ML17328A164
| ML17328A164 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 09/14/1989 |
| From: | Giitter J Office of Nuclear Reactor Regulation |
| To: | Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| References | |
| GL-81-12, GL-86-10, TAC-65161, TAC-65162, NUDOCS 8909270204 | |
| Download: ML17328A164 (9) | |
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Docket No. 50-315 and 50-316 Hr. Milton P. Alexi ch Indiana Michigan Power Company c/o American Electric Power Service Corporation 1-Riverside Plaza
- Columbus, Ohio 43216
Dear Hr. Alexich:
DISTRIBUTION UKUBIKKI NRC 5 LOCAL PDRs PD31 GRAY FILE GMOLAHAN MVIRG I LIO RINGRAM JGI ITTER OGC EJORDAN BGRIMES ACRS(10)
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION-POST-FIRE SAFE SHUTDONN METHODOLOGY, D. C.
COOK NUCLEAR PLANT (TACS NOS.
65161 AND 65162)
By letter dated February 12, 1987, American Electric Power Company (AEP) submitted a revised report on the post fire safe shutdown methodology.
Included with this information were revised exemption requests from the requirements of Section III.G of Appendix R to 10 CFR 50 and numerous fire hazards analyses which purport to justify non-fire-rated features in plant fire barriers.
Because of the nature and extent of the new information contained in this submittal, the NRC staff reviewed the safe shutdown methodology in accordance with the existing fire protection criteria in Appendix R along with the guidance issued in Generic Letter 81-12 and 86-10.
In order to complete our evaluation of this information, the staff requires clarification on several issues.
Accordingly, the staff has prepared the enclosed request for additional information which identifies a
number of issues where AEP's approach is not in conformance with the above-referenced guidelines and which the staff cannot except in the absence of sufficient additional justification.
The staff requests that a meeting be
- arranged, preferably at the Cook site, to discuss these issues in detail.
The request in this letter affects fewer than ten respondents; therefore, OMB clearance is not required under P.L.96-511.
Sincerely,
Enclosure:
As stated cc w/enclosure:
See next page
- See previous concurrence LA/PD31: DPSP
- PH/PD31: DRSP RINGRAMP JGI ITTER 9/1$ /89 9/13/89 Joseph G. Giitter, Project Manager Project Directorate III-1 Division of Reactor Projects - III, IV, V 5 Special Projects Office of Nuclear Reactor Regulation
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Docket No. 50-315 and 50-316 Mr. Milton P. Alexich Indiana Michigan Power Company c/o American Electric Power Service Corporation 1 Riverside Plaza
- Columbus, Ohio 43216
Dear Mr. Alexich:
September 14, 1989 DISTRIBUTION DOCKET FILE NRC 8 LOCAL PDRs PD31 GRAY FILE GHOLAHAN MVIRGILIO RINGRAM JGIITTER OGC EJORDAN BGRIMES ACRS(10) 0KUBICKI S UBJECT:
REQUEST FOR ADDITIONAL INFORMATION-POST-FIRE SAFE SHUTDOWN METHODOLOGY, D.
C.
COOK NUCLEAR PLANT (TACS NON. 65161 AND 65162)
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION-POST"FIRE SAFE SHUTDOWN METHODOLOGY, D. C.'OOK NUCLEAR PLANT (TACS NOS.
65161 AND 65162)
By letter dated February 12,
- 1997, Amencan Electric Power Company (AEP) submitted a revised report on the post fire safe shutdown methodology.
Included with this information were revised exemptiop~requests from the requirements of Section III.G of Appendix R to 10 CFR 50 apd numerousfire hazards analyses which purport to justify non-fire-rated features in plant fire barriers.
Because of the nature and extent of the new information contained in this submittal, the NRC staff reviewed the safe shutdown methodology in accordance with the existing fire protection criteria in Appendix R along with the guidance issued in Generic Letter 81-12 and 86-10.
In order to complete our evaluation of this information, the staff requires clarification>on several issues.
Accordingly, the staff has
-prepared the enclosed request /for additional information which identifies a
number of issues where AEP's,approach is not in conformance with the above-referenced guidelines and wP>ch the staff cannot except in the absence of sufficient additional justification.
The staff requests that a meeting be
- arranged, preferably at the Cook site, to discuss these issues in detail.
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The request in this letter affects fewer than ten respondents; therefore, OMB clearance is not requ'ired under P. L.96-511.
Sincerely,
<<4+4 gQO(sd 5<
Joseph G. Giitter, Project Manager Project Directorate III-1 Division of Reactor Projects - III, IV, V & Special Projects Office of Nuclear Reactor Regulation
Enclosure:
As stated cc w/enclosure:
S e next page LA/PD31: DRSP PM RSP JG q
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Dockets Nos.
50-315 and 50-316 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 September 14, 1989.
Mr. Milton P. Alexich Indiana Michigan Power Company c/o American Electric Power Service Corporation 1 Riverside Plaza
- Columbus, Ohio 43216
Dear Mr. Alex ich:
SUBJECT:
REtlUEST FOR ADDITIONAL INFORMATION-POST-FIRE SAFE SHUTDOWN METHODOLOGY, D.
C.
COOK NUCLEAR PLANT (TACS NOS.
65161 AND 65162)
By letter dated February 12,
- 1987, American Electric Power Company (AEP) submitted a revised report on the post fire safe shutdown methodology.
Included with this information were revised exemption requests from the requirements of Section III.G of Appendix R to 10 CFR 50 and numerous fire hazards analyses which purport to justify non-fire-rated features in plant fire barriers.
