ML20004F413
| ML20004F413 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek, Callaway  |
| Issue date: | 06/15/1981 |
| From: | Petrick N STANDARDIZED NUCLEAR UNIT POWER PLANT SYSTEM |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| SLNRC-81-45, NUDOCS 8106180313 | |
| Download: ML20004F413 (15) | |
Text
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SNUPPS si ne.,ei e w.i,unie Posse, Mont Sy.eene s t,aoke cherry n d Nicholas A. Petrick vil land 200e0 Executive Director June 15,1981 SLNRC 81-45 FILE: 0541 SUBJ: NRC Request for Additional Infonnation - 10 CFR 50, Appendix R Mr. Harold R. Denten, Director)
Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, f C.
20555 Docket Nos:
"TN 50-482, STN 50-483, STN 50-486
References:
1.
NRC (Tedesco) letter to' Union Electric (Bryan),
dated May 15, 1981,- Request for Additional Infonnation - Callaway 2.
NRC (Tedesco) letter to Kansas Gas and Electric (Koester), dated May 27, 1981, Request for Additional Information - Wolf Creek
Dear Mr. Denton:
The referenced letters requested infonnation concerning compliance to 10 CFR 50, Appendix R - Fire Protection. The enclosure to this letter provides a comparison of the SNUPPS standard plant design to the applicable provisions of Appendix R.
The enclosure will be incor-porated into the SNUPPS FSAR in the next revision.
Very truly yours K
Nicholas A. Pe ck RLS/mtk
,9,g gy'O Enclosure
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J. K. Bryan UE y
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T. E. Vandel USNRC/WC j
W. A. Hansen USNRC/ CAL J
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SNUPPS s
Q280.0 FIRE PROTECTION Notification of Appendix R to 10 CFR Part 50 as a Licensing Requirement 280.6 Appendix R to 10 CFR Part 50 will also be used as guidance for our review of your fire proL:ction program.
Your compliance with the requirement set forth in Appendix R as modified by accepted excep-tions will be made a license condition.
Identify any exceptions your program takes to the require-ments of Appendix R as well as BTP ASB 9.5-1, and describe your alternative for providing an equivalent level of fire protection.
RESPONSE
See Appendix 9.5(E) for a design comparison to Appendix R of 10 CFR Part 50.
See Appendix 9.5 (A) for a design comparison to BTP APCSB 9.5-1.
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SNUPPS APPENDIX 9.5E This question response provides a design comparison to 10 CFR 50 Appent,ix R, Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979.
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SNUPPS 10 CFR 50 Appendix R SNUPPS III.A Water Supplies for Fire Suppre's-Refer to each Site Addendum.
sion Systems III.B Sectional Isolation Valves Refer to each Site Addendum.
III.C: Hydrant Isolation Valves Refer to each Site Addendum.
III.D Manual Fire Suppression Standpipe and hose systems shall be Complies.
Wet standpipes installed no that at least one effective for power block fire hoses hose stream will be able to reach any are designed in accordance location that contains or presents an with the requirements for cxposure fire hazard to structures, class II service of NFPA cystems, or components important to No. 14-1976.. Hose racks cafety.
are located so that no mdre than 100 feet separates Access to permit effective functioning adjacent hose racks.
Access of the fire brigade chall be provided to to permit fur.ctioning of the all areas that contain or present an fire brigade is adequately cxposure fire hazard to structures, provided and is discussed cystems, or components important to in Appendix 9.5B.
cafety.
The standpipe system for Standpipe $ndhosestationsshallbe the containment is supplied inside PWR containments and BWR con-from the fire main loop tainments that are not inerted.
Stand-through a safety-grade pipe and hose stations inside contain-containment penetration.
ment may be connected to a high quality The containment standpipes water supply of sufficient quantity and are normally dry and may pressure other than the fire main loop be charged by operator if plant-specific features prevent action at the control room.
cxtending the fire. main supply inside containment.
For BWR drywells, stand-Each hose rack is provided pipe, and hose stations shall be placed with 75 feet of 1-1/2-inch outside the dry well with adequate hose, except the diesel lengths of hose to reach any location generator room which has inside the dry well with an effective 100 feet of hose.
hose stream.
III.E Hydrostatic Hose Tests Refer to each Site Addendum.
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C SNUPPS 10 CFR 50 Appendix R SNUPPS III.F ~ Automatic Fire Detection Autc.iatic fire detection systems shall Automatic fire and smoke he installed in all areas of the plant detector systemp are that contain or present an exposure provided througnout the fire hazard to safe shutdown or safety-plant on the basis of the fire hazards analysis and related systems or components.
