ML20151H175
| ML20151H175 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Cook |
| Issue date: | 01/21/1982 |
| From: | Johnston W Office of Nuclear Reactor Regulation |
| To: | Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML082321542 | List: |
| References | |
| FOIA-88-92 NUDOCS 8202110116 | |
| Download: ML20151H175 (1) | |
Text
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JAN 211982 Docket Nos.: 50-315/316 MEMORANDUM FOR:
J. Taylor, Director g
Division of Reactor Programs Office of Inspection and Enforcement FROM:
William V. Johnston, Assistant Director Materials & Qualifications Engineering Division of Engineering
SUBJECT:
FIRE PROTECTION - D.C. COOK UNITS 1 AND 2 As requested by J. Stone of your office, we are enclosing a copy of a memorandum and several lettert regarding fire protection for 0.C. Cook Units 1 and 2.
1.
Letter from Eisenhut to the licensee dated November 24, 1980, transmitting Fire Protection Rule and Sumary of staff require-ments to resolve open items.
2.
Letter from Eisenhut to the licensee dated February 20, 1981, transmitting staff position safe shutdcwn capability and request for additional information.
1 3.
Letter from the licensee to Denton dated March 27, 1981, responding to our letter of November 24, 1980.
4.
Memorandum from Johnston to Novak dated December 31, 1981, indicating fire protection status for D.C. Cook Units 1 and 2.
NRR review of the fire protection program is complete.
MAbh William V. Johnstorf, Assistant Director Materials & Qualifications Engineering Division of Engineering
Enclosure:
As stated cc:
R. Vollmer R. Ferguson D. Eisenhut S. Varga R. Tedesco V. Panciera V. Benaroya S. Minor T. Wambach T. Sullivan
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November 24, 19530 Docket Mc. 50-315/316 Plant Name:
D. C. Cook, Unit Nos. 1 and 2
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TO ALL POWER REACTOR LICENSEES WITH PLANTS LICENSED PRIOR T0' JANUARY 1,1979 The Comission published on Novent>er 19,1980 (45 FR 76602), a revised Section 10 CFR 50.48 and a new Appendix R to 10 CFR 50 regarding fire protection features of nuclear power plants. The. revised Section 50.48 and Appendix R will become effective February 17, 1961, which is 90 days after publication. A copy of the Federal Register Notice is enclosed (Enclosure 1)..
The provisions of ~ Appendix R that are applicable to the fire protection features of your facility can be divided into two categories.
The first category consists of those provisions of the Appendix that are required to be backfit in their entirety by the new nile, regardless of whether.or not alternatives to t previously approved by,he specific requirements of these Sections have been the NRC staff. These requirements are set forth in Sections III.G, Fire Protection of Safe Shutdown Capability; III-J, Emergency Lighting; and III-0, Oil Collection Systems for Reactor Coolant Pump. The fire protection features of your facility nust satisfy the specific requirements of these three Sections by the dates established by Paragraph 50.48(c), unless an exenption from the Appendix.R requirements is approved by the Comission. You should note the provisions for telling the time for conpleting the modifications required by these three Sections of Appendix R set forth in Paragraph 50.48(c)(6).
The second category of Appendix R provisions applicable to the f. ire protection f eatures of your f acility. consists of requirements concerning the "open" items of previous NRC staff fire protection reviews of your facility. An open item is defined as a f. ire protection feature that has 'not been previously 4
approved by the NRC staff as satisfying the provisions of Appbndix A to Branch Technical Position BTP'PCSS 9.5-1, as reflected in a staff fire.
protection safety evaluation report.
The fire protection features of your f acility that are in this category nust satisfy the specific requirements of Appendix R by the dates. established by Paragraph 50.48(c), un1.ess an exenp-tidn from the Appendix R requirements on those features is approved by the Comi s sion.
. is a sunvnary listing of the open items concerning the fire protection features of your f acility based on a review cf our records.
Also included is our position on the specific requirements tha't nust be satis'fied in order to resche these open items.
If you have any questions or disagree-ments with this enclosure, please advise us within 30 days of your receipt of this letter.
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2 Kith regard to the fire protection nodifications that have been previously approved by the NRC staff, Paragraph 50.48(d) specifies a new schedule for' their co@letion.
