power cable out of the MCR through the southwest-stairwell where a power interrupt device will be located. An operator leaving the NCR will open-this switch preventing PR-SOV-90 from opening.

3. - Charging Line Motor-Operated Isolation Valves The charging line contains two motor-operated isolation valves.

CH-MOV-52411s located in the vapor container. and CH-MOV-523 is >

' located in the PAB. Both of these valves must remain open to allow using the charging pumps for primary water addition.

CH-MOV-524 must remain open to allow using the SSS for primary water addition. Control cables for both valves run together in the MCB. The power and position indication cables for CH-MOV-524 run vertically.up the south wall of the NCR.

A fire-induced hot short to the control cables of either valve

) -could cause an inadvertent closure signal. However.-the power

[- supply breakers to both valves are normally locked open. As l discussed previously, with power removed from the circuit, a' l -fire cannot cause the-spurious operation of a valve.

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! 4. -Shutdown Cooling Motor-Operated Isolation Valves l~

L The shutdown cooling system has a suction and return connection to the primary system. gach line is isolated by two MOVs in series, SC-MOV-551, 552, 553, and 554. These. valves are

.normally closed and must remain closed to prevent possibly overpressurizing a lower pressure system and causing an uncontrolled loss of primary coolant.

The power, control, and position indication cables for all four valves run through the MCR. However, the power supply cables to all of these valves are removed at the valve contactors in the H SWGR. The control fuses are also removed. Therefore, with power removed, a fire in the MCR affecting any of these cables will not cause an inadvertent opening of these valves. ,

3; 5. Reactor Coolant System Vent System Motor-Operated Isolation  !

Valves The reactor head vent line and pressurizer vent line are each isolated with two MOVs in series, VD-MOV-559'and 561 and PR-MOV-558 and 560. The power, control, and position indication

-cables for all four valves run through the MCR. These valves B-4 l

must remain closed to prevent an uncontrolled loss of primary coolant.

.As discussed previously, a fire'affecting the power and position indication' cables for an MOV cannot cause an inadvertent operation of the valve. However, a hot short of the control  !

' cables can cause an inadvertent actuation. The control cables for all four valves run together in thu MCB. Due to the piping configuration, only'one valve can be allowed to inadvertently open. The present arrangement requires modifications to prevent these valves from opening.

Two of these valves are powered from an amergency NCC in the SWGR, and two from an emergency MCC in the DGB. The two valves powered from the DGB will have their power supplies relocated to the SWGR, and the power supply breakers to all four valves will be locked open removing power from the circuit. As discussed i- previously, this will prevent a fire from causing the valves to inadvertently open.

This modification will require a change to plant Technical' Specifications. Proposed ChanSe No. 195 was submitted by

, Letter No. FYR 85-110, dated October 15, 1985. A copy of this proposed change is attachel.

6. Main Coolant Loop Motor-Operated Isolation Valves i

The Yankee plant is a four loop Westinghouse pressurized water reactor. Each loop contains a motor-operated hot leg and cold leg isolation valve, MC-MOV-301, 302, 309, 310, 318, 319, 325, and 326. The hot leg and cold leg loop isolation valves in at least one loop must remain open to allow natural circulation flow through the loop for decay heat removal. Power, control, and position indication cables for all eight valves.run through the MCR. As discussed previously, a fire affecting the power and position indication cables for an MOV cannot cause an

. inadvertent operation of the valve.

Each Main Coolant Loop Isolation Valve (MCLIV) control circuit consists of two control switches, two control cables and two valve contactors. The control switches are grouped in the same l' section of the main control board. All of the control cables run to this area. These valves are provided with a dual l ~.

contactor arrangement to insure that a single failure will not result in the inadvertent closure of the valve. The purpose of the following circuit failure analysis is to demonstrate that the fire-induced closure of one MCLIV is a highly unlikely occurrence. A copy of the MCLIV elementary diagram is attached to assist in following this discussion.

i B-5

.The.following circuit failure analysis outlines what is required to cause one NCLIV to close:

a. The 42C closing contacts in the three power leads to the valve motor operator are normally open when the valve is in the open position. In order to energize the 42C closing

, coil, two simultaneous hot shorts are required. A hot

-short is required to the' control wire for the 1-2 control

(

-switch contact-and a simultaneous hot short is required to the control wire for the 5-6 control switch contact. When these two hot shorts have occurred simultaneously,-the 42C closing coil is energized and the 42C closing contacts in the power leads to the valve motor operator are closed.

However, power is still not applied to the motor operator since the dual contactor 42X contacts are still open.

Note: Up to this point, the dual contactor control circuit is completely de-energized. Control power is provided to the dual contactor only when the 42C or o contacts are closed. The control cable for the main contactor is a seven-conductor cable. Some of these conductors are normally energized since control power is applied to the circuit, and position indicating lights are lit. A hot short within this cable could be postulated. However, the control cable for the dual contactor is normally de-energized, and therefore a hot short in this cable cannot be postulated.

b. The 421 contacts in the power leads to the valve motor. 3 operator are still open. In order to close the 42I contacts, a hot short is. required to the 2C point of the circuit. This. simulates control switch closure, energizing the 42K coil and closing the 42K contacts in the power leads to the motor operator. At this point, power is provided to the. valve operator and the valve begins to close. Valve closure time is two minutes.

