ML19350D197
| ML19350D197 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 04/07/1981 |
| From: | Stolz J Office of Nuclear Reactor Regulation |
| To: | Hancock J FLORIDA POWER CORP. |
| References | |
| NUDOCS 8104130757 | |
| Download: ML19350D197 (6) | |
Text
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UNITED STATES yq)*
NUCLEAR REGULATORY COMMISSION 7 i O
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WASHINGTON, D. C. 20555 April 7,1981 i
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Docket NO. 50-302 l
Mr. J. A. Hancock Director, Nuclear Operations Florida Power Corporation P. O. Box 14042, Mail Stop C-4 St. Petersburg, Florida 33733
Dear Mr. Hancock:
SUBJECT:
FIRE PROTECTION - ALTERNATE SHUTDOWN CAPABILITY - ITEM 3.1.15 By letter dated December 17, 1979 you provided information on an alternate safe shutdown system at Crystal River Unit 3.
Enclosure No.1 provides our Interim Safety Evaluation of your December 17, 1979 submittal.
Our Final Safety Evaluation will be issued after our review of your submittal of the design description required by 10 CFR 50.48(c)(5). You are requested to resolve the concerns raised in the enclosed evaluation in that submittal. The schedule requirements for your response will be specified in our response to your March 19, 1981 request for exemption from the sub-mittal date requirement of 10 CFR 50.48(c)(5),
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U.L s Ja n F. Stolz, Chie erating Reactors Branch #4 Division of Licensing
Enclosure:
Interim Safety Evaluation cc w/ enclosure:
e-N See next page
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i Crystal River Unit No. 3 50-302 Florida Power Corporation i
cc w/ enclosure (s):
Mr. S. A. Brandimore Mr. Robert B. Borsum Vice President and General Counsel Babcock & Wilcox P. O. Box 14042 Nuclear Power Generation Division St. Petersburg, Florida 33733 Suite 420, 7735 Old Georgetown Road Bethesda, Maryland 20014 Mr. Wilbur Langely, Chairman Board of County Commissioners Mr. Tom Stetka. Resident Inspector Citrus County U.S. Nuclear Regulatory Commission Iverness, Florida 36250 Routa #3. Box 717 Crystal River, Florida 32629 U. S. Environmental Protection Agency Region IV Office Mr. Dan C. Poole ATTN: EIS COORDINATOR Nuclear Plant Manager 345 Courtland Street, N.E.
Florida Power Corporation Atlanta, Georgia 30308 P. O. Box 219 Director, Criteria and Standards Crystal River, Florida 32629 Division Office of Radiation Programs (ANR-460)
U. S. Environrental Protection Agency Washington, D. C. 20460 tsundau of Intergovernmental Relations 660 Apalachee Parkway Crystal River Public Library Tallahassee, Florida 32304 668 N. W. First Avenue Crystal River, F1orida 32629
-l Mr. J. Shreve j
The Public Counsel Room 4 Holland Bldg.
Tallahassee, Florida 32304 Administrator Department of Environmental Regulation Power Plant Siting Section State of Florida 2600 Blair Stone Road Tallahassee, Florida 32301 Attorney General Department of Legal Affairs i
The Capitol Tallahassee, Florida 32304 l
Or. William R. Stratton Los Alamos Scientific Lab Box 503 Los Alamos, New Mexico 87544 b' l e
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INTERI!! SAFETY EVALUATION REPORT BY THE OFFICE OF NUCLEAR REACTOR
- I REGULATION POST FIRE SHUTDOWN CAPABILITY CRYSTAL RIVER NUCLEAR POWER PLANT - UNIT #3 i
Section 3.1 of the SER, Safe Shutdown Systems, states that a remote safe shutdown control station will be installed which it independent of the control room or cable spreading room. Sections 5.3, 5.4, 5.7 and 5.8 state that the licensee will do an analysis that demonstrates that the redundant safe shut-down system will not be damaged by an unsuppressed fire in these areas.
By letter dated December 17, 1979 the licensee addressed Section 3.1 of the SER requirements. Further information was received from the licensee by a conference call on February 17, 1981.
The licensee proposes to install a remote shutdown panel in the 4160 volt emergency switchgear room 3B. From this panel the licensee plans to be able to control the safe shutdown of the plant in the event of the loss of the cable spreading room or the control room due to a fire.
The licensee has not stated which system will be used to achieve alter-native shutdown.
Instead, he has listed 16 systems and given a brief descrip-tion of each, stated whether it would be used for hot or cold shutdown (most were for both), and referred to the final safety analysis report for further infonnation.
Included in this list is equipment that cannot be used for either hot or cold shutdown because this equipment requires the use of off-site power.
The submittal does not address the alternative shutdown capability in the areas noted in Sections 5.3, 5.4, 5.7 and 5.8; and therefore the licensee is relying on fire protection methods in these areas.
No fire protection ap-plications are noted in the submittal of December 17, 1979.
Considerable ef-f art has gone into addressing isolation for safety-related circuits in both tie proposed remote shutdown panel and in local shutdown stations.
