ML19305E212
| ML19305E212 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 03/24/1980 |
| From: | Schwencer A Office of Nuclear Reactor Regulation |
| To: | Peoples D COMMONWEALTH EDISON CO. |
| References | |
| NUDOCS 8004230125 | |
| Download: ML19305E212 (22) | |
Text
f ph e
f* M G uq'c, UNITED STATES
- .a$s.f;y' j
[ jp NUCLEAR REGULATORY COMMISSION
. g WASHINGTON, D. C. 20555 t%4E.1[8/
March 24, 1980 Docket Nos. 50-295 and 50-304 Mr. D. Louis Peoples Director of Nuclear Licensing Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690
Dear Mr. Peoples:
We have reviewed your submittals dated April 14, May 1 and 17, July 11, September 8 and 29, 1978, and April 9, June 29, and August 31, 1979, relating to the Zion Station Fire Protection Program.
The status of resolution of the incomplete items identified in our Safety Evaluation dated March 10, 1978, and April 13, 1979, is shown in Enclosure 1.
The results of our evaluation of the outstanding items are shown in Enclosures 2, 3, and 4. presents our evaluation of issues that are complete. presents our evaluation of issues for which we need additional information. presents our evaluation of those issues which we find your position presently not acceptable and indicates requirements that would resolve the issue. is the NRC Staff Position on Safe Shutdown Capability.
We request that you respond within 30 days of the date of receipt of this letter.
If you do not plan to meet these requirements, you should request a meeting within the same 30 days.
Sincerely,
/$
A. Schwencer, Chief Operating Reactors Branch #1 Division of Operating Reactors
Enclosures:
1.
Status of Resolution of Incomplete Items 2.
Evaluation of Supplement Items (Complete) 3.
Evaluation of Supplement Items (Require Additional Information) 4.
Evaluatien of Suppletent Items (Unacceptable) 5.
Staff Position - Safe Shutdown Cacability cc w/ enclosures:
See next page l
l 80OM230[S
Mr. 3. Louis Peoples 2-March 24,1980 Cc:honwealth Edisen Ccmpany
.m cc: Robert J. Vollen, Esquire 109 North Dearborn Street Chicago, Illinois 6C602 Dr. Cecil Lue-Hing Director of Research and Development Metropolitan Sanitary District of Greater Chicago 100 East Erie Street Chicago, Illinois 60611 7
Zion-Benton Public Library District 2600 Ennaus Avenue Zicn, Illinois '60099 Mr. Phillip P. Steptoe Isham, Lincoln and Beale Counselors at Law One First National Plaza 42nd Floor Chicago, Illinois 60603 Susan N. Sekuler, Esquire Assistant Attorney General l
Environmental Control Division 188 West Randolph Street, Suite 2315 Chicago, Illinois 60601 Resident Inspector
[
Zion Nuclear Station t
U. S. Nuclear Regulatory Cocmission Post Office Box 374 Deerfield, Illinois 60015 9
1
0 ENCLOSURE 1 ZION STATION STATUS OF RESOLUTION OF INCOMPLETE ITEMS Licensee SER Item Staff Evaluation Response Due 3.1.1 Smoke Detection Systems Information (test results)
Upon Test Completion 3.1.3 Gas Suppression System (1)
Inner and Outer Cable Information 30 days Spreading Areas (2) Containment Penetration Cable Vaults Complete (3) Auto gas suppression for diesel driven containment spray pumps Information 30 days 3.1.4 Water Suppression Systems l
(a) Automatic water curtain for diesel generator air intakes Information 30 days (b) Automatic directed water suppression over diesel fire pump and day tank Information 30 days 3.1.5 Fire Water System (a)
Leakage detection of failures - in fire water system Complete 3.1.10 Portable Ventilation Equip Complete 3.1.18 Reactor Coolant Pumps Complete 3.2.1 Administrative Controls Requirement 30 days 3.2.2 Electrical Cable Tests Complete 3.2.3 Tests of Typical Electrical Penetrations Complete 3.2.4 Physical Separation Tests Requirement 30 days 3.2.5 Control Room Analysis Requirement 30 days 3.2.6 Containment Penetration Vaults Analysis Complete 3.2.7 Auxiliary Electrical Room Analysis Requirement 30 days 3.2.8 Alternate Shutdown Capability Requirement 30 days i
1 t
I
ENCLOSURE 2 ZION STATION - FIRE PROTECTION EVALUATION OF SUPPLEMENT ITEMS THAT ARE COMPLETE 3.2.2 Electrical Cable Tests Our evaluation of March 10, 1978, noted that control and instrument cables manufactured by the Boston Insulated Wire and Cable Company would be tested to the. flame test requirement of IEE Std. 383-1974.