Note: Since ti.e nait contactor control cable contains normally energized' conductors, t hot short could be postulated in the cable. However, a hot short in the dual contactor must be fire induced. This requires that the five conductor control cable insulation and the individual conductor insulation be burned off to the control wire and to~another energized conductor to result in a hot short.

The dual contactor control cable is an IEEE 383 qualified, fire resistant cable which retards fire growth, and the formation of a hot short.

The circuit failure mode outlined above describes what is required to happen to close one valve. The discussion below outlines what could happen to this circuit in a fire to prevent the valve from closing.

B-6

_ - _ _ _ _ _ _ _ _ - - _ - _ - - _ _ _ _ _ i

R pg As discussed:above, two simultaneous hot shorts are required to energize the main contactor closing' coil, 42C. Also, a fire is needed of large enough magnitude to burn the insulation off of

.the dual contactor control cable and.some of its conductors. It is^not reasonable to assume that a fire.of this magnitude only

.affects selected wires. Multiple hot shorts and shorts to,

• - ground would be expected. The main contactor control circuit is only protected by a 3-amp fuse. This fuse.would be easily

-blown, de-energizing the entire control circuit. This de-energizes the 42C closing coil and opens the 42C contacts, removing power from the motor operator stopping valve motion if it had begun, and removing power from the dual contactor control:

circuit.

The discussion above also applies to the dual contactor cont ol-circuit. It is also only protected by'a 3-amp fuse. Since the fire must be of sufficient magnitude to burn off the cable-insulation and'some individual wire insulation, it is not reasonable to assume that only selected wires,are affected. The 3-amp control fuse would be easily blown, de-energizing the dual contactor and opening the 42X contacts, removing power from the valve motor operator and stopping valve motion, if it had begun.

The discussion above has centered on the possible circuit failure modes that could result in or prevent valve closure.

This has only considered one valve. The following discussion outlines the system and-operator interactions that can prevent

'this-fire from impacting the plant safe shutdown capability:

a. The circuit fallare analysis relates to the closure of a single valve. Yankee is a four-loop pressurized water-reactor.~ Each loop contains two MCLIVs for a total of.

eight. Only two valves in.any one loop must remain open to allow natural circulation flow through the loop for decay heat removal. Therefore, the scenario described above for one valve must be repeated four times and be selective to

~

close one valve per loop.

~b. 1te MCLIVs are 20. inch gate valves which require a full two minutes once they are energized to close. A valve could go over half closed before it would have any effect on loop flow. Natural circulation flow is a small percentage of normal flow and is, therefore, affected even less by partial valve closure.

, .c. The main section of the MCB is 20 feet long, 6 feet wide and 8 feet high. There are two end sections at 400 angles to the main section. Each is an additional 8 feet long. A sloped desk section runs along the front of all three sections. It is 2 1/2 feet wide by 3 feet high. The inside area of the main control board is wide open and can be walked through from end to end. Access doors are provided at each end. The inside of the MCB is monitored by five ionization type detectors spaced evenly l

l B-7 J

'throughout. This provides for rapid detection of a fire befcre it could spread and affect all the MCLIV control cables,

d. The MCR is continuously manned. A security guard is stationed at the auxiliary security panel 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day.

-This is within 10 feet of the west end of the main control board. The main fire detection panel is within arms length of the security guard. The main control board detectors alarm at this panel. The two Control-Room operators and the shift supervisor are stationed in front of the MCB.

=Their desks are no more than 4 to 6 feet away from the MCB .' . The nuclear side Control Room operator desk is right in front of the section containing the MCLIV controls. It-is not a credible event that a fire of the magnitude required can rage inside the MC8 without being noticed.

e.. Portable CO2 fire extinguishers are located inside the NCR as well as inside the MCB to extinguish the fire before it does the postulated damage. In addition, one of the operators can leave the MCR and proceed to the SWGR to open the breakers to these valves before they could all close This action is proceduralized in the fire procedure developed for Appendix R.

Based on the discussion above Yankee believes that the complete fire-induced closure of one MCLIV per loop is a highly unlikely occurrence, i

7. Main Coolant Bleed Line Motor-Operated Isolation Valves During normal operation, the main coolant bleed line is draining a controlled amount of primary coolant for purification purposes. This bleed flow is isolated by closing CH-MOV-525 or CH-MOV-526 and/or 527, depending upon the bleed orifices in service.

The power, control, and position indication cables for these three' valve 3 run through the NCR. A fire affecting any of these cables could prevent the closure of the valves. However, the bleed line contains a normally open containment isolation trip valve located in the PAB, CH-LCV-222. .The closure of this valve would isolate the line if the MOV cables were damaged. f The control cabling for the MOVs is located in the MCB, while

- the power and position indication cabling run vertically up the south wall of the MCR. The CIS control cabinets and ,ower cabling to the solenoid valves that actuate CH-LCV-222 are also located in the MCR. The fire protection criteria of Section III.G.2 cannot be fully met for these components in the NCR.

Yankee will therefore add an additional solenoid valve capable of closing the bleed line trip valve outside of and independent ,

of the NCR. l 1

I B-8

4. Shutdown Cooling System Motor-Operated Isolation Valves The review of these valves under the NCR associated circuit review also applies for a SWGR fire.

15 . ' Reactor Coolant System Motor-Operated Isolation Valves

'The review of these valves under the MCR. associated circuit

-review also applies for a SWGR fire. The modification described for the NCR fire is also required for a fire in the SWGR.

