ML17053D144

Forwards Request for Addl Info to Complete Review of 810319 & 0609 Submittals Re Design Description of Mods Required to Meet Section III.G.3,App R to 10CFR50

ML17053D144
Person / Time
Site:	Nine Mile Point
Issue date:	04/26/1982
From:	Vassallo D Office of Nuclear Reactor Regulation
To:	Dise D NIAGARA MOHAWK POWER CORP.
References
GL-81-12, NUDOCS 8205060562
Download: ML17053D144 (58)

Text

Docket No. 50-220 APR 3 6 1982 Mr. Donald P. Disc Vice President - Engineering c/o Miss Catherine R. Seibert Niagara Mohawk Power Corporation 300 Erie Boulevard Hest

Syracuse, New York 13202

Subject:

Fire Protection Rule - 10 CFR 50.48(c)(5) - Alternative Safe Shutdown - Section III.G.3 of Appendix R to 10 CFR 50 Re:

Nine Mile Point Nuclear Station, Unit No.

1 The Fire Protection Rule (10 CFR 50.48 and Appendix R to 10 CFR 50) became effective on February 17, 1981.

Paragraph 50.48(c)(5) required submittal of design descriptions of modif'ications needed to satisfy Section III.G.3 of Appendix R to 10 CFR 50 by March 19, 1 981.

By letters dated March 19, 1981, and June 9, 1981, you submitted the design description of modifications required to meet Section III.G.3 of Appendix R

to 10 CFR 50 f'r the Nine Mile Point Nuclear Station, Unit No. 1.

He have reviewed your submittal and find that additional information is required for us to complete our review.

The infomation required was originally requested from you by letter dated February 20, 1981.

Enclosure 1 to this letter indicates what information you have not supplied.

Provide a complete response of items indicated in the enclosure within 60 days of receipt of this letter. If your response is not complete at that time, you will be found in violation of 10 CFR 50.48(c)(5).

Such a violation will be a continuing one and a civil penalty may be imposed for each day the violation continues.

Enclosure 2 provides a rewording of the request for information included with generic letter 81-12.

This rewording is the result of meetings with representa-tive licensees who felt that clarification of the request would help expedite responses.

It does not include any new requests and, therefore, will not adversely affect licensees'bility t'o respond to generic letter 81-12.

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Hr. Donald P. Disc Enclosure 3 provides information regarding our criteria for evaluating exemption requests from the requirements of Section III.G.2 of Appendix R.

The reporting and/or recordkeeping requirements contained in this letter affect fewer than ten respondents; therefore, OHB clearance is not required under P.L.96-511.

Sincerely, Otlglll8)sigtlt!6 ".It.

g B 'gasQ90 Domenic B, Vassallo, Chief Operating Reactors Branch ¹2 Division of Licensing

Enclosures:

l.

Request for Additional Information 2.

Clarification of Generic Letter 3.

Criteria for Evaluating Exemptions to Section III.G of Appendix R of 10 CFR Part 50 cc vI/enclosures See next page DISTRIBUTION Docket File J.

Heltemes I&E NRC PDR NSIC D. Eisenhut ORB¹2 Rdg S. Norris T.

Wambach LPDR OELD ACRS-10 P. Polk Gray

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Mr. Donald P. Disc CC:

Leonard M. Trosten, Esq.

LeBoeuf, Lamb, Leiby 8 MacRae

.1333 New Hampshire

Avenue, N.. W.

Sui te 1100 Washington, D. C.

20036 State University College at Oswego Penfield Library - Documents

Oswego, New York 13126 Resident Inspector c/o U.S.

NRC P.O.

Box 126

Lycoming, New York 13093 Carl D. Hobelman, Esq.

LeBoeuf, Lamb, Leiby 5 MacRae 1333 New Hampshire

Avenue, N.W.

Suite 1100 Washington, D.C.

20036 Ronald C.

Haynes Regional Administrator, Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406

Enclosure 1

Re uest for Additional Information Section III.G.3 of A endix R.

to 10 CFR 50 for the Nine Mile Point Nuclear Power Station (Unit 1

Docket No. 50-220 DPR-63 1.

