ML20052F976
| ML20052F976 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 05/10/1982 |
| From: | Crutchfield D Office of Nuclear Reactor Regulation |
| To: | Linder F DAIRYLAND POWER COOPERATIVE |
| References | |
| GL-81-12, LSO5-82-05-019, LSO5-82-5-19, NUDOCS 8205140204 | |
| Download: ML20052F976 (25) | |
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May 10,1982
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',f DI STRI BUTI ON N' 7 N' e Doc ket Docket No. 50-409 NRC PDR LSO:
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br. Frank Linder DCrutchfield General Manager y
HSmi t h Dairyland Power Cooperative
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gp RDudl ey 4 kT[4 2615 East Avenue South OELD Lacrosse, Wisconsin 54601 OI &E ACRS (10)
Dear Mr. Linder:
SE PB VBenaroya
SUBJECT:
FIRE PROTECTION RULE (10 CFR 50.43) REQIIIREMENTS RFerguson TWambach RE:
La Crosse Boiling Water Reactor The Fire Protection Rule (10 CFR 50.48 and Appendix 7 to 10 CFR 50) became effective on February 17, 1981.
On February 20, 1981, in generic letter 81-12 sent to all licensees, you were requested to submit your
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plans and schedules for meeting the provisions of Paragraphs (c)(2),
(c)(3) and (c)(4) of 10 CFR 50.48 as well as your reassessment of the i
design features at your plant for meeting the requirements of Sections III.G III.J and III. O of Appendix R to 10 CFR Part 50.
On March 19,1981 (LAC 7424), you responded by requesting an exemption from Section III.0 of Appendix R which was granted by the NRC on March 1, 1982.
Your March 19, 1981 letter also contained detailed information regarding your facility's capability to meet Section III.G of Appendix R which was presented in response to open items 3.1.20, 3.1.22(2), 3.2.1 and 3.2.4 of a previous NRC Fire Protection Safety Evaluation Report issued on July 27,1979 (License /cendment No.17).
However, Section 50.48(b) of the fire protection rule states that nuclear power plants licensed before January 1,1979 shall comply with the specific require-ments of Sections III.G, III.J, and III.0, except for fire protection features proposed or inplemented by the licensee which have been accepted by the NRC staff in safety evaluation reports issued prior to ti e effective date of the rule.
Therefore, we have reviewed your submittal of March 19, 1981 and find that additional information is required for us to complete our review.
Provide a complete response to itens indicated in Enclosure 1 within six months of receipt of this letter.
If your response is not complete at that time, you will be found in violation of 10 CFP, 50.48(c)(5).
Such a violation will be a continuing one and a civil penalty may be imposed for each day the violation continues.
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Mr. Frank Linder. May 10,1982 This information was originally reque;ted from you by generic letter 81-12, dated February 20, 1981, which was approved for issuance by GA0 clearance number R0071. Therefore, this request is for information within the purview of that approval. of this letter provides a rewording of the request for information included with generic letter 81-12. This rewording is the result of meetings with representative Itcensees who felt that clarification of the request would help expedite responses. It does not include any new requests and, therefore, will not adversely affect ifcensees' ability to respond to generic letter 81-12. provides information regarding our criteria for evaluating exenption requests from the requirements of Section III.G.2 of Appendix R.
Sincerely, Original signed by Dennis M. Crutchfield, Chief Operating Reactors Branch #5 Division of Licensing
Enclosures:
(2)
As stated cc w/ enclosures:
See next page l
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- Mr. Frank Linder May 10,1982 Cc Fritz Schubert, Esquire U. S. _ Environmental Protection Staff Attorney Agency Dairyland Power Cooperative Federal Activities Branch 2615 East Avenue South Region V Office La Crosse, Wisconsin 54601 ATTN:
Regional Radiation Representative 230 South Dearborn Street O. S. Heistand, Jr., Esquire Chicago, Illinois 60604 Morgan, Lewis & Bockius 1800 M Street, N. W.
Mr. John H. Buck Washington, D. C.