We have evaluated the Crystal River post fire shutdown capability using MC guidelines " Staff Position, Safe Shutdown Capability" dated June 19, 1979
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and NRC requirements in Section III.L of Appendix R to 10 CFR Part 50. We rave found that:
1 1.
Although the licensee has addressed the isolation of certain safety related circuits, the post fire shutdown capability has not been completely shown to be isolated from associated circuits so that fire damage to associa;ed circuits in a fire area may prevent the operation of shutdown equipment.
In the telephone call of February 17, 1981 the licensee stated that the isolation devices used are remote switches and relays; the relay contacts are to provide isolation. However, the licensee stated that it was possible that these isolation devices were not Class 1 even where used at the interface of Class 1 equipment.
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' 2.
Support functions could be Icst with a fire in the control room or cable spreading room. An example of this is the electric control for valves EFY-3 and ARV-48F and 49F; these valves are necessary for i
emergency feedwater system operation.
When off-site power is lost, the cooling water for both emergency feedwater pumps is lost.
I 3.
The post fire process monitoring function has not been shown to be capable of providing direct readings of the process variables neces-sary to perform and control shutdown functions. The licensee has not shown that indication will be provided for: pressurizer pressure t
and temperature, condensate storage tank level, auxiliary feed water flow or radiation levels.
4.
The licensee has not as yet demonstrated that repair procedures for cold shutdown systems are fully developed and r.aterial for repairs is maintained on site.
5.
The Itcensee's submittal calls for cold shutdown repairs including j
the use of jumpers. However, by the telephone conversatio.1 of February 17, 1981 we were advised by the licensee that the remote shutdown panel plans are being revised so that jumpers will not be required for hot or cold shutdown.
i 6.
The submittal was not clear as to whether or not cold shutdown could be achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
In the phone call of February 17, 1981 i
the licensee did not give assurance that this objective could be met.
7.
Hot and cold shutdown procedures are not fully prepared.
8.
Repairs for pressur'izer heater controls are planned for pressurizer e
use in both hot and cold shutdown.
9.
The post fire shutdown capability depends on fire protection 7
measures in the following areas: auxiliary building at elevations I
119 feet and 95 feet and intermediate building at elevations 119 feet and 95 feet.
These protection features should meet the re-quirements of Section III.G of Appendix R to 10 CFR Part 50.
We conclude that the proposed alternate shutdown capability for the Systsi River Nuclear Power Station does not conform with NRC guidelines and reca rements and, therefore, is unacceptable.
j We recomend the following:
A.
The alternative shutdown capability should be modified to meet the requirements of Se: tion. III L of Appendix R to 10 CFR Part 50, tak-ing into consideration the above findings.
B.
The process monitoring should be shown to be capable of providing direct readings of the process variables necessary to,:entrol re-
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activity, reactor coolant rakeup, and reactor heat removal.
Pe ma-
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nently installed instruments shoula be used to provide capability e
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3-for reading: pressurizer pressure, temperature and level, reactor coolant loop temperature, steam generator level and pressure, auxiliary feedwater flow, and condensate storage tank level and radiation levels.
'i C.
All repair procedures should be fully developed and it should be verified that the materials for the repairs are maintained on site.
Repairs should not be used in getting to hot shutdown.
D.
All support functions should be available for the equipment used in the alternative shutdown capability. The ifcensee should either i
justify their claim that they have " sufficient time" for manual i
operation or provide isolation for the cirucits involved.
E.
The ability to achieve safe shutdown in each plant area where a fire is postulated must be shown.
F.
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 heur fire rating or equivalent protection (see Sec-tion III.G.2 of Appendix R).
Therefore, if option III.G.4 is chosen for the protection of shutdown capability, cabling required for or associated with the alternative method of hot shutdown for each 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 to ground.
Safety related and nonsafety related cables that are associated with 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 ccordinated 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 isolation 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 accordance with Section III.G.3 of Appendix R 10 CFR Part 50 is provided by proposed codifications the following information 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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s, l (1) Provide a table that lists all equipment including instrumenta-tion and support system equirnent that are required by the alternative or dedicated method of achieving and maintaining i
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.
(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 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.
G.
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 Sanch Technical Position RSB 5-1.
Thus, this interface most likely consists of two redundant and independent motor operated valv'es.
These two motor operated valves and their associated cable may may be subject to a single fire hazard.
It is our concern that this single fire could cause the two valves to open resulting in a fire-initiated LOCA through the subject high-low pressure system interface.
To assure that this interface and other high-low pressure interfaces are adequately protected from the ef-fects of a single fire, we require the following infomation:
Identify each high-low pressure interface that uses redundant electrically controlled devices (such as two series motor oper-ated 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-l tion.
Identify each location where the identified caoles are separated by less than a wall having a three-hour fire rating from cables l
for tne redundan. device.
For the areas identified in tne above paragraph, provide the bases and justification as to the acceptability of the existing design or any proposed modifications.
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