ML20195G527

Technical Evaluation Rept:Millstone Nuclear Power Station, Unit 1,Post-Fire Shutdown Evaluation,App R

ML20195G527
Person / Time
Site:	Millstone
Issue date:	10/02/1987
From:	SCIENCE APPLICATIONS INTERNATIONAL CORP. (FORMERLY
To:	NRC
Shared Package
ML20151M066	List: ML20151M062 ML20195G527
References
CON-NRC-03-87-029, CON-NRC-3-87-29 SAIC-87-3084, TAC-60188, NUDOCS 8710060577
Download: ML20195G527 (17)

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TECHNICAL EVALUATION REPORT I MILLSTONE NUCLEAR POWER STATION, UNIT NO. 1 i I POST-FIRE SAFE SHUTDOWN EVALUATION, I APPENDIX R I

TAC NUMBER 60188 l l N ] l l

October 2, 1987 Mlw i

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l Prepared for U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Contract NRC 03 87 029 3 7/ood es ? ? fg { ~1 l . '

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Post Of%ce Sos 73D.17f0 Goomdpe Ome. McLam. Wyrie 227C2. (7tD> rf 410

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i TECHNICAL EVALVATION REPORT l MILLSTONE NUCLEAR POWER STATION, UNIT NO. 1 POST FIRE SAFE SHUTDOWN EVALUATION,

, APPENDIX R

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TAC NUMBER 60188 l

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1 October 2, 1987

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l U.S. Nuclear Regulatory Comission

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4 Washington, D.C. 20555 .

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Section ELqt l 1 INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . 1 i 1 11 EVALUATION . . . . . . . . . . . . . . . . . . . . . . . 2 j i Shutdown Capability . . . . . . . . . . . . . . . . 2 l Repair Procedures . . . . . . . . . . . . . . . . . 5 l Associated Circuits . . . . . . . . . . . . . . . . 6 Comu n i c a t i on . . . . . . . . . . . . . . . . . . . 10 l Instrumentation Requirements ........... 10 l l Ventilation Systems . . . . . . . . . . . . . . . . 12 1  !!! CONCLUSIONS ...................... 13 14 l IV REFERENCES . . . . . . . . . . . . . . . . . . . . . . .

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TECHNICAL EVALVATION REPORT MILLS 10NE NUCLEAR POWER STATION, UNIT NO. 1 POST FIRE SAFE SHUTDOWN EVALVATION, APPENDIX R I

1. INTRODUCTION I The licensee has provided a discussion of shutdown system availability in the event of a fire as part of the fire protection evaluation for Millstone I Unit 1 by a submittai, '10CFR50, Appendix R Compliance Review," dated December 10, 1986 (Ref. 1). This submittal supersedes previous submittals and is intended to address additional staff concerns as presented in Generic l

Letter 86 10 (Ref. 2).

The scope of this technical evaluation was limited.to a review comparing the changes to the licensee evaluation with the previous submittals which have l already undergone staff review. Topics considered in this review include the systems used to achieve safe shutdown in the event of a fire, repair procedures, the associated circuit analysis, instrumentation requirements, I ventilation systems, comunication requirements, and the isolation of high/

low pressure interfaces at the reactor vessel boundary in the event of a l fire.

During the review several questions about the submittal were sent to the licensee for further clarification, Information in response to these questions was supplied during a plant audit of the Hillstone Unit I site I during the week of August 17, 1987. Additionally, a newer version of the submittal (Revision 2) was made available during the plant visit. Most of the coments contained in this review pertain to Revision 1, the December l 10, 1986 subrittal (Ref. 1). However, Revision 2 was examined and g

significant modifications to Revision I were identified. Where noteworthy, I these differences are highlighted in this report. However, based on this examination of the changes to the reviewed submittal, the information '

contained in Revision 2 does not significantly modify the conclusions of l this review.

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II. EVALUATION Shutdown Caoability In this analysis, the licensee has divided the Millstone Unit I nuclear power plant into ten major fire areas. (The control room fire area has been further divided into four fire zones and the reactor building has been divided into two fire zones.) The systems required to achieve hot shutdown, to maintain reactor inventory (i.e., provide makeup for normal leakage), and s to achieve cold shutdown have been identified for each of the fire arear.

