B.1Design Specification
The details of the design change are specified below:
B.2Scope Description
This engineering change is used to evaluate the acceptability of allowing fourteen (14) scaffolds erected in accordance with MNT-NGGC-0004 to remain “stored” in-place in the Reactor Containment Building on a long-term basis during Plant Operating Modes1-4 in addition to Modes 5 and 6 (Refueling) and defueled. The scaffolds shall be seismically restrained per requirements of MNT-NGGC-0004 to prevent them from adversely impacting safety related components in accordance with Reg. Guide 1.29 and FSAR Section 3.8.3.4.2. The continued structural integrity of the scaffolds is assured by performing inspections in accordance with PLP-401.
Revision 0 of this EC does not evaluate a specific scaffold installation or provide specific changes to PLP-401, AP-545, MMM-020 and OST-1081. Revision of this EC will be required, as described in the Turnover Summary, during RFO-11 to document the as-installed location and configuration of the specific scaffolds that meet the requirements for remaining in-place above Mode 5 and mark-ups for document updates accordingly.
This engineering change also evaluates the acceptability of allowing four (4) stainless steel storage boxes and sixteen (16) 30 gallon barrels to remain “stored” in-place in the ReactorContainmentBuilding.Three storages boxes (SB1, SB2 and SB4) will have nominal dimensions of 4’Wx13.5’Lx3’H. Storage box SB3 will have nominal dimensions of 4’Wx8.5’Lx3’H. Each storage box will have four barrels placed in its vicinity. The 30 gallon barrels are approximately 2feet in diameter and 3 feet tall. The purpose of the storage boxes is to house scaffold components such as scaffold poles and ladders. The purpose of the barrels is for storage scaffold connections (e.g., knuckles). PLP-401 will control the placement and removal, as required, of the storage boxes and barrels at the specified locations in this EC.
See Section A.4 and Section A.5 for formal problem and solution statements.
B.3References
Industry Standards:
AISC Manual of Steel Construction, 8th Edition
OSHA Standard, 29 CFR Parts 1910.28 & 1926.451
Design Basis Documents:
None
Specifications:
CPL-HNP1-C-001, R0, “Floor Response Spectra Curves”
CPL-XXXX-W-005, R1, “Specification for Nuclear Power Plant Protective Coatings”
CPL-XXXX-W-006. R5, “Nuclear Power Plant Protective Coatings Procurement”
Drawings:
2165-G-011, R16, “GeneralArrangementContainmentBuilding Plan El. 221.00’ & 236.00’ “
2165-G-012, R17, “GeneralArrangementContainmentBuilding Plan El. 261.00’ & 286.00’ “
2165-G-040, R11, “ContainmentBuilding Equipment Letdown Area Unit 1”
2165-G-137, R17, “CVCS piping Containment Building Partial Plans”
2165-G-138, R17, “CVCS piping Containment Building Partial Plans”
2168-G-219, R8, “ContainmentBuilding Platform Sh 1”
2168-G-220, R10, “ContainmentBuilding Platform Sh 2”
2168-G-221, R12, “ContainmentBuilding Platform Sh 3”
2167-G-0680, R8, “ContainmentBuilding Internal Mat – Plan at El 221’, Unit 1”
SK-2165-MNE-R-0067, R10 - Reactor Bldg and Aux. building - Break and restraint locations & Jet impingement envelopes MS Piping plans
SK-2165-MNE-R-0071, R13 - Reactor Bldg and Aux. building - Break and restraint locations & Jet impingement envelopes FW Piping plans
SK-2165-MNE-R-0073, R9 - ContainmentBuilding - Break and restraint locations & Jet impingement envelopes Aux FW Piping plans
SK-2165-MNE-R-0074, R5 - ContainmentBuilding - Break and restraint locations & Jet impingement envelopes Aux. FW Piping plans
SK-2165-MNE-R-0147, R5 - ContainmentBuilding - Break and restraint locations & Jet impingement envelopes RC Piping plans
SK-2165-MNE-R-0148, R0 - ContainmentBuilding - Break and restraint locations & Jet impingement envelopes RC Piping partial plans
SK-2165-MNE-R-0137 (R6), -0138 (R7), -0139 (R6) - ContainmentBuilding - Break and restraint locations & Jet impingement envelopes. CVCS Piping plans
SK-2165-MNE-R-0154 (R3), -0155 (R2), 0156 (R3) - Containment Building - Break and restraint locations & Jet impingement envelopes SIRHR Piping plans
SK-2165-MNE-R-0176, R6- Containment Building - Break and restraint locations & Jet impingement envelopes SG Blowdown and Sampling Piping plans
SK-2165-MNE-R-0163, R4- Containment Building - Break and restraint locations & Jet impingement envelopes Reactor Primary Coolant Loop Piping plans
2165-G-176 R.13 - Steam Gen Blowdown and Sampling piping
2165-G-074R.18 - Aux. Feedwater piping
2165-G-072 R.23 - Feed Water piping
2165-G-071 R.24 - Feed Water piping plans
2165-G-067 R.14 - Main Steam piping layout dwg.