20036 Atomic Safety and Licensing Appeal Board U. S. Nuclear Regulatory Commission Mr. R. E. Shimshak Washington, D. C.
20555 La Crosse Boiling Water React'or Dairyland Power Cooperative Mr. Ralph S. Decker P. O. Box 135 Route 4, Box 190D Genoa, Wisconsin 54632 Cambridge, Maryland 21613 Mr. George R. Nygaard Charles Bechhoefer, Esq., Chairman Coulee Region Energy Coalition Atomic Safety and Licensing Board 2307 East Avenue U. S. Nuclear Regulatory Commission
.La Crosse, Wisconsin 54601 Washington, D. C.
20555 Dr. Lawrence R. Quarles Dr. George C. Anderson Kendal at Longwood, Apt. 51 Department of Oceanography Kenneth Square, Pennsylvania 19348 University of Washington Seattle, Washington 98195
,U. S. Nuclear Regulatory Commission Resident Inspectors Office James G. Keppler, Regional Administrator Rural Route #1, Box 276 Nuclear Regulatory Commission, Region Ill Genoa, Wisconsin 54632 799 Roosevelt Road G1en Ellyn, Illinois 60137 Town Chairman Thomas S. Moore Town'of Genoa Atomic Safety and Licensing Appeal Board Route 1 U. S. Nuclear Regulatory Commission Genoa, Wisconsin 54632 Washington, D. C.
20555 Chairman, Public Service Commissi6n of Wisconsin Hill Farms State Office Building
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Madison, Wisconsin 53702 Alan S. Rosenthal, Esq., Chairman
. Atomic Safety and Licensing Appeal Board U. S. Nuclear Regulatory Commission Washington, D. C.
20555 W
,3 CLARIFICATION OF GEllERIC LETTER On February 20, 1981, generic letter 81-12 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 nece'ssary to achieve and mair.tain hot shutdown conditions are located to determine whether the require-ments of Section III.G.2 of Appendix R to 10 CFR 50 were satisfied. Additionally, l and Enclosure 2 of the generic letter requested additional infomation concerning those areas of the plant requiring alternative shutdown capability. Section 8 of Enclosure 1 request'ed information for the systems, equipment and procedure' of alternative shutdown capability and Enclosure'2 s
defined associated circuits and requested information concerning ' associated circuits for those areas requiring alternative shutdown.
In our review of licensee submittals and metings 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,xcessive l
information. Thus, the staff has rewr.itten Section 8 of Enclosure 1 and
' of the' February,20,1981 generic letter. Additionally, further clarification of the definition of associated circuits has been provided to aid in the reassessments to determine compliance with the requirements of Sections III.G.2 and III.G.3 of Appendix R.
In developing this rewrite we have t
I considered the coment of the Nuclear Utility Fire Protection Group.
The attached
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rewrite of the Enclosures contains no new requirements but merely attempts l
l to clarify the request for additional information.
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2-k.icensees who have not responded to the February 20, 1981 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 progress that are. based upon February 20, 1981 letter.. Licensees whose.
response to the February 20, 1981 letter, has been found [ncomplete resulting in staff identifications of a major unresolved item (14el, 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. assoc'iated circuits, use rewrite of Enclosure 2).
If additional clarification is needed, please contact the staff Project Ilanager for your plant.
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ATTACEERnr 1 N
c REWRITE OF SECTION 8 REQUEST F0P ADDITIONAL INFORMATION The following is, a rewrite of the staff's request for additional information concerning design modification to meet the requirements of Section III.'G.3 of Appendix P..
Trc following contains no new requests but is merely a rewording of Section 8 of Enclosure 1 of the February 20, 1981 generic letter.
l.
Identify those areas of the plant that will not meet the requirements of Section III.G.2 of Appendix R and', thus alternative shutdown will be provideh
, or an exemption from the requirements 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 f. ire area:
List the system (s) or portions thereof used to provide the shutdown a.
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 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 to wha' equipment, control of what components and instrumentation).
Describe the system (s) or portions thereof used to provide the alternative shutdown capabibty 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 c'ircuits being provided.
Identify the location (fire zone) of the alternative shutdown equipment and/or. circuits that bypass the fire area and verify that the alternative shutdown equipment and/or circuits e
O are separated from the fire area in accordance with Section II.I.G.2.
