ML20039B279
| ML20039B279 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 12/14/1981 |
| From: | Wells R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| 15105, NUDOCS 8112220487 | |
| Download: ML20039B279 (40) | |
Text
{{#Wiki_filter:. t CODSumBIS Power u, w coa Vice President - Projects, Engineering and Construction General offices: 1945 West Parnali Road, Jackson, Mt 49201 + (517) 788 0453 December 14, 1981 t-O Harold R Denton, Director p/ y.177,. s y Office of Nuclear Reactor Regulation . U/ US Nuclear Regulatory Commission -{ gEC21N& ~i Washington, DC 20555 L 't ug;g,au V a MIDLAND PROJECT 9 0 N ' l i '3 \\"'-. MIDLAND DOCKET NOS 50-329, 50-330 MIDLAND COMPARISON TO APPENDIX R OF 10 CFR 50 FILE B9.5.1, 0485.1 SERIAL 15105
REFERENCES:
(1) RLTEDESCO LETTER TO JWC00K, DATED JUNE 29, 1981 (2) JWC00K LETTER TO HRDENTON, SERIAL 13353, DATED AUGUST 6, 1981 (3) EGADENSAM LETTER TO JWC00K, DATED SEPTEMBER 24, 1981-(4) NRC
SUMMARY
OF OCTOBER 7, 1981 MEETING, NRC LETTER DATED OCTOBER 27, 1981 ENCLOSURE: " APPENDIX R COMPARISON - MIDLAND UNITS 1 AND 2" DATED DECEMBER 1, 1981 In response to the NRC's correspondence of June 29, 1981 and September 24, 1981 (References 1 and 3), we are forwarding the enclosed document which is a point-by point tabular comparison of the Midland Plant fire protection program and design features with Appendix R to 10 CFR 50. The enclosed Appendix R comparison is a reflection of the commitments already contained in Section 9A of the Midland FSAR. We call your attention to one area of concern which we have identified and which is current 13 under evaluation. This relates to Item 1 of Appendix R located under Section D, " Manual Fire Suppression." We are currently evaluating the locations of hose stations and hose lengths in relation to the as-built configuration of structures and systems to evaluate whether at least .one effective hose stream can reach any location that contains or presents an exposure fire hazard to safety-related structures, systems or components. To provide an opportunity to discuss the results of our evaluation of hose station locations, we recommend a meeting with the Staff to be held at a mutually convenient time in January 1982. This meeting could also provide a p@J JN "* ' -M 02a 100 Dftfh7811214' 05000329 F PDR
2 convenient forum in which to resolve any remaining SER open items and address remaining Staff concerns on the Midland fire protection program. We will contact our NRC Project Manager to make arrangements for this meeting. s' i R A Wells Executive. Manager For J W Cook i JWC/RLT/dsb CC RWHernan, NRC, w/a (3) RKAnand, NRC. w/a WILeFave, NRU, w/a JGKeppler, NRC, Region III, w/a JMPeschel, NRC, Region III, w/a LHCurtis, Bechtel oc1281-0502a100
3 ~' BCC REBerry,II-416B, w/a DTPerry, P-14-300, w/a RAPolich, P-14-212, w/a JDAlderink, Midland, w/a JAMooney, P-14-115A, w/a RMiuston, Washington, w/a DFLewis, Bechtel, w/a DBMiller, Midland, w/a RJBurg, Bechtel, w/a DPHoffman, P-24-118A, w/a WJllall, P-24-621, w/a BLHarshe, P-24-618, w/a KJTerry, P-24-611, w/a TJSallivan/DMBudzik, P-24-624A, w/o Licensing Clerk NRC Correspondence File oc1281-0502a100
1 APPENDIX R* COMPARISON MIDLAND UNITS 1 AND 2 DOCKET NO 50-329 AND 50-330 CONSUMERS POWER COMPANY-DECEMBER 1, 1981
- Note:
Appendix-R noticed 45 FR 76602 on November 19, 1980 and as amended 46 FR 44734 on September 8,1981. mi1081-0450a100
e a APPENDIX R COMPARISF Midland Units 1 and 2 APPENDIX R DESCRIPTION OF REGULATORY POSITIONS COMPLIANCE I. Introduction and Scope I. Introduct. ion and Scope A. Definitions A. Definitions 1. The phrases "important to safety," or 1. The phrase "sa fety-related," used " safety-related," will be used throughout throughout the Appendix 9A to the this Appendix R as applying to all safety Midland FSAR, refers to systems and functions. The phrase " safe shutdown" components important to safety. The will be used throughout this Appendix R plant conditions of hot shutdown and .as applying to both hot and cold shutdown cold shutdown, as used in the Midland functions. plant technical specifications, are possible plant conditions af ter a fire caused disruption. The phrase " shut-down" is used'to refer to either hot standby or cold shutdown. 2. Three levels of fire damage limits are 2. Levels of fire damage limits which have been established according to the safety considered in the analysis and design of functions of the structure, system, or Hidland are as follows: component: Safety Function Fire Damage Limits Safety Function Fire Damage Limits Hot Shutdown...One train of equipment Hot Shutdown...One train of equipment necessary to achieve hot necessary to achie ve and shutdown from either the maintain hot standby control room or emergency conditions from either control station (s) must be the control room or maintained free of fire alternate control ~ damage by a single fire, stations will be free including an exposure from fire damage, given.
- fire, the occurrence of any.
' exposure fire, miO3SI-0219a100
2 APPENDIX R DESCRIPTION OF REGULATORY POSITIONS COMPLIANCE Cold Shutdown..Both trains of equipment Cold Shutdown..Syst. ems necessary to necessary to achieve cold achieve and maintain cold shutdown may be damaged by shutdown from either the a single fire, including control room or alternate an exposure fire, but. control stat. ions are avail-damage must. be limited so able or can be repaired that at least. on train can and made available within be repaired or made oper-72 hours af ter a single able within 72 hours using
- fire, onsite capabilit.y.
