ML18047A278

Forwards Request for Addl Info Re Design Description of Mods Needed to Satisfy Section III.G.3 of App R to 10CFR50. Rewording of Generic Ltr 81-12 Request for Info Encl.Safety Evaluation Re Safe Shutdown Mods Deficiency Also Encl

ML18047A278
Person / Time
Site:	Palisades
Issue date:	04/07/1982
From:	Lainas G Office of Nuclear Reactor Regulation
To:	Vandewalle D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
References
GL-81-12, LS5-82-4-20, LSO5-82-04-020, LSO5-82-4-20, NUDOCS 8204160274
Download: ML18047A278 (48)

Text

-*'I Docket No. 50-255 LSOS-82-04-020 Mr. David VandeWalle Nuclear Licensing Administrator Consumers Power Company 1945 West Parnall Road Jackson, Michigan 49201

Dear Mr. VandeWalle:

Apri 1 7, 1 982

SUBJECT:

FIRE PROTECTION RULE - 10 CFR 50.48(c)(5) - ALTERNATIVE SAFE SHUTDOWN - SECTION III.G.3 OF APPENDIX R TO 10 CFR 50 Palisades Plant The Fire Protection Rule (10 CFR 50.48 and Appendix R to 10 CFR 50) became effective on*Febrtiary 17, 1981.

Paragraph 50.48(c)(5} required submittal of design 'descriptions of modifications needed to satisfy Section III.G.3 of Appendix R to 10 CFR 50 by March 19, 1981. *

/

By letter dated March 19 and May 19, 1981 and February 16, 1982, you submitted the design description of modifications required to meet Section III.G.3 of Appendix R to 10 CFR 50 for Palisades Plant.

We have reviewed your submittal and find that additional information is required for us to complete our review.

The information required was originally _requested from you by letter dated February 20, 1981.

Enclosure l to this letter indicates \\*1hat information you have not supplied.

Provide a complete response to items indicated in the enclosure within 60 days of receipt of this letter. If your response is not complete at that time, you will be found in violation of 10 CFR 50.48(c)(5).

Such_ a violation will be a continuing one and a civil penalty may be imposed for each day the violation continues. provides a rewording of the request for information included with generic letter 81-12. This rewording is the result of meetings with representative licensees who felt that clarification of the request would help expedite responses. It does not include any new requests and, therP.fore, will not adversely affect licensees' ability to. respond to generic letter 81-12. provides information regarding our criteria for evaluating exemption requests from the requirements of Section III.G.2 of Appendix R *

. OFFICE.....,;;:................... 1........................ 1........................

SURNAME.,-S204160274 820407 PDR ADOCK 05000255 DATE.

F PDR NRC FORM 316 {10-60) NRCM 0240 OFFICIAL RECORD COPY USGPO: 1981-335-960

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• .~:.~

Mr.'David Vandewalle April 7, 1 982 is our draft safety evaluation report that states our position with regard to features of your proposed alternative, safe shutdown modifications that we find deficient (Section IV.l'.:of Enclosure 4). Please provide your responses to these items within 60 days of receipt of this letter. If you have any questions regarding this matter, contact your NRC project manager.

The reporting and/or recordkeeping requirements contained in this letter are specific to the Palisades Plant and affect no other license; therefore OMB clearance is not required under P.L.96-511.

Enclosures:

As stated cc w/enclosures:

See next page DISTRIBUTION Docket NRC PDR Local PDR ORB Reading NSIC DCrutchfield HSmith TWambach OELD OI&E ACRS (10)

SEPB BFerguson VBeneroya Sincerely, Original signed by T. A. Ippolito for/

Gus C. Lainas, Assistant Director for Safety Assessment Division of Licensing I

DL.:: ORB #5 OFFICE.........................

TWambach:cc SURNAME).......................

'-( /of,/82 DATE........................

NRG FORM 318 (10-80) NRCM 0240 OFFICIAL RECORD COPY USGPO: 1981-335-960

• .J

. Mr*. Dav~d J. VandeW~lle cc M. I. Miller, *Esquire Isham, Lincoln & Beale Sutte 4200

• One First National.Plaza Chicago, Illinois. 60670 e**.

• Mr. Paul A. Perry, Secretary

• Consumers Power Company 212 West Michigan Avenue Jackson,_ Michigan 49201

_ Judd L. Bacon, Es qui re Consumers Power Company 212 West Michigan Avenue Jackson, Mi _chi gan 49201

• CHERRY & FLYNN Suite 3700 Three First National Plaza thicago, Illinois 60602 Ms. Mary P. Sinclair Great Lakes Energy Al 1 i ance 5711 Summerset Drive Midland, 'Michigan 48640 William J. Sca~lon, Esquire 2034.Pauline Boulevard Ann Arbor, Michigan 48103 Township Supervisor Covert Townshi Route 1, Box 10 Van Buren County, Michigan 49043 Office of the Gov.ernor (2)*

Room 1 - C_apitol Building Lansing, Michigan 48913 Palisades Plant-

.ATTN:

Mr. Robert Montross Plant Manager Covert, Michigan 49043 :.*

April 7-, 1982 U. S. Environmental Protection Agency Federal Activities Branch.

Region V Office ATTN:

Regional Radiation-Repr~sentative 230 South Dearborn Street Chicago, !llinois 6_0604 -

Charles BecHhoefer, Esq., Chairman Atomic Safety and Licensing Board Panel

u. s. Nuclear Re9ulatory Commission Washington, D. c. 20555 Dr. George c. Anderson *.

Department of Oceanogra~hy University of Washington Seattle, W~shington 98J95 Dr. *M. Stanley Livingston 1005 Calle Largo Santa Fe, New Mexico* 87501 Resident Inspector c/o U. S. NRC Palisades Plant Route 2, P. o. Box 155 Covert, Michigan 49043 James G. Keppler, Regional Administrator Nuclear Regulatory Commission, Region.III*

799 Roosevelt Road Glen Ellyn, Illinois 60137

J ENCLOSURE-l Information Required Provide the following lists of associated circuits:

l. Related to systems used for cold shutdown *in the event of a fire in the following fire areas_:

control room, cable spreading room, engineered safeguards panel room, and the corridor between the charging pump room and switchgear room. 1-c;

• 2. Related to systems used for hot and cold shutdown in the event of a fire in the auxiliary shutdown control panel *area; and

3. A description of the isolation devices and the circuits in which they are used for associated circuits identified in l and 2 above.

1:.NCLUSUKt: l e

CLARIFICATION OF GENERIC.LETTER on* February 20, 1981, generic letter 81-12.was forwarded to all reactor licensees with p.lants licensed prior to January 1, 1979*. The letter restated the require-ment of Section 50.48.to 10 CFR Part 50 that each licensee would be required to reassess areas of the plant where cables or equipment including associated non-safety-circuits of_ redundant trains of systems necess_ary to achieve and n'\\Clintain hot shutdown conditions are lofated to deterrifine whether the require-inents of Section III.G.2 of Appendix~ to 10 CFR 50 were satisfied. Additionally,

• Enclosure l and Enclosure 2* of the generic letter requested additional

".infonnation concerning those areas of the plant requiring alternative shutdown c~pabili_ty *. *section 8 of Enclosure l requested infonnation for the systems,.

equipment and procedures of alternative shutdown *capability and Enclosure.2 defined associatep circuits and requested information concerning associated circuits for those areas requiring alternative shutdown.