Niagara Mohawk Power Corporation should analyze all areas of the plant for compliance to Section III.G and III.L of Appendix R and answer the questions 8A through 8L and Enclosure 2 of the'Staff's position dated February 20, 1981 or the clarification given in Enclosure 2 to this letter.

2. If a fire occurred in the shutdown logic panels, would safe hot shutdown still be obtainable?

What alternative means would be used to obtain hot shutdown?

3.

4.

Will the 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of initial cooling water from the emergency condenser tanks be available with the loss of'ffsite power?

Can the plant achieve cold shutdown in 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> with the loss of offsite power?

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.QJ Enclosure 2 "

CLARIFICATION OF GENERIC LETTER I

On February 20, 1981, generic letter 81-12.was forwarded to all reactor licensees with plants licensed prior to January,l, 1979.

The letter'restated the require-ment of Section 50.48 to 10 CFR Part 50 that each licensee would be required to reassess areas of the plant where cables or equipment including associated non-safety circuits of redundant trains of systems necessary to achieve and maintain hot shutdown conditions are located to detemine whether the require-ments of Section III.G.2 of Appendix R to 10 CFR 50 were satisfied.

Additionally, Enclosure l.and Enclosure 2 of. the. generic letter requested additional

',information concerning those areas of the plant requiring alternative shutdown capability.

Section 8 of Enclosure 1 requested information for the systems,,

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equipment and procedures of alternative shutdown capability and Enclosure 2

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defined associated circuits and requested information concerning associated circuits for those areas requiring alternative shutdown.

'I In our review of licensee submittals and meetings with licensees, it has become

'pparent that. the request for information should be clarified since a lack of clarity could result in the submission of either insufficient or excessive information.

Thus, the staff has rewritten Section 8 of Enclosure 1 and-Enclosure 2 of the February 20, 1981 generic letter.

Additionally, further

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- clarification of'he definition of associated circuits has been provided to aid in the. reassessments to determine compliance with the requirements of Sections III.G.2 and III.G.3 of Appendix R.

In developing this=rewrite we have considered the comoent of the Nuclear UtilityFire Protection Group.

The attached rewrite of the Enclosures contains no new requirements but merely attempts

, to clarify the request for additional information.

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2 Licensees who have not responded to the February 20, 1981.generic letter, may choose to respond to the enclosed request for information.

Since the enclosed request for information is not new, but merely clarification of our previous letter, responding to it should not delay any submittals: in.

progress that are.based upon February 20, 1981 letter.

Licensees whose response to the February staff identifications of 20, 1981 letter, has been found incomplete resulting in a major unresolved item (he., associated circuits),

may choose to.respond to pertinent sections of the enclosed request for infor-

'ation in order to'lose open'items (i.e.-, open item for. associated

circuits, use rewrite of Enclosure 2).

If additional clarification is needed, please contact the staff Project ilanager for your plant.

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REWRITE OF SECTION 8 RE(VEST FOR ADDITIONAL INFORYATION The following is a rewrite of the staff's request for additional informat'ion concerning design modification to meet the requirements of Section III.G.3 of Appendix P..

The following contains no.new requests but is merely a rewording of Section 8 of Enclosure 1 of the February 20, 1981 generic letter.

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Identify those areas of the plant that will not meet the requirements of Section III.G.2 of Appendix R and', thus alternative shutdown will be provided~

'or an exemption from the 'requirements of Section III.G.2 of Appendix R will be

. provided; Additionally provide a statement that all other areas of the plait

're or will be in compliance with Section III.G.2 of Appendix R.

For each of those fire areas of the plant requiring an alternative shutdown system(s) provide a complete set of responses to the following requests

'for each fire're'a:

a; List the system(s) or portions thereof used to provide the shutdown

'apability with the loss of offsite power.

b.

For those systems identified in ".la" for which alternative or dedicated.

shutdown, capability must be provided, list the equipment and components.

of the normal shutdown system in the fire area and identify. the functions J

of the circuits of the normal shutdown system in the fire area (power to what equipment, control of what components and instrumentation).