Design Basis...Both trains of equipment Design Basis...Both trains of equipment Accidents necessary for mitigation Accidents necessary for mitigation of consequences following of consequences following design basis accidents may design basis accidents may be damaged by a single be damaged by a single exposure fire. exposure fire. 3. Exposure Fire. An exposure fire is a 3. Exposure Fire. The term " exposure fire", fire in a given area that involves either used throughout Appendix 9A of the Midland in situ or transient combustibles and is FSAR, refers to a fire in a given area that external to any structures, systems, or involves either in situ or transient com-components located in or adjacent. to that bustibles and is external to any structures, same area. The effects of such fire (eg, systems or components located in or adjacent smoke, heat, or ignit. ion) can adversely to that. same area. It is recognized that affect those structures, systems, or the effects of such fire (eg, smoke, heat. components import. ant to sa fety. Thus, a or ignition) could adversely affect those fire involving one train of safe shutdown struct.ures, systems or components important equipment may constitute an exposure fire to safety, and appropriate precautions or for the redundant t. rain located in the design changes have been made for Midland, same area, and a fire involving combust-ibles other than either redundant train may constitute an exposure fire to both redundant. trains located in the same area. I miO381-0219a100
'3 APPENDIX R DESCRIPTION OF REGULATORY POSITIONS COMPLIANCE B. Objectives B. Objectives 1. The most stringent fire damage limit 1. The most stringent fire damage limit shall apply for those systems that fall was applied to those systems that into more than one category, did fall into more than one of the above categories. 2. Redundant systen.s used to mitigate the 2. Redundant systems used to mitigate the consequences of other design basis acci-consequences of other design basis acci-dents but not necessary for safe shutdown dents but not necessary for safe shutdown may be lost to a single exposure fire. are protected. However, protection shall be provided so that a fire within only one such system will not damage the redundant system. II. General Requirements II. General Requirements A. Fire Protection Program A. Fire Protection Program 1. A fire protection program shall be estab-1. The Midland fire protection program lished at each nuclear power plant. The complies with these objectives as program shall establish the fire protec-documented in FSAR Appendix 9A. Lion policy for the protection of struc-tures, systems, and components important to safety at each plant and the proce-dures, equipment and personnel required to implement the program at the plant site. 2. The fire protection program shall be 2. The fire protection program is under the under the direction of an individual who direction of qualified individuals with has been delegated authority commensurate appropriate levels of delegated authority with the responsibilities of the position as stated in Subsection 9A.I.10 of FSAR and who has available staf f personnel Appendix 9A. Individuals knowledgeable in knowledgeable in both fire protection and both fire protection and nucles. safety have nuclear sa fety, been utilized in the preparation of FSAR Appendix 9A and will be utilized in the implementation of the Midland fire protec-tion program. miO381-0219a100
r 4 APPENDIX R DESCRIPTION OF REGULATORY POSITIONS COMPLIANCE 3. The fire protection program shall extend 3. The Midland fire protection program the concept of defense-in-depth to fire extends the concept of defense-in-depth protection in fire areas important to to meet these objectives as documented safety, with the following objectives: to in FSAR Subsection 9A.I.2. prevent fires from starting; to detect rapidly, control, and extinguish promptly those. fires that do occur; to provide protection for structures, systems, and components important to safety so that a fire that is not promptly extinguished by the fire suppression activities will not prevent the safe shutdown of the plant. B. Fire llazards Analysis B. Fire llazards Analysis A fire hazards analysis shall be performed by The Midland fire protection evaluation qualified fire protection and reactor systems report has been performed by qualified engineers to: fire protection and reactor systems engineers. 1. Consider potential in situ and transient 1. The Midland fire protection evaluation fire hazards; report considered potential in situ and and transient fire hazards. 1 2. Determine the consequences of fire in any 2. Systems and components needed to achieve location in the plant on the ability to and maintain shutdown were identified. An safely shut down the reactor or on the analysis was performed to determine factors ability to minimize and control the re-affecting modes of operation and control. lease of radioactivity to the environ-These factors include: ment; and a. The time at which a system should resume operation after a fire initiated disrup-tion has occurred; b. The ability and desirability to control a system by operator action; miO381-0219a100 u~
APPENDIX R DESCRIPTION OF REGULATORY POSITIONS COMPLIANCE i c. The location and suitability of alternate points of control; and d. The effects of a fire on the systems and components. 3. Specify measures for fire prevention, 3. A description of fire prevention, fire fire detection, fire suppression, and detection, fire suppression, and fire fire containment and alternative shutdown containment and shutdown capability mea-capability as required for each fire area sures used at the Midland plant for each containing structures, systems, and com-fire area containing structures, systems, ponents important to safety in accord-and components important to safety is pro-ance with NRC guidelines and regulations. vided in Section 9A.2 of FSAR Appendix 9A. C. Fire Prevention Features C. Fire Prevention Features Fire protection features shall meet the The Midland plant fire protection and preven-following general requirements for all fire tion features meet the following general areas that contain cr present a fire hazard requirements: to structures, systems, or components impor-tant to safety. 1. In situ fire hazards shall be identified 1. In situ fire hazards were identified, and suitable protection provided. and suitable protection is provided. 2. Transient fire hazards associated with 2. Transient fire hazards were identified, normal operation, maintenance, repair, or and eliminated where possible. For those modification activities shall be identi-that cannot be eliminated, suitable protec-fied and eliminated where possible. tion has been provided for.the area. Those transient fire hazards that can not be eliminated shall be controlled and suitable protection provided. 3. Fire detection systems, portable extin-3. Fire detection systems, portable extin-guishers, and standpipe and hose stations guishers, and standpipe and hose stations shall be installed. have been designed and are installed as . identified in FSAR Appendix 9A. miO381-0219a100
'6 APPENDIX R DESCRIPTION OF REGULATORY POSITIONS COMPLIANCE 4. Fire barriers or automatic suppression 4. Fire barriers or automatic suppression systems or both shall be installed as systems have been installed as necessary necessary to protect redundant systems or to protect redundant systems or components components necessary for safe shutdown. necessary for shutdown. 5. A site fire brigade shall be established, 5. A fire brigade is established, trained, and trained, and equipped and shall be on site equipped and will be on site at all times at all times. as discussed in FSAR Subsection 9A.3.B. e 6. Fire detection and suppression systems 6. Fire detection and suppression systems shall be designed, installed, maintained,* are designed, installed, maintained, and and tested by personnel properly quali-tested by properly qualified personnel, fled by experience and training in fire protection systems. 7. Surveillance procedures shall be estab-7. During construction Bechtel field lished to ensure that fire barriers are personnel will ensure that fire in place and that fire suppression systems barriers are in place and suppres-and components are operable. sion systems are operable in accord-ance with agreed upon turnover procedures. Surveillance proce-dures will be estab'.! :.c' to ensure that fire suppression system. and components are operable during plant operation. Surveillance procedures are listed in the Midland Plant Fire Protection Implementing Procedures. D. Alternative or Dedicated Shutdown Capability D. Alternative or Dedicated Shutdown Capability In areas where the fire protection features Alternative, rather than dedicated, canno( ensure safe shutdown capability.in the shutdown capability is provided in the event of n fire in that area, alternative or Midland plant design. dedicated safe shutdown capability shall-be provided. miO381-0219a100