This paragraph, when it becomes effective, will supersede the currently effective section of the regulations that temporarily suspends corpletion dates for previously approved fire protection modifications that j
are given.in f acility license conditions (45 FR 71569, October 29,1980).
i The Comission expects that all such modifications will be cogleted in accordance with this new schedule, unless an extension has been requested J
and granted by the Director of the Office of Nuclear Reactor Replation
[see Paragraph 50.48(d)] or an exegtion has been requested and granted by the Comission pursuant. to Section 50.12 of the.Comission's' regulations.
If you have previously requested extensions of ' dates for cogletion of modifications that are required by license conditions for your facility which were not approved, and you have determined that these extensions are Wil necessary and justifiable, it sill be necessary fo: you to reapply for any such. extensions in accordance with the provisions of Paragraph 50.48(d).
. All requests for Comission action resulting from this rule are subject to the schedule of fees specified in 10 CFR 170.21. 'If you have any qu'estions concerning the subject matters of this letter, please contact the NRC Project Manager for your facility.
Sincerely.
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.q f Darrell G. Eisenhut. Director Division of Licensing Office of Nuclear Reactor Regulation
Enclosures:
l.
Notice - Fire Protection Rule 2.
Sumary of Staff Require-ments to Resolve Open Items cc w/enclosurest See next page 1
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SUMMARY
OF STAFF REQUIREMENTS TO RESOLVE OPEN ITEMS D. C. COOK, UNITS 1 A 2
' There are no open items for this facility.
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UNITED STATES 7,
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- February 20,*1981
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TO ALL POWER REACTOR LICENSEES WITH PLANTS LICENSED PRIOR TO JANUARY 1,1979
SUBJECT:
hiiRDR' DYE'CiiNRULIk45 FR 76602, NOVEMBER 19, 1980) -
1.Mner{QittMJW-Paragraph 50.48(blof 10 CFR Part 50, which became effective on February 17, 1981, requires a0 nuclear plants licensed to operate prior to January 1,1979 to meet the requirements of Sections III.G III.J and 111.0 of Appendix R to 10 CFR Part 50 regardless of any previous approvals by the Nuclear Regulatory ConTnission (NRC) for alternative design features for those items. This woul_d reaui.ItJach licensee to _ reassess all those areas of the plant "... where cables or equipment, including associated non-safety circuits, that could prevent operation or cause maloperation due to hot shorts, open circuits or shorts to ground or (sic) redundant trains of system necessary to achieve and maintain hot shutdown conditions are located within the same fire area outside of primary containment..."* to determine whether the requirements of Section III.G.2 of Appendix R are satisfied.
If not, the licensee must provide alternative shutdown capability in conformance with Section III.G.3 or request an exegtion if there is some justifiable basis.
Paragraph 50.48(c)(5) requires that any modifications that the licensee plans in order to meet the requirements of Section III.G.3 of Appendix R must be reviewed and approved by the NRC. This paragraph also requires that the plans, schedules and design descriptions of suc1 modifications nust be submitted by March 19,1981.
To expedite our review process and reduce the number of requests for additional information with regard to this review, we are enclos-ing two documents which specify the information that we will require to coglete our reviews of alternative safe shutdown capability. Enclosure 1 is "Staff Position Safe Shutdown Capability". This document was originally sent to you in late 1979. Section 8 specifies the information requirad for staff review. G have already submitted arty of the information required, you need only reference that previous submittal.
Enclosyre 2 indicates the additional information needed to ensure that associated circuits for alter-native safe shutdown equipment is included in your reassessment and in our re view.
If you made no modifications that were required to provide alternative i
safe shutdown capability and if your reassessment concludes that alternative safe shutdown capability in accordance with the provisions of Section III.G.3 is not necessary, you do not have to provide the inf.ormation requested by these Enclosures.
- Quoted from Section I!!.G.2 of Appendix R to 10 CFR Part 50. Note that the "or" preceding "redundant trains" is a typographical error and should read "of redundant trains".
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Finally, we request that as part of your subnittal of plans and schedules for meeting the provisions of Paragraphs (c)(2), (c)(3) and (c)(4) of 10 CFR 50.48 as required by Paragraph 50.48(c)(5), you include the results of your reassessment of the design features at your plant for meetir:g the require-ments of Sections !!I.G, Ill.J and 111.0 of Appendix R to 10 CFR Part 50.
This detailed information need not acconpany the design description that must be submitted by March 19, 1981. However, we request that it be submitted as soon as possible, but no later than May 19, 1981.
