ML17213A467

Requests Meeting to Resolve NRC Concerns on Use of Remote Shutdown Panel & Areas of Noncompliance W/App R.Bnl Review of Util 820610 Info Encl

ML17213A467
Person / Time
Site:	Saint Lucie
Issue date:	08/25/1982
From:	Clark R Office of Nuclear Reactor Regulation
To:	Robert E. Uhrig FLORIDA POWER & LIGHT CO.
References
NUDOCS 8209220017
Download: ML17213A467 (13)

Text

4 Docket No. 50-335 Dr. Robert E. Uhrig Vice President Advanced Systens It Technology Florida Power 8 Light Company P. 0.

Box 529100 Miami, Florida 33152

Dear Dr. Uhrig:

AUG 25

>~ -'t'ISTRIBUTION Docket File NRC PDR Local PDR ORBA'3 Rdg DEisenhut OELD ISE MConner NFiorvante DWagner PKr eutzer NSIC ACRS (10)

JHeltemes, AEOD Re:

Appendix R Review for St. Lucie, Unit No.

1 By letter dated 0une 10, 1982, you submitted information to demonstrate that by a combination of compliance with and exemptions from the specific provisions of Section III.G.,to Appendix R, the objective of assuring safe shutdown capability for St. Lucie, Unit No.

1 in the event of fire would be met.

Nottitithstanding the fact that you prpposed no alternative shutdown modifications, we requested Brookhaven National Laboratory (BNL) to review the submittal to ensure safe shutdown requirements of Appendix R are met.

A copy of BNL's report is enclosed.

This report represents the current status of our review.

You have proposed use of the remote shutdown panel as a means of alternative shutdown in the event of a fire in the control room; however, you have not provided sufficient information concerning use of this panel.

Additionally, during BNL's review, areas of non-compliance with Sections III.G.and III;L of Appendix R were identified for which you have not requested an exemption.

Me request that a meeting be scheduled through your assigned prospect manager after you have reviewed the enclosure to resolve our concerns on (1) use of the remote shutdown panel and (2) those areas of non-compliance with Appendix R identified in the BNL report.

This meeting should be scheduled for mid-September 1982.

82092200i7 820825 PDR ADOCK 05000335 LF PDR

Enclosure:

As stated Sincerely, Origirlai stgned bV Robert A, Clark Robert A. Clark, Chief Operating Reactors Branch 83 Division of Licensing cc: w/enclosure See next page urrence a

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oo Docket No. 50-335 Dr. Robert E. Uhrig Vice President Advanced Systems 5 Technology Florida Power 8 Light Company P. 0. Box 529100 Miami, Florida 33152

Dear Dr. Uhrig:

Re:

Append R Review for St.

DISTRIBUTION:

Docket File NRC PDR Local PDR ORB ¹3 Rdg.

D. Eisenhut OELD ISE M. Conner N. Fiorvante D. Wagner P. Kreutzer NSIC ACRS (10)

J. Heltemes, AEOD Lucie, Unit No.

1 By letter dated une 10, 1982, you submitted information to demonstrate that by a combina on of compliance with and exemptions from the specific provisions of Secti

n. III.G to Appendix R, the objective of assuring safe shutdown capability for St. Lucie, Unit No.

1 in the event of fire would be met.

Notwithstandin the fact that you proposed no alternative shutdown modifications, we r equest Brookhaven National Laboratory (BNL) to review the submittal to ensure saf hhutdown requirements of Appendix R are met.

A copy of BNL's report is enc sed.

You have proposed use of the remo shutdown panel as a means of alternative s

shutdown in the event of a fire in he control room; however, you have not provided sufficient information conc ning use of this panel.

Additionally, during BNL's review, areas of non-comp iance with Sections III.G and III.L of Appendix R were identified for which ou h$ve not requested an exemption.

We request that a meeting be scheduled th pugh,your assigned project manager after you have reviewed the enclosure to re> lve our concerns on (1) use of the remote shutdown panel and (2) those ar as of non-compliance with Appendix R identified in the BNL repo} t.

This ecting should be scheduled for mid-September 1982.