I 7 APPENDIX R DESCRIPTION OF REGULATORY POSITIONS COMPLIANCE III. Specific Requirements III. Specific Requirements A. Water Supplies for Suppression Systems A. Water Supplies for Suppression Systems 1. Two separate water supplies shall be 1. The water source for the fire provided to furnish necessary water protection system is the plant volume and pressure to the fire main cooling pond. loop. 2. Each supply shall consist of a storage 2. The Midland design utilizes two fire tank, pump, piping, and appropriate pumps drawing suction from a single isolation and control valves. Two sepa-intake bay. Failure of one fire rate redundant suctions in one or more protection water system (pumps, piping, intake structures from a large body of and valves) will not result in the water (river, lake, etc.) will satisfy the failure of the other system. These requirement for two separated water water supplies are described in FSAR storage tanks. These supplies shall be Subsection 9A.3.E. separated so that a failure of one supply will not result in a failure of the other supply. 3. Each supply of the fire water distribu-3. The volume of the cooling pond available Lion system shall be capable of providing for the fire protection system is suffi-for a period of 2 hours the maximum cient to meet all fire protection require-expected water demands as determined by ments for a period of 2 hours. This volume the fire hazards analysis for safety-is discussed in FSAR Subsection 9A.3.E.2. related areas or other areas that present a fire exposure hazard to safety-related areas. 4. When storage tanks are used for combined 4. Midland does not use storage tanks for service-water / fire-water uses the minimum a source of water to the fire protection volume for fire uses shall be ensured by system. means of dedicated tanks or by some phys-ical means such as vertical standpipe for other water service. Administrative controls, including locks. for, tank outlet valves, are unacceptable as the only means to ensure minimum water volume, miO381-0219a100
8 APPENDIX k DESCRIPTION OF RF LATORY POSITIONS COMPLIANCE 4 l 4 5. Other water systems used as one of the 5. The Midland plant fire water supplies i two fire water supplies shall be perma-are not connected to any other water nently connected to the fire main system systems. and shall be capable of automatic align-ment to the fire main system. Pumps, controls, and power supplies in these systems shall satisfy the require-ments for the main fire pumps. The use of other water systems for fire protec-tion shall not be incompatible with their functions required for safe plant shut-down. Failure of the other system shall not degrade the fire main system. B. Sectional Isolation Valves B. Sectional Isolation Valves ] Sectional isolation valves such as post indi-Post-indicator valves will be used for cator valves or key operated valves shall be section isolation of fire mains, as 1 installed in the fire main loop to permit described in FSAR Subsection 9A.2.3.2(a). isolation of portions of the fire main loop a for maintenance or repair without inter-4 rupting the entire water supply. C. Hydrant Isolation Valves C. Hydrant Isolation Valves Valves shall be installed to permit isolation Midland's design will isolate underground of outside hydrants from the fire main for sections of the fire main which contain maintenance or repair without interrupting the hydrant (s) needed to be isolated. The the water supply to' automatic or manual fire water supply to fire protection systems in suppression systems in any area containing or safety-related or shutdown areas will not be j. presenting a fire hazard to safety-related or subsequently interrupted. 4 4 safe shutdown equipment. miO381-0219a100
9 APPENDIX R DESCRIPTION OF REGULATORY POSITIONS COMPLIANCE t i D. Manual Fire Suppression D. Manual Fire Suppression 1. Standpipe and hose systems shall be 1. This concern is under evaluation. j installed so that at lease one effective hose stream will be able to reach any location that contains or_ presents an i exposure fire hazard to structures, systems, or components important to safety. 2. Access to permit effective functioning of 2. Access to permit effective functioning the fire brigade shall be provided to all of the fire brigade is provided to areas areas that contain or present an exposure in which postulated fires can occur, as fire hazard to structures, systems, or described in FSAR Section 9A.2. components important to safety. 3. Standpipe and hose stations shall be 3. The M 41and plant fire protection system inside PWR containments and BWR contain-includes standpipe and hose stations ments that are not inerted. Standpipe inside the containment buildings which and hose stations inside containment may are connected to the fire water system be connected to a high quality water and can be isolated by a single manual supply of suf ficient ' quantity and pres-valve. sure other than the fire main loop if plant-specific features prevent extending the fire main supply inside containment. E. Hydrostatic Hose Tests E. Hydrostatic Ilose Test Fire hose shall be hydrostatically tested at Fire hose will be hydrostatically tested at a pressure of 150 psi or 50 psi above maximum a pressure of 250 psi. Hoses stored out-fire main operating pressure, whichever is side will be tested annually. Interior greater. Ilose stored in outside hose houses standpipe hose will be tested every three shall be tested annually. Interior standpipe years. hose sitall be tested every three years. I 4 miO381-0219a100 i b
IU APPENDIX R DESCRIPTION OF REGULATORY POSITIONS COMPLIANCE F. Automatic Fire Detection F. Automatic Fire Detection Automatic fire detection systems shall be Automatic fire detection will be supplied installed in all areas of the plant that for all areas of the plant that contain contain or present an exposure fire hazard to an exposure fire hazard to shutdown or safe r,hutdown or safety-related systems or safety-related components. A description components. These fire detection systems of the fire detection system is contained shall be capable of operating with or without in Subsection 9A.I.9.3 of FSAR Appendix 9A. offsite power. G. Fire Protection of Safe Shutdown Capability G. Fire Protection of Safe Shutdown Capability 1. Fire protection features shall be 1. The Midland plant has been analyzed to provided for structures, systems, and provide fire protection features for struc-components important to safe shutdown. tures, systems, and components needed to These features shall be capable of achieve and maintain shutdown in the event limiting fire damage so that: of any in situ or transient fire. a. One train of systems necessary a. One train of systems necessary to to achieve and maintain hot shutdown achieve and maintain hot standby from conditions from either the control the control room or alternate control room or emergency control station (s) station will be free from fire damage. is free of fire damage; and b. Systems necessary to achieve and b. The systems necessary to achieve and maintain cold shutdown from either maintain cold shutdown from either the the control room or emergency control control room or emergency control sta-station (s) can be repaired within 72 tions are available or can be repaired hours. and made available within 72 hours. 2. Except as provided for in paragraph G.3 of 2. An analysis was performed to determine this section, where cables or equipment, places within the plant in which an including associated non-safety circuits exposure fire could damage cables or thpt could prevent operation or cause equipment and prevent operation of maloperation due to hot shorts, open cir-redundant train of systems necessary cuits, or shorts to ground, of redundant to achieve and maintain shutdown. The trains of systems necessary to achieve criteria used for this analysis is and maintain hot shutdown conditions are given in Subsection 9A.I.8.3 of FSAR located within the same fire area outside Appendix 9A. miO381-0219a100
~_ i 11 APPENDIX R DESCRIPTION OF REGULATORY POSITIONS COMPLIANCE of primary containment, one of the following means of ensuring that one of Outside the main control room (MCR) the redundant. trains is free of fire and primary containments, where cable j damage shall be provided: or equipment, including associated non-safety-related circuits that could prevent operation or cause maloperation of redundant trains of systems necessary j _to achieve and maintain hot' standby. I conditions are located within the same fire area, one of the following means of ensuring that one of the redundant trains is free of fire damage has been provided unless specified otherwise in FSAR Section 9A.2: a. Separation o: cables and equipment a. Separation of cables, equipment, and and associated non-safety circuits of associated nonsafety-related circuits redundant trains by a fire barrier by a fire barrier having a 3-hour having a 3-hour rating. Structural rating. Structural steel forming a j steel forcing a part of or supporting part of or supporting such fire bar-such fire barriers shall be protected riers is protected to provide fire to provide fire resistance cquivalent resistance equivalent to that required to that required of the barrier; for the barrier;. b. Separation of cables and equipment and b. Separation of cables, equipment, and associated non-safety circuits of re-associated nonsafety-related circuits' dundant trains by horozontal. distance or redundant trains by a horizontal of more than 20 feet with no intervening distance of more than 20 feet with no 4 combustible or fire hazards. In addi-intervening combustible or fire hazards. 3 tion, fire detectors and an automatic Fire detectors and automatic suppression fire suppression system shall be in-systems are installed as described in stalled in the fire. area; or FSAR Section 9A.2; or 4 a i 1 miO381-0219a100 1 1
