ML110700086
| ML110700086 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 10/20/2009 |
| From: | Sullivan K Brookhaven National Lab (BNL) |
| To: | Daniel Frumkin, Brian Metzger NRC/NRR/DRA/AFPB |
| References | |
| FOIA/PA-2011-0069, TAC ME0780, Job Code J-4242 | |
| Download: ML110700086 (17) | |
Text
Metzger, Brian From:
Sent:
To:
Cc:
Subject:
Attachments:
Sullivan, Kenneth [ks@bnl.gov] 6y)CL-Tuesday, October 20, 2009 6:00 PM Frumkin, Daniel; Metzger, Brian Higgins, James C DRAFT RAI OCNGS Ph 2 102009 DRAFT RAI OCNGS Ph 2 102009.doc Dan / Brian Attached is a draft version of the RAIs related to the review of the Oyster Creek Phase 2 dated March 4, 2009 Would appreciate any comments or suggestions you may have so they can be incorporated into the final version Thanks Ken Sullivan BNL 1
Enei BROOKHAVEN NATIOjN-A'L LABORATORY managed by Brookhaven Science Associates for the U.S. Department of Energy www.bnl.qov Mr. Daniel Frumkin U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Division of Risk Assessment, Fire Protection Branch (NRR/DRA /
Washington, DC 20555-0001 rgy Sciences and Technology Department Building 130 P.O. Box 5000 Upton, NY 11973-5000 Phone 631 344-7915 ksabnl.qov October 20, 2009
Reference:
Dear Mr. Frum JCN No. J-4242, Task Order No. 1, Exelon (
Oyster Creek Nuclear Generating Station, I
ME0780 ikin*
By letter to the Nuclear Regulatory Commisisho(NRC) datedMMa'rch 4, 2009, Exelon Generation Company, LLC (the licensee), submitted a Rqu6estlfor Exempti*ronfom Title 10 of the Code of Federal Regulations, Part 50, Section IlI.G, "Fire Protetion of'S ShutdolCapability," for Oyster Creek Nuclear Generating Station (designated by the' censee4,slthe, 'Phase 2 submittal). In accordance with the scope of work described ir Ybf Project 1122.
havevewed the request submitted by the ln ain1 have r" tt, licensee andidentified a~o n
- ,"o~r additional inforation, as set forth in the Enclosure.
It should be noted that thIIIIIiofth:ecnca mrtso
,tshu.ee1a-s descrbennthis repoi!f esulted from a review of the technical meris of the licensee's March 4, 2 0dt!j bmit JQ P 11""11111115'.
t e 4 0
it pecifilally;-,tl, review was limited to an assessment of the feasibility andrblieablity 6fthe OMAs and the adequacy of defense-in-depth provided for fire areas which credit the performance of OMAs a,, a means of achieving and maintaining hot shutdown conditions.
Issues related to the licensee's interpret'ation of its fire protection licensing basis, were beyond the scope of this revie wilh If you have any me at the phone number or e-mail address indicated above.
Sincerely, Kenneth Sullivan, Systems Engineering and Safety Analysis Group cc: B. Grenier, NRC 1
D. Diamond J. Higgins Project File J4242., Task 1
- 1I if'
- II1pp, Ii 2
Enclosure II~liI,.
1111 IIIIIIt
REQUEST FOR ADDITIONAL INFORMATION REGARDING REQUEST FOR EXEMPTION FROM 10 CFR 50 APPENDIX R. SECTION III.G OYSTER CREEK NUCLEAR GENERATING STATION DOCKET NO. 50-219 OCNGS Phase 2 Request, NRC TAC No. ME0780
Background
1tII.
By letter to the Nuclear Regulatory Commission (NRC) datedlM arc*{,4 2009 (Agencywide Documents Access and Management System (ADAMS) Accession NoML090640225 ), Exelon
' 1 C i k i, 4 1111f Generation Company, LLC (the licensee), submitted a Request for Exemption from Title 10 of the Code of Federal Regulations, Part 50, Section IIhIG "Fire Protection of Safe Shutdown Capability," for Oyster Creek Nuclear Generating.Saton (OCNGS).