6. Main Coolant Loop Motor-operated Isolation Valves The review of these valves under the NCR associated circuit review also applies for a SWGR fire.

A fire of the magnitude required to close the MCLIVs would actuate.the SWGR Fire Suppression System. The SWGR is monitored by 25 ionization-type fire detectors arranged in two zones. One detector in one zone actuates an alarm in the NCR on the MCB and

( the fire detector panel as well as a local alarm. .When a

[ detector alarms in the second zone, the automatic halon flooding j system is actuated. This system will rapidly extinguish the fire, as was demonstrated in a recent SWGR switchgear fire.

(See Inspection Report No. 50-29/84-17, NYR 84-200,~ dated September 18, 1984.)

l In addition, if the valves were to begin closing, this would be indicated on the MCB. The operators could then de-energize the 480 volt busses that power the MCLIVs from the NCR, stopping i valve. closure.

F f This, in addition to the discussion under the NCR review,

[ provides the justification for Yankee's belief that the L, fire-induced closure of one MCLIV per loop is a highly unlikely

[

occurrence.

7. Main Coolant Bleed Line Motor-Operated Isolation Valves The review of these valves under the MCR associated circuit review' applies for a SWGR fire.

8. Main Steam Nonceturn Valves The review of these valves under the MCR associated circuit review also applies for a SWGR fire.

i l'

L B-12

Question

c. Provide a table that lists all the cables in the fire area that share a common enclosure with circuits of the alternative or dedicated shutdown systems and the function of each cable listed.

L

Response

.As discussed in the response to Item a under the NCR associated circuit review, thero is only one connection between the SSS

[ electrical system and the normal plant electrical system. The one

[ connection-is from a MCC in the PAB. Therefore, there are no cables in the DGB that share a common enclosure with the SSS circuits.

Question

d. Show that fire-induced failures (hot shorts, open circuits, or shorts to ground) of each of the cables listed in a, b, and c will not prevent operation or cause maloperation of the alternative or dedicated shutdown method.

Response

The following reviews assess the impacts of fire-induced failures of associated circuits in the DGB on the dedicated shutdown method:

1. Reactor Coolant System Vent System Motor-Operated Isolation Valves The power and control cables, and the valve contactor and air circuit breaker for VD-NOV-559 and PR-MOV-560 are located in the l DGB. Both valves are normally closed and must remain closed to prevent an uncontrolled loss of primary coolant.

A fire-induced hot short of-the control cables for both valves could generate inadvertent opening signals. This condition is similar to what would happen to these valves in e NCR or SWGR fire. The modification outlined under the MCR review of these valves would completely remove these cables and equipment from f~

the DGB, and relocate them in the EWGR. This modification would eliminate this associated circuit concern for a DGB fire. The I proposed change to the plant Technical Specifications discussed under the MCR review is also cpplicable here. l

2. Containment Isolation Trip Valves n j:

Power supply cables to CIS Train A and B solenoids are routed through the DGB. Power must be provided to the solenoids to vent the air and close the trip valve.

Only CH-LCV-222, the bleed line trip valve, is required to be closed. The normal bleed flow rate is above the capacity of the SSS primary pump. The bleed line is normally isolated with NOVs, however these valves are powered by off-site power.

B-19

o Primary Auxiliary Buildina ouestion:

c '

La. -Provide a table that-lists all the power cables in the fire area that

-connect to.the same. Power supply of the alternative or dedicated shutdown method and the function of each power cable listed (i.e.,

power for RHR pump).

{

- Response-The safety' injection pumps are powered off of the 480-volt emergency buses Nos. 1, 2 and 3. There are no power cables from equipment in the PAB that connect directly to these buses. Power cables from NOVs in the PAB do connect to Emergency Motor Control Centers (EMCC) which are powered by these three buses. However, Yankee has recently

. reviewed breaker coordination and determined that the breakers on these ID0CCs are properly coordinated so that power will not be lost to the 480-volt emergency bus. Therefore, a table of power cables l- from the PAB to the ENCCs is not required since proper coordination

>- of all loads has been verified.

i.

!- The safety injection tank level transmitter is powered by vital Bus No. 2. Tank level indication is also provided by a pneumatic level.

transmitter (SI-LT-401)-that is provided with a nitrogen backup.

Therefore, a table of specific power cables from the PAB to the vital bus is not required since a nonelectrical backup indication channel is provided.

p.

Question

! b. Provide a table that lists all the cables in the fire area that were considered for possible spurious operation which would adversely

l. affect shutdown and the function of each cable listed.

Response

Table IV lists all cables in the fire area that were considered for spurious operation and their function.

Ouestion f c. Provide a table that lists all the cables in the fire area that share a common enclosure with circuits of the alternative or dedicated  ;

shutdown systems and the function of each cable listed.

Response I There are two possible solutions for common enclosure associated l circuit concerns:

'1. Provide electrical protection for the associated circuit.

B-36

o -

2.- Provide a. barrier that prevents propagation of the fire into the common enclosure.

h ..

l

t. The coordination review discussed in Item a covered any circuit that L .would require electrical protection. This responds to the first common enclosure-solution. 'At Yankee, all cables that pass through a L . fire barrier are sealed with an equivalent fire barrier material, whether inside a conduit or a cable raceway. This would respond to the second common enclosure solution. Therefore, it is not necessary to review each cable in the PAB for common enclosure concerns since the steps. required to correct any deficiencies found have been performed for all cables in the area.

