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uc n n MEMORAMUM FOR: Richard W. Starostecki, Director Division of Project and Resident Programs, Region I John A. Olshinski, Director Division of Reactor Projects, Region 11 Charles E. Norelius, Director Division of Reactor Projects, Region III Richard P. Denise Director Division of Reactor Safety and Projects, Region IV Dennis F. Kirsch, Acting Director :
Division of Reactor Safety and Projects, Region V i Darrell G. Eisenhut, Director
{
Division of Licensing NRR Robert Bernero, Director l
Division of Systems Integration, NRR ,
Richard H. Vollmer, Director !
Division of Engineering, NRR 1
FRON: J. Nelson Grace, Director l Division of Quality Assurance, Safeguards, and Inspection Programs Office of Inspection and Enforcement
SUBJECT:
DRAFT COPY OF PROCEDURES FOR INSPECTION OF 10 CFR 50 APPENDIX R REQUIREMENTS FOR SAFE SHUTCOWN Enclosed is a draft copy of TI 2515/62, Revision 2 for your coment. This document has been prepared primarily to provide procedures for conducting i inspections against the requirements of 10 CFR 50 Appendix R (Sections III '
G., J. and 0) for both operating plants licensed before 1979 and those plants (operating and NTOL) licensed after 1979. Previous versions of TI 2515/62 applied to only those plants licensed prior to 1979.
Appropriate revisions to this TI will be initiated subsequent to Conr.ission action on the Fire Protection Steering Comittee recomendations. We request that you expedite consideration of this instri ion and provide any coninents not later than January 4, 1985. I J. Ne lson Grace Dire or Division of Quality Assurance, Safeguards, and Inspection Prograr.s Office of Inspection and Enforce ent
Enclosure:
TI 2515/62, Rev. 2 (draf t copy)
CONTACT- E,-Whitne (49-29688) yr-I h, C ,. 1M g/
o lcg cl M9 pg '
00A51F TEMPORARY INSTRUCTION 2515/62, REY. 2 INSPECTION OF SAFE SHUTDOWN, EMERGENCY LIGHTING AND OIL COLLECTION REQUIREMENTS AT ALL NUCLEAR POWER PLANTS 2515/62-01 PURPOSE To ascertain whether licensees are in conformance with Sections III.G. J.
and O. of 10 CFR 50, Appendix R, to the extent made applicable by licensing requirements and comitments, or the provisions of 10 CFR 50.48. This instruction provides inspection guidance for all consnerical nuclear power plants.
2515/62-02 BACKGROUND Effective February 17, 1981, the Nuclear Regulatory Consnission amended its regulations by adding Section 50.48 and Appendix R to 10 CFR 50 to require certain provisions for fire protection in nuclear power plants licensed to operate prior to January 1,1979. This action was taken to resolve certain contested generic issues in fire protection safety evaluation reports (SERs) and to require all applicable licensees to upgrade their plants to a level of protection equivalent to the technical requirements of Sections III.G. , J. and 0, of 10 CFR 50, Appendix R. Licensees were required to meet the separation requirements of Section III.G.2., the alternative or dedicated shutdown capability requirements of Sections III.G.3. and III.L.,
or request an exemption in accordance with 10 CFR 50.48.
Plants licensed after January 1,1979, are subject to requirements similar to 10 CFR 50, Appendix R, as specified in the conditions of their Facility Operating License, comitments made to the NRC, or deviations granted by the NRC. These "post-79" reactor plants are subject to the requirements of 10 CFR 50.48 (a) and (e) only.