Sincerely,

Enclosure:

As stated cc:

w/enclosure See next page c E'E 7 Mo~kec) r1 Robert A. Clark, Chief Operating Reactors Branch ¹3 Division of Licensing OFFICEI SURNAME/

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Florida Power

& Light Company CC:

Harold F. Reis, Esquire Lowenstein,

Newman, Reis

& Alexrad 1025 Connecticut, Avenue, N.W.

Washington, D. C.

20036 Norman A. Coll, Esquire McCarthy, Steel, Hector

& Davis 14th Floor, First National Bank Building Miami Florida 33131 Indian River Junior College Library 3209 Virginia Avenue Fort Pierce, Florida 33450 Administrator Department of Environmental Regulation Power Plant Siting Section State of Florida

.2600 Blair Stone Road

.Tallahassee, Florida 32301 Mr. Weldon B. Lewis County Administrator St. Lucie County 2300 Virginia Avenue, Room 104 Fort'ierce, Florida 33450 U.S. Environmental Protection Agency Region IY Office ATTN:

Regional Radiation Representative 345 Courtland Street, N.E.

Atlanta, Georgia 30308

~Mr. Charles B. Brinkman Manager - Washington Nuclear Operations C-E Power Systems Combustion Engineering, Inc.

4853 Cordell Avenue, Suite A-1

Bethesda, Maryland 20014 Regional Administrator Nuclear Regulatory Commission, Region II Office of Executive Director for Operations 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 Mr. Jack Schreve Office of the Public Counsel Room 4, Holland Building Tallahassee, Florida 32304 Resident Inspector c/o U.S.N.R.C.

7900 S. AIA Jensen Beach, Florida 33457 State Planning and Devel pment Clearinghouse Office of P 1 arming and Budgeting Executive Office of the Governor The Capitol Builling Tallahassee, Florida 32301

POST FIRE SHUTDOWN CAPABILITY ST.

LUCIE UNIT NO.

1 BNL Reviewer - J.H. Taylor

1. 0 INTRODUCTION 1.!

~Bk The St. Lucie Unit No.

1 Appendix R review, transmitted by Florida Power and'ight's June 10, 1982 letter, outlines the licensee's plans for post-fire safe shutdown and provides a chronological history of the licensee's fire protec-tion activities dating back to their March 1977 Fire Hazards Analysis.

The licensee also responds to the NRC's generic letter 81-12'dated February'20,-.'.

1982 and the subsequent clarification letter dated May 10, 1982.

The licensee's submittal supports requests for exemptions from Appendix R

based on improved fire protection and fire hazards analyses.

Since the task of reviewing and preparing recommendations for exemptions on this basis is not within the scope of work assigned to Brookhaven National Laboratory, the fol-lowing commentary does not constitute a recanmendation for or against the licensee's proposals.

It is felt that the canments provided herein might. be useful in assisting the NRC in making a determination in this case.

1.2 Fi re P rotecti on SER Pos ition The St. Lucie SER dated August 17, 1979 noted that the separation between re-dundant divisions of cables required for safe shutdown was still 'under review by the NRC.

In their review 'of open fire protection items for St. Lucie No.

1, issued in February 1980, the NRC concluded that the minimum separation dis-tance between redundant divisions of cables is not acceptable, and that cables coated with a fire retardant coating will be damaged or will ignite when directly exposed to a flame for several minutes.

And finally, that the lack of wide separation between redundant divisions of safe shutdown cables at St.

Lucie could result in damage to both divisions from direct flame impingement from an exposure fire.

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The licensee was then directed to provide alternate shutdown independent of the following areas:

Cable Spreading Room Switchgear Rocms - Elevation 43 feet,.Auxiliary Building Cable Lofts - Elevation 19.5 feet, Auxiliary Building The licensee was also directed to provide alternate shutdown or adequate fire protection similar to Section III.G.2 for the following equipment or areas:

I Chargi ng Pumps Reactor Containment Building Auxili ary Feedwater Pumps Intake Cooling Water Pumps Auxiliary Building - Elevation 5 feet

<<2 The licensee responded to the NRC in a letter dated February 3,1, 1981 stating that they have demonstrated the capability for post fire safe-shutdown and then restated their Fire Hazards Analysis position.

