ML17278A850

Forwards Request for Addl Info Re Fire Protection Program, Based on Review of Documents Resulting from Mar 1986 Fire Protection Audit

ML17278A850
Person / Time
Site:	Columbia
Issue date:	05/23/1986
From:	Adensam E Office of Nuclear Reactor Regulation
To:	Sorensen G WASHINGTON PUBLIC POWER SUPPLY SYSTEM
References
TAC-60915, NUDOCS 8605300319
Download: ML17278A850 (8)

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~ ll May 23, 1986 Docket No. 50-397 Mr. G.

C. Sorensen, Manager

'egulatory Programs Washington Publ,ic Power.Supply System P.O.

Box 968 3000 George Washington Way

'ichland, Washington 99352

Dear Mr. Sorensen:

DISTRIBUTION:

~0 =3.7-NRC PDR Local PDR

'PRC System BWD-3 r/f EAdensam JBradfute EHylton

Attorney, OELD EJordan BGrimes JPartlow ACRS (10)

Subject:

WNP-2 Fire Protection Program - Request for Additional Information The staff of the Nuclear Regulatory Commission has reviewed several of the documents that resulted from the Fire Protection audit conducted at your facility by Region V and contractor personnel early in March 1986.

On the basis of that review, we need information identified in the enclosed Request for Additional Information.

We estimate that a minimum of four weeks after receipt of the information will be required, for preparation of the safety evaluation.

We are prepared to meet with your personnel, as necessary, in order to expedite resolution of this issue.

Sincerely,

/S/

Elinor G. Adensam, Director BWR Project Directorate No.

3 Division of BWR Licensing

Enclosure:

As stated cc:

See next page 86053003i9 8bOM3 F Oa AOOCK OSaOOSS7 F

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Mr. G.

C. Sorensen, Manager WPPSS Nuclear Proiect No.

2 Washington Public Power Supply System (WNP-2)

CC:

Nicholas S. Reynolds, Esq.

Bishop, Liberman,

Cook, Purcel 1

5 Reynol ds 1200 Seventeenth

Street, N.W.

Washington, D.C.

20036 Mr. G.

E.

Doupe, Fsquire Washington Public Power Supply System P. 0.

Box 968 3000 George Washington Way Richland, Washington 99532 Mr. Curtis Eschels, Chairman Energy Facility Site Evaluation Council Mail Stop PY-ll Olympia, Washington 98504 P. L. Powell, Licensing Manager Washington Publ.ic Power Supply System P. 0.

Box 968, MD 956B

Richland, Washington 99352 Mr.

W.

G.

Conn Burns and Roe, Incorporated c/o Washington Public Power Supply System P. 0.

Box 968, MD 994E

Richland, Washington 99352 R.

B. Glasscock, Director Licensing and Assurance Washington Public Power Supply System P.

0.

Box 968, MD 280

Richland, Washington 99352 Mr. C.

M. Powers WNP-2 Plant Manager Washington Public Power Supply System P. 0.

Box MD 927M Richland, Washington 99352 Regional Administrator, Region V

U.S. Nuclear Regulatory Commission 1450 Maria Lane, Suite 210 Walnut Creek, California 94596

WNP-2 -.FIRE PROTECTION PROGRAM REQUEST FOR ADDITIONAL INFORMATION In the advanced copy of Appendix'-Fire Protection Evaluation submitted by WPPSS on April 4, 1986, [Ref:

WNP-2 FSAR Amendment No.

37 Section F.4.3.d Page F.4.6a - "General Requirements of APP:R",j the following statement is given:

"Since the loss-of-offsite power transient is the least severe of the Chapter 15 analyzed transients no other transients would be allowed.

This is impractical to implement.

Discussions with the NRC and interpretations of General Letter 85-01 allow consideration of a s,ingle transient bounded by the FSAR Chapter 15 transient analysis.

The WNP-2 scheme of shutdown, using the Remote Shutdown

System, does not result in any single unanalyzed transients.

Therefore WNP-2 complies with Appendix R Section III.L" In the previous draft Amendment 837 it was stated that "The Desiqn Basis Fire (DBF) for the main control room and the cable spreading

room, even though not considered

credible, can result in generatinq transients more severe than presently analyzed in the FSAR Chapter 15 if worst case conditions are applied.