By letters dated May 17, 1978, and July 11, 1978, the licensee provided a summary of the test results and their conclusion that the cable had passed the test.
We have reviewed the test results and find that the electrical cables are acceptable.
3.2.3 Electrical Penetration Fire Tests Our evaluation of March 10, 1978, noted that tests or typical electrical penetration seals would be conducted to determine their fire resistance rating.
By letters dated April 14, June 19, and September 29, 1979, the licensee provided a description of the fire test procedures, a summary of the test results, and a third party evaluation of the test result:.
We have reviewed the test procedure and results.
Our consultant has witnessed the fire barrier tests conducted at the U.S. Gypsum facility.
We find that the cable penetration fire barriers seals constructed in accordance with those tests are acceptable.
3.2.6 Containment Penetration Vaults Analysis Our evaluation of March 10, 1978, noted that an analysis of safety-related shutdown systems would be conducted to demonstrate that fire-related damage in the containment penetration vaults would not inhibit the capability to safely shut down.
By letter dated May 1, 1978, the licensee submitted an analysis of the effects of a fire in the electrical penetration vaults.
The analysis assumes the loss of the upper and lower cable vaults to fire.
The licensee indicated that (a) the operability of pumps and valves required for saf.e shutdown would be unaffected; (b) a maximum l
cf two of four channels of instrumentation may be affected; and (c) control would be maintained from the main control board for the l
postulated fire.
l l
l
~
l 1
Because hot or cold shutdown conditions can be achieved.and c:aintained in spite of the loss of all cables in these vaults, we i
find that fire-related damage in this area will not prevent safe shu.down.
i l
f 4
I e
l 1
i a
I J
k
?
d g
4 Y
1
[
r I
l l
4 ENCLOSURE 3 ZION STATION - FIRE PROTECTION EVALUATION OF SUPPLEMENT ITEMS THAT REQUIRE ADDITIONAL INFORMATION 3.1.1 Fire Detection System Tests By letter to the licensee on February 14, 1979, we indicated the licensee's commitment to do the tests identified was acceptable. We have informed the licensee of our intent to review the findings of any test program he conducts to comply with this request.
Data should be provided for our review.
3.1.3 Gas Suopression Systems Our evaluation of March 10, 1978, inadvertently omitted an asterisk for this item.
Additional information is required for Items 3.1.3(1) and 3.1.3(3) as noted in Enclosure 1 to this letter.
The licensee has been advised of this need by telephone.
3.1.4 Water Suopression Systems Our evaluation of March 10, 1978, inadvertently omitted an asterisk for this item. Additional information is required.
The licensee has been advised of this need by telephone.
l
ENCLOSURE 4 ZION STATION - FIRE PROTECTION EVALUATION OF SUPPLEMENT ITEMS FOR WHICH THE LICENSEE'S PROPOSAL IS UNACCEPTABLE 3.2.1 Administrative Controls Our initial Safety Evaluation Report (SER) for the reevaluation of fire protection at Zion 1 and 2 was issued on March 10, 1978.
Section 6.0 of this SER noted that the licensee's description of their administrative controls was not adequate to permit a con-clusion by the staff.
To resolve this concern, we had recommended that the licensee's administrative controls follow the guidelines set forth in " Nuclear Plant Fire Protection Functional Responsibili-ties Administrative Controls and Quality Assurance."
By letters dated January 24, March 15, July 27, and November 30, 1978, and January 31, 1979, the licensee responded to our requests for additional information and staff positions.
We have evaluated these submittals and find that licensee complies with our administrative controls guidelines except for deficiencies in: (1) fire protection organization description; (2) fire brigade physical examination; (3) control of combustibles and ignition sources; and (4) prefire plans.
To resolve the deficiencies in the licensee's description of their (1) fire protection organization and (2) audit of fire brigade drills, we will require that the licensee:
1.
identify the offsite management position responsible for developing the fire protection program using NFPA publications.
2.
provide assurance that at 3 year intervals, drills are audited by qualified individuals independent of the utility's staff.
By letter dated July 27, 1978, the licensee noted that "their pre-employment physical" is sufficient to determine fire brigade members' ability to perform in strenuous physical activities, and the physical examination to meet Regulatory Guide 0.15, " Acceptable Program for Respiratory Prctection," fulfills the fire brigade members' requirement for periodic physical examinations." We have evaluated the licensee's proposal and find it is not acceptable because these physicals do not screen out brigade members who are unable to perform effectively under strenuous firefighting activity.