. ln oµr r.eview of licensee submittals and meetings with licensees, it has become apparent that the request for information should be clarified since.a lack"'

of clarity could result in the*submission of either insufficient or excessive

• 4

_infonnation. Thus, the staf{ has rewritten Section 8 of Enclosure 1 *and

• Enclosure 2 of the February 20, 1981 generic letter. Additionally, further l

t clarification.of* the definition o~ associated circuits has been provided to*

aid in the reassessments to determine compliance with the requirements of Sections 111.G.2 and 111.G.3 of Appendix R.

In developing thi s=rewrite we have

~-:~:=-.

considered the-cement of the Nuclear Utility Fi re Protection Group.

The a.ttach-ed rewrite of the Enclosures contains no new requirements but merely attempts to clarify the request for additional_ information.

• ~.**

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... Licensees who have not responded to the February 20, 1981 generic letter,

~Y choose to respond. to the enclosed request far information. Since the enclosed request.for information is not new, but merely clarification of our previous letter, responding to it should not delay any submittal>. in progress that are *,based upon February 20, 1981 l et~er..Licensees whose respons*e to the February 20,. l 981 lett~r, has been found !'-incomplete resulting in staff identifications of a major unresolved item (i1e., associated circu.its),

may *choos*e to respond to pertinent sections of the enclosed request for infer-

• mation in order to *close open' items (i.e., open item for.assodated circuits, use rew_rite of Enclosure 2).

-tf additional c_la<f"ification is needed,_ please contact the staff Project

- Manager for your plant.

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'TACHMENT 1..

REWRITE OF SECTION 8 REQUEST FOR ADDITIONAL INFORMATION The following is a rewrite of the staff's request for additional information concerning design modification to meet the requirenents of Section III.G.3 of Appendix R.

Thc*following contains no new req~ests but is merely a r~wording of Section a* of Enclosure l of the February 20,.1981 generic letter.

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Ide.ntify those areas of the plant that will not meet.the requirenients of Section III.G.2 of l'.ppendix Rand*; thus alternative shutdown will be provid~',

or an exemption fro"m the requirements of Section III.G.2"of Appendix R will" be provided. Additionally.provide a statement that all o~her areas of the plant.

are or will be in compliance wi~h Sec_tion III.G.2 of Appendix R *

. For. each of thos~ fire areas o"! the pl ant requiriJ19 an alternative shutdown systen(s) pro'-lide a complete set of responses to the following requests for each fire area:

a. List the system(s) or portions thereof used to provi.de the shutdown capability with the loss of offsite power *

. b.

For those systems identified in "la" for which alternative or.dedicated shutdown capability must be provided, list the equipment and components of 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 equi"pment, control of_ what components and instrumentation) *. Describe the system(s) or portions thereof used to provide the alternative shutdown capabi.Jjty for the fire area and provide a table that lists the _equipment and components of the alternative shutdown system for the fire area.

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For each alternatjve system identify the function of the new circu.its being provided.

Identify the location (fire zone) of the alternative shutdown equipment and/or. circuit~ that bypass the fire area and verify that the alternative shutdown equipment and/or circuits are separated from the fire area in accordance with Section lII.G.2.

c.

Provide drawings of the alternative shutdown sy~tem(s) whic;h highlight any

• con._necti~ns to th_e norrr.al s.hutgow~ systems _lP&IDs for piping ana compo~em:s, elementary wiring diagrams of electrical cabling) *.

~how*the electrical I

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location of all break.ers *for power cables, and.isolation devices for

. ~ont~ol and. instrumentation circuits for the alternative shutdown systems for. that fire area.

d. Verify that changes *to. safety systems wil 1 not degrade safety systems;:

(e.g., ~ew isolation switches and control switche~ should meet de~ign.

criteria and standards in the FSAR for electrical* equipment. in the system that the switch iS to be i*nstalled; cabinets that the switches are to be mounted in should also meet the same criteria (FSAR) as. other safety related cabinets and panels; to avoid inadvertent isolation from the control room,_ the isolatio*n switches should be keyloc_ked or alanned

~M the control ~oom if in the "local" or "isolate~" position; period~~

checks should be ma.de to_ verify that the switch is in the proper positi.on for nonnal operation; and a *single transfer switch or other new device should

. not be a source of a failure which causes *1oss ot" reaunaarrt scif~t.r ~b~

sys terns).

• e.:-

Verify that 1 i censee procedures have been or will.,be developed which describe the ta*sks to be perfonned to effect *the shutdown_ method.

Provide a summary of these procedures outlinin~ operator* actions.

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• Provide a commitment to perform adequate acceptanc;~: ~es ts ~f _th~.~ lJe.r-.

native shutdown capability. These tests should verify that: equipment operates from the local control station when the transfer or isolation

• I switch is placed i.n the "local" position and that the 'equipment -e-annot be operated from the control room; and that equipment operates from' the control room but cannot be operated at the loca.l control station ~hen 1

the transfer isolation switch is in the 11remqte 11

• positjon~. *~. *~ -

h. Provide Technical Specifications of the surveillance requirements and limiting conditions for operation for that equipment not already

~overed by existing Technical Specifications. For example. if new isolation and control switches are added to a shutdown system, the existing Technical* Specificatio_n surveillance requirements should

.be supplemented to verify system/equipment functions from the alternate shutdown station at.testing intervals consistent with the*guidelines of

• Reyulatory Guide 1.22 and IEEE 338.

Credit may be taken for other exi°sting

• tests *using g-roup overlap test concepts.

. e.

.... f.

For new equipment comprising the alternative shutdown capability, verify that the systems available are adequate to perform the necessary shut-down function.

The functions required should be based on previous analyses. if possible (.e.g ** in the FSAR). -such as a loss *of nonnai.-a*c power or shutdown on Group l isol~tion (BWR). -The equipment required

• for the alternative capability should be the same or equival er:it _t~ ~hat relied on in the above analysis.

j, 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 for repairs~~-~--**::*-<*-=*- __

Attachmen.t 2

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~--*-e SAFE SHUT.DQl.JN CAPABILITY

• The followi~g discusses the requirements for.protecting re9undant and/or

• alternative equipment *nee.ded for safe shutdown in the event of a_fire. The requirements of Appendix R address hot shutdown equipment which must be free of fire* damage.

The follOW.i.:ng..r~qµirements also apply to cold. s.hutdown

~quii:mient *tt ttu;.. ltcensee elects to -~~onstrpte that _th_e.equip!1Jen~. is *to_b~

free of. fire.daff!age.

App.endiX R does allow.repairabie damage *to coid shutdown

~

eQufoment.

• - -. *-:-- o*

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 an~ area of the pl ant* in conjunction wi.th a. loss* of offs i te power for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

Section III. G of. Appendix R.provides four methods for ensuring th?-t the hot shutdown capa-

. - bility is protected from fires. The first three options as defined in Section I I I. G. 2 pro vi des methods ~or protection* from ftres of equipment need~d for hot shutdown:

• l.

• Redundant systems including cables, equipm_ent, and associated Circuits may be separated by a three-hour fire rated barrier; or,

.2.

Redundant systems.tncludt_n*g caoles, equipment and.associated circuits may be.separated by a horizontal distance of more than 20.feet. with no inter-vening combustibles.

In addition, fire detection and an automatic fire suppression system are required; or9 3*.

Redundant systems 'including cables, equipment and associated circuits may by enclosed by a one-hour fire rated barrier.

In addition, fire detectors and an automatic fire suppression system are requjred.

. \\

- 2 The last option as defined by Section III.G.3 provides an alternative shutdown capability to the redundant trains damaged by a fire.

4. Alternative shutdown equipment must be independent of the cables, equip-ment and associated circuits of the redundant systems damaged.by the fire.