Provide drawings of the alternative shutdown system (s) which highlight any c.
connections to the normal sh' tpown systems.(P& ids for piping ana 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 d criteria and standards in the FSAR for electrical' equipment in the sys that the switch is to be installpd; 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 isolation from the control room, the isolation switch'es should be keylocked or alamed in the control. room if in the " local" or " isolated" position; periodic
' checks should be made to verify that the switch is in the proper position for
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nomal operation; and a single transfer switch or other new device should not be a source of a failure which causes loss of recunaant saft:ty i
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systems).
Verify that licensee procedures have been or will, be develop' ed which d a.'
tasks to be perfomed to effect the shutdown method.
Provide a summary
,of these procedures outlinin,q operator actions.
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Verify that the manpower required to perform the shutdown functions using
.the proce~dures of e:. as well as to provide fire brigade members to fight the fire is available as required by the fire brigade technical speci-fications.
9 Provide a commitment to perform adequate acceptance tests -f 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 control room; and that equipment operates from~ the control room but cannot be operated at the local contro1' station when
.the transfer. isolation switch is in the " remote" position.
h.
Provide Technical Specifications of the surveillance requirements and limiting conditions for operation for that equipment not alr'eady '
covered by existing Technical Spedifications.
For example, if ne.w isolation 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 tests using group overlap test concepts.
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For new equipment comprising the alternative shutdown capability, verify that the systems available are adequate to perform the necessary shut '
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down function. The fuhetions 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 isola, tion (BWR).,The equipment required for the alternative capability should be thi same or equivalent to that relied on in the above. analysis.
j Verify.that repair, procedures for cold shutdown systems 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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SAFE SHUTDOWN CAPABILITY o,
The following discusses the requirements for. protecting redundant and/or The alternative equipment needed for safe shutdown in the event of a fire.
require ^ments of Appendix R address hot shutdown equipment which must b The following.rsquirements also apply to cold s,butdown a
free of fire damage.
equipnent if the. licensee elects to-deEenstrate that the. equip 9ent..is to be Appandfx R does allow.rejairable damage to cold shutdown free of fire. damage.
eouf oment'.
_Us'ing the requirements of Sections III.G and III.L of Appendix R, the capa -
bility 'to achieve hot shutdown must exist given a fire in any area of the Section III.G 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 />.
of Appendix R provides four methods for ensuring thati the hot shutdown capa-bility is protected from fires. The first three options as defined in Section III.G.2 provides methods for protection from fires of eqtripment needed for hot shutdown:
Redundant systems including cablesh equipment, and associated circuits 1.
may be separated by a three-h5ur fire rated barrier; or, Redundant systems.tncitiding cables ~, equipment and associated circuits may.
2.
be separated by' a horizontal distance of more than 20, feet with no inter-In addition, fire detection and an automatic fire vening, combustibles.
suppression system are required; or, Redundant systems including cables, ecoipment and associated circuits may 3.
In addition, fire detectors by enclosed by a one-hour fire rated barrier.
and a.n automatic fire suppression system are required.
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' l The last option as defined by Section III.G.3 provides an alternative s'hutdown
- capability to the redundant trains damaged by a fire.
4.
Alternative shutdown equipment must be independent of the cables, equip-
~i ment and associated circuits of the redundant systems damaged by the fi~re.
Associated Circuits of Concern The following discussion provides A)'a definition of associated circuits for,
" Appendix R consideration, B) the guidelines for protecting the safe' shutdown
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capability from the fire-induced failures of associated circuits and C) the in-formation requ' ired by the staff,to review associated circuits. The definition of associated circuits has not changed from the February 20, 1981 gercric letter; -.
but is merely clarified.
It is important to note that our interest is only with those circuit (tables) whose fire-induced failure could effect shutdown.
The guidelines for protecting the safe shutdown capability from the fire-induced
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failures of associated circuits are not recuirements.
These guidelines should i
be used only as guidancs when needed. These guidelines do not' limit the' alter.
I natives available to the licensee for protecting the shutdown capability.
All proposed methods for protection of the shutdown capability from fire-inducsd failures will be evaluated by the staff for acceptability,
A.