This request for information was approved by GA0 under a blanket clearance number R0071 which expires Septenter 30, 1981. Conments on burden and dupli-cation may be directed to the U. S. General Accounting Office, Regulatory Reports Revied, Room 5106, 441 G Street, N. W., Washington, D. C.
20548.
incerely.
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L Darrel G.
isenhut, Oliec or Division of.icensing Office of Nuclear Reactor Regulatioa
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Enclosures:
1.
Staff Position 2.
Request for Additional Information cc w/ enclosures:
1 See next page
STAFFPOSITiON SAFE SHUTDOWN CAPABILITY Staff concem w...;
Curing the staff's eialuation of fire ' protection programs at operating plants, one or more specific plant areas may be identified in which the staff does not have adequate assurance that a postulated fire will not damage both redundant divisions of shutdown systems.
This lack of assurance in safe shutdown capability has resulted from one or both of the following situatiens:
- Case A: The licensee has not adequately identified the systems and components required for safe shutdown and their location in specific fire areas.
- Case B: The licensee has not demonstraied that t.he fire protection for specific plant areas will prevent
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damage to both redundant divisions of safe shutdown components identified in these areas.
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l For Case A, the staff has required that an adequate safe shutdcwr.
analysis be performed. 1his evaluation includes the identification of the systems required for safe shutdown and the location of the system components in the plant. Where it is determined by this evaluation.that safe shutdown components of both redundant divisions 4
are located in the same fire area, the Itcensee js required to demonstrate that a postulated fire will not damage both divisions or provide alternate shutdown capability as in Case B.
For Case 8, the staff may have required that an altamate shutdcun
. capability be provided with is independent of the area of concern or the licensee may have preposed such a capability in Ifeu of certain additional fire protection ruidifications in the area. The specific modifications associated with the area of concern along with other systems and equipment already independent of the area form the alternate shutdoan capability. For each plant, the modifications needed and the combinations of systems.which ' provide the shutdown functions may be unique for each critical area; however, the shutdown functions provided should raintain plant parahmters within the bounds of the limiting saaty consequences deemed acceptable for the design basis event.
Staff Position Safe shutdcwn capability should be dem. castrated (Case A) or alternate shutdown capability provided (Case B) in accordance with the guidelines proviced belcw:
- 1. Cesien Sasis Event Be design basis event for considering the need for alternate shutt:wn is a pestulated fire in a s:ecific fire area containing redundant safe shutd:wn cables /ecuiprent in ef ose pr:ximity where it nas been detemined that fire ;rotecticn mea 6.s cannot assure t.at safe shut::wn capability will be preserved. Two cases shculd be c:nsidered: (1) offsite power is available; and (2) offsite
- wer is net available.
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- 2. Umitino Safety Consecuences and Raout red Shutdewn Functions j
2.1 No fissic't product boundary integrity shall be affected:
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No fuel clad damage; b.
No rupture of any primary coolant boundary; c.
No rupture of the containrent boundary.
2.2 The reactor coolant system process variables shall be within i
l those predicted for a loss of nomal ac power.
2.3 The altemate shutdown capability shall be able to achieve and maintain suberitical conditions in the ranctor, maintain reactor coolant inventory, achieve and mairtain hot standby
- conditions (hot shutdown
- for a ENR) for an extended period of time, achieve cold shutdown
- conditions within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and maintain cold shutdown conditions thereafter.
As defined in the Staridard Technical Specifications.
- 3. Performance Goals 3.1 The" reactivity control function shall be capable of achieving and maintaining cold shutdown reactivity conditions.
3. T.
The reactor coolant makeup function shall be capable cf maintaining the reactor coplant level above the top of the core for 8WR's and in the pressurizar for 'WR's.
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l 3.3 The reactor heat removal function shall be capable of achte,ving and maintaining decay heat removal.
3.4 The process monitoring function shall be capable of i
providing direct readings of the process variables necessary to perform and control the above functions.
3.5 The supporting function shall be capable of providing th'e process cooling. lubrication, etc. necessary to pemit the operation of the equiprent used for safe shutdown by i
the systems identified in 3.1 - 3.4.
The equipment and sy(stems used to achieve and maintain hot 3.6 standby conditions hot shutdown for a SWR) should be (1) free of fire damage; (2) capable of maintaining such conditiens for an attandei.i titne period longer than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 4if the ec uA
_shu_.tdown is not availa b,1e_due_ to_ fire damaje_;. and (3) capable i.7 cc'.
of being powered oy an onsite emergency power system.