Associated Circuits of Concern The following discussion provides A).. a defi.nition of associated. circuits for*

I Appendi".' R consideration, B) the guidelines for protecting the *safe' shutdown.

. capability from the fire-induced failures of associated circuits and C} the in-formation. required by the staff to. review associated circuits. "The definition of associated circuits has. not changed from the February *20, 1981 generic--letter;*..

-*bu~ is merely.cl~rified. It is important to note that our. intere$t is only with those circuit (cables) whose fire-induced failure could effect shutdown~

• The guidelines for protecting the safe shutdown capability from the fire-induced fa.ilures of associated ctrcuits are not requirements *. These guidelines should be used *bnly as guidanc~ ~hen needed. These guidelines do noi limit the alter-.

natives available to the licensee for protecting the shutdown capability..

Al 1 proposed. methods for protection of the shutdown capability from fire-induced failures will be evaluated by the* staff for acceptability...

A.

Our con-cern is that circuits with.in the fire area _wj}l_ receive fire da.mage which can affect shutdown capability and thereby prevent post-fire safe -

shutdown. Associated Circuits* of Concern are defined as those cables (safety related, non-safety related,Cla~s lE, and non-Class lE) that:

• The *definition for associated circuits is not exac.tly the same as the definition pres~nted in IEEE-384-1977.

9*..

........ l. Have*a physical separation less than that required by Section 111.G.2 of Appendix R,.and; 2~ Have one of the f_ol lowing::

a. a common power source with the shutdown *equipment (redundant or a-lternative).and the power source is not electrjcally protected from the circuit of concerp b~ coordinated breakers, fuses, or similar devices (see diagram,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 dump val~es, instrument~tion, steam byp~ss, etc.) (see ~iagram 2b), or I

c. a corrrnon enclosure (e.g., raceway, panel, junction) with the* shutdown cables (redundant and alternative) and, (1) are not electricalJy protected by circuit breakers, fuses or simi-lar devices, or

( 2) wi 11 a 11 ow propaga.ti on of the fire into the common

.enclosure, (se.e diagram *2c}.

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BUS Diagram 2A

• EXAMPLES OF ASSOCIATED CIRCUITS OF CONCERN I

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I VAL.\\IE 1 Pu.tti P Er";'f"' e;r;i: wJiose sf ~C'S "f "'o;tkm co&Mol af fecil sfwkl "&IJ71 Diagram 2B I

.1 I

I i.

1.

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L_. - -

-I -~

I I l.:

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• ca,,1101.1 ENCLOS *..

The area barriers shown above meet tha appropriate sub-paragraphs (a-f) of section III.G-2 of Appendix R.

l

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Diagram 2C

- 4 B.

The following guidelines are for protecting the shutdown capability from fire-induced failures of circuits (cables) in the fire area.

The guidance p~ovided *below for interrupting devices applies only to new devices installed to provide electrital isolation of associated circuits of concern~ or as *

.part of the alternative or dedicated shutdown sys~em. The srutdown capability may.be protected from the adverse effect of damag~ to associat~d circuits

~

of concern by the following methods:

1. Provide protection;~etween* the associ~ted circuits of concern and the shutdown circuits as per Section III.G.2 of Appendix R, or

2. a. For a conmen power source case of associated. circuit:.

Prqvi'de 1 oad fuse/breaker ( i nt~rrupti ng devices) to *feeder

. fuse/breaker coordination to prevent loss of the redundant or alternative shutdown power* source. To ensure that the following coordination criteria are met the.for1owing should apply:

(1) The associated circuit of concern interrupting devices (breakers dr.fuses) time'."'overcurrent trip characteristic for all circuits faults should cause the interrupting device to interrupt the fault current prior to initiation of a trip of any upstream interrupting device which will cause a loss of the common power source, J?) The power source shall supply the necessary fault current for sufficient tim~ to ensure the proper coordination without loss of function of the shutdown loads.

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The acceptability of a particular interrupting.device is considered demonstrated if the following criteria are met:

(i) The interrupting device design shall be factory tested to verify overcurrent protection as designed in acc9rdance with th*e applicable UL, ANSI. or NEMA standards.

(ii) For low and medium voltage switchg*ea-r *c4ao* v *and-.c1:b-ovel-circuit breaker/protective* relay periodic' testfng*,*shall-demonstrate that the overall coordination scheme remains within*the limits specified in the design cri~eria~ This testing may be performed as a series of overlapping tests.

(iii)' Molded case circuit-breakers shall p~ridi*cally be rnam,.all.Y exercised and inspected to insure ease of operation.

On

. a rotating refueling outage basis a sample of these breakers shall ~e tested to d~termine that breaker drift is within that allowed by the design criteria.* Breake~should_be tested i.n accordance with an accepted QC testing methodology such as MIL STD 10. !:i D. *

(iv)* Fuses when us~d as interrupting device~ do not require periodic testing, due to th_eir stability, lack_of drift,.

and high reliability. Administrative controls must insure that.replacement fuses with ratings other than.those selected for proper coordinating ar~ not accidentally° L1Sed.

b.

For circuits of equipmer:it and/or components whose spurious operation would affect ~he capab1lity to safely shutdown:

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(1) provide a means to isolate the equipment and/or components from the fire area prior to the fire (i.e., remove power cables, open circuit breakers); or (2) provide electrical isolation that*prevents spurious operation.

Po!ential isolation devices include.breakers, fuses, ampli-fiers, control switsbes; current XFRS, fiber optic c0uplers, relays and tran~du~ers; or

• (3) provide a means to 'detect spur.ious operations a~*d then proce-dures to defeat the maloperation of equipment {i.e., closure of t~e block valve if PORV $purioµsly_ operat~s *. qpening -of the ~reakers to remove spurious operation of.safety injection);

c. For col'l1Tlon enclosure cases of associated circuits:

{l) provide appropriate measures to prevent propagation of tne

• fire; and C.

• We recognize that there are d~ fferent approaches which may be used to*

reach the same objective of determining the interaction of a?sociated circuits with shutdown systems.

One approach is to start with the fire area, id~Qtify what is in the fire area, and' determine the interaction between what is in the fire area and the shutdown systems which are out~ide t~e fire area.

We have entitled this approach, "Th~ Fire Area Approach~" A second approach-which we*have nameq '.'Th_e Systems Approach" would be *to define the shutdown systems-around.a fire area and then.determine

....e

- 7 those circuits that are located in the fire area that are associated with the shutdown system.

We have prepare~ two s-ets of requests fpr information, one for each approach. The licensee may choose to respond to either set of requests dep~nding on the approach selected by the licensee.

FIRE AREA APPROACH

l. *For eac}1 fire area where an aliernative or dedica~eq sh~tdqw11 metho9_,

in ac~ordance with Section III.G.3 of Appendix R is pr9vided, the follow~ng infonnatibn is required to dempnstrate that ~ssociated circuits will not pre.verit operation or cause maloperati~n of the alternative or dedi ca.ted stiut~own method:

a. provide a table that lists all the pow~r cable~ in the fife area that connect to the same power supply of the.alternative or dedicated shutdown method and the function of*each power cable

' listed, (i.e., power for RHR pump).

b. Provide a table that lists all the cables in the fire area that were considered for.possible spurious operation which would adversely affect shutdown ~nd the function of each cable li~ted.

c.. Provide a table that lists all the cables in the fire area that share a common e*nclosµre with circuits of the alternative or

• dedicated shutdown systems and the function of each cable li~ted.

d.

