ML17212B610
| ML17212B610 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 05/10/1982 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | FLORIDA POWER & LIGHT CO. |
| Shared Package | |
| ML17212B611 | List: |
| References | |
| NUDOCS 8205210028 | |
| Download: ML17212B610 (38) | |
Text
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ENCLOSuRE I NUCLEAR REGULATORY COt'ItlISSION In the i'latter of P QR'>Q PO'~!ER AND LIGHT COhP"NY (St. Lucie Plant Unit Ho. I)
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Docl:et Ho. 50-335
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EXEi~lPT!ON DESIGN ED ORIGINAL Cert1f1eR 3 1.
.-,".;:.:;;..~."::.',:.'-:,7)e;F1ori+:,Power,.-.'andi Ligh't,.Company...-'(.the...).icos'ea):,.iz M:.holdero f;..::,'.:-.-
':;.".;.'.:i
- Facility Operating License
>!o.
OPR-'67 which au'thorizes oper'ation of the St. Lucie Plant, Unit Ho. 1, a pressurized water reactor located in St. Lucie County, Florida.
This license provides, among other things, that it is subject to all rules, regulations'nd Orders of the Commission now or h reafter in effect.
On JJovember 19,
- 1980, he Commission publish d a revised Section 10 CFR 50.48 ard a
new Appendix R to 10 CFR 50 regarding fire protection features of nuclear power plants (45 F.R.
76602).
The revised Section 50.48 and Appendix R
became effective on February 17, 1981.
Section 50.48(c) established the sche~u~as for satisfying the provisions of Appendix R.
Section III of Appendix R contains fifteen subsections, lettered A through 0, each of which specifies requirements for a particular aspect of the fire protection features at a
nuclear power plant.
One of these fifteen subsections, III.G., is the subject of this exemption request.
III,G. specifies detailed requirements for fire protection of the equipment used for safe sh!outdo>>n by me ns of separatioil nd barriers (III.G.2). If the requirements for separation and barriers could not be met, in an area, alternative sa e shutdown capabil ity, independent of that at ea and equipment in that area, was required (III.G.3.).
~>05~1 g000335 820510 DR ADDgW 0 P
Section 50.48(c) required completion of all modifications to meet the provisions of Appendix R within a specified time fl OM the effective date of this fire pro ection rule, February 17,
- 1981, except for modifications to provide 1 ter: a '
ve safe s iut.own capabi 1 i ty.
These 1 at.er modifications
( I I I.G. 3. )
require'ERC review and approval.
- Hence, Section 50.48(c) requires their completion within a certain time after HRC approval.
The date for submittal of design descriptions of any modifications to provide alternative safe shutdown L
'apability was.'Specified as','la'rch'19 198'l.' ':
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By letter dated Harch 19,
- 1981, as supplemented April 3 and July 10,
- 1981, and January 20 and Harch 18, 1982, Florida Power and Light requested exemptions from 10 CFR 50.48(c) with respect to the requirements of Section III.G of Appendix R as follows:
Should the Commission deny Florida Power and Light's (FPL's) request for ai exem"tion for all areas of the plant that. have alreadv been reviewed and approved by the Commission as shown by the HRC's Safetv Evaluation Peport (SER) for St. Lucie Unit Wo.
1, extend for a period of twelve mont is from the date of denial, pursuant to 550. 12(a) and 50.48(c),
the date for submittal of plans, schedules and/or design descriptions for any
- -.-:difications
. ecessary to achieve compliance with, and/oi request exe-;..p-tions from Sec" ions III;6.2 and III.G.3 of Appendix R for all items not in compliance with Sections III,G.2 and III.G.3 regardless of ivhether such items were ever approved in t'e SER.
. By letter dated June 4, 1981 the Commission did deny the exemption V
requested for those areas of the plant which have already been reviewed
, and approved by the Commission.
Therefore, the twelve month delay requested corresponds -to a submittal date of June 4; 1982.
Rhen this Fire Protection Rule was aoproved by the Commission, it was understood that the time required for each licensee to re-examine those previously-approved configurations at its plant to determine whether tiiey meet.
the requirements of Section III.G of Appendix R to 10 CFR 50 was not well known and would vary depending upon the degree of conformance..
Fcr each item of non-.
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~ la was found, a f'e haz".i ds ara lys 1 5 lad 0
be pel formed io CPtel "t'e wlPiler tie exlsiiilg configuration provided sufficient':re p; oiection.
If it.did, a basis had to be formulated for an exemption request.
If it did not, modifications to either meet the requirements of Appendix R or to provide some, A
other acceptable configuration, that could be justified for an exeimption, had
. '.';.'.-..-"~.'4'o.be.'designed:
4'heal'e fir'e-:go'tee'tioh 'f'eh@re's-al'one'cou'14':iiot"enquire'pro'-"
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'teciion of safe shutdown capability, alternative safe shutdown capability had
'o be desianed as required by Section III.G.3. of Appendix R.
Dependina upon the extensiveness and number of the areas
- involved, the time required for this re-examination.
reanaljsis and redesign could vary iron a few months to a
ye:r or more.