Our concern is that circuits within the fire area,will, receive fire damage yhich can affect shutdown capability and thereby prevent post-fire safe shutdown. Associated Circuits
- of Concern are defined as th'ose cables (safety related, non-safety related, Class lE, and non-Class 1E) that:
- The definition for associated circuits is not exactly the same l
l as the definition presented in IEEE-3S4-1977, 1
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1.
Have a physical separation less than that required by Section III.G.2 of Appendix R,.and; l
2.
Have one of the following:
a.
a common power source with the shutdown' equipment (redundant or alternative) and the power source is not electricalli protected fromthecircuitofconcerpbycoordinatedbfeakers, fuses,or similar devices (see diagram 2a), or aconnectiontocirc'uitsofequipmentwhoses5uriousoher~ation b.
would adversely affect,the shutdown capability (e.g., RHR/RCS isolation valves, ADS valves, PORVs, steam genera. tor; atmospheric dump valyes, instrumentation, steam bypass, etc.) '(see; diagram 2b), or
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a common enclosure (e.g., raceway, panel, junction)' with the shutdown P
c.
cables (redundant and alternativp) and, l
(1) are not electrically protected by circui.t. breakers, fuses.or simi-lar devices, or i
(2)will allow propagation of the fire into the' common ~
l enclosure, (see diagram 2c).
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EXAMPLES OF ASSOCIATED CIRCUITS OF CONCERN I
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fum P The area barriers shown above meet Ep.u g a,,e,ga 'ans the~ appropriate sub-paragraphs (a-f) o - sus i
f *'*II'd ca"M al'fac/.
of section III.G-2 of Appendix R.
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Diagram 2A Diagram 28 Diagram 2C
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4-B.
The following guidelines are for protecting the shutdown capability from fire-induced failures of circuits (cables) in the fire area. The guidance 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 tb associated circuits of concern by the following methods:
1.
Provide protectio'n 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:
Provi'de load fuse / breaker.(interrupting devices) to feeder fuse /bre,aker coordination to prevent loss of the redundant or alternative shutdown power source.
To ensure that the following coordination criteria are met the 'foT}owing should apply:'.
(1) The associated circuit of concern interrupting devices '
(breakers or. fuses) time-overcurrent trip characteristic for all circuits faults should cause the interrupting device to interrupt the fault current prior to initiation i
of a trip of any upstream interrupting device which will cause a loss of the cor: mon power source,
,(2) The power source shall supply t'he necessary fault current for sufficient time to ensure the proper ccordination without loss of function of the shutdown loads.
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The' acceptability of a particular interrupting device is considered demonstrated if the following criteria are met:
l (i) The interrupting device design shall be factory tested to verify overcurrent protection as designed in accordance with
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the applicable UL, ANSI, or NEMA standards.
(ii) For low and medium. voltage switchgear (480 V and above) ---
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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) Holded case circuit breakers shall peridically be nanually-exercised and inspected to insure ease of operation..On a rotating refueling outage basis a sample of these breakers-shall be tested to determine that breaker drift is within that al' lowed by the design criteria.
Breakens'should be
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tested in accordance with an accepted QC testing methodologyI aq -
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such as MIL STD 10 5 D.
(iv)
Fuses when used as interrupting devices do not require periodic testing, due to their stability, lack of drift, and high reliability. Administrative controls' must insure that replacement fuses with ratings other than those selected for proper coordinating are not accidentally used.
. b.
For circuits of equipment and/or components whose spurious operation would affect the capability to s'afely shutdown:
1 i
(1) provide a means to isolate the equipment and/or components from the fire area prior to the fire (i.e., remove power cables, open
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circuitbreakers);or
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(2) provide electrical isolation that prevents spurious operation.
Pot,ential isolation devices include. breakers, fuses, ampli-fiers, control switches, current XFRS, fiber optic couplers, relays and transducers; or (3) provide a'means to ' detect spurious operations and then proce-dures to defeat the maloperation of equipment,(i.e., c16sure of the block valve if PORY spuriously operates, opening of the breakers to remove spurious operation of safety injection);
For common enclosure cases of assoc.iated circuits:
c.