The Fire Hazards Analysis (FHA) (Fire Protection Review, Fire Protection Evaluation) document of these post-79 reactor plants may hsve been reviewed under Appendix A to Branch Technical Position APCSB 9.5-1 "Guidelines for Fire Protection for Nuclear Power Plants Docketed Prior to July 1,1976" of August 23,1976 (in which case, the licensee conducted an Appendix R com-parison and justified FSAR or FHA differences from specific provisions of Appendix R). It is also possible that these post-79 licensee submittals were reviewed under Standarc Review Plan NUREG 0800 and Branch Technical Position CMEB 9.5-1 (fonnerly BTP ASB 9.5-1) "Guidelines for Fire Protec-tion for Nuclear Power Plants", Rev. 2 of July 1981 (in which case, licensee submittels were reviewed against requirements which with some s exceptions, closely paralleled tne provisions of Appendix R).
Issue Date:
SAFE SHUTDOWh, EMERGENCY LIGHTihG, 2515/62-02 AND O!L COLLECTION The actual fire prcte:tior, recoirements i.;;ilcatie tt a giser. rea:ter plant licensed af ter January 1,1979 arise fror the soe:ific li:ense concitions in a plant's Facility Operating License. These license conditions refer to Safety Evaluation Reports (SERs) and Supplemental Safety Evaluation Reports (SSERs). SER Introduction Section 9.5 will delineate which licensee submittals were reviewed (e.g., a Fire Hazards Analysis would be such a submittal). The plant configurations and procecures oescribed in these submittals are "requirements of the license". Answers to question < raised in the SER review process would be termed "licensing comitments." These "licensing comitments" are "requirements of the license" if referenced by or appended to SERs which are, in turn, referenced within the Facility Operating License. -
2515/62-03 GENERAL INFORMATION l 03.01 It is recorrrnended that a team be assigned to perfom this in.
spection. The following is a suggested minimum team. ,
- a. Team Leader . leads discussion with licensee at entrance l ano exit interview. Should be a region-based inspector. '
Also partictpates in inspection effort.
- b. Safe Shutdowe Specialist - inspects the safe shutdown i systems, equfpment, and circuits. I l
- c. Fire Protection Specialist - inspects fire protection of !
the safe shutdown systems, equipment, and circuits. l 03.02 Inspection experience to date has shown the usefulness of adding one team member to review the licensee's alternative safe shut-down systems and procedures.
03.03 This is a technically complex inspection. Since there are many variations in the technical details by which a facility can meet safe shutdown criteria, a site-specific inspection i plan must be prepared. See Appendix A for detailed guidance l on the preparation of inspection plans. l 2515/62 04 SPECIFIC INSPECTION REQUIREMENTS Fct reactor plants licensed after January 1,1979, items to be inspected (and the necessary degree of compliance with Appendix R) at a reactor plant art dependent upon the specific requirements and comitments of the reactor plant's Facility Operating License and its supporting documentation (see y Section 2515/62-02). Section 2515/62-04 is written under the assumption
- Regions may use inspectors who have the necessary expertise, request assistance from NRR, or use available IE contractors who have the necessary expertise.
Issue Date: - - - . . _ . , . - ... - . . _ . - . . - - . . - . - - . . -
l I
SAFE SHUTDOWN, EMERGENCY LIGHilhG,
. AND O!L COLLECTION 2515/62-04 i
that all previsions of 4;enci) E. Sc:a cr.s :::.G. J. an; 0, are a W 1catie it the plant uncer cons 1ceration. ;
04.01 Section III.G.2. Safe Shutdown Capability
- a. Review the systems and equipment used to meet the safe {;
shutdown requirements. Systems included should fulfill the following requirements.
- 1. The reactivity control function shall be capable l of achieving and maintaining cold shutdown reactivity conditions. ,
- 2. The reactor coolant makeup function shall be capable of maintaining the level above the top of the core for BWRs and within the level indication of the j pressurizer (or solid plant) for PWRs.
- 3. The reactor heat removal function shall be capable of achieving and maintaining decay heat removal.
l
- 4. The process monitoring function shall be capable of l
. providing direct readings of the process variables necessary to perform and control the functions in Items a.1., a.2., and a.3., above. Note: Source range
, neutron indication is not required for BWRs.