.0uestion 1 d. Show that fire-induced failures (hot shorts, open circuits, or shorts to ground) of each of the cables listed in a, b, and c will not L -prevent operation or cause maloperation of the alternative or dedicated shutdown method.

Response

The following reviews assess the impacts of fire-induced failures of associated circuits in the PAB on the alternative shutdown method:

1. CIS Trip Valves There are eight air-operated CIS trip valves located in the upper level PAB, 'if-202, 203, 206. 401A, 401B, 401C, 401D and CH-LCV-222. The solenoid-operated valves that actuate these trip valves and the power. cable to them are all located in the L upper level PAB. A fire could disable all of these valves preventing the capability of tripping them closed during a fire.

TV-202 isolates the main coolant drain line to the LPST. It is only required to operate as a backup to the drain system NOVs in the event of their inadvertent actuation from a fire. These valves and their related electrical equipment are located outside of the PAB. Therefore, TV-202 is not required to function after a fire in the PAB.

TV-203' isolates the high pressure vent header. This line continuously vents a small amount of steam and gases from the pressuriser steam space for noncondensible gas control. For a fire in the PAB, this line can be left unisolated until a VC entry can be made to close a manual valve or the air supply to the PAB can be isolated and vented from outside of the PAB to close the valve from a loss of air.

B-37

.. _ _ _ _ _ _ _ - _ ._ _ -- i

TV-206 isolates the high pressure sample line to che sample sink. This line is not normally in service. However, if it-were in use, the sample line could be isolated by. closing CH-MOV-525 inside the VC. This valve and its cocpone.tts are outside of the fire area and would remain oparabic following a fire in the PAB.

TV-401A, B, C and D" isolate the SG blowdown lines from each SG.

The flow through each line is normally 1 gpn. Following a fire in the PAB, this loss of water is within the capacity of the SDEBFP, and steam generator emergency feedwater flow can be mainte.ined until a containment entry is made and all four blowdown lines are isolated with manual valves in the VC.

( CH-LCV-222 is used to isolate the bleed line. However, the I bleed line can be isolated by closing CH-MOV-525 or 527. These valves are all located inside the VC, and are not affected by a fire in the PAB. The valves are remotely operated from the MCR.

For a fire in the PAB, the loss of these CIS trip valves will not affect the safe shutdown of the plant.

l l

2. Safety Injection Valves The PAB contains the power cqbla to and the position indication cable from the safety injection tank isolation valve, SI-MOV-S18, and the high pressure header throttle valve, SI-MOV-46. These valves are normally open and'must remain open for safety injection pump operation. As discussed previously, a fire involving these cables will not result in an inadvertent closure of these valves. Therefore, a fire in the PAB will not prevent operation of the safety injection pumps which provide alternative shutdown capability for the charging pumps.

Question

e. For each cable listed in a, b, and c where new electrical isolation has been provided or modification to existing electrical isolation has been made, provide detailed electrical schematic drawings that show how each cable is isolated from the fire area.

Response

No modifications are required for associated circuits in the PAB.

l i

B-38

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ i

j.

TABLE IIV

' Alternative Shutdown Components for the PAB Fire Cable No. Function-M181, 182, 931 Power to SOV-CA-809 for TV-203 M176, 179, 937 . Power to SOV-CA-909 for TV-203 M181, 182, 932- Power to SOV-CA-810 for CH-LCV-222 M176, 179, 938 Power to SOV-CA-910 for CH-LCV-222 M181, 182, 933 Power to SOV-CA-811 for TV-206

,s,.

M176, 179, 939 - Power to SOV-CA-911 for TV-206 M181, 182, 934 Power to SOV-CA-812 for TV-202 M176, 179, 940 Power to SOV-CA-912 for TV-202 M180, 181, 918 Power to SOV-CA-804 for TV-401C M175, 179, 926 Power to SOV-CA-904 for TV-401C M180, 181, 919 Power to SOV-CA-805 for TV-401B M175, 179, 927 Power to SOV-CA-905 for TV-401B M180, 181, 920 Power to SOV-CA-806 for TV-401A M175, 179, 928 Power to SOV-CA-906 for TV-401A M180, 181, 922 Power to SOV-CA-808 for TV-401D M175, 179, 930 Power to SOV-CA-908 for TV-401D 64PL46 Power to SI-MOV-46 64PL48 Position indication for SI-MOV-46 75PL11, 12 Power to SI-MOV-518 75PL13, 14 Position indication for SI-MOV-518 B-39  !

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YANKEE ATOMIC ELECTRIC COMPANY T*'*pho"* (' ") * ' ** ' 00 THOC 710-380 7619 sg607,rpg,

-Q X*

1671 Worcester Roact Framinghan Massachusetts 01701 2 C.15.1

, YANKEE -

FYR 85-110 he PC f 193 October 15, 1985 t

United States Nuclear Regulatory Commission Washington, DC 20555 Attention: Office of Nuclear Reactor Regulation

References:

(a) License No. DPR-3 (Docket No. 50-29)

(b) YAEC Letter to USKRC, dated April 17, 1984 (c) YAEC Letter to USNRC, dated April 30, 1985

Subject:

Request for Change to Technical Specifications 3/4.4.11 and 3.4.11 Main Coolant System Vents

Dear Sir:

Pursuant to Section 50-59 of the Commission's Rules and Regulations, the Yankee Atomic Electric Company hereby requests the authorization to make the following changes:

PROPOSED CHANGE Reference is made to the Proposed Change 183 to the Technical Specifications of License No. DPR-3.. This change was submitted for staff review by Reference (b). We propose to modify the license as follows:

1. Replace Page 3/4 4-39 with the attached revisef Page 3/4 4-39.

2. Replace Page B 3/4 4-13 of the Bases section with the attached revised Page B 3/4 4-13.

REASON AND BASIS FOR CHANGE These Technical Specification changes are necessary to accommodate modifications to the power supplies of the Reactor Coolant System Vent System valves committed to by Yankee Atomic Electric Company in Reference (c).

