ML20057B644

SER Concluding That Safe Shutdown Capability at Plant, Satisfies Requirements of Section Iii.G & Iii.L of App R to 10CFR50

ML20057B644
Person / Time
Site:	Peach Bottom
Issue date:	09/16/1993
From:	Office of Nuclear Reactor Regulation
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ML20057B643	List: ML20057B642 ML20057B644
References
NUDOCS 9309230062
Download: ML20057B644 (14)

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W ASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION OF THE PEACH BOTTOM ATOMIC POWER STATION FIRE PROTECTION PROGRAM PEACH BOTTOM ATOMIC POWER STATION. UNITS 2 AND 3 DOCKET NOS. 50-277 AND 50-278

1.0 INTRODUCTION

This safety evaluation (SE) is based on Philadelphia Electric Company's (PEco or the licensee), Peach Bottom Atomic Power Station, Units 2 and 3 (Peach Bottom, PBAPS), Fire Protection Program (FPP) submittal of September 30, 1986, and subsequent revisions that the licensee submitted as part of its annual Updated Final Safety Analysis Report (UFSAR). The PBAPS FPP cites numerous previous submittals, including exemption requests, that address compliance with Appendix R to 10 CFR Part 50. These submittals are referenced and summarized in this SE where appropriate. Previous NRC staff safety evaluations and exemptions issued in response to the submittals and inspection reports are also cited and summarized where appropriate. This SE does not change any conclusions drawn in previous NRC staff documents.

1.1 Plant-Soecific Backaround

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During the period of March 17 through 21, 1986, the NRC conducted an inspection at Peach Bottom to evaluate the licensee's compliance with the requirements of Appendix R to 10 CFR Part 50. NRC Region I issued Inspection Report (IR) 50-277/86-08 and 50-278/86-08 (IR 86-08) after the inspection. At the time of the inspection, PEco was conducting an Appendix R safe shutdown confirmatory study, but the study was substantially incomplete. As a result, the NRC staff could not conclude that PEco was in compliance with Sections III.G, III.J and III.L of Appendix R. The inspection report identified five l unresolved issues due to incomplete analysis. The NRC issued a confirmatory i action letter (CAL) to PEco on April 11, 1986 (CAL 86-07), which required the licensee to complete the Appendix R safe shutdown review by September 30, 1986, and provide a copy of the completed report to the NRC.

The CAL also required PEco to notify the NRC of any areas of noncompliance with Sections III.G or III.J of Appendix R uncovered during the study.

On September 30, 1986, PEco submitted the Peach Bottom Atomic Power Station Fire Protection Program, which contained the results of the Appendix R safe shutdown confirmatory study. The study had determined that certain design >

deficiencies existed with respect to Appendix R requirements. The FPP reflected the licensee's expected plant configuration and fire protection program content after it implemented a series of planned modifications.

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The NRC reinspected the licensee compliance with Sections III.G, III.J, and III.L of Appendix R during the period October 19 through 23, 1987.

IR 50-277/87-30 and 50-278/87-30 (IR 87-30) documented the results of the inspection. The report identified several issues concerning the associated  ;

circuit analysis. The issues are discussed in Section 2.5 of this report.

l The inspection report also closed the unresolved items identified in IR 86-08. '

l.2 Review Criteria The criteria used in reviewing the licensee's FPP are based on the following documents:

1. 10 CFR 50.48, " Fire Protection Program for Operating Nuclear Power Plants," and Appendix R to 10 CFR Part 50, " Fire Protection Program for i Nuclear Power Facilities Operating Prior to January 1, 1979." ,

2. NUREG-0800, Standard Review Plan, Section 9.5.1, " Fire Protection  :

Program."

3. Generic Letter 86-10, " Implementation of Fire Protection Requirements,"

April 24, 1986.

2.0 POST-FIRE SAFE SHUTDOWN CAPABILITY 2.1 Systems Recuired for Safe Shutdown Shutdown of the reactor is initiated by either automatic or manual reactor trip. The licensee has identified four methods (designated Methods A, B, C i and D) to shut down the plant in the event offsite power is lost concurrent with a fire. After closure of the main steam isolation valves (MSIV), reactor coolant system (RCS) pressure is controlled with the main steam relief valves ,

(RV). Reactor coolant inventory is maintained with either the reactor core isolation cooling (RCIC) system (Method A), the high pressure coolant injection (HPCI) system (Method B), or either the low pressure coolant  ;

injection (LPCI) mode of the residual heat removal (RHR) system or the core '

spray (CS) system in concert with automatic depressurization system (ADS)

(Method C). Shutdown Method D is used for fire scenarios requiring the use of the alternate control stations (ACS). Method D uses HPCI to maintain vessel water level.

