ML17320A873

Forwards SER Re Fire Protection Rule,Sections III.G.3 & Iii.L of App R to 10CFR50 on Alternate Safe Shutdown Capability.Alternate Shutdown Methods Meet Performance Goals for Reactivity Control

ML17320A873
Person / Time
Site:	Cook
Issue date:	11/22/1983
From:	Varga S Office of Nuclear Reactor Regulation
To:	Dolan J AMERICAN ELECTRIC POWER SERVICE CORP., INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
References
NUDOCS 8312090183
Download: ML17320A873 (21)

Text

Docket Nos. 50-315 and 50-316 Hr. John Dolan, Vice President Indiana and IIichigan Electric Company c/o American Electric Power Service Corporation 1 Riverside Plaza

Columbus, Ohio 43216

Dear Ilr. Dolan:

Docket File NRC PDR Loca1PDR ORB b'1 D Eisenhut D WIgginton C Parrish T Wambach ACRS (10)

OELD J Taylor E Jordan Gpay Files

SUBJECT:

FIRE PROTECTION RULE-ALTERNATE SAFE SHUTDOWN CAPABILITY-SECTIONS III.G.3 AND III.L OF APPENDIX R TO 10 CFR 50-DONALD C.

COOK NUCLEAR PLANT, UNIT NOS.

1 AND 2 We have completed our review of the subject as noted above based on your submittals dated March 27, 1981, I)arch 31, 1983, and August 22, 1983.

Our enclosed Safety Evaluation provides the results of our review.

The alternate safe shutdown of Donald C. Cook Nuclear'Plant, Unit Nos.

1 and 2, in the event of a fire, was evaluated against the requirements of Sections III.G and III.Lof'ppendix R to 10 CFR Part 50.

Based on our review, we conclude that the Donald C. Cook Nuclear Plant alternate shutdown methods meet the performance goals for reactivity control, reactor coolant inventory makeup, reactor heat removal; monitoring of shutdown and support functions.

Therefore, we conclude that the Donald C.

Cook Nuclear Plant proposed alternative shutdown capability complies with the requirements of Sections III.G and III.Lof Appendix R.

However, since the proposed capability relies on shutdown procedures for coordinating the activities of two units, we require that the final procedures be submitted to the NRC for review and that the Technical Specifications for alternative shutdown cal1ability be submitted to the NRC prior to completion of the plant modifications for approval.

,The schedule for you to complete required modifications is specified in 10 CFR 50.48(c)(4).

Compliance with the Fire'rotection Rule will be the subject of future Commission inspections.

Sincerely, 8312090183 831122 PDR ADOCK 05000315 F

PDR

Enclosure:

Safety Evaluation Steven A. Varga, Chief Operating Reactors Branch No.

1 Division of Licensing OFFICE/

SURNAME$

DATE P See next page

'ORB+1 DWigginton$

-1 I/($33-f Tllambac)

..$ $/2+83.....

R NRC FORM 318 (10.80) NRCM 0240 OFFICIAL RECORD COPY USGPO: 1981~960

>e

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Indiana and Michigan El empiric Company Mr.

M.

P.

Al ex ich Vice President,-

Nuclear Engineering American..Electric Power Service Corpora tiun 1 Riverside Pl az<)

Columbus, Ohio 43?15 Mr.

1 i 1 1 i an R. Rusten (2)

Office of the Governor Room 1 - Capitol 'Bui 1 di ng

Lansing, Michigan 4891 3

.".r.

'k'ade Schuler, Supervisor Lake Township Ba roda, Michigan 49101 Honorab'1 e Jim Catania, Mayor

, "Ci ty, c'.

Bridgman, Mi ch>oan 49106 U. S.

="nvironmental Protection Agency Region V Office ATTN:

E I S COORD I 1,,ATOR 230 South Dearborn Street

Chicago, l 1 1 inoi s 60604 Maurice S.

Re i zen, M. 0.