12 APPENDIX R DESCRIPTION OF REGULATORY POSITIONS COMPLIANCE c. Enclosure of cable and equipment and c. Enclosure of cable, equipment, and associated non-safety circuits of one associated nonsafety-related circuits l redundant train in a fire barrier of one redundant train in a fire j having a 1-hour rating. In addition, barrier having a 1-hour rating. In fire detectors and an automatic fire addition, a method of fire detection suppression system shall be installed and an automatic fire suppression sys-- 4 in the fire area; tem is provided for the fire area. j As an alternative to the fire protection recommendations given above, the Midland plant provides the following fire protec-tion inside the main control room: 3 a. Smoke detection both at ceiling level 7 and above the ceiling and also in all major walk-in control cabinets. b. Fire suppression through the use of portable extinguishers and manual hose reals. l Should a fire occur inside the NCR 1 Limited manual action inside the MCR is possible and extensive manual action occurs outside the MCR. The effects of a fire will be limited to any single cabinet. Electrical isolation of 1 Train A controls, required to achieve and maintain shutdown, located both j in the NCR and at the alternate emer-i gency control stations is provided by l; transfer switches. The Midland transfer switches are multicontract, break-before-make switches. When a transfer switch is in the normal position, the preferred point of control is energized and i active, and the secondary or redundant I point of control is isolated. Should a fire disrupt the preferred point of niO381-0219a100 t
13 APPENDIX R DESCRIPTION OF REGULATORY POSITIONS COMPLIANCE control, the transfer switch can be thrown to isolate the preferred point of control and make the alternate point of control active. Inside noninerted containments one of The Midland containment atmosphcre is a the fire protection means specified noninerted atmosphere. Due to adminis-above or one of the following fire trative controls, exposure fires inside protection means shall be provided: containment are assumed not to occur during normal operations. Fire protec-tion has been provided as specified in FSAR Section 9A.2. 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 associated non-safety circuits of redundant trains by noncombustible radiant energy shield. 3. Alternative or dedicated shutdown capa-3. Alternate shutdown capability and its bility and its associated circuits associated circuits, which is independent (alternative shutdown capability is of cables, systems, or components in the provided by rerouting, relocating or mod-area, room, or zone under consideration, ification of existing systems; de:licated are provided where the protection of systems, shutdown capability is provided by whose function is required for hot shutdown, installing'new structures and systems for does not satisfy the requirements of Para-the function of' post-fire shutdown), _ graph G.2 above. miO381-0219a100
14 APPENDIX R DESCRIPTION OF REGULATORY POSITIONS COMPLIANCE independent of cables, systems or com-ponents 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 activites 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. H. Fire Hrigade H. Fire Brigade A site fire brigade trained and equipped for A site fire brigade, trained and equipped fire fight.ing shall be established to ensure for fire fighting, will be established to adequ.ste manual fire fighting capability.for ensure adequate manual fire fighting cap-all areas of the plant. containing structures, ability for all areas of the plant contain-systems, or components important to safety, ing structures, systems, or components important to safety. The fire brigade shall be a least five The fire brigade consist.s of 5 members on each members on each shift. The brigade leader shift. The brigade leader and at least and at. least. two brigade members shall have two brigade members have sufficient training suf ficient training in or knowledge of plant. in or knowledge of plant safety-related safety-related systems to understand the systems to understand the effects of fire effects of fire and fire suppressants on safe and fire suppressants on shutdown capability. shutdown capability. The qualification _of These three members will be from the fire brigade members shall include an annual Operations Department of the plant. The physical examinat. ion to determine their qualification of the fire brigade members ability to perform strenuous. fire fighting includes a preemployment. physical examina-niO381-0219a100
15 APPENDIX R DESCRIPTION OF REGULATORY POSITIONS COMPLIANCE 4 activities. The shif t supervisor shall not tion to determine their ability to perform be a member of the fire brigade. The brigade various activities during their work leader shall be competent to assess the assignments. Each brigade member also potential safety consequences of a fire and has the opportunity to have a physical advise control room personnel. Such compe-examination each year. Also, each' brigade tence by the brigade leader rz.y be evidenced member who would wear a self-contained by possession of an opert sr e license or breathing apparatus has completed a equivalent knowledge of plant safety-related respiratory fitness program performed systems. by an outside agency. The shift sup-ervisor has a senior operator's license and is the leader of the fire brigade, Due to the organizational structure of t the Midland plant, a shift supervisor can be a member of the fire brigade without adversely affecting plant op-i e ra tions. The plant supervisor has the overall operational responsibility of operating the plant and sipervising the actions in the control room. l The minimum equipment provided for the The equipment provided for the brigade brigade shall consist of personal protective consists of turnout coats, gloves, hard equipment such as turnout coats, boots, hats, portable two-vay radios, portable gloves, hard hats, emergency communications lights and portable extinguishers. NIOSl! equipment, portable lights,. portable ventila-approved self-contained breathing apparatus Lion equipment, and portable extinguishers. using full-face positive-pressure masks will Self-contained breathin'g apparatus using be provided for the fire brigade and control full-face yositive pressure; masks approved room personnel. At least 10 masks will be by NIOSil (National Institute for Occupational available for fire brigade personnel. Service Safety and llealth-approval formerly given by or rated operating life will be one hour the U.S.' Bureau of Mines) shall be 1;rovided for the self-contained units. -At least two for fire brigade, damage' control and control extra oxygen bottles will be located on room personnel. At least 10 masks chall be site for each self contained breathing unit. availaple 'for fire brigade personnel. In addition, an on-site 6-hour supply of ~ ~ Control room personnel.may be furnished reserve oxygen will be provided and arranged breathing. air by a manifold system piped to permit quick and complete replenishment from a ~ storage reservoir if practica~i. of. exhausted supply oxygen bottles as they 4 aiO381-0219a100 L. l ? 4 r. i w ./, i' 1 N
_a 16 APPENDIX R DESCRIPTION OF REGULATORY POSITIONS COMPLIANCE e Service or rated operating life shall be are returned. This reserve supply will a minimum of 1/2 hour for the self-contained consist'of extra oxygen bottles and an units.1 oxygen cascade refilling system. At least a 1-hour supply of breathing air in exfra bottles-shall be located on the plant site for each unit of self-contained breathing apparatus. In addition, an ou ' site 6-hour supply of reserve air shall be provided and arranged to permit quick and complet e replenishment of exhausted air supply bottles as they are returned. If compressors are used as a source of breathing air, only units approved for breathing air shall be used, and the com-pressors shall be operable assuming a loss of offsite power. Special care must be taken to locate the compressor in areas free of dust and contaminants. I. Fire Brigade Training I. Fire Brigade Training The fire brigade training program shall The following program will be implemented for ensure that the capability to fight potential fire brigade training at Midland: fires is established and maintained. The program shall consist of an initial class-room instruction program followed by periodic classroom instruction, fire fighting practice, and fire drills: 1. Instruction 1. Instruction a. The initial classroom instruction a. The initial classroom instruction shall include: will include: (1) Indoctrination of the plant (1) Training of all fire brigade fire fighting plan with spe-members in all positions within cific identification of each the brigade. The brigade will individual's responsibilities. work as a team with all members miO3SI-0219a100
17 ' APPENDIX R DESCRIPTION OF REGULATORY POSITIONS COMPLIANCE being able to assume all posi-tions. Because of illness, injury, absence, etc, the member composition of the 5-man fire brigade cannot be predetermined and assignment of specific indi-viduals to specific functions may result in confusion during a fire. I (2) Identification of the type and (2) Identification of the type and location of fire hazards and location of fire hazards and associated types of fires that associated types of fires that could occur in the plant. could occur in the plant. (3) The toxic and corrosive (3) The toxic and corrosive characteristics of expected. characteristics of expected products of combustion, products of combustion. (4) Identification of the location (4) Review of the plant layout l of. fire fighting equipment for through discussions on each fire area and familiariza-locations of plant fire l tion with the layout of the fighting equipment and fire plant, including access and protection systems. Also, egress routes to each area. plant layout will be covered when considering access to individual fire areas for pur-poses of fire fighting. Separate instruction in the layout of the plant will not be taught during fire brigade training sessions because all members of fire brigade will already be familiar with the plant layout due to their daily normal job experience and act-ivities, and other plant training. miO381-0219a100