The Commission decided,
- however, to require, one, short-term date for ai'~ licensees in
.ile in"'.rest of ensurIng a best-ef;or".,
expedited co~pletion of co".piiance w',th tie Fire Protection Rule, recognizing thai there would he a
nu-".ber of licensees who cou'.d not meet these tire restraints hut!vho could ti!en
~ 1 request appropria.e relief hr ough the exemption process.
Licensees for 44 of ihe 72 plants to which Appendix R app'lies (plants with an operating license
, issued prior to January 1,
1979) have requesiCd sucil sciledular relief.
The licensees for ihe remaining 28 plants made submittals to meet the schedular requirements of 50.48(c).
All of these submittals,
- however, were I
deficient in some re'spects.
In general, much of the information requested
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in a generic letter (81-12) dated February 20, 1981, io the licensees of all
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- plants, was not provided, There ore, additional time is being
..sed to complete those,submittals also.
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.".rior to the issuance of Appendix R, St. Luci e Unit bio.
1 had been reviewed acainst the cri teria of Appendix A to the Branch Technical Position v(
- 9. 5-1
{8TP 9. 5-1).
The BTP 9. 5-1
<<as developed to resolve the lessons 1 earned from the fire at Browns Ferry Nuclear Plant.
It is broader in scope than 1
Appendix R, formed the nucleus of the criteria developed further in Appendix R
~ '..and in its present revised form constitutes the. section of the Standard Review v
.. Pian used:fo,r the review, of applications 'for. construction permits.and operating licenses of new plants.
The review was completed by the HRC staff and its fire protection consultants and a Fire Protection Safety Evalua tion IFPSER) was issued.
j As a result of that review numerous. modifications have been made to plant physical features,,
svs
- ems, and administrative control s to meet the cr iteria of Appendix A
to 8TP 9.5-1.
St. Lucie Unit Ho, 1 has been upgraded to a high degree of fire protection already and the extensive reassessment involved in this request for additional tire is to quantify, in detail, the differences between what was.
recently approved and the specific requirements of Section III.G of Appendix R
to 10 CFR 50.
In its March 19, 1981 exemption request, the licensee stated that "Except to the extent specific exe...ptions are requested in tshis docuiment, St. Lucie 1
is in full'ompliance with the requirements of he rule."
A ew items addressed in the exemption, request and which are-not subject to. the requirements of Section III.G remain unresolved.
These items deal with Section III.A, Water Supplies
'or Fire Suppression Systems.
The licensee has r quested until the Spring 983 reload to reroute fire pump cables; not to replace exist'ng fire punp controllers with U.L. approved controllers meeting all the require:~ents of HFPA-20; and not to automatically load the fire pumps onto vital buses in he presence of a safeguards actuation.
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.< o, ai +wc, >e These exemption requests are being reviewed by the sta f.
The staff has, with !.espect to the technical exemptions requested, previously determined thai the licensee has provided sound iechnical bases wa!ranting further staff review.
Because the Spring 1983 reload i.s the first scheduled
- outage, following receipt of the final design plans, in which to perform the cable rerouting, the current vire pump control]ers and swi tchgear are nuclear, class IE and seismic category.
, I,'and the fire pum'ps.wH 1 auto. load, onto the.vii;al buses i,n. the,event:of loss.
of oifsi te power and a drop in fire system pressure the staff.has determined that the outstanding exemption requests associated with Section III.A do not affect the accep ability of the requested delay in submitting Sectibn III.G information.
Furthermore, compliance with the balance of the Fire Protection
!ule means that fire protection requirements, other than the identified exemp-tions from Section III.A and ihe requested delay in submi.ting Section liI.G infor"aiion, have been or will be compleied on o!. before il!e implementation dates req;!ired by the Fire Protection Rule.
Based on the above considerations, we find that the licensee has com-pleted a substantial part of the fire.protect'ion features at St. Lucie Unit 1
ii conformance with the requirements of the Fire Protection Rule and is applying sinifioant effort io co!.piete the reassessment of any remaining nodifica ions
.; which might be necessary for.strict conformance with. Section. III.G." Ve find that because of the already-completed upgrading'f this facility, there is no undue risk to the health and safety of the public involved by delaying the completion of this reassessment until June 4, 1982.
Therefore, an exemp-tion should be granted to alldw such time for completiori.
- However, because
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"e have sound that most submittals of this reanalysis to date from other licensees have not been complete; that is, not all of the information requested by Generic Letter 81-12 daten re.".ruary 20,
- 1981, was pl ovi~ed, we ale adding 'ondition to this Exemption that requires all such information to be submitted by the date granted.
IV.
Accordingly, the ComIt1ission has'etermined
- that, pursuant to'10 CFR 50.12, an exemption is authorized by law and will not endanger life or property or the co,.:mon defense and security and is otherwise in the public interest and hereby grants the following exemption with respect to the'requirements of Section III.G. of Appendix R to 10 CFR 50:
The date,
!'iarch 19, 1981, for submittal of plans, schedules and/or design
~escr ot o1s fo1 any r.odi fice 'ons
~ 'cssa1y 0 ach i=Ye comp 1
l ce
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and/or request exemption from Sections IiI.G:2 and III.G.3 of Appendix R
'.s
..x ended to June 4
19..2.