Describe.

the system(s) or portions thereof used to provide the alternative shutdown capabi3ity for the fire area and provide a table that lists the equipment and components of the alternative shutdown system for the fire area.

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For each alternative system identify the function of the new circuits being provided.

Identify the location (fire zone) of the alternative shutdown equipment and/or. circuits that bypass. the fir'e area and verify that the alternative shutdown equipment and/or circuits

're separated

'from the fire area. in accordance with Section III.G.2.

c.

Provide drawings of the'lternative. shutdown system(s) which highlight any connections to the nodal shutdown systems (PQDs for pipi.ng apa.componems,

,elementary wiring diagrams of electrical cabling).

Show the electrical...,

location of all breakers for power cables, and.isolation devices for,

. control and instrumentation circuits for the alternative shutdown systems for that fire area. y; I

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J d.'e'rify that changes to safe'ty systems will not degrade safety systems; (e.'g.,

new isola'tion switches and control switches should meet design criteria. and standards in the FSAR for electrical equipment in the system that the switch iS to be installed; cabinets that the switches are to be mounted in should also meet the same criteria (FSAR) as other safety

. related cabinets and panels; to avoid inadvertent isolation from the r

control room, the isolation switches should

.be keylocked or alarmed in the control. room if in the. "local" or "isolateg" position; periodic

. checks. should be made to verify that the switch is in the proper position for norvial operation; and a single transfer switch or other, new device should

. not be a source of a failure which causes

'loss of reaunoanr, safety

ystems).:

e.

Verify that, licensee procedures have been or will be developed-which describe the tasks to~e,performed to effect the shutdown method.

0 of these procedures'utl.ining operator actions.

Provi.de a summary

f.. Verify that the manpower required to perform the shutdown functions using the procedures of e:.

as well as to provide fire brigade members to fight the fire is available as required by the fire brigade technical speci-'ications.

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Provide a commitment to perform adequate acceptance tes'ts of the alter-native shutdown capability.

These tests should. verify that:

equipment P

operates from the local control station when the.transfer or isolation switch is placed iz the "local" position and that the equipment cannot'e operated: fromithe control room; and that equipment operates from'the control. room but cannot be operated at the local control station when 4]

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.the transfer isola'tea switch is in the "remote" position.

AIt h.

Provide Technical Specifications of the surveillance requirements ahd limiting conditions for operation for that equipment not already

'overed by existing Technical Specifications.

For example, if new isolation and control switches are added to a shutdown system.

~ the existing Technical Specification surveillance requirements should:..:-

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.be.supplemented to verify system/equipment functions from the alternate shutdown station at testing intervals consistent with the guidelines of Regulatory Guide 1.22 and IEEE 338.

Credit may be taken for other existing

'ests. using group overlap test concepts.

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For new equipment comprising the alternative shutdown capability, verify

. that the systems available are adequate to perfor'm the necessairy'shut-

'own

function, The functions required should be based on previous analyses, if possible {e.g., in the FSAR), such as a-loss of normal ac power or shutdown on Group 1 isolation (BMR).

The equipment required for the alternative capability should be the. same or equivalent to that relied on in the above analysis.

Yerify.that repair.procedures for cold shutdown systems're developed

'and material for repairs is maintained on site.

Provide a summary of these procedures'n& a':list of the material ne'eded for repairs.:

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ATTACHNENT 2.

SHUTDOWN CAPABILITY The following discusses the requirements for.protecting redundant and/or I

'alternative equipment needed for safe shutdown in the event of a fire.

The requirements of Appendix R address hot shutdown equipment which must be free of fire'amage.

The following..reqpirements also apply to cold shutdown 1

equipment M'he li:censee elects to demonstrate that the.equipment.is'to be

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free of. fi're.damage.,Appendix R dqes allow. repairable damage to cold shutdown

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Using the requirements of Sections III.G and III.Lof Appendix R, the capa-hoity 'to achieve hot shutdown must exist giVen a fire in any area of the plant in conjunction with a loss of offsite power for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

Section III.G

'f Appendix R provides four methods for ensuring that the hot shutdown capa-bility is protected from fires.