Di rector Department of Public Health P.G.

Box 30035

Lansinc, Michigan 48109 h.

G. Snith, Jr.,

Pl ant.Manaoer Donald C.

Cook Nuclear.Plan.

P.

0.

Box '458 Bridgman, Yichigan 49106 U.

S. Nuclear. Reoul atory Co~mi ssion Resident Inspectors Office 7700 Red Arrow Highway Stevens vi1 1 e, Michigan 49127 Geral d Charnof'f, Esquire

Shaw, Pittman, Potts and Trowbridge 1800 M Street, N.l'.

washington, D.

C.

20036 The Honorable Tom Corcoran

'ni ted States House of Representatives washington, D.

C.

205) 5 J anes G.

1'epp1 e r Regional Administrator - Region I I I U, S.

Nuclear Regul atory Commi ~s i on 799 Poosevelt Road Glen

="1 lyn, I 1 1 inoi s 60137

D C

COOK NUCLEAR POWER PLANTr UNITS 1'

2 SAFETY EVALUATION REPORT

. ALTERNATIVE SHUTDOWN CAPABILITY On February 17'981'he f i re protect i on. rule for nuc Lear power plantsr 10 CFR 50.48 and Appendix R to 10 CFR 50 became effective.

This rule required all Licensees of plants licensed prior to January 1i 1979'o submit by March 19r 1981:

(1) plans and scheduLes for meeting the applicable requirements of Appendix Rr (2) a design description of any modifications proposed to provide alternative safe shutdown capability pursuant to Section III.G.3 of Appendix R

and (3) exemption requests for which the tolling provisions of Section 50.48(c)(6) were to be invoked.

Section III.G of Appendix Ri "Fire Protection of Safe Shutdown Capability" was ret rofit to all pre-1979 plants regardLess of previous SER positions and resolution.

,By letter dated March 27m 1981'he Licensee indicated that modi-fications -were not required to provide alternative safe shutdown capability for the D.

C.

Cook plants-An NRC inspection of the plants ident ified a

number of concerns with the safe shutdown capability.

Subsequent to the inspections the Licenseeei by letter dated March 31'983 submitted the results of its reassess-ment of the safe shutdown capability to the requirements of

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Section III.G of Appendix R

and a description of proposed modifi-cations to provide alternative shutdown capability.

Additional information was'r ovided by a Letter dated August 22'9S3.

H A.

Systems Used for Post-Fire Safe Shutdo I'. the. event of a fir e c'oncurrent with a

Loss of'ffsite

'owers'he following systems are used to provide the shut-,

.I

.-> down. capability forone unit.. Reactor'hutdown is initiated

~:;;,*,,:-',,",'",,'-;;*".',from'he,', control~oom by' manuaL'.'scr'am-"of'=:the'."control'odsi.',""'"

if an automatic scram has not occurred.

Reactor coolant

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inventory and reactor shutdown react ivity are maintained by one of two centrifugaL charging pumps taking suction from the refueling water storage tank.'rimary system pressure r,

is maintained by use" of the pressurizer heaters.

Over-pressurization protection is provided by the pressurizer safety" relief valves.

For hot standby/shutdowns decay heat removaL is accompli'shed by the auxiliary feedwater, system supplying water. to, the.,',.:,:,';;.,;.

!I I

steam generators from the condensate storage tanks-:

One of

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three auxiliary feedwater plumps is needed for decay heat r

removal.

The essential service water system provides an

additional water source for

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. The'tmospheric dump valves used to remove heat from the shutdowns decay heat removal heat removal.

(RHR) -system in cooling water system and the the aux i l iary feedwater system.

or the code safety valves are I

",I steam gener ators.

For cold is accomplished by the residual conjunction with the component" I

essential service water system.

Cold shutdown can be achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

e The. above systems'are, supported by thefcomponent cooling-water (CCW)- system and, the essent ia.l. service-water": (ESW)-"-." ';,; '.";";-,-;;:",""I",.g';.,;

I

'I system.