- 5. The supporting functions shall be capable of pro- !
viding the process cooling, lubrication, etc. neces- 1 sary to pennit the operation of the equipment used for safe shutdown functions, l
- b. Verify, on a sample basis, that plant fire areas (bounded !
by 3-hour-rated walls or equivalent approved by NRR) which contain components from both redundant trains of safe shutdown equipment meet one of the following: !
- 1. Separation requirements of III.G.2; or
- 2. An alternative or dedicated shutdown capability meet- l ing the requirements of III.G.3, and III.L as de-l scribed in the safety evaluation report (SER) issued l by NRR or licensee documents referenced therein.'
- c. Verify, on a sample basis, that modifications necessary to ensure safe shutdown are in confonnance with the infor-mation described in the NRR SERs, SSERs, or applicable license documents.
- See Section 04.02 (belo.) for inspe: tion requirements if alternative or decicated shutdown is required.
Issue Date:
SAFE SHUIDOWN, EMERGEN'Y LIGhilt.G, 2515/62-04.01d AND O!L COLLECTION
- d. Verify that re car.c a r t t ra i r,1 of ca:les ( s a f e t. - r t 'i a
- t ; ,
nonsafety-relatec, ar4 ass:-iated circuits) anc ecuip ert in selected fire areas have been identified anc analyze:
by the licensee to snow tnat they would not prevert safe shutdown operation because of hot shorts, open circuits,
) or shorts to ground. Verify that they have separat1or.
/ l or barriers as required by III.G.2 of Appendix R.
- e. Verify, on a sample .-. sis, that installation M t=t4;-
of necessary fire detectors and automatic fire suppression
, # ,v systems required by III.G.2 are as described in NRR SERs, SSERs, or other license documents. rd mm . 4 c'# ~ * - *s w e ">
>'fi' l /
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- f. *ld'.i.%~2.TA'*
Verify, on a sample $lu:basis, d5'WEl.~ih'ai r!."AWEZ edundant trains Tl?: of -. ' '*
- .1 systems required for hot shutdown located in the same
, # r# ,+
i r' ; fire area are not subject to damage from fire suppression
(' ?' activities or from the rupture or inadvertent operation V
< .'. f fL %'f/j" -
of fire suppression systems (reference IE Infor1 nation Notice No. 83-41 of June 22,1983),
pgJ[+ / }, , .
- 1. Whether a fire in a single location (or inadvertent
," ; " s actuation of fire suppression system) could directly cause activation of potentially damaging automatic Y (" fire suppression systems for all redundant trains, or;
- 2. Whether a fire in a single location could, indirectly, through the production of smoke, heat, or hot gases, cause activation of potentially damaging fire suppres-sion for all redundant trains, or; i
- 3. Whether a fire in a single location (or inadvertent actuation or rupture of a fire suppression system) could , through local fire suppression activity, in-directly cause damage to all redundant trains (e.g., 1 sprinkler caused flooding of other than the locally '
affected train), or;
- 4. Whether, in response to a fire in a single location the utilization of manually controlled fire suppres-sion systems could cause damage to all redundant trains.
04.02 Sections III.G.3 and L. Alternative and Dedicated Shutdown capability
- a. Review the systems and equipment used to meet the alter-native or dedicated shutdown requirements. Verify they meet the following functional requirements.
- 1. The reactivity control function shall be capable of achieving, monitoring, and maintaining cold shutdowr.
reactivity concitions.
Issue Date:
SUESHUT00WN,EMERGENGSLIG-ilhG,
. AC Olt C0U.ECTION > # 2515/62-04.02a2
/)
/ 2/' hine rea::cr c ci:,i e r.: r.a.eup function stci; be casa;',e c / / ef mir.tairir.; tne rea:ter coolant level above tre
? 59 top of the core fer BARS or be within the level
/ C# indica tior, in tne pressurizer (or solio plant) for
.- p F/
PWRs.
e " [y 7 3. The reactor heat removal function shall be capable of M /pd[/ / achieving anc maintaining decay heat removal.