3.7 The equipment and systems used to achieve and maintain cold shuti:wn conditions should be either free of fire damage or the fire damage to such systems should be limited such that re: airs can be'made and cold shutdewn conditions acnieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Equipment and systems used prior to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />
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after the fire should be capable of being powered by an ensite emergency pcwer system; those used after 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> may be powered by 1
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offsite power.
3.8 These systems need not be designed to (1) seismic category I criteria; (2) sin,gle failure criteria; or (3) cope with other plant accidents such as pipe breaks or stuck valves (Appendix A BTP 9.5-1), except those portions of these systems which interface with or icipact existing safe,ty systems.
- 4. PWit Eeuipment Generally Necessary 'For Hot Standby _
(1) Reactivity control Reactor trip capability (scram). Beration capability e.g.,
charging pump, makeup pug or high pressura injection pump taking suction from concentrated barated water supplies, and letdown system if required.
(2) Reactor Coolant Makeuo r,eactor coolant makeup capability, e.g., charging pugs or the high pressure injection pumps.
Power operated relief valves may be required to reduce pressurt to allow use of the high pressurt injection pumps.
(3) Reactor Coolant System Pressure Control Reactor pressure control capability, e.g., charging pugs or pressurizer heaters and use of the letdown system if required.
(4) Deca'y Heat Removal _
Decay heat removal capability, e.g., perwer operated relief valves.(steam generator) or safety relief valves for heat removal with a water supply and energency or auxiliary feedwater pumps for makeup to the steam generator. Service water or other pugs may be required to provide water for auxiliary feed pus suction if the condensate storage tank capacity is not adequate for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
(5) process Mon;torino Instrumentation Process monitoring capability e.g., pressurizer pressure and level, steam generator level.
(5) Sueoort.
The equiseent recuired to sucocrt c:eration of the above described shutdenn equi; rent e.g., c:::enent c oling) water service water, et:. and ensi e :ower s urces (AC, DC with their associated electrical cistributten system.
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- 5. PVR Ecuiofrent Generally Necessary For Cold Shutdewn*
(1) Reac'ter Coolant System Pressure Reduction to Residual Heat Removal System' (RHR) Caoacility_
Reactor coolant system pressure reduction by cooldown using steam generator power operated relief valves or atmcspheric dug valves.
(2) Decay Heat Removal Decay heat removal capability e.g., residual heat removal system, component cooling water system and service water system to removal heat and maintain cold shutdown.
(3) Sueoort_
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Support capability e.g., onsite power sources (AC & DC) er offsite after 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and the associated electrical distribution system to supply the above equipnent.
Equipment necessary in addition to that already provided to maintain hot standby.
- 6. BWR Ecuioment Generally Necessary For Hot Shutdown (1) Reactivity Control Reactor trip capability (scram).
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(2) Reactor Coolant Makeuo Reactor coolant inventory (makeup capability 4.g., reactor cort system RCIC) or the high pressure coolant isolation cooling (HPCI).
injection system (3) Reactor Pressure Control and Decay Heat Removal Depressurization system valves or safety relief valves for dug to the suppression pool. The residual heat rencval system in steam condensing mode, and service water system may also be used for heat removal to the ultirate heat sink.
(4) Suoortssion Pool Cooling Residual heat rte. oval system (in suportssion ;ool cooling moce) service water system to cairtain hot shutdown.
(5) Process Monitorino Process monitoring ca:acility e.g., reactor vessel level and pressure and suporessi:n pos1 temoeraturt.
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(6) Suocort l
Support capability e.g., onsite power source (AC & DC) and their associated distribution systems to provide for the shutdown equipment.
- 7. BWR douibment Generally Necessary For Cold Shutdown
- At 'this peint the equipment necessary for hot shutdown has reduced the prisary system pressure and temperature to where the RNA system my be placed in service in RHR cooling mode.
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Residual heat removal system in the RHR c:411ng sede, service water system.
(2) Supeert Onsite sources (AC & DC) or offsite af ter 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and their associated distribution systems to provide for thutdown equipment.
Equipment provided 'n addition to that for achieving hot shutdown.
- 8. Informatten Recuir t pr staff Review _
(a) Description of the systems or portions thereof used to provide the shutdown capability and modifications required to achieve the alternate shutdown capability if required.
j (b) Syst'em design by drawings which show normal and alternate.
