ML20052F809
| ML20052F809 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 05/04/1982 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | WISCONSIN ELECTRIC POWER CO. |
| Shared Package | |
| ML20052F807 | List: |
| References | |
| TAC-43600, TAC-43601, NUDOCS 8205130672 | |
| Download: ML20052F809 (31) | |
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ENCLOSURE 1 NUCLEAR REGULATORY COMMISSTON In the Matter of
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WISCONSIN ELECTP.'C POWER
) Docket Nos. 50-266 and 50-301 COMPANY
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(Point Beach Nuclear Plant
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Unit Nos.1 and 2)
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e EXEMPTION I.
The Wisconrin Electric Power Company (the licensee) is the holder of Facility Operating License Nos. DPR-24 and DPR-27 which authorize operation of the Point Beach Nuclear Plant, Unit Nos.1 and 2.
These licenses provide, among other things, that they are subject to all rules, regulations and Orders of the Commission now or hereaf ter in effect.
The facility comprises two pressurized water reactors at the licensee's site located in Manitowoc Coanty, Wisconsin.
II.
On November 19, 1980, the Commission published a revised Section 10 CFR 50.48 and a new Appendix R to 10 CFR 50 regarding fire protection features of nuclear power plants (45 F.R. 76602). The revised Section 50.48 and Appendix R became effective on February 17, 1981. Section 50.48(c) established the
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schedules for satisfying the provisions of Appendix R.
Section-III-of Appendix R contains fifteen subsections, lettered A through 0, each of which specifies requirements for a particular aspect of the fire protection features at a nuclear power plant. Four of these fifteen subsections, III.F, III.G., III.M and III.0, are the subjects-of-this exemption request.Section III.F required installation of automatic-fire detection systems in all areas of the plant that contain or present an exposure fire hazard to safe shutdown or safety-related systems or components. These systems shall be capable of ope' rating with or without offsite' power.
III.G specifies detailed requirenents for fire 8205130672 920504 i
PDR ADOCK 05000266 F
- protection of the equipment used for safe shutdown by means of separation and barriers (III.G.2).
If the requirements for separation and barriers could not be met in an area, alternative safe shutdown capability, independent of that area and equipment in that area, was required (III.G.3.).Section III.M required qualification of fire barrier seal penetrations by tests that are comparable tto tests used to rate fire barriers.
It provided specific acceptance criteria for the qualification tests and required that penetration seal designs only use noncombustible material.Section III.0 provided requirements for the reactor coolant pump oil collection system if the containment is not inerted during normal operation. These requirements included design, installation and engineering such that failure would not lead to fire during normal or design basis accident conditions and that there would be reasonable assurance that the system would withstand the Safe Shutdown Earthquake.
Section 50.'48(c) required completion of all modifications to meet the provisions of Appendix R within a specified time from the effective date of this fire protection rule, February,17,1981, except for modifications to provide alternative safe shutdown capability. These latter modifications (III.G.3.)
require NRC review and approval. Hence, Section 50.48(c) requires their completion within a certain time after NRC approval. The da'te 'for' submittal
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of design descriptions of any modifications to pro' vide alternative safe shutdown capability was specified as March 19, 1981.
By letter dated March 18, 1981, as amended April 4, 1981, October 2, 1981 and January 29,1982, Wisc6nsin Electric Power Company requested exemptions from 10 CF'R 50.48(c) wit'h respect to the requirements of Sections III.F, III.G, l
III.M and 111.0 of Appendix R as follows:
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' 1.
That the date in Paragraph (c)(5) for submitting plans and schedules for meeting the provisions of (c)(2), (c)(3), and (c)(4), w'ith respect to the requirements of Section III.G of Appendix R to Part 50, be extended to June 30, 1982 and, with respect to the requirements of Section III.0 of Appencix R to Part 50, be extended to Jar.uary 31, 1982.
2.
That the date in Paragraph (c)(5) for submitting design descriptions of lifications needed to satisfy Section III.G.3 of Appendix R be extended to June 30, 1982.
3.
That the implementation date in Paragraph (c)(2) for the installation of modifications that do not require prior NRC approval or plant cations required by Section III.G.
30, 1982 for modifi-shut-down be extended to nine months after June That the date for implementation of modifications required by Sections III.F and III.M of Appendix R to 10 CFR 50 be extended until June 30, 1982.
4.
That the implementation date in Paragraph (c)(3) for the installation of modifications that do not require NRC approval, but require plant shut-down, be extended to before start-up after the earliest of the specified events commencing 180 days or more after June 30, 1982 for modifications required by Section III.G and to before start-up after the earliest of the specified events commencing 180 days or more after January 31, 1982 for modifications required by Section 111.0.