In all four shutdown modes, decay heat removal is accomplished by placing one l loop of the RHR system in the suppression pool cooling mode or in the '

alternate shutdown cooling mode depending on the status of reactor pressure.

In both modes of operation, heat is transferred to the high pressure service water (HPSW) system via the RHR heat exchanger. The emergency diesel generators (EDG), which are used for achieving safe shutdown in the event of a loss of offsite power concurrent with a fire in the plant, are cooled by the emergency service water (ESW) system.

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2.2 Areas Where Alternate Shutdown is Not Reauired In a letter dated September 16, 1983, the licensee provided an evaluation of the Peach Bottom plant for compliance with Appendix R,Section III.G.2. For ,

l certain areas that were found to be in noncompliance, PECo proposed an i alternative shutdown capability. These fire areas and the proposed I alternative shutdown system are described in Section 2.3 of this report. For other areas that were found to be in noncompliance, PEco proposed l

modifications to achieve compliance or requested exemptions f;om Section III.G.2 on technical grounds.

The PEco letter of September 16, 1983, provided a fire zone by fire zone analysis and described the modifications necessary to bring each zone into compliance with Section III.G or provided the technical justification for an exemption from the requirements of Section III.G for the zone. The subsequent September 30, 1986 FPP (including subsequent revisions) provides a fire area j by fire area analysis of compliance with the requirements of Section III.G. i l For certain fire areas, the licensee sought and received exemptions from the '

requirements of Section III.G (see exemption summary below). For certain fire areas, the licensee has presented fire hazard analyses as allowed by Generic Letter 86-10, describing the adequacy of the protection provided by the installed fire protection barriers. These analyses were submitted by the licensee in a letter dated December 10, 1986. The NRC staff reviewed the analyses and issued exemptions for the affected areas. The exemptions and the NRC staff's SE are contained in a letter dated October 3,1991.

During an Appendix R confirmatory review conducted in 1986, the licensee identified instances of noncompliance with Sections III.G.2 and III.G.3. By letter dated November 28, 1986, the licensee provided a justification for l continued operation. The licensee proposed modifications as permanent solutions to many of the identified discrepancies. The NRC staff will review the modifications during a future inspection at Peach Bottom.

For those fire areas and barriers determined by the licensee to be in compliance with Section III.G.2, the NRC staff reviewed the adequacy of implementation on a sampling basis. In Inspection Report 50-277/87-30, the NRC inspectors documented its reviews of drawings and procedures, and the results of walkdowns in selected fire areas to assess compliance with the detection, suppression and separation requirements of Section III.G. The inspectors did not identify any unacceptable conditions.

1 l The licensee has submitted specific requests for exemption from Section III.G.2 for various fire areas. The exemption requests and NRC staff reviews are summarized below.

1. Fire Barrier Ratina: By letters dated May 27, 1983, September 16, 1983, and December 2, 1983, the licensee requested an exemption from the requirements of Section III.G.2 to the extent that it required the installation of 3-hour rated fire barriers between redundant l

trains. The excmption was requested with respect to the adequacy of ventilation fire dampers at thirty-two locations throughout the pl ant. The NRC staff reviewed the request and issued an SE and the exemption by letter dated March 13, 1985.

By letters dated September 17, 1984, May 23, 1985, and September 24, 1985, the licensee requested exemptions from the '

requirements of Section III.G.2 to th4 extent that it required installation of 3-hour rated fire barriers between redundant trains.

The exemption was requested for Radwaste Building ventilation duct penetrations that were not provided with fire barriers. The NRC staff reviewed the request and issued the exemptions and SE by letter dated December 31, 1986.

By letters dated September 17, 1984, May 23, 1985, and September 24, 1985, the licensee requested exemptions from the requirements of Section III.G.2.a to the extent that 3-hour rated fire dampers are not provided it duct penetrations related to the i Unit 2 and Unit 3 Main Steam Pipe Tunnel, the standby gas treatment system, the Unit 2 control rod drive equipment area, the Unit 2 switchgear room duct chase, the spent resin tank room and the outboard main steam isolation valve rooms. The NRC staff reviewed the request and issued the exemptions and SE by letter dated  !