5-G1000 S01 (R2) 5-G1000 S02 (R4) 5-G1000 S03 (R1) 5-G1000 S04 (R2) 5-G1000 S05 (R0) 5-G1000 S06 (R2) 5-G1000 S07 (R0) 5-G1000 S08 (R1) 5-G1000 S09 (R0) 5-G1000 S10 (R0) 5-G1000 S11 (R2) 5-G1000 S12 (R0) 5-G1000 S13 (R0) 5-G1000 S14 (R2) 5-G1000 S15 (R1) 5-G1000 S16 (R1) 5-G1000 S17 (R1) 5-G1000 S18 (R3) 5-G1000 S19 (R2) 5-G1000 S20 (R1) 5-G1000 S21 (R0) 5-G1000 S22 (R1) 5-G1000 S23 (R1) 5-G1000 S24 (R0) 5-G1000 S25 (R1) 5-G1000 S26 (R1) 5-G1000 S27 (R0) 5-G1000 S28 (R0) 5-G1000 S29 (R1) 5-G1000 S30 (R1) 5-G1000 S31 (R1) 5-G1000 S32 (R2) 5-G1000 S33 (R0) 5-G1000 S34 (R1)
5-S1005 (R0)
Calculations:
HNP-C/STRU-1014, R0
HNP-C/STRU-1027, R0
HNP-C/STRU-1003, R1
NED-C/EQ-1007, R0, “Seismic Response of Freestanding Scaffolding”
NED-C/STRU-1006, R1, “Qualification of Scaffolding for MNT-NGGC-0004”
3-A-08-005, R2, “Hydrogen Generation Study”
3-A-05-001, R1, “Heat Sink calc for CB Analysis”
CPA-0015, R1, “Containment Net Free Volume Calc”
CPA-0016, R0, “Open Area at Flood Water Line (El. 228.14)”
PRA-W-MS/FW-1157-3, R5 - Determination of postulated Break locations and rupture restraints for MS/FW Loop #2
PRA-W-MS/FW-1155, R2 - Determination of postulated Break locations and rupture restraints for MS/FW Loop #1
PRA-W-MS/FW-1156-40, R2 - Determination of postulated Break locations and rupture restraints for MS/FW Loop #3
PRA-W-AF-200-3-22, R4 - Determination of postulated Break locations and rupture restraints for Aux FW Piping Loop #2
PRA-W-AF-200-2-23, R4 - Determination of postulated Break locations and rupture restraints for Aux FW Piping Loop #3
PRA-W-AF-200-1-24, R3 - Determination of postulated Break locations and rupture restraints for Aux FW Piping Loop #1
PRA-W-BD-3068-1C-19, R4 - Determination of postulated Break locations and rupture restraints Blowdown Piping
PRA-W-BD-3069-1C-18, R5 - Determination of postulated Break locations and rupture restraints Blowdown Piping
PRA-W-BD-3070-1C-17, R4 - Determination of postulated Break locations and rupture restraints for Blowdown Piping
PRA-W-SI-0055, R1 - Determination of postulated Break locations and rupture restraints for Safety Injection Piping
PRA-W-CS-0057, R1 - Determination of postulated Break locations and rupture restraints for CVCS System
PRA-W-CS-3003-1C-41, R3 - Determination of postulated Break locations and rupture restraints for CVCS System
PRA-J-M-0001 , R2 , Jet Impg Eff On ESSN PPG/Break In The Hi Head Safety Inj.H.L.