When this Fire Protection Rule was approved by the Comi'ssion, it was understood that the time required for each licensee to re-examine those previously-approved configurations at its plant to determine whether they meet
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the requirements of Section III.G of Appendix R to 10 CFR 50 was not well known and would vary depending upon the degree of conformance. For each item of non-conformance that was found, a fire hazards anal' sis had to be ' performed to
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determine whether the existing configuration provided sufficient fire protection.
If it did, a basis had to be formulated for an exemption request.
If it did not, modifications to either meet the requirements of Appendix R or to provide some other acceptable configuratioil, that could be justified for an exemption, had to be designed.
Wherelire protection features alone could not ensure pro- '
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tection of safe shutdown capability, alternative safe shutdown capability had to be designed as required by Section III.G.3. of Appendix R.
Depending upon
e the extensiveness and number of the areas involved, the time required for this re-examination, reanalysis and redesign could vary from a few months to a year or more. The Commission. decided, however, to require one, short-term date for all licensees in the interest of ensucing a best-effort, expedited completion of compliance with the Fire Protection Rule, recognizing that there would be 4 number of licensees who could not meet these time restraints but who could then request appropriate relief through the exemption process.
Licensees for 44 of the 72 plants to which Appendix R applies (plants with an operating license issued prior to January 1,1979) have requested such schedular relief.
The licensees for the remaining 28 plants made submittals to meet the schedular requirements of 50.48(c). All of these submittals, however, were deficient in sone respects.
In general, much of the information requested in a generic letter (81-12) dated February 20, 1981, to the licensees of all 72 plants, was not provided. Therefore, additional time is being used to conplete those submittals also.
JII.
Prior to the issuance of kppendix R, the Point Beach Units had been reviewed against the criteria of Appendix A to the Branch Technical Position 9.5-1 (BTP 9.5el). The BTP 9.5-1 was developed to resolve the, lessons learned from the fire at Browns Ferry Nuclear Plant.
It is broader in scope than Appendix R, formed the nucleus of the criteria developed further in Appendix R and in its present, revised form constitutes the section of the Standard Review Plan used for the review of applications for construction permits and operating licenses of new plants.. The review was conpleted by the NRC staff and its fire j
protection consultants and a Fire Protection Safety Evaluation (FPSER) was issued.
A few items remained unresolved.
Further discourse between the licensee and the NRC staff resulted in resolution of most of these items as documented'in three i
the extensiveness and number of the areas involved, the time required for this re-examination, reanalysis and redesign could vary from a few months to a year or more.
The Cennission. decided, however, to require one, short-term date for all licensees in the interest of ensuring a best-effort, expedited completion of compliance with the Fire Protection Rule, recognizing that there would be a number of licensees who could not meet these time restraints but who could then request appropriate relief through the exemption process.
Licensees for 44 of the 72 plants to which Appendix R applies (plants with an operating license issued prior to January 1,1979) have requested such schedular relief.
The licensees for the remaining 28 plants made submittals to meet the schedular requirements of 50.48(c). All of these submittals, however, were deficient in sone respects.
In general, much of the information requested in a generic letter (81-12) dated February 20, 1981, to the licensees of all 72 plants, was not provided. Therefore, additional time is being used to complete those submittals also.
411.
Prior to the issuance of kppendix R, the Point Beach Units had been reviewed against the criteria of Appendix A to the Branch Technical Position 9.5-1 (BTP 9.5-1).
The BTP 9.5-1 was developed _to resolve the,les. sons learned from the fire at Browns Ferry Nuclear Plant.
It is broader in scop.e than Appendix R, formed the nucleus of the criteria developed further in Appendix R and in its present, revised form constitutes the section of the Standard Review Plan used for the review of applications for construction permits and operating licenset of new plants.. The review was completed by the NRC staff and its fire protection consultants and a Fire Protection Safety Evaluation (FPSER) was issued.
A few items remained unresolved.
Further discourse between the licensee and the NRC s' aff resulted in resolution of most of these items as documented' in three t
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- supplements to the FPSER. The remaining unresolved items were to be completed in accordance with Appendix R.
The FPSER and its supplements suoported the issuance of amendments to the operating licenses of the Point Beach Units 1/
which required modifications to be made to plant physical features, systems, and administrative controls to meet the criteria of Appendix A to BTP 9.5-1.
Essentially all of these modifications have been completed. Therefore, the Point Beach Units have been upgraded to a high degree of fire protection already and the extensive reassessment involved.in this request for additional time is to quantify, in detail, the differences between what was recently approved and the specific requirements of Section III.G to Appendix R of 10 CFR 50 and to complete portions of the modifications required by Sections III.F, III.M and III.0 to Appendix R of 10 CFR 50.
III.F and III.M modifica-tions are essentially complete.
