10 CFR 50.48(b)(1) requires, in part, that all nuclear power plants licensed to operate prior to January 1, 1979, must satisfy the applicable requirements of Appendix R,
Section III.G.
Section III.G invokes
Section III.L, which requires that the alternate or dedicated post-fire SSD capability shall be able to achieve and maintain hot standby conditions and the
reactor coolant system process variables shall be maintained within those predicted for a loss of normal alternating current power. Also,
10 CFR 50, Appendix R, and related NRC Fire Protection
SERs dated August 8, 1984, and November 21,1985, confirmed the licensees compliance with Sections III.G. and III.L and required that where alternate or dedicated shutdown is relied upon, the pressurizer
PORVs must be de-energized early in fire scenarios to prevent spurious operation. Contrary to the above, prior to November 19, 2003, the licensees alternative/dedicated post-fire SSD capability for a fire in FZs 19, 20, or 22 did not meet these requirements. Plant procedures would not de-energize the pressurizer
PORVs early in fire scenarios to prevent spurious operation. Further, spurious operation of the
PORVs could cause a steam void in the reactor vessel head and failure to maintain
RCS process variables within those predicted for a loss of normal
AC power. Additionally, spurious operation of the charging pump suction valves could result in damage to the A charging pump, which in turn could result in failure to maintain
RCS process variables (e.g., pressurizer level) within those predicted for a loss of normal
AC power. These nonconforming conditions have existed since the requirements of Appendix R became applicable in 1984 and 1985. Pending completion of a significance determination, this finding is identified as
URI 05000261/2004006-03, Appendix R
Safe Shutdown Vulnerabilities.