PRA-J-M-0002, R2 - Jet Impingent Loads on Main steam lines
PRA-J-M-0003, R1 - Jet Impingent Loads on main steam penetration
PRA-J-M-0006, R4 - Jet Impingent Loads on Mech equipment
PRA-J-M-0007, R4 - Jet Impingent Loads on Mech Piping
PRA-J-M-0008, R2 - Jet Impingent Loads on Mech Equipment (Various Systems)
PRA-J-M-0009, R1 - Jet Impingent Loads on Mech Equipment (SI)
8S44-P-0101, R4 – Station Blackout Coping Analysis Report
Nuclear Generating Group (NGG) Procedures:
EGR-NGGC-0003, R9, ”Design Review Requirements”
EGR-NGGC-0005, R18, “Engineering Change”
EGR-NGGC-0102, R3, “Safe Shutdown/ Fire Protection Review”
EGR-NGGC-0308, R6, “Pipe Stress Analysis”
MNT-NGGC-0004, R3, “Scaffolding Control”
MNT-NGGC-0003, R7, “Radiation Shielding Use”
MNT-NGGC-0005, R1, “ Control of Rigging and Temporary Loads”
MNT-NGGC-0007, R2, “Foreign Material Exclusion Program”
Plant Procedures:
AP-545, R24, “Containment Entries”
CMP-003, R14, “Protective Coatings”
ENP-017, R10, “Component Quality Class”
FPP-004, R12, “Transient Combustible Control”
MMM-011, R24, “Cleanliness and Housekeeping”
MMM-020, R40, “Operation, Testing, Maintenance and Inspection of Cranes and Special Lifting Equipment”
OST-1081, R9, “Containment Visual Inspection When Containment Integrity is Required Mode5”
PLP-110, R13, “Quality Assurance Program for Quality Class B Items and Activities”
PLP-401, R16, “Ladder and Equipment Use and Storage”
PLP-610, R16, “Equipment Identification and Numbering System”
TMM-409, R2, “Aluminum/Zinc Inventory Control in Containment”
Plant Change Documents:
None
Regulatory Documents:
Regulatory Guide 1.29
Regulatory Guide 1.61
HNP FSAR
HNP Technical Specifications
OSHA Standard, 29 CFR Part 1910.28 and 1926.451
Other References:
Steam Tables
B.4Design Inputs
Following is a list of applicable design inputs specified to meet the requirements of ANSI N45.2.11. (See EGR-NGGC-0005, Attachment 2, for details).
1. Basic Functions of Each Structure, System and Component:
Scaffolds, storage boxes and barrels stored in Containment do not have an on-line or operating SSC function other than pre-staging for outage use that is specific to the access, shielding, or other activity using it.
The purpose of the ContainmentBuilding is to house, support, and protect the Reactor and its support systems and components. It functions as a support structure and a fission product barrier to releases involving the reactor and the support systems it houses for normal and abnormal loading conditions.
Reference:
- FSAR Sections 3.8.1, 3.1.12 and 6.2
2. Performance Requirements such as Capacity, Rating, and System Output:
Scaffolds, storage boxes and barrels must be qualified for 0.075g OBE (Operating Basis Earthquake) and 0.15g SSE (Safe Shutdown Earthquake) ground motion. Scaffolds must be rated for their intended use in accordance with MNT-NGGC-0004.
Reference:
- MNT-NGGC-0004
- CPL-HNP1-C-001
- FSAR Section 3.8.3.3.3
- FSAR 3.1.2, Criterion 2 – Design bases For Protection Against Natural Phenomena
3. Codes, Standards, and Regulatory Requirements:
The scaffolds, storage boxes and barrels will be evaluated to ensure that the Reg. Guide 1.29 criteria are satisfied.
Reference:
- Reg. Guide 1.29
4. Design Conditions such as Pressure, Temperature, Fluid Chemistry and Voltage:
The design conditions in containment are, Normal Condition: temperature < 120°F, Accident Condition (LOCA): temperature 270°F. During LOCA conditions, hydrogen is generated in containment as a result of the borated water in containment spray solutions. The containment spray initiates corrosion of zinc galvanized metal, aluminum and zinc based paints to produce hydrogen.
Reference:
- Calculation 3-A-08-005
- FSAR section 6.2.1 and 6.2.5
- FSAR section 3.1.37, Criterion 41 – Containment Atmosphere Clean Up
5. Loads such as Seismic, Wind, Thermal, and Dynamic:
Deadweight, live load, high energy line break, jet impingement, thermal and seismic (SSE equivalent to DBE)
References:
- FSAR Sections 3.6, 3.6A and 3.8.3.3.3
- FSAR 3.1.4 – Criterion 4 Environmental And Dynamic Effects Design Bases
6. Environmental Conditions:
SSC’s and items stored in Containment are subject to LOCA environmental conditions in Containment. Any applied coatings must be of a type qualified for such environmental conditions. The scaffolds, storage boxes and barrels must have insignificant impact on Containment Heat Sink and Free Volume analysis considered in Containment and Accident Analysis.