In this submittal, Exelon is requesting that the Nuclear, Regu a1'ry Commission (NRC) approve an exemption request to allow the use of operator manu Ia1'tions (OMAs) as a means of satisfying the technical requirements 8f!Section III.G.2 of "p'ienaix R to 10 CFR 50 in certain satsfyng hetecnicl rqurem nts5 tiju p i.9!
'1111h.
locations (i.e., fire areas or fire zones) ofthe GCNGS None of *t e OMAs identified in the March 4, 2009 request were previously reviewed byithe Itaff. PaIgraph III.G.2 of Appendix R aameanis of ensurinPg th titoneýdat ransofeqhpen does not identify OMAs asam redundant trains of equipment remains free of fire damag.
,,HoWe'ver, plantswhic credit manual actions for Section IIl.G.2 compliance, mayu, obu.i acton forii Neto IIvG.
compliance may obtain )specfic NRQ approvalIfo the manual action via the exemption process in accordance with'trequiremetsf 10 CFR 50.12.
This exemption re~quest diesdrIes operat, map, ual actions that were not identified in a previous exempti.T request;,diorreviewe~dI)y the staff in a Safety Evaluation Report. The specific manual actiop~irlated to this request at, listed in Attachment 2 of the licensee's March 3, 2009 submift 1
The licensee's, stated basis fo6this request is the special circumstances of 10 CFR 50.12 (a)(2)(ii), which,ý states: "Application of the regulation in the particular circumstance would not serve the underlyin'yrgpurpose of the rule or is not necessary to achieve the underlying purpose of the rule" as the basis forthis request.
Under contract to the NRC, Mr. K. Sullivan, of Brookhaven National Laboratory, has been assisting the staff in reviewing the submittal and has determined that additional information is needed to complete his review. The requests for additional information (RAIs) described below resulted from a review of the technical merits of the March 4, 2009 submittal.
1
Requests for Additional Information RAI-01 Circumstances for Review The basis for this exemption request is described in Section 2.0 of Attachment 1 as follows:
Modifications needed to achieve compliance with Section II.G.2 of Appendix R, (e.g., _adding fire suppression and detection systems, installing fire barriers and/or rerouting cables) represent an unwarranted burden because they are not necessary to meet the underlying purpose of the rule.,!
Provide the following relevant details to support this conclusion':'III
,II"I I
th A technical justification of how the proposed arrangement achieves the underlying purpose of the rule.
Il' K
The specific requirements of II.G.2 that arenot met forfpach of the requesta exemptions, for example, a lack of fire barriersý,spatiablseparation, automatic suppression, etc.
A summary of the plant specific featuresj that, compensa e.for this lack of IlI.G.2-required features for each of the requestedli emptionsL"Eor example§, note any enhanced defense-in-depth measures such asliack K*Onition~sources and/or combustibles, more robust and/or suppl*,,*,tletection and s1uppression systems and the availability of the requestedemanual actionsI.
"* te h ica l ex ln to th t.f ATtechnical expla
'1a'on at jutifies, bow tl' roposed methods will result in a level of protection that is commepsurate with that intended by llI.G.2.
ii Sectionll['of Attachment ii statesthat the existing level of defense in depth is considered accelbtable for the majorityý Of OM.f s *ontained in the request. Section ILA of Attachment 1 identifies Ithe defense-in-deptlhielements (detection, suppression, combustible loading, etc) available i*ach of the 35 fire areas / zones. However, the request does not provide a sufficiently clexplanation rto pconfirm that the existing level of defense in depth is adequate to support the use aflMAslas a means of satisfying Section II.G.2 of Appendix R.
As described in Section 1.8.2 of Regulatory Guide 1.189 (RG 1.189), requests to permit the use of an alternative approach (i.e., use of OMAs as a means of satisfying Section II.G.2 criteria) should include a sound technical basis clearly demonstrating that the fire protection defense-in-depth philosophy is appropriately maintained and that the exemption is technically justified.
For each fire area/zone identified in the March 4, 2009 request, provide a justification which clearly demonstrates that the existing defense-in-depth elements (i.e., administrative controls, 2
fire protection systems and features, and safe-shutdown capability) are adequate to support the use of the requested OMAs as a means of satisfying Section III.G.2 of Appendix R.
Identify all areas where you do not propose to install or improve the automatic suppression and/or detection capabilities, and/or do not intend to implement other more restrictive fire prevention, detection, or suppression measures. For each of these areas, provide a technical justification to support the use of OMAs as a means of satisfying Section lII.G.2 in areas.