(1) provide appropriate m'easures to prevent propagation of the fire; and (2) provide' electrical protection (i.e., breakers, fuses or similardevices)
We recognize that there are different approaches which may be used to C.
reach the same objective of determining the interaction of associated circuits with shutdown systems. One approach is to start with the fire area, identify what is in the fire area, and' determine 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-have named "The Systers Approach" would be to define the shutdown systems around a fire area and then determine
1 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,
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in accordance with Section. III.G.3 of Appendix R is provided, the
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following information is required to demonstrate that associated circuits will not pre.verit operation or cause maloperation of the alternative or dedicated sh'utdown method:
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a.
Provide a table that lists all the power cables in. the fire area '
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.
Phvide 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 al.1 the cables in the f, ire area that 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 shutdown method.
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For each cable listed in a, b and c where new electrical isolation has been provided or modification to existir.g electrical isolation 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 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 prevent operation or cause maloperation of tiie -
alternative or dedicated shutdown method:
a.
Describe the methodolo2y used to assess the potential of associated circuit adversly affecting the alternative or dedicated shutdown.
The description of the methodology should include the ~ methods used to identify the circui-ts which share a comon power, supply f,.
or a comon enclosure with 'the alternative or dedicated shutdown system and the circuits whose spurious operation would affect a
shutdown. Additionally, th'e description should include the methods used to identify.if these circuits are associated circuits '
of concern due to'their locatinn in the fire area, b.
Provide a table that lists all associated circuits of concern located in the fire area.
c.
Show that fire-induced failurds (hot shorts, open circuits or 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 l'sted in b where new electrical isolation has been provided, provide detailed electrical schematic drawings that show how each cable is isolated from the fire area.
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e.
Provide a location at the site or other office,s where all the tables. and drawings generated by this metho' dolo'gy approach for the associated circuits review may" be audited to verify,the information provided above.
HIGH-LOW PRESSURE INTERFACE For either approach chosen the following concern dealing with high-low.
, pressure interface should be addressed.
2.
The residual heat removal system is generally a low pressure system that interfaces with the high pressure primary coolant system. To -
preclude a LOCA through this interface, we require compliance with the recommendations of Branch Technical Position. RSB 5-1.
Thus, the interface most likely consists of two redundant and independent motor-operated valves. These two motor op'erated valves and their a'ssocidted
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cables may be subject to a single f. ire hazard.
It is our concern tha.t this single fire could cause the two valves to open resulting in, l
a fire initiated LOCA through the high-low pressure system interface. To assure that this interface and other high-low i
pressure interfaces are adequately, protected from the effects of a l
single fire, we require the following information:
a*.
Identify each high-low pressure interface that uses' redundant electrically controlled dev' ices'(such as two series motor operated valves) to isolate or preclude rupture of any primary coolant boundary.
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b.
For each set of redundant valves fdentified in a., verify the redundant cabling (power and control) have adequate physical
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separation as required by Section III.G.2 of Appendix R.
c.
For each case where adequate sop ration is r.ct providej, sh:: that fire induced failures (hot short, open circuits or short to ground) of the cables will not cause maloperation'and result in a 10CA.
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CRITERIA FOR EVALUATING fXEMPi10NS TO SECTIO'N _.I 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 approved by an SER be reexamined for compliance with the requirements of Section III.G.
Section III.G is related to fire 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 require-ments of Section III.G or an alternative ' fire protection configuration' must be.iustified by a fire hazard analysis.
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The general criteria for accepting an alternative fire prbtection configur-i ations are the following:,
The alternative assures that one train of equipment necessary to achieve hot shutdown from either the control room or emergency control stations is free of fire damage.
The alternative assures that fire damage to at least one train of equipment necessary to achieve cold shutdown is limited such that -
it can be repaired within a reasonable time (minor repairs ki,th n' components stored on-site).
Fire retardant coatin.gs are not used as fire barriers; Modifications required to meet Section III.G would.not enhance fire protection safety above that provided by either existing or
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proposed alternatives Fg n e e.w ;.
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r Modifications required to meet Section III.G would be detrimental *
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'M to overall facility safety.
Because of the broad spectrum of potential configurations fo.r which exemptions may be, requested, specific criteria that account for all of the parameters that are important to fire protection and consistent with safety requirements of all plant-unique configurations have not been devel oped.