__m... i i 18 APPENDIX R DESCRIPTION OF REGULATORY POSITIONS COMPLIANCE (5) The proper use of available (5) The proper use of available fire fighting equipment and the fire fighting equipment and the i correct method of fighting each correct method of fighting each type of fire. The types of type of fire. The types of fires fires covered should include covered will include fires in-fires in energized electrical energized electrical equipment, equipment, fires in cables and fires in cable and cable trays, i cable trays, hydrogen fires, hydrogen fires, fires invol-fires involving flammable and ving flammable and combustible combustible liquids or hazardous liquids or hazardous process process chemicals, fires chemicals, fires resulting I resulting from construction or from construction to modifica-t modifications (welding) and tions (welding), and record record file fires. file fires. l (6) The proper use of communication, (6) The proper use of communication lighting, ventilation, and lighting, ventilation, and l emergency breathing equipment. emergency breathing equipment. i (7) The proper method for fighting (7) The proper method for fighting j fires inside buildings and fires inside buildings and confined spaces, confined spaces. (8) The direction and coordination (8) The direction and coordination of the fire fighting activities of the fire fighting activities (fire brigade leaders only). (brigade leaders only). (9) Detailed review of fire (9) Review of fire fighting strategies fighting strategies and proce-and procedures. dures. (10) Review of the latest plant (10) Review of the latest plant } modifications and corresponding modifications and co'rrespond-i changes in fire fighting plans. ing changes in fire fighting i plans as deemed necessary. l Note - Items (9) and (10) may be deleted from the training of no more than a l two of the nonoperations personnel who may be assigned to the fire brigade. miO381-0219a100
19 cPPENDIX R DESCRIPTION OF REGULATORY POSITIONS COMPLIANCE b. The instruction sh all be provided by b. The instruction will be provided qualified individuals who are know-by qualified individuals who are ledgeable, experienced, and suitably knowledgable, experienced, and trained in fighting the types of suitably trained in fighting the fires that could occur in the plant types of fires that could occur and in using the types of equipment in the plant and in using the available in the nuclear power plant, types of equipment available in the Midland plant. c. Instruction shall be provided to all c. Instruction will be provided to all fire brigade members and fire brigade fire brigade members and fire leaders. brigade leaders, d. Regular plcnned meetings shall be d. Fire drills and regular training held at least every 3 months for all sessions are held throughout the brigade members to review changes in year. Changes in the fire protec-the fire protection program and other tion program and other subjects subjects as necessary. will be discussed during drills and regular training sessions. Regular planned meetings held at least every 3 months for all brigade members for the exclusive review of changes in the fire protection program and other subjects would be redundant, repetitive, and unnecessary. e. Periodic refresher training sessions e. Periodic refresher training sessions shall be held to repeat the classroom will be held to repeat the classroom instruction program for all brigade instruction program for all brigade members over a two-year period. members over a two year period. These sessions may be concurrent with These sessions may be concurrent the regular planned meetings. with the regular planned meetings. miO381-0219a100
i 20 l APPENDIX R DESCRIPTION OF i REGULATORY POSITIONS COMPLIANCE i i 2. Practice 2. Practice Practice sessions shall be head for each Practice sessions will be held for shift fire brigade on the proper method each shift fire brigade on the proper j of fighting the various types of fires method of fighting the various types of i that could occur in a nuclear power fires that could occur in the Midland i plant. These sessions shall provide Plant. These sessions will provide . brigade members with experience in actual brigade members erith experience in fire extinguistument and the use of emer-extinguishing actual fires and use j gency breathing apparatus under strenuous of emergency braathing apparatus 1 conditions encountered in fire Ogthing. under the strenuous conditions encount-l The practice sessions shall be provided ered in fire fighting. The practice at least once per year for each fire sessions will be provided at least } brigade member. Once per year for each fire brigade i member. 4 3. Drills 3. Drills a. Fire brigade drills shall be per-a. Fire brigade drills will be performed formed in the plant so that the fire in the plant so that the fire brigade can practice as a team. brigade can practice as a team. f 1 b. Drills shall be performed at regular b. Drills will be performed at regular intervals not to exceed 3 months for intervals not exceeding three months for 4 { each shift fire brigade. Each fire each shift fire brigade. Each brigade [ brigade member should participate in me:aber will particpate in at least i each drill, but must participate in two drills per year. at least two drills per year. i i A sufficient number of these drills, A sufficient number of these drills, l but not less than one for each shift but not less than one for each shift 2 fire brigade per year, shall be fire brigade per year, will be unannounced to determine the fire unannounced to determine the fire fighting readiness of the plant fire fighting readiness of the plant fire brigade, brigade leader, and fire brigade, brigade leader, and fire protection systems and equipment. protection systems and equipment. Persons planning and authorizing Persons planning and authorizing an unannounced drill shall ensure an unannounced drill will ensure that the responding shift fire that. the responding shift fire i, I miO381-0219a100 1 1
21 APPENDIX R DESCRIPTION OF REGULATORY POSITIONS COMPLIANCE brigade members are not aware that brigade members are not aware that a a drill is being planned until it drill is being planned. Unannounced is begun. Unannounced drills shall drills will not occur more frequently not be scheduled closer than four than at four-week intervals. weeks. At least one drill per year shall be At least one drill per year will performed on a "back shif t" for each be performed on a "back shif t" shift fire brigade. for each shift fire brigade, c. The drills shall be preplanned to c. Drills will be preplanned to establish establish the training objectives of the training objectives of the drill the drill and shall be critiqued to and will be critiqued to dotermine determine how well the training how well the training objectives have objectives have been met. Unan-been met. Unannounced drills will be nounced drills shall be planned and planned and critiqued by members of critiqued by members of the manage-the management staff responsible for ment staff responsible for plant plant safety and fire protection. safety and fire protection. Perform-Performance deficiencies of a fire ance deficiencies of a fire brigade brigade or of individual fire or of individual fire brigade members brigade members will be remedied shall be remedied by scheduling addi-by scheluling additional training tional training for the brigade or for the brigade or members. members. Unsatisfactory drill per-formance shall be followed by a Unsatisfactory drill performance repeat drill within 30 days. will be followed by a repeattirill within 30 days. d. At 3 year intervals, a randomly d. At 3 year intervals, a randomly selected unannounced drill shall be selected unannounced drill will be critiqued by qualified individuals critiqued by qualified individuals independent of the licensee's staff. independent of the licensee's staff. 'A copy of the written report from A copy of the written report from such individuals shall be available such individuals will be available for NRC review. for NRC review. miO381-0219a100 l
22 APPENDIX R DESCRIPTION OF REGULATORY POSITIONS COMPLIANCE e. Drills shall as a minimum include the e. Drills, as a minimum, will include following: the following: (1) Assessment of fire alarm effect-(1) Assesment of fire alarm iveness, time required to notify effectiveness, time required and assemble fire brigade, and to notify and assemble fire selection, placement and use of brigade, and selection, equipment, and fire fighting placement, and use of equip-strategies, ment and fire fighting strategies. (2) Assessment of.each brigade (2) Assessment of each brigade member's knowledge of his or her member's knowledge of his or l role in the fire fighting her role in the fire fighting strategy for the area assumed to strategy for the area assumed contain the. fire. Assessment of to contain the fire; assess-the brigade member's conformance ment of the brigade member's with established plant fire conformance ' with established i fighting procedures and use of plant fire. fighting procedures; fire fighting equipment, and use of fire fighting equip-including self-contained ment, including self-contained emergency breathing apparatus, emergency breathing apparatus, I communication equipment, and communications equipment, and ventilation equipment, to the ventilation equipment, to the extent practicable. extent practical. l (3) The simulated use of fire (3) The simulated use of fire fighting equipment requird! to fighting equipment required cope with the situation and type to cope with the situation i of fire selected for the drill. and type of fire selected The area and type of fire chosen for the drill. The area and for the drill should differ from type of fire chosen for the those used in the previous drill drill will differ from those so that brigade members are used in the previous drill trained in fighting fires in t o that brigade members are various plant areas. The situa-
- rained in fighting fires in tion selected should simulate various plant aresis.