These fire' detection systems shall be capable consequences of specific of operating with or without offsite postulated fires.
A dis-cussion of, detector types power.
and specific locations is provided in Appendix 9.5B on an area-by-area basis.
Certain areas which con-tain safety-related equip-ment, but have negligible amounts of combustibles and are separated from adjacent areas by 3-hour fire barriers do not have automatic detectors.
The only such areas that are related to safe shut-down are auxiliary feed-water valve compartments, A-29 through A-32, and RHR Heat Exchanger Rooms A-9 dnd A-10.
As indicated in Section 9.5.1.2, the fire detec-tion system is provided with a backup battery power supply.
The batteries are served by a battery charger that can be manually III.G Fire Protection of Safe Shutdown connected to the plant Capability emergency ac power supply.
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Fire protection features shall FSAR Appendix 9.5B pro-be provided for structures, vides an area-by-area systems, and components impor-analysis of the SNUPPS tant to safe shutdown.
These power block that demon-features shall be capable of strates that no single limiting fire damage so that:
fire can prevent safe shutdown.
a.
One train of systems neces-sary to achieve and main-Redundant trains of sys-tain hot shutdown condi.
tems required to achieve and tions from either the maintain hot standby are separated by 3-hour-rated fire barriers, or the equivalent provided by 9.5E-2 L
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~w-l SNUPPS 10 CFR 50 Appendix R SNUPPS control room or emergency III.G.2, or else a diverse control station (s) is free means of providing the of fire damages; and safe shutdown capability exists and is unaffected b.
Systems necessary to achieve by the fire.
and maintain cold shutdown from either the control For redundant trains of room or emergency controi systems required to achieve station (s) can be repaired and maintain cold shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
that could potentially be affected by a single fire, 2.
Except as provided for para-graph G.3 of this section, repairs or local where cables or equipment, operator. actions can be including associated non-safety performed within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
circuits that could prevent operation or cause maloperation As described in Appendix due to hot shorts, open circuits, 9.5B and Section 7.4, an or shorts to ground, of redundant auxiliary shutdown panel trains of systems necessary to is provided as a dedicated achieve and maintain hot shut-means of achieving and down conditions are located maintaining hot standby in within the same fire area the event that the main outside of primary containment, control room is unihabit-one of the fo116 wing means of able due to a fire.
ensuring that one of the redun-dant trains is free of fire Refer to each Site Addendum damage shall be provided:
for site-related structures.
a.
Separation of cables and equipment and associated non-safety circuits of redundant trains by a fire barrier having a 3-hour rating.
Structural steel forming a part of or sup-porting such fire barriers shall be protected to provide fire resistance equivalent to that required of the barrier; e
b.
Separation of cables and equipment and associated non-safety circuits of redundant trains by a i
horizontal distance of more than 20 feet with no inter-vening combustible or fire hazards.
In addition, fire detectors and an automatic 9.5E-3 y-w.
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o SNUPPS 10 CFR 50 Appendix R SNUPPS fire suppression system shall be installed in the fire area; or c.
Enclosure of cable and equipment and associated non-safety circuits of one redundant train in a fire barrier having a 1-hour rating.
In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area; Inside noninerted containments one of the fire protection means specified above or one of the following fire protec-tion means shall be provided:
d.
Separation of cables and equipment and associated non-safety circuits of redundant trains by a horizontal distance of more than 20 feet with no inter-vening combustibles or fire hazards; e.
Installation of fire detec-tors and an automatic fire suppression system in the fire area; or f.
Separation of cables and equipment and associated non-safety circuits of redundant trains by a noncombustible radiant energy shield.
3.
Alternative or dedicated shut-down capability and its asso-ciated circuits,s independent i
'Alterrative shutdown capability is provided by rerouting relocating or modificating of existing systems dedi-cated shutdown capability is provided by installing new structures and systems for the function of post-fire shutdown.
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SNUPPS 10 CFR 50 Appendix R SNUPPS of cables, systems or compo-nents in the area, room, or zone under consideration shall be providsd:
a.
Where the protection of systems whose function is required for hot shutdown does not satisfy the re-quirement of paragraph G.2 of this section; or b.
Where redundant trains of systems required for hot shutdown located in the same fire area may be subject to damage from fire suppression activites or from the rupture or inadver-tent operation of fire suppression systems.