The CCW system provides cool.ing for the charging pumpsi the RHR pumps and heat exchangers and the reactor-

, If coolant pump thermal barrier heat'xchangers.

The CCW I

system for each untt consists of two trainsi each with a

'I pump and lieat exchanger.

A fifth CCW Aumpi. a spare..'swing'umps is available to replace any CCW pump in either unit.

The ESW system which i>s shared by the two unitsr consists of four pumps utilizing two main headers'he ESW system provides cooling to the CCM heat exchangers and the dieseL I

generator beat excbangers.-

The dieseL generators and,,

associated el.ectricaL distribution system supply the essen-tial power for the shutdown systems."

There are two diesel II

'I I generators for each unit.

The above systems are normally t

I control. Led and monitor ed from the control room-In the event of a fire resulting in Loss of the control roomr aLternati've means of controlLing and monitoring these systems a f.e orovided.

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B.

Associated Circuit Protec To assure the availability of the above systems following a firei the Licensee identified associated circuits that could prevent operation or cause maloperation of; shutdown--"--

systems and equipment-For identified associated circuitsr.

protection for the safe shut'down systems was provided in accordance with NRC guidelines as outlined in the following pa ra graph s-I

Power Sour ce Case The'icensee'ndicated that 'aL'L

circuits in tbe emergency power system (dieseL generators) were reviewed to assur e proper coordination of protec" tive breakers and fault inter upting devices.

The emer-gency power system is utiLized to supply the" essential power for the post"fire shutdown systems.

Coordination of circuit protective devices was part of the'riginal electrical system design of the D.

C.

Cook plants.

Thus'y design of the plants associated circuits of this type should not exist'.

Additional lyr the Licensee wi L L verify coordination for the safe shutdown p

1 C

2.

Spurious Signal Case - The Licensee of circuits where fire-induced fa i Lu ower supply system.'

ident ified a number res may adversely af feet the safe shutdown capability.

In identifying

associated circuits of concerns the Licensee reviewed control circuit electricaL interlocks between shutdown circuits and other circuits-A Failure Mode and Effects Analysis (FMEA) was then performed to determine if fire-

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induced fai Lures of these inter Locks could adverse ly.'.-:

.impact safe'hutdown.

Further'he L icensee.reviewed;""~.-

K plant systems to identify any component which had the potential for adver sely affecting safe shutdown.

A FNEA was performed on these components to determine if fire" induced c ircuit fai Lures could result in the component:--'"=-'..'--

"=".~:.".',

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'Pw

",."'.'.-,.-,-,'.~,*.':",. being,')n; an. un'acce'pta'bLe'tate'.":.'-~

Unacceptable~, in the"'-".<PA-',"'~~>',;.'".~g'4;.">~

sense that it adversely impacts shutdown.

The Licensee liminated some failure modes from considerationi based on their low pr obability of occurrence-as discussed in

~or t6e fel L owi'ng paragr aph s.

'2 t

I The Licensee did not consider three-phase ac power cir-cuit cable to cable fauLtsr two wire ungrounded dc power circuit cable to cable fault (250V); two wire ungrounded dc control curcuit cable to cable faults (250V) r and one phase ungrounded ac controL circuit cable to cable faults (220V).

For the case of the three phase circuitsr the Licensee indicated that two power circuitsi one of which is energized and the other in nonener gizedi would

need to be damaged by the fire such that power would be supplied to the nonenergized circuit.

The Licensee indicated that for three phase circuitsr this failure V

was unlikely.

For the case of the two wire dc power circuitsi two power circuitsr one of which is energized and the other is nonenerg4zed would need to be damaged by the fire such that power would be supplied to the nonenergized circuit.

Since the dc power system is a

nongr ounded systemr the short of the two circuits would

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~ have to'ccur prior to one of-- the-circuits.. being shorted.',

I I I'o ground.