In a "L-81-122, Requests Exemption from 10CFR50.48 & App R to 10CFR50 Schedule Dates for Compliance W/Fire Protection Requirements Per 10CFR50.12(a) & [[CFR" contains a listed "[" character as part of the property label and has therefore been classified as invalid.)|letter dated March 19, 1981]] the l.icensee responded to the NRC "open items" letter dated November 24, 1980 and the NRC generic letter 81-12 dated February 20, 1981.

In this letter the licensee requested exemptions from the requirements of Appendix R for those areas previously approved in the

SER, including safe shutdown.

In their June 4,

1981 response letter, the NRC denied the licensee's-request for exemption and stated that the licensee must meet the requi rements of Sec-tion III.G or provide a detailed fire hazards analysis supporting an alterna-tive approach.

1.3 Plant Descri tion St. Lucie Unit No.

1 is a Combustion Engineering pressurized water reactor plant rated at 777 MWe, which went into commerical operation in December 1976.

It is owned and operated by the Florida Power and Light Company.

2.0 REVIEW AND EVALUATION 2.1'::Section III.G - Fire'rotection of Safe Shutdown Capabilit J

2.1.1 S stems Used for Post Fire Safe Shutdown

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Reactivity control is accomplished by control rod insertion and by boric acid injection via the boric acid transfer pumps taking suction from the two boric acid storage tanks.

A secondary boration method is water. injection from the refueling water'torage tank via gravity feed to the charging pumps.

Reactor coolant system makeup is achieved through the use of any of the three charging pumps taking suction from the Refueling Water Storage Tank.

Decay heat removal is accomplished through the steam generators by the auxili-ary.'.feedwater system supplying water from the condensate'storage tank, with..

steam relief via the atmospheric dump valves.

The licensee's submittal notes that per NRC Staff requirements, a missile protected.crosstie is provided be-tween the Unit No.

1 auxiliary feedwater pump suction line and the Unit No 2

condensate storage tank.

This will provide additional condensate to Unit No.

1 at a later date.

Reactor pressure c'ontrol is achieved by use of redundant trains of pressurizer heaters.

Process monitoring is provided for the following parameters:

pressurizer pres-sure and level, steam generator pressure and level, reactor coolant system temperature indication, containment pressure and tank levels for the boric

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',I'cid and condensate storage tan'ks.'.

Indications should also be provMed for the refueli,ng water storage tank level and for source range monitoring.

In addition to the equipment required, for hot shutdown, for cold shutdown, re-activity is controlled by borating the RCS using the charging systeman con-junction with the chemical and vol'ume control system.'CS heat removal will be via the Shutdown Cooling System.

Mechanical support systems required for hot and cold shutdown area's fol'lows:

component cooling water, intake cooling water, diesel generators, and HVAC fc the containment, auxiliary buildi"ng and the contro'1 roan.

Electrical systems used for safe shutdown are the 4KV, 480V and 120V AC'and the 125V DC,distribution systems.

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2.1.2 Ty' of Fire Protection Provided The licensee has divided the plant into the same eighty-two fire areas for ar alysi s that he used for hi s ori ginal fire hazards analysis.

The licensee states that forty-two of these areas fully comply with Section III.G. 1 and 2 of Appendix R and are not discussed in the submittal.

Addi-tionally, the licensee proposes to modify four of the areas so that they will fully comply with Section III.G.2.

These areas are the boric acid makeup tar area, auxiliary'building HVAC equipment room, and the lA and 1B battery room.

The modifications consist of:

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1) upgrading the walls, floors and ceilings to a 3-hour rating by the addition of qualified doors, dampers and penetration seals

2) 3-hour barrier protection for cables. of one SD train 3) some cable relocation The remaining thirty-six fire areas do not fully comply with Appendix R Sec-tion III.G.

The licensee has requested separate exemptions from the separa-

,tion requirements of 'Section III.G.2 for each'f these areas based on a com-bination of fire protection modifications, administrative procedural control.

and fire hazards analyses.

The licensee provides a cost comparison between their modifications and those required for full canpliance, which is three miTlion versus fourteen million dollars, respectively.

