JPN-92-064, Forwards Safe Shutdown Capability Reassessment,10CFR50 App R, in Ref to Util Re Fire Protection Improvement Program & NRC Re Insp Rept 50-333/92-80 on Fire Protection

Forwards Safe Shutdown Capability Reassessment,10CFR50 App R, in Ref to Util Re Fire Protection Improvement Program & NRC Re Insp Rept 50-333/92-80 on Fire Protection

ML20115J363
Person / Time
Site:	FitzPatrick
Issue date:	10/26/1992
From:	Ralph Beedle POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20115J367	List: JPN-92-064, Forwards Safe Shutdown Capability Reassessment,10CFR50 App R, in Ref to Util Re Fire Protection Improvement Program & NRC Re Insp Rept 50-333/92-80 on Fire Protection ML20115J387
References
JPN-92-064, JPN-92-64, NUDOCS 9210280153
Download: ML20115J363 (5)

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twem cenmanon h.i October 26,1992 JPN-92-064 U.S. Nucioar Regulatory Commission ATTN: Document Control Desk Mail Station P1-137 Washington, DC 70555

SUBJECT:

-- James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Fire Protection Program 1992 3afe Shutdown Capability Assessment r3ferencos: 1. NYPA letter, R. E. Beedle to the NRC, dated May 27,1992 (JPN 92-023), regarding the Fire Protection improvement Program. .

2. NRC letter, M. W. Hodges to H. P. Salmon, Jr., dated April 15,1992, regarding the Special Inspection (92 80) on Fire Protection.

3. NRC letter, R. A. Capra to R. E. Beedle, dated September 10,1992, regarding the issuance of exemptions from requirements of 10 CFR 50 Appendix R.

Dear Sir:

Thi > itter transmits the 1992 Appendiy R assessment of safe shutdown capability for the Je ',s A. FitzPatrick Nuclear Power Pio.it. The report titled " Safe Shutdown Capability b Gsessment,10 CFR 50 Appendix R,' September 1992," satisfies the Authority's .

commitments to complete and submit a new Appendix R analysis ( Attachment 1, item 1.1.6 of Reference 1). The assessment is the technical bases for achieving safe shutdown of the plant using the criteria in 10 CFR 50.48 and Appendix R. An earlier draft of this assessment was made available to the NRC during the March 1992 special safety team inspection of the fire protection program.

'Section 8 of the report, " Safe Shutdown Scenario and Timetable," has not been finalized and will be resubmitted by November 6,1992. Preliminary walkdowns indicate that there is sufficient plant staff and time to safely shutdown the plant.

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Modifications described in the assessment will be completed prior to startup from the current refueling outage, except where the NRC granted a temporary exemption from the requirements of 10 CFR 50 Appendix R (Reference 3). Additionally, the assessment resolves five Inspection Report 92-80 open items listed in Attachment 1. Coordination hnalyses for AC and DC Appendix R safe shutdown power supplies s tems 1.1.4 and 1,1.5 of Reference 1) will be submitted separately to the NRC by November 6,1992.

If you have any questions, please contact Mr. J. A. Gray, Jr.

Very truly yours, f/ -

Ralph E. Beedle REB /wcb

Enclosures:

1. Attachment 1

2. Safn Shutdown Capability Assessment cc: Regional Administrator U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA. 19406 Office of the Resident inspector U. S. Nuclear Regulatory Commission P.O. Box 136 Lycoming, NY 13093 Mr. Brian C. McCabe Project Directorate 11 Division of Rector Projects-l/Il U. S. Nuclear Re0ulatory Commission Mail Stop 14 B2 Washington. DC 20555

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-4 e ATTACHMENT 1 Fire Protection Program Safe Shutdown Capability 1992 Assessment-James A. FitzPatrick Nuclear Power Plant -

Docket No. 50-333 The assessment resolves the following open items identified in Inspection Report 92-80 (Reference 2):

1. Section 2.1.1, DET ltem 1: Consider the affects of offsite power availability during the fire scenarios (URI 333/92-80-01).

Resolution: The affecto of the availability of off-site power has been taken into account in performing this analysis as confirmed in Section 3.2.2, Loss of Off-Site Power, page 3-4, of the assessraent report.

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2. Section 2.1.1, DET ltem 2: Previous analysis did riot consider the affects of high impedance faults (URI 333/92-80-01).

Resolation: . The assessment evaluated the affects of multiple high impedance faults as discussed in Section 10.1 of the assessment report. This also resolves item 1.1.3 of Reference 1,

3. Section 2.2.2: Long term corrective action (identified as item X C.6 in Reference 3) requires development of an optimal shutdown equipment list (URI 333/92-80-02).

Resolution: Table 3-1 identifies the minimum safe and alternative shutdown components, fable 3-2 proddes a listing of plant monito.ing instruments utilized for safe and alternative shutdown. The tables identify the safe shutdown equipment designation, the associated equipment description, the component fire zone and fire area location along with the system identification number. This also resolves item 1.1.2 of Reference 1.

4. Section 2.3.4: Proposed use of ADS /LPCI method for safe shutdown would requlre additional NRC review (URI 333/92-80-05).

Resolution: Table 1 1 of the Safe Shutdown Capability Assessment report provides the compliance method and the safe shutdown systems available for each fire area, in Fire Areas ID, Vll, IX, X, XI, XV, XVI, XVil, and XVill, hot shutdown will be achieved and maintained by the use of ADS /LPCI and/or ADS /CS.