These conditions are not analyzed."

We require clarification as to which statement is correct and the basis for it.

2.

In the advanced copy of Appendix-R Fire Protection Evaluation submitted by WPPSS on April 4, 1986, [Ref:

WNP-2 Amendment No.

37 Section F.4.4.3 Page F.4.9 -.."Safe Shutdown Systems"j it is stated that six main steam safety/relief valves will result in less core uncovery and lower fuel clad temperatures.

" Plant specific analyses should be provided demonstratinq that with credit for only those systems which are, operable from the remote shutdown

room, there is no (or minimal) core uncovery as a result of the worst case design basis fire.

Justification for analysis assumptions must be included with the analyses.

3.

'Provide the analysis of ADS/LPCI systems for supporting a safe shutdown of the plant, and also identify the power systems, the instrumentation, the control systems, and the auxiliary systems asso'ciated with the safe shutdown methodology.

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Provide the hot short to overvoltage analysis for the associated circuits in the common enclosure.

5.

Paragraph F.4.4.2.9 states that "Following a Main Control Room evacuation (because of a fire); before operation of the remote shutdown transfer switches, it is assumed that the results of spurious failures, for analysis

purposes, are limited to loss of power supplies and blown fuses."

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Our position is that this assumption is insufficient.

Provide a revised analysis which assumes that any circuit can spuriously operate to energize or to de-enerqize

valves, pumps, or other equipment in such a manner as to operate in the worst direction for achieving safe shutdown.

These spurious signals need only be considered one at a time and should be assumed to initiate immediately upon scramming the reactor.

They are not to be assumed terminated, if possible, prior to regaining control of the plant at the remote locations away from the control room.

Similarly, paragraph F.4.4.4.3 states that "Spurious signal cables are those cables which... could cause an Appendix R safe shutdown circuit to malfunction."

It is our position that this is inadequate.

All circuits are to be reviewed for spurious signals to determine if any spurious signal could result in inhibiting the safe shutdown of the plant.

Paragraph F.4.4.3 states that "For any postulated fire in the plant a

single set of undamaged systems including power and control and instrumen-

'ation must be available to bring the plant to a cold shutdown condition."

This is acceptable.

However, it should be noted that there is no requirement that safe cold shutdown must be achieved with only undamaqed systems.

Only hot shutdown must be'chieved with undamaged systems.

If repairs are necessary to achieve cold shutdown, then they are acceptable provided that the following conditions are met:

1) the materials that are necessary to make the repairs are available onsite and dedicated for those repairs,

2) the operators are trained to make the repairs,

3) the appropriate procedures are in place to instruct personnel in makinq the

repairs, and 4) that the repairs can be made in sufficient time such that the plant can be in cold shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> from the initiation of the fire without offsite power.

In view of the above, verify that no credit is being taken for repairs in going to cold shutdown," or provide a

discussion of the repairs that are necessary which addresses the above four points.

On page F.4-9, the licensee states that "With the inclusion of the Alternate Remote Shutdown System in the WNP-2 design the number of ADS valves available will be increased to six."

Paragraph F.4.4.3.3 states that "The equipment required to provide cold shutdown capability, in the event of a Main Control'oom fire, consists of an isolated portion of the Appendix R Division 2 Safe Shutdown equipment, three division I SRV's along with auxiliary components...".

The above statements appear to be contradictory.

Verify that control of six ADS/SR valves will be provided at a remote location from the control room. If only three ADS/SR valves will be controlled from outside the control room, provide the results of a water inventory analysis which demonstrates that the effects of a fire in the control room, with the worst spurious signal and only controlling three ADS/SR valves, will result in no reactor coolant system (RCS) parameters exceeding those values which would exist during a

loss-of-offsite power event.

Verify that there will be no uncovery of the core, or alternatively identify the amount of fuel uncovered, length of time fuel is uncovered, and the maximum fuel and cladding temperatures in the core.

8.

On page F.4-11, the licensee states that Appendix R Remote Shutdown System consists, in part, of the "Reactor Vessel Instrumentation (Non-lE)".

