ML20151H926
| ML20151H926 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Fort Saint Vrain |
| Issue date: | 12/07/1983 |
| From: | Johnston W Office of Nuclear Reactor Regulation |
| To: | Lainas G Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML082321542 | List: |
| References | |
| FOIA-88-92 TAC-52647, NUDOCS 8312220153 | |
| Download: ML20151H926 (7) | |
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DEC 7 1983 e:.
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. *h, MEtiORANDUM FOR: Gus C. Lainas, Assistant Ofrector c,
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! William V. Johnston, Assistant Director
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'..A lic " 4./..' Materials, Chemical & Environmental Technology q...;
- ? W 9'.'.w Division.of.Esminevring
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,SUBJECTi REGION IV REQUEST FOR TECHNICAL ASS!$TANCE CLARIFICATION l,.
OF APPENDIX R TO 10 CFR 50 APPLICABILITY TO FORT ST. VRAIN N,.'
.(50 267),(TACJ52647-TIA 83-105)
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By' memorandum dated Novembe' '2,1983 (J. E. Gagliardo to D. G. Eisenhut),
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Region-IV requested. technical assistance re
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. Appendix R to 10 CFR 50 to Fort.St. Vrain. garding the applicability of The region posed two questions.
'g response is enclosed.,14 u 1;"
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res'ponding to'these' questions, we are reviewing the performance goals for Ft. St. Vrain's Alternate Shutdown Cooling Method. The results of this review will be forwarded within the next month.
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c ta William V. Johnston, Assistant Director h
Materials, Chemical & Environmental Technology Division of Engineering
Enclosure:
As stated
Contact:
D. Kubicki x27743 v
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R. Vollmer S. Ebneter, Region !
D. Eisenhtt T. Conlon, Region II J. Miller C. Norelius, Region !!!
F. Rosa G. Madsen, Region IV H. Srinivasan P. Sternberg, Region V g'
V. Bensroya W. Shields 4
T. Wambach S. Trubatch Distribution C. Trammell S. Pawlickt dentral4 Files 3R T. Sullivan
- 0. Parr J. Wermeil J. Taylor CHEB Reading
- 0. Kubicki CMEB Plant DE:CPIB 4 %. O EB OKubt DE:CMEB V; hWJohnstonDE:AO:MCET@
uson VBenaroya 12/
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/43 12/'1/83 12/j /g3 4
q e312220153 031297 CF ADOCK 05000267 5(.
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FORT ST. VRAIN CLARIFICATION OF APPENDIX R TO 10 CFR 50 APPLICABILITY TO FORT ST. VRAIN (50-267).
Chronology As a result of the 1975 audit, which revealed deficiencies in cable routing at the plant, PSCo and NRC reached an agreement to implement additional fire protection modifications. These modifications included the installation of additional fire detectors, fire suppression systems, a fire retardant T.
coating on combustible cable insulation and an alternate cooling method (ACM) for the three room control complex and cable concentration areas.
This work was to be completed in three stages.
2 lj-In our SER of June 18, 1976, in conjunction with Amendment No. 14 to Facility Operating License No. OPR-34, we reviewed the Stage 1 a
modifications and found them acceptable.
In our SER of October 28, 1977, in conjunction with Amendment No. 18
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to OPR-34, we reviewed the Stage 2 modifications and concluded that the
'I fire protection requirements for Stage 2 operation had been satisfactorily completed.
We indicated that approval for Stage 3 operation would necessitate that PSCo develop an acceptable plan for "substantial conformance" with NRC fire protection guidelines, which may include Appendix A to NRC Branch Technical Position 9.5-1.
t In our 1ctter to the licensee dated February 10, 1978, we requested that PSCo.
compare the fire protection program for the balance of plant, i.e., all areas other than the three room complex and cable concentration locations, to the guidelines in Appendix A to BTP APCSB 9.5-1.
3 The licensee transmitted this comparison by letter dated October 13, 1978.
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2 In our SER of June 6,1979, in conjunction with Amendmcnt No. 21 to OPR-34, we summarized the fire protection modifications which would be implemented l
l in conjunction with Stage 3 operation.