All of'the fire area.

listed in Section 1.2 of this report (requiring compliance with Section III.'.

are contained within these thirty-six fire areas.

A schedule exemption request is also included for each area, which requests nine months subsequent to NRC approval for full implementation of all. propos modifications.

A summary of the proposed modifications for the exemption requests are as fc lows:

I) Upgrading of floors, walls, and ceiling to a three-nour fire rated barrier by sealing all penetrations, installing qualified doors, etc.

2) Preparation of emergency procedures to locally open breakers',

operate valves, 'and pull fuses to place equipment in their".,shutdown posi'-

tions.

3) Provide portable lighting.

4) Installation of fire resistant baffles to protect cable trays.

. 5) Spraying of a fire protection coating, Flamastic:77; on gxpqsed.-.-

cabl es.

6) Protect conduit, where required, with a thermal 'insulating. material.

7) Provide fire barrier or enclosures around specific motor operators.

8) Minimum rerouting of cable.

9) Addition of some automatic supprehsion.

The task of reviewing and evaluating these modifications and exemption re-quests is not within the scope of work assigned to BNL.

However, the fol-lowing comments are offered for consideration:

1.

-Th'e licensee proposes to pull control fuses to close the PORY's; steam generator dump valves, and the main steam isolation valves as necessary,

~ - i n case of fire damage in the contairment, electrical penetration

rooms, and the A'nd B switchgear rooms.

This is unacceptable because Appendix R

precludes the use of repairs in hot shutdown, and the pulling of fuses is

-.-.considered an unacceptable repair.

In the case of the PORV's, this is not

--.a good course of action anyway because these valves have been known to

---.stick in the open position.

A more prudent course of action would be to close the PORV block valve, either manually or automatically.

2;, 'In fire area I, the auxiliary feedwater pump area;:.the control cable for AFW pump C is located in zone I along with AFW pumps A and B.

This is unacceptable since the means to remove decay heat would be lost in

. case of a fire.

This zone must meet the requirements of III.G.2 or

'II.G.3.

3.

In fire area 26, the containment building, the following concerns are noted:

a.

Attempting to reach hot shutdown conditions without the use of any pressurizer heaters is not acceptable since there is no di rect means of positive pressure control.

b.

Emergency procedures should be prepared for the proposed operator actions, that are requi red as a result of a fire in this area.

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As a 'res'ult of a fire in the A switchgear room, the following equipnant would be'noperable:

the A and 8 charging

pumps, and the A and 8 boric acid'transfer pump.

This seriously reduces the reliability of the re-activityI control and reactor coolant makeup functions since the only re-maining piece of equipment to perform these functions is the C charging Dump+

1 In his analysis of the control rocm, fire area 70, the-licenkee-offers the remote, shutdown panel as a means of alternate shutdown for-hot-shutdown conditions.

He has requested an exemption for the cold shutdown cables based on a fire hazards analysis..

A '.1.3. Alternative or Dedicated S stems Pro osed

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A remote shutdown panel is located in the Auxifiaiy.Su))ding'at-the'43 foot

.elevation.

0ith this panel, the reactor can be. brought to-hot shutdown'con-

'itions independent of the main control room.

The licensee states that there are isolation switches to isolate the control roon circuitry from the emer-gency controls.

In his evaluation of the control room', the 1icensee offers this remote shutdown'anel as a means of alternate shutdown for hot shutdown conditi ons.

.In Section'3.1.G of their submittal, the licensee states that in the event

.that local and remote control stations used to*maintain hot standby'conditions

.: are unavailable, then the equipment can be started or tripped at their as-sociated power sources.

However, no further details are presented, nor does

-..the licensee, state that procedures are available for these activities.

2.2 Section III-LAlternative and Shutdown Ca abilit Com liance 2.2.1 Performance 'Goals The licensee does not propose an alternative or dedicated shutdown system, ex-

.cept for hot shutdown in the control room, and therefore does.not comply with the requirements of Section III.L.

The remote shutdown panel is deficient in

..pt-ocess monitoring of.storage.tahk levels and source range monitoring as well as cold shutdown capability; I

'. 2.2.2 72-Hour Re uirement Although the licensee would prefer to renain in hot shutdown,. he has stated that cold shutdown can be achieved.

