ML19347D461
| ML19347D461 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 03/09/1981 |
| From: | Clark R Office of Nuclear Reactor Regulation |
| To: | William Jones OMAHA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 8103170716 | |
| Download: ML19347D461 (6) | |
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UNITED ST ".TE3 I
- 1 NUCLEAR REGULAToi.Y CO.. 'f _ J c y, [ ' j WASmr:GTON, D. C. NCLS o., b M
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March 9, 1981 Docket No. 50-285 A
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.9 Mr. W. C. Jones o
Division Manager, Production Operations d,AR1g39OIA C F.
u.a.DasDmn Omaha Public Power District
-1623 Harney Street s
Omaha, Nebraska 68102
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Dear Mr. Jones:
g In accordance with our February 10, 1981 letter related to the Fort Calhoun Station's fire protection program, we are forwarding the Interim Report for Post Fire Shutdown Capability prepared for the NRC by our consultant, Brookhaven National Laboratory (BNL). The NRC staff has reviewed this report and agrees with BNL's conclusion that the proposed modifications and systems do not meet the criteria presented in Appendix R to 10 CFR Part 50.
As stated in our February 20, 1981 letter, 10 CFR Part 50.48(b) requires all nuclear plants licensed to operate prior to January 1, 1979 to meet the requirements of Sections III.G, III.J and III.0 of Appendix R to 10 CFR Part 50.
The NRC reviewof the fire protection program for the Fort Calhoun Station indicates that the provisions of Section III.J and III.0 are satisfied but the provisions of Section III.G are not.
In order for us to resolve this issue, we request that you provide the information required by 10 CFR 50.48(c)(5), to be submitted by March 19, 1981, by incorporating those applicable portions of the infor ation request in the attached report and providing the remainder of the requested information contained in the attached report and the staff's February 20, 1981 letter by May 19, 1981.
The NRC Staff reccgnizes that the recommendations in Section I of BNL's report are germane to the Wash 1400, Event V reviews, which are being conducted; however, this review has not considered the decay heat removal suction path which contains the valve configuration of concern expressed in the attached report.
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If you have any questions on this subject, please contact your NRC Project Manager.
Sincerely,
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W Robert A. Clark, Chief Operating Reactors Branch #3 Division of Licensing
Enclosure:
As stated cc: See next page
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Omaha Public Power District cc:
Marilyn A. Tebor Director, Criteria and Standards Division LeBoeuf Lamb, Leiby & MacRae Office of Radiation Programs (ANR-460) 1333 New Hampshire Avenue, N.W.
U.S. Environmental Protection Agency Washington, D. C.
20036 Washington, D. C.
20460 Mr.,Emmett Rogert U.S. Environmental Protection Agency Chairman, Washington County Region VII Board of Supervisors ATTN: EIS C0ORDINATOR Blair, Nebraska 68023 324 East lith Street Kansas City, Missouri 64106 Omaha Public Power District ATTN: Mr. Spencer Stevens Plant Manager Fort Calhoun Plant 1623 Harney Street Omaha, Nebraska 68102 Director, Nebraska Department of Environmental Control Mr. Frank Gibson P. O. Box 94877, State House Station W. Dale Clark Library Lincoln, Nebraska 68509 215 South 15th Street Omaha, Nebraska 68102 Alan H. Kirshen Esq.
Fellaan, Ramsey & Kirsten 1166 Woodmen Tower Omaha, Nebraska 68102 Mr. Dennis Kelley U.S.N.R.C. Resident Inspector P. O. Box 68 Fort Calhoun, Nebraska 68023 -
Mr. Charles B. Brinkman Manager - Washington Nuc* ear Operations C-E Power Systems Conbustion Engineaing Inc.
4853 Cordell Avenue, Suite A-1 Bethesda, Maryland 20014
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t INTERIM REPORT POSY FIRE SHUTD0iN CAPA3ILITY FORT CALHOLN NUCLEAR PO'nER STATICN Section 3.1.21 of the SER, Alternate Shutdown Capability states that the licensee has agreed to provide alternate shutdown capability, independent of cabling in the cable spreading rom and the control room tc preserve safe shu,tdown capability in the event of a fire in these areas.
