ML20138G548

Affidavit of Pc Hearn Re Potential for Loss of Both Control Structure Chilled Water Sys.Certificate of Svc Encl

ML20138G548
Person / Time
Site:	Limerick
Issue date:	12/12/1985
From:	Peter Hearn Office of Nuclear Reactor Regulation
To:
Shared Package
ML20138G537	List: ML20138G533 ML20138G541 ML20138G548
References
OL, NUDOCS 8512160351
Download: ML20138G548 (6)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COM4ISSION In the Matter of )

)

PHILADELPHIA ELECTRIC COMPANY ) Docket Nos. 50-352

) 50-353

-(Limerick Generating Station, )

Units 1 and 2) )

AFFIDAVIT OF PETER C. HEARN I, Peter C. Hearn, depose and state as follows:

1. I am employed by the U.S. Nuclear Regulatory Commission as a Senior Mechanical Engineer with the Plant Systems Branch -in the Division of BWR Licensing, Office of Nuclear Reactor Regulation. My duties include the plant systems review of nuclear generating facilities including the evaluation of the effects of flooding en plant safety systems.

2. During-a design review performed in support of a proposed modi-l~

fication, the Licensee discovered that a potential existed for the occur-rence of a condition not covered by the plant's operating or emergency procedures, specifically, the loss of both redundant Control Structure Chilled Water Systems. Earlier design evaluations had concluded that water intrusion as a result of precipitation as severe as the Probable Maximum Precipitation (PMP) or a cooling tower basin break would not adversely affect safety related equipment. Those evaluations utilized

. site conditions and the plant configuration as described in the Final Safety Analysis Report (FSAR). Hcwever, existing grading, as a result of temporary construction buildings, precluded the establishment of final grading as described in the FSAR. During the evaluatien for the 8512160351 851213 '"

PDR O ADOCK 05000352.

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proposed modification, which used the same design base as the FSAR, the incomplete construction of barriers to water intrusion into the Unit 2 turbine building was recognized. Analyses utilizing these existing conditions indicated that water intrusion into the Control Structure was possible, leading to the resultant loss of the redundant, safety-related ,

Control Structure Chilled Water Systems. The Licensee has stated that this situation will be permanently corrected when the final grading for Unit 2 _

is complete. For the interim period, engineered barriers and floor drain plugs have been installed in the Unit 2 turbine building construction openings and higher curbs have been installed at pennanent plant personnel doorways to assure that floodwaters will not enter the control structure to the extent that the loss of safety-related equipment can result.

Because of the installation of engineered barriers and floor drain plugs, I have determined that the conclusions of the evaluation are unchanged.

3. The Licensee identified the following inleakage paths to the turbine building:

1) Two rolling steel doors located in the north wall'of the turbine building;

2) Three temporary construction openings covered by sheet metal walls in the condenser pit area of the north wall of the turbine buildirg;

3) -One personnel door located in the north wall of the turbine building.

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4) One : bank of steam line blow out panels located 19 the

, north wall of the turbine building; 5). Two two-inch equipment floor drain lines that di:, charge out of the north wall of the turbine building;

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6) One rolling steel door located in'tne#ecst wall of the '

turbine building; and ,

7) One personnel door located in the east wall of the turbine building. i ,

4. The rolling steel door in the east wall is sealed by a three-

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foot high barrier that consists of eight-inch I-Beams or eighteen-in,ch centers with corrugated steel sheathing. Similar barriers are installed in the turbine building behind the,three temporary construction openings -

and the two rolling doors in the norih wall V.o prevent water that leaks through the construction openings and rolling, doors' from reaching the control building. For analysis purposes, no credit was takt.s for these outer rolling doors or sheet metal vills. The added barriers can be opened to allow access to the turbine building. As part o'f the plant surveillance program, the Licensee has committed to leck 't.e barriers closed and provide administrative controls that requirt, shif t super-vision to be notified in order to open the bart:brs. Ir)ddition,tl'c Licensee has administrative controls to verifh to shift supervishun that

. the barriers are tiosed when access +.hrough the barriers is not. requir<.d.

5. The steam line blow out panels are also sealed by Lirriers that consist of eight-inch I-Beany;. on eighteen-inch centers with steel w .

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6. To minimize inleakage through the two personnel doors, a three-4 inch high concrete grout ramp was installed on the interior side of each door. The two floor drain lines and the two personnel doors are the only leakage paths that will allow flood water to enter the turbine and control buildings.' Because of the ramps near the turbine building personnel doors and the small size of the two floor drain lines, an insignificant amount of water will enter the turbine and control buildings during the short time interval that these leakage paths are under the flood water.

The water that enters the control building will collect on the floor at the 180 feet elevation, well below the 200 feet elevation where the con-trol building chillers are. located.

7. Based on my evaluation of the leakage paths and the additional engineered flood barriers, I conclude that the plant safety-related equip-ment will remain functional af ter the design basis flooding event described in the Limerick FSAR.