December 31, 1986. l l

2. Automatic Suppression: By letters dated May 27, 1983, September 16, i 1983, and December 2, 1983, the licensee requested two exemptions i from the requirements of Section III.G.2 to the extent that it required fixed fire suppression systems in several locations in the Unit 2 and Unit 3 reactor buildings. The NRC staff reviewed the request and issued an SE and the exemptions by letter dated March 13, 1985.

By letters dated September 17, 1984, May 23, 1985, and September 24, 1985, the licensee requested an exemption from the requirements of Section III.G.2.b to the extent that automatic fire suppression systems were not installed in certain fire areas in the turbine and reactor buildings (Fire Areas 8 and 50). The NRC staff reviewed the request and issued the exemption and SE by letter dated December 31, 1986.

3. Penetration Seal Material: By letter dated May 27, 1983, the licensee requested an exemption from the Section III.M requirements concerning the use of combustible materials in penetration seals.

The NRC staff reviewed the request and issued an SE and the exemption by letter dated Novemb- 14, 1986.

4. Structural Steel: By letter dated June 6, 1985, the licensee requested an exemption from the requirements of Section III.G.2 for certain fire areas to the extent that it required structural steel forming a part of or supporting fire barriers to be protected to provide fire resistance equivalent to that of the barrier. The ,

licensee requested the exemption for areas of the reactor building, the radwaste building and the turbine building as described in the June 6, 1985 letter. The NRC staff reviewed the request and issued the exemption and SE by letter dated December 31, 1986.

2.3 Areas Where Alternate Shutdown is Reouired In letters dated March 24, 1983, and September 16, 1983, the licensee proposed to establish an alternate shutdown system to achieve safe shutdown in the event of a fire in the control room, the cable spreading room, or the emergency shutdown panel area. The licensee committed to install additional control stations, modify existing control stations, and provide additional modifications to allow shutdown of the plant independent of any of the three '

areas. PECo proposed to use HPCI as the system for providing level and pressure control and committed to install an appropriate HPCI alternate control station.

i In an SE dated January 26, 1984, and revised on May 4, 1984, the NRC staff I found PECo's proposed alternate shutdown capability acceptable. The proposed l configuration was found to meet the requirements of Sections III.G.3 and III.L '

of Appendix R to 10 CFR Part 50.

The FPP specified the plant computer room as an area requiring to use of the alternate control stations and revised the designation of other fire areas from those used in the submittal of September 16, 1983. The plant computer room, which is located within the cable spreading room, is included in Fire Area 25 along with the main control room, the cable spreading room and the remote shutdown panel area.

The FPP incorporates the designation of the various shutdown methods as Methods A, B, C, and D. The FPP reflects the as-built alternate shutdown systems modifications developed from the letter of September 17, 1984, which described the specific modifications necessary to implement an alternative shutdown capability. NRC IR 87-30 and IR 50-277/92-31 and 50-278/92-31 (IR 92-31) confirmed that the licensee provided alternate shutdown capability independent of the cables, systems or components in the applicable locations in accordance with Section III.G.3 of Appendix R.

PEco also submitted requests for an exemption from Section III.G.3 of Appendix R for fire areas where alternate shutdown capability is required. The exemption requests and NRC staff review are summarized below.

I Fixed Suooression: By letter dated September 16, 1983, the licensee requested an exemption from the Section III.G.3 requirements to install fixed suppression systems in the main control room. The NRC staff reviewed the request and issued the exemption by letter dated March 13, 1985.

By letter dated September 16, 1983, the licensee requested two exemptions from the Section III.G.3 requirements to install fixed suppression systems in the cooling pump structure and the 165 foot elavation of the radwaste building. The NRC staff reviewed the requests .

and issued the exemptions by letter dated March 13, 1985.  !