The sit-the size and arrangement of a uation selected will simulate fire that could reasonably occur the size and arrangement of i miO381-0219a100
23 APPENDIX R DESCRIPTION OF REGULATORY POSITIONS COMPLIANCE in the area selected, allowing a fire that could reasonably for iire development due to the occur in the area selected, time required to respond, to allowing for fire development obtain equipment, and organize due to the time required to for the fire, assuming loss of respond, obtain equipment, and automatic suppression organize for the fire, assuming capability. loss of automatic suppression capability. (4) Assessment of brigade leader's (4) Assessment of brigade leader's direction of the fire fighting direction of the fire fighting effort as to thoroughness, effort as to thoroughness, accuracy, and effectiveness. accuracy, and ef fectiveness. i 4. Records 4. Records Individual records of training provided Individual records of the training provided to each fire brigade member, including to each fire brigade member, including drill critiques, shall be maintained for drill critiques, will be maintained for at least 3 years to ensure that each at least 3 years to ensure that each member receives training in all parts of member receives training in all portions the training program. Those records of of the training program. These records training shall be available for NRC of training will be available for NRC review. Retraining or broadened training review. Retraining or broadened train-for fire fighting within buildings shall ing for fire fighting within buildings be scheduled for all those brigade will be scheduled for all those brigade i members whose performance records show members whose performance records show deficiencies. deficiencies. J. Emergency Lighting J. Emergency Lighting Emergency lighting units with at least an The Midland plant design provides an 8-hour battery power supply shall be provided emergency lighting system with an in alJ areas needed for operation of safe 8-hour battery supply, i 4 shutdown equipment and in access and egress routes thereto. l miO381-0219a100
24 APPENDIX R DESCRIPTION OF REGULATORY POSITIONS COMPLIANCE K. Administrative Controls K. Administrative Controls Administrative controls shall be established Administrative controls will be established to minimize fire hazards in areas containing to minimize fire hazards in areas containing structures, systems, and components important structures, systems, and components important to safety. These controls shall establish to safety. Procedures will be established to procedures to: state or control: .l. Govern the handling and limitation of 1. Use of combustible and flammable the use of ordinary combustible mate-materials in all safety-related areas, rials, 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 2. Prohibit storage of bulk combustible and safety-related areas or establish desig-flammable materials in safety-related nated storage areas with appropriate areas, or establish designated storage fire protection. areas with appropriate fire protection. 3. Govern the handling of and limit tran-3. Quantities of transient combustible and sient fire loads such as combustible and flammable liquids, wood, plastic pro-flammable liquids, wood and plastic ducts, and other combustible materials products, or other combustible materials during maintance activities, plant in buildings containing safety-related modifications and refueling activities systems or equipment during all phases to only that quantity necessary to per-of operating, and especially during main-form the activity. This control applies tenance, modification, or refueling opera-to all safety-related areas. tions. 4. Designate the onsite staff member 4. Designation of the onsite staff member responsible for the inplant fire protec-responsible for the plant fire protec-l tion review of proposed work activities tion review of praposed work activities to identify potential transient fire to identify potential tr.3nsient fire hazards and 'specify required additional hazards and specify required additional fire protection in the work activity fire protection in the work activity procedure. procedure. mIO381-0219a100
25 APPENDIX R DESCRIPTION OF REGULATORY POSITIONS COMPLIANCE 5. Govern the use of ignition sources by 5. Maintenance orders addressing fire use of a flame permit system to control protection requirements for the welding, flame cutting, brazing, or activities is assigned at the be-soldering opetations. A separate permit ginning of each shift or work actisity shall be issued for each area where work and is returned at the end of each is to be done. If work continues over shift or activity, effectively con-more than one shift, the permit shall be trolling potential ignition sources. valid for not more than 24 hours when This procedure is described in FSAR the plant is operating or for the dura-Subsection 9A.3.2.3. tion of a particular job during plant shutdown. The plant will assign a cognizant indiv-idual to coordinate plant modifica-tions. Contractors performing plant modifications are required to adhere to Consumers Power Company fire protection policies. 6. Control-the removal from the area of all 6. Removal from the area of all waste, waste, debris, scrap, oil spills, or debris, scrap, oil spills, or other other combustibles resulting from the combustibles resulting from the work work activity immediately following com-activity immediately following pletion of the activity, or at the end completion of the activity, or at the of each work shift, whichever comes end of each work shift, whichever first. comes first. 7. Maintain the periodic housekeeping 7. Periodic housekeeping inspections will be inspections to ensure centinued com-performed to ensure continued compliance pliance with these administrative with the requirements of these administra-controls. tive controls. 8. Control the use of specific combustibles 8. Requirements for the use of combus-in safety-related areas. All wood used in tible materials during maintenance, safety-related areas during mainten-modifications, or refueling operations ance, modification, or refueling opera-will have quantities of combustibles tions (such as lay-down blocks or scaf-limited to those required to support folding) shall be treated with a flame the activity. Removal of excess com-retardant. Equipment or supplies (such bustibles from safety-related areas, as new fuel) shipped in untreated com-such as packing containers or crates, bustible packing containers may be is conducted in accordance with the miO381-0219a100