References:
- FSAR Section 3.11
- FASR 3.1.34 – Criterion 38 Containment Heat removal
- FSAR 3.1.4 – Criterion 4 Environmental And Dynamic Effects Design Bases
7. Interface Requirements:
Scaffolds, storage boxes and barrels remaining in Containment must not adversely interact with any Safety-Related SSC’s during normal Operation, Safe Shutdown Earthquake, or Design Basis Accident. Scaffolds, storage boxes and barrels remaining in Containment must not contain elements that represent potential debris for transport to and impact on Recirculating Sumps.
References:
- FSAR Section 3.2.1
8. Material Requirements:
Scaffolds, storage boxes and barrels remaining in Containment during modes 1-4 must not contain aluminum and zinc or have any more than negligible impact on hydrogen generation in a DBA. Items installed or stored in Containment must not contain aluminum unless evaluated and its addition will not exceed the cumulative inventory design limit described in calculation 3-A-08-005 and the associated inventory log. Applied coatings on exposed surfaces in Containment must be Service Level I, DBA resistant type, as provided by CPL-XXXX-W-005 and CPL-XXXX-W-006 unless evaluated for acceptability otherwise. Service Level 1 coatings in the Containment shall be applied per CMP-003 requirements.
Materials shall be compatible with the normal and accident environmental conditions. Per PLP-110, “Seismically designed materials, such as steel plate, structural steel, bolts, nuts, pipe, etc., may be procured as nonsafety related items (i.e., Quality Class E).”
References:
- CPL-XXXX-W-005
- CPL-XXXX-W-006
- PLP-110
- FSAR section 3.1.37, Criterion 41 Containment Atmosphere Clean Up
9. Mechanical Requirements:
See design input 8 for hydrogen generation limit considerations.
The structures added by this EC must not cause a pressure imbalance inside containment. A pressure imbalance refers to blocking air flow with the boxes, barrels and scaffolds such that air flows are redirected resulting in pressures that are different than, or did not exist prior to the modification. Containment pressure changes must not negatively affect the scaffolds, boxes and barrels.
10. Structural Requirements:
Restraint of scaffolds shall be provided where contact and clearances to Safety-related SSC’s could result in adverse impact by the scaffolds as described in MNT-NGGC-0004. Scaffolds will be installed and inspected in accordance with MNT-NGGC-0004.Storage boxes and barrels should be located so that there are sufficient clearances to safety-related SSC’s to preclude any adverse impact, per the requirements in PLP-401.
References:
- MNT-NGGC-0004
- NED-C/STRU-1006 (basis for MNT-NGGC-0004)
- PLP-401
11. Hydraulic Requirements:
Not applicable
12. Chemistry Requirements:
Not applicable
13. Electrical Requirements:
Not applicable
14. Layout and Arrangement Requirements:
Scaffolds are to be arranged and configured to support shielding or access function with minimal potential for seismic interaction and without blocking personnel access in Containment. Storage boxes and barrels to be located such that there is minimal potential for seismic interaction and blocking of personnel access in Containment.
References:
- FSAR Section 3.2.1
- FSAR 3.1.35 Criterion 39 Inspection Of Containment Heat removal System
15. Operational Requirements Under Various Conditions:
The scaffolds will be functional for use during Modes 5 and 6 (Refueling) but not procedurally acceptable (green tagged) for personnel use during Modes 1-4 when the walkboards have been removed from Containment. At each Containment entry and prior to Containment closeout, the inspection checklist requirements specified in PLP-401 shall be completed.
The storage boxes and barrels shall be secured shut prior to entering Modes 1-4.
References:
- PLP-401
16. Instrument and Control Requirements:
Not applicable
17. Access and Administrative Control for Plant Security:
Not applicable
18. Redundancy, Diversity, and Separation Requirements of Structures, Systems, and Components:
Not applicable
19. Failure Effects on Requirements of Structures, Systems, and Components:
Scaffolds must not contain coatings, netting, temporary tags, lead shielding blankets, or other elements that could fail during DBA and become transportable debris resulting in Recirculating Sump functional loss during Modes 1-4. Scaffolds must be designed, configured, located, or restrained to preclude adverse seismic interaction with any Safety-related SSC’s.
Storage boxes and barrels must be configured such that they do not allow intrusion of water into the boxes during Modes 1-4 in order to preclude the generation of hydrogen in a DBA.