The licensee has not requested an exemption for any other subsections of Appendix R and therefore should meet the schedules required by 10 CFR 50.48(c) for all other subsections except as noted below. As mentioned earlier,
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there are 11 other subsections which contain criteria for other aspects of fire protection features. One of these,Section III.L., provides the criteria for Alternative Safe Shutdown capability and thus affects the final reassessment and redesign, if necessary, of this feature at the Point Beach Units. Neverthe-less, this means that compliance with the remaining applicable sections of 1/
- Point Beach Unit 1 - Operating License DPR-24 Amendment 39 supported by FPSER issued August 2,1979 FPSER Supplement 1 issued March 5, 1980
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FPSER Suppl.ement 2 issued-October 21, 1980 FPSER Supplement 3 issued January 22, 1981 Extension of Completion-Dates issued February 13, 1981 Amendment 52 with SER issued August 20, 1981 Point Beach Unit 2 - Operating License DPR-27 Amendment 44 supported by FPSER issued August 2,1979 FPSER Supplement 1 issued March 5,1980 FPSER Supplement 2 issued October 21, 1980 FPSER Supplement 3 issued January 22, 1981 Extension of Completion Dates issued February 13, 1981 i
Amendment 58 with SER issued August 20, 1981
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- Appendix R have been or will be completed on or before the implementation dates required by the Fire Protection Rule.
Based on the above considerations, we find that the iicensee has. completed a substantial part of the fire protection features at Point Bea'ch 'Jnits 1 and 2 in conformance with the req,irements of the Fire Protection Rule and is applying significant effort to complete the reassessment of any remaining modifications which might be necessary for strict conformance with Section III.G, and is essen-tiallly complete with the modifications required by III.F and III.M. The licensee has also completed his evaluation of the modifications necessary to comply with Section III.0 of Appendix R.
We find that because of the already-completed upgrading of these facilities, there is no undue risk to the health and safety of the public involved with continued operation until the completion of the III.G reassessment by June 30, 1982, the III.F modifications by June 30, 1982 and III.M modifications by June 30, 1982, or in extending the time for completion of nodifications required by Section III.'0.
Therefore, an exemption should be granted to allow such time for corpletion. However, because we have found that most submittals of the III.G reanalysis to date from other. licensees have not been complete; that is, not all of the information requested by Generic Letter 81-12 dated February 20,1981, was provided, we are adding a condition to this Exemption that requires all such infor-
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mation to be submitted by the date granted.
IV.
Accordingly, the Commission has determined that, pursuant to 10 CFR 50.12, an exemption is authorized by, law and will not endanger life or property or the common defense and security and is otherwise in the public interest and herehy grants the following exemptions with respect to the requirements of Section I
t III.G, III.F, III.M and 111.0 of Appendix R to 10 CFR 50:
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1.
That the date in Paragraph (c)(5) for submitting plans and schedules for meeting the provisions of (c)(2), (c)(3), and (c)(4), with respect to the requirements of Section III.G of Appendix R to Part 50, be extended to June 30, 1982 and, with respect to the requirements of Section III,n of Appendix R to Part 50, be extended to January 31, 1982.
2.
That the date in Paragraph (c)(5) for submitting design descriptions of modifications needed to satisfy Section III.G.3 of Appendix R be extended to June 30, 1982.
3.
That the implementation date in Paragraph (c)(2) for the installation of modifications that do not require prior NRC approval ~or plant shut-down be extended to nine months after June 30, 1982 for modifi-cations required by Section III.G.
That the date for implementation of modifications required by Sections III.F and III.M of Appendix R to 10 CFR 50 be extended until June 30, 1982.
4.
That the implementation date in Paragraph (c)(3) for the installation of modifications that do not require NRC approval, but require plant shut-down, be extended to before start-up after the earliest of the specified events commencing 180 days or more after June 30, 1982 for modifications required by Section III.G and to before start-up after the earliest of the specified events commencing 180 days or more after January 31, 1982 for modifications required by Section 111.0.
Provided the following condition is met with regard to t'he outstanding III.G information:
The design descriptions of alternative or decidated shutdown systems to comply with Section III.G.3., as required by 50.48(c)(5)shall include a point-by-point response to each item in Section 8 of to Generic Letter 81-12 dated February 20,1981, and to each item in Enclosure 2 to Generic Letter 81-12, dated February 20, 1981.
If the licensee does not meet the above conditions, the licensee will be found in violation of 10 CFR 50.48(c) even though the submittal may be'made within the time limit granted by the exemption.
If such a violation occurs, imposition'of a civil penalty will be considered under Section 234 of the Atomic Energy Act, as amended.
Such a violation will be a continuing one beginning with the date set in the exemption for submittal and terminating I
when all inadequacies are corrected.
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8-A delay in the determination of inadequacy by the staff, caused by the work-load associated with reviewing all of the submittals falling due near the same time, will not relieve the licensee of the responsibility for completeness 'of the submit-tal, nor will such delay cause any penalty that may be imposed to be mitigated.
The NRC staff has determined that the grantin,g of this Exemption will not r'esult in any significant environmental impact and that pursuant to 10 CFR 51.5(d)(4) an environmental impact statement or negative declaration and' environ-mental impact appraisal need not be prepared in connection with this action.