56 APPENDIX R DESCRIPTION OF REGULATORY POSITIONS COMPLIANCE unpacked in safety-related areas if requirements of housekeeping procedures, required for valid operating reasons. Ilowever, all combustible materials shall be removed from the area immediately following the unpacking. Such transient combustible material, unless stored in approved containers, shall not be left unattended during lunch breaks, shift changes, or other similar periods. Loose combustible packing material such as wood or paper excelsior, or polyethylene sheeting shall be placed in metal containers with tight-fitting self-closing metal covers. 9. Control actions to be taken by an 9. Actions to be taken by an individual individual discovering a fire, for discovering a fire. For example, notif-example, notification of control room, ication of control room, attempt to attempt'to extinguish fire and actuation extinguish fire, and actuation of local of local fire suppression systems, fire suppression systems. 10. Control actions to be taken by the 10. Actions to be taken by the control room control room operator to determine the operator to determine the need for brigade need for brigade assistance upon report assistance upon report of a fire or receipt of a fire or receipt of alarm on control of an alarm (s) on the CRT at the main room annunciator panel, for example, operator's desk. For example, announcing announcing location of fire over PA location of fire over PA system, sounding system, sounding fire alarms, and fire alarms, and notifying the shift notifying the shif t supervisor and the supervisor and the fire brigade leader of fire brigade leader of the type, size, the type, size, and location of the fire. and location of the fire. 11. Control actions to be taken by the fire 11. Actions to be taken by the fire brigade brigade af ter notification by the after notification by the control room control room operator of a fire, for operator of a fire. The procedures will example, assembling in a designated contain provisions such as assembly location, receiving directions from the location, fire fighting responsabilies, fire brigade leader, and discharging fire fighting equipment selection, pro-miO381-0219a100
27 APPENDIX R DESCRIPTION OF REGULATORY POSITIONS COMPLIANCE specific fire fighting responsibilities tective equipment to be used, operating including selection and transporation of instructions for use of fire suppression fire fighting equipment to fire systems and equipment transportation location, selection of protective equip-methods. ment, operating instructions for use of fire suppression systems, and use of preplanned strategies for fighting fires in specific areas. 12. Define the strategies for fighting fires 12. Basic fire fighting strategies will be in all safety-related areas and areas developed for use in training the fire presenting a hazard to safety-related brigade on attacking and extinguishing equipment. These strategies shall fires. Fire fightir.g strategies will be designate: discussed during fire brigade training and drills. Methods for extinguishing fires from various positions and directions will l be covered as well as possible problems encountered as a result of the fire brigade responding to and extinguishing a fire. I a. Fire hazards in each area covered by Developing detailed and inflexible firt l the specific prefire plans. fighting strategies for the brigade for l l cach area may be ineffective and may b. Fire extinguishants best suited for hinder the actual fire fighting effort, j Fire fighting strategies or guidelines j controlling the fires associated with the fire hazards in that area must be flexible to be effective; fires i and the nearest location of these are never exactly the same and fire extinguishants. fighting conditions vary. Based on a fire hazards analysis, it is apparent c. Most favorable direction from which that the time a fire would most likely to attack a fire in each area in occur in any specific area would be view of the ventilation direction, when that area was subject to a access hallways, stairs, and doors transient fire loading. To write a that are most likely to be free of procedure that consistently and acc-fire, and the best station or eleva-urately determines probable fire sources, tion for fighting the fire. All ' locations of such sources, methodology access and egress routes that of fire fighting, and the equipment involve locked doors should be necessary to fight such a fire, an exact specifically identified in the knowledge of. fire loading is necessary. ciO381-0219a100
'28 APPENDIX R DESCRIPTION OF REGULATORY POSITIONS COMPLIANCE s procedure with the appropriate Because transient fire loadings cannot precautions and methods for access be accurately forecast, no procedure can specified. be adequately written to cover all the various possibilities. Consequently, d. Plant systems that should be managed while generalized. fire fighting strategies to reduce the damage potential for training are beneficial, we have con-during a local fire and the location cluded that detailed fire fighting pro-of local and remote controls for cedures by fire area are not desireable such management (e.g., any hydraulic or beneficial. or electrical systems in the zone covered by the specific fire fighting procedure that could increase the hazards in the area because of overpressurization or electrical hazards). 4 e. Vital heat-sensitive system com-ponents that need to be kept cool j whi'e fighting a local fire. Particularly hazardous combustibles that need cooling should be designated. f. Organization of fire fighting brigades and the assignment of special duties according to job title so that all fire fighting functions are covered by any complete shift personnel complement. These duties include command control I of the brigade, transporting fire suppression and suppport equipment to the fire scenes, applying the extinguishant to the fire, comm-unication with the control room, and coordination with outside fire departments, miO381-0219a100
29 APPENDIX R DESCRIPTION OF. REGULATORY POSITIONS COMPLIANCE g. Potential radiological and toxic hazards in fire zones. t h. Ventilation system operation that ensures desired plant air distribution when the ventilation flow is modified for fire containment or smoke clearing operations. 7 1. Operations requiring control room ~ and shift engineer coordination or authorization, i j. Instructions for plant operators and general plant personnel during fire. L. Alternative and Dedicated Shutdown Capability L. Alternate and Dedicated Shutdown Capability 1. Alternative or dedicated shutdown 1. The alternate shutdown capability capability provided for a specific fire provided for a specific fire area is 1 area shall be able to (a) achieve and able to achieve and maintain suberitical j maintain subcritical reactivity reactivity conditions in the reactor, conditions in the reactor; (b) maintain maintain reactor coolant inventory, reactor ecolant inventory;. (cf achieve achieve and maintain hot standby con-and maintain hot standby (as defined ditions, and achieve and maintain cold in the Standard Technical Specifications) shutdown in 72 hours. The reactor conditions for a PWR (hot shutdown for coolant process variables are maintained a BWR); (d) achieve cold shutdown (as within those predicted for a loss of I defined in the Standard Technical normal AC power. { Specifications) conditions within 72 hours; and (e) maintain cold shutdown cpnditions thereaf ter. During the postfire shutdown, the reactor coolant 4 system process variables shall be maintained within those predicted for a loss of normal A.C. power, and the fission product boundary integrity 4 miO381-0219a100
i '30 APPENDIX R DESCRIPTION OF REGULATORY POSITIONS COMPLIANCE shall not be af fected; i.e., there shall be no fuel clad damage, rupture of any primary coolant boundary, or rupture of the contain-ment boundary. i 2. The performance goals for the shutdown 2. The performance goals for the shutdown functions shall be: functions have been met as follows: a. The reactivity control function shall a. The reactivity control function is cap-be capable of achieving and main
- able of achieving and maintaining cold taining cold shutdown reactivity shutdown reactivity conditions.