For the cases of the two wire ungrounded dc control circuit and the one phase ungrounded ac control circuits similar conditions exist.

For the dc or ac fJ cir cuits supplied from different sources at Least two electrically independent cable to cable shor ts without grounding must occur.

Fog the

'dc or ac'i'remits supplied from the same sources two independent cable to cable shorts without grounding must occur because of the Cook design which requires that the control switch and relay contacts "double break" the positive and negative control Leads for components whose spurious operation could affect safe shutdown.

Thereforei the above failure modes were not considered based on their Low probability of occurrence.

For the identified associated circuits of concern the Licensee proposed methods for protecting the safe shutdown capability consistent with the severity of the problem..

For examples for spurious oper ation of com-ponents which could divert auxiliary feedwater flowi the Licensee proposed removing power to those components by II operating the plant with the appropriate circuit breaker open.

For other component si the. shutdown pr ocedures wi L L require isolation of the components; thus'imiting the impact of spurious operations.

For cold shutdowns pro-cedures will verify proper alignment to correct any spurious operations-Further'or prevention of a pos-iie sible fire induced LOCAL the power for one of the redun" dant electrically controlled valves at the high/Low pres-sure interface of the reactor coolant system and the RHR pump suction Line~ will be removed by opening the breaker for either valve during normal operation.

3..

Common Enclosur e Cage The Licensee indicated that electrical circuit fault protection was provided by pro-tective relayingr circuit breakers and fuses as part of the original plant design of the e lect rinal system.

These circuit fault protective devices prevent cable

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~ I removali process monitoring and support for the above func-tions:

6Ni 6S~ 'l4i ZOi 40Ar 40Bi 41 r 42A th r ough D~ 44Ni fs V

f I t

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I~t 44Sr 45'6A through Dr 47Ar 47Br and 53 through 60."

These

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fire zion'es, of. both units include the control roomsi the cable h

vault area'si-'the switchgear -.cable., vaultsi.-., the 'switchgear, and,*, "'"~.,

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'otor'ontrol rooms and the transformer rooms.

For the rea'ctivity controL funct ionj. the" charging systems of the two units will be connected by a four"inch Line between the centrifugaL pump discharge headers.

Each unit's charging system consists~of two high-head centrif ugal pumps. with only one pump needed for a unit's post-fire shutdown.

The p>ping connections between the units'ystems wi Ll be normally isolated by two manual valves.

Thh alternative shutdown capability will also utilize the crossties between charging systems for the reactor coolant makeup function-For pre" mar y side pressure contr oli the alternative shutdown cap-ability wiLL utilize repairs to establish pressurizer heater s-Repairs to the pressurizer heaters power cables

,*'rovides operational flexibilityto operators.

The pres" sur izer heaters are not required for shutdown.

The plant wiLL have the capability of pr oceeding to cold shutdown as the plant depressurizes.

Use of the heater extends the time before depressurization.

t P

I For., hot" standby!shutdowns the alternative shutdown" capability.,-,

wiLL utilize the existing crossties between the motor"driven pumps of each unit's auxiliary feedwater

systems, for,. decay,.,-".,

heat, removal.'. The connections between'he.

two units'ystem '-

I are normally'solated by manual, valves..

Flow to" the steam gener ator wiLL'econtrol'L"ed'y ma'nuaL control'f. the"-affected'-

unit's steam generator inlet valves.

For heat removal from the steam gereratorsi the alternative shutdown capability will ut ilize manual operat ion of t

~fj from local cont rol st at i ons.

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Cont l

pneumat i c va L~e loading cont rol wi the plant N> distribution header.

he atmospheric dump valves roL will be provide'y

th backup motive power from For cold shutdowns repairs to the power cables for one residual heat removal pump of the fire affected unit will be used to provide aLternative shutdown capab i lity.

For, the, process., monitoring, function for each'- unit's alter-nat ive shutdown capab it ityi the L i censee 'rop'oses use of four instrument panels-Each of the instrument panels will have the capability of being powered from either unit's emergency power system.