ProYided Oh@ fol in ling condioions ene nee:
1).
Reouests for exemption pursuant to '50,48(c)(6) must include:
a)
A concise statement of the extent of the exemption; b)
A concise description of t< e proposed al terna.ive design features rel a ed to as suring pos'= fire slsutdown capabi 1 ity; and c) a sound technical basis that justifies the proposed alternative in terms crf protection afforded to post-fire shutdown capability, degree of.enhancement jn fire safqty by full compliance with III.G requirements,'or the detriment to plant safety incurred by full compliance with III.G.
A simple statement that the feature for which t>"e exemption is requested was previously approved by the staff 1s "ot su ficieni.
A simple assert10n t'1at in the licensee's judgment the feature for which the exemption is 1 eques ed 1s adequate fire protection is not sufrici erst.
2).
The design descriptions os alternative or dedicated shutdown systems
. to comply with Section III.G.3., as required hy 550.48(c)(5) shall include a point-by-point, response to each item in Section 8 of Enclosure 1 to generic letter 81-'12 dated February-20, 1981; and to each itesm in.-nclosure 2 to Generic Letter 81-12, dated;ebruary 20, 1081.
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!f the licensee does not meet the above conditions, the licensee will oe found in,"o!ation of 10 CFR 59.48(c) even though the submittal may be. made within the time 1imi". granted by the exemption.
tf such a violation occu s, imposition of a civil penalty will be considered under Section 234 of the-A omic Energy Act, as amended.
Such a violation will be a contiruing one beginning with the. date set in the exemption for submittal and terminating when all inadequacies are corrected..
delay in the determination of inadequacy by the staff, caused by the work-load associated with reviewing all of the submittal s falling. due near the same
- time, will not relieve the licensee of the responsibility for completeness of the submi t-tal, nor wil) such delay cause any penalty thai may be imposed to be mitigated.
The 4!RC staff has determined that the granting of tnis Exemption will Aoi result in any 51.5(d)(4) an significant environmental impact and that purs,lant to 10 CFR eAvi l onmental impact statelheni ol Aega ive decl a, t ion and Qnv; Poll-men.al impact appraisal Aced Aoi be prepal ed in conn ciioA wi h
.is action
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4I FOR THE I'UCLEAR REGULATORY CGHhiSSI",'!
l arold R. Oenion, Oi; ector 0ffice of Nuclear Reactor Regulation Da ted at Bethesda, t'a ryland this 10th day tray, 1982.
CLARIFICATION OF GEHERIC LETTFR l3n. Februarv 20,
- 1981, generic letter 81-12 was forwarded to all reactor licensees with plants lice..sed prior to January 1,
1979.
The letter restated the requi re-ment o
Sect'on 50.48 to 10 CFR Part 50 that each licensee
>>ould be required to reassess areas of the plant where cables or equipment including associated non-s~ty circuits of redundant trains of systems necessary to achieve and
.>laintajn. hotshutdown.conditions are located.to deter.',ine whether the require-.
H
-menis o>" Sec"ion III.G.'2 of Appendix P. to 1O GFR 50.weie satisfied>
Additionally, Enclosure 3 and inclosure 2 of the generic letter requested additional information concerning those areas of the plant requiring alternative shutdown capcbl 1 'lty.
'efired ass
'.a.ed circuits and r Ques d information concerning associated Section 8 of "nclosure 1 requested information =or the systems, I
equ'p;.. nt an'rocedur s of alt rnati,e shutdown capa~ility and nclosure 2
c>rcui'ts fo! those
=reas requirirg alternative shuldown.
I", our r=v'.'=;. of licens=.e ub.-;ittals 2nd meet-ints w-'th lice> sc s
i s
U come apparent hat 'the request
-"or information should be of clarity could result in the submission of either i>lfo;,>ratioll.
TIlus
'he s'aif 5 rewritten Section clarified since a lack insufficient or excessive 8
o-, Enclosure 1
and Enclosure 2 of the February 20, 1981 generic letter.
Additionally, further H
clarification of the definition of associated circuits has been provided to aid in the reassessments to determine compliance with the requirements of Sec ions iii.6.2 and iii.Q.3 of Appendix R.
indevelopirig this"1 ew lee we have consloel ed e-col lei1t of the I>iuclear Utility Fire Protection Gl oup
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lile enclosed rewrite of the Enclosures contains no new requirements but merely attempts to clari >y the request for'additional information,
1 Licen52es who have riot res ponded to the February 20, 1 981 generi c 1 etter m=-v choose to respond to the enclosed request for information.
Since the enclosed request for inior-iation is not new; but merely clarification of our previous letter, responding to it should not delav any submittals, in progress that are based upon February 20, 1981 letter.
Licensees whose
,;:=::response:, to" th e',.Feb'ar'y.20';
') 981..-T ether', has, been, found, ineo@pl e
~e',sesqui ting.'in...