l 2.4 Alternate Shutdown Capability The alternate shutdown capability uses the safe shutdown systems and equipment described in Section 2.1 of this SE. Subsequent to the issuance of the SEs of January 26, 1984, and May 4, 1984, PEco developed the modifications necessary to implement the alternate shutdown capability. Some of the modifications refined the basic modifications described by PEco in the submittal of September 16, 1983. The refinements included the addition of a specific ADS transfer / isolation station panel and installation of controls on the HPCI ACS for the A, B and K relief valves in the respective units. These alternate shutdown system modifications are described in a PEco letter dated September 17, 1984. The FPP describes the installed alternate shutdown system, which is substantially the same as that described in the submittal of September 16, 1983. Consequently, the NRC staff's conclusion that the Peach Bottom alternate shutdown capability is in compliance with Section III.G.3 and Section III.L of Appendix R, established in the SEs of January 26, 1984 and May 4,1984, remains valid for the FPP aralysis. The systems and equipment used by the licensee to implement its alternative shutdown capability are discussed below. ,

4 2.4.1 Reactivity Control Reactivity control will be accomplished from an automatic reactor protection system trip or by manual scram from the control room. The reliance on control rod insertion either by automatic or manual initiation to accomplish the reactivity control function was discussed by the licensee in the submittal of September 16, 1983, and in the current FPP. The NRC staff found the licensee's approach acceptable in the SE of January 26, 1984. The NRC staff's conclusion remains valid for the FPP.

2.4.2 Reactor Coolant Inventory Control During alternate shutdown scenarios, the licensee uses the HPCI system to maintain reactor water level. The HPCI system is controlled from the HPCI I ACS, located in the recirculation pump motor generator room for each unit.

The HPCI ACS has control and transfer / isolation switches and a flow controller I for the HPCI system. The NRC staff found the licensee's approach acceptable  !

in the SE of January 26, 1984. The NRC staff's conclusion remains valid for  !

the FPP.

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2.4.3 Reactor Coolant Pressure Control Reactor coolant pressure control is provided by the main steam relief valves (MSRV) operating in the pressure relief mode. The licensee's description of pressure control has been carried forward into the FPP from the submittal of September 16, 1983. Therefore, the NRC staff's conclusion in the SE of January 26, 1984, that the licensee's provisions for pressure control in the alternative shutdown mode is acceptable, remains valid for the FPP.

2.4.4 Decay Heat Removal Decay heat removal in hot shutdown is accomplished initially by natural circulation within the reactor pressure vessel through operation of the MSRVs discharging to the suppression pool and makeup flow from the HPCI system. For cooldown (suppression pool cooling mode) and cold shutdown, decay heat removal is provided by the RHR system and high pressure service water system. The licensee's description of decay heat removal capability has been carried forward into the FPP. Therefore, the NRC staff's conclusion in the SE of January 26, 1984, that the licensee's provisions for decay heat removal in the alternate shutdown mode is acceptable, remains valid for the FPP.

2.4.5 Process Monitorina Process monitoring for important reactor parameters including reactor water level, reactor pressure suppression pool temperature and condensate storage tank level are provided at the HPCI ACS. The HPCI ACS also has indications for performance of the HPCI, HPSW, RHR, and ESW systems. The NRC staff found PEco's proposed process and alternative shutdown system monitoring scheme acceptable in the SE of January 26, 1984. The FPP contains a description of the as-built process monitoring which is substantially the same as that proposed in the September 16, 1983 analysis. Therefore, the NRC staff's conclusions on the acceptability of process monitoring remain valid for the system described in the FPP.

2.4.6 Support Systems The analysis of September 16, 1983, and the FPP describe the emergency diesel generators, the emergency service water system, and the DC emergency power systems required for safe shutdown of the plant. Controls for these systems are provided at the alternative control stations discussed in Section 2.4.7 of this SE. The support systems used as alternative shutdown equipment were found acceptable by the NRC staff in the SE of January 26, 1984. That conclusion remains valid for the alternative control support systems described in the FPP.

2.4.7 Modifications In a letter dated September 17, 1984, PEco described the modifications required to implement the alternative shutdown capability. The modifications included development of new alternate control station panels, development of

controls for alternate safe shutdown equipment, encapsulation of circuitry required to meet Section III.G.3 of Appendix R, and design of alternative control instrumentation. PEco provided a series of modification status 1 reports by letters dated January 16, 1985, May 23, 1985, September 24, 1985, January 17, 1986, and May 23, 1986. The following ACS were installed by the licensee:

1. HPCI ACS: This panel, located in the recirculation pump motor generator room, 135 foot elevation for each unit, has control, transfer / isolation switches, and a flow controller for the HPCI system. The HPCI ACS also has RHR and HPSW systems controls and instrumentation, and reactor process monitoring instrumentation.