We will require that, annually, fire brigade members be given a physical examination to determine their capacity to undergo strenuous physical activity as experienced in firefighting.
l l
l l
. The licensee has indicated in his administrative control. description and by letter of June 1,1978, that, "no specific procedural controls are currently in effect in their plant, other than information contained in generalized safety handbooks, work practice guidelines, materials handling and operating procedures." This situation is not acceptable.
To resolve this concern, we will require the licensee to establish administrative controls to minimize fire hazards in areas containing structures, systems, and components important to safety.
These controls shall establish procedures to:
1.
Govern the handling and limitation of the use of ordinary combustible materials, combustible and flammable gases and liquids, high efficiency particulate air and charcoal filters, dry ion exchange resins, or other combustible supplies in safety-related areas.
2.
Prohibit the storage of combustibles in safety-related areas or establish designated storage areas and fire protection therefor.
3.
Govern the handling of and limit transient fire loads such as combustible and flammable liquids, wood and plastic products, or other combustible materials in buildings containing safety-related systems or equipment during maintenance, modification, or refueling operations.
4.
Designate the onsite staff member respcasible for the in plant fire protection review of proposed work activities to identify potential transient fire hazards and specify reqired additional fire protection in the work activity procedure.
5.
Govern the use of ignition sources by means of a flame permit system that controls welding, flame cutting, brazing, or soldering operations. A separate permit shall be issued for each area where work is to be done, and if work continues over more than one shift, the permit shall be valid for not more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
6.
Govern the removal from the area of all waste, debris, scrap, oil spills, or other combustibles resulting from the work activity, or at the end of each work shift, whichever comes first.
7.
Govern the periodic housekeeping inspections to ensure continued compliance with these administrative controls.
S.
Govern the use of specific combustibles in safety-related areas.
All wood used in safety-related areas during main-j tenance, modification, or refueling operations (such as i
lay-down blocks or scaffolding) shall be flame-retardant treated.
Equipment or supplies (such as new fuel) shipped in untreated combustible packing containers may be unpacked in
Enclosuro 4 safety-related areas if required for valid operating reasons.
However, all combustible materials shall be removed from the area immediately following the unpacking.
Combustible material shall not be left unattended during lunch breaks, shift changes, or other similar periods.
Loose combustible packing material such as wood or paper excelsior shall be placed in metal con-tainers with tight-fitting self-closing metal covers.
By letter dated March 15, 1978, the licensee response to our staff position for the control of ignition sources proposed the following:
When performing welding or open flame work and cutting, shields are used at the work location.
If there is a potential for the flames to go to a lower elevation, shield mats are used. This precludes the need for covering flammable material within a 35-foot radius.
We have reviewed this proposal and find it is not acceptable.
l Shields used around a " hot" work location do not fully guarantee protection of flammable materials within a 35-foot radius.
The protection provided by a shield is a variable quantity, dependent on such items as shield design, its location, the amount of hot particles escaping from the shield, and the ignition characteristics of the flammable materials in the area. We, therefore, require the licensee to comply with our position which states:
Where welding, grinding, open flame work and cutting is being performed, all immovable combustible material below and within a 35-foot radius should be protected by asbestos curtains, metal guards, or flame proof covers.
The licensee's administrative controls description and their letters dated May 15 and July 27, 1978, in response to our staff positions regarding firefighting strategies indicate that:
1.
the licensee does not consider that specific firefighting strategies and plans should be included in any of their fire protection administrative controls; 2.
firefighting strategies will be continuously evaluated and reasonably upgraded with available technological advancements during periodic fire drills conducted at company's stations; and 3.
the station fire brigade members' familiarity with plant access and component locations precludes the necessity for the desig-nation of area access, critical equipment, and potential fire source locations.
We have evaiuated these responses and find they are not acceptable because they do not comply with our established position on'this l
l l
[
. s matter.
To resolve this concern, we require that firefighting strategies be established for fighting fires in all safety-related areas and in areas presenting hazard to safety-related equipment.
These strategies shall designate:
a.
Fire hazards in each area covered by the specific firefighting procedures.
b.
Fire extinguishants best suited for controlling the fires associated with the fire hazards in that area and the nearest location of these extinguishants.
c.
Most favorable direction from which to attack a fire in each area, in view of the ventilation direction, access hallways, stairs, and doors that are most likely to be fire free, and the best station or elevation for fighting the fire.
All access and egress routes that involve locked doors should be specifically identified in the procedure with the appropriate precautions and methods for access specified.
d.
Plant systems that should be managed to reduce the damage potential during a local fire; location of local and remote controls for such management (e.g., any hydraulic or electrical systems in the zone covered by the specific firefighting procedure that could increase the hazards in the area because of overpressurization or electrical hazards).
e.