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The isolation condenser is the primary means of achieving hot shutdown l following fires in the control room, fire area F-1 zones A, B, C, and D.

The isolation condenser must be manually initiated either locally or from I the control room. Control room initiation of the isolation condenser is possible only for fires in zones B, C, and D. Makeup to the secondary side l of the isolation condenser is provided by the fire water system, which consists of a diesel-driven pump and two motor-driven pumps; one pump is powered from Millstone Unit 2. Operator actions required to operate the I isolation condenser are: 1) open valve 1-1C-3, the isolation condenser return valve and 2) open valve 1-1C-10 to provide makeup to the secondary l side of the isolation condenser. Additionally, for a fire in zone A the operator must isolate the power supplies to valves 1-1C-1, -2, and 4 to

. prevent spurious closure of these valves.

Reactor inventory is maintained through the use of a control rod drive (CRD)

I pump that will be powered through a Unit 2-to-Unit I backfeed connection.

Initiation of the CRD pump requires operator action to align the pump to the self-cooling mode and to make the backfeed connection. For CRD pump use in l conjunction with the isolation condenser, the operators will have four hours to bring the pump into service.

Cold shutdown is achieved through the use of the shutdown cooling (SDC) system for all control room fires. The SDC system mu:t be manually l initiated. The major differences in system operation are dictated by the support systems affected by the control room fire. For fires in zones A and I D the normal SDC heat exchangers secondary side cooling water is used. This is the reactor building closed cooling water (RBCCW) system. (The RBCCW 2

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system in turn transfers heat to the service water system.) Power for the SDC and RBCCW systems is supplied from the plant diesel generator. For l fires in control room zones B and C, the RBCCW system and the nomal onsite power supplies may not be available. In response to these fires the opera-I tors align the SDC pumps to the Unit 2-to Unit 1 backfeed power supply and i manually connect the fire water system to the secondary side of the SDC heat exchangers. For a fire in control room zone B, some repairs to the SDC l system may be required since pump control circuits could be damaged by the fire. The licensee states that all repairs and system alignments can be i

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Additional operator actions required for a fire in any of the control room l l fire zones include isolation of the power supplies to the MS1Ys and auto-matic depressurization system (ADS) valves. This is accomplished through ,

I the use of an Appendix R isolation switch, f l

The systems used to achieve a safe shutdown following a fire in fire areas F-2, the cable vault, and F 3, the turbine building, are identical to those used following a fire in the control room area F-1 zone C. These systems i include the the isolation condenser (actuated locally), the CRD pumps (self-cooled and powered via the Unit 2 to Unit I backfeed), and the sDC system (also powered via the Unit 2-to Unit 1 backfeed and using fire water on the secondary side of the heat exchangers). The manual actions required of the operators are the same as described in the preceding paragraphs.

Fires in fire areas F-4, office area; F-8, the condensate storage area; F-9, 4

the fire pump house; and F-10, the radwaste building do not disable any systems used during normal shutdown procedures. Only in fire area F-9 are any components in these systems affected. For this one area the Unit 1 fire pump would not be available following a fire and the Unit 2 powered motor- i l

driven fire pump would be required. As stated earlier, this fire pump is l l connected to the Millstone Unit 1 fire water system. Nomal shutdown 1

procedures would be followed for fires in these four areas. l I The reactor building is divided into two fire zones, F-5 zone A and F-5 zone B. Zone B consists of the SDC pump room while zone A covers the rest of the I reactor building. Following a fire in zone A, hot shutdown is achieved through the use of the feedwater coolant injection (FWCI) system and the i l 3

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I. l l .- 1 SRVs. The FWCI system utilizes a feedwater train to provide makeup; heat removal and overpressurization protection are provided by the SRVs. To l reach cold shutdown, the isolation condenser, located in zone A, will be repaired and used to bring the reactor to a condition where the SDC system I can be utilized. SDC system operation will require the operator to align the fire water system to remove heat from the SDC heat exchangers and possibly to repair parts of the SDC system. Repair procedures for both the l SDC system and the isolation condenser consist primarily of power and con- l trol cable repair or replacement. The isolation condenser repairs are  !

I expected to take less than ten hours and the SDC repairs less than a day.