As discussed in FitzPatrick's Updated FSAR Section 6.5, ADS, LPCI, and CS are the safety-related systen.s redundant to HPCI Using ADS /LPCI and/or ADS /CS to cool the core, it is possible to temporarily uncover the core depending on the coolant

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levelin the ieactor when the low pressure ECCS are initiated While the core may i become temporarily uncovered, Updated FSAR Section 6.5 concludes that excessive fuel clad temperature will not occur.

For Fire Areas IX, X, XI, XVll, and XVill, low pressure ECCS is considered redundant to HPCI and is the means used to achieve and maintain hot shutdown.

The fire protection requirements of Ill G.2 have been implemented to protect low pressure ECCS in these Fire Areas. For Fire Areas ID, Vil, XV, XVI, it is not practical to meet the fire protection requirements of lil,G.2, thus the alternative ,

shutdown capability provided by low pressure ECCS must meet the performance I requirements of Ill.G.3 and Ill.L. or an exemption from the requirements of these regulations must be approved by the NRC. The Au'hority requested and was granted exemptions for these fire areas.

The NRC approved the use of ADS /LPCI for achieving remote reactor shutdown for a fire in Fire Area Vil (Control Room, Relay Room, and Cable Spreading Room) in Reference 4.

In References 5 and 6, the Authority requested an exemption from the requirements of 10 CFR UO, Appendix R, Sections Ill.L.1.b and Ill.L.2.b to allow the reactor coolant level to drop below the top of the core during the use of alternative safe shutdown following a postulated fire anywhere in Fire Area Vil which renders the Control Room uninhabitable. The exemption request was based on an analysis which assumed the loss of all high pressure makeup coincident with reactor scram and isolation, and the operator initiation of ADS thirty minutes later. The NRC approved the exemption in Reference 7.

For Fire Areas ID and XVI, the Authority requested (Reference 8) that the exemption requested for Fire Area Vll be revised to include Fire Areas ID and XVI.

This revised exemption was gnnted by the NRC (Reference 11),

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For Fire Area XV, the NRC granted an exemption (Reference 9) from the requirements of Sections Ill.G.2, Ill.G.3, and Ill.L. In References 8 and 10, the Authority requested that the exemption be revised to more accurately reflect the equipment and configuration of the Torus Room. This exemption was granted by the NRC (Reference 11). The revised Fire Area XV exemption precludes the need to provide fire protection and precludes the need for alternative or dedicated shutdown capability. This exemption was based on the fire loading, occupancy and physical geometry of the Torus Room. Therefore, the revised Fire Area XV exemption allows the use of the redundant shutdown capability of the low pressure I

ECCS.

5. Section 2.3.3: NYPA's 1992 assessment identified a concern with the failure to include the instrument tubing in the earlier Appendix R analysis (URI 333/92 04).

Resolution: The assessment evaluated the affects of fires on instrument tubing as discussed in Section 10.3, " Affects Of Fire On instrument Tubing," of the assessment report.

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REFERENCES _

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1. NYPA letter, R. E. Beedle to the NRC, dated May 27,1992 (JPN-92-023),

regarding the Fire Protection improvement Program.-

2. NRC letter, M. W. Hodges to H. P. Salmon, Jr., dated April 15,1992, regarding the Specialinspection (92-80) on Firo Protection.

3. NYPA letter, R. E. Beedle to the NRC, dated September 13,1991 (JPN 91-050),

regarding the schedule for long term fire protective actions.

4. NRC Letter from D. B. Vassallo to J. P. Bayne, dated April 26,1983, regarding "Altemative Safe Shutdown Capability, Modifications and Exemptions to Meet Appendix R of 10 CFR 50 - Fire Protection."

5. NYPA Letter, J. C. Brons to D. B. Vassallo, dated June 14,198 5, (JPN-8 5-49),

regarding " Appendix R to 10 CFR 50, Section Ill.L Request for Exemption Regarding Alternate and Dedicated Shutdown Capability."

6. NYPA Letter, J. C. Brons to D. R. Muller, dated December 17,1985, (JPN-85-90),

regardng " Appendix R to 10 CFR 50, Section Ill.L Exemption Request Regarding Alternate and Dedicated Shutdown Capability."

7. NRC Letter, R. M. Bernero to J. C. Brons, dated September 15,1986, regarding

" Exemption From Appendix R of 10 CFR 50 Concoming Core Uncovery During Alternate Safe Shutdown."

8. NYPA Letter, R. E. Beedle to NRC, dated June 26,1992, (JPN-92-032), regarding

" Revised, New, or Temporary Exemptions From 10 CFR 50, Appendix R."

9. NRC Letter, D. B. Vassallo to J. P. Bayne, dated July 1,1983, regarding

" Exemption Requests - 10 CFR 50.48 Fire Protection and Appendix R to 10 CFR 50."

10. NYPA Letter, R. E. Beedle to NRC, dated July 31,1992, (JPN-92-043), regarding

" Revision To Exemption From 10 CFR 50, Appendix R."

11. NRC letter. R A. Capra to R. E. Beedle, dated September 10,1992, regarding

" Issuance of Exemptions from Requirements of 10 CFR 50,= Appendix R, for the James A. FitzPatrick Nuclear Power Plant."

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