Two panels are Located adjacent to the Local controls for, the steam generator inlet valves and the atmos-phersc dump valves.

These two panels provide monitoring."','..-""

t, f~ y j4i g ~~ +

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)\\ 'ot. t Jl

'4'or reactor" coolant hot'nd'old Leg temperat'ures"'and; s'team",.

I generator pressures and Levels for their respective Loops.

The additional two panels are centrally Located and will be., "',,;...

used for'oo"rdinat ion of shutdown activities.-*

One paneL,;-".~.;.>:.;.'"."."'::-"=,;"'";-".

prov'ides monitoring for r eactor coolant pr essur ei P'ressurizer,'.""

','.",'<<~.",'."

h C*

Leveli charging fLow and Letdown f Low.

~ The otheranel pro""."."',.'"-'-'<<.'."'...",'",,'--,~.",

vides monitoring for reactor coolant hot and cold Leg

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temperatures and steam generator pr essures and levels for each of the four Loops and source range neutron fLux.

Addi"-

'pic tionaLLyi"~onitor fng of the ona ffec'tedunit

's equipment is p'o-'ided from the unaffected unit's controL room.

The alternative shutdown capability will utilize the unaffected unit's component cooling water (CCW) systems essentiaL service water system and 'emergen'cy power'ystem CEPS) to provide the necessary support functions'.;.

For hot shutdowns the CCW systems the ESW system and the EPS provide support-,

to the unaffected unit's equipment which. is being used for',-...'lternative

shutdown, Additionally~ the EPS is capable of'ki>

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powering the fire"affected unit's four alternative instrument panels.

For cold shutdowns the CCW and the ESW systems of r

the unaffected unit will be manually'aLigned to provide r

, cooling. for one residual heat r emoval (RHR) pump and heat; excha'ng'er'f the fiie-affected unit.', Additionallyr. th"e RHR.'.1-l t*

pump will be re"powered from the unaffected unit's EPS.

la The L icensee has'ommitted to provide a shutdown procedure

'1 describing use of the alternative shutdown capability.

Tje

'-";">>-'".;:.'.;-e'.".'-'shutdown'ro'cedui e.,invo l ves use of three operators f rom the fire-'affected unit and some oper ator functions from the unaffected unit's control room.

The three operators will initially manually isolate the primary and secondary systems and manually align the cross"ties for the charging and auxiliary feedwater systems.

The contr ol room operators of the unaffected unit wiLL start the unaffected unit's motor-driven auxiliary feedwater pump and maintain operation of the unaffected unit's equipment being used (CCWr ESWr charging system and EPS).

The three operators of the fire" h

affected unit will controL. charging and auxiliary. feedwater,.

- ~,"-". ; ".;:....."

f Low to achieve and maintain hot standby.

The procedure II wiLL also describe the operation necessary to achieve cold shutdown.'

-1 3-The alternative shutdown capability will utilize two repair activities for safe shutdown.

As described above'epair of the pressurizer heaters is used to provide operational flexibility.

Permanently installed power cabling between the" pressurizer heater containment penetratio'n.

area'- and",a;"",'-'.,"-'";.,';i,-,-"'

V 480V MCC cubicle powered from the aL ternate unit wi L l be-";.,'..'-'.;-'.. '".".

provided.

The post-f i re"- repair wi L l consi st'f disconnect in'g';=~-;~.".;.".,'",*-'.:,>>,

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the damaged cabling and connect ing the repair cable, f rom,-=

P the penetration area.

The pressurizer heaters would then be powe red' rom the" alter'nateunit'-.,

q Al L'. tools and procedures;~>,.'-i;,<<.. "'

needed for the repair activity will be stored with the cabling in the penetration area.'epair of the power source

for one RHR pump is utilized to achieve and maintain cold ",

r,

= 44r shutdown.'he repair consists of interrupting the power;..

r'upply to one of the unaf fected unit 's RHR pump and rerout-.