Following a fire in the SDC pump room (F-5 zone B), the isolation condenser l is used to maintain hot shutdown and the CRD pump is used to provide inven- I tory makeup. Neither system is affected by the fire, and normal system I operating procedures can be used to operate the systems. Cold shutdown is achieved through the use of the low pressure coolant injection (LPCI) system l and the automatic depressurization system (ADS). Reactor pressure is l reduced, a flow path to the torus is created by opening the ADS valves, and  !

the LPCI system is used to provide makeup and core cooling. Heat is removed l from the LPCI heat exchangers through the emergency service water system.

This mode of core cooling is prescribed in previously existing plant l emergency operating procedures.

I Revision 2 of the Millstone Unit 1 safe shutdown analysis outlines another l means of reaching cold shutdown following a fire in the SDC pump room. In this procedure the JCI system is used to provide maktup to the reactor l vessel but does not provide cooling. A gravity-driven flow path through the SDC system from the reactor vessel to the torus is established, and the SDC heat exchangers are used to remove heat from the core to the RBCCW. This l eliminates the need to operate the ADS valves. Both methods of achieving cold shutdown are explained in Revision 2.

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Fire area F 6 is the gas turbine building. Essentially normal shutdown procedures can be followed after a fire in this area. The isolation l

condenser, CRD pumps, and SDC system are all available. Power supplies are either the normal power supplies or the unit diesel generator.

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A fire in area F-7, the screenwell building, causes a loss of the service water system. The loss of the service water system fails the diesel gene-l rator and the RBCCW system (normally the heat sink for the SDC heat l exchangers). Therefore, the fire water system must be manually connected to l the secondary side of the SDC heat exchangers in order to use the SDC system ]

to maintain cold shutdown. Hot shutdown and reactor inventory is maintained '

with the isolation condenser and the CRD pump. Power to the CR0 pump is )

l provided from the gas turbine generator or via the Unit 2-to Unit 1 i backfeed.

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The systems described in this utility submittal for safely shutting down the l Millstone Unit 1 plant in the event of a fire are the same as those l described in previously reviewed utility submittals. The operator actions required to place the systems into service or to repair damaged components  !

I also have not changed between submittals. Additionally, the repair l procedures for the isolation condenser and SDC system, which were comitted I to in previous submittals, have been developed (Station procedures MP799.1 l and MP799.2 respectively). )

i One concern resulting from this review that may or may not have been addressed in previous submittal reviews was the capability of the fire pro-l tection system to adequately perform all functions required of it in a fire induced transient. These functions include: providing water to fight the fire, providing makeup to the isolation condenser, oroviding SDC heat exchanger secondary side flow, and providing flow for drywell cooling (dry- l well spray flow). In response to this concern the licensee provided (during i the site audit) calculations of fire water use as a function of time after the fire and calculations of makeup capacity to the fire protection system water tanks. Based on these calculations, the fire protection system would l be capable of providing sufficient flow to meet the fire fighting and heat '

removal demands.

Reoair Procedures I Another concern identified in the review was the staffing requirements for the repairs postulated for the isolation condenser and the SDC system. The i submittal implies that personnel from the fire brigade could be used for equipment repair. Discussions with plant personnel and a reviN of the 5

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procedures indicate that, while the fire brigade may be available for the g work, when staffing repair requirements were formulated no credit was taken l for the fire brigade. The on call shift and the operating staff excluding l the fire brigade were deemed adequate to perform all necessary repairs.  !

l A11ociated Circuits I The licensee performed an associated circuit arialysis for circuits with physical separation less than that prescribed in Appendix R Section !!! G.2 I and associated with safe shutdown circuits in one of three ways: comon j bus, comon enclosures and spurious signals. The review of circuits to be l examined for associated circuit failures included power, l instrumentation circuits.

control and I I Two items of concern were addressed in the associated circuit analysis for circuits linked by a comon bus: breaker coordination and multiple l simultaneous high impedance faults (below the trip point for individual breakers). A breaker coordination study was performed but was not included g in the submittal. This inforniation is available at the Hillstone Unit 1 site.  !

l Samples of the breaker coordination study were reviewed during the plant audit. This study addressed breaker coordi.ation in both the AC (4160V, 480V, and 120V) and 125V DC power systems In all cases sampled, proper l breaker coordination did exist between t* breaker in the area of the fire  !

and the feeder breaker (not located in t , area of the fire) for the damaged I bus. Sample studies for each of t's four power supply systems were reviewed. Based on this review, the Hillstone Unit 1 power supply systems meet the breaker coordination requirements of Ger.aric Letter 81 12 (Ref. 3).