FOR THE NUCLEAR REGULATORY COMMISSION hO/
Harold R. Denton, Director Office of Nuclear Reactor Regulation Dated at Bethesda, Maryland this 4th day of May, 1982 6
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tNCLUSURL Z CLARIFICATION OF GEllERIC LETTER On February 20, 1981, ger.eric letter 61-12 was forwarded to all reactor licensees with plants licensed prior to January 1,1979. The letter restated the require-ment of Section 50.48 to 10 CFR Part 50 that each licensee would be required to reassess areas of the plant where cables or equipment including associated non-safety circuits of redundant trains of systems necessary to achieve and maintain hot shutdown conditions are located to detershine whither the require-ments of Section III.G.2 of Appendix R to 10 CFR 50 were satis'fied. Additionally, and Enclosure 2 of the generic letter requested additional
.infomation concerning those areas of the plant requiring alternative shu' tdown capability. Section 8 of Enclosure 1 requested infomation for the systems, equipment and procedures of alternative shutdown capability and Enclosure'2
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defined associated circuits and requested infomation concerning associated circuits for those areas requiring alternative shutdown.
In our review of licensee submittals and meetings with licensees, it has become apparent that the request for information should be clarified since a lack-of clarity could result in the submission of either insufficient or e,xc'essive information. Thus, the staff has rewritten Section 8 of Enclosure 1 and
' of the February 20,1981. generic letter. Additionally, fu'rther
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clarification of the definition of associated circuits has been provided tp aid in the reassessments to detemine compliance with the requirements of Sections III.G.2 and III.G.3 of Appendix R.
In developing this= rewrite we have considered the-coment of the Nuclear Utility Fire Photection Group.
The enclosed rewrite of the Enclosures contains no new requirements but merely attempts to clarify the request for additional infomation.
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2-Licensees who have not responded to the February 20, 1951 generic letter, may choose to respond to the enclosed request for information. Since the-enclosed request for information is not new, but merely clarification of our previous letter, responding to it should not delay any submittals. in progresi that are. based upon February 20, 1981 letter.
Licensees whose response to the February 20, 1981 letter, has been found.4ncomplete resulting in staff identifications of a major unresolved item (ise., associated circuits),
may choose to respond to pertinent sections of the enclosed request for infor-mation in order to close open' items (i.e., open item for. associated circuits,
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use rewrite of Enclosure 2).
If additional clarification is needed, please contact the staff Project Manager for your plant.
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REWRITE OF SECTION 8 REQUEST FOR ADDITIONAL INFORMATION The following is a rewrite of the staff's request for additional infonnaticn I
concerning design modification to meet the requirenents of Section III'.G.3 of
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Appendix P..
The rollowing contains no new requests but is merely a rewording of Section 8 of Enclosure 1 of the February 20,'1981 generic letter.
1; Ide'ntify those areas of the plant that will not meet the requirenients of of Appendix R and, thus alternathe shutdown will be provide (~
Section.III.G.2
, or an exemption from the require.ents of Section III.G.2 of Appendix R will" be provided. Additionally provide a statement that all other areas of the plant are or will be in compliance with Section III.G.2 of Appendix R.,
For each of those fire areas of the plant requiring an alternative shutdown systen(s) provide a complete set of responses to the following requests for each fire area:
a.
List the system (s) or portions thereof used to provide the shutdcwn capability with the loss of offsite power.
b.
For those systems identified in '.'la" for which alternative or dedicated shutdown capability must be provided, list the equipment and components l
of the normal ' shutdown system'in the fire area and identiff the functions of the circuits of the normal shutdown system in the fire area (power ' o what t
equipment, control of what components and instrumentation).
Describe 1
the system (s) or portions thereof used to provide the alternative shutdown capability for the fire area and provide a table that lists the equipment, and components of the alternative shutdown system for the fire area.
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For each alternative system identify the function of the new l
circuits being provided.
Identify the location (fire zone) of the i
alternative shutdown equipment and/or circuits that bypass the fire' l
area and verify that the alternative shutdown equipment and/or circuits are separated from the fire area in accordance with Section III.G.2.
c.
Provide drawings of the alternative shutdown system (s) which highlight any conne_ctions to the normal sh'tdown systems (P& ids for piping anc components, u
elementary wiring diagrams of electrical cabling).. Show"the electrical location of all' breakers for power cables, and. isolation devices for control and instrumentation circuits for the alternative shutdown systems for that fire area.
d.
Verify that changes 'to safety systems will not degrade safety systems;'
(e.g., new isolation switches and control switches should meet design criteria and standards in the FSD. for electrical equipaent in the system
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that the switch is to be installed; cabinets that the switches are to be mounted in should also meet the same criteria (FSAR) as other safety related cabinets and panels; to avoid inadvertent is' lation,from the o
control room, the isolation switches should be keylocked or alamed in the contro1 room if in the " local" or "is~olated" positi'on; period.ic
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checks should be made to verify that the switc'h is in the proper position for
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normal operation; and a single transfer switch or other new 'davice should not be a source of a failure which causes loss of reaunaant safety 4
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Verify that licensee procedures have been or will be develo' ped which describe she a.'
tasks to be perfomed to effect the shutdown. method.