Show that fire-induced failures (hot shorts, open circuits* or shorts to ground) of each of the cables listed in ~~ *b, and c will not prevent operation ~r cause maloperation of the alternative o~.dedi~ated.~hutdown meth6d.

- - -**-* - -------~-~--------------------=----~

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....... e. For each cable listed in a, b and c where new electrical isolation has.

been provided or modification to existir.g el~ctrical isolation has been made, provide detailed electrical s~hematic drawin~s that

• show how each cable is isolated from the fire area.

SYSTEMS APPROACH

1. For each area where an altercative or dedicated shutdown method, in accordance with Section III.* G.3 of Appendix R is provided, the following infonna~ion is required to demonstrate that ass.ociated circui*ts wil 1 not prevent operation or c~use maloperation of. the alternative or dedicated shutdown method:

a.

• Oe~cribe the methodology used to assess the potential of associate~

circuit adversly affecting the alternative or dedicated shutdown.

The description of the methodology should include the methods

~~ed ~Q identify the ~ircuits whicti ~~~re a corm}on ~wT*r ~up~ly

• or a conmen enclosure with the alternative or dedicated*shutdown system and the circuits whose spurious operation.would affect shutdown. Additionally, the description should include the

. methods* used to identify if these circuits are.associated circuits of concern due to their location in the fire area,

b. Provide a table that lists all associated circuits of concern lmcated in the fire area.

c. Show that fire-induced failures (hot short$, operi circuit~ 9r shorts to ground) of each of the cables listed in b will hot prevent operation or cause ma1operation of the *alternative or dedicated shutdown method.*

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d.. For each cable listed in b where new electrical isolation has been provided, provide detailed electrical schematic drawings that show how each cable. is isolated from the fire area.

e. Provide a location at the site or othe~ offic~s where al1 the tables and drawings generated by this methodolo:gy approaC:Ji for the associated circuits review may ~e ~u~ite~ ~Q verify.the information provided above.

HIGH-LOW PRESSURE INTERFACE For e~ther app:~ach chosen th~ fpllowing ~9nirer~ c;ie~lin~ with ~igh-lqw.

pressure interface should be addressed.**

2.

The res.idual heat remova*l system is generally a low pressure system that interfaces with the high pressure primary coolant system.

To preclude a LOCA through this interface, ~e requ~re compliance with the recommendations of Branch Techni ca 1 Pas i t1 on. RSB 5-1

• Thus, the*

interface ~ost likely consists of two redundant and independent motor operat~d valves.** These*.two motor operated valves and th~ir associ6ted cables may be*subject to _a single fare hazard. It is our concern that this single fire coul~ cause the two valves to open resultirg in a *fire initiated LOCA through.the high-low pressur~ system interface. To assure that this interface ~nd oth~r hi~p-lo~

pressure interfaces are adequatelx protected from the.effects of a single fire, we require the following information:

a.

I~entify each hi gh-1 ow pressure interface that uses. redundant electrically controlled ~evices' (such as two seri.es motor operated val.ves) to isolate or prec1ude*r~pture of any primary coolant boundary.

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- 10 b.. For each set 0f redundant va 1 ves

• fdentifi ed in a., verify the-r.edundant cabling (pow~r and control) have adequate physical separation as required by Section III.G.2 of Appendix R.

c. For e~ch case where adequ~te s~paration is ~c~ provide~, sho~ th~t

• fire induced failures (hot short; open ~ircuits or s~ort to ground)

- of 'the*cables will not cause maloperation*and result in a LOCA.

• • '?

.IA FOR EVALUATING ENCLOSURE 3_.

{'

EXEMPTIONS TO SECTION III G OF APPENDIX R OF 10 CFR PART 50 Paragr~ph 50~48 Fire Protection of 10 CFR Part 50 requires that all nuc1 ear power pl ants licensed prior to January l, l 979 satisfy the requirements of Section 111.G of Appendix R to.10 CFR Part 50.

lt ?1so r~quir~s ~hat alternative fire protection configurations, previous1y approved.bY an SER be*reexamined for ccxnpliance with

. the requirements of Section 111.G. Section 111.G is related to fire protection features for ensuring that syst~ms and associated circuits used to a~hieve and maintain safe.shutdown.are free of fire damag~.

Fi re prbt~ction configurations must eith~.r meet the speci fie require*

• ments Qf ~ection I 11.G or an al t~rnative fire prot~c;tion c9nftguration

• mu~t be justified by a fire hazard analysis.

I r

The.general criteria for accepting a'n alternative fire pro.~ect.ion.~oofigur-

~tionf. are the ~ol lowing:.

. The* a1 ternative assures that one train of equipment necessar.y to

• achieve hot shutdown from either the control room or emergency contro1 stations is free of fire dai:nage.

Tne *~lternative a~sures that fire' dar1age to*at-1eas11*~ne tr~in of

~qui pment netessary to ~chi eve cold shutdown *is l imi teq sµch that

• it can be repaired within a reasonable time (minor repairs.with

• components stared on-site).

Fire.retardant coatin~s are not* used as fire barriers

• Modifications required to meet Section 111.G would.nQt enhanc~

fi~e protect;on safety above that prqvided by eit~er existing or proposed alterna~ives~

Modifications r.equir,ed to. meet Section 111.G would be detrimenta1 to overall faci1 i ty s~fety.

I Because of the broad spectrum of potential configurations for which

- exemptions may be, requested, speci fie :ri teri a th~t acc.oun~ f~r ~11 O!.

. the parameters that are important to f1 re pr~te~ti~n and cons1 stent yn th safet~ requirements of all plant-unique co~f19~rat1ons have not be~n developed.

H'owever, our e~aluations of dev1at1oris from these requ~re-*

ment~ in our ~revious-review~_and in the req~ests fo: III.~ exempti~n~

~eceived to date have identified some recurr1ng configurations for which speci fie criteria have been deve1 op'ed.

t'

....... e**.. Section.III.G.2 accepts three methods of fire protection. A passive 3-hotir fire barrier should be used where possible.* Where a fi~ed barrier cannot be installed, an automatic suppression system in combination with a fire barrier or a separation distance free of combustibles is used if the configurations of systems to be protected and in-situ combustibles are such that there is.reasonable assurance that the protected systems will survive. If thi~ latter condition is not met, alternative shutdown capa-bi.lity is required and a fixed suppression sy~tein install~d 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 adequate-protection ror those configurations in which they are aecepted.

When the fire protection features of each fire area are evaiuated, the whole system of such features must be kept in perspective *.. The defense-ih-depth principle of fire protection prog~ams is aimed at a~hi~vin~ an adequate balance betwe~n the d.i fferent features.

Strengthe11in~ any one can compensate in*some measure for weaknesses, known pr unknown in others.

Th~ adequacy of fire protection for any particular p_lant safety sys1:em--~r

. qrea is detennined by analysis of the effects of-postulated fjre r~la'\\:ive to maint~ini~g,the ability to safely ~hutdown the plant and.minimize radio-active relea~es to the environment in the event of a fire. During these evaluations i.t is necessary to consider the two.. edged nature of fire pr9tection features recognized in General Design Criterion 3 namely, fire protection should -be prowi ded consistent with other saf~ty cQns i c!~ration~.

Ap evaluation must b~ made.for.each fire ar~a for which an exemption is requested.