In addition, it is not clear how existing exemptions were considered in the evaluation of the level of defense-in-depth provided for each fire area / zone identified in the!March 4, 2009 submittal.
For example, Section III-A of Attachment 1 states that SER dated JUne 25, 1990 provided an exemption for a lack of automatic fire detection in Fire Zone T,,BrFZ**i B but the potential impact of a lack of detection on the feasibility and reliability of OMAs~lis not specifically addressed in the submittal li~l such The requested responses should clearly demonstrate that defense-in-depth is pf vided such that operators are able to safely and reliably achieve and maint*ihfhot shut down C'Pability from the control room. Note that it is the Nuclear Cegulatory guaomrcn~is~sion (NRC) staffs position that operator manual actions alone, regardless of their feasibilitYý and reliability, do not meet the underlying purpose of the rule without specific consideration!,
f the overall concept of defense-in-depth that is being applied in a ParticUilerfirareua.
RAI-02 Ensuring ThatOne bf the iRedundant Tains Is Free of Fire Damage Section Ill-A of Attachment 1 identifies 35 fire areas/zones that are not in compliance with Appendix R, Section IllR.2 b.cae s
dow*'
MAs would be required to align redundant train systemIs.N ach ieve'saf e snutown. Section11J-B also states that the analysis assumed worst-cas'e 1 "* 1 orT fire amage requiring all of the manual actions for a particular fire area/ne to be perrormed.
i Section 1!11 2 of Appendix! i provides three options for ensuring that one of the redundant trains of equipment remains 0 'e of fire damage. The use of Operator Manual Actions (OMAs),
in lieu of the thren options pro\\'Vided in III.G.2, is not explicitly included as a means of demonstrating com6plianceiwith Section III.G.2. Thus, systems and equipment that are not provided with a leveliof fire protection commensurate with Section III.G.2 must be assumed to be lost or damaged as a result of fire.
Confirm whether all redundant equipment located within a particular fire area, that is not provided with fire protection features specified in Section III.G.2 is assumed lost or damaged during a fire event and also confirm the time at which this equipment is assumed to be lost or damaged.
3
Section Ill-A of Attachment 1 states that the staff's approval of an exemption for a lack of automatic fire detection in Fire Zone TB-FZ-1 1 B was based on the following:
- the fire will not be of significant magnitude or duration,
- it will be promptly extinguished by one of the two automatic sprinkler systems installed in this fire zone, and
" the flow alarms will promptly alert the fire brigade who will respond to manually fight the fire.
As described in Section 6.2 of the June 25, 1990 SER, however,,1this list of considerations is not complete, as it does not include fire protection features provdifdorithe credited train of hot shutdown cables (i.e., a 1-hour rated fire wrap or relocating....
les). I For each of the fire areas/zones identified in the March"2009 submittal, proide a cross reference between the fire area/zone and any apl)r.oed exemptions being credi4d. For each exemption provide a concise, but accurate, listing0of fire prote~ction features identifi by the staff in the associated SER, and identify any cases where theSlevel of fire protection described by in the SER is no longer valid. For example, the staffosr6llIuation may have been based, in part, on the provision of a 1-hour rated fire*b arrier wrap fdrialhhot shutdown cables but the barrier may no longer be credited (i.e., rabandoned iniIlace). For any cases where ththhrabd by the staff, provide the level of fire protection has changed frromlia w W
I
- 1C hi 4111d justification which clearly demonstrates that e curient leV6bfife safety is equivalent to that which was approved by t alf"s '11! I In~ ~
~
~~p adiin1tah~LSc io l!ttsothate'IER In addition, Attachre1, Section I*states that tmanual operator actions identified in the March 4, 2009 submitta Iare requirddisja1result 6f%!
a) chahages to the origia'al safe shutdown anialysis, or b),jw, e implied in: the origti61safe shutdown analysis but for which an SER does not exist.
For each~fre area / zone idetifed inthe request, identify which manual actions are required as a result of (qaipr (b) above.
RAI-03 Other EVaIiatiots Fire areas may have other exemptions or engineering evaluations that affect fire protection systems or safe shutdown capabilities.
Provide a discussion of any other exemptions or evaluations that impact this request in any way and a justification for why such impact should be considered acceptable.