1

ng the power supply to the fire-af fected unit 's RHR pump'."

The rerout ing of power cabling. wi L L result in one RHR pump from each unit being powered from the unaffected unit's erne rgen cy powe r system.

I The materials tools and p'rocedures for the

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repairs wilL be stored onsite,....

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I Method 2

For the following fire zones of Units 1

and 2i the alternative shutdown capability utilizes the proposed cross-A tie between the two units char ging systems to provide the shutdown functions of reactivity control and reactor coolant makeup:

62A through C

and 63A through C ~

These fire zones are the respective charging pump areas for each unit.

As described above'he charging systems of the two units will be connected by a four"inch line between the centrifuga l pump discharge headers-',

Thus'n the event of, a.'ire causing 1

4

.'.~.=., Loss,'"of,. one;.'unit,',

s', charging, pumpsii one; pump~ fro, t unaf fected'nit wit L supply the reactivity control'nd-" reactor' coolant makeup functions via the crosstie.

All other shut-down functions are unaffected by a fire in these areas.

Safe shutdown will be controlled from the controL room.

Method 3 For the following fire zones of Units 1

and 2r the alternative shutdown capability utilizes the shared features of the essential.

service water (ESW) system to provide the necessary support function for safe shutdown:

29A through F.

These fire zones are the respect ive ser vice pump areas. for iF-each unit.

The ESW system which is shared by'he" two" units".

consist of four pumps utilizing two main headers.

Two operable pumps are suf ficient for heat removal Loads of two

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-15"

'tl units.

The Licensee proposed cable rerouting and installa-tion of isolation relays to assure separation of the, two units'umps-

-, Thus'n the event of, afire causing, Loss'f p -.

'f one unit 's service water pumpsr the unaffected =unit's pumps,;

will supply the cooL ing for both units.

All other shutdown'".,',':-

functions are unaffected by a fire in these areas.

Safe shutdown will be controlled from the control room.

Nethod 4." For the following fire zones of Units,. 1 and 2i the 4

"'..,".'"'"'-':,":,'-a Lternat i've"'shutdown" capability'tilizes Local'- control~: 'of-'.~'"

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1 the atmospheric dump valves to provide the decay heat removal funct ion:

15<

18<

33r 34'8r 39 and 52.

A fire in these areas could result in either Loss of the atmospheric dump valves control circuit or Loss of emergency power supply for the atmospheric dump valves.

Alternative control will be provided at local panels by pneumatic valve loading con" tr ol with backup motive power from the plant N

distribution system.

The valves could also be operated by existing manual handwheels.

ALL other shutdown functions are unaf-fected by a fire in these zones except for zones 15'8'8 and 39; For these four zone portions of the shutdown F

monitoring function could al'so be damaged by a fire.

The alternative capability for these zones is descr ibed in the following paragr aphs.

method 5 - For the following fire zones of Units 1

and 2i the aLternative, shutdown capability utilizes alternative instru-II ment panels, to pr ovide portions of the process monitoring I

.,;-.i.=;'unct i on.'o';."- 10'-,." 15'"- 18%'-'4i ~ 38~

~ 39'i-, 66r 67'. 74'5r'~120 through='..~.. '.-,~-';,.;,,

123.-

A fire in these areas could result in Loss of.'eactor 4'

T cooLant, hot and cold Leg temperature. instrumentation cables r"'h'" power'" supply for'he" instrumentation-"

-'. As described."-;

-.;;~. '-'.,'.-,'~'~4;,

above'he L icensee wiL L insta L I. inst rument panels. for each,'nit;-

which.,will'. providemonitoring..for reactor. coolant hot;,;.:,>>,,',,

and cold'Leg te'mp'eratures'nd steam'-generator pressures and -'-.--

Levels for each of the four Loops.-.