20. Test Requirements:
Coatings installation on scaffold material is inspected per CMP-003. There is no testing other than sign off of the coating inspection report. This work is being performed by WO 239133-03. Scaffold installation will be inspected in accordance with MNT-NGGC-0004 requirements and acceptance will also be documented on the inspection report.
21. Accessibility, Maintenance, Repair, and ISI Requirements:
The scaffolds, storage boxes and barrels are maintained by performing inspections that will identify degraded and/or missing parts. The HNP Facilities Coordinator is responsible for maintaining the scaffolds and storage boxes and ensuring the integrity of the scaffolds and storage boxes parts to prevent the possibility of creating foreign material in Containment.
Reference:
- MNT-NGGC-0007
22. Personnel Requirements and Limitations:
Not Applicable
23. Transportability Requirements:
The scaffold components, storage boxes and barrels shall be transported into the RCB per MNT-NGGC-0005 and MMM-020, as required.
Reference:
- MNT-NGGC-0005
- MMM-020
24. Fire Protection or Resistance Requirements:
Surface coatings of more than 1/16” thickness and combustible or flammable materials must be evaluated for impact on the Containment combustible loading calculation. The scaffold structures must not adversely impact the physical integrity or proper functioning of sprinklers and detectors. Rubber matting under base plates must not extend beyond the perimeter of the base plate. The scaffold structures must not obstruct Fire Brigade access or access required to fire fighting equipment or valves.
Reference:
- FPP-004
- FSAR 3.1.3 Criterion 3 – Fire Protection
25. Handling, Storage, and Shipping Requirements:
Scaffold, storage box and barrel locations and configurations within Containment must not adversely impact any SSC’s during operation, SSE or DBA.
26. Other Requirements to Prevent Undue Risk to the Health and Safety of the Public:
Not applicable
27. Materials, Processes, Parts, and Equipment Suitability for Application:
Refer to Design Input # 8.
28. Safety Requirements for Preventing Personnel Injury:
Scaffolds are to be built in accordance with MNT-NGGC-0004. Scaffold walkboards, scaffold ladders, lead shielding blankets, netting and miscellaneous hardware (such as S hooks to hang shielding), as applicable, must be reinstalled and re-inspected and appropriately tagged for use at the start of every outage in accordance with MNT-NGGC-0004 and MNT-NGGC-0003. Scaffolds will not be rated for personnel access/work platforms during Modes 1-4 when the walkboards are not in-place.
Reference:
- MNT-NGGC-0004 and MNT-NGGC-0003
B.5Assumptions
None
B.6Evaluation
HNPReactorContainmentBuilding is a seismically designed, Safety-Related structure. The systems within the ReactorContainmentBuilding are either seismically designed, Safety-Related or their design or location assures that no Safety-Related SSC’s can be adversely impacted by their failure in a DBA or SSE. Accordingly, storage or pre-staging of equipment, including scaffolds and storage boxes, in the Containment at above mode 5 or 6 must meet certain key acceptability criteria as described in PLP-401, MNT-NGGC-0004, MMM-011, FSAR, and other design and licensing basis documents. These include:
a)Scaffolds, storage boxes and barrels must maintain structural integrity under SSE, DBA, and post-accident conditions.
b)Items must be restrained, located, or evaluated as required to assure no adverse seismic interaction with sensitive safety-related components from rolling, sliding, or overturning of the scaffold.
c)Floor loading must be within design or an analyzed limit of the floor. If a scaffold is attached to an SSC, it shall be attached in such a way as to limit the loading impact on the SSC to maintain design basis compliance.
d)Must not exceed the cumulative total allowed quantity of aluminum/zinc described in AP-545 and calculation 3-A-08-005 to assure hydrogen generation limits are not exceeded.
e)Must have no protective coatings, have protected coatings that are DBA resistant per specifications/procedures, be encapsulated, or specifically exempted from coatings requirements via an approved EC to assure minimal coatings impact on Recirculating Sumps.
f)Containment Free Volume and Heat Sink are within limits or not adversely affected.
g)Containment spray distribution must not be adversely affected.
h)Air flow in Containment must not be adversely affected.
i)Thermal growth of SSC’s and stored material must be considered in the restraint and clearances provided.
j)Pressurization must be considered to assure no adverse impact on Containment pressures or adverse impact of Containment pressure on the items.
k)Scaffolds, storage boxes and barrels must not adversely impact post-LOCA flood level.