Because of the. nature and extent of the new information contained in this submittal, the NRC staff reviewed the safe shutdown methodology in accordance with the existing fire protection criteria. in Appendix R along with the guidance issued in Generic Letter 81-12 and 86-10.
In order to complete our evaluation of this information, the staff requires clarification on several issues.
Accordingly, the staff has prepared the enclosed request for additional information which identifies a
number of issues where AEP's approach is not in conformance with the above-referenced guidelines and which the staff cannot except in the absence of=
sufficient additional justification.
The staff requests that a meeting be
- arranged, preferably at the Cook site, to discuss these issues in detail.
The request in this letter affects fewer than ten respondents; therefore, OMB clearance is not required under P.L.96-511.
Sincerely,
Enclosure:
As stated oseph G. Giitter, Project Manager Project Directorate III-1 Division of Reactor Projects
- III, IV, V 8 Special Projects Office of Nuclear Reactor Regulation cc 'w/enclosure:
See next page
Nr. Milton Alexich
'Indiana Michigan Power Company Donald C.
Cook Nuc1 ear Pl ant CC:
Regional Administrator, Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen El lyn, Il1 inois 60137 Attorney General Department of Attorney General 525 West Ottawa Street Lansing, Michigan 48913 Township Supervisor Lake Township Hall Post Office Box 818 Bridgman, Michigan 49106 W.
G. Smith, Jr., Plant Manager Donald C.
Cook Nuclear Plant Post Office Box 458 Bridgman, Michigan 49106 U.S.
Nuclear Regulatory Commission Resident Inspectors Office 7700 Red Arrow Highway Stevens vi l 1 e, Michigan 49127 Gerald Charnoff, Esquire
- Shaw, Pittman, Potts and Trowbridge 2300 N Street, N.W.
Washington, DC 20037 Mayor, City of Bridgman Post Office Box 366
- Bridgman, Michigan 49106 Special Assistant to the Governor Room 1 - State Capitol Lansing, Michigan 4 90" Nuclear Facilities and Environmental Monitoring Section Office Division of Radiological Health Department of Public Health 3500 N.
Logan Street Post Office Box 30035 Lansing, Michigan 48909 Mr.
S.
Brewer American Electric Power Service Corporation 1 Riverside Plaza
- Columbus, Ohi o 43216
ENCLOSURE RE VEST FOR ADDITIONAL INFORMATION-SAFE SHUTDOWN METHODOLOGY D.
C.
COOK NUCLEAR PLANT "UNITS 1 AND 2 TACS NOS.
65161 AND'.65162 3.
4, 5.
6.
Will all fire barriers which are necessary to satisfy the criteria of Appendix A to Branch Technical Position APCSB 95-1 and Section III.G of Appendix R to 10 CFR 50 be maintained and surveilled under the provisions of the plant Technical Specifications?
The licensee states that a separation analysis of the HVAC system was not required.
The staff is concerned that a fire could result in the loss of ventilation to safe shutdown components, resulting in failure of redundant systems.
Provide the technical justification to support the conclusion that a separation analysis was not necessary.
Provide a list of any safe shutdown components, such as valve assemblies and heat exchangers, that are assumed not to be damaged by fire regardless of existing fire protection features.
The licensee's submittal has not identified any diagnostic instrumentation as being required for post-fire-safe'shutdown.
This does not appear to be.
consistent with the methodology described.
Identify such instrumentation and sum".arize how the taking of readings has been incorporated in the emergency shutdown procedures.
For a fire in a number of locations, such as area I, the licensee appears to be taking credit for manua 1 actions to achieve safe shutdown.
These actions are required to be taken in the. fire area itself.
Identify all such locations, the time to achieve this action before an unrecoverable'lant condition occurs and the justification to support the conclusion that entry into the fire area is achievable.
The licersee also appears to be taking credit for manual actions outside of the fire areas, such as those associated with mitigating the conseouences of spurious, fire-induced signals.
The staff is concerned that a sufficient safety margin of time may not be available between-the occurrence of a fire and an unrecoverable plant condition that is prevented by the manual action.
Identify all such manual actions that must occur within the first half hour of a fire event.
7.
The licensee has not clearly described how common enclosure type associated circuits have been protected against fire damage.
The licensee appears to
,indicate that non-fire propagating type cable insulation will preclude damage.
This is not consistent with the guidance issued in Generic Letter 81-12.
For these types of associated circuit indicate how the guidance in the generic letter has been satisfied.
The licensee's assumptions regarding the low probability of three phase and single phase
- a.c. faults (cases 1 and 4 of the 1987 submittal) are not consistent with the guidance issued in Generic Letter 86-10.
Three phase
- a.c. cable-to-cable faults need be considered credible for hi-low pressure interfaces only.
Describe how spurious signals resulting from such faults will be mitigated to assure the post-fire viability of the safe shutdown capability.
The licensee states that the RHR system is required for hot shutdown and that repairs will be implemented following a fire. 'his is not consistent with the criteria delineated in Section III.L of Appendix R.
The licensee should clarify the need for any repairs associated with'chieving hot shutdown conditions following a fire.
Provide a description as to how the hot shutdown panel area is electrically independent from the control room.
The staff is concerned that a fire in this area will adversely affect the shutdown capability from the control room.
What precautions have been taken to preclude water from fire fighting activities from flowing down through the hatchways and damaging redundant safe shutdown systems below?
Are all proposed fire protection modifications being implemented in accordance with the applicable NFPA standards (detection and suppression system) and manufacturers installation practices (cable wraps)?
What testing, if any, has been performed on the field fabricated fire damper referenced in Section 9.7?
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