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The licensee does not consider the existence of multiple high impedance I faults to be likely for several reasons. However, the capability to recover from these fault combinations has been addressed. All fire areas were l examined to identify the potential for high impedance faults. As a result of this examination, procedures were modified to alert the operator to the potential for breaker failures due to multiple high impedance faults as a I result of fires in the reactor building, the turbine building, and the screenwell building. Since the turbine building is one large fire zone, the 6

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power supplies loss of AC tnd DC power is addressed for this area; normal are not available. For a fire in the reactor building or in the intake l structure (screenwell building), procedures ONP 5250 and 525G direct the operator to strip unnecessary loads until the supply breakers can be l reclosed.

The fire area approach was used to accoun'. for potential associated circuit l problems due to comon enclosures. Since all equipment in a fire area was assumed to be affected by a fire in that area, all equipment in a comon I enclosure would be affected by the fire.

Spurious operation of various equipment has been addressed in one of three l ways. Some equipment (not required to function during normal operation or during a fire-related shutdown) is isolated before a fire by cpening cf I designated breakers. Equipment isolated in this manner included the reactor head vent valves and the main steam drain valves. Other equipment is isolated by transfer or isolation switches. Equipment in this category l

includes ADS, isolation condenser, reactor water cleanup, and main steam isolation valves. Finally, for equipment where spurious operation has I already occurred, precedures are established to mitigate the misoperation of the squipment.

Of special interest for tqe spurious operation of equipment is the operation of equipment that could result in the failure of an isolation device between I the reactor v:ssel and a low pressure system. The licensee identified those systems that penetrate the reactor vessel that could causa a loss or diver-l sion of reactor inventory if not isolated. The systems identified include the following:

I Reactor clean up system l Reactor head cooling line Reactor feedwater system '

Contn1 rod hydraulic Standby liquid control l Low pressure coolant injection Main steam  !

I Recirculation loop sample line j

! solation condenser vent to main steam I

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Automatic depressurization system Shutdown cooling system i Reactor head vent Sampling system l Scram discharge volune  !

1 The first six of these systems are passively isolated from the reactor l vessel through the use of check valves. For the remaining systems, orotec- l tive actions to insure proper isolation in the event of a fire have either I l been taken or are planned. The main steam system is isolated by closing the I MSIVs. The control circuits of the MSIVs will be modified with the instal- l 1ation of an Appendix R isolation switch, and appropriate portions of the l cable will be protected with flexible metal conduit.

Two shorts, one positive and one negative on an ungrounded 125V DC power supply, are required to open the safety / relief valves (the four automatic i depressurization valve' and two additional safety / relief valves). This type l of fire induced failure, although considered to be unlikely, was considered based on Generic Letter 86 10 (Ref. 2). The licensee has installed an l I Appendix R isolation switch to insure that these valves do not spuriously open.

The reactor water cleanup system suction line is isolated with a single motor operated valve in parallel with a normally closed manual valve. The I- licensee has installed an Appendix R isolation switch to insure that this motor operated valve will remain closed.

Both the main steam drain and reactor head vent lines are isolated by valves that are normally closed and have their power sources disconnected and are l not subject to spurious openings. In Revision 2 of their submittal, the licensee cor,ects the statement about the reactor head vent lines isolation I valves being normally deenergized. Based on additional review, these ,

solenoid valves were found not to be deenergized. The two series isolation valves are normally closed and fail closed on a loss of power.

l inventory loss calculated by the licensee for this one inch reactor head The g

vent line is an equivalent liquid flow rate of less than 1 gpm. Based on a this low flow rate, which is considerably 1ers than the 25 gpm Technical I 8 I

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Specification allowed leakage, the licensee does not consider this high/ low pressure interface to be an Appendix R concern.

l Tho isolation condenser noncondensable gas vent line contains two normally open solenoid-operated valves that fail closed on a loss of power in series with a manual valve that can be closed in the reactor building.