4
RAI-04 Fire Protection System and Fire Barrier Design Criteria Section III of Attachment 1 notes that several areas are equipped with various fire detection and suppression systems. However, the request does not state whether the systems have been designed and installed in accordance with applicable design standards or requirements.
For example: Section III of Attachment 1 states that Fire Zone OB-FA-9 is protected by a fixed, total flooding, automatic Halon 1301 extinguishing system but the request does not state whether the Halon system was installed and maintained in accordarfc'e'i particular design standard or basis, e.g. National Fire Protection Association Standard' 12A.
Section III of Attachment 1 also states that OB-FZ-6A is p, arated frbl~ther plant areas by
,s te.1,d" f illqth.
rated fire barriers. For areas such as these which credoitir[
barriers for proiding separation from other plant areas, state what the fire rating is for'*he barriers as well asl any penetrations and whether they are designed and installed in accordance with a particular standard or listing.
Where fire protection features such as detection and isu ppre sioh systems and fire rated assemblies are installed, describe the technical basis foS, such installations including the applicable codes, standards and listingsP ilna ddition, proVicdea technical justification for any deviations from codes, standards and lis.tigs 1!ndependent testing laboratories in the fire areas that could impact this evaluation. Lasty, po' a echnilufco for any non-rated fire protection assemblies."
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Additionally, Section of Attachment 1 staes that a water curtain located in openings between the 23' to5'fMelevations aJd51' to 75' elevations will provide reasonable assurance of extinguishing any pociUlated fire)1I t
of physical barriers between redundant s d cs m
i t
U h[
a s cc shutdown systems is pre dde f
pted, in concept, the use of an automatic fire suppression*
system whicoh discharges a "water curtain" across the boundary areas separating the reduindant systems. Awateicurtain may aid in the extinguishment of fires. However, as "HI*, _.ll,,,
discussed in Generic Lett't(pL) 83-;3,3, the design objective of a 'water curtain" is to reduce
'Ili*I,,
,i It; 11...
the spreao ases and ductsof combustion between adjoining areas, not fire extinguishment. Provide a technical basis to support your reliance on water curtains for fire extinguishmelnt 1
RAI-05 Time and Sdquence Assumptions An action is considered feasible if it is shown that it is possible to be performed within the available time (considering relevant uncertainties in estimating the time available). The tables provided in Section III.B of Attachment 1 do not provide a clear link to NUREG 1852 criteria for determining feasibility. For example, the notes accompanying the table state that the "allowable time limit" was obtained from safe shutdown calculations. Since these calculations were likely developed prior to the issuance of NUREG-1 852, the criteria and assumptions used to establish these times may not be consistent with those contained in the NUREG.
5
For each of the OMAs contained in this request, identify:
- 1) Action classification (prompt or symptom based)
- 2) Time available - defined as the period of time from a presentation of a cue for an action to the time of adverse consequences if the action is not taken
- 3) Diagnosis time, defined as: The time required for an operator to examine and evaluate data to determine the need for, and to make the decision to implement, an action 0
- 4) Implementation time; defined as: The time required by theloperator(s) to successfully perform the manipulative aspects of an action (i.e., not thediagnosis aspects themselves, but typically as a result of the diagnosis aeopts),zlincluding obtaining any necessary equipment, procedures, or other aids or de~vices; traveling to the necessary location; implementing the action; and checkingfthM the action has Ihad its desired effect In addition describe the amount of time, that hasbeen assumed for detection andiassessment of a postulated fire and provide a technical basis'fall this time The response should describe the methodology and ail assumptions used to determine each time. For example, it is not clear if anlysis assumel tiating time (i.e., Time 0) as the time at which the fire is detected, the timeiat whi*hthe fire is determined to pose a threat to safe shutdown equipment, the time the reactonisiscrammmedl te time'tat a spurious signal or actuation is observed in theicontrol room, orisomeibther in the fire scenario.
For "symptom based'*1MAs, providela justificatin to support the time assumed to be available to perform the action',iincluding confirmation that;there is adequate time for the operators to diagnose the need forie~act
ýionstaveli-to action 16tation(s), perform the actions, and confirm the expected, response befre:a firndesd cpsre equence occurs. Include a justification for assumi g 1*t'ht30ufiiptUtes would *e available to diagnose all actions.