Provide a summary of these procedures outlining operator actions.
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Verify that the manpower required to perform the shutdown functions using the prccedures of e:. as well as to provide fire brigade member: to fight the fire is available as required by the fire brigade technical speci-fications.
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9 Provide a commitment to perform adequate acceptance tests of the alter-
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native shutdown capability.
These tests should verify that:. equipment operates from the local control station when the transfer or isolation switch is placed in the " local" position and that the equipment cannot be operated from the c'ontrol room; and that equipment operates from'the control room but cannot be operated at the local control station when the transfer isolation switch is in the " remote" position.
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Provide Technical Specifications of the surveillance requirements and limiting conditions for operation for that equipment not 'already '
covered by existing Technical Specifications.
For. example, if new,
isolatio.n and control switches are added to a shutdown system, the existing Technical Specification surveillance requirements should
.be supplemented to verify system / equipment functions from the alternate shutdown station at testing intervals consistent with.the guidelines of Regulatory Guide 1.22 and IEEE 338.
Credit may be taken for other existing l
tests using group overlap test concepts.
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For new equipnnt comprising the alternative shutdown capab*11ty, verify that the systems available-are adequate to perform the necessary. shut-down function. The functions required should be based on previous analyses, if possible (e.g., in the FSAR), such as a loss of normal ac power or shutdown on Group 1 isolation (BWR).
The equipment required for the alternative capability should be the same or equivalent to that relied on in the above analysis.
j Ierify.that repair procedures for cold shutdown systes are developed and material for repaiis is maintained on site.
Provide a summary of these procedures and a: list of the material needed for repairs.
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.tNCLOSURE 2 SAFE SHUTDOWN CAPABILITY The following discusses the requirements for-protecting redundant and/or alternative equipment needed for safe shutdown in the event of a fire. The requirements of Appendix R aodress hot shutdown equipment which must be free of fire damage.
The following requirements also apply to cold s, hut'down equipment if tha licensee elects to deEonstrAte that the.equipgent.is to be free of. fire. damage. AppendEc R does allow.rejairable damage to cold shutdown ecutoment.,
Using the requirements of Sections III.G and III.L of Appendix R, the ca'pa-bility'to achieve' hot shutdown must exist given a fire in any area of the plant in conjunction with a. loss of offsite power for.72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Section III.G of Appendix R provides four methods for ensuring that th'e hot shutdown capa-bility is protected from fires. The first three options as defined in Section IIT.G.2 provides methods for protection from fires of equipment needed fer
. hot shutdown:
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Redundant systems including, cables, equipment, and associated circuits may be separated by a three-hour fire rated barrier; or, Redundant systems.tncludi.ng cables, equipment and _ associated cir,cuits may 2.
be. separated by a horizontal distance of more than 20 f'eet with no inter-vening combustibles.
In addition, fire detection and an automatic fire suppression system are required; or,
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3.
Redundant systems including cables, equipment and associated circuits may by enclosed by a one-hour fire rated barrier.
In addition, fire detectors and an iutomatic fire suppression system are required.
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, The last option as defined by Section III.G.3 provides an alternative shutdo capability to the redundant trains damaged by a fire.
Alternative shutdown equipment must be independent of the cables, equip 4.
ment and associated circuits of the redundant systems damaged by the f Associated Circuits of Concern The following discussion provides A) a definition of associated circuits fo Appendix R consideration, B) the guidelines for protecting the safe
- In-capability from the fire-induced failures of associated circuits and C The definition formation required by the staff to review associated circuits.
20, 1981 generic letter;.
of associated circuits has not changed from the February It is important to note that our interest is only but is merely clarified.
with those circuit (cables) whose fire-induced failure could The guidelines for protecting the safe shutdown capability from the These guidelines should failures of associated circuits are not reouirements_.
These guidelines do not' limit the alter.
be used only as guidaned when needed.
natives available to the licensee for protecting the shutdown capability.
All proposed methods for protection of the shutidown capability failures will be evaluated by the' staff for acceptability..
Our concern is that circuits sithin the fire area will, receive fir,e da. ma A.
b t post-fire safe which can affect shutdown capability and there y preven Associated tircuits* of Concern are defined as those c
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shutdown.
(safety 7 elated,non-sa'fetyrelated, Class 1E,andnon-Class 1E)th
- The definition for associated circuits is not exactly the same as the definition presented in IEEE-384-1977.
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1.
Have'a physical separation less than that required by Section III.G;2 of Appendix R,.and;
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2.