Vital heat-sensitive system components that need to be kept cool while fighting a local fire.
Particularly hazardous combustibles should be designated to receive cooling.
f.
Organization of firefighting brigades and the assignment of special duties according to job title so that all firefighting functions are covered by any complete shift personnel complement.
These duties include command control of the brigade, transporting fire suppression and support equipment to the fire scenes, applying the extinguishant to the fire, communication with the control room, and coordination with outside fire departments.
g.
Radiological and toxic hazards in fire zones.
h.
Ventilation system operation that ensures desired plant pressure distribution when the ventilation flow is modified for fire containment or smoke clearing operations.
i.
Operations requiring control room and shift engineer coordination l
I or authorization.
J.
Instructions for plant operators and general plant personnel during fire.
. 3.2.4 Physical Separation Tests Our SER noted that tests would be conducted to confirm that the physical separation of electrical cable trays is adequate to prevent fire damage to redundant safety-related systems due to electrical cable insulation fires or exposure fires.
Our SER designated the areas of concern to be cable spreading room, containment penetration vaults, auxiliary electrical equipment room, auxiliary building elevations 642, 617, 592, 560, and 542, reactor containment and the crib house.
By letter dated September 8, 1978, the licensee provided information on the cable spreading tests indicating that the results of the Sandia Laboratories tests demonstrated the effectiveness of the cable separation and, therefore, no tests would be conducted by the licensee.
The licensee's arguments center on the results of tests performed on solid bottom cable trays with IEEE and non IEEE-383 qualified cables; and with covered and ventilated trays.
The licensee refers to the fact that IEEE-383 qualified cable when subjected to an external fire source did not catch fire, and that solid bottom trays provide an effective fire barrier.
We have reviewed the licensee's argument, the Sandia test reports, and have observed the physical separation of redundant cables during our site visit.
The results of our evaluation are as follows:
(a) The cable configuratiens Sandia tested were different from the physical separation conditions existing at Zion Station; (b) The cable concentrations and geometries of the cables were different from those at Zion Station; (c) There are a number of areas at Zion Station where tray covers are not installed; and (d) There is no assurance that exposure fires comparable in size and intensity to the Sandia exposure fires would not cause the loss of redundant safe shutdown related cables in the areas noted above.
The licensee has not provided sufficient information to confirm the adequacy of physical separation.
Therefore, we require an alternate shutdown capability independent of the areas designated above.
The Staff Position on safe shutdown capability is provided in Enclosure 5.
o
. 3.2.5 Control Room Analysis Our SER noted that an analysis of safety-related shutdown systems would be conducted to demonstrate the fire-related damage in the control room would not inhibit the capability to safely shut down.
By letter dated June 26, 1978, we asked the licensee to verify:
(a) that the controls located at the remote shutdown panel are wired in such a manner that it was possible to override the main control board and take control at these local panels, (b) that the capability for local indication of essential parameters is provided, which is either independent of fire damage in the control room or can be restored by the use of transfer switches, if a portion of the indication circuit is damaged by a control room fire, (c) that fuses and procedures be readily available for operations required to achieve and maintain hot shutdown conditions, and (d) the operability of diesel generator units and the capability to supply oower to the ESF buses independent of fire damage to circuits located in the control room.
Our concern was raised over the licensee's statement contained in his May 1, 1978 letter that "all equipment required to perform functions needed to achieve and maintain hot shutdown are powered from ESF buses and are, therefore, available under loss of offsite power conditions."
Our criteria stipulates that safe shutdown must be achievable assuming the loss of.offsite power and a fire.
The licensee analysis therefore does not make the necessary assumptions to comply with our criteria; it assumes that a fire cannot affect equipment required for safe shutdown.
In response to the concerns of our June 26, 1978 letter, the licensee provided responses dated April 9, September 8, August 31, and September 29, 1978.
The licensee's responses do not permit an adequate conclusion with respect to safe shutdown in two respects as follows:
(a)
In the April 9,1979 sub:nittal, the licensee agreed to install test switches in each essential indication circuit to provide for isolation from the control room in the event of fire damage.
The design that has been presented by the licensee does not permit a conclusion on two counts.
First, the sketches presented in a supplemental August 31, 1979 submittal contradicts information presented in the September 8, 1978 submittal.
The result is that the technical details of how circuit isolation is to be accomplished is unknown; e.g.,
it is not clear if we are dealing
with current loops or voltage loops.
Secondly, ables to the safe shutdoon panel rcom pass through the control room.
The details of how these cables are to be protected from exposure fires in the control room have not been provided by the licensee.