By letters dated October 12 and Mcvember 15, 1979 the licansee has ad-dressed tnis requirement in two documents, one entitled " Alternate Shutdown Capability, Final Design Description" dated October 10, 1979, revised January 1980 and the other, " Alternate Shutdom Capability, Cold Shutdown Phase" dated November 17, 1979, revised March 1980. Further infomation was received from the licensaa by a conference call on January 30, 1981.
The alternative shutdown capability relies on existing system equipment with manual realignments to achieve hot and cold shutdown. The alternative shutdown capability for the cable spreading room and the control room relies very little on existing or proposed fire protection metMds. A charging pump is used for reactor coolant makeup; the existing auxiliary feed water systes is used for steam generator makeup; pressurizer heaters and spray are used for pressure control; decay heat removal is also accomplished with the auxiliary feed water systes and the dumping of the secondary steam to atmosphere with the main steam safety relief valves. Cold shutdown relies on this same equip-I ment as well as auxiliary pressurizer spray and the low pressure safety injec-tion system.
The areas addressed for alternate shutdown capability are the cable spreading roam and the control room.
We have evaluated the Fort Calhoun post. fire shutdown capability uting NRC guidelines " Staff Position, Safe Shutdown Capability" dated June 19, 1979 and NRC requirements in Section III L of Appendix R to 10 CFR Part 50. We have found that:
1.
The post fire support functions have not been shown to be capat ie i
of providing the auxiliary systems such cs process cooling or lubrication necessary to permit the opeeation of equipment used for shutdown functions. This is shown in tr.e hot shutdown submittal, paragraph 4.6 where the licensee indicates that the component cool-ing pumps will not be available to provide cooling for the charging pumps. The availability of otMr support functions is not clear.
2.
The heat tracing for the boric acid gravity reed line will not be available. The licensee stated in t": csnference call of January 30, 1981 that it would not be needed because the system was all in-side at roaa temperature. The licensee has not stated at what ten-perature the boric acid would be at the time of boration and whether or not the technical specifications for boric acid con-centration would be met.
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3.
The diesel fire pump is to be used to provide water to the emergency auxiliary feedwater tank one hour after the initial reactor trip.
4.
The post fire shutdown capability has not been shown to be isolated from associated circuits so that fire damage to associated circuits in a fire area may prevent tne operation of shutdown equipment.
5.
The post fire process monitoring function has not been shown to be capable of providing direct readinos of the process variables neces-sary to perform and control shutdown functions. An example of this is the repair procedure where the licensee proposes to temporarily connect a Wheatstone bridge to resistancJ temperature detection ex-tensien leads in order to determine reactor coolant system tem-perature. The licensee stated that he did not plan to use steam generator status indication, or flow indication.
6.
The licensee has not as yet demonstrated that repair procedures for cold shutdown systems are fully developed and material for repairs is maintained on site.
7.
The post fire shutdown capability depends on fire protection mea-sures in the following areas: Fire area 6 - cable tray and person-nel corridor; Fire' Area 20 - personnel corridor; Fire Area 32 com-pressor area; Fire Area 34 - electrical penetration area; and Fire Area 36 - switchgear room. These protection features should meet the NRC requirements oof 5 action III G of Appendix R to 10 CFR 50.
We conclude that the proposed alternative shutdown capability for the Fort Calhoun Nuclear Power Station does not conform with NRC guidelines l
and requirements and, therefore, is unacceptable.
i We recommend the following:
A.
The alternative shutdown capability should be modified to meet the requirements of Section III L of Appendix R to 10 CFR Part 50, tak-ing into consideration the above findings.
B.
The supporting functions should be capable of providing the process cooling, lubrication, etc. necessary to permit the operation of the equipment used for safe shutdown by the systems identified as part of the alternate shutdown capability. All of the support functions should be available for the equipment used in the alternative shut-down capability.
C.
The licensee should verify that the existing technical speci-fications for boric acid concentration are adhered to with the absence of heat tracing.
D.
The water requirements for core cooling should be met witnout using the diesel fire pump or other equipment designed for fighting fires.
A separate pump not associated with the fire protection water system should be used to produce water for the auxiliary feedwater tank.