--..'...'i'a-i identificat ons of a major unresolve'd item (iie., associated circuits)',
1 may'choose to respond to pertinent sections of the enclosed request for infor-I
-mation in order to'lose open items (i.e.,
open item for. associated
- circuits, use rewri e of ":nclosure 2').
I-additional clarification is needed, please contact the staff Project.
ilanager for your plant.
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REWRITE OF SFCTIO>< 8 RE/VEST FOR ADDITIOhAL IhFORtQTIO>>
The,ollowing is a rewrite of the s>.af>
s request
>Or add1t1ollal informa ioh I
nin.
G-si '
m>odi
> ic tion l>ee th>e rcou\\r8"ants 0
eciloll III.G.3 o
"".-'erdix >;.
ho f'ollowino contains no new requests but is merely a rewording of'ection 8 of Enclosure 1 of he February 20, lg81 gereric letter.
l.
Identify those areas o-,
the plant that will not meet the requirem>ents of Section:IIE.G.2 o>. Pppendix.R ard,. thug al.ierna-'iyy st;utdov,n,will bt, provided-
~ or an exemption. from the requirements of Section'II.G.2 of Appendix R will be provided.
Additionally provide a statement, that all other areas of the plant are or will be in co>lpliance with Section III.G.2 of Appendix R.
For each of those f1re areas of the plant requiring an alternative shutdown sys m(s) provide a complete set of responses to the following requests for eacn
~ 1re al ea:
a.
Lis ne syste
>(s) ol po) t10
>s thereof used to provide the shuidown cap=bility with the loss of o fsite power.
b.
For those systems identified in "la" for which alternative or dedicated shu~v'cNn capabl 1 i ty mus i e pl Gv ided, list the equipment and co>> ponents cf the normal shutdown system in the fire area and identify the functions of the circuits of the normal shutdown system in the fire area (power to what equipment, control of what components and instrumentation).
Describe th>e system(s) or portions thereof used to provide the alternative shutdown capabUD ty for t>h>e T1l e area and pro,'ide a table
>.ha>. lists th>e equip
> ent and components o> the alternative shutdown system or the >ire area.
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For each alternative system identify the function of the new circ its b ing provided.
Identify the loca.ion (fire =one) of tho alternative s,"shutdown eouip.-..ent and/or, circuits that bypass the fire ar=a aIld verify that the alternative shutdowr.
equipment and/Or circuits are separated from the fire area in accordance with Secticn III.G.2.
c.
'Provide drawings of the alternati re shutdown system(s) which highlight any connections to tbe..portal.shutdown systems lPLAIDS for piping ana componenzs, elementary. wiring diagrams of electrical cabling).
Show th.electrical location of all breakers for power cables, and isolation devices for
. control and instrumentation circuits for the alternative shutdown systems or that fire area.
d.
Verify that changes to sa ety systems will not degrade safety systems;
{e. c.
ne'w 1 sol a '
on 5'x'i tches and 'control swl 'hes s houl d meet des i gn criter',a ano st.ndares in the FSAR for elec rical equip.".,ent in h
system that the switch iS to b
instal Ied; cabi-cts that the switches are to be moun I ed in should al so neet the same criteria
{FSAR) as otr>'e'r safety related cabinets and panels; to avoid inadvertent isolation from the co tj'01 room, the isolation swi "ches should be keylocked or alarmed in the control room if in the "local" or "isolated" position; periodic I>>
V checks should be -ade to verify that the switch is in the proper positioa foI
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nornal operation and a s.ngle transfer switch or other new device should not be a source of a failure which causes'toss of reaunoa:Iz sa tv.-
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s.js ten>s)
Verify that licensee procedures have been or 4,]1.
be developed which d=
.'b tasks to e performed to effect the shu down method.
Provide a su";=ary J
of these pl ocecures outl inlng operatol actions.
f..
Verify that the mianpower required to perform the shutdown functions usina oc "u -s 07 ".:s wel t as 0
. ov 1 0 '
b.
1 "ace
~ hers gq c! J t'1"- fire iis -va:,lable as req'r"-0 by the ii e b'gade techlical speci-ications.
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Provide a commitment
.o per orm adeouate acceptance tests of the alter-native shutdown capability.
These tests should veri,y that:
equipment
op'crates froni tne 'T'ocalico1itrol "stat'ion wnen'the trhnsfer. or'isol'ation I
switch is placed in the "local" position and that the equipment cannot be operated from the control room; and that, equipment operates from the control room but cannot be operated at the local control station when ti ans e1 i so I ation swi tch is in the remiote posi ti0A.
h.
Provide Technical Speciiicaticns of the surveillance requirements 2nd limii:i~g conj i t10 s fol cue 2 ion f01 that equipment not alrecdv cove
~ ed bv exi stinl T=c ";:iica I Speci T ications.
For exampl e, if Aew 1 sol ation and control swi tches are added to a shutdo"n. system the exist-ng Technical Specification surveillance requireriients should be supple "en'ad t0 Y r y svste; i/equi"-.."ent iurictlons 1'mi
'one al tei:,a i si~utdown station at tes ing intervals cons.stent with the guidelines oi Siiu iCown Regulatory Guid 1.22 and IEEE 338.