The configuration of combustibles and redundant systems in each area must be evaluated to demonstrate that adequate shutdown capability will survive a postulatec fire.
(b)
In respense to our concerns on the operability of the diesel generater units, the licensee responded by letter dated September 29, 1978. We have reviewed the licensee's response and we find the following:
(1) it is not clear that products of combustien will not propogate from the Reactor and Safeguards (R&S) Centrol boards to the Auxiliary Power Control Boards via
[
the two open channels connecting them.
Therefore, it would be prudent to provide an appropriately rated fire barrier in the open chanrel between the two panels; (2) the licensee stated that a fire cculd cause a shift in the diesel generator voltage, but he has r.ot addressed whether this shift would result in a reduction of capacity such that essential shutdown loads would be affected; and (3) the local-remote transfer switch for the diesel generator governor is presently wired in such a way that it is not possible to isolate the main control board.
The licensee has indicated he intends to provide isolation capabil-ity, to allcw ccmplete isolation of the main control board diesel generator governor control switch, from the main control room. We find this acceptable in concept pending our review of the verifications required by our guidance in Staff Position -
Safe Shutcown dated June 9, 1979, Section 8b thru 1.
Therefore, in light of the inadequacies cited above, we require a means to shut the plant down independent of the control room.
Refer to the requirements under our evaluation comments for item 3.2.8 bales.
3.2.7 Auxiliary Electrical Eouipment Room Analysis Our SER noted that an analysis of safety-related shutdown systems would be concucted to demonstrate that fire-related damage in the auxiliary electrical equipment room would not inhibit the capability to safely shut down.
Ey letter datec May 1, 1979, the licensee provided an analysis of tne effects of a fire in the auxiliary electrical equipment room'.
The analysis does not assume the complete loss of the auxiliary electrical equip ent room because the licensee claims a 3-and 5-foot aisle spacing and enclosed metal control cabinets.
However within a row, all adjacent cabinets are assumed lost, and control would be I
caintained frem :ne main control board.
The licensee indicates that
- ne capability :c achieve and maintain hot shutdown will not be affected becausa:
(a) the operability of pumps and. valves will be l
. F unaffected by a fire; and (b) a minimum of three separate channels of instrumentatien are available, and a maximum of two out of the three channels may be affected by the postulated fires.
We have examined the drawings of the auxiliary electrical equipment room submitted by the licensee in his fire hazards analysis.
These drawings indicate all three divisions in one cabinet; and in another case, in a single row, all three divisions adjacent to one another.
The licensee cites the Sandia tests to conclude the acceptability of separation; however, we have found that the separation for the divisions in the auxiliary electrical equipment room is not adequate.
The configurations of cables do not permit a direct comparison between the Sandia test configurations and the ones found in the Auxiliary Electrical Equipment Room at Zion.
Because the Zjon configurations are different and because our site visit identified large cable concentrations with geometries dif ferent from those used at the Sandia tests, we do not accept the Sandia tests as appropriate ta these areas.
The licensee's analysis assumes a fire only in a row of panels and does not consider a fire in the overhead cabling.
The licensee has not identified which functions would be lost if a fire were to affect these panels.
We have reviewed the licensee's submittals and we find that the licensee has not provided sufficient justification for the following assumptions.
The licensee:
(a) has not assumed the coincident loss of offsite power, (b) has assumed limited fire damage, (c) has taken credit for manua: cperations without reference to the manpower required, (d) has not evaluated spurious activitation of components, and (e) has assured that all equipment auxiliaries, pumps, and valves are available.
We require that the licensee provide an alternate shutdown system to shut the plant dcwn independent of the auxiliary electrical equipment room.
Refer to the requirements under our evaluation comments for item 3.2.8 below.
3.2.8 Alternate Shutdown Caoability Our SER noted that if the proposed test program for the physical separation of electrical cables or the analysis of critical areas does not demonstrate thc capability to safely shut down exists, an alternate means will be provided for safe shutdown which is independent of fire damage in such areas.
Our SER identified several areas where redundant cables or equipment necessary to achieve and maintain safe shutdown conditions could be da.maged by an un..itigated fire. We noted in our SER that the licensee had not identified the systems, their associated electrical circuits,
. and electrical cables to determine the consequences of fires on safety-related cables which are routed in close proximity.
The separation of such cables and equipment and the rate at which fire could propagate through the cable trays was not sufficiently defined to give the staff reasonable assurance that a fire would not degrade safe shutdown capability beyond acceptable levels.