Since all Appendix R fire events include the concurrent loss-of-offsite power, it is not clear how Non-lE instrumentation can be relied on to be available for safely shutting down the plant in the event of a fire in the control room.

Verify that all instrumentation in the Remote Shutdown System is powered by class lE systems (i.e. the diesel generators).

9 10.

Paragraphs F.4.4.4.3. 1.4 and F.4.4.4.3.2.4 state that "Spurious signals are isolated by manually operated transfer switches if available."

Ver'ify that there are no spurious signals which could result in a worse transient than a loss-of-offsite power event in the event of a fire in the control room.

For each spurious signal which does not result in a worse transient than a loss-of-offsite power in the event of a fire in the control room:

I) describe the available parameters and procedures which will be used to verify the presence of a spurious signal, of its

absence, and the frequency at which this determination will be made during the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of the>transient (or until cold shutdown is achieved);

2) identify the specific location and the identification number of the breaker which will be used to isolate the spurious signal.;

3) identify the person or persons who will make these determinations and will take the appropriate corrective actions;

4) verify that these people will either be in addition to the currently identified number of personnel needed for safe shutdown and the fire brigade, or that there will be adequate time for the personnel to perform their previously identified functions and to determine all spurious signals and take the appropriate corrective actions in a timely manner;

5) for each spurious siqnal which requires operator action, identify the amount of time available for operator action in order to prevent the spurious signal from inhibiting the safe shutdown of the plant;

6) for each spurious signal which does not have a means of isolation (Part 2 above),

assume that it occurs simultaneously with any other non-isolatable spurious signal and remains in the condition which produces the maximum hinderance to safely shutting down the plant.

For this scenario, verify that safe shutdown can be achieved and that no RCS parameter will exceed the value of the parameter for a loss-of-offsite power eveni.

Paragraph F.4.4.4.3.2.7 states that "Appendix R Division I Safe Shutdown System cables that contain', potentially spurious signals to other Division I Circuits do not require analysis".

This is not clear.

Any fire event can cause spurious signals.

Every spurious siqnal should be reviewed to verify that it will not adversely affect the safe shutdown of the plant and every spurious signal which will potentially have an adverse effect on the safe shutdown of the plant should be provided with protection and isolation capability.

Verify for every fire area that all non-3-phase power cables and control cables have been considered as potentially spuriously operating the related equipment and that every cable either:

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4 1) will not adversely affect the ability to achieve safe shutdown of the plant and will not result in any RCS parameter exceeding the value which would be observed during a loss-of-offsite power event, or 2) the spuriously actuated device will either be:

a)

'normally isolated from the control room during normal power operation; b) isolated immediately upon leaving the control room in the event of a fire in the control room; or c) there has been an analysis performed which demonstrates that, there is adequate time for the operator to identify the spurious signal and to isolate it from the control room.

For this case, provide a list of the spurious signals, the time available for operator action before any parameter exceeds the value associated with a loss-of-offsite power event, and a description of the actual operations and movements of the operator necessary to isolate the spurious signal in the event of a fire in the control room.

For case 2 above, verify that the appropriate procedures include the instructions for the operator to identify and isolate the spurious signals and that all operators will be trained to identify and to isolate spurious signals in the event of a fire.

11.

Paragraph F.4.4.4.3.3.2 states that "All Appendix R Remote Shutdown Components located fire area other than the Main Control Room will perform their designated function and do not require additional protection."

For each of the following areas, verify that the remote shutdown system will perform its designated functions in the event of a fire in that area and the spurious signals generated by the fire.

1) the area containing the transfer switches;

2) the area containing the RHR 'pumps;

3) the area containing the remote shutdown panel(s);

4) the area containing the motor control centers for the remote shutdown systems;

5) the areas containing the cables (signal and power) for all of the remote shutdown systems; and

6) the areas for the remote shutdown systems where cables (power and signal) pass through areas where other cables are present.

12.

Paragraph F.4.4.4.3.3.4 states that "Spurious signals are isolated by normally open circuit devices that are located outside the Main Control

'oom".

Describe how the operators will identify which signals are spurious and how they determine which circuit devices to open.