Credit may be taken "or other existing tes.s using group overlap test concepts.
.=or new equipment comprising the alternative shutdown capability, ve that the systems available are adeouate to perform th necessary'hul-do>>n function.
The fuhctions 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'solation (B'HR).
The equipment required for the, a]ternaiive capability should be-. the.game or,equivalent. to that;
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~'I, relied on in t'e above analysis.
Verify.that repair procedures for cold shutdown systems are developed and material for repairs is maintained on site.
Provide a
summary of these procedures and a,list of the material needed or repairs.
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SAFE SHUTDOWN CAPABILITY The following discusses the require<ments for.protecting redundant and/or al terna t i ve ec J i p: ent needed
< Gr sa
< e shutdown in tne event OT a
< 1 re.
l.le requl l efhen <.s p
Appef<o n Pi <-'d< '-ss
<<c <. sh J dol<A equ
< p<i<en>> 4<<<<i<>>iJs Qe equiplieAt
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7o I Ãr'<"<<o... eo-.< <; e<,.en<is a
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< 0 co f u< d elects to'demonstrpte
-'hat th
.equip,",ent. is to be free of.
< >'re
~ damage..<ppendix R dQes al low. repairabl e damage to cold shutoowl equioment.
Using the requirements of Sections III.G and III.L of Appendix R, the capa-bility'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 />.
Sectiion III.G 0
AppeAc ix Pi p ovi des our methods
=or ensuring that the hot shutdol' capa-bility is protected
<rom fires.
The first three options as defined in Section III.G.2 provides f.<e'hoes fol plot'"-c'iorl fro<<l fj es of e:f:i-ment r<eeded
<ol
<'.Ot S<l<JtCGbQ<:
.";edundant sys em<s including cables, equipment, and associated circui.s may be separated by a thro e-hour <ire rated barrier; or, 2.
U daf<t 5Js
< e:s encl uo (< g c2 Dlf es, equ i p..<eAt
<".f'<d assoc
< a ed c
< t cu 5
be separated by a Aori=ontal distance of more tran 20 feet with n<o A=er-
.venino cambustibIes.
In addition, fire detection and an aut'omatic fire" suppression system are requi red; or,-
e
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".r=, s ifcl "dif<o c '1 "="
eq01~<ent 2nd associate by enclosed by a one-hour ire rated barrier.
In addition', fire d tectors and an automatic fire supression system are required.
Tr>e last option as defined by Section III.G.3 provides an alternative shu.down capa5'.1'ty to t>".e redundant trains damaged by a fire.
Alternative shutdown equipm>ent must be independent of the cables, equip-ment ard associated circuits of the redundant systems damaged by the fire.
Associated Circui ts of Concern
'Yhe" fol1'owi'ntj:discuss'i'on. provi'dhs A')"a""definition'of 'a'ssocia'tk'd" cVrcui ts fear r
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~ P Appendix R consideration, B) the guidelines
,or protecting the sa e'shutdown capability
=rom the fire-induced failures of associated circuits and C) tne in-formation required by the staff to review associated circuits.
The definition of associiated circuits has not changed from the February 20, 1981 generic letter; but is merely clari>ied.
It is important to note that our interest is only with those circuit (cables) whose fire-induced failure could effect shutdown.
The gu Gel ines 0,
pnotec i ng t>ie sa fe shutdown capabi 1 ity -,; om> the fi re-i r>duced I ures 0
as soci ated c ircuits are rot reeui rements These gui del i nes s houl d 4
be used only as guidance when needed.
These guidelines do not limit the alter-natives available to the licensee for protecting the shutdown capability.
Al 1 o
o~" d e i h>ods for protection of the shutdown capabi1 ity from fire-i nd>.ced failures will be evaluated by the'taff for acceptability..
A. 'Our concern'is that circuits within the fire area
~ri11 receive fire darIiace
'ti'ich can affect shutdown capabi1ity and thet eby pre;ent post-fire safe shutdown.
Associated Circuits" of Concern are defined as those cables (safety related, non-safety related, Class lE, and non-Class lE).that:
The de
> i 1 i >.1 on
>or associated circui ts i s not exactly the same 4
as the definition presented in IEEE-384-1S77.
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Have a physical separa ion less than that required by Section III.G.2 o.-" appendix R,.and; 2.
Have Gn 0
01 1 O'.Mi ng a.
a commion power source with the shutdown equipment'redundant or alternative) and the power source is not electrically protected f'rom the circuit of concern by coordinated.breakers,
.fuses, or sirtilar devi'ces'see'i'agram 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 valves,
- PORVS, steam generator atmospheric du;;p val ves, i As i um ni:'on, ste" 1 bypass, e c. ) (see c
- g. aiil 2b), or c.
a cc..
ion enclosure (e.g.,
- raceway, panel, jinction) with the shutdown cables (reduncant and a.1ternative)
- and, t
(1) are not electrically protected by circuit breakers, fuses or simi-lar devices, or (2) will allow propagation of the "iire into the co mon enclosure, (see diagram 2c).
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B.