. shutdown control and power circuits, location of conponents, and that wiring which is in the area and the wiring which is out of the area that rtoutred the alternate system.
(c)
Danonstrate that changes to safety systens will not degrade safety systems.
(e.g., new isolation switches and control. switches should meet design criteria and standards in FSAR for electrical equipment in the system that the switch is to be installed; cabinets that the switches are to be reunted in should also meet the same criteria (FSAR) as other safety related cabinets and panels; to avoid inadvartant isolation from the control room, the isolation switches should be keylocked, er alarmd in the control room if in the "local" or "isolatsd* ;osition; periodic checks should be made te verify switch is in the procer position for normal coeration; and a single transfer switch or other new device should not be a source for a single,ailure to csuse icss of redundant safety systems).
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(d) Dec.onstrate that wiring, including cower' sources for the control circuit and equierent c:erstion for :he alternate shutdenn metnod, is inoependent of equipr4nt wiring in the area to be avoided.
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Demonstrate that alternate shutdown power sources, including (e) a11 breakers, have isolation devices on centrol circuits that are routed,through the area to be avoided, even if the
- g. j breaker is to be operated manually, Demonstrate that licensee procedure (s) have been de' eloped (f) which describe the tasks to be perforned to effect the shutdown sethod. A sumary of these procedures should be submitted.
Demonstrate that spart fuses are available'for control
(.9) circuits where these fuses,may be required in supplying power to control circuits used for the shutdown method and may be blown by the effects of a :able spreading room fire. The spart fuses should be locat2d convenient to the existing fuses. The shutdown proce:ure should infonn the operator to check these fuses.
Demonstrate that the manpower required to perform the (h) shutdown functions using the procedures of (f) as well as to provide fire brigade senters to fight the fire is available as required by the fire brigade technical s pe,ci fications.
(1) Demonstrate that adequate acceptance tests are perforsed.
equipment operates from the These should verify that:
local control station when the transfer or isolation twitch is placed in the "local" position and that the equipment cannot be operated from the control room; and that equip-rent operates from the control room but cannot be operated I
at the local control station when the transfer or isolation switch is in the "remote" position.
Technical Specifications of the surveillance requirements (j) and limiting conditions for operation for that equipeent For exagle, not a'1 ready covered by existing Tech. Specs.
if new isolation and control switches are added to a service water system, the existing Tech. Spec. surveillance require-ments on the senice water system should add a statement similar to the following:.
"Every third pug test should also verify that the pug starts from the alternate shutdown station after moving all service water system isolation switches to the local control position."
(k) Demonstrate that the systems available are adequate to perform tne necessary shutdown functions. The functions required shculd be based on previous analyses, if possible (e.g.,
in the FSAR), such as a less of normal a.c. power or shutdown j
j on a Group I isolation (BWR). The equipment required for the alternate cacability shculd be the same or equivalent to that relied on in the above analysis.
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l (1) Demonstrate that repair procedures for cold shutdwn systems I
are developed and material for repairs is maintained on site.
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REQUEST FOR ADDITIONAL INFORMATION 0
1.
Section III.G of Appendix R to 10 CFR Part 50 requires cabling for or associated with redundant safe shutdown systems necessary to achieve and maintain hot shutdown conditions be separated by fire barriers having a three-hour fire rating or equivalent protection ( see Section III.G.2 of Appendix R). Therefore, if option III.G.3 is chosen for with the alternative method of hot shu, cabling required for or associated the protection of shutdown capability tdown for each fire area mu j
physicallyspearatedbytheequivalentofathree-hourratedfIre^stbe arrier l
from the fire area.
i In evaluating alternative shutdown methods, associated circuits are circuits that could prevent operation or cause maloperation of the alternative train which is used to achieve and maintain hot shutdown condition due to fire induced hot shorts, open circuits or shorts to ground.
Safety related and non-safety related cables that are associated with the equipment and cables of the alternative, or dedicated method of shutdown are those that have a separation from the fire area less than that required by Section III.G.2 of Appendix R to 10 CFR 50 and have either (1) a comon power source with the alternate shutdown equipment and the power source is not electrically protected from,the post-fire shutdown ciret t of concern by coordinated circuit breakers, fuses or similar devicest (2) a connection to circuits of equipment whose spurious operation will adversely affect the shutdown capability, e.g., RHR/RCS Isolation Valves, or (3) a comon enclosure, e.g., raceway, panel, junction box, with alternative shutdown cables and are not electrically protected from the post-fire shutdown
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circuits of concern by circuit breakers, fuses or similar devices.