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E.
The process monitoring shoeld be shown to be capable of providing direct readings of the process variables necessary to control re-activity, reactor coolant makeup, and reactor heat removal. Pe rma-nently installed instruments should be used to provide capability for rtading pressurizer pressure, tenperature and level, reactor coolant loop temperature, steam generator level and pressure, auxiliary feed water flow, and condensate storage tank level and radiation levels.
All repair procedures she id be fully developed and it should be F.
n verified that the caterials for the repairs are maintained on site.
G.
The manpower for these procedures should be shown to be available on site and the work to be perforned. should be reasonable in light of the manpower available.
H.
Section III.G of Appendix R to CFR Part 50 requires cabling for or associated with redundant safe shutdown systems necessary to achieve and maintain hot shutdown conditions be separated by fire barriers having a three hour fire rating or equivalent protection (see Sec-tion III.G.2 of Appendix R). Therefore, if option III.G.3 is chosen for the protection of shutdown capability cabling required for or associated with the alternative method of hot shutdown for eac% fire area, must be physically separated by the equivalent of a three-hour rated fire barrier from the fire area.
In evaluating an alternative shutdown method, associated circuits are circuits that could prevent operation or cause malfunction of the alternative train which is used to achieve and maintain hot shutdown conditions due to fire induced hot shorts, open circuits, or shorts the ground.
Safety related and nonsafety related cables that are associated with l
the equipment and cables of the alternative or dedicated method of shutdown are those that have a separation from the fire area less than that required by Section III.G.2 of Appendix R to 10 CFR 50 and have either (1) a common power source with the alternative shutdown equipment and the power source is not electrically protected from the post fire shutdown circuit of concern by coordinated circuit breakers, fuses, or similar devices, (2) a connection to circuits of equipment whose spurious operation will adversely effect the shut-down capability, e.g., RHR/RCS isclation valves or (3) a. common en-closure, e.g., raceway, panel, junction box with alternative shut-down cables and are not electrically protected from the post fire shutdown circuits of concern by circuit breakers, fuses, or similar devices.
For each fire area where an alternative or dedicated shutdown method, in accor' dance with Section III.G.3 of Appendix R 10 CFR Part 50 is provided by proposed modification the following informaticn is required to demonstrate that associated circuits will not prevent operation or cause malfunction of the alternative or dedicated shutdown method.
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(1) Provide a table that lists all equipment including instmenta-tion and support system equipment that are required by the alternative or dedicated method of achieving and maintaining hot shutdown.
(2) For each alternative shutdown equipment listed in (1) above, provide a table that lists the essential cable (instrumenta-tion, control and power) that are located in the fire area.
i (3) Provide a table that lists safety related and nonsafety related cables associated with the equipment in cables constituting the alternative or dedicated method of shutdown that are located in the fire area.
(4) Show that fire induced failures of the cables listed in (2) and (3) above will not present operation or cause malfunction of i
the alternative or dedicated shutdown method.
(5) For each cable listed in (2) above provide a detailed elec-trical schematic drawing that show how each cable is isolated from the fire area.
I.
The residual heat removal system is generally a low pressure system that interfaces with the high pressure primary coolant system. To preclude a LOCA through this interface, we require compliance with the recommendations of Banch Technical Position RSB 5-1.
Thus, this interface most likely consists of two redundant and independent motor operated valves. These two motor operated valves and their associated cable may be subject to a single fire hazard. It is our concern that this single fire could cause the two valves t' noen resulting in a fire-initiated LOCA through the subject high-low pressure system interface. To assure that this interface and ot..ar f
high-low pressure interfaces are adequately protected from the ef-fects of a single fire, we require the following infomation:
l Identify each high-low pressure interface that uses redundant electrically controlled devices (such as two :eries motor oper-cted valves) to isolate or preclude rupture of any primary cool-ant boundary.
Identify the device's essential cabling (power and control) and describe the cable routing (by fire area) from source"to temina-tion.
Identify each location where the identified cables are separated by less than a wall having a three-hour fire rating from cables for the redundant device.
For the areas identified in the above paragraph, provide the bases and justification as, to the acceptability of the existing design or any proposed modifications.
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