The following guidelines are for protecting the shutdo~n capability from
'ir e-induced fai lul es of cii cui is (cables) in the fire ai e Tiie guidance pl ov
~ ded el ow or ili =i Upt i".g devi' appl ics only to n&w devi c" 5 instal led to pl ovide electrical isolation of associated circuits of concern, or's'art of the al ternative or dedicated shutdown system.
The shutdown capability may be protected from the adverse effect of damage
.o associaied circuits of concern. by the folio>>'ing'inethods':
Provide proteciion between the associated circui.s of concern and the shutdown circuits as per Section III.G.2 of Appendix R, or 2..
a.
For a, corinion power source case of associated circuit:
Provide load fuse/breaker (interrupting devices) to feeder fuse/br aker coordination to prevent loss of the redundant or r
alternative shuidown power source.
To ensure that ihe following coordination criteria are met the following should apply:
(1)
The associated circuit of concern intet rupiing devices
{breakers or fuses) time-overcurrent trip characteristic for all circuits faults should cause the interrupting II device to irierrupt ihe fault current prior to initiation of a trip of any upstream interrupiing device 'which will cause a loss o-the co;,ron power source, h
(2)
Tn'e po>>er source shall supply ihe necessary fault current for sui icient time to ensure the prop r coordination without loss of "unction of the shutdown loads.
The acceptability of a particular interrupting device is considered demonstrated i= the following criteria are met:
(i)
The inte rup lng device design sha11 be factory tested to verify overcurrent protection as designed in accordance with the applicable UL,. AWS1, or NEt% standards.
... (j,i.}
Eqr, low and,rnegium voltage ski tchgear.,(480,V,and:above)
'circuit'reaker/protective'elay periodic testing shall demonstrate that the overall coordination scheme remains within the limits specified in the design criteria.
This testing may be performed as a series of overlapping tes.s.
(iii). t~iolded case circuit breakers shall peridically be manually e"ercised and insp c ed to insure ease of operation.
On a rotating refueling outage basis a'ample of ~hese breakers shall be tested o determine that breaker crift is within V
that allowed by the design criteria.
Breakersshould be tested in accordance with an accepted gC testing methodology such as NiL STD 10 5 D.
(iv)
Fuses when used as interrupting dev'ices do not require periodic testing, due to their stability, lack of drift, and hign reliability.
Administrativ controls must insul e that replacement fuses with ratincs 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:
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II e
(1) provide a
means o isolate the equipment and/or componen>'ts from
- i. ie fire a? ea priol to
+h>e ille
(
~.e.,
re ove power cab)es, open circ it breakers);
or (2) provide electrical isolation that prevents spurious operation..
Potential isolation devices include breakers,
- fuses, ampli-V fiers, control switches',
current 'ÃFRS,"fiber optic couplers,
.relays and transducers; or (3) provide a r>cans 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
.he breakers to remove spurious operation of safety injection);
c.
For comon enclosure cases of associated circuits:
(1 )
I ov i de PppropriP te m>easures to p1 event propagation 0
the fire; and (2) provide electrical protection {i.e., breakers,
>uses or similar devices)
C.
We recognize, that, there are, different approaches which may be used to reach the same objective. of determining the interaction of associated circuits with shutdown systems.
Gne approach is to start with the Tire area ident> ly w>>at s in the Tire atria PAd deter>il;n>e n>e interaction between what is in tre iire area arid tho shutdown systems which are ou s.ide the Approach.
fire area.
We have entitled this approach, "The Fire Area A secoiiQ appl oach which we hPYe Aa ed TAe Sys'ems Approach" wo id 5e to definie the shutdewl syste>m>s ar:u>>d 'lre area and then deieroine
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~ those circuits thai are located in the fire area that are associated wiih the shutdown system.
4'e have prepared two se s of requests for informa ion, one -or each approach.
The licensee may choose to resoond to ei iher set of requests depending on the approach selected by ihe licensee.
FIPE AREA APPROACH
- l. '.For each fire area where an alternative or dedicated shutdown method,'n accordance with Seciion III.G.3 of Appendix R is provided, the following information is required to demonstrate ihai associated circuits will not prevent operation or cause maloperation of the alternative or dedicated shutdown method:
a.
Provide a "able that lists all the power cables in the fire area that connect to tne same power supply of the alter'nat')ve or dedicaied shutdown method and ihe function of each power cable listed (i.e.,
power or RHR pump).
V b.
Provide a table that lists all the cables in the fire area that were considered for possib1e spurious operation which would adversely affect shu down and the function of each cable listed.
c.
Provide a table that.lis s all the..cables in the fire area that share a
common enclosure with circuits of the alternative or.
dedicated shutdown sysiems and the function of each cable listed.
d.
Show that fire-induced failures (hot shorts, open circuiis or shorts to ground} of each of the cables listed in a; b, and c will noi prevent operation or cause maloperation of the al tel native or ded-icated sh tdown meihod e.
For each cable listed in a, b and c "here new electrical:solation has b=en provided or modification to existing ele trlcal isolation has been
- made, provide detailed electrical schematic dra'jings that show how each cable is isolated from the fire area.