The reactor head vent line and pressurizer vent line are each isolated with two motor-operated valves in series: VD-MOV-559 and 561, and PR-MOV-558 and 560, respectively. As discussed in Attachment (b) of Reference (c), a u -s

' ,I !y f .1 ~1 / ? ?j --^L I ?7,1 j B-41 J:f gg ,

t',

United States Nuclear Regulatory Commission October 15, 1985

, Attention: Office of Buclear Reactor Regulation page 2 fire affecting the control cables of these valves can cause an inadvertent actuation if power is available to the motor operstars. Therefore, to insure the valves remain closed, power will be norinally removed from all four valve operators. However, this will first require relocating the power supplies for all four valves to the Switchgear Room. This area is accessible after an accident requiring operation of these valves so that power can be resupplied ta the valve operators when they are required to operate.

This modification and Technical Specification change will satisfy the following NRC criteria:

1. All four valves will be powered from emergency buses as required by NUREG-0737. Item II.B.1.

2. power will be normally removed from these circuits so that a fire affecting them will not cause an inadvertant opening of two valves

-and the resultant loss of coolant, as required by Section III.G of Appendix R to 10CFR50.

3. The power supplies for all four vahes will be located in the Switchgear Room which is accessible following the accident they were designed to operate for, per NURgG-0737. Item II.B.1.

8AFETY CONSIDERATION The significant hazards consideration is based on the guidance provided by example in 48FR14870. The change described herein is classified according to the following examples of actions involving no significant hazards:

(1) A change to make a license conform to changes in the regulations, Where the license change results in very minor changes to facility operations clearly in keeping with the regulations.

The above change represents an additional operational requirement not presently included in the Technical Specification. However, this change ensures that the Reactor Coolant System Vent System valves remain closed to prevent an uncontrolled loss of primary coolant.

Based on the consideration contained herein, it is concluded that there is reasonable assurance that operation of the Yankee plant consistent with the proposed Technical Specification will not endanger the health and safety of the public. This proposed change has been reviewed by the Nuclear Safety Audit and Review Committee.

FEE DETERMINATION l An application fee of $150.00 is enclosed in accordance with 10CFR170.21.

B-42 i

]

um

United States Nuclear Regulatory Commission October 15, 1985 Attention: Office of Nuclear Reactor Regulation Page 3 SCHEDULE OF CHANGE These changes to the Yankee Technical Specification will be implemented upon Comission approval. A timely review and approval of this submittal consistent with our schedule for Core XVIII would be appreciated. The refueling outage is scheduled to comumence on or about October 19, 1985.

I Very truly yours, YANKEE ATOMIC ELECTRIC COMPANY YM L. H. Heider Vice President / Manager of Operntions LHH/glw COMMONWEALTH OF MASSACHUSETTS)

)ss MIDDLESEX COUNTY )

Then personally appeared before me L. H. Heider, who, being duly sworn, did state that he is Vice President / Manager of Operations of Yankee Atomic Electric Company, that he is duly authorized to execute and file the foregoing document in the name and on the behalf of Yankee Atomic Electric Company and that the statements therein are true to the best of his knowledge and belief.

W Robert H. Croce Notacy Public My Comission Expires August 29, 1991 B-43

t MAIN COOLANT SYSTEM MAIN COOLANT SYSTEM VENTS LIMITING CONDITIONS FOR OPERATION P

3.4.11 At least one main coolant system vent path consisting of at least .

two valves in series powered from emergency buses shall be OPERABLE and closed witM power removed'from the valve actuator at each of the following locations:

a. Reactor vessel head (VD-MOV-559 and 561)

b. Pressurizer steam space (PR-MOV-558 and 560)

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTION:

a. With one of the above main coolant system vent valves inoperable, STARTUP and/or POWER OPERATION may continue provided the inoperable valvo is maintained closed with power removed from the valve actuator of 'the inoperable valve; restore the inoperable vent valve to OPERABLE status within 30 days, or, be in HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

b. With both main coolant systems vent paths inoperable; maintain the inoperable vent paths closed with power removed from the valve actuators of the inoperable valves, and restore at least one of the vent paths to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE REQUIREMENTS 4.4.11.1 At least once per 31 days verify that the supply breakers at the EMCC for each of the following valves is locked open:

a. VD-MOV-559 and 561

b. PR-MOV-558 and 560 4.4.11.2 Each main coolant system vent path shall be demonstrated OPERABLE at least once per 18 months by:

a. Verifying all manual isolation valves in each vant path are locked in the open position.

b. Cycling each motor-operated valve in the vent path through at least one complete cycle at full travel from the Control Room during COLD .

SHUTDOWN or REFUELINC.

c. Verifying flow through the main coolant vent system vent paths during venting during COLD SHUTDOWN OR REFUELINC.