For each fire area where an alternative or dedicated shutdown method, in accordance with Section III.G.3 of Appendix R to 10 CFR Part 50, is provided by proposed modifications, the following infomation is required to demonstrate that associated circuits will not prevent operation or cause maloperation of the alternative or dedicated shutdown method:
A.
Provide a table that lists all equipment including instrumentation and support system equipment that are required by the alternative or dedicated method of achieving and maintaining hot shutdown.
B.
For each alternative shutdown equipment listed in 1.A above, provide a table that lists the essential cables (instrumentation, control and power) that are located in the fire area.
C.
Provide a table that lists safety related and non-safety related cables associated with the equipment and cables constituting the alternativa or dedicated method of shutdown that are located in the fire area.
D.' Show that fire-induced failures of the cables listed in B and C above will not prevent operation or cause maloperation of the alternative or dedicated shutdown method.
q E.
For each cable listed in 1.8 above, provide detailed electrical schematic drawings that show how each cable is isolated from the-fire area.
2.
The residual heat removal system is generally a low pressure system that interf aces with the high pressure primary coolant system.
To preclude a LOCA through this interf ace, we require conpliance with the recommenda-tions of Branch Technical Position RSB 5-1.
Thus, thic interface mst likely consists of two redundant and independent motor operated valves.
These two notor operated valves and their associated cable may be subject to a single fire hazard.
It is our concern that this single fire could cause the two valves to open resulting in a fire-initiated LOCA through the subject high-low pressure system interface. To assure that this interface and other high-low pressure interfaces are adequately pro -
tected from the effects of a single fire, we require the following inf ormation:
A.
Identify each high-low pressure interf ace that uses redundant electrically controlled devices (such as two series motor operated valves) to isolate or jreclude rupture of any primary coolant boundary.
8.
Identify the device's essential c abling (pcmer and control) and describe the cable routing (by fire area) f rom source to termination.
C.
Identify each location where the identified cables are separated by less than a wall having a three-hour fire rating f rom cables i
for the redundant device.
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s D.
For the areas identified in item 2.C above (if any), provide the bases and justification as to the acceptability of the exist:ng i
design or any proposed modifications.
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wtw vonx, M. v. tocoa March.27,1981 AEP:NRC:00428A i
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Donald C. Cook Nuclear Plant Unit Nos.1 and 2 T,k Docket Nos. 50-315 and 50-316 l
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License Nos. OPR-58 and DPR-74 FIRE PROTECTION RULE (45 FR 76602)
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- b Mr. Harold R. Denton, Director
'h Office of Nuclear Reactor Regulation i
i U. S. Nuclear Regulatory Consnission Washington, D. C.
20555 Dear Mr. Denton.
The attachment to this' letter provides our response to Mr. Eisenhut's letter of November 24, 1980 regarding the provisions of Appeidix R to 10 CFR 50 which are applicable to the D. C. Cook Nuclear Plant. Those provisions are set forth in Section !!!.G. "Fire Protection ~of Safe Shytdown Capability";
III.J. "Emergency Lighting"; and !!!.0 "Oil Collection Systems for Reactor Coolant Pump" of the said Appendix R.
On July 31, 1979, the Consnission issued Amendments No. 31 and No.12 to the Cook Plant Operating License, along with the corresponding Fire Protection Safety Evaluation Report (SER). Table 1 of the SER listed the plant modifications and their respective completion dates. All of the items in Table 1 have been implemented, as required. and as'such the fire protection program for the' Cook Plant is in' full compliance with the guidelines contained in Appendix A to Branch. Technical Position APCSB 9.5-1 and Gener.a.1 Design Criterio, 3.
These facts are supported by the 14RC's conclusion drawn in the July 31.1979 SER which states:
"Our conclusion is that a fire occurring in any area of the,
D. C.* Cook Nuclear Plant will not prevent either unit from
' being brought to a controlled safe shutdown, and further that such a fire would not cause the release of significant amounts of radiation".