SYSTEHS APPRGACH Fgr..e~ch..arep..I hery.an altergativp. or,d dilated. Shutdown.,me.".hod, j n...
accordarce with Section III.G.3 of Appendix R is provioed, the following information is required to demonstrate that. associa ed circuits will not prevent operation or cause maioperation of the alternative or dedicated shutdown method:
Describe the methodology used to assess the potential of associated I
circuit adversly affecting the aite na lve or dedicated shutcown.
The cescri ptlon 0f.he methodology should include the methods used to iceiltiify the circuits which share a co;..i;on power supply or a coi~>.on enclosure with the alternative or dedicated shutdown system and the circuits whose spurious operation would affect sl utdown.
Addit i onal ly, the descr i pt i on should include the
- ethods Used to ident,i fy if these circuits are associated ci1 cul 5
of concern due to their location in the fire area.
b.
Provid a table that lists all associated circui I s 0
co ce located in the fire area.
c.
Show that fire-induced failures (hot shor ts, open circuits,or
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shorts to ground) of each of the cables listed in b will not prevent operation or cause maioperaiion or'he alterratir'e or ced ice c""~ shutdown m shod.
d.
For'each cable listed in b where new electrical isolation has been pi"ovlded pI ovi ce ce' I lcd el ectl"ical schematic d aw ings hP t show ho'w eac.l ca Die i s i sG1 atcd fi Gm the l" re -'I 2 e.
PI ovlde 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-LOM PRESSURE INTERFACE For either approach chosen the following concern dealing with hi.gh-low pressure interface should be addressed.
2.
Tho residual:".rat removal system is ger;=-;ally a lcw pressure sys interfaces with the high pressure primai y coola.
sys em.
Io preclude a
LOCA through this interface, we require co..pliance with the recom
- r ndations of Branch Technical Position RSB 5-1. 'hus, the interface most likely consists of two redundant and independent motor operated valves.
Inese two mGior operated valves and their assoc ated cab'}es may be subject to a single fire hazard.
It is our concern that tilis 5'ingle fire could cause the. two val Yes to ope'1 1 esul ting in a fire initiated LOCA through the high-low pressure system intel ace.
Io assu1 e that this interface and o'her high-Icw pressqre inter aces are adequately pi.otected from the effects of a single,ire, we require the following information:
a.. Identify eacn high-low pressure interface that uses redundant electrically contro'lied devices (such as two series motor Opera'ed valves) to isolate or precl"de rupt: re of any pr>m ry coolant
b.
For each set of redundant, valves iden" ified in a., verify the redundant cabling (power and control ) have adeouate physical separation as required by Section iii.G.Z of Appendix R.
,2.
c.
For each case where adequate sep=-ration is -,c'; provide:, s:.";: that fire induced failures (hot short, open circuits or short to ground) of tne cables will not cause -a'Ioperation and result in a LOCA.
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hv IBERIA FOR EvALUATING EXEMPTIONS TO SECTION III G OF APPENDIX R 5 Pil.LL.'>Vlf@
OF 10 CFR PART 50 Paragraph 50.48 Fi. e Protec ion o, 10 CFR Pari 50 requires that all n,!clear power plants licensed prior to January 1, lgi9 satisfy the re<uir"=.agents of Sect ion 'I ~ G of App"ndix R io 10 CFR Part 50.
It also requires thai al'iernaiive fire proieciion configurations, previously approved bv an SER b
reexamined for canpli ance with ihe requiremenis of Sec" ion II..G.
Sec ion III.G is rela.
ed to fire protection'eatures for ensuring tha" systems and associated circuits used to ach',eve and maintain safe shutdown. are fr e of fire damage.
Fire prot ction configurations musi either meet 'the specific require-ments of Seci',on III.G or an alternative fire proiection configuration must be justified by a fire hazard analysis.
The general cri eria for accepting an alternative fire protec ion configur-ations a.re the following:
The alternative assures that one train of equipm nt necessary to achieve hot shutdown from either the control room or emergency control staiions is free of fire damage.
'he al ernative ass res that, fire damage to at least ono train of equip. eni necessary io achieve cold shutdown is limited such that i i can be repaired within a reasonable iime (minor repairs wi th cc...ponents s io red on-si. ).
Fire retardant coatings are not used as fire barriers.
- Modifications required to meet Seciion III.G would.not enhance fire protection safety above that provided by either existing or proposed a.lternatives, Modifications required to meet Section III G would be detlimental to cvelal 1 fac)! i ip sa7e iy ~
Because of the broad spectrum of potential configuraiions for which.
~ exempiiors may be requested, specific criteria that a'ccount for'll of
'he pal ameters thai are impoi iant to fire proteciion and consiste'nt wi.ih e*'equi remen
- s. 0 2
Dl an -u!iique conf i gurations have noi beell s
developed.
- However, our evaluations of devi a.iions 7rc;"1 I.hese Iequire-m nt 5 in cur pt evlous reviews and in the requests for I II.G exemptions received o daie have iden ified som recurring configuraiions for which specific ciiteria have been developed.
r '
Section III.G.2 accepts three methods of fire protection.