,4 ilY 'fill,,
RAI-06 I"lnhiton Sources and Combuistible Fuel Load The information*.r*ovided in Attachment 1 of the request is generally too vague to determine the adequacy of methods established to control the handling and use of combustibles and ignition sources. For example i1for each fire area identified in the March 4, 2009 request, Attachment 1 identifies the principalf tpes of combustibles (e.g., fuel oil, cable insulation, lube oil, paper, furnishings, etc.) but does not quantify the amount, room size, or location of combustibles with respect to the cables and / or equipment of concern (i.e., those for which the exemption is being requested). In addition, the Attachment does not include any discussion of ignition sources in these areas.
Provide critical details and/or assumptions regarding the fire hazards for each fire area included in the request. This information may include, but is not limited to:
6
0 The number, type and location of potential ignition sources, The number and types of equipment that may exhibit high energy arcing faults, and the relationship between this equipment and any secondary combustibles, The quantity of cables and other secondary combustibles and their relationship to potential ignition sources, dt!Ii',
The cable type, e.g., thermoplastic or thermoset. If ther rm'plastic cables are used, provide a discussion of self-ignited cable fires,
! i t
Ratings for cables, e.g., IEEE-383, etc. If not rat*l*justify why fitrlespread would be assumed to be slow, Controls on hot work and transient combustibles in the are'a, and the proxinmity of secondary combustibles that could be impadted'1 by a{transient fire, and Dimensions of the rooms includigiceilig heights."I, RAI-07 Use of SCBAs,
'For Clarify the use of For exanTip',
althog g1Actions 10 & 12 may require the use of a self-contained breathin44alparatus SCBA Section ilB implies that operators would not be expected to need tMrtio!s a result, it is not clear if the discussion expetedto eedSCBA'sjto perforrr~e-se actionsts of the use of.SCBAs is it`nd*ýdet por-ray'enwrionmental conditions operators may be reasonabýy expect eencou'nter or if the request is seeking staff approval of the rationale provid'e so the need f'oSCBA rhay be eliminated.
RAI-08 Fire -enarios SectionIll Band Attachment 2, identify the OMAs that may be needed as a reulfieai
- fir, a / zone, but do not contain a suitably detailed description of the specific fire scenarios that have been considered. Although OMAs are identified to isolate damaged cables and reestablish control locally, no information is provided to describe the separation between the redundant trains of cables. For example, the scenario described for Action 14 in Attachment 2 states:
This action is being performed because there is the potential that the normal ventilation system would not be available due to cable damage.
7
The scenario does not provide any further information regarding the specific circuits of concern, such as, cable type, location / separation, location of potential sources of fire damage, etc.. It is also not clear where the cables are located relative to floor, walls and other trains or whether any spatial separation exists between the two trains.
For each OMA included in this request, describe the in situ and transient fire hazards (ignition potential and combustibles) in the fire area that have the potential to affect the redundant trains.
Provide a description of the proximity of the redundant train equipment to in situ hazards and the spatial relationship between the redundant trains in the fire area such that if they are damaged, manual actions would be necessary. Note, that this question is distinct from the RAI addressing Ignition Sources and Combustible Loading, whicn focused on the combustibles in an area, whereas, this RAI addresses the'seific relationship between ignition sources and combustibles and the redundant trains.
1,.
RAI-09 Fire Area of Origin Re-entry
, iitii, Section 111.8. of the March 3, 2009, request states thtdepehding on the fire scenario, operators may be required to re-enter certain fire areas; 10p'clu Iding Fire Zone TB-FZ-1 10C and TB-FA-26 to perform an action following fJrievent. However,11Sections 111.C.3 and 111.C.4 state:
"all operator manual actions addressed Yn'rthi b, pton rq *,taeprfomd in sepaate fir zones from the initiating fire area (no re-efftky rernt ontaditio between Sections 111.B and,,lll;G,.
For areas where operator re-entry "',6t-fire may be required (as described in Section Ill.B):
justifcatio (a) Provide a elUiau ac essibility, availability and operability of the equipment to Ili o n of, i;S lU p M n ti e d re be operated, givewltheassumptionstatbdin'the request that all unprotected equipment lcat6d, in a fire affed6ted area / zone is lost or damaged as a result of the fire.