Have one of the following:
a.
a common po'wer source with the shutdown equipment (redundant or' alternative) and the power source is not electrically protected from the circuit of concerp by coordir.ated breakers, fuses, o~r similar devices (see diagram 2a), or b.
a connection to circuits of equipment whose spurious operation would a'dversely affect,the shutdown capability (e.g., RHR/RCS 1
isolation valves, ADS valves, PORVs, steam generator atmospheric dump valves, instrumentation, steam bypass, etc.) (see diagram 2b), or a comon enclosure (e.g., raceway, panel, junction) with the shutdown c.
cables (redundant and alternative) and, (1) are not electrically protected by circuit breakers, fuses or simi-lar devices, or (2) will allow propagation of'the fire into the common, enclosure, (see diagram'2c).
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EXAMPLES OF ASSOCIATED CIRCUITS OF CONCERN 1
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The area barriers shown above meet
.Epup,,,c4 a,,e,yu the~ appropriate sub-paragraphs (a-f) 6-hus
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's-i Diagram 2A Diagiam 2B Diagram 2C 4
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The following guidelines are for protacting the shutdown capability from fire-induced failures of circuits (cables) in the fire area. The guidance
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provided below for interrupting devices applies only to new devices installed to provide electrical isolation of associated circuits of concern, or as.
..part of the alternative or dedicated shutdown system. The shutdown capability may be protected from the adverse effect of damage to associated circuits s
of concern by the following methods:
1.
Provide protection between the associated circuits of concern and the shutdown circuits as per Section III.G.2 of Appendix R, or 2.
a.
For a comon power source case of associated circuit:
provide load fuse / breaker (interrupting devices) to' feeder fuse / breaker coordination to prevent loss of the redundant or alternative shutdown power source. To ensure that the following coordination criteria are met the 'foi-)owing should apply:
(1)
The associated circuit of concern interrupting devices '
(breakers or. fuses) time-overcurrent trip characteristic
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for all. circuits faults should cause the interruptin,g device to interrupt the fault current prioi to initiation
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of a trip of any upstream interrupting device which will' cause a loss of the common power source, J2) The power source shall supply t'he necessary fault current for sufficient time to ensure the proper coordination without loss of function of the shutdown loads.
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i The acceptability of a particular interrupting device is considere'd demonstrated if the following criteria are met:
(i) The interrupting device design shall be factory tested to verify overcurrent protection as designed in accordance with the applicable UL, ANSI, or NEMA standards.
(ii)
For low and medium voltage switchgear (480 V and above) circuit breaker / protective relay periodic testing shall demonstrate that the overall coordination scheme remains within the limits specified in the design criteria. This
. testing may be performed as a series of overlapping tests.
(iii) Molded case circuit breakers shall peridically be manually exercised and inspected to insure ease of operation. On a rotating refueling outage basis a' sample of these breakers shall be tested to datermine that breaker drift is within
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that al' lowed by the design criteria.
Breakens'should be tested in accordance with an accepted QC testing methodology s0ch as MIL STD 10 5 D.
(iv)
Fuses when used as interrupting devices do not require i
periodic testing, due to their stability, lack of drift, an'd high reliability. Administrative controls must insure that replacement fuses with ratings other than those selected for proper coordinating are not accidentally used.
1 b.
For circuits of equipment and/or components whose spurious operation i
would affect the capability 'to s'afely shutdown:
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t (1) provide a means to isolate the equipment rnd/or cceponents from the fire area prior to the fire (i.e., remove power cables, open circuitbreakers);or (2) provide electrical isolation that prevents spurious operation..
Potential isolation devices include breakers, fuses, ampli-fiers, control switches, current XFRS, fiber optic couplers, relays and transducers; or
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(3) provide a means to' detect spunious operations and then proce-dures to defeat the maloperation of equipment (i.d., closure of the block valve if PORV spuriously operates, opening of the breakers to remove spurious operation o.f safety injection);
For common enclosure cases of associated circuits:
c.
(1) provide appropriate measures to prevent propagation of the fire; and (2) provide electrical protection (i.e., breakers, fuses or
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similardevices)
C.
We recognize that there are different approaches which may be used to reach the same objective of determining the interaction of associated circuits with shutdown sy, stem, s.
One approach is to start with the fire area, iglentify what is in the fire area, and'detemine the interaction between what is in the fire area and the shutdown systems which are outside the fire area. We have entitled this approach, "The Fire, Area Approach." A second approach which we h' ave named "The Systems Approach" would be to define the shutdown systems around a fire area and then determine G
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those circuits that are located in the fire area that are associated with the shutdown system. We have prepared two sets of requests for
- information, one for each approach. The licensee may choose to respond to either set of requests depending on the approach selected by the licensee.
FIRE' AREA APPROACH 1.
For each fire area where an alternative or dedicated shutdown method, in accordance with Section III.G.3 of Appendix R is provided, the
'following information is required to demonstrate that associated circuits will not preverit operation or cause maloperation of the alternative or dedicated sh'utdown method:
a.