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Mr. Harold R. Denton 2-AEP:NRC:00428A On January 30, 1981, the Comission issued hiendments No. '44 and No. 26 to the Cook Plant Operating Licenses which provided us with the final revision to our fire protection Technical Specifications in accordance
'vith Table 1 of the Fire Protection SER. to M. Eisenhut's November 24, 1980 letter states that no open items from previous NRC staff fire protection reviews exist for the Cook Plant. The attachent to this letter demonstrates that the Cook Plant is already in empliance with the applicable provisions of Apundix R, noted above, which Mr. Eisenhut's letter requires to be backfit. T use. provisions of Appendix R. although not explicitly required by NRC Branch -Technical.:
Position APCSB 9.5-1, were included in the previous fire pr'otection. upgrade effort as a result of the' Plant's Fire Hazards Analysis and the ensuing.NRC questions / positions on the fire protection features of the C00K Plant.
Very truly yours.
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'R7 S. Hunter Vice President cc: John E. Dolan - Coltabus R. W. Jurgensen D. Y. Shaller - Bridgman R. C. Callen G. Charnoff Region !!! Resident Inspector at Cook Plant - Bridgman 9
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AEP:NRC:00428A G
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j This attactnent provides er response to Sections !!!.G. JII.J and 111.0 of Appendix R to 10.CFA.50 as required-by 10CFR50.48(c)(5). The information and references provided below demonstrate compliance with those sections of Appendix R and, as such, no further olant, modifications are neces-sa ry.
Section III.G,
- Fire Protection of Safe Shutdown Capability" The initial design of the Cook Nuclear Plant employs a Hot Shutdown panel for each Unit separated from its associated Unit's control room. This control panel contains suffrcient instruments and controls to 3
shut the reactor down and maintain'it in a hot shutdown condition.
Upon receipt of IE Bulletins 75-04 and 75-04A, issued subsequent i
to the Brown's Ferry Fire, a thorough study of the Cook Plant design was made to determine what' changes and additions would have to be made to the existing plant design to permit shutting the reactor down and bringing the Unit to a cold shutdown condition.from outside the control room. This study was completed and is described in our responses to the bull'etins and monthly progress reports on the status of the work submitted to the NRC. The re '
quired engineering changes consisted of the installation in each Unit of local remote shutdown indicator panels with. cabling independent of the cable spreading rooms. An' alternate. emergency shutdown and cooldown procedure in the event of a loss of normal and preferred alternate methods has been dei veloped for use in conjunction with the local shutdown system. The procedure j
has been written so that it can be used in part or in its entirety by pro-viding instructions for taking local control of any operation that can not 3
be performed using normal or preferred alternate methods. The specific procedures for modifying cor.ponents for local control are mounted at the 1
component so that they will be readily available when the need arises.
i Through the use of these local shutdown panels, modifications of standby essential equiment for local manual control and the associated emergency
.i shutdown and cooldown procedure, we have the installed and demohstrated cap-l ability to safely shutdown and cooldown the plant with or without offsite i
power upon loss of control of essential systems and equipment from the con-trol room and/or the hot shutdown panel.
'We provided further detailed descriptive inf shutdown system er.d procedures in our response to Appe,orwation on the local j
ndix A to Branch i
j Technical Position APCSB 9.5-1.in our Fire Hazards Analysis, during ;he NRC i
1 fire protection site visit (April 19-22,1977), at the May 11,197/ meeting I
with the NRC staff, in'our letter of June -1, 1977 (followup to the May 11, 1977 meeting)', in parts of Appendix Q to the FSAR (Question 040.5) and in i
our responses to the "Fire Protection Questions" 1, 40, 46, 47, 52 asked in Mr. K. Kniel's letter of July ll, 1977.
In addition, we have provided in both Units 1 and 2 local manual centrol capability of the emergency diesel generators as part of the alter'nate local shutdown system in accordance with Unit 2 license condition 2. C. 3. (0). (c). This provides the local shutdown I
system with the capability of performing its function given a loss of offsite power. The NRC fire protection SER, issued July 31, 1979, accepted the Cook local shutdown system and amended the Cook operating licenses accordingly, (removing Unit 2 license condition 2.C.3.(0) entirely). All changes and l:
improvements listed in Table 1 of the SER, including those pertaining to the i
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local shutdown system have been implemented. Furthennore, as reported in the SER, the procedures and control operations for the local snutdown method rare tested. during Unit 2 initial power ascension. As such, the Cook Plant capability to achieve and maintain a safe cold shutdown condition including the necessary connunications has ' Deen fully demonstrated.