2. Emeroency Switchaear ACS: Two switchgear ACS for each unit were ,

installed in the 8 and D 4 kV switchgear rooms. The stations contain control and transfer / isolation switches for EDG circuit breakers, load center circuit breakers, the 2B and 3D RHR pumps, the 2B and 3D HPSW pumps, and the A ESW pump.

3. EDG ACS: Alternative control stations are provided for the E-2 (B) and E-4 (D) EDGs. The ACS are located in the Unit 2, B and D emergency switchgear rooms.

4. Automatic Depressurization System ACS: Two ADS ACS for each unit are provided in the A and B 4 kV switchgear rooms. The ADS ACS contain transfer / isolation switches for the A, B and K MSRVs which transfer control of these valves to the H?CI ACS. The ADS ACS also includes transfer / isolation and control switches for the outboard isolation valve in the two nitrogen supply lines to the relief valves.

The ACS were reviewed by the NRC staff during inspection 50-277/87-30. The inspection report did not identify any discrepancies.

l 2.4.8 Technical Soecifications In an SE dated January 26, 1984, as clarified by a letter dated May 4,1984,  ;

the NRC staff found the licensee's proposed alternative shutdown capability j acceptable. In approving the alternative shutdown proposal, the NRC staff i indicated that Technical Specifications would be required for the controls and i instrumentation associated with the alternate shutdown capability. The licensee has TS action statements and surveillance requirements for the i emergency (remote) shutdown panels, which as approved in the SE of I January 1984, were modified as part of the alternative control station modifications.

The licensee has incorporated numerous TS requirements on Fire Protection l equipment over the operating life of the plant. Generic Letter 86-10, as clarified by Generic Letter 88-12, made provisions for licensees to remove

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_g_ l certain fire protection system requirements from the TS provided that the licensee had incorporated an approved Fire Protection Program into the FSAR.  ;

- PEco has not taken advantage of the TS improvements allowed by GL 88-12.

i 2.5 Associated Circuits and Isolation i Enclosure 2 to Generic Letter 81-12, issued February 20, 1981, defines associated circuits as cables that have a separation from a particular fire area less than that required by Section III.G.2 of Appendix R and have either (1) a common power source with alternate shutdown equipment and where the power source is not electrically protected from the post fire shutdown circuit of concern by coordinated protective devices, or (2) a connection to circuits of equipment whose spurious operation will adversely affect the shutdown capability, or (3) a common enclosure such as a raceway, panel, or junction box with alternative shutdown cables, that are not electrically protected from-the post fire shutdown circuits of concern by circuit breakers, fuses or similar devices.

The licensee has examined associated circuit concerns, such as common power source including high impedance faults, common enclosure concerns, fire induced spurious operations including cigh/ low pressure interfaces and electrical isolation deficiencies. The issues, which are discussed in the FPP, have been reviewed by the NRC staff as described below.

2.5.1 Common Power Source The licensee states in the FPP that all systems and components that are relied  ;

on for achieving safe shutdown are powered from Class IE ac or de power '

sources. The licensee also states that all power circuits, both Class IE and a non-Class IE, that are powered from Class IE sources are individually protected by coordinated Class IE fault-actuated protective devices. The information and analysis in the current FPP related to common power source concerns is substantially the same as that submitted by the-licensee in the Alternative Shutdown Analysis of September 16, 1983. The NRC staff issued an >

SE dated January 26, 1984, that did not cite any deficiencies with regard to common power source concerns.

The NRC staff reviewed the protective relay coordination for selected 4160V ,

and 480V buses during inspection 50-277/87-30. During that inspection, the '

NRC staff identified a concern with the methodology used by the licensee in addressing the impact of multiple high impedance faults on circuit protection  !

coordination (0 pen Item 50-277/87-30-03). By letter dated June 15, 1988, PEco responded to the open item, by submitting a PECo test report entitled *

" Appendix R Multiple High Impedance Cable Fault Flame Test." By letter dated .

December 19, 1988, the NRC staff rejected the PEco test report as the sole '

basis for closing the concern and suggested.possible alternatives. PEco, in a response dated March 23, 1989, elected to . implement restorative procedures such.that if multiple high impedance faults did cause a breaker to trip, plant operators would have guidance on how to reset the source breaker and restore safe shutdown loads such that the breaker would not re-trip due to high

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impedance faults. In an SE dated April 11, 1989, the NRC staff found the licensee's approach acceptable. Inspection Report 89-15, dated May 24, 1989, i transmitted the NRC staff's acceptance of the approach and closed Open Item 87-30-03.