Provide a table that lists all the power cables in the fire area 9
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that connect to the same power supply of the. alternative or dedicated shutdown method and the function of. each power cable listed (i.e., power for RHR pump).
b.
Provide a table that lists all the cables in the fire area that were considered for. possible spurious operation which would, adversely affect' shutdown and the function of each ~ cable. listed..-
c.
Provide a table that lists all the cables in the fire area that t
. share a common enclosure with circuits of the alternative or dedicated shutdown systems and the function of each cable listed.
d.
'Show that fire' ~ induced failures (hot shorts, open circuits or shorts to ground) of each of the cables listed in a; b, and c will not prevent operation or cause maloperation of the alternative
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or dedicated shutdevn method.
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For each cable listed in a, b and c where new elect.-ical isolation has e.
been provided or modification to existir.g electrical isolatior, has
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been made, provide detailed electrical schematic drawings that show how each cable is isolated from the fire area.
SYSTEMS APPROACH 1.
For each area where an alternative or dedicatied shutdown method, in accordrnce with Section III.G.3 of Appendix R is provided, the following information is required to demonstrate that associated circuits will not prevent operation or'cause maloperation of the alternative or dedicated shutdown method:
Describe the methodology used to assess the potential of associated a.
circuit adversly affecting the alternative or dedicated shutdown.
The descriptiori of the methodology should include the methods used to identify the circuits which share a comon power supply or a comon enclosure with the alternative or dedicated shutdown system and the circuits whose spurious operation would affect shutdown. Additionally, the description should include the
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methods used to identify if these circuits are associa ed circuits of concern due to their location in the fire area.
b.
Provide a table that lists all associated circuits of concern
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located in the fire' area.
Show tha,t fire-induced failures (hot shorts, open circuits or c.
shorts to ground) of each of the cables listed in b will not prevent operation or cause maloperation of the alternatife or.
dedicated shutdown method.
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~ d.
For each cable listed in b where new electrical isolation has been provided, provide detailed electrical schemati: drawings that show how each cable is isolated from the fire area.
Provide a location at the site or other offic'e.s where a.ll the e.
tables and driwings generated by this metho'do'le'gy approach for the associated circuits review ma be pudited to verify,the information provided above.
HIGH-1.0W PRESSURE INTERFACE For either approach chosen the following concern dealing with high-low.
pressure interface should be addressed.
2.
The residyal heat removal system is generally a low p,res,sure system that interfaces with the high pressure primary coolant system. To preclude a LOCA through this interface, we require compliance with the recommendations of Branch Technical Position RSB 5,1.
Thus, the interface most likely consists of'two redundant and independent motor
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operated valves. These two motor operated valves and their associdted
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cables may be subject to,a single f. ire hazard.
It is~ ou~r c6ncern.that
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this single fire could cause the two valves'to open resultiniin a"fireinitiatedLOCAthroughthehigh-lowprbssuresystem interface. To assure that this interface and other high-low pressure interfaces aie idequately protected from the effects of a single fire, we require the following information:
a.
Identify each high-low pressure interface that uses redundant alectrically controlled dev' ices' (such.as two series motor operatd valves) to isolate or precludeJrupture of any primary coolant bounda ry.
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For each set of redundant valves identified in a., verify the b.
redundant cabling (power and control) have adequate physical i
separation as Nguired by Section III.G.2 of Appendix R.
that For each :sse where adequate separation is r.et previded, shot:
fire induced failures (hot short, open circuits or short 'to g c.
' of the cables will not cause maloperation and result in a LOCA o#
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CRITERIA FOR EVALUATING EXEMPTIONS TO SECTION III G OF APPENDIX R OF 10 CFR PART 50 Paragraph 50'.48 Fire Protection of 10 CFR Part 50 requires that all nuclear power plants licensed prior to January 1,1979 satisfy the requirements of Section III.G of Appendix R to 10 CFR Part 50.
'It also requires that alternative' fire protection configurations,.
previously appioved by an SER be reexamined for compliance withSection II the requirteents of Section III.G.
protection features for ensuring that systems and associated circuits used to achieve and maintain safe shutdown.are free of fire damage.
Fire protection configurations'must either meet the specific must be,$dstified by a fire hazard analysis.
The general criteria for accepting an alternative fire protection configur-ations are the following:,.
The alternative assures that one train of equipment nece stations is free of fire damage.
The alternative assures that fire damage h.o at least one train'of is limited such ttjat equipment necqssary to achieve cold shutdown (minor repairs with it can be repaired within a reasonable time components stored on-site).
Fire retardant coatin.gs are not'used as fire barriers.
Modificati3ns required to meet Section III.G would. net enhance fire protection safety above that providpd by either existing or proposed alternatives.
Modifications required to meet Section III.G would be detrimental to overall facility safety.