During these evaluations, the 'staff considers the following parameters:. * *

~-. Area Description

~alls, floor, and c~iling construction ceiling. hei gh-t room volume

. ventilation congestion_

• B.* Safe* Shutdown Capability numper pf redundant systems in_area

\\'1hether or not system or equ_iment is -required for hot shutdown type of equipment/cables involved repair time for cold sh~tdown equipmnt within this area separation between redundant c_omponents ~nq in-situ *

- concentration of combµstibles

~ alternative shutdown capabi~ity

.*.9

- 3 C. *Fire Hazard Analysis type and configuration of combustibles in area quantity of combustibles ease of ignition and propagation heat rel ease rate potential transient and installed combustibles suppression damage to equipment whether the area is continuously manned

~.traffic ~hrough the area accessibility of the area"

0. Ffre Protection Existing* or Committed

- *fire de~ection systems

-. fire extinguishing systems

• .. -... ho~e station/extinguisher radiant hea~

• shi ~1 ds A specific description of the fire-protection features of the configuration

• i~ required to justify the compensating feat~res of the ?lternative. Low fir~ lpading is not a sufficient basis for granting an exemption in areas

• where there are cables.

If necessary, a team of. experts, including a fire protec~iop engineer,

• will visit.the site to determine the existing circumstanc~s. This ~1isual.

inspection is also considered in the review process.

I Th~ ~~jority of the III.~ exernption requests received to date ar13 being denied because they lack specificity. Licensees have not identified the extent of the exemption re.quested, have not provided a tectin i cal basis

.For the request and/or have not provided.a speGific description of the alternµtive.

We expect to receive requests f9r exemption of the following

. nature:

l*~

Fiied fire barriers les~ than 3-hbur rating.

2.

Fi re barrier without an automatic fire suppression system.

3. * *L~ss than 20 feet separation of cab1es with fire propagation retardants (e.g_., coatings, blankets, covered trays) and an auto111at.i.c suppression system.

4.

For *large open areas with few components to. be protected and few in-situ combustibles, no automatic suppression system with separation as* in Item

~ above.

5.

No fixe9 suppres~;ion in the-contr'o1 room.

I

\\.

I i

9*..

........ 6 *. No fixed suppression in areas without a large concen~tation of ~ables for

. -which alternative shutdown capability has been provid~.

Our fire research test program is conducting tests to provide information that will be usef_ul to determine the boundary of acceptable cond.itions for fire protection configurations which *do not include a fire rated barrier.

Based.on d~viations recently approved, specific criteria for certain recurring configurations are as follows:

Fire* Barrier Less than Three Hours This barrier is a wall, floor, ceiling or an ~ncfosure which separates one fire area from anoth*er*.

Exemptions *may be* granted for a lower rating (~.g., one hour or two hours) where the fire loading is no*more than 1/2 of the barrier ra~ing. *The fire rating of t~e barrier shall-be no less t~an one hour~

Exemptions may be granted for a fixed barrier wit~ a 1ower fix rating supplemented'by a water curtain.

An Automatic Suppression System With Either One Hour Fire Barrier or 2o.LF.oot Separation

.1 *.

Th.is barrier i$ an enclosure which separates those p(;>riions i;>f one divi~ion

..

• which are within 20 feet of the red1,mdant di vision. The suppressan_~ may_

be water or gas.

Exemptions may be granted for. configurations of redundant ~ys~ems which

• hav*e compensating features *. For example:

A *. Separation distanc~s less *than 20 feet may be deemeq acceptabl~ where_:

• l... Fir~ propagation retardants (i.e., cable c;oat~ngs, covered trays, conduits, or mineral wool blankets) assure that fire propagation through in-situ.combustibles will not occur or will be delayed suffici~ntly to' ensur~ adequate time for detection ~nq*suppression.

2.

Di~tance above ~floor level exposure fire and below ceiling assures that redundant systems will not be simultaneously subject to an unaJ;ceptable temperature or heat flux.

~* The ommission of an automatic suppression system mQy be deemed acceptable where:

l. Distance above a fl oar 1 evel.exposure fire and ~el ow ceil; ng assures that redundant systems* wil 1. not be simultaneously subject to an unacc~p~able temperature or hea~ flux.

0

e..2.

Th~ fire area is required to be manned continuously by the provisions in the Technical Specifications.

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--*~.. *~-*.-*.. --** -:*~*~***- - ~---~ *-*** --* -*- -*---

-. ***-*----ENCLOSURE. 4 - - -..

PALI SADES PLAiff DRAFT SAFETY EVALUATION REPORT REVIEW IN.ACCORDANCE WITH APPENDIX R, SECTIONS III.G AND III.l (SEP TOPIC IX-6)

I.

Introduction The staff has pr~viously prepared a Fire Protection Safety Evaluation Report (FPSER) dated Septenber l, 1978 (Enclosure 2 of Reference l). This FPSER identified several concerns which are still open an.d remain valid in the context of the present review which is being performed to the requirements of.10 CFR 50.48 and Appendix R.,

The FPSER enumerated four areas for which.alternative safe shutdown capabilitj is required, as follows:

T.

Control Room

2.

Cable S[ilreadi ng Room

3.

Engine~red Safeguards Panel Room

4.

Corridor Between Charging Pump and Switchgear Room 1-C.

Further, regarding problems in switchgear rooms associated with.safe. shutdown,

~the FPSER"noted that 11 ---a fire in Room lC may cause loss of redundant safe shutdown equipment.

11 This lass.would result from damage to ca bl es associated with both dies~l ge~erat6rs, all service water pumps and all component

\\

~oolin~ water pumps.

In order to resolve the problem of a *fire in switchgear room lC the FPSER recommended that the licensee reroute cab1es passing through that *room.

e *--------**---

-~----* ------*:-----:------------* The licensee responded to the staff's concerns in a series of letters (References 2-4).

In these, CPC did not propose any new system dedi-cated for safe shutdown in the event of *a fire.

Instead, CPC proposes*

to make the following additions and modifications to address the issues which were raised in th~ FPSER:

A.

Install an auxiliary shutdown control _panel.in the southwest electrical penetration roo~. The panel will be used to control auxiliary *feedwater (AFW)i system valves and the AFW steam turbine driven pump.

The panel will also be used to display indications of AFW system flow rate to both steam generators, the water level

. in both steam generators~ pressurizer. 1 evel, ~rnd prirn?rY ~ysterri pressure.

Thi.s wi,11 provide the ability to bri_n*g the plant.to hot' shutdown in the event of a fire in any one of the four areas noted above, i.e., (a) control room, (b) cable spreading room, (3).er1gine~rcc safegu~rds panel room, and (4) corridor between charging pump and switchgear room lC.

'B.

Reroute control circuitry for auxiliary feedwater valves and turbine steam supply to bypass switchgear room 1-C.

Reroute the service water pump motor fee.der to bypass the corri ~or between switchgear room 1-C and the charging pump room; and rero~te control and instru-mentation circuits to bypass switchgear room 1-C.

These change.s are required to assure the ability to bring the plant to hot shutdown and to cold shutdown in the event of a*fire in switchg~ar room 1-C:

~ -

c

• e**

....... Install a 2400 psig nitrogen cylinder manifold in the auxiliary feedwater pump room and another in the component cooling room.

The manifold in the AFV' pump room will be *used to. operate the steam source ~alve and steam regulatory valve to the turbine propelling the AFW steam turbine driven pump, the manifold in the component cooling room will be used to operate the.auxiliary*f~ed~ater control valves.

This modification will provide a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> backup to the normal air source.

The normal air source is powered by of~site power which must be assumed to be unavailable for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in the event of a fire* in accordance with the requirements of Appendix R.

D).

• In-stall a new circuit from 480 volt Bus #13 to charging pumps P55B and P55C to provide a backup po~er source in the event a fire in the cable spreading room damages the normal 480V power sources for the pumps.