The foregoing is true and correct to the best of my knowledge and belief, c%G Peter C. Hearn

. Subscribed and sworn to before me this \ 2. day of w c. , 1985 chah

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i BEFORE THE COMMISSION s 5

In the Matter of ),

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, PHILADELPHIA ELECTRIC COMPANY ) Docket Nos. 50-352 .' '

) 50-353 (Limerick Generating Station, )

Units 1 and 2) )

CERTIFICATE'0F SERVICE d I hereby certify that copies of NRC STAFF RESPONSE TO R. L. ANTHONY / FRIENDS OF THE EARTH'S MOTION TO REOPEN.THE RECORD AND TO STAY OPERATION" in the >

above-captioned proceeding have been served on the following by deposit in the.'

United States mail, first class, or as indicated by an asterisk through deposit in the Nuclear ~ Regulatory Commission's internal mail system, this 13th day of December 1985:

Samuel J. Chilk Herzc H. E. , Plaine, Esd.,

Office of the Secretary General Counsel U.S. Nuclear Regulatory Commission Office of the General Counsel Washington, D.C. 20555* U.S. Nuclear Regulatory Commission Washington, D.C. ,20555*

Helen F.. Hoyt, Chairperson (2) Mr. Edward G. Bauer, Jr.

Administrative Judge Vice President & General Counsel Atomic Safety and Licensing Board Panel Philadelphia Electric Company U.S. Nuclear Regulatory Commission 2301 Market Street

' Washington, D.C. 20555* Philadelphia, PA 19101

• Dr. Richard F. Cole Troy B. Conner, Jr. , Esq.

Administrative Judge .

Mark J. Wetterhahn, Esq.

Atomic Safety and Licensing Board Panel . Conner and Wetterhahn U.S. Nuclear Regulatory Commission 1747 Pennsylvania Avenue, N.W.

Washington, D.C. 20555* Washington, D.C. 20006 s

Dr. Jerry Harbour Mr. Marvin I. Lewis i Administrative Judge 6504 Bradford Terrace Atomic Safety and Licensing Board Panel Philadelphia, PA 19149 U.S. Nuclear Regulatory Commission

. . . Washington, D.C. 20555* Joseph H. White, III 15 Ardmore Avenue Mr. Frank R. Romano Ardmore, PA 19003 Air and Water Pollution Patrol 161 F~ o rest Avenue Ambler, PA 19002 Kathryn S. Lewis, Esq..

1500 Municipal Services Bldg.

Ms. Phyllis Zitzer, President 15th and JFK Blvd.

Ms. Maureen Mulligan Philadelphia', PA 19107 Limerick Ecnlogy Action 762 Queen Street Po'.tstown, PA 19464 t

a -

> r, Thomas Ge'rusky, Director Zori G. Ferkin Bureau'.of Radiation Protection Governor's Energy Council Dept. of Environmental Resources P.O. Box 8010 L5th Floor, Fulton Bank Building 1625 N. Front Street Third and Locust Streets Harrisburg, PA 17105 Harrisburg, PA 17120 Director Associate General Counsel Pennsylvania Emergency Management Federal Emergency Management Agency

, Agency' Room 840 Basement, Transportation & Safety 500 C Street, S.W.

Building. Washington, D.C. 20472

'.Harrisburg, PA 17120 Robert J. Sugannan, Esq.

Robert' L. Anthony Sugarman, Denworth & Hellegers Friends'of the Earth of the 16th Floor-Center Plaza Delaware Valley 101 North Broad Street 103 Vernon Lane, Box 186 Philadelphia, PA 19107

.Moylan, PA 19065

, James Wiggins Angus R. Love, Esq. Senior Resident Inspector Montgomery County Legal Aid U.S. Nuclear Regulatory Consnission 107 East Main Street P.O. Box 47 Norristown, PA 19401 Sanatoga, PA 19464

! t q .

Charles W.'Elliott, Esq. Atomic Safety and Licensing Brose & Poswistilo- Board Panel

.325 N. 10 Street U.S. Nuclear Regulatory Commission-Easton, PA 18042 Washington,.D.C. 20555*

y' y Atomic Safety and Licensing Appeal David Wersan . Board Panel (8)

V f, Consumer Advocate U.S. Nuclear Regulatory Conunission

~yl X '

Office of Attorney General- Washington, D.C. 20555*-

1425 Strawberry Square s Harrisburg, PA 17120 Docketing and Service Section Office of the Secretary g Jay Gutierrez U.S. Nuclear Regulatory Commission Regional Counsel Washington, D.C. 20555*

, USNRC, Region I 4 631 Park Avenue Gregory Minor King of Prussia, PA 19406.' MHB Technical Associates 1723 Hamilton Avenue M- j

' Steven P. Hershey, Esq.

- Community Legal Services, Inc.

San Jose, CA 95125 t , 5219 Chestnut Street Timothy R. S. Campbell, Director Philadelphia, PA 19139 Department of Emergency Services 14 East Biddle Street West Chester, PA 19380 d; M ,q%

Joseph \Rutberg

- Assjlta)1t Chief Hearing , Counsel