These areas are as follows:
5.1 Control Rcom 5.2 Cable Spreading Room 5.3 Containment Penetration Cable Vaults (acceptable) 5.4 Auxiliary Electrical Equipment Room 5.9 Auxiliary Building El 642' 5.10 Auxiliary Building El 617' 5.11 Auxiliary Building El 592' 5.12 Auxiliary Building El 579' 5.13 Auxiliary Building El 560' 5.14 Auxiliary Building El 543' 5.15 Reactor Centainment 5.17 Crib House As discussed earlier, the licensee has promised an analysis that shows alternate shutdown capability is not required independent of the control room.
With the exception of 5.3 Containment Penetration Cable Vaults, the staff does not have sufficient information to conclude that the separation is adequate for the fire areas 5.1 thru 5.17 above.
The licensee has not proviced sufficient basis to assure that fire damage could not result in the loss of safe shutdown capability.
We require an alternate shutdcwn system independent of fire damage in areas identified above as 5.1, 5.2, 5.4, 5.9, 5.10, 5.11, 5.12, 5.13, 5.14, 5.15 and 5.17.
The staff position on safe shutdown capability is presented in Enclosure 5.
i l
[
thLLUdVKL b s
STAFF POS!TfCH SAFE SHUT:0WN CAPAS8L8TY l
D ""]D D
' T Y h\\
oo3
,jj}{
j Staff Concern During the staff's evaluatien of fire ' protection programs at.
0;erating plants, one or mere specific plant areas may be identified l
in which the staff does not have adequate assurance that a postulated l
fire will net damage both redundant divisions of shutdown systems.
l This la:k of assurance in.;afe shutd:wn capability has resulted from one or both of the foilcwing situations:
(
Case A: The licensee has e:t adequately identified the j
systems and c mponents required for safe shutdown and their location in specific fire areas.
l Case 3: The licenses has nat dem:nstrated that the fire protecticn for specific plant areas will prevent damage to both redundant divisions of safe shutdcwn c:mpenents identified in these areas.
For Case A, the staff has required that an adequate safe shutdown i
analysis be perfer=ed. Tnis evaluation includes the identification 4
of the systems required fer safe shutdcwn and the lor:ation of the system ec=penents in.the plant. Where it is deter:ni.ied by this evaluatien that safe shutdcwn c:=ponents of both redundant divisions are located in the same fire area, the licensee is required to demenstrate that a pestulated fire will not da= age both divisions or provide alternate
[
shutd:wn capability as in Case B.
j i
For Case S, the staff may have recuired that an altemate shutdown l
capability be provided with is independent of the area of concern l
or the licensee may have preposed such a capability in lieu of 1
certain additicnal fire protection mdificatiens in the area. The specific : dificatiens associated with the area of concern along with other systa=s and equipment already independent of the area for:n the alternate shutdown capability. For each plant, the modifications needed and j
the c::binations of systems which prqvide the shutdown functions may be i
i unique for each critical area; however, the sh0tdown functions provided shculd =aintain plant parameten within,the bounds of the limiting l
safety consequences deemed acceptable for the design basis event.
l l
i Staff Position j
Safe shutdewn capability should be den:nstrated (Case A) or alte-nate shu:dewn capability provided (Case 3) in accordance with the guidelines pr:vided below:
l
- l. Cesien Sasis Event The design basis event for considerin'g the ne'ed for alternate t
shu:d:wn is a ; stulated fire in a specific fire area containing
[
reduncant safe shu:d:wn cables /etuipment in close proximity where it has been deter =ined that fire pr:tectica means cannot assure
- na: safe shu:::wn capability will be preservec. Two cases shculd be ::nsidered:
(1) offsite ;cwer is available; and (2) offsia l
- wer is not available.
i a
-~n
's
- 2. Umi. ine safe:v c: secuences and Recuimd shutdewn Functions
?.1 No ft'ssion pr: duct beundary in'tegrity shall be affected:
a.
No fuel clad damage; b.
No rupture of any pri=ary coolant boundary; c.
No rupture of the c:ntainment boundary.
2.2 The re.act:r c:elant system process variables shall be with n those predicted for a loss of normal ac power.
2.3 The alternate shutd:wn capability shall be able to achieve and maintain suberitical c:nditions in the reactor, maintain i
reae::r c: elan: inventory, a:hieve and maintain hot standby' c nditions (hot shu dewn' for a BWR) for an extended peried of time, achieve c:ld shutdown
- c:nditions within 72 l
hours and maintain cold shutdown cend-ltions thereafter.
As defined in the Standard Technical Specificatiens.
- 3. perfo:-nance Geals 3.1 The' reactivity c:ntrol function shall be capable of achieving and :daintaining cold shutdown reactivity conditions.
3.2 The react:r c::lant makeup functica shall be capable of maintaining the nactor c: plant level above the top of the core for SWR's and in the pressurizer for PWR's.