M l ;* F

.m+

..h YANKEE-ROWE 3/4 4-39 B-44 AMENDMENTNO.[

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?,

MAIN COOLANT SYSTEM BASES F

Whenever the results of any steam generator tubing inservice inspection fall into Category C-3, these results will be promptly reported to the Conunission pursyant to Specification 6.9.4 prior to resumption of plant operation. Such cases will be considered by the Conunission on a case-by-case basis and may result in a requirement for analysis, laboratory examinations, tests, additional addy-current inspection, and revision of the Technical Specifications, if necessary. -

3/4.4.11 Main Coolant System V_ents Main coolant system vents are provided to exhaust noncondensable gases and/or steam from the primary system that could inhibit natural circulation core ,

cooling. The OPERABILITY of at least one main coolant system vent path from the reactor vessel head or the pressurizer steam space ensures the capability exists to perform this function.

The redundancy of the main coolant system vent paths, the normally closed valves and the open valve circuit breakers serve to minimize the probability of inadvertent irreversible actuation while ensuring that a single failure of a vent valve, power supply, or control system does not prevent isolation of the vent path.

The function, capabilities, and testing requirements of the main coolant system vent systems are consistent with the cequirements of Item II.B.1 of NUREG-0737, ** Clarification of TMI Action plan Requirements," November 1980.

I l

l l

l l

YANKEE ROWE B3/4.4-13 B-45 Amendment [, [

w~ ~ ~ s "-x v .> .u,,,- -, -- -

ATTACHMENT C Exemption Requests Exemptions are being requested from the requirements of Sections II.G.2 and-3 of Appendix R for the following areas:

o Main Control Room o Switchgear Room o Cable Spreading Room o Diesel Generator Building o Vapor Container o Primary Auxiliary Building o Turbine Building l- All exemption requests are grouped by area.

I. MAIN CONTROL ROOM Yankee has previously requested an exe.7ption from the requirement to install a fixed fire suppression system in the Main Control Room (MCR). This is required based on the last statement in Section III.G.3 of Appendix R. The basis for this exemption request is contained in letter number FYR 82-50, dated May 13, 1982. This exemption request

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has been accepted ty letter number NYR 82-177, dated August 5, 1982.

Exemption Request Number 1 Deleted, i

Exemption Request Number 2 i

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Exemption Request Number 3

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Deleted.

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Exemption Request Number 4

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' *a g II. SWITCHGEAR ROOM Exenstion Request Number 5 Deleted.

III. CABLE SPREADING ROOM '"

t i Exemption Request Number 6 N

Deleted.

IV. s DIESEL GENERATOR BUILDING g Exemption Request Number 7

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I An exemption is requested from the requiremert to have a fixed fire

suppression system in the Diesel Generator Building (DGB). This ,

exemption is required based on the last statement in Section III.G.3 which requires a fixed fire suppression system in areas requiring dedicated shutcown capability, which the DGB requires.

In this exemption request, Yankee is requesting an exempt ots from the criteria requiring a fixed fire suppression system in the DGB. The DGB

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3, does not contain any equipraent required to bring the plant to hot shutdown following a fire in the DGB.

The following information is provided in support of this exemption request:

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1. The DGB, which abuts the PAB, is an L-shaped building constructed with 8-inch concrete blocks. Adjacent to this room on the northeast wall is the Post Incident Cooling System (PICS) Building

. constructed of 12-inch filled concrete blocks, and the LPSI Accumulator Tank Room constructed of 8-inch concrete block.

.The DGB is divided into four areas which are: (1) the three Diesel l= Generator Rooms, (2) the Pump Room, (3) storage area, and (4)

! Station Battery 3. The Diesel Generator Rooms'are separated from the rest of the building by 8-inch concrete block walls. The other three areas are not separated by any form of barrier.

The wall which is common to both the DGB and the PAB is 12-inch poured concrete with all penetration sealed to provide a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire barrier between the two buildings. The roof is constructed of a metal deck, covered with approximately 1-inch of insulation, tar, and gravel. Personnel access is through a UL rated 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire door from the PAB. The door leading into the LPSI Accumulator Tank Room has a 1-1/2 hour fire rating. Each Diesel Generator Room has a UL rated 1-1/2 hour fire door from the pump area. A doorway separates each Diesel Generator Room and has a UL 3-hour fire

' rating. The door leading to the outside from the west end of the

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DGB has no fire rating specified. The door leading to the PICS l' Building has a 3-hour UL fire rating. The door leading outside from the PICS building has a 3-hour UL fire rating. Each Diesel

!. Room has a screened hood for diesel cooling air exhaust, two air intake hoods on the roof, and a piped diesel exhaust vent on the roof.

2. Automatic fire detection is provided throughout the DGB. Two detectors are also provided in each diesel generator cubicle, and four detectors are provided in the PICS Building. These detectors, with the exception of the PICS Building detectors, alarm on a graphic display panel located at the radiation control point in the Turbine Building. This area is the accesu point for access to the controlled side of the plant, containing the DGB. An alarm is also C-3

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. received in the NCR indicating an alarm condition at this panel.

i C The slatin in the NCR is also actuated by the PICS Building i

, detectors. ~The DGB contains a fire header that feeds a hose ,

station and a manually actuated sprinkler system in each diesel ,

- cubicle .' This header is a dry header and is normally~ isolated at two points outside of the DGB. Portable C0g fire extinguishers ,

are also provided in the DGB.; Upon receiving an alarm, an l auxiliary operator would proceed to the DOB and survey the fire situation. If fire suppression is required; the operator would

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unisolate the header by opening one quarter turn ball valve. If ,

the fire was in a diesel cubicle, the operator would also have to open one quarter turn ball valve at the cubicle to provide water to the sprinklers.