The instrumentation cir-cuits for the remote panels wiLL be separated from the present reactor 'c>>oolant temperature instrumentation circuits

\\

in accordance with the separation criteria of Appendix R.

ALL other shutdown functions are unaffected by a fire in these zones except as previously ident ified.

E.

Technical Spec ification The alternative shutdown capability of one unit relies on the t

equipment of the opposite unit.

Thereforei the technical specifications (T.S.) covering the alternative equipment for both units must be coordinated alternat ive equipment when one uni W

assure availability of t i s oper at ing.

The

Licensee's review of its

~ T-S. indicated that only for. operat-ing modes 4r 5 and 6 (shutdown modes) some equipment avaiL-.

ability is not covered by T-S-The equipment not completely.

covered by T.S., includes the charging systems the motor-driven aux i L i ary feedwater pumpsi, the component cooL ing water.

syst'm and'he essential service water system.'

tl Pt"'<

>t>>gt>>i>>'Pj >>l >>r>>>>>>~<<+'44 >>jttt<<>'$ N '.' ~Q'(4" lP'lip'>'"'t' '~ >>> "~j'1 ~>>t >> 1 t>, P '1 $ >> l><<c'>t <<'f;'l'l<<>>tt><<t>> <<')Q A~+>><<>> >>>>1>>> vP <<P@>'<<Q'gc4<<>> >tlPj', >>g+zLqlwf. The L i censee proposed the fol l owing gui de L ines for modi fying'","-'. its T.S. Whenever one unit is in operating modes 4i 5 or <<>,>5M 6 and the opposite unit i s in operat ing modes 1i 2 or 3i the unit must maintain sufficient equipment available to support its operating mode and the alternative shutdown capability 1>>, of the opposite unit. With insufficient equipment availablei the minimum capability must be restored within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or establish a daily fire inspection of the opposite unit's areas which require alternative shutdown capability and verify operability of the fire detection and suppression equipment for those areas If the minimum capability can not be restored within 30 days'he Licensee must report and outLine proposed cor rect ive actions".-.-,"-"'l "='- 'he event We have reviewed the Li censee's proposed guidelines and it is our position that the guidelines for T.S. may allow seven days to restor e the minimum capability; however; we ~ ' ~I 4<< r ecommend a fir e inspection of the opposite unit's areas once every shift-Additionallyi the pLant must restore the mini-mum capability or bring the opposite unit to cold shutdown within 30 days. T Based on our'eviews we conclude that the Licensee> has:~~;,->> -.... ~ <<~)g->>>>>> ~y!! gT <<)(~ T,~, ) T,P N. 'T-"T, <<<<yy'4>>>>e T<> u$ PIP>>>> TT'T ~ PQf4-T 2'! 0+>>>>+'>>T>>>> @T>>>>'A T Q"<<4- <<8'> > TT+! -+ =+ adequately'.ident ified the. systems needed. for post,"f ire 'safe-'.'-'.,,"';.;; ~ ! ~ T T shutdown and analyzed'ssociated circuits to assure. avail-.;:

• . ability of the post" fir e shutdown 'systems".".

AdditionaL Lyi', -"'. we conclude that the alternative shutdown methods proposed T for various fire zones of Units 1 and 2 meet the performance goals for reactivity controls reactor coolant inventory makeup'eactor heat removalr monitoring of shutdown and support T functions. Thereforei we'onclude that the design of the '-'lternative shutdown capability complies with the requirements r of Sections III.G and III.L of Appendix R. Howevers since the alternative shutdown re lies on shutdown procedures for coor-dinating the activities of two unitsr we wiL L require the L icensee. to submit the f i'na L pr ocedures for NPC-r eviewi' Addi-tionally'r we wilL require technical specifications for the'.. '.'. ~ t 'T alternative shutdown capability be submitted prior to comple-tion of the plant modif i cat i ons. Me wi L l pr ovide'eparate evaluations for both the procedures and the technical specif ication. ~ ~ T II h