(, P rovide a tabular rbss reference between all fire areas / zones that credit operator re-hli,
q11[ 1
'*It.
entry to perform O s and the specific equipment to be operated. For each piece of
" Ii st,
11l111.
equipment and /or ccmponent, provide a justification of why the assumption that all
. i 1 1" l l tt i
1 I ! 1 1 1 equipment located i. t e fire area of origin is lost during a fire does not apply.
(c) Provide information which demonstrates that the required shutdown equipment located within the area is maintained free of fire damage and remains operable following the fire event.
RAI-1O Information Request Reference 4 of the March 4, 2004 request (SP-1302-06-013, Fire Protection Specification for Post-Fire Safe Shutdown Program Requirements at Oyster Creek) states that detailed 8
information regarding manual actions for each fire area/zone and their associated time line studies is contained in calculations identified in Reference 3.3.1.1. Provide the calculations identified in Reference 3.3.1.1 of SP-1302-06-013 and describe their applicability to the current request.
RAI-11 Spurious Actuation of Containment Spray Pump states that the purpose of Action 10 (trip two breakers a t,USS 1 B2 and remove the close fuses) is to prevent spurious start of the Containment Spra" 1PUmps. The Attachment states further that this action has no upper time limit and is onlylpe eformed to "ensure their availability for use later in the event" (i.e., cold shutdown). Coifirtrnithat spurious operation of the containment spray pumps would have no impact on the tated O&Atimes, expected performance of other shutdown systems (e.g., cause an eIectrical overlo a)or the operator's ability to achieve and maintain hot shutdown conditi*n's ii, RAI-12 OMA Reliability "I
i1i
As stated in Section II of the request, "reliable action" is a feasible action that is analyzed and demonstrated as being dependably re'patable within an av*ilable time, so as to avoid a defined adverse consequence, while consideringd !,aryifig) bonditions thatcould affect the available time and/or the time to perform the action.
- i.
.. lllII" lUIt I.,
The results of an expert elicitatio process presented: 6 App'ndix B of NUREG-1 852, conclude factorbfti'ast 2 (i e. 100 that a time margin facto t
e0percent of the demonstrated time should be shown to be additionally available):'
uld allow for a "high confidence of a low probability of failure" for local operatr manual actions in response to fire. As clearly stated in the NUREG, this discussion is prov ie*for guidanrce-andd is not eant to imply that a factor of 2 should always be shown or ay, s*
a t, 1 Is ou alwayjse such an approach. However, the available margin mi. Rt, e aleate sure that the requested OMAs are reliable.
In c iln 1II.B the reques states theevaluation will demonstrate that "sufficient margin" exists to perform, the individual opýrjtor manual action. The specific time margin available for each action is provided in Attachmient 2. Attachment 2 also provides an apparently qualitative judgment with regard to the~adequacy of the stated time margins, stating, for example, that adequate margin,.or,' s ffnt margin" is available. However, the submittal does not provide sufficient detail to determYin'e the technical basis for the time margins provided in the submittal.
Provide information which demonstrates that the uncertainties described in Section 4.2.2 of NUREG-1 852 are accounted for in the analysis of the time margins presented in Attachment 2 of the March 4, 2009 request, and that the margins are sufficient to ensure that they would be successful a very high percentage of the time (i.e., they provide adequate time to cover potential variations in plant conditions and human performance).
This information should clearly show that the demonstrated time (or estimated time to complete the action based on the demonstration), along with the extra time (i.e. margin) needed to account for factors not 9
included in the demonstration, can be enveloped by the estimate of the time available, then it can be argued that the actions may also be performed reliably.
In addition, the March 4, 2009 request indicates that a sequential set of MOAs must be executed in a specified order. For example, RAI-13 Use of MOAs in Lieu of Approved Fire Protection Features Identify any fire areas/ zones where MOAs were used to supplant fire protection features (e.g.,
1-hr rated fire barrier wrap) described by the staff in the 1986&d 411990 SERs. For each affected fire area/zone:
l "ItiW1 l a) Identify the applicable exemption(s) and relatec iS;R(s) b) Indicate if the exemption is still being credited inithe March 4, 2009 request.
c) Provide a technical justification which clea monstrates that reliancln MOAs will
~
it fit not result in a reduction of the safety marg'in established iiMthe original SEI.V!,
RAI-14 Equipment Operator LocationsII,
As discussed in NUREG-1852, the locatioi*h! r activitiet[of needOW p.ant personnel when the fire starts could delay their participation in exec.ting theoperatomanuial actions (e.g., they may be in a location that is on the " oposit~eside of eiplant from the main control room and/or may need to restore certaitý equipment before beingjable to participate).