With the exception of the establish-I ment of a plant fire brigade and training program, these modifications pertained to fire protection for the three room complex and cable concentration
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These modific.tions were found to follow the applicable guidelines of areas.
Appendix A to BTP 9.5-1.
Based on:
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(1) The satisfactory resolution of all fire protection concerns with the
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1evel of fire safety in the critical three room complex and cable
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(2) The ability to achieve safe shutdown, via the ACH, if a fire occurred
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in the plant; b
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(3) The availability of a trained plant fire brigade; and bi (4) Our in-house audit of the Itcensee's Appendix A comparison;
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we did not deem it necessary to mandate additional fire prct.stion modifications for continued plant operation.
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In our final SER of August 19, 1980, which reported on revisions to the
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fire protection technical specifications, we stated that this review l3 "closes out the last remaining open item in the fire protection program review of Fort St. Vrain".
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Becads(theresolutionofourprincipalfireprotectionconcernswith
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FortSgVrainweredocumentedinthepreviouslyreferencedSERs,wedid
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not doc 0 ment the results of our audit of the Itcensee's Appendix A 1 i y-comparison.
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On May.23, 1.980, the Commission issued a.Hemorandum and Order (CL1-80-21 i-whic'h' states that, "The combination of the guidanca contained in Append to BTP d5u 9.5-l',and the requirements set forth in this Rule (s50.48 and
.bi its' Apden'dikR) define the essential;e'lements for an acceptable fire (p
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tion p:rogram,at nuclea'r p...ower plants docketed..for Construction 4
to NM1,1976,for demon t[ahl'on of' compliance with General De 1
h Critirion 3 o' f' Appendix A to 10 CFR 50".
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a-On November 19, 1980, 150.48 Fire Protection and Appendix P was published
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in the Federal MeOllier, H0,44 sets forth the appitsability of Appendix R
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j as follows:
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... (b) Appendix R.to this part establishes fire protection features
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.ekuired'to satisfy.{Crjterion 3 of Appendix A to this part h
with respect'to certain generic issues for nuclear power i
plants' Itcensed to operat'e prior to January 1,1979.
Except for the requirements of Section III.G, III.J. and III.0, the ya
' provisions of Appendix R to this part shall not be applicable p.,
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.to the extent that fire protection features proposed or implemented pff'
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' by the licensee have been accepted by the NRC staff as satisfying i
W-the provisions of Appendix A to Branch Technical Position 0
BTP APCSB 9.5-1 reflected in staff fire protection safety
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evaluation reports issued prior to the effective date of this i
rule, or to the extent that fire protection features were d i.,
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,;g.f.,n.ccepted by the staff in comprehensive fire protection safety n
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- n.,;lev <. : -aluation reports issued before Appendix, A to B
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,,},j Position BTP APCSB 9.5-1 was published in August 1976.With j.
k respect to all other fire protection features covered in Appenoix R, all nuclear power plants licensed to operate
,i prior to January 1, 1979 shall satisfy the applicable require-7
! O' ments of Appendix R to this part, including specifically the requirements of Sections III.G. III.J. and III.0".
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y i-3 NRC letter to all power reactor IIcensees f rom 0. G. Eisenhut, dated November 24, 1980, alerted licensees to the issue of revised Section 10, CFR 50.48 and a new Appendix R, to 10 CFR 50, to become ef fective February 17 1981.
This letter provides some clarification as to applicability:
'p "The provisions of Appendix R that are appitcable to the fire protection f
features of your facility can be divided into two categories.
The first h
category consists of those provi:lons of the Appendia that are required if to be backfit in their entirety by the new rule, regardless of whether I
or not alternatives in the specific requirements of these sections have been previously approved by the NRC staff.
Those requirements are f'.,
set forth in Sections III.G Fire Protection of Safe Shutdown g
Capability;...."