However, he has not clearly stated that, it, can be achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

. 2.2.3 Procedures and Manpower The licensee has canmitted to preparing emergency procedures for all required operator actions, except for those required in case of a containment fire.

The licensee has ccmmitted to the requirements of Appendix R for the staffing of a fire brigade.

However, he has not demonstrated that concurrent with a

~fire., ther'e would be sufficient operators available to safely shut the plant down, including implementing any emergency procedures:

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~e 2.2.4 Repairs I'i No repairs were deemed necessary by the licensee for post-fire safe shutdown.

2.2. 5 Associ ated Circuits The licensee has satisfactorily addressed associated circuits of concern.

He has used the guidance provided in the NRC generic letter 81-12 and the sub-sequent clarification letter dated May 10, 1982.

In the case of the common power source, the licensee has stated that all power, control, and instrumentation circuits are protected in a coordinated fashion by either circuit breakers or fuses.

The licensee supplies three ex-amples including electrical schematics to support this statement.

However, the licensee has not demonstrated that coordination of electrical protection is an ongoing program.

With regard to equipment whose spurious operation could impact safe shutdown capability or violate a high/low pressure interface, the licensee has treated these circuits identically to the circuits required for safe shutdown.

All circuits in this category have been identified as "equipment required to mitigate the consequences of a fire" and are discussed in Section 3.3 of the submittal and analyzed similar to safe shutdown circuits.

Emergency safety featur e actuation signals were also reviewed and analyzed in a similar fashion.

In addition to determining circuits to be reviewed with the safe shutdown cir-cuits, the licensee took the position that spurious operation of 3/8" sample valves for the steam generators and the reactor coolant system would not sub-stantially impact the inventory of these systems.

This is acceptable.

Associated circuits that share a

ccmmon enclosure with SSD systems are not of concern because all power, control, and instrumentation circuits are elec-trically protected.

Furthermore, all circuits are fire sealed where they penetrate walls, floors, and ceilings.

In summary, the only associated circuits of concern are those whose failure could'ause spurious operation, and cables in this category are evaluated in the fire area evaluation.

2.2. 6 Hi h/Low Pressure Interface The licensee has addressed this concern via ttis associated circuits review.

2.2.7 Automatic Functions - Shutdown Lo ic The licensee has also addressed spurious actuation of a safety injection and containment spray via his associated ci rcuits review.

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3.0 CONCLUSION

S AND RECOMMENDATIONS 3.1

~C The goals of reactivity control, inventory control, decay heat removal and pressure control have been met, except as noted in Section 3.2.

The goal of process monitoring has not been met.

The licensee has not met the require-ments of Section III.Lof Appendix R.

3.2 ~Dt 3.2.1 The licensee should provide process monitoring capability for the fol-lowing parameters:

refueling water storage tank level, and source range mon-itoring.

3.2.2 The pulling of fuses to close the PORV's, steam generator atmospheric steam dump valves, and the main steam isolation valves is considered hot shut-down repair, which is a violation of Appendix R.

The licensee should meet the requirements of III.G.2 or III.G.3.

3.3.3 In the a.xiliary feedwater pump area, the control cables for the C pump must be separated from the A and B pumps such that they meet the requirements of III.G.2.

3.2.4 In the containment building, the following conditions must be cor-r ected:

a.

The loss of all pressurizer heaters must be precluded, or b.

Emergency procedures must be prepared for the proposed operator acti ons.

I 3.2.5 The licensee should clarify whether or not he is preparing. the remote shutdown panel as a means of alternate shutdown.

If so, he must. demonstrate that. the requirements of Section III.L are met.

3.2.6 The licensee should state that cold shutdown'conditions can be achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following any postulated fires.

3.2.7 The licensee should demonstrate that. sufficient manpower is available to both fight a fire and safety shut the plant down.

3.2.8 Regarding associated circuits of concern, the licensee has satisfac-torily addressed the cases of spurious operation and ccmmon enclosures.

For the common power source situation, the licensee should demonstrate that co-ordinhted protection is an ongoing program.

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