During inspection 92-31 (IR 50-277/92-31 and 50-278/92-31), the NRC staff again examined common bus concerns, including selected protective coordination calculations, and found no additional concerns. Based on the NRC staff review of common bus concerns described in the SEs dated January 26, 1984, and April 11, 1989, and in IR 50-277/87-30 and 50-277/92-31, the NRC staff finds the licensee's approach to common bus concerns in the FPP acceptable.

2.5.2 Common Enclosures In the FPP, the licensee states that all safe shutdown equipment, with the exception of some process and diagnostic equipment, are Class 1E equipment.

Non-Class IE circuits, designated as associated circuits, may be routed in one channel of Class IE raceways. Non-Class IE circuits identified and treated as Class IE circuits do not become associated with other Class IE channels. The licensee states that the potential for propagation of an electrical fire in enclosures containing Class IE cabies is minimized by selection of appropriate cable construction systems and provisions of physical separation.

In the alternative shutdown report dated September 16, 1983, PEco stated that a review of electrical circuit protection schemes confirmed that most circuit protective devices had been properly selected and coordinated. For those that were identified as deficient, PEco stated that design changes would be implemented to correct the deficiencies.

In the SE of January 26, 1984, the NRC staff reviewed the submittal dated i September 16, 1983, and did not find any concerns associated with common  ;

enclosures.

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2.5.3 Spurious Operations l

l Fire in some areas can impair safe shutdown due to fire-induced spurious  !

operation of safe shutdown equipment or components. Therefore, Appendix R <

Section III.G.2 separation requirements have been provided between redundant l safe shutdown equipment, components and associated cabling as far as practical l to ensure the availability of minimum safe shutdown systems. When this is not possible, spurious operations are to be mitigated in a timely manner by corrective manual operations at local stations. This is made possible by  !

isolating the minimum safe shutdown systems needed from the fire affected area l and providing manual control capability at the local stations.  !

One special category of spurious operations involves high/ low pressure interfaces. The licensee lists all such interfaces in Table A-5 of the FPP.

The interface valves are associated with the RHR system, reactor water cleanup (RWCU) system, main steam safety relief valve (MSRV), core spray (CS) system, i and main steam systems. The spurious operations of most of these valves do j not require corrective actions, since they satisfy one of the following '

considerations:

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l 1. mechanical check valve or manual valve (i.e., use of a hand wheel to operate the valve) in series with the applicable valve is available ,

to prevent reactor coolant (RC) inventory loss via.the applicable i i valve; j l 2. RC inventory loss via the valve is limited by its associated line .i l size and the minimum safe shutdown systems has the capability to i mitigate the consequences,  ;

a There is however, a set of high/ low pressure interface valves not covered by the above considerations at Peach Bottom. These are RHR shutdown cooling i

suction line isolation valves (M0-10-17 and 18). By letters dated 1 l March 31, 1989, and April 11, 1989, the licensee committed to remove motive  ;

power from M0-10-18. This action is acceptable to the NRC staff as a '

resolution to the concern about high/ low pressure interface for the RHR '

shutdown cooling system suction. The NRC staff's acceptance was addressed in IR 89-15 which documented the closure of Open Item 87-30-04.

2.6 Manual Operations Each of the four shutdown methods. identified by the licensee in the FPP, (Methods A, B, C, and D), require that manual actions be performed outside of l

L the control room to achieve shutdown following fires in certain fire areas.

Table A-4 of the FPP describes the manual operations that may be required and the fire areas that may require manual actions. The actions specified in l

Table A-4 are incorporated into the T-300 Fire Guide series of specific station procedures.

l The NRC staff had questioned the acceptability of some of the specific manual I actions, contending in IR 87-30 that these actions constituted repairs which are not allowed by Appendix R to achieve hot shutdown. This was identified as Open Item 87-30-02 in IR 87-30. PEco responded to the open item by letter dated May 11, 1988. In the response,. PEco provided a rationale for considering the questionable actions as manual operations. The licensee contended that the actions, which included fuse pulling and manual operation l of motor-operated valves from motor control centers, were necessary for the l l operator to gain positive control of the equipment and to aid in proper local )

l operation. The NRC staff reviewed the licensees justifications and concluded J l that they were acceptable. The open item was closed in IR 88-41 of November 14, 1988. Based on the review conducted as part of Inspection Report ,

87-30 and the closure of Open Item 87-30-02, the NRC staff finds the manual  !

operations described in the FPP acceptable.