3.3 The react:r heat rem: val function shall be capable of achieving and =aintaining decay heat removal.
3.4 The process ::nitoring function shall be capable of providing dire:t readings of the process variables necessary to perfor::: and c:ntrol the above functions.
- 3. 5 The supporting function shallle capable of providing the process cooling, lubrication, etc necessary to permit the operatien of the equipatnt used for safe shutdown by the systems identified in 3.1 - 3.4.
3.5 3e ecuipment and systems used to achieve and maintain hot standby c:ndittens (hot shutdown for a 3WR) should be (1) free of fi.e damage; (2) capable of maintaining such c:nditiens for an ex:anded ti:ne period longer than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> if the equi; e..s required to achieve and maintain cold shutdown is nc available due to fire damage; and (3) capable of being powered by an onsite emergency power system.
3.7 he ecuipcen and systems used to' achieve and maintain cold shu:d:wn c:ndi i:ns should be either free of fire damage or the fire damage :: such systams should be limited such tha re: airs :an be':ade and cold shutd:wn c:nditions achieved l
wi:nin 72 h:urs.
Ecuipment and systems used prior to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> af er -he fire sh:uld be capable of being powered by an onsite j
amergency p:wer system; : nose used after 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> may be powered by t
D**]D "]D}S k 3' l 5
oom o mu
_a P
-3 offsite power.
These syste.T.s need not be designed to (1), seismic category I 33 criteria; (2) single failure criteria; or (3) cope with other plant accidents such as pipe breaks cr stuck valves (Appendix A STp 9.5-1), except those portiens of these i
systems which interface with or impact existing safety systems.
- 4. PN Ecutement Generally Necessarv For Hot Standby _
I (1)
Reactivity Centrol' Reactor trip capability (scram). Scratien capability e.g.,
l charging pump, =akeup pump or high pressure injection pump taking suction from concentrated borated water supplies,
~ ~..
i and letdown system if required.
(2) panctor Coolant Makeuo I
Reactor coolant makeup capability, e.g., charging pugs t
or the high pressure injection pu=ps. Power eserated relief valves may be required to reduce pressure to allow use of the higit pressure injection pt..:ps.
(3) Reacter Coolant System pressure Control _
Reactor pressure centrol capability, e.g., charging pumps t
or pressurizer heaters and use of the letdewn systems
~~
r if required.
(4)
Cecay Heat Removal f
Cecay heat rem: val capability, e.g., power c;erated relief valves.(steam generator) or safety relief valves for heat removal with a water supply and emergency or auxiliary Service j
fesewater pumps for makeup to the steam generator.
water or other pumps may be required to provide water for auxiliary feed pump suction if the condensate storage tank capacity is
+
not adequate for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />..
(5)
Process M nitoring Instrumentation Process monitoring capability e.g., pressuriter pressure and level, steam generator level.
\\
(5)
Succort.
The equipment required to support cperatien of the above described shutdcwn equi; rent e.g., ccmpenent cooling water service water, etc. and ensite power scurces (AC, DC) with their associated electrical distributien system.
l l
i W
-4.
- 5. FWR Ecutement Generally Necessary For cold Shutdew (1) Reacter coolant System Pressure Reductien to Residual Heat Aecevai sys em iRnR) caca:3 i ny Reacter coolant system pressure reduction by c:old:wn using steam generat:r power operated relief valves or at=: spheric dump valves.
(2) Dacay Heat Rereval_
Cecay heat rer. oval capabi ity e.g., residual heat removal system, c =penent cooling water system and service water system to rem: val heat and maintain cold shutdown.
(3) Succort Support capability e.g., ensite power sources (AC 4 DC) l or offsite after 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and the associatad electrical distribution system to supply the above equiprent.
t
' Equi;=ent necessary in addition to that already provided to maintain hot standby.
- 6. BWR Ecuiement Generally Necessary For Het Shutdown (1) Reactivity Centro 1_
Reactor trip capability (scram).
(2) Reactor Coolan: Makeuo Reactor coolant inventory (makeup capability e.g., reactor core isolatten cooling system RCIC) er the high pressure coolant injection system (HPCI).
(3) Reactor Pressure Centrol and 6ecay Heat Removal l
De'pressuri:ation system valves or' safety relief valves for du=p to the suppression pool.
The residual heat re.cyal T
system in steam cendensing cde, and service water system i
may also be used for heat removal to the ultimata heat sink.
(?) Suceressien Fe:1 C: cline Residual heat rem val systam (in suppression ;ool ecoling mode) service water system to r.aintain het shutdcwn.