The first three options as defined in Section III.G.2 p'rovides. methods for protection from ftres of equipment needed for hot shutdown:

'."'Redundant systems including cables, equipment, and associated circuits'ay be separated by a three-hour fire rated barrier; or,

2. "Redundant systems.including

cables, equipment and associated circuits may be separated by a horizontal distance of more than 20.feet with no inter-1

, vening combustibles.

In addition, fire detect'ion and an automatic fire suppression system'are required; or, 3:

Redundant systems including cables, eqoipment and associated circuits may

'y enclosed by a one-hour fire rated barrier..

In addition, fire detectors and an automatic fire suppression system are required.

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The last option as defined by Section III.G.3 provides an alternative shutdown capability to the redundant trains damaged by a fire.

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Alternative shutdown equipment must be independent of the cables, equip-,

ment and associated circuits of the redundant systems damaged by the fire.

Associated Circuits of Concern The following discussion provides A) a definition of associated circuits for Appendix R consideration, B) the guidelines for protecting the safe'shutdown

. capability from the fire-induced failures of associated circuits and C) the in-t formation required by the staff to review associated circuits. 'he definition of associated circuits has, not changed from the February 20, 1981 generic letter;'ut is merel'y clarified. It is important to note that our interest is only with those circuit (cables) whose fire-induced failure could effect shutdown.

The guidelines for protecting the safe shutdown capability from the fire-induced iii i

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Tt didii t

id be used only as guidance when needed.

These guidelines do not. limit the alter-.

natives available to the licensee for protecting the shutdown capability.

All proposed methods for protection of the shutdown capability from fire-induced failures will be evaluated by the'taff for acceptability,.

d A.

Our concern is that circuits within the fire area will receive fire damage

~hich can affect shutdown capability and thereby prevent post-fire safe shutdown.

Associated Circuits* of Concern are defined as those'ables (safety related, non-safety related, Class lE, and non-Class lE) that:

• The definition for associated circuits is not exactly the same as the definition presented in IEEE-384-1977.

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1 Have.a physical separation. less than that required by Section III.G.2 of Appendix R,. and;

.2.

Have one of the following:

a.

a common power source with the shutdown equipment (redundant or alternative) and the power source is not electrically protected from the circuit of concern by coordinated br'eakers, fuses, or similar devices (see diagram 2a), or

.b.

a connection to circuits of equipment whose spurious operation would adversely.affect the shutdown capability (e.g.,

RHR/RCS isolation valves, ADS val'ves,

PORYs, steam generator atmospheric dump valves, instrumentation, steam bypass, etc.)

(see diagram 2b), or I

c.'

co'ranon enclosure (e.g.,

raceway, panel, junction) with the shutdown cables (redundant and alternative)

and, (1) are. not electrically protected by circuit breakers, fuses or simi-lar devices, or (2) will a11ow propagation of the fire into the common enclosure, (see diagram '2c).

EXAMPLES OF ASSOCIATED CIRCUITS OF CONCERN FIRe. Aeeg I

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p pg PQQA I.

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8-BUS VAI V6)

Pu,+ p

+pcupmem+ uhosg sptlAAAlls oper~ coAK 07geej S/RAQO~

. Qchgg~g/

. euccos The area barriers shown above mee't the appropriate sub-paragraphs (a-f).

of section III.G-2 of Appendix R.

I Diagram 2A Diagram 28 Diagram 2C

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B.

The following guidelines are for protecting the shutdown capability from Are-induced failures of circuits (cables) in the fire. area.

The guidance provided 'below for interrupting devices applies only to new devices installed to provide electrical isolation of associated circuits of concern, or as part of the alternative or dedicated shutdown system.

The shutdown capability may be protected from the adverse effect of damage to associated circuits of concern by the following methods:

1. 'rovide protection between the associated circuits of concern and E

the shutdown circuits as per Section III.G.2 of Appendix R, or 2.

a.

For a common power source case of associated.circuit:

Provide load fuse/breaker (interrupting devices) to feeder fuse/breaker coordination to prevent loss of the redundant or

,alternative shutdown power source.