Because of the broad spectrum of potential con f
' the parameters that are important to fire protection and consis safety requirements of all plant-unique configurations i
ments in our pr_evious reviews and in the reques developed.
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ih specific criteria have been developed, q
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2-A passive-Section 111.G.2 accepts three methods of fire protection.Where a fixed barrier 3-hour fire barrier should be used where possible.
cannot be installed, an automttic suppressier. ystem in combination with a fire barrier or a separation distance free of ecmbustibles is used if the. configurations of systems to be protected and in-situ combustibles are such that there is. reasonable assurance that the protected systems will If this latter co.ndition is not met, alternative shutdown capa-bility is required and a fixed suppression system installed in the fire-survive.
'~It is area of concern, if it contains a large concentration of ca However, they provide adequate protection for those to be equivalent.
configurations in which they are accepted.
hheri the fire protection fe'atures of each fire. area are evaluated, the The defense-whole system of such features must be kept in perspect Strengthening, any one adequate balance between the different features.can compens The adequacy cf fire protection for any particular plant safety' system or area is determined by analysis of the effects of pos active releases to the environment in the event of a fire. During thes,e evaluations it is necessary to consider the two-edged nature of fire protection features recognized in General Desi An evaluation must be made.for each fire area for which is requested.
parameters:-
'A.. Area Description walls, floor, and esiling construction ceiling height room volume ventilation congestion Safe Shutdown Capability B.
number of redundant systems in area whether or not system or equiment is required for hot shutdown
- - type of equipment / cables involved
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within this area
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repair time for cold shutdown equipmn?
separation between redundant c.omponents and in-situ concentration of combustibles 1
alternative shutdown capability
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C.
Fire Hazard Analysi:
d type and configuration of combustibles in area quantity of combustibles ease of ignition and propagation heat release rate poter.tial transient and installed combustibles
. suppression damage to equipment whether the area is continuously manned traffic through the area accessibility of the area D.
Fire Protection Existing or Committed fire detection systers fire extinguishing systems
..ho,se station / extinguisher radian,t heat shields A. specific description of the fire protection features of the configuration is required to justify the compensating' features of the alternative; Low 1
fire loading is not a sufficient basis for granting an exemption in areas where there are cables.
If necessary, a team of. experts, including a fire protection engineer, This visual
.will visit the site to determine the existing circumstances.
inspection is also' considered in the review process.
The majority of the III.G exemption requests received to date are being denied because they lack specificity. Licensees have not identified the extent of the exemption requested, have not provided a technical basis t
For the request and/or have not provided.a specific description of the alternative. We expect to receive requests for exenption of the.following
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. nature:
1.
Fix'ed fire barriers less than 3-hour rating.
Fire barrier without an automatic fire suppression system..
2.
Less than 20 feet separation of cables with fire propagation 3.
retardants (e.g., coatings, blankets, covered trays) and an automatic suppressio,n system.
.For large open areas with few components.to be protected and few in-situ i
4.
combustibles, no automatic suppression system with separation as in Item 3
j 3 above.
5.
No fixed suppression in the contr'o1 foom.
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No fixed suppression in areas without - large concentration of cables for which alternative shutdown capability has been provide 4 Our fire research test program is conducting tests to provide information
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that will be useful to determine the boundary of acceptable conditions for fire protection configurations which do not include a fire rated barrier.
Based on deviations recently approved, specific criteria for certain recurring configurations are as follows:
Fire Barrier Less than Three Hours This barrier is a wall, floor, ceiling or an enclosure which separates one fire area from another'.
Exemptions may be granted for a lower rating (e.g., one hour or two hou'rs) where the fire loading is no more than 1/2 of the barrier rating. The fire rating of the barrier shall'be no less than one hour.
Exemptions may be granted for a fixed barrier with a lower fix rating
' supplemented by a water curtain.
An Automatic Suppression System With Either One Hour Fire Barrier or 20-Foot Separation
_This barrier is an enclosure which separates those portions of one division which are within 20' feet of the redundant division,. The suppressant may be water or gas.
Exemptions may be granted for configurations of redundant systems which
'have compensating features.
For example:
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Separation. distances less.than 20 feet may be deemed acceptable where:
A.
1.
Fire propagation retardants (i.e., cable coatings, covered trays, conduits, or mineral wool blankets) assure that fire propagation through in-situ combustibles will not occur or will be delayed sufficiently to ensure adequate time for detection and' suppression.
Distance above a fl.cor level exposure fire and below ceiling assures 2.
that redundant systems will not be simultaneously subject to an unasceptable temperature or heat flux.
The ommission of an automatic suppression system may be deemed acceptabic B.
where:
Distance above a floor level exposure fire and below ceiling assures 1.
that redundant systems will not be simultaneously subject to an unacceptable temperature-cr heat flux..
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.2. 'The fire area is required to be manned continuously by the provisions in the 72chnical Specifications.
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