~ ii.il"'
n The tables provided in'5ection Il.l ý1B theirequest ihnicate that the 2 field / equipment operators were assumedo be loc,tinht.,
main w
ocatedin 6 mainontro lrom at the start of the fire event. Provide a al,11IR JI.ilh liý t "
justificatior i~thi asumton1 RAI'V1!6alidity of Timeline, Aissumptions Section 11I C states that the timr!eline for operator actions for the specific fire area assumes that all potential fir6damage identified for that fire area occurs instantaneously at the point of plant shutdown. This section alsb'states that the procedural direction in ABN-29, "Plant Fires,"
requires that the FSPI,e9entered as soon as the existence of a fire is confirmed. These statements appear to be contradictory and require clarification. Procedural direction to implement ABN-29 upon confirmation of fire is consistent with NUREG-1 850 (which describes the fire itself as the only criterion for initiating these types of actions) and recognizes the need to complete prompt actions well before "the point of plant shutdown" which could be considerably later than the time the fire was first confirmed. The stated timeline assumption that fire damage will not occur prior to the decision is made to trip the plant, is not consistent with NUREG-1 850 or ABN-29 entry conditions and, therefore, is not valid. Provide a technical justification to support the validity of a time line that uses a different entry condition than that stated in 10
ij NUREG-1 852 or the plant procedures ( i.e., "the point of plant shutdown" vs. "time of fire confirmation).
In addition, Attachment 2 states that the indicated performance time of prompt actions includes the time for operators to verify equipment response to the action (e.g. verify valve is closed).
However, it is not clear how the additional time needed to take actions if the expected / desired response is not obtained was incorporated into the timeline. Section III*C states that in cases where confirmation is required from the operator in the field to the Control Room, additional time has been added to the estimated time to perform the operator manu'al,action.
However, the amount of time allotted for confirmation and the basis for that time!4zs'ot readily discernable.
Also, Section 11.1B of the request states that a generic tir diagnosing prompt actions. Demonstrate that the addi 4.2.2 of NUREG-1852 are enveloped by the 10 min te operator actions.
'i Ji Also, Section 1lI.B states: "since the Control RoolI in parallel with the safe shutdown operators performingi time was allotted for subsequent ations V,.ithe same o0 of this statement, including specific examp, ofsitlsappl Iwas allotted for
.'listed in Section f&rdiagnosing prompt fn a state of continual diagnosis tions, no additional diagnosis
" Provide additional clarification it Also, Provide a clear description *of how thinepotential corrective reactive actions in the,v*,*pevdierpnpt actionl did lnot accomplish the desired result (i.e.,
response not obtainedo8j) was factored into the -@MA performance time and provide the technical basis for til"!Jtme allotted for each reactive action.
RAI-16 Time~toFire Dama ge.
The spleific location of, potential;!"targets" (i.e., cables and equipment important to post-fire safe shutdb(*'n) within each
'f 1he: fi shutdown),within each of~h tfire areasiS not included or discussed in the request. As discussed-iin.,NUREG-1852 !ii! should;,4therefore, be assumed that the fire could start exactly in the area where the equipment of concern would be affected at the earliest possible time. As a result, in the absence of a d0ettailed evaluation of each fire zone which demonstrates that the prompt actions could be co~r"pleted before serious equipment damage could occur, or information which shows that "reactive" OMAs have been appropriately incorporated into the shutdown procedures to mitigate the potential effects of fire damage, it is not clear how the prompt actions specified in the March 4, 2009 request can be credited for ensuring that one train of systems and equipment required to achieve and maintain hot shutdown conditions remains free of fire damage, as specified in Section III.G.2 of the regulation.
Provide either: (1) an analysis and/or technical justification that demonstrates that the detection capability is sufficient to provide notification of a postulated event coincident to or before damage to the redundant trains of equipment occurs; or (2) provide an analysis and/or technical 11
justification for scenarios where the redundant components are damaged before a fire has been confirmed.