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The second category referred to involved any "open" items from previous
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NRC staff fire protection reviews as tvtlected in a staff fire protection safety evaluation report. to the letter provided a list or 1
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i "No outstanding fire protection issues on Fort St. Vrain."
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Licesee letter to NRC, serial P-81181, dated July 2,1981, stated that:
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"Public Service Company of Color' ado has reviewed Appendix R to 10 CFR 50 for applicability to the fire protection facilities at T
Fort St. Vrain. We find that Fort St. Vrain is in compliance with the provisions set forth in Appendix R."
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4, Following a special inspection of Fort St. Vrain for compliance with
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Section III.G of Appendix R to 10 CFR 50, Region IV. by memorandum
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dated Neverrber 2,1983, requestod clarification of two questions.
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response is as follows:
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What is the status of the fire protection Safety Evaluation Report for
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}y Fort St. Vrain andhr evaluation of compliance witn Branch Technical
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Position 9.5-1?
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The fire protection guidelines in Appendix A to BTP APCSB 9.5-1 were specifically developed for light water reactors.
Because Fort St. Vrain is a gas cooled reactor, several sections of the guidelines could not be 8PP11e4 direStly.
To regglyt many of the fire protettien tuutt senterning 64tt thetdDun, the licensee proposed a dedicated shutdown system for which acceptance criteria were developed and the impact of this system on the M era 11 fire program was considered in our review..
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g, At the time that Appendia R was prepared, the evaluation of the fire k
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.k to ll> APCS 8 9.5-1 was deemed complete.
Therefore, none of the 15 h.
specific requirements in Section I!! of Appendix R were written
'i to resolve contested issues on Fort St. Vrain. Although, the specific requirements in Section III were not developed for contested issues on Fort St. Vrain, CL1-80-21 and 150.48 established that these requirement eust be met or an equivalent alternative must be approved under the
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exemption process.
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As stated previously, the documentation of our review is contained in the Safety Evaluation Reports attached to amendments to the operating Ilcense:
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(1) Amendment No. 14 dated June 18, 1976 3-l (2) Amendment No.18 dated October 28, 1977
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(3) Amendment No. 21 dated June 6,1979 Because these SERs may not address the specific requirements of Section !!!
of Appendix R, acceptable alternatives to those requirements may not be specifically approved. However, the liensee has stated that Fort St. Vrain is in compliance with the provisions set forth in Appendix R, therefore.
a.ty issues raised by the lack of documentation of the staff audit of the 4
l fire protection program is moot.
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6-If routine fire protection inspections identify deviations which were sttp not approved, each deviation has to be evaluated against the specific l
requirements of Section III.
Lack of documentation of contested issues or approved alternatlyes implies approval of deviations identified in the licansee's documents.
However, this implied approval does not negate the Commission requirement to reexamine all plants for ccmpliance with l
Sections !!!.G. III.J and 111.0.
2.
How do the requirements of Section !!!.G. and Ill.L of Appendix R to 10 CFR 50 pertain to Fort St. Vrain?
As stated previously, the Comrnission directed the backfit of Section i
III.G to all nuclear power plants.
The Commission gave no specific t
exemption to Fort St. Vrain, therefore, Section !!!.G of Appendix R to 10 CFR 50 pertains directly to Fort St. Vrain in the same way it s
pertains to all other nuclear power plants, o
gr Section !!!.Q.3 requires an alternative or dedicated shutdown capability
'j be provided for certuin conditions outlined in Sections !!!.G.3.a j
and Ill.G.3.b.
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The minimum requirements for this shutdown capability are set forth in Section !!!.t..
The performance goals for this Ys shutdown capability were set forth, in part, in terms of damage to the multiple fission product barriers and process vairables limits that r
art appliC4ble LO $VR1 and PWRI.
Ihtrefore, thelt performance gLall n'
cannot be applied to a GCR such as Fort St. Vrain.
Our review of the performance goals for the Alternate Shutdown Cooling Method (ASCM) provided at Fort St. Vrain is ongoing. We will report later on whether these previously approved perfortrance goals for the ASCH should be modified.
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