Our fire hazards analysis considered the effects of fire in every fire zone'in,the Cook Plant with respect to structures, systems, and com-ponents important to safe shutdown.
In all cases the ability to achieve.
and maintain a safe shutdown condition is preserved. Redundancy of design and separation of systems and equipcent is provided in the Cook Plant design.
As stated in our response to Question 040.6 in Appendix Q to the FSAR, the design of the Cook Plant complies with the separation requirements of Safety Guide 1.75 as applied to Class IE equipment and circuitry.
For the treatment of associated i:ircuits the Cook Plant design provides the following:
a) flon Class lE cables are ro'uted with Class IE cabics in cable trays. The cable numbers of these associated cir-cuits are modified to include a letter designation identifying the train association. These cables are allcwed to leave the Class IE cable trays and be routed with non-safety cables but are not allowed to be again routed with Class IE cables of either safety train.
i b) t;on-safety loads are allowed to be connected to eafety buses in the following minner. All non-safety loads, whether shed automatically upon transfer to emergency pewpr or retained, are powered through Class IE circuit interruptir.9 devices. All load shedding devices are Class IE as are the fault detecting and isolating equipment applied to disconneettng non-safety.
related loads. The non-safety loads are described in our re-sponse to Question 040.11 and 040.14 in Aopendix Q to the'FSAR.
These non-safety loads do not degrade the performance of any i
safety bus. Class IE circuit breakers are provided for non-safety AC loads fed from AC safety buses which are not shed following a loss of offsite power.
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For the DC power system, fuses are used as the protective de-vices for non-safety loads con't..ted to the R safety buses.'
a Non-safety cables originating from the CD battery. (for example) are permitted to be routed wi-th safety cables of the CD battery only.
Non-safety canles from the CD hattery are allowed to leave the CD battery safety trays and be routed with the balanc6 of plant cables in non-safety trays but are not allowed to be again routed witn CE battery safety cables. Once the non-safety 1
cable leaves the safety train routirg it must remain in the non-safety cable routing and cannot ce again ' routed with the' safety train cables of either train.
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-.3-d) protection grade instrumentation safety equipment is protected from faults in the non-safety enalog circuits l
connected to it by Isolators.
I When accounting for the redundancy and separation of circuits for equipment necessary to achieve and maintain safe shutdown (Class IE circuits) and our treatment of associated circuits, the Cook Plant design provides adequate protection of safe shutdown capability. For any areas of the plant which were detennined to be susceptible to a fire exposure from transient fire loads automatic fire detection and automatic sprinkler systems are provided. These fire protection systems were installed in the Cook Plant in accordance with Table 1 of the SER and these systems are included in our fire protection Techn,ical Specifications. As such the Cook Plant design provides, sderpate protection of safe shutdown capability and supports the conclusion i
that a fire occurring in any area of. the Cook Plant should not prevent either Unit from being brought to a controlled safe shutdown. Furthemore, special -
attention was given to the design of the local shutdown system so that either Unit could be brought to and maintained in a cold shutdown condition for the case of a fire in the cable spreading room rendering circuits in the main con-trol ' room and hot shutdown panel inoperable. No further actions need to be taken with regard to Section III.G of Appendix R for the' Cook Plant.
Section !!!.J "Emergency.Lichting" Emergency lighting units with an eight (8) hour battery pack are provided in all areas of the plant needed for operation of safe shutdown equipmer.4 and in ' access and egress routes thereto.
This requirement has already been implemented in accordance with our September 30, 1977 response '
i to fire protection questions Nos. I and 40 on the schedule pursuant to item
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Ho. 22 contained in Table 1 of the NRC fire protection SER. No further actions are necessary with regard to Section !!!.J of Appendix R for the Cook Plant.
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Section !!!.0 "Oil Ccilection System for Reactor Coolant Pump"
' The Reactor Coolant Pump (RCP) oil spillagt. control and protection system has already been installed on each RCP in both Units of the Cook Plant in accordance. with our August 19, 1977 response to fire protection question No. 51 as supplemented by our November 22, 1977 letter which,in part,provided additional information with regard to question No. 51 subsequent to our November 3-4' 1977 meeting with the NRC. Staff.
This system was installed in accordance with item No.19A of Table 1 of the NRC Fire Protection SER. ThIs system fully eeets the requirements of Section 111.0 of Appendix R and to further action is required for Cook.
Plant.
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