4 2.7 Safe Shutdown Procedure Review and Manpower l j The licensee has developed procedures for coping with various fire scenarios.

Licensee procedure ON-Il4, " Actual Fire Reported in the Power Block, or Diesel l Generator Building, Emergency Pump, Inner Screen or Emergency Cooling Tower,"

directs operators to the T(Trip)-300 series of procedures. These procedures provide guidance for coping with fires in specific fire areas. For example,

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T-325 provides guidance for fires in the cable spreading room. The T-300 series can direct the operators to special event procedures, depending on the type of fire and the impact on safe shutdown equipment. For example, SE-10, +

" Plant Shutdown From the Alternative Shutdown Panels," provides guidance to implement a Method D safe shutdown. The licensee provided specific information on manning requirements based on fires in specific fire areas in a letter dated October 16, 1987.

The NRC staff reviewed safe shutdown procedures during inspections 50-277/87-30 and 50-277/92-31. Inspection 92-31 postulated a severe cable spreading room fire and reviewed the adequacy of the procedural guidance available to operators for coping with this fire scenario. The inspection included a simulator scenario to observe operator use of the procedures. While certain weaknesses were observed with respect to the interface between the various procedure series, the procedures were found to be adequate overall.

For the cable spreading room fire scenario, the NRC staff determined that, based on the design of the alternative shutdown stations and the procedural guidance provided, the actions required to isolate equipment affected by a fire in the cable spreading room would be within the capability of the TS required shift manning. Based on the sampling reviews conducted as part of inspections 50-277/87-30 and 50-277/92-31, and in the manpower information provided in the letter of October 16, 1987, the NRC staff finds the safe shutdown procedure guidance and manning levels acceptable. 1 2.8 Other Exemptions i

The FPP lists all of the exemptions from the requirements of Appendix R to 10 CFR Part 50 granted by the NRC for the facility. Exemptions to the requirements of Section III.G and Section III.M were summarized above.

Additional exemptions are summarized below.

Automatic Fire Detection: By letters dated May 27, 1983, l September 16, 1983, and December 2, 1983, the licensee requested an exemption from the requirements of Section III.F to install automatic fire detection systems for the MSIV rooms, chemical waste tank room, offgas line tunnel and diesel generator building supply enclosures. The NRC staff reviewed the request and issued an SE and the exemption by letter dated March 13, 1985.

By letter dated December 2, 1983, the licensee requested an exemption from the Section III.F requirements to install automatic fire detection equipment in the emergency cooling tower stairwell. The NRC staff reviewed the request and issued an SE and the exemption by letter dated November 14, 1986.

3.0 CONCLUSION

S The NRC staff concludes that the safe shutdown capability at Peach Bottom, as described in the PBAPS Fire Protection Program, with approved exemptions, satisfies the requirements of Section III.G and III.L of Appendix R to 10 CFR Part 50. This SE does not change the results of any previous NRC staff evaluations or inspections of the PBAPS FPP or any of the conclusions drawn in previous NRC staff documents.

The NRC staff is currently reviewing the ability of certain fire barriers, including Thermo-Lag 330-1, to provide adequate protection against fires and to satisfy the requirements of Appendix R. This SE does not resolve any issues related to this staff review and does not relieve the licensee in any way from any actions required to resolve fire barrier issues at Peach Bottom.

Principal Contributors: J. Shea A. Singh Date: September 16, 1003 m

e ,,

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( y-Mr. George A. Hunger, Jr. September 16, 1993 I

Supplement 1, " Failure of Thermo-Lag 330 Fire Barrier System to Perform Its

. .Specified Fire Endurance function." Resolution of fire barrier issues will be

the subject of separate correspondence.

Since y, s -

Josephj W. Shea, Project Manager Prqj ec't Directorate I-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation +

Enclosure:

Safety Evaluation cc w/ enclosure:

See next page DISTRIBUTION Docket File NRC & Local PDRs PDI-2 Reading SVarga JCalvo '

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