To ensure that the following coordination criteria are met the fol'lowing should apply:

(1)

The associated circuit of concern interrupting devices (breakers o', fuses). time-overcurrent trip characteristic for all circuits faults should cause the interrupting device to interrupt the fault.current prior to initiation of a trip of any upstream interrup'ting device which will cause a loss of the common power source,

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The power source shall supply the necessary fault current for sufficient time to ensure the proper coordination without loss of function of the shutdown loads.

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The acceptability of a particular interrupting device is considered demonstrated if the following criteria are met:

(i)

The inter'rupting device design shall be factory tested to

'erify overcurrent protection as designed in. accordance with the applicable UL, ANSI, or NEt@ standards.

(ii)

For low and medium voltage switchgear (480 V and above) circuit breaker/protective relay periodic testing shal'1 demonstrate that the over'all coordination scheme remains within the limits specified in the design criteria.

This testing may be performed as a series of overlapping tests..

(jii)

Nol'ded case circuit breakers shall peridically be manually exercised and inspected to insure ease of operation.

On a rotating refueling outage basis a sample of these breakers'hall be tested to determine that breaker drift is within that allowed by the design criteria. 'reakeeshould be tested in. accordance with an accepted QC testing methodology such as NIL STD 10 5 D.

(iv)

Fuses when used as interrupting devices do not require periodic testing, due to their stability, lack of drift, and high reliability.

Administrative contr'ols must insure that replacement fuses with ratings other than those selected for proper coordinating are not accidentally used.

b.

For circuits of equipment and/or components whose spurious operation would affect the capability to safely shutdown:

(1) provide a means to isolate the equipment and/or components from the fire area prior to the fire (i.e.,

remove power cables, open circuit breakers);

or (2) provide electrical isolation that prevents spurious operation.

. Potential isolation devices include breakers, fuses, ampli-fiers, control switches; current XFRS, fiber optic couplers, relays and tr'ansducers; or (3) provide a means to detect spurious operations and then proce-dures, to defeat the maloperation of equipment (i.e., closure of the block valve if PORV spuriously.operates, opening of the breakers to remove spurious operation of safety injection);

c.

For 'common enclosure cases of associated circuits:

.(1) provide appropriate measures to prevent propagation of the

~ II fire; and (2) provide electrical protection (i.e., breakers, fuses or similar devices)

C.

We recognize that there are differ'ent approaches which may be used to reach the same objective of determining the interaction of'ssociated circuits with.shutdown systems.

One approach is to start with the fire area, identify what is in the fire area, and determine the interaction between what is in the fire area and the shutdown systems which are outside.the fire area.

Me have entitled this approach, "The.Fire Area Approach."

A second approach which we'have named "The Systems Approach" I

would be to define the shutdown systems around a fire area and then determine

7 those circuits that are located in the fire area'hat are associated

'ith the shutdown system.

Me have prepared two sets of requests for 1

information, one for each approach.

The licensee may choose to respond to either set of requests depending on the approach selected by the licensee.

FIRE'REA APPROACH 1.

For each fire area where an alternative or dedicated shutdown method, in accordance with Section III.G.3 of Appendix R is provided, the following information is required to demonstrate that associated circuits will not preve'nt operation or cause maloperation of the alternative or dedicated shutdown method:

a.

Provide a table that lists all the power cables in the fire area that connect to the same power supply of the. alternative or dedicated shutdown method and the function of each power cable

'isted (i.e., power for RHR pump).

b.

Provide a table that lists all the cables in the fire area that were considered for. possible spurious operation which would adversely affect shutdown

'and the function of each cable listed.

c.

Provide a table that lists all the cables in the fire area that share a

common enclosure with circuits of the alternative or dedicated shutdown systems and the function of each"cable listed.

d.

Show that fire-induced failures (hot shorts, open circuits, or shorts to ground) of each of the cables listed in a;'b, and c will II not prevent operation or cause maloperation of the alternative or.dedicated shutdown method.

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e.

For each cable listed in a, b and c where new electrical isolation has been provided or modification to existirg eTectrical isolation has been

made, provide detailed electrical schematic drawings that show how each cable is isolated from the fire area.

SYSTEHS APPROACH 1.