However, our evaluations of devjations from these require-ments in cur grevious review and in the requests for III.G exemptions received to date have identified some recurring configurations for which specific criteria have been developed.
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,Section III.G.2 accepts three methods of fire protection.
A passive' 3-hour fire barrier should be used where possible.
Where a fixed barrier cannot be installed, an automatic suppression system in co=bination with a fire barrier or a separation distance free'of combustibles 11 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 survive. 'If this latter condition is not met, alternative shutdown capa-bility is requi.ed and a fixed suppression system installed in the fire area of concern, if it contains a large concentration of cables.
It'is essential to remember that these alternative requirements are not deemed to be equivalent.
However, they provide adequate protection for those configurations in which, they are accepted.
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3 Wheri the' fire protection features of each fire. area are evaluated, the
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whole system of such features must be kept in perspective. The defense-in-depth principle of fire protection programs is aimed at achieving an adequate. balance between the different features. Strengthening any one can compensate in some measure for weaknesses, known or unknown in others.
The adequacy of fire protection for any particular plant safety system or are'a.is determined by analysis of the effects of postul.ated fire relative
'E to maln'taining the ability to safely shutdown'the plant and minimize radio-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 Design Criterion 3 namely, fire protection should.be provided consistent with other safety considerations.
An evaluation must be made for.each fire area for which an exemption
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During these evaluations, the staff considers the following parameters:.. - '
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A.
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l walls, floor, and ceiling construction ceiling height room volume ventilation
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Safe Shutdown Capability
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I number of redundant systems in area whether or not system or equiment is. required for h t' shutdown
. type of equipment / cables involved repair time for cold shutdown equipant within.this area l
separation between redundant components and in-situ I
concentration of combustibles alternative shutdown capability e
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Fire Hazard Analysis type and configuration of combustibles in area quantity of combustibles ease of ignition and propagation heat release rate potential transient and installed combustibles
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suppression damage to equipment whether the area is continuously manned traffic through the area accessibility of the area.
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D.
Fire Protection Existing or Committed
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radiant heat shie1ds
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A specific des *cription of the fire protection features of the configuration '
is required to justify the compensating features of the alternative. Low ~
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1 fire loading is not a sufficient basis for granting an exemption in areas where there are cables.
i If necessary, a team of. experts, incipding a fire protection engineer, will visit the site to detennine the existing circumstances. This visual inspection is also considered in the review process.
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~-: % = 2 The majority of the III.G exemption requests received to date are being ff$.'yy~-1
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denied because they lack specificity.
Licensees have not identified
,9; the extent of the exemption requested, have'not provided a technical basis @%yR For the request and/or have not provided a specific description of the alternative. We expect to receive requests for exemption of the following--
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nature:
1.
Fix'ed fire barriers less than 3-hour rating.
2.
Fire barrier without an automatic fire suppression system.
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3.
Less than 20 feet separation of cables with fire propagation retardants (e.g., coatings, blankets, covered trays) and' an automatir suppression system.
4.
For large open areas with f.ew components to be protected and few in-situ combustibles, no automatic suppression system with separation as in item 3.ab ov e.
No fixed suppression in the' contr$1 taom.
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.Ho fixed suppression in areas without a large concentration of cables for which alternative shutdown capability has been providesi.
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Our fire research test program is conducting tests to provide infomation
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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 dehiations recently approved, specific criteria for certain recurring configurations are as follows:
Fird Barrier Less than Three Hour's
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This barrier is a wall, floor, ceiling or an enclosure which separates J
one' fire area from another'.
Exemptions may be granted for a lower rating (e.g., one hour or two' hours) 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..
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e A..Separat' ion distances less 'than 20 feet may be deemed acceptable where:
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Fire propagation retardants (i.e., cable coatings, covered tr'ays, l
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.
2.
Distance above a floor level exposure fire and below ceiling assures that redundant systems will not be simultaneously subject to an.
l unaf;ceptable temperature or heat flux.
B.
The ommission of an automatic suppression sy' stem may be deemed acceptable i
,.where:
1.
Distance above a floor level. exposure fire and below ceiling assures that redundant systems will not be simultaneously subject to an l
unacceptable temperature or heat flux.
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The fire area is required to be manned continuously.by the provisions in the Technical Specifications.
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