In addition, fire detection and a fixed fire suppres-sion system shall be in-stalled in the area room or zone under consideration.
III.H Fire Brigade Refer to each Site Addendum.
III.I Fire Brigade Trainicg Refer to each Site Addendum.
III.J.
Emergency Lighting Emergency lighting units with at least Complies.
As stated in cn 8-hour battery power supply shall be Section 9.5.3.2.3, emergency provided in all areas needed for opera-lighting units with eight-tion of safe shutdown equipment and in hour batteries are located cccess and egress routes thereto.
in all plant areas re-quired to be manned for safe shutdown and also those areas necessary for access and egress.
III.K Administrative Controls Refer to each Site Addendum.
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SNUPPS 10 CFR 50 Appendix R SNUPPS III.L Alternative and Dedicated Shut-down capability 1.
Alternative or dedicated shut-An auxiliary shutdown down capability provided for a panel, described in Sec-specific fire area shall be tion 7.4, in conjunction able to achieve and maintain with certain local con-suberitical reactivity condi-trols, provides a means tions in the reactor, maintain of achieving and maintain-reactor coolant inventory ing hot standby in the event achieve and maintain hot that the main control room 7 conditions for PWR is uninhabitable.
standby (hot shutdown 7 for for a BWR) and achieve cold shutdown 7 The auxiliary shutdown conditions within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and panel contains the maintain cold shutdown condi-controls and indication f
tions thereafter.
During the necessary to maintain postfire shutdown, the reactor reactor coolant system coolant system process variables inventory, remove decay shall be maintained within those heat, and provide the predicted for loss of normal ac required boration for hot power and the fission product standby.
Cold shutdown boundary integrity shall not be can be achieved and main-affected i.e., there shall be tained from outside the no fuel clad damage rupture or control room by additional any primary coolant boundary or manual operator actions at rupture of the containment local control sites..
boundary.
The auxiliary shutdown 2.
The performance goals for the panel is included in the shutdown functions shall be:
fire hazards analysis, a.
The reactivity control
. function shall be capable of achieving and main-taining cold shutdown reactivity conditions.
b.
The reactor coolant makeup function shall be capable of maintaining the reactor coolant level above the top of the core for BWRs and be within the level indication in the pressurizers for PWRs.
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SNUPPS 10 CFR 50 Appendix R SNUPPS c.
The reactor heat removal function shall be capable of achieving and main-taining decay heat removal.
d.
The process monitoring function shall be capable of providing direct readings of the process variables necessary to perform and control the above func-tions.
e.
The supporting functions shall be capable of pro-viding the process cooling lubrication etc. necessary to permit the operation of the equipment used for safe shutdown functions.
3.
The shutdown capability for specific fire areas may be unique for each such area or it may be one unique combination of systems for all such areas.
In either case the alternative shutdown capability shall be independent of the specific fire area (s) and shall accom-modate postfire conditions where offsite power is avail-able and where offsito power is not available for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Procedures shall be in effect to implement this capability.
4.
If the capability to achieve and maintain cold shutdown will not be available because of fire damage, the equipment and systems comprising the means to achieve and maintain the hot standby or hot shutdown condi-tion shall be capable of main-taining such conditions until cold shutdown can be achieved.
If such equipment and systems will not be capable of being powered by both onsite and offsite electric power systems because of fire damage an 9.5E-7 1
SNUPPS 10 CFR 50 Appendix R SNUPPS independent onsite power system shall be provided.
The number of operating shift personnel, exclusive of fire brigade members, required to operate such equipment and systems shall be on site at all times.
5.
Equipment and systems com-prising the means to achieve and maintain cold shutdown conditions shall not be damaged by fire or the fire damage to such equipment and systems shall be limited so that the systems can be made operable and cold shutdown achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Materials for such repairs shall be readily available on site and proce-dures shall be in effect to implement such repairs.
If such eguipment and systems usedprior to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after the fire will not be capable of being powered by both onsite and offsite electric power sys-tems because of fire damage an independent onsite power system shall be provided.
Equipment and systems 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 offsite power only..
6.
Shutdown systems installed to ensure postfire shutdown capa-bility need not be designed to meet seismic Category I criteria, single failure criteria, or other design basis accident criteria, except where required for other reasons, e.g., because of ir.terface with or impact on esist.ing safety systems, or be:ause of adverse valve ac-1 tions due to fire damage.
7.