For each area where an alternative or dedicated s'hutdown method, in accordance with Section III.G.3 of Appendix R is provided, the following information is required to demonstrate that associated circuits will not prevent operation or cause maloperation of. the alternative or dedicated shutdown method:

a ~

Describe the methodology used to assess the potential of associated circuit adversly affecting the alternative or dedicated shutdown.

The description of the methodology should include the methods used to identify the circuits which share a

common power supply S

or. a cordon enclosure with the alternative or dedicated shutdown system and the circuits whose spurious operation would affect shutdown.

Additionally, the description should include the methods used to identify if these circuits are, associated circuits

'of concern due to their location in the fire area.

b.

Provide a table that lists all associated circuits of concern lecated in the fire area.

c.

Show that fire-induced failures (hot shorts, open circuits or shorts to ground) of each of the cables listed in b will not prevent operation. or cause maloperation of the 'alternative or dedicated shutdown method..

d.

For each cable listed in b where new electrical isolation has been provided, provide detailed electrical schematic drawings. that show how each cable is isolated from the fire area.

e.

Provide a location at the site or other offices where all the tables and drawings generated by this methodology approach for the associated circuits review may be audited to verify the information provided above.

HIGH-LOW PRESSURE INTERFACE For either approach chosen the following concern dealing with high-low.

V pressure interface should be addressed.

2.

The residual heat removal system is generally a low pressure system that interfaces with the high pressure primary coolant system.

To preclude a

LOCA tht'ough this interface, we require compliance with the recommendations of Branch Technical Position. RSB 5-1.

Thus, the interface most likely consists of two redundant and independent motor operated valves.

These two motor operated valves and their associated cables may be subject to a single fire hazard.

It is our concern that

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this single fire could cause the two valves to open resulting in a fire initiated LOCA through. the high-low pressure system interface.

To assure that this interface and other high-low pressure interfaces are adequately protected. from the effects of a single fire, we require the following information:

a ~

Identify each high-low pre'ssure interface that uses redundant electrically controlled devices (such as two series motor operated valves) to isolate or preclude rupture of any primary coolant boundary..

b.

For each set of redundant valves identified in a., verify the redundant cabling (power and control) have adequate physical

'eparation as required by Section III.G.2 of Appendix R.

c..

For each case where adequate separation is rot provide:,

sho:; that fire induced failures (hot short, open circuits or short to ground) of the cables will not cause maloperation and result in a LOCA.

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RIA FOR EVALUATING EXEMPTIONS TO SECTION III G OF APPENDIX R

Enclosure 3

OF 10 CFR. PART 50 Paragraph 50.48 Fire Pr'otection of 10 CFR Part 50 requires that all nuclear power plants licensed prior to January 1,

1979 satisfy the requirements of Section III.G of Appendix R to 10 CFR Part 50.

It, also requires that alternative fire protection configurations, previously approved by an SER be reexamined for compliance with

~ the requirements of Section III.G.

Section III.G is related to fire protection features for ensuring that systems and associated circuits used to achieve and maintain safe'shutdown.are free of fire damage.

Fire protection configurations must either meet the specific require-

'ments of Section III.G or an alternative fire protgction configuration'ust be justified by a fire hazard analysis.

The general'riteria for accepting an alternative fire protection configur-ations are the following:

The alternative assures that one train of equipment necessary to achieve hot shutdown from either the control room or emergency control

. stations is free of fire damage.

1 The alternative assures that fire damage to at least one train of equipment necessary to achieve cold shutdown is limited such that it can be repaired within a reasonable time (minor repairs with

.'omponents stored on-site).

Fire.retardant coatings, are not'used as fire barriers.

. Modifications required to meet Section III.G woql.d.not enhance

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fire protection safety above that provided by either existing or proposed alternatives, Modificat'ions required to meet Section III.G would be detrimental to,overall facility safety.

Because of the broad spectrum of potential configurations for which

. exemptions may be requested, specific criteria that account for all of

'he parameters that are important to fire protection and consistent with safety requirements of all plant-unique configurations have not been developed.