.e-
. ' ' '# 4. The process monitoring functions shall proJ1de direct b
t *,.cd3 reading of the process variables necessary to perform
/ " ?:" and control the functions in Items a.1. , a.2. , and a.3. , above.
- (See memo referred to in Appendix A,
// Section A.19 of this temporary instruction.)
- b. Verify that alternative or dedicated shutdown capability is in conformance with information provided in the appli-cable SERs, SSERs and supporting documents.
c-
- c. Examine the alternative or dedicated shutdown equipment and verify that it is independent of the fire area, room or zone under consideration and that electrical isolation capability is provided as described in the SER and sup-porting documents.
- d. Review the licensee's testing program for ensuring alter-native or dedicated shutdown capability and verify that it includes, at a minimum, provisions for ensuring that equipmen*, operates from the local control station but '
cannot be operated from the control room when the transfer 1 or isolation switch is placed in the "local" position and that equipment operates from the control room but cannot be l operated from the local control station when the transfer l or isolation switch is in the "remote" position.
- e. Verify that the licensee's training program for licensed and non-licensed personnel has been expanded to include alternative safe shutdown capability training for all required individuals in the event of a fire.
- f. Verify that personnel required to achieve and maintain the plant in hot shutdown following a fire using the alternative shutdown systems, can be provided from !
normal onsite staff, exclusive of the five-person fire i brigade.
- g. Verify that adequate procedures for use of the alternative i shutdown system exist. Verify the operators can perform j the procedures within applicable shutdown time require- '
ments. The licensee can be requested to demonstrate the 4 adequacy cf the alternative shutdown procedures by "walking through" the pro:ecural steps.
).
Issue Date:
SAFE S C D;n , EMERGE C .iGri:.;,
2515/62-04.03 A'C Olt COLLEttig 04.C3 Ere-et :.. L 1;* :1 rs
- a. Verify that the plant etergen:y lig*:in; capaMiities reet tre following requirements of III.J.
- 1. Emergency Lightine Areas a, control room,
- b. other critical area (s) and access routes which require illumination to allow manual safe shut-down equipment operation or the monitoring of '
safe shutdown indications.
- 2. If tne emergency lights are powered from a central battery or batteries, then the distribution system must contain such protective devices that a fire in one area will not cause a loss of emergency lighting in any unaffected area needed for safe shutdown operations.
- 3. Review the manufacturer's information to verify that
. battery power supplies are rated with at least an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> capacity.
- b. In adcition to the regulatory requirements of III.J. above, the following areas should be reviewed.
- 1. Tour the plant and inspect the emergency lights in-stalled in a sample of the areas identified in ;
04.03.a. and the access routes to those areas. Verify the following:
- a. lamps are properly aimed.
- b. installed indication that the batteries are being procerly maintained such as:
l
- charge rate indication (lamp or meter)
- specific gravity indication
- c. sufficient illumination to pennit access for the monitoring of safe shutdown indications and/or the proper operation of safe shutdown equipment 4
. , . , . . . u, w k . ~ s.< c n H : e.a. , a >vn o - .
- 2. Review the manufacturer's infonnation to determine the periodic maintenance recomendations.
- 3. Review the surveillance of preventive maintenance procedure used for periodic checks of the emergency lights.
Issue Date: _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _
SA:E SnLTDOWi., EMERGEh:Y LIGHTINS, AND OIL COLLECTION 2515/62-04.03a .
- a. s e ri f,5 trat i t,t f re:w e n c;. 15 as specifie: 0,. t r,(
r.anuf a:turer,
- b. verify that the units are being maintainec as specified by the ma nuf a ctu re r. For example:
- lamps being checked -discharge cycle
- state of charge checked -electrolyte level
- connections (wetcell) 4 Review the emergency lighting drawings to determine if emergency lighting had been designated for a sample of areas not toured and areas found that did not have emergency lights installed.