The safe shutdown equipment and systems for each fire area shall be known to be isolated from associated non-safety 9.5E-8
o SNUPPS 10 CFR 50 Appendix R SNUPPS 2.
The temperature levels recorded for the unexposed side are analyzed and demonstrate that the maximum temperature is sufficiently below the cable insulation Ignition tempera-ture; and 3.
The fire barrier penetration seal remains intact and does not allow projection of water beyond the unexposed surface during the hose stream test.
III.N Fire Doors Fire doors shall be self-closing or Standard fire doors are provided with closing mechanisms and provided with self-closing chall be inspected semiannually to devices.
Doors are normally verify that automatic hold-open, release, closed and locked unless cnd closing mechanisms and latches are the door is a means of operable.
egress, in which case they are closed and latched.
One of the following measures shall be provided to ensure they will protect the Special doors such as opening as required in case of fire:
pressure, watertight, and missile-resistant that are 1.
Fire doors shall be kept closed also fire doors are normally and electrically supervised at closed and locked.
a continuously manned location; Doors for areas protected 2.
Fire doors shall be locked by halon systems are closed and inspected weekly to self-closing and are verify that the doors are in electrically supervised by the closed position; the plant security system.
3.
Fire doors shall be provided See each Site Addendum for with automatic hold-open and inspection and administra-release mechanisms and in-tive requirements.
spected daily to verify that doorways are free of obstruc-tions; or 4.
Fire doors shall be kept closed and inspected daily to verify that they are in the closed position.
The fire brigade leader shall have ready cccess to keys for any locked fire doors.
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SNUPPS 10 CFR 50 Appendix R SNUPPS Areas protected by automatic. total flooding gas suppression systems shall havn electrically supervised self-closing fire doors or shall satisfy option 1 above.
III.O Oil Collection System for Reactor Coolant Pump The reactor coolant pump shall be The reactor coolant cquipped with an oil collection system pumps (RCP) cre provided if the containment is not inerted during with an oil spillage normal operation.
The oil collection sys-protection and control tem shall be so designed, engineered, and system that' consists of installed that failure will not lead to a package of splash fire during normal or 'esign basis guards, catch basins, cccident conditions and that there is and enclosures assembled reasonable assurance tdat the system as attachments to the will withstand the Safe Shutdown Earth-RCP motors at strategic quake.8 locations to preclude the possibility of oil making such collection systems shall be capable contact with hot components of collecting lube oil from all poten-and piping.
tial pressurized and unpressurized leakage sites in the reactor coolant The low points of the collec-pump lube oil systems.
Leakage shall be' tion systems are piped to collected and drained to a vented closed two collection tanks (each container that can hold the entire lube tank serves two RCPs) oil system inventory.
A flame arrester located in the reactor is required in the vent if the flash building as shown on Figure point characteristics of the oil present 9.5.1-3.
Each collection the hazard of fire flashback.
Leakage tank has a capacity of points to be protected shall include approximately 300 gallons.
lift pump and piping overlow lines, lube Each RCP motor contains oil cooler, oil fill and drain lines and approximately 265 gallons plugs, flanged connections on oil lines, of oil; however, it is end. lube oil reservoirs where such unlikely that common failure features exist on the reactor coolant would occur that would pumps.
The drain line shall be large cause the entire inventory enough to accommodate the largest poten-of oil in two RCP motors tial oil leak.
to leak out.
The collection tanks are provided with level indication and high level alarm in the control room.
Therefore, the plant operators would have an early indication of a significant oil leak and could initiate corrective "See Regulatory Guide 1.29
" Seismic action.
Design Classification," Paragraph C.2.
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SNUPPS 10 CFR 50 5ppendix R SNUPPS Should the leakage exceed the collection tank capacity before corrective actions are completed, the tank would overflow onto the containment floor.
Any such leakage would flow into the drainage trenches located adjacent to the tanks (see FSAR vigure 1.2-11) and.be collected in the containment normal sumps.
This oil would not come into contact with hot surfaces and would not pose a significant fire hazard.
The tanks are constructed to the requirements of ASME Section VIII and have flame arrestors on the vents.
The drain piping is ANSI B31.1.
The tanks and piping are seis-mically supported in
.accordance with the requirements of Para-graph C.2 of Regulatory Guide 1.29.
The RCP oil collection system was added to the SNUPPS urits prior to the issuance of Appendix R and was not specifically designed to maintain its integrity following an SSE.
The oil collection devices
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mounted on the RCPs will be evaluated and assurance will be provided that the system meets the intent of Appendix R.
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