However, our evalua ions of deviations from these require-ments in our previous reviews and in the requests for III.G exemptions.

received to date have identified some recurring configurations for which specific criteria have been developed.

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Section III.G.2 accepts three methods of fire protection.

A passive 3-ho'ur fire barrier should be used where possible.

Vhere a fixed barrier cannot be installed, an automatic suppression system in combination with a fire barrier or a separation distance free of combustibles is used if the configurations. of systems to be protected and in-situ combustibles are such that there is reasonable assurance that the protected systems will survive. If this'latter condition is not met, alternative shutdown capa-bility is required and a fixed suppression system installed in the fire

~ area of concern, if it contains a large concentration of cables.

It is essential to remember that these alternative requirements are not deemed to be equivalent.

However, they provide adequate. protection for those configurations in which they are accepted.

Mhen the fire protection features of each fire area are evaluated, the whole system of such features must be kept in perspective.

The defense-in-depth principle of fire protection programs is aimed at ag'ttievjng an adequate balance between the different features.

Strengthening any one carl compensate in some measure for weaknesses, known or unknown in others.

The adequacy of fire protection for any particular plant safety system or

. area is determined by analysis of the effects of postulated fire relative to maintaining the ability to safely shutdown the plant and minimize radio-active releases to the environment in the event of a fire.

During these evaluations it is necessary to consider the two-edged nature of fire protection features recognized in General Design Criterion 3 namely, fire protection should 4e provided consistent with other safety conside'rations.

An evaluation must be made for each fire area for which an exemption is requested.

During these evaluations, the staff considers the following parameters:

'A.

Area Description walls, floor, and ceiling construction ceiling height room volu'me ventilation congestion B.

Safe Shutdown Capability r

number of redundant systems in area whether or not system or equipment is required for hot shutdown type of equipment/cables involved repair time for cold shutdown equipment within this area separation between redundant, components and in-situ concentration of combustibles alternative shutdown capability

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.Fire Hazard Analysis type and configuration of combustibles in area

-, quantity of combustibles ease of ignition and propagation heat release rate potential transient and installed combustibles suppression damage to equipment whether the area is continuously manned

.traffic through the area accessibility of the area D.

Fixe Protection Existing or Committed fire detection systems fire extinguishing'ystems

-...hose station/extinguisher radiant heat.shiel ds r

A specific description of the fire protect~on features of the configuration

'is required to justify the compensating features of the alternative.

Low fire loading is not a sufficient basis for granting an exemption'in areas where there are cables.

If necessary, a team of. experts, including a fire protection engineer, will visit.the, site to determine the existing circumstances.

This 'visual inspection is also considered in the review process.

The majority of the III..G exemption requests received to date are being denied because they lack specifi'city.

Licensees have not identified the extent of the exemption requested, have not provided a technical basis

~ For the request and/or have not provided a specific description of the alternative.

Me expect to receive requests for exemption of the following

. nature:

1.

Fixed fire barriers less than 3-hour rating.

2.

Fire barrier without an automatic fire suppr'ession system.

3. Less than 20 feet separation of cables with fire propagation retardants (e.g., coatings,

blankets, covered trays) and an automatic suppression system.

4.

For large open areas with few components.to be protected and few in-situ combustibles, no automatic'uppression system with separation as in Item 3 above.

5.

Ho fixed suppression in the contr'ol r'oom.

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'hich alternative shutdown capability has been providQ.

Our fire research test program is conducting tests to provide information that will be useful to determine the boundary of acceptable conditions for fire protection configurations which 'do not include a fire rated barrier.

Based on deviations recently approved, specific criteria for certain recurring configurations are as follows:

Fire'arrier Less than Three Hours This barrier is a wall, floor, ceiling or an enclosure which separates one fire area from another.

Exemptions may be granted for a lower rating (e.g.,

one hour or two hours) where the fire loading is no more than 1/2 of the barrier rating. 'he fire rating of the barrier shall be no less than one hour.,

Exemptions may be granted'for a fixed barrier with a lower fix rating supplemented by a water curtain.

An Automatic Suppression System Mith Either One Hour Fire Barrier or

- oot eparats on This barrier is an enclosure which separates those portions of one division which are within 20 feet of the redundant division.