A passive 3-hour fire barrier should be used where possible.
'~hei e a fixed barrier cannot be -installed, an 2u orna ic s 'ppression system in co.;bination with a fire barrier cr a separ ation distance free of combustIbles is used if the conf; u, a ions of systems to be protected and in-si tu cc i'stibles are such that there is reasona'ole assurance tha" the protected systems will survive. if this lat er condition is not me', al.ternative 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 adequa e protection for those
'.confi gurat'.ons in which-they at;e accepted.
Vhen tie fire protection features of each fire. area are evaluated, the whole system of such eatures must be kept in perspective.
The defense-in-depth principle of fire protection programs is aim d at achieving.
an adequate balance between the different fea mres.
Strengthening any one can co-pensate 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 abil,i y to safely shutdown th plant and minimi=e radio-
'ctive r leases to tne environment in the event of a fire.
During these evaluations it is necessary to consider the two-edged nature of fire ro'c i+n natu es r-cooni z d in General Desi gn Cri teri on 3 navel v, fire pro ection should be prov toed consistent with other sarety considerations'.
An evaluation -..ust be ~ace ior each fi e al ea fol which an exemption s requested.
During these evaluations, the staff considers the rollowing parameters:
'A.
Ar ea Descript.ion walls, floor, and co il Ing construction ceiling height room volume ventilation congestion B.
Sa:e Shu"down Capability numbe" oi - dundant systems in area whether or not system or equiment is required for hot shutdown t~e of-eouipment/cables irvolved repair time for cold shutdown equipmnt within this area sepal atiotl between redundant components and in-si tu concentration of combustibles al ternative shutdown capability
1 7
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& A(
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C.. Fire Hazard Analysis
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type and configuration of combustibles in area quafiti ty 0(
corn(bus ibles ease of igni tion and 'propagation heat, release rate potential transient and installed combustibles suppression damage to equipment whether the area is contin'uously manned traffic through the area accessibility of the aria D.
Fire Protection Existing or Committed fire detection systems fire extingui shing systems
-., hose station/extinguisher ra'di(ant heat shields A speci(ic description of the fire protection features of the configuration is required to justi;y.he corn(pensat:ng features of the alternative.
ow fire loading is Aot a sufficient basis for granting an exemption in areas 1(,'h(ere there are cab) es.
If necessary, a
.earn( of.exper s, including a fire prot ciion engineer, wi I l vis i" t Ie s ite to deter.".inc t(-,e. ex i si i Rg c i cu 5 cances
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I ji i s visu a l inspection is also considered in the" review process.
The m(ajority of the III.G exe~ption requests received to da.e are being denied because they lack specificity.
Licensees have not identified ex(.eni of the exemption requested; have not provided a.echnical basis For (.le-reqUest
?Ad/or'(iave Aot provided a speci(ic description o( the alternative.
Me expect to receive requests for exemption of the following nature:
l'.
Fixed fire barriers less han 3-hour rating.
(
5 2.
Fire barrier without an automatic fire suppression system..
Lr s s the A 20 feet sepa ra tiion of cables l'(ith
(.i re propagation retardants (e.g., coatings,
- blankets, covqred trays) and an aU(o Iatlc sUppl essioA system 4.
For large open areas with few components
(.0 be protected 2Ad few 1A-situ combus ibles, no automatic suppression system with sepa'ration as in Item
.3 above.
5.
ho fixed suppression in the contr'ol r'oom(.
s~-
)
c
6..Ho fixed suppression in areas without a la) ge concentration of cables for which alternative shutdown c pability has been provide~.
Our f'.re research:est program is conducting tests to provide. informa Ion that wl 1 1 be useful to detel mine the boundary of acceptable condl tlons fo fire protection configurations which do not include a fire rated barrier.
Based on deviations, recently approved, specific criteria for certain recurring configurations are as folio>is:
Fire Barrier Less than Three Hours This barrier is a wall, floor, ceiIing or an enclosure which separates one'ire area from another.
Exemptions may be granted for a lower rating {e.g., one hour or t<<o 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 or a ixed barrier with a lower fix rating supple.-,ented by a ~eater curtain.
An Automatic Suppression SystI:m With Either One Hour Fire Barrier or Fii-..oo-Sa/a-,ae;on Th'.s barrier is an enclosure which separates those portions of one oivision which are w thin 20 '.eet of the redundart division.
,he suppressant may be watei ol 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.
Fire propagation retardants (i.e., cable coatinos, covered trays, condui ts, or mineral wool blankets) assure that fire propagation throuch in-situ combustibles will not occur or will be delayed sufficiently to ensure adequate time for' tection and suppression.
2.
Distance abo
'e a floor level xposure fire and below ceiling assures that redundant systems will not be si>,ultaneously subject t'o an unaccep able temperature or heat flux.
B.
The o,".mission of an automatic suppression system may be deemed acceptable where:
Distance above a,loor level exposure fire and below ceiling assures that redundan" syste
.s sill not be simultaneously subjec to an unacceptabl e temperature
'or heat flux.
,2.
The f're ar a is required to be manned continuously by the provisions in Tec".ical Specifications.
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