04.04 Oil Collection System for Reactor Coolant Pump
- a. Review the drawings for the system to verify that all potential leakage points have been contained and the drain line(s) have been sized to accomodate the maximum leak. ~
- b. Verify that the oil collection system components have been designed so that there is reasonable assurance that they would withstand the safe shutdown earthquake (see Section !!!.0 of Appendix R).
- c. Verify that either the oil has a sufficient high flash point to prevent ignition of the oil by any equipment in the area or the tank vent has a flame arrestor installed.
- d. Verify that the licensee has a surveillance procedure for the oil collection system and has implemented the procedure. Included in the procedure should be:
- 1. periodic testing of the remote level indication (if installed).
- 2. periodic visual examination of the oil collection system piping and tank,
- e. Verify that the collection tank is a closed, vented tank and has sufficient capacity to collect all the oil from all reactor coolant pumps (upper and lower lube oil system),
simultaneously, or sufficient capacity to collect the oil from one reactor coolant pump and that overflow is directed to a location which does not present a fire hazard. Refer to applicable SERs for the specific configuration required.
- f. Inspect the reactor coolant pump oil collection syster to verify that it was installed as indicated by the drawings. If the plant is operating, the spare reactor coolant pump r.sy be inspected.
7 Issue Date:
SAFE SHUI 00a.'i, EMERGENO) LIGHilhG, i 2515/62-05 AND O!L COLLECTION l
\
'E15f,1-Oi RE G EI.h5 EE;. UlM. JL The results of this ins:ect. ion will be documented in a standare inspectier report. A copy of the fir 61 report shall be forwarcec to tne Of fice of Inspection anc Enforcer.ent, Division of Quality Assuran:e, Safeguards, and Inspection Progrims, and to the Office of huclear Reactor Regulation, Division of Licensifig.
)
2515/62-06 EXPIRA?!ON This temporary instruction will remain in effect for one year from the date of issue. -
2515/62-07 IE CONTACT Questions regarding this Tempora ry Instruction should be addressed to Mr. Leon Whitney (301-492-9668).
2515/62-08 STATISTICAL DATA REPORTING --
Following is a list of inspection procedures for which credit may be taken.
Credit taken should be based on what the licensee had to do to seet the requirements or licensing conditions and commitments applicable to the facility.
Facilities Licensed before January 1,1979:
Procedure Number Credit Title 37700 100 % Design Changes and Modifi-cations 37701 100 % Facility Hodifications Training 41700 30 t' Training 42700 50 Plant Procedures 64704 100 % Fire Protection / Prevention Implementatien 72701 100 i Startup Testing New/ Modified l
Facilities Licensed after January 1,1979:
Procedure Number C redi t Title 37301 50 i Comparison of As-built Flant tc FSAR Description Issue Date: .. . . _ _ . - _ . . _ _ - - . _
5/JE SHJiDOWri, EMERGENCY LIGHilhG, AND OIL COLLECTION 2515/62-04.08 4 '. 7 ;; .: i Training 42700 5 0 '. Plant Procedures 64704 100 Fire Protection / Prevention Implementation 92718 50 % Safety Evaluation Report Review and Followup
- honlicensed individual training inspection credit up to 30% .
END 6
4 0
9- Issue Date:
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SAFE ' UTDOWr., Et'ERGEh;) U GC i tG ,
. Ap OIL COLLECTI0t; APPENDIY A. 2515/62 AiFEriDIA A Ih5FECT!0ti PLAN PREPARATI0h A. Document Review Because the inspection of the safe shutdown, emergency lighting, and oil collectinn requirements of Sections !!! .G. , J. , and 0, of of Appendix R to 10 CFR 50 is a complex undertaking, it is impor-tant that the personnel selected to perfonn the inspection be prepared before they arrive at the site.
- 1. Following is a list of documents that inspection personne1' should obtain and review before the inspection:
- a. Fire Hazard Analysis and related documents prepared by the licensee.
- b. NRR Fire Protection Safety Evaluation Report and supple-ments