(5)
Process ".:nitorine Pr'ecess =eni : ring capability e.g., reactor vessel level and pressure and su:oressi:n pcol te=:erature.
(5) Sue: ort Support capability e.g., :nsite pewer s:ur:s (AC 1 DC) and their associated distribution systems to provide for the shutd:wn equi; ment.
l
- 7. 3'.!R Eeui:=ent Ganerally Necessarv For Cold Shutdown?
At'this point the equipment necessary for het shutdown has reduced the primary system pressure and temperature to where the PJiR system may be placed in service in MR cooling mode.
(1) Decay Heat Removal Residual heat re cyal system in the MR cooling ::cde, service water system.
(2) Su mort Onsite sources (AC & DC) or offsite after 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and their associated distribution systems to pr: vide for shutdown equipmen..
r Equipment provided in additien to that for achieving het shutdewn.
- 3. Infor=ation Recuired For Staff Review i
(a) Description of the systems' or portions thereof used to provide the shutdown capability and modifications retuired
, to achieve the alternate shutd:wn capability if required.
l (b) System design by drawings which shew nomal and alternate shutdown centrol and pcwar circuits, location of components, and
. that wiring wnich is in the area and the wiring which is cut of the area that required the alternate system.
(c) Demonstrate that changes to sa'fety systems will not degrade safety systems.
(e.g., new isolation swit:hes and centrol switches shculd meet design criteria and standards in FSAR for electrical equipment in the system that the switch is to be installed; cabinets that the switches are to be mounted in should also meet the same criteria (FIAR) as other safety r?. lated cabinets and panels; to avoid inadvertent isolation from the c:ntrol recm, the isolatien swit:hes should be keylocked, or alarmed in the control re:m if in the " local" or " isolated" ;osition; periodic checks shculd be made to verify switch is in the pr::er positten f:r nomal c:eration; and a single transfer switch or other new device shculd not be a scur:e for a single failure to cause less of redundant safety sys:ams).
(d)
Demonstrate that wiring, including power scurces for the c:n:rol circuit and equipment coeration for the alternate shu:dewn methed, is independent of equipment wiring in the area :: be avoided.
l n
Th kmE.$1MN gmw D
^
s
-6 (e)
Demonstrate that alternate shutd:wn power scurces, including all breakers, have isolation devices en c:ntr:1 circuits that are routed through tho area to be avoided, even if the breaker is to be cperated manually.
(f)
Demonstrate that licensee pr:cedure(s) have been develcped which describe the tasks to be parformed to effect the shutdewn rethod. A su:ntary of these precedures should be reviewed by the staff.
(.g)
Demonstrate that spare fuses are available'for control i
circuits where these fuses,may be required in supplying
- wer to c
- ntrol circuits used for the shutdown rathed and may be bicwn by the effects of a cable spreading l
re:m fire. The spare fuses should be located convenient to :he existing fuses. The shutd:wn procedure should inform, the cperator to check these fuses.
(h)
Demonstrate that the manpcwer required to perfom the shutdown functions using the procedures of (f) as well as to provide fire brigade members to fight the fire is available as required by the fire brigade technical s pecifications.
F (i) Demon' strate that adequate ac:eptance tests are perfcmed.
These shculd verify that: equipment operates from the local control stati:n when the transfer or isolation switch is placed in the " local" nesitien and that the equipment i
cannet be operated frem the c:ntrol reem; and that equip-rent operates frem the c:ntrol re:m but cannot be operated at the local c:ntrol statien when the transfer or isolation switch is in the "remota" position.
l (j) Technical Specificatiens of the surveillance requirements and limiting c:nditions for cperation for that equipment not a'iready c:vered by existing Tech. Specs. For exa: sle, i
i if new isolation and control gwjtches are added to a service wa:er system, the existing Tech. Spec. surveillance require-ments en the service water system should add a state ent similar to the fo11cwing:,
1 "Every third pump test should also verify that the pu=p starts from the alternate shutdewn station after moving all service water system isolatien switches to the local c:ntrol pcsitien."
(k) Cemonstrate that the systams available are adequata to perform 1
i the necessary shutdown functions. The functions required shculd be based en previcus analyses, if pessible (e.g.,
i in the FSAR), such as a less of normal a.c. ;ower or shutdown
~
- n a Gr:up I isolatien (SWR). The equipment required for the l
I al:ernate ca: ability should be the same Or ecuivalent to
- .at relied :n in the above analysis.
f u
h e
~
~-
e,
' O e
7-(1)
Demonstrate that repair precedures for cold shutdewn systems are deveicped and material for repairs is mintair.ed :n sita.
h p
'D**]D D TTA a e ju e A..d.
c' i
.