The suppressant may be water or gas.

Exemptions may be granted for configurations of redundant systems which have compensating features.

For example:

A..Separation distances less than 20 feet may be deemed acceptable where:

1.

Fir e propagation retardants (i.e.', cable coatings, cov'ered trays,

'conduits, or mineral wool blankets) assure that fire propagation through in-situ. combustibles will not occur or will be delayed sufficiently to ensure adequate time for detection and suppression.

2.

Distance above a floor level exposure fire and below ceiling assures that redundant systems will not be simultaneously subject to an unacceptable temperature or heat flux.

B.

The ommission of an automatic suppression system may be deemed acceptable where:

1.

Distance above a floor level exposure fire and below ceiling assure's that redundant systems will.not be simultaneously subject'o an unacceptable temperature or heat flux.

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The fire area is required to be manned continuously by the provisions in the Technical Specifications.

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Docket No. 50-220 Hr. Donald P. Disc Vice President - Enqineering c/o Hiss Catherine R. Seibert Niagara Hohavik Power Corporation 300 Erie Boulevard West

Syracuse, New York 13202

Dear Hr. Disc:

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Subject:

Furnace Sensitized Stainless Steel Safe-Ends at Boiling Water Reactors Re:

Nine Nile Point Nuclear Station, Unit No.

1 On Harch 23, 1982, a hydrostatic test was performed at 900 psig on the primary system at the Nine Hile Point Nuclear Station, Unit 1.

Leakage was visually observed in tvio recirculation loop safe-end vields.

The inspection identified three leaks in a recirculation pump discharge safe-end and one leak in a recirculation pump suction safe-end.

Pre-liminary investigation has identified three pinhole leaks and a single 1/2-inch leak, all of which are in the area of the heat affected zone of the safe-end to pipe weld.

On Harch 26, 1982, you conducted ultrasonic tests on the affected safe-ends.

It is our understanding that these tests confirmed the initial visual observati on.

We understand that ten nevi replacement safe-ends are onsite and that you estimate six months to one year to accomplish core offload, reactor vessel dewatering and decontamination and the changeou't of a minimum of two safe-ends.

Furthermore, we understand that you intend to replace all ten safe-ends unless test results would indicate otherwise.

Pursuant to 10 CFR.50.54(f),

we request that you provide the NRC, within 15 days of receipt of this letter, your plans and schedule for: (1) reactor decontamination, (2) mitigation of worker radiation doses, (3) removal and replacement of safe ends, and (4) your justification for resuming operation.

This information should be submitted to the NRC, signed under oath and "affirmation, to enable th'e Commission to determine-whether or not the license should be modified, suspended, or revoked.

In this regard your submittal on the repair program including decontamination measures should be provided to this office for prior approval before significant and irreversible repair programs are undertaken The principal reasons for this requirement are to ensure that important generic data is not lost because of the method of OFFICE I}

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DATE I}

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Please note that it is our present intention to require the replacement of all ten affected safe-ends prior to the restart of the Nine l1ile Point Nuclear Station, Unit No. l.

The reporting and/or recordkeeping requirements contained in this letter affect fewer than ten respondents; therefore, OH8 clearance is not required under P.L.96-511.

Sincerely, cc:

See next page a>>oil

~80 by G.'as Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation Distributi on:

Docket File NRC PDR LPDR ORBg2 Reading D. Eisenhut J.

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Yir. Donald P. Disc cc:

Leonard N. Trosten, Esq.

LeBoeuf, Lamb, Leiby & HacRae 1333 New Hampshire

Avenue, N.

W.

Suite 1100 Washington, D. C.

20036 State University College at Oswego Penfield Library - Documents

Oswego, New York 13126 Resident Inspector c/o U.S.

NRC P.O.

Box 126

Lycoming, New York 13093 Carl D. Hobelman, Esq.

LeBoeuf, Lamb, Leiby 8 MacRae 1333 New Hampshire

Avenue, N.W.

Suite 1100 Wasliington, D.C.

20036 Ronald C.

Haynes Regional Administrator, Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406

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