3. The DGB is normally toured hourly by an operator for inspection and los readings.

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- 4' . Dedicated shutdown capability is provided outside of the DGB for-a fire in the DGB. The DGB contains most of the plant emergency. I power equipment. . Assuming a loss of off-site power concurrent with l a fire, as required by Appendix R, results in a station blackout when the-fire is assumed in the DGB. The SSS is completely

' independent of the DGB.. Equipment in the DGB is therefore not required for hot or cold shutdown following a fire in'the DGB that results in a station blackout.

~5. -Almost all of the cables running through the DGB are in conduit and are therefore not considered intervening combustibles. The only places where cables are grouped together and not in conduit are inside the emergency switchgear and motor control centers. Also, in the room containing EMCC 3 and 4, where cable is routed in trays over the motor control centers. The storage area in the building contains potentially contaminated valves and parts, most of which- a is nonflasunable. The safety injection pumps have oil lubricated bearings which contain only the oil in the bearings and a small bearing cup, an insignificant amount for fire purposes. The major C-4 r

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combustible in the building is the diesel fuel oil. Each cubicle is separated by a one-hour fire barrier, and as discussed above, have individual detectors and manual fixed suppression systems.

Oil piping is run outside of the cubicles and inside the DGB. The area containing this piping is limited to the front of the diesel cubicles. This piping is sectioned off from the rest of the room with a splash shield which directs diesel fuel spillage to the area in front of the cubicles. This area has a 4-inch berm, and a drain to an oil collection tank outside of the building. Since this piping is only gravity fed from the fuel oil storage tank, flow rates from a broken line are low. In addition, strict control is maintained over the use of flammable materials in the DGB, and transient combustible movement through the area is very low since this area is not in a travel route to other areas of the plant.

6. The installation of a fixed suppression system in the DGB could

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4 decrease overall plant safety rather than increase it. The DGB contains all of the safety injection pumps and the majority of the Emergency Power System. The inadvertent actuation of a fixed sprinkler system would affect all of the equipment in the building. With the present system, an operator first evaluates the extent of the fire and responds appropriately, only extinguishing the affected areas, minimizing the effect on safety-related equipment. This is lost with full coverage fixed system. The fire piping in this area has been maintained as a dry system, specifically for past NRC concerns about inadvertent flooding of safety-related equipment.

Based on the information provided above, Yankee believes that the ,

installation of a fixed suppression system in the DGB is not necessary and may be detrimental to overall plant safety. Yankee also believes than an adequate level of protection already exists, therefore, justifying an exemption from the requirements of Section III.G.2.C and r- III.G.3 of Appendix R.

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l other plants. The only remaining collection of combustibles inside containment is the electrical cables in the trays off the reactor head. _As previously discussed, these trays are monitored with line type fire detectors.

Based on the information provided above, Yankee believes that even though 20 feet of horizontal separation without intervening combustibles is not available between these cables, an adequate level of protection is available to justify an exemption from the requirements of Section III.G.2.d of Appendix R.

Exemption Request No. 11 Deleted.

VI. PRIMARY AUXILIARY BUILDING Exemption Request No. 12.. j An exemption is requested from the requirement to have a fixed fire suppression system and fire detection throughout the Primary Auxiliary Building (PAB) as required by Section III.G.3 of Appendix R. 'A fire in the PAB could cause a loss of all 3 charging pumps. The safety injection pumps would then be used to provide alternative shutdown capability for these pumps. The last sentence of Section III.G.3 requires fire detection and fixed suppression throughout an area regt:1 ring alternati;v shutdown capability.

The following information.is provided in support of this exemption request:

1. The PAB is an L-shaped building which has two stories except for the section containing the primary drain tank and gravity drain tank which is three stories tall. The building is approximately 131 feet long by 32 feet wide at the narrow end and approximately 50 feet wide at the other end. The PAB abuts the DGB at the west I

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end. This wall is constructed of poured concrete, 12-inch thick, Which provides a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire barrier. All penetrations through this wall are sealed with a 3. hour fire barrier material. The northeast end of the building abuts the ion exchanger vault. This wall consists of 4 feet of poured concrete. The first floor outside walls have a minimum thickness of 12 inches of poured concrete or concrete block. The second story is constructed mainly of 8-inch concrete block. The building is basically divided into two sections by a 24-inch poured concrete wall. This wall separates the PAB into the east and west sides which are considered the radioactive and nonradioactive sides, respectively. Personnel access between the east and west sides of the PAB is through two doors on the second floor and one door on the first floor, all with no fire rating specified. The roof is constructed of either a metal roof deck, with approximately 1-inch of insulation with tar and gravel, or a concrete slab roof with tar and gravel. An attached building in which hydrogen bottles are stored vertically

'in racks, abuts the PAB on the second floor level, west end. This building has its own natural ventilation system to vent any hydrogen from leakage and its own outside door. One door leads to this room from the PAB, which has no fire rating specified.

Personnel access from the DGB to the PAB is through a UL rated 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire door. Additional personnel access to the first story l

is through double doors located on the north and east outside walls, which have no fire rating specified. Personnel access to Mechanical Equipment Room #3 is through two doorways. There is a door in the east and north wall of the building with no fire rating specified. There are also two rolling steel doorn in the south wall for equipment removal and one single door, which have no fire rating specified. The Safety Injection Accumulator Room abuts the PAB at the northwest corner. The wall separating this room from the PAB is 8-inch concrete block. All penetrations through this wall are sealed with an equivalent fire barrier material to maintain this wall as a fire barrier. The west wall of this room abuts the DGB with an 8-inch concrete block wall, the penetrations through which are not sealed. Access to the accumulator room is C-17

from two doors, one in the DGB with a 1-1/2 hour UL fire rating, ,

and one from outdoors above the roof line of the DGB with no fire rating specified.' The accumulator room wall that abuts the PAB provides a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire barrier between the PAB and the DGB.

2. The PAB does not contain fire detectors throughout. Instead, fire detectors are located in the few areas which have some level of combustible loading. One fire _ detector is located above each charging pump cubicle in the radioactive side of the PAB. The detectors were located here since each charging pump contains 7 to 17 gallons of lubricating oil in the. gear drives between the pumps and motors. This oil is not pressurized since lubrication is accomplished through a gear splash arrangement. Therefore, an oil leak would not develop any spray, just spillage. The cubicles are separated by 8-inch filled concrete block, and the pumps are sunk in pits 3 to 4 feet below floor lovel. The cubicles are not complete barriers since doors are not provided, and the divider walls are not complete to the ceiling. A fire detector is also provided on the nonradioactive side above Station MCC 4. This location was selected since it is the only area Where insulated cables are located that are not in conduit. These cables are inside the MCC. A fire hose is provided in each side of the PAB, as well as portable CO extinguishers.

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3. The PAB is normally toured hourly by an operator for inspection and los readings. Traffic through the area is kept at a minimum since the area is on the controlled access side of the plant.

'4. The PAB conttins both motor driven emergency feedwater pumps, all three charging pumps, and the associated MOVs for each. The steam driven emergency feedwater pump provides the redundant train for the motor driven pumps. It is located in the Turbine Building

-Which is separated from the PAB by the Vapor Container and the yard-area between the buildings. This separation is in excess of what is required by Section.III.G.2.- The charging pumps are backed up by the safety injection system pumps which are located in the DGB.

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As discussed under Item 1, these building abut each other, but are separated by a minimum of a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire barrier. The safety injection system is not a redundant train of the charging system, but is being considered alternative shutdown capability as defined by Section III.G.3.

S. ..The PAB contains a very low combustible loading. The major combustible material is electrical cabling. The majority of the electrical cables installed during original plant construction are MI cable. This cable is an assembly of one or more conductors

. insulated with a highly compressed refractory mineral insulation and enclosed in a liquid tight and gas tight continuous copper sheath. MI cable is therefore noncombustible. The remaining cable is routed in conduit and is not considered an intervening combustible. The only other combustible material is the lubricating oil in the various pumps. The amount of oil is quite small. usually consisting of the oil in the bearing and the .

reservoir maintained in'the oil cup. The largest amount of oil is in the charging pump gear drives, discussed under Item 2. In addition, the amount of transient combustibles in the PAB is minimized since the area is on the controlled side, and travel

-through it is not required to reach many other areas. Transient combustibles brought to the PAB are those required for work in the PAB, and they are controlled.

Based on the information provided above, Yankee believes that the fire

-detectors provided are adequate and a fixed fire suppression system is not required in the area. An adequate level of' protection is available to justify an exemption from the requirements of Section III.G.3 of Appendix R.

'VII. TURBINE BUILDING hemption Request No. 13 An e::emption is requested from the requirement to have fire detection

_and a fixed fire suppression system throughout the Turbine Building C-19 l

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off-site power concurrent with a fire in the DGB, as required by Appendix R.-results in a station blackout. The SSS is completely independent of the DGB. Equipment inside the DGB and manhole No. 3 is therefore not required.for hot or cold shutdown following a fire in the DGB or manhole No. 3 that results in a station blackout.

l- The only component of concern is an associated circuit. The CIS is L required to operate to isolate the bleed line by closing CH-LCV-222. Power and control cables as well as the power supply, battery No. 3, for the CIS train A trips solenoid are located in the DGB. The power cable for the CIS train B trip solenoid is run through manhole No. 3 which is accessed from inside the DGB. The l~ control cable and power supply for the train B trip solenoid are I located outside of the DGD fire' area. One of the.immediate operator actions, once it is decided to go to the SSS, is to bleed L

down the a!r system inside the Turbine Building. This action backs

-up the CIS since no air is available to reopen the trip valve once both CIS trains are damaged in the fire. This action is completed within 30 minutes. Therefore, the train B CIS must only be protected against fire damage for this length of time.

Based on the information provided above, Yankee believes that the installation of a 1-hour fire barrier over the top of the access cover to manhole No. 3 is unnecessary since an adequate level of protection already exists. This therefore justifies an exemption from the requirements of Section III.G.2.c of Appendix R.

'II. VAPOR CONTAINER (ADDITIONAL)

Exemption Requirement No. 15 Deleted.

Exemption Request No. 16 Deleted.

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Exennotion Request No.17 Deleted, l

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