conditions. b. The reactor coolant makeup function b. The reactor coolant makeup function is shall be capable of maintaining the capable of maintaining the reactor coolant reactor coolant level above the top inventory wit hin the level indicating of the core for BWRs and be within range of the pressurizer, the level indication in the pres-surizer for PWRs. c. The reactor heat removal function c. The reactor heat removal function is shall be capable of achieving and capable of achieving and maintaining decay maintaining decay heat removal. heat removal. d. The process monitoring function shall d. The process monitoring functions are be capable of providing direct capable of providing readings of the readings of the process variables process variables necessary to perform necessary to perform and control the and control the above functions. above functions. e. The suppcrting functions shall be e. The supporting functions are capable of capable of providing the process providing the process cooling, lubrica-cooling, lubrication, etc., necessary Lion, etc, necessary to permit the opera-to permit the operation of the Lion of the equipment used for shutdown equipment used for safe shutdown functions. functions. miO381-0219a100 4
'1 3 APPENDIX R DESCRIPTION OF HEGULATORY POSITIONS COMPLIANCE 3. The shutdown capability for specific fire 3. The alternate shutdown capability is in-areas may be unique for each such area, dependent of the specific fire areas and or it may be one unique combination of will accommodate post fire conditions for. systems for all such areas. In either 72 hours. Procedures will be in effect to case, the alternative shutdown capability implement this. shall be independent of the specific fire area (s) and shall accommodate postfire conditions where offsite power is avail-able and where offsite power is not available for 72 hours. Procedures shall be in effect to implement this capa-bility. 4. If the capability to achieve and maintain 4. The capability to maintain hot standby cold shutdown will not be available until cold shutdown can be achieved has because of fire damage, the equipment and been ve.-i fied. The required munber of systems comprising the means to achieve operating shift members, required to and maintain the hot standby or hot shut-operate such equipment and systems will down condition shall be capable of be onsite at all times. maintaining such conditions until cold shutdown can be achieved. If such equip-ment and systems will not be capable of being powered by both onsite and offsite electric power systems because of fire damage, an 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. l 5. Equipment and systems comprising the 5. The damage to systems required to achieve 1 means to achieve and maintain cold shut-cold shutdown are limited so that cold d,own conditions shall not be damaged by shutdown can be achieved within 72 hours. fire; or the fire damage to such equip-ment and systems shall be litited so that the systems can be made operable and cold shutdown can be achieved within 72 hours. Materials for such repairs shall be m10381-0219a100
~ ~. 3'2 APPENDIX R DESCRIPTION OF REGULATORY POSITIONS COMPLIANCE readily available on site and procedures shall be in effect to implement such repairs. If such equipment and systems used prior to 72 hours after the fire will not be capable of being powered by both onsite and offsite electric power systems because of fire damage, an 4 independent onsite power system shall be provided. - Equipment. and systems used after 72 hours may be powered by offsite power only. 6. Shutdown systems installed to ensure 6. Alteri. ate shutdown systems are designed postfire shutdown capability need not be to meet other design basis accident-l designed to meet seismic Catagory I criteria as required by interfaces with criteria, single failure criteria, or existing safety systems, other design basis accident criteria, except where required for other reasons, e.g., because of interface with or impact on existing safety systems, or because of adverse valve actions due to fire damage. 7. The safe shutdown equipment and systems 7. A postulated fire involving associated for each fire area shall be known to be circuits will not prevent a shutdown isolated from associated non-safety of the Midland Units. ' circuits in the fire area so that hat shorts, open circuits, or shorts to ground in the associated circuits will not prevent operation of the safe shut-down equipment. The separation and barriers between trays and conduits containing associated circuits of one safe shutdown division and trays and t copduits containing associated circuits or safe shutdown cables from the s . redundant division, or the isolation of these associated circuits from the safe shutdown equipment, shall be such that a 1 postulated fire involving associated miO331-0219a100
33 APPENDIX R DESCRIPTION OF REGULATORY POSITIONS COMPLIANCE circuits will not prevent safe shutdown. (An acceptable method of complying with this alternative would be to meet Regulatory Guide 1.75 position 4 related to associated . circuits and IEEE Std 384-1974 (Section 4.5) where trays from redundant safety divisions are so protected that postulated fires affect trays from only one safety division.) I M. Fire Barrier Cable Penetration Seal M. Fire Barrier Cable Penetration Seal 1 Qualification Qualification l Penetration seal designs shall utilize only Fire barrier penetration seals are noncombustible materials and shall be designed and constructed to achieve a j qualified by tests that are comparable to fire rating equivalent to the rating of i tests used to rate fire barriers. The the barrier being penetrated. Specimens acceptance criteria for the test shall of the seals will be tested in accordance include: with ASTM E 119, the NHL reference stand-1 l ard IEEE 634 as modified by NHL, and NRC Federal Register Vol. 45, No. 225, 10 CFR Part 50. The criteria used to evaluate the performance of fire stops and seals will follow the ANI-DIA/MAERP method for testing ] which is: 1. The cable fire barrier penetration seal 1. Fire shall not propagate to the unexposed has withstood the fire endurance test side of the fire stop nor shall flaming without passage of flame or ignition of be observed. cables on the unexposed side for a period of time equivalent to the fire resistance rating required of the barrier; ~2. The tempe 4ture levels recorded for the 2. The temperature on the unexposed surface l un, exposed side are analyzed and demon-of the fire stop is sufficiently below strate that the maximum temperature is the cable insulation ignition temperature. l sufficiently below the cable insulation ignition temperature; and miO381-0219a100 l l l
34 APPENDIX R DESCRIPTION OF . REGULATORY POSITIONS COMPLIANCE 3. The fire barrier penetration seal remains 3. The wall fire stops shall withstand the intact and does not allow projection of hose stream test without causing an water beyond the unexposed surface during opening in the stop. 'the hose stream test. N. Fire Doors N. Fire Doors Fire doors shall be self-closing or provided The fire hazard analysis presented in FSAR Sec-with closing mechanisms and shall be tion 9A.2 discusses each area and its fire inspected semiannually to verify that barriers in detail. Watertight, missile resis-automatic hold-open, release, and closing tant, and pressure resistant doors are mechanisms and latches are operable. considered to be equivalent to 3-hour fire doors. The rating of watertight doors is discussed in FSAR Subsection 9A.I.2.k. One of. the following measures stall be provided to ensure they will prvcect the opening as required in case of fire: 1. Fire doors shall be kept closed and All fire doors are self-closing and have been electrically supervised at a continuously identified as fire doors on the doors. Plant manned location; procedures have been established requiring all plant personnel to maintain the doors in their 2. Fire doors shall be locked closed and normally closed or locked closed position. A l inspected weekly to verify that the doors
- door.which does not have an automatic hold-are in the closed position; release mechanism and must be opened for extended periods will be monitored by a fire watch until 3.
Fire doors shall be provided with it is returned to its normally closed or locked l automatic hold-open and release position. mechanisms and inspected daily to verify that doorways are free of obstructions; or ^ 4. Fire doors shall be kept closed and Fire doors are inspected semi-annually to verify inspected daily to verify that they are-that any automatic hold-open release and closing in the closed position. mechanisms and latches are operating properly, i The. fire brigade. leader shall have ready The fire brigade leader will have access to i access to' keys for any locked fire doors, keys for any locked closed fire doors. miC331-0219a100 I
e 35 APPENDIX R DESCRIPTION OF REGULATORY POSITIONS COMPLIANCE Areas protected by automatic total flooding gas suppression systems shall have electrically supervised self-closing fire doors or shall satisfy option 1 above. O. Oil Collection System for Reactor Coolant O. Oil Collection System for the Reactor Coolant Pump Pump The reactor coolant pump shall be equipped The reactor coolant pump will be equipped with with an oil collection system if the an oil collection system. The oil collection containment is not inerted during normal system will be designed, engineered, and in-operation. The oil collection system shall stalled so that failure will not lead to a fire be so designed, engineered, and installed that during normal or design basis accident condi-failure will not lead to fire during normal tions. The collection system will be or design basis accident conditions and that seismically analyzed to withstand a safe there is reasonable assurance that the system shutdown earthquake. The collection system will withstand the Safe Shutdown Earthquake will be designed to hold the entire lube oil (See Regulatory Guide 1.29 "Sesimic Design system inventory. of all four pumps. The collec-Classification" Paragraph C.2.). tion system will be capable of collecting lube oil from all potential pressurized and unpressurized leakage sites. Such collect. ion systems shall be capable of collecting lobe oil from all potential pressurized end unpressurized leakage sites in the reactor coolant pump lobe oil systems. Leakage shall be collected and drained to a vented closed container that can hold the entire Inbe oil system invectory. 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 *, overflow lines, lube oil cooler, oil fill and drain lines and plugs, flanged connections on oil lines, and lube oil reservoirs where such features exist on the reactor coolant pumps. The drain line shall miO381-0219a100
1 o 36 APPENDIX R DESCRIPTION OF p REGULATORY POSITIONS COMPLIANCE be large enough to accommodate the largest potential oil leak. miO381-0219a100}}