RAI-17 Simulator Demonstrations Section II1.C.4(1 1) describes simulator exercises performed to demonstrate that the operator manual actions can be performed reliably within the times allotted by the fire safe shutdown calculations. This section states further that Fire zones TB-FZ-1 1 D and OB-FZ-8C were selected because they include manual actions that are prompt actionsfln other fire areas and include a number of common operator manual actions to performrwithin the first 45 minutes.
Since a prompt action is defined as an action that must be plegormedWithin 45 minutes, the stated basis for selecting Fire zones TB-FZ-1 1 D and requiresslparification Also, provide a detailed justification which clearly.'demonstrates that the simulator1exercises performed for fires in fire zones TB-FZ-1 1 D and OB'4FZ-8C adequately bound all 6dier fire scenarios.
lll..4 11) f te rques prvid a
' 1 In addition, provide information to demonstrate that the simulbtor exercises described in Section II1.C.4 (11) of the request provide a realistic simulation (to thele*.ent practicable) of the entire h l
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0'7,".
fire-induced accident scenario, including ac actiWies. In your response, provide documentation to confirm that all actions assiateUý With detecting and diagnosing the presence of the fire and dgnosi" te need for an'd executin the relevant manual actions were timed during thedllonstratio.;ýlf an asp6t of the fire scenario could not be simulated, identify it and deschbe ihow its potejiat1 impact
,ripe was predicted.
RAI-18 Diagnostic Instrumentation Several sections of Attachment '!1state that the need for an operator to perform a required OMA can b'e'f`readily diagnosed from the !66ntrol Room due to the numerous indications and symptomsa.vailable.h Section I s1.C.l1-tates that t Selire upport Procedures (FSPs) provide a symptom-based approach to achievi.g safe shutdown and provide the operators with information as to the available equipmentfinIrUding instrumentation) that can be relied upon following a fire. Because the operator remains within the symptom-based EOP procedure framework, the operator retains the ability to use any mitigating system that is unaffected by the fire.
Section II1.C.5 states that the diagnostic instruments that are available are listed at the beginning of each FSP and that the available indications are consistent with the guidance in Generic Letter 81-12, "Fire Protection Rule (45 FR 76602, November 19, 1980)," and Information Notice 84-09, "Lessons Learned from NRC Inspections of Fire Protection Safe Shutdown Systems (10 CFR 50, Appendix R)."
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The staff has defined diagnostic instrumentation in it's response to Question 5.3.9 of Generic Letter 86-10, as follows:
"Diagnostic instrumentation is instrumentation, beyond that previously identified in Attachment I to I&E Information Notice 84-09, that is needed to assure proper actuation and functioning of safe shutdown equipment and support equipment (e.g., flow rate, pump discharge pressure).
Therefore, it may not be sufficient to protect only the instrumentation needed to show conformance to IN 84-09 and GL 81-12; especially for symptom bas6drocedures such as the FSPs, which incorporate the EOP procedure framework for diagooIing the effects of fire since EOPs typically include instruments that are not evaluated for fireidamage.
Diagnostic instrumentation beyond that needed to detejnd diagnose thellocation of the fire, may not be required if the OMA is taken immedi rey~sponse to fire an "d1~s been properly integrated into fire response procedures. However; Happropriate diagnostic indic6ations are necessary if the fire response procedures direct'operator actionsin response to ob'Yrved changes in plant conditions or other unexpected syimlptoms Of fire damage.
For each OMA that relies on controlmro'l ications to detectthe need for the action, provide information which demonstrates that suitible diagbostic instr'ur entation has been identified and that the credited indications are: (a) knowrf to remain u*uiaffected by a postulated fire, (b) identified in the safe shutdowný equipment listand fir eireslonse procedures, (c) capable of promptly identifying the. need for thejaction withoutforcing operators to enter complex diagnosis procedures and (d) th'a~tte action, b.ince comphee, has achieved its objective.
RAI-13 Operator Re-ent Tir~
Attachmerntllýtat'esthat the assessment of OMAs in fire-affected areas assumes that the area can behr.6entered within 90 minut~s..
Provide 'technical justification to support this assumption including why a 90 minute period of time is suitable for all fire areasp/ zones requiring re-entry.
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