• E '.

Re*locate fuses between batteries and bus from the cable sprea.ding room to their respective bat~ery rooms; install a circuit breaker (non-auto) with stiunt trip between the fuse and its bus.

Install

• new DC distribution panels in switchgear room l~C and diesel generator room 1-1, install new circuits for opera~ing and control power* to each di es el generator and 2400 volt bus.

New circuits will avoid the cable spreading room and the diesel generator and switchgear room of the other channel.

These modifications, will assure the availability of 125V DC operating and control power in the event a fire damages distribution equipment in the cable spreading room.

~

I i ;

. i

• • ~.

. F.

Reroute the generator power cables and control and instrument circuits from diesel generator 1-2 to 2400 volt Bus 1-D to bypass diesel generator room 1-1. Relocate the power source to the diesel generator crankcase

_blowers from the present source to the 2400 volt terminals of the diesel generator.

Relocate control and instrument circuits from diesel generator 1-2 to the control room to bypass switchgear room 1-C.

These I

modifications will assure the provision of 2400V operating power in the event of a fire in either the control room, cable spreading room, switch-gear room 1-C or diesel generator room 1-1.

6:.

Install a second solenoid valve into the control for the valve.in :t~e steam admission line to the turbine for the AFW steam turbine driven pump.

The power source for this solenoid valve is provided from the new auxiliary shutdown control panel so that the AFW turbine driven pump may be controlled from the new panel. in the event of a fire in the control room.

All Of the foregoing modifications are designed to provide for ~afe shutdown in accordance with Section III.G.3 of Appendix R in the event of a fire in any of the rooms des_1.gnated as Items< 1-A.. tn Sectton I' above, or. in S\\'/itChgear room lC.. (The licensee has pursue.d the solution recommended in the FPSER for*

safe shutdown in the event of a fire in switchgear room lC by rerouting cables,..

thus complying with Section IILG.2 of Appendix*R.)

-~

e**** In response to the staff's question regarding a fire in the area of the au.x.il i ary shutdown contra 1 panel which would require shutdown, the 1 jcensee stated that this wou_ld affect only the* path to hot shutdown.

The auxiliary shutdown panel contains a switch which enables oper.ation of the AFW system from thi.s panel., disabling (preventing) normal operaticm at the control room.

During normal operation the switch w~uld be in the position in which the

- auxiliary shutdown panel was disabled; hot shutd.own would be effected by means of' the electrically powerfi!d AFW pump with the operators using normal control room means to *control the AFW pump (Reference 4).

If the fire were to cause a hot short in the transfer switch relay, thus enabling the auxiliary shut~_own

. control panel, hot shutdown could not be effected in the control room or at the auxiliary sht.it~own control panel with the presently existing AFW system but would have to.be carried out by means of a new auxiliary feedwater s*y.stem which has been proposed by_ the licensee and which could be controlled, i hdependently, from the control room.

This new AFW system will use the..

third high pressure safety injection pump and a path to the steam generators which is separate from the existing system.

l"

-T"...... -- *-..

.e I~. Cowpliance with Appendix R A.

Hot Shutdown *

1.,B.eactivity Control and Maintenance of Reactor Coolant Inventory When the operator becomes aware of the ?nset of a fire, he may trip the reactor manually;_a fire of sufficient severity may cause the plant to be tripped automatically. This control rod insertion is sufficient to attain hot shutdown:.

Boron, in the form of boric acid solution, will be added to the reactor vessel by means of one.of the three charging pumps in ord~r to maintain the reactor in the subcritical state for subsequent' cooldown, if needed.

The charging.Pump will use either the safety injection and refueling water (SIRW) tank or the boric acid tank (BAT) as the source of borated* wa'ter: to. be injected into the reacto~ vessel.

The charging pump will alsb

, inject water into the reactor vesser (RV) as necessary to maintain the proper water level in the RV.

The charging pu~p selected for use may be started at its circuit breaker, and all valves in the system may be positioned manually.

The 1 i censee must ::irovi de the fo11 owing instrumentation which wil 1 be available in the event of a fire in either the control room, cable spreading room, engineered safeguards panel room or corridor between the c*harging. pump room and switchgear room lC (hereinafter to be known as Areas 1-4):

1.

Source range fl~x monitor;

2.

BAT tank level indicator;

3. *SIRW tank level indicator; and 4.. Charging pump flow rate indicators.

1 '

.l i

i '

J l

. - r**-* -

. ---~. *-*-

With regard to the source range flux monitor, the licensee did discuss (Reference 4) the use of grab samples of the reactor coola.nt* and subsequent an.alysis as a means for determin.ing core criticality during a fire.

However, Appendix R requires direct re~din~ rather than indirect measurement 6f this sensitive para-meter and indirect read'lngs have inherent uncertainty which could I

lead to return to power transients. Thus, the staff ~oDcludes that a readout for the source range*fiux monitor at the alternate shutdown control panel is n~c~ssary.

2.

Reactor Coolant System Pressure Control The plant will maintain pressure in the primary syste~ by means of the pressurizer heaters.

If the heaters are not available, the plant will use the charging. pump system to maintain the system pressure between 1500 psia.and operating pressure in order to achieve a minimum subcooling of 25°F.

The liten~ee noted

(.Reference 4) that the primary system pressure wi*ll not fall to 1500 psi a for "several" hours, allowing the plant operator suffi-cient time to respond in the event all the pressurizer heaters are 1 ost.

-:*.: *)

-~*-

~ I

... ~:' : !.

\\

-~

I.

r

• !! The licensee has agreed (Reference 6) to provide procedures for operator guidance in maintaining primary system p~essure by mea~'-----~

of the charging pump during hot shutdown in the event all the pressurizer heaters are lost during a fire.

The licensee will provide the staff with a summary of these procedures for its review.

The staff finds this accepta-Ole.

3.

Decay Heat Removal The steam tur'bine driven AFW pump may be used to supply water to

.either or both steam generators, as necessary.

The motive st~am for the turbine comes from steam generator No~ 2 (E-50-B).

The turbine driven pump nonnally draws water from the condensate storage tank (CST). but the fire mains,. dravring water from. Lake Michiga~ can be used to supply water to the turbine dr{ven AFW.

pump in the ev_ent the water supply in the.CST is* depleted or cannot be utilized.

The pump can be started from the new auxiliary shutdown panel which is to be. installed in the southwest electric_al pehetratiOn room; the controls for the auxiliary feedwater valves and steam supply valve to the turbine.. driven AFW pump will also be.on *the new auxiliary shutdown panel. These controls are enabled by means of a transfer switch in the southwest electrical penetrat-ion room

. which also disables the controls in the control *room ~nd c~uses an annunciator in the control room to signal transfer of the control functions.

e**

....,. The steam which is generated will be released to the atmosphere by means of the code safety valves in the secondary (s.team)

• system.

The licensee must provide suitable indication of steam generator pressure in the event ef a fire in Areas 1-4.

The licensee discussed (Reference 4) elimination of the need for a steam generator pressure measurement, citing the possibility of using. the prima*ry system temperature as a guide.

The staff feels that such a measurement would be adequate only if the --

.secondary (stam) side were at equilibrium. At non-equilibrium conditions the temperature of the primary side would not be adequate to show secondary side pressure.

Since maintaining equilibrium conditions on the secondary side*may not be possibl~

J -

~uring and after a fire~ the staff requires that the licensee pro-vide the required steam generator pressure measurements.

4.

Air Supply.

