ML20011B250
| ML20011B250 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 11/20/1981 |
| From: | Lee O PUBLIC SERVICE CO. OF COLORADO |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| FSV-65, P-81299, NUDOCS 8112080240 | |
| Download: ML20011B250 (5) | |
Text
- _
punne service company 4' Ce m de November 20, 1981 Fort St. Vrain Unit No. 1 P-81299 D h.%
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Mr. Darrel G. Eisenhut, Director 3.
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Division of Reactor Licensing O
4 Office of Nuclear Reactor Regulation
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c.;g.D' *lA U. S. Nuclear Regulatory Commission c
Washington, D. C.
20555 r
J Docket No. 50-267 7 g
Subject:
Appendix R to 10CFR -
Fire Protection Rule
Reference:
Letter dated 11/22/81, G-81202
Dear Mr. Eisenhut:
PSC has reviewed your letter dated October 22, 1981, Section 10CFR50.48, and Appendix R to 10 CFR Part 50 for applicability to the fire protection facilities at Fort St. Vrain (FSV).
PSC previously submitted a review of FSV fire protection facilities per Appendix. A to Branch Technical Position BTP APCSB 9.5-1 and upgraded our facility per that review.
Section 10 CFR 50.48 (paragraph b) states:
"(b) Appendix R to this part establishes fire protection features required to satisfy Criterion 3 of Appendix A to this part wi th respect to certain generic issues for nuclear power plants licensed to operate prior to January 1, 1979.
Except for the requirements of Sections III.G, III.J, and III.0, the provisions of Appendix R to this part shall not be applicable to nuclear power plants licensed to operate prior to January 1,1979, to the extent that fire protection features proposed or implemented by the licensee have been accepted by the NRC staff as satisfying the provisions of Appendix A to Branch Technical Position BTP APCSB 9.5-1 reflected in staff fire protection safety evaluation reports issued prior to the effective date of this rul e, or to the extent that fire protection features were accepted by the /O{
staff in comprehensive fire protection safety evaluation reports T issued before Appendix A to Branch Technical Position BTP APCSB f
9.5-1 was publised in August,1976."
/ ff 8112080240 811120 DR ADOCK 05000
P-81299 Page 2 Novembe r 20, 1981 Based upon the above, PSC has detennined that only Sections III.G, III.J and III.0 of Appendix R require evaluation as they rel ate to FSV. This evaluation is summarized on the attached Table 1.
PSC plans no further action dealing with the Fire Protection Facilities at FSV at this time.
If you have any further questions, please contact me.
Very truly yours, a///r
- 0. R. Lee, Vice President Electric Production ORL/JRR:pa Attachment
TABLE 1 NRC POSITION III.G. Fire Protection of Safe Shutdown Capability 1.
Fire protection features shall be provided for structures, systems, and components important to safe shutdown.
These features shall be capable of limiting fire damage so that:
a.
One train of systems necessary to achieve and maintain hot shutdown conditions from either the control room or emergency control station (s) is free of fire damage; and b.
Systems necessary to achieve and maintain cold shutdown from either the control room or emergency control station (s) can be repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
2.
Except as provided for paragraph G.3 of this section, where cables or equipment, including associated non-safety circuits that could prevent operation or cause mal-operation due to hot shorts, open circuits, or shorts to ground, or redundant trains of systems necessary to achieve and maintain hot shutdown conditions are located within the same fire area outside of primary containment, one of the following means of ensuring that one of the redundant trains is free of fire damage shall be provided:
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 supporting such fire barriers shall be protected to provide fire resistance equivalent to that required of the barrier.
b.
Separation of cables and equipment and associated non-safety circuits of redundant trains by a horizontal distance of more than 20 feet with no intervening combustible or fire hazards.
In
- addition, fire detectors and an automatic fire suppression system shall be installed in the fire area; or, l
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 i
detectors and an automatic fire suppression system I
shall be installed in the fire area:
Inside noninerted containments one of the fire protection means speci fied above nr one of the following fire protection means shall be provided:
l l
r 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 intervening combustibles or fire hazards:
e.
Installation of fire detectors and an automatic fire suppression system in the fire area: or f.
Separation of cables and equipment and asociated non-safety circuits of redundant trains by a noncombustible radiant energy shield.
3.
Al ternative or dedicated shutdown capability and its associated circuits, independent of cables, systems or components in the area, room or zone under consideration, shall be provided:
a.
Where the protection of systems whose function is required for hot shutdown does not satisfy the requirement 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 activities or from the rupture or inadvertent operation of fire suppression systems.
In
- addition, fire detection and a fixed fire suppression system shall be installed in the area, room or zone under consideration.
PSC RESPONSE FSV complies with Sections III.G.2 and G.3.
As required by G.2(e), fire detection and automatic fire suppression (water) have been added to the congested cable areas.
All cables in the congested areas are coated with "Flammastic" and the three room complex is al so equipped wi th a "Helon" fire suppression system.
This l
installation was previously review 3d by the NRC both on-and off-site and approved.
l Addi tional ly, FSV fulfills the requirements of Section III.G.3.
At the direction of NRC, an Alternate Cooling Method System (ACli) was installed which provides a Diesel-Generator as a source of electrical power to the equipment required for Safe Shutdown Capability including emergency lighting.
This ACM generator is in addi tion to the Emergency Diesel Generators.
Electrical cabling for this system is separate from other plant cabling and does not traverse the " Congested Cable Areas."
NRC POSITION III.J.
Emergency Lighting Emergency lighting units with at least an 8-hour battery supply shall be provided in all areas needed for operation of safe shutdown equipment and in access and egress routes thereto.
PSC RESPONSE FSV has 2-8 hour station batteries which supply emergency lighting and is therefore in compliance.
As discussed in our response to BTP APCSB 9.5-1, the emergency lighting at FSV does not contain individual batteries, but rather is supplied by the station ba tteries.
Additional emergency lighting powered by the ACM Diesel Generator is provided.
No further action is required.
NRC POSITION 111.0.
Oil Collection System for Reactor Coolant Pump The reactor coolant pump shall be equipped with an oil collection system if the containment is not inerted during normal operation.
The oil collection system shall be so designed, engineered and installed that failure will not lead to fire during normal or design basis accident conditions and that there is reasonable assurance that the system will withstand the Safe Shutdown.
Earthquake Such collection systems shall be capable of collecting lube oil from all potential pressurized and unpressurized leakage sites in the reactor coolant pump lube oil systems.
Leakage shall be collected and drained to a vented closed container that can hold the entire lube oil system inventory.
A flame arrester is required in the vent if the flash point characteristics of the oil present the hazard of fire flashback.
Leakage points to be protected shall include lift pump and piping, overfl ow lines, lube oil cooler, oil fill and drain lines and plugs, flanged connections on oil lines, and lube oil reservoirs where such featu res exist on the reactor coolant pumps. The drain lines shall be large enough to accommodate the largest potential oil leak.
PSC RESPONSE This requirement is not applicable to the HTGR design of Fort St.
Vrain.
4