I The shutdown cooling system (SDS) injection line is isolated from the reactor vessel by a check va 'e in the low pressure injection system. The I licensee has comitted to remo.ing the power supply to the AC powered isolation valve on the shutdown cooling system suction line in the event of a fire. This valve is in series with two parallel DC powered normally open l valves that are also capable of providing system isolation. In Revision 2 of their submittal, the licensee removed the SDC system from the list of I high/ low pressure interface systems. The SDC system piping is high pressure piping, and tne low pressure refueling makeup connection was found to be l flanged closed with a reactor pressure rated flange. Therefore, there are no low pressure boundaries in tte SDC system.

Isolation for the sampling system is provided by three valves in series, two solenoid-operated valves (normally closed) and a back pressure-controlled l valve. The licensee does not intend to provide any additional isolation capability for this system.

I Isolation for each scram discharge volume is provided by two solenoid-operated valves in series. Both valves must remain deenergized to insure l scram discharge vclume isolation. In the Revision 1 analysis, the licer.see states thtt they in'.end to perform additional work to determine the effects of a fire on the.isolatien capability of the SDV vent and drain valves. An l associatect circuit analysis performed as part of Revision 2 sh us that a control room fire in Zone D could prevent these valves from operating I properly. To compensate for this, an operator will manually dump scram ,

pilot air from the SDV vent and drain line isolation valve operators. This operation will be performed in the reactor building. These valves cannot be l isolated prior to a reactor scram since during power operation the valves are open to ensure proper operation of the scram discharge volume.

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j Comunication i In the event that the Hillstone Unit I comunication system is lost because of a fire, which could happen for fires in areas F-1, F-2, and F-3, the I operators are instructed to use the Millstone Unit 2 comunication system.

This equipment is located in the Unit 2 control rcom; it can be set to broadcast on the Unit 1 station frequency and will actuate both vibrating l pages and operator radios. The Unit 2 comunication system is completely j independent of the affected Unit I comunication system components. The {

i comunication console is located in the Unit 2 control room, the base sta-  ;

tion is in Unit 3, and the antenna and repeater station is located at the meteorological tower. The repeater station has its own independent power I l supply in addition to an offsite power supply.  :

l l The submittal does not address the capability of the comunication system to l reach all plant locations and ensure the ability of the shift supervisor to i l effectively comunicate with operators in the plant regardless of their location. In response to this question, the licensee produced the results of tests showing that the comunication console signal would reach all areas of the plant and activate the vibrating pages (which all operators have) and that voice comunication can be established in almost all areas. Therefore, l in the event that the Unit ] control room must be evacuated, an effective means of comunication does exist for the shift supervisor.

I In the event that the Unit I control room must be evacuated or the Unit 2 comunication system must be used, a set of emergency procedures has been g

I placed outside of the Unit I control room. This will ensure that the shift supervisor has a set of procedures available under all fire-accident conditions.

l Instrumentation Reouirements NNECo has identified a set of parameters that it feels is adequate to ensure a safe reactor shutdown in the event of a fire. These parameters are:

l o Reactor level and pressure I o Isolation condenser shell level o Condensate storage tank level I 10 1

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f o Fire water storage tank level l Hotwell level I l o o Drywell temperature In addit'on to the control roca indication of these parameters, local j instrumentation that does not require ele trical power is available for l reactor level and pressure at two locations in the reactor building. The l cables for the control room indication cf these parameters is protected by a three-hour rated fire wrap.

The condensate storage tank level can be determineo using local indication l l of condensate transfer pump suction pressure which can be converted to a  !

tank level using a level vs pressure chart. The fireaater tank level can be visually monitored if necessary. Isolation condenser and hotwell level can I be monitored through the use of local gauges. l l Local monitoring of drywell temperature (required to ensure that reactor level indication will not be lost because of reference leg flashing) is possible by means of a portable meter. This meter must be manually

onnected when needed. The connection is made in the shutdown cooling pump

'oom (Fire Area F-5, zone B).

The Millstone Unit 1 instrvmentation available after a fire does not include suppression pool level and temperature. These parameters are recomended as parameters needed to achieve safe shutdown in IE Information Notice No. 84-

09. It is not included in the Millstone 1 safe shutdown analysis based on a set of calculations by the licensee that show that the torus level and temperature will not exceed design limits if safe rhutdown procedures are followed properly and that the initial conditions in the torus are within plant technical specification limits. The calculations are based on the heat added to the torus through operation of the FWCI system and SRVs to provide initial decay heat removal. (This method of shutting down the plant is used only for a fire in the reactor building, Fire Area F-5, zone A. In <

response to a fire in all other areas, the decay heat removal during hot shutdown is achieved through the use of systems that do not use the suppression pool.) In this accident sequence, shutdown procedures call for the repair of the isolation condenser (within 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />) and use of this system and the shutdown cooling system to reach and maintain cold shutdown.

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This removes the torus as a heat sink for decay heat. Based on this l

analysis, the lack of suppression pool level and temperature indication l after a reactor building fire should not adversely affect the ability of the operator to bring Millstone Unit I to a safe shutdown condition.

Ventilation Systems l The ventilation requirements for the areas containing the following systems /

components were evaluated for the Millstone Unit I safe shutdown analysis.

FWCI system CR0 pumps Diesel generator Switchgear area l LPCI pumps Control room SDC pumps Both the diesel generator and the FWCI system have ventilation systems that meet the requirements of Appendix R.

l The utility performed tests, before the startup of Millstone Unit 1, on the I LPCI pumps to determine the operability of the pumps with no ventilation available. The results of these tests showed that these pumps could operate for extended periods without ventilation. Because of similar spatial arrangements, the licensee feels that these test results are applicable to the CRD pumps as well. An additional consideration is that the substantially lower CRD pump operational requirements, intermittent rather than continuous operation and smaller pump size, would reduce the heat load  ;

in the area of the pump. l The utility performed analysis to show that the ambient temperature in the switchgear area, the control room, and the shutdown cooling pump room would not exceed temperatures beyond which equipment operability would be I affected. However, these analyses did not include the effect of any fires ,

on the area ambient temperature. In discussions with plant personnel this apparent oversight was clarified. The fires that would affect switchgear l area and control room temperatures are the same fires that would require local operation of the isolation condenser and the connection of the Unit 2-I to-Unit I backfeed to power the CRD pump. In these scenarios the equipment l 12 l

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in the switchgear room is not used, and local control of the equipment used ,

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Ill. CONCLUSIONS The systems designated as safe shutdown systems and the instrumentation used for a post-fire environment have not been significantly modified since the last staff review of the Millstone Unit No. I fire protection analysis.

The same systems (isolation condenser, FWCI system, S/RV (ADS valves), f I

shutdown cooling and low pressure injection system) are being used to provide the means to maintain coolant invet. tory and to achieve hot and cold shutdown. All required instrumentation is available in the post-fire environment. The one deviation (suppression pool level and temperature) from the staff suggested instrumentation was adequately explained and is not needed at this plant.

The analysis performed by the licensee adequately addresses the major areas l of concern for an alternate shutdown capability analysis. The associated circuit analysis identified areas where the existing design was not suffi-cient to meet Appendix R requirements. These deficiencies were corrected through several means, including installation of isolation switches, removal of power supplies to components whose spurious operation would lead to system damage or an interfacing systems LOCA, and procedural modifications.

I support in the analysis of system availability in a post-fire environment, systems were included. Power, cooling, and ventilation interactions were l identified and proper operation verified when needed.

Communication capability is supplied for the response to fires in which the l normal comunication system may not be available.

This is particularly important for Millstone Unit 1 since a large number of the alternate I shutdown systems require local operation. ,

The safe shutdown capability of Millstone Unit No. 1, as described in this l submittal and based upon conversations with utility personnel, meets the requirements of Sections Ill.G.3 and Ill.L of Appendix R and is therefore i acceptable.

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v ', IV. REFERENCES

1. J.F. Opeka to C.I. Grimes, "Millstone Nuclear Power Station, Unit No.1 Fire Protection Evaluation. 10CFR50. Accendix R Como11ance Review."

December 10, 1986.

1 g 2. "Implementation of Fire Protection Requirements (Generic Letter 86-10)," U.S. NRC, April 24, 1986,

3. "Fire Protection Rule (45 FR 76602, November 19, 1980) - Generic letter 81-12," USNRC, February 20, 1981.

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