Air is required to operate the ~alve supplying steam to the turbine driven AFW pump (CV0522B), the valve (PCV 0512A) ~egulating the steam pressure to the turbine, and the two control valves (CV 0736A and CV 0737A) in the AFW system, each of which opens to permit feedwater to enter one of the two steam generators.

The licensee intends to install a 2400 psi nitrogen cylinder manifold in the AFW.pump room to supply air to the stea~ *supply and regulatin~

..5-v~lves in the case of loss of the nonnal offsite power source for tbe air compressors.

Similarly, th~ licensee intends to install a 2400 psi nitrogen cylinder manifold in the component coo-ling pump area to supply air to the two control valves upon failure of the normal air supply. This standby source of-com-pressed gas (nitrogen cylinders) is intended to provide an 11air 11 source for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.,

The licensee noted (Reference 6) that he had the ability to trans-fer the air compressors which provided compressed *air to these valves to an onsite, non-1( power source somewhat before the--1"2 ho~r nitrogen supply was exhausted.

The staff finds this accept-able.

5.

Electric Power The licensee has planned to modify the electrical. system to assure the availability of 125V-DC operating arid control power and 2400V Class lE power in the event of a fire in switchrear room lC, in the control room, in the cable spreading room, in the engineered sa~eguards panel room, o~ in the corridor between the charging pump room and switchge~r room 1-C.

The staff finds this acc~ptable.

. i I

I.

• 1 I!

' r L

I i i I i I I

_(

e** 6.

Process Monitoring Information The new shutdown panel will contain instrumentation to' provide the followfng information:

a.

Pressurizer level,

b.

Primary system pressure,

c.

Water level in each steam generator, and

d.

Feedwater fl ow to each steam gen-era tor A. new sensor will be installed to provide primary system pressure only on the auxiliary shutdown panel.

The other information will be provided by instrumentation which i-s normally supplied to the

• control. room; a transfer switch, in the ~outhwest electrical

.'.penetration room, will enable the instrument channels on.the auxiliary panel and dis~ble them in the control room.

CPC has committed

{Reference 4) to provide hot leg and cold leg reactor coolan~ temper-atures on the new shutdown panel.

CPC also committed {Reference 5) to provide an ann~nciator.at the auxiliary shutdown control panel to indicate:

low pressur.e at the suction. of the turbine driven AFW pump.

The 1 i censee has agreed to verify the fact that the o*perator will have sufficient time, upon annunciation of low suction'pressure, to prevent damage to the pump.

The staff finds this acceptable.

'I II I

I* ii I

.:.7_

7.

Administrative Control CPC specified (Refer~nce 2) that operation of the transfer switch to enable operation of the auxiliary shutdown control panel for control of systems for safe shutdown (and disaoling such control at the main control panel) will be annun~iated in.the control room.

As a further adm-inistrative control the licensee reported (Reference*6) that a magnetic card lock acces~ to the area of the auxiliary *shutdown control panel (a vital security area) is maintained.

The.staff finds this acceptable.

1.

Pressure Reduction.and Cooldown In the transition from hot shutdown to cold shut~own, the decay and sensible heat is removed by use of one of the steam generators (SG No. 2) with water from the CST or fire mains fed into it by the steam-driven AFW pump; the steam produced will be released to the atmosphere by means of the steam jet air ejector.

The licensee.has agreed {Reference 6) to verify.the fact that use of the steam jet air :,ejector is suffkient for timely transition from hot* shutdown to conditions at which cold shut-down may be initiated.

The staff finds this acceptable.

.. ~

'.-..I

2.

........ e** Decay Heat Removal Wh_en the primary system pressure has been reduced to. below 250.psig, one of the two low pressure safety injection pumps will be started (if not already oper_ating} in recirculation r:iode.

to.provide shutdown cooling. The decay heat from the primary system will be transferred to the component cooling system via I

a shutdown cooling heat exchanger; in turn,:tnedecay-heat -_::

will be transferred to the *service water system via a component..

cool fog water h.eat exchanger.

Only one shutdown heat exchanger, one component cooling water heat exch~n~er, one comp6nent_

, cooling system pump and one service water pump are needed for this service.

The 1 i censee must pr.ovi de instrumentation to i ndi ca te service water pump flows, component cooling pump flows, and component cooling system surge tank level in the -event of a fir.e in one of the areas deii~nated herein~ as Areas 1-4.

C.

Compli.ance*with Secti~ns I!l.G and III.L

1.

Hot shutdown will be achieved with the steam turbine driven AFW pump with controls at a new panel, the auxiliary shutdown con-trol panel to be installed in the southwest electrical pene-tration room. the new panel is intended to provide an alter-nate hot shutdown control area in the event of a fire in the control room, cable spreading room, engineered safeguards panel room and corridor between the charging pump room and.

I.

I

2.

• ~ switchgear room lC.

The isolation devices associated with the circuits of the auxiliary shutdown control panel are being reviewed.

Provided that this review confirms acceptable iso_lation of these circuits, this complies with the requirements of Section III.G.3 and III.L of Appendix R.

The staff finds this acceptable.

I Cables passing thro.ugh switchgear room lC were rerouted so that a fire in room lC would *not damage :redundant systems. Thi,s change complies with Section III.G.2 of Appendix R. *The staff finds this acceptable.

e***

(

III. Al.f'ernate and Dedicated Safe Shutdown Capability A.* Performance Goals The perfonnance goals for achieving safe shutdown will be met using the systems and equipment described in Sections I J and II I.

Subcritical reactivity conditions will.:init'fally *b.e achieved through the

- use of the control-rods followed by boratio-rr-via *one of the three charging pumps to maintain shutdown margin during cooldown.

Reactor coolant *inventory wnl be maintained by the* charging pump used for boration, dra'!"ing on either the -boric acid tank or the-SIRW tank for a-water so"urce.

To achieve and maintain a hot shutdown condition, decay heat will be rejected via the code safety valves with steam generator make-up pro-vided oy the auxi 1 i ary feedwa ter pump (steam driven) and drawing on the condensate storage tank or fire mains for a water supply.

To proceed from hot to cold shutdown, heat removal is *accomplished by means of a steam generator with tre steam produced released to the*

atmosphere by the steam jet air ejector.

The turbine driven AFW pump will feed water to the steam generator from the CST or fire mains.

Wh~n pressure in the primary side is reduced below iso ~si, one low pressure safety injection pump and one shutdown cooling'heat exchanger w~ll be Jsed to achieve and m~intain cold shutdown.

• I I

• -~ *-

• B.

Procedures The licensee has committed (Reference 3) to provide*procedures for taking the plant to hot shutdown in the event a fire prevents use of the control room.

The licensee has agreed to extend these procedures to incl tide cold shutdown in the event of a fire in Areas 1-4 or in the area of the new auxiliary shutdown control parrel.

The litensee will provide the staff with a sum1nary of these procedures for its review..

C.. Personnel Requirements*

The technical specifications require three members of the minimum shift crew to be free from other. duties during a fire emergency to be available to conduct safe shutdown ~ctivities. The licensee stated ~Reference 4) that two members are sufficient to shut -the plant down safely, from either the control room, or safe shutdown area but provided no further verification to show that two members of the crew were sufficient to bring the plant to cold shutdown.

The licensee has agreed to provide procedures (see Item 8, above) to bring the plant to cold shutdown.

The procedures must confirm the li~ens~e's position. The staff finds this acceptable.

D.

Repairs There are no repairs contem_pl ated for either hot or col.d* shutdown

.which require replacement of cable or equipment.

Cold shutdown may requjre disconnecting associated circuits.

E.* 72 Hour Requirement~

As discussed.with the licensee (Reference 5), 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 /> following initiation of shutdown due to fire

. and loss o"f offiste power..

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~

F.

-~

l

-~

1

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)..

e** Associated Circuits and Isolation The licensee has not provided a complete list of associated circuits for the staff's review.

The licensee stated that the new isolation devices he intends to provide will meet the standards for similar devices rev~ewed and approved in the Systematic Evaluation Program (SEP).

However, the licensee stated (Reference 3) that there were no cables, either safety related or non-safety related; in any of the fire Areas 1-4

• associated with the_ auxiliary shutdown control panel.

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--*-~------.-*~-------*-,---*-*-**---**

The lic~nse~, therefore, ~~st still provide a lis~ of.associated cir-cuits related t~ systems to be used for-cold sh~tdown in fhe event of a fire in Areas 1-4. In addition, the licensee must also provide a list of associated circuits related to systens to be used for hot *and cold shut-down in the event of a fire in the area of tne auxiliary shutdown con-trol _panel.

For fires in the area of the auxiliary shutdown control

• panel special emphasis should be made with regard to systems used in the event the tr.ans fer switch relay develops a hot short, causing transfer of control to the auxiliary shutdown control panel. The staff is reviewing isolation devices in schematic wiring diagrams provided by the licensee (Reference 4) for the shutdown systems operab1~

from the auxi_liary shutdown control panel. If the 1 icensee identifies any further associated circuits, as noted above,,he.mµst also provide l..

description of the isolation provided for these cir~uits and identify the circuits in which they are used.

.e J

-* G.

Pressure Isolation at High-Low Pressure Interface The only high-low pressure interface idertified which is part of this concern. is in the shutdown cooling line connecting the reactor coolant system to the ~uction of the low pressure safety _injection pumps.

Isolation is provided by two valves iri series, (M0-3015 and M0-3016).

In order to prec__1ude inadvertent opening of both valves due to fire induced circuit faults, CPC committed.to p~ovide an*

operating procedure which Would require a check to assure both valves are closed and operating power disconnected before raising.th~ r~actor coolant system pressure to a level greater than 260 psig (Reference 4).

The staff finds this acceptable.

H.

Communication The licensee stated (Reference 5) that portable radios can be u~ed for communications between the new shutdown panel and other 16cations which have to be manned to assure ~afe shutdown.

The staff finds this *

• acceptable.

______ ::..=....------ -----: **--

e**

rv: Summary and Conclusions As a result of the siaff'~ review rega~ding safe-shutdown after a fire in the Palisades Plant (using Appendix R, Sections III.G and III.Las guides) the staff finds some deficiencies in the information provided by the licensee.

As a result, the staff requires that the licensee provide more instrumentation (outlined in Paragraph 1, below) and further information re:-garding.associated circuits (outlined in*Paragraph 2; below)~ __ :

• The licc:isce -has** c:greeC: to prcvic'.e ;:rcCCGl!r~s 7::r c;::::--~:cr rt.:i~::.:ice in taking.the plant to <::old shutdown, in mai.ntaining primary system pressure in the event of inoperability of the pressurizer heaters and to assure

.closure of the valves constituting the high-low pr~ssure interface before raising reactor coolant system pressure (outlined in Parag~aphs 3a, 3b and.Jc, below).* The licensee has also agreed to verify that two crew memb~rs can safely shut the plant down after a fire (Paragraph 3d~ below),

that the operator has ~ufficient time to prevent damage to the steam turbine driven AFW pump in the event of low suction pressure (Paragra.ph

-- - ----~ --*--**--

3e, below), and to verify that use of the steam jet air ejector is suf-ficient for timely transition from tiot to cold shutdown {Paragraph 3j\\ l:>elow).

.The staff finds that, subject to provisio_n of instrumentation (required in Paragraph 1, below) and information regarding associatea circuits (req.uired in Paragraph 2, below) and the procedures and verifications (required in Paragraphs 3a through 3f.below), the licensee's plans for safe shutdown in the event of a fire comply with the requirements of Appen-dix R, Sections III.G and III.L.

• 1 i

I..

I

~

!* r*

r.

l.

2.

--~ *

.e T~e licensee must provide instrumentation to indicate the following in the event of a fire in Areas 1-4:

a. Source*range flux monitor;

b.

Steam generator pressures;

c.

Pump flow rates

i.

Charging pumps ii. Service water pumps*

iii.

Component cooling 'pumps and

d.

Tank levels

i.

BAT iii.

Component cooling systen surge tank Instruments outlined in Paragra,phs le and ld above, are intended for use in providing surveillance regarding proper:_ operation of systems used in maintaining the required reactor coolant boron conten:t;*reat,tor coolant make-up and sufficient cooling capability. There may be alter-native instruments and methods which may prove acceptable to the staff if

• the licensee provide~ suit~ble justification for such alternatives.

The licensee must p"rovide the followir.~ *lists of associated circu.its:

a.

Related to systems used for cold ihutdown in the event of a fire in Areas 1-4;

b.

Related to systems used for hot and cold shutdown in the event of a fire in the auxiliary shutdown control panel area; and

c. A description of the.isolation devices and the circuits in ~hich

.they are used in the event additional associated circ~its are identified in Item 2a or 2b, above.

• '\\.

3.

The licensee has agreed to provide the following:

a.

Procedures for operator guidance in taking the plant to cold shutdown

.in the event of a fire in Areas 1-4 or in the auxiliary shutdown control panel;

b.

Procedures for operator guidance in maintaining primary system pressure during hot shutdown in the event of a fire which destroys all the.pressurizer heaters, their*controls or. their power supplies; c..

Procedure to assure closure of andremoval of power from two valves constituting the high-low pressure interface between the reactor coolant system (RCS) and suction of low pressure safety inje~~ion p~mps before raising the RCS pressure -above 260 psig.

d.

Verification that the plant can be safely shutdown by two crew members in the event of a fire in Areas 1-4 or in the area*of the auxiliary shutdown control panel (This may be established by.means of the procedures discussed in Paragraph a, above);

e.

Verification that the opera.tor has sufficient time to act to pro-tect the steam turbin~ driven AFW pump in the event of annunciation of low suction prr.ssure when operating at the auxiliary shutdown control; and 1..

Verification that the use of the steam jet air ejector is sufficaent for timely transition from hot shutdown to conditions at which cold shutdown may be initiated.

~I I

(

' *f _,,,

References

l. Letter fro~ Dennis L. Ziemann, USNRC to David Bixel, Consumer~ Power Company.dated September l, 1978.

2.

Letter from Brian D. Johnson, Consumers* Power Company to Dennis M.

Crutchfield, USNRC,

Subject:

"Docket 50-255 - Licensee DPR-20, Palisades Plant - Fire Protection Modifications," dated March 19, 198.l.

3. Letter from Brian D. Johnson, Consumers Power Cpmpany to Dennis M.

Crutchfield, USNRC,

Subject:

~ "Docket 50-255 - License DPR Palisades Plant - Fire Protection Modi,fications, 11 dated May 19, 19.81.

4.

Letter fro~ Bria~ D~ J:~~so~. So~s~~ers Power to Dennis M.

Cr~tchfie1d, USNRC,

Subject:

"Docket 50-255 - License SPR Palisades *Pla'nt *-

Post-Fire Safe Shutdown Review: *Additional Information in Response to NRC Questions.

11 dated February 16, 1982..

Telephone Conference among Consumers Power Company,* Brookhaven National Laboratory, USNRC, on December 16, 1981.

6.

Telephone Conference betweeru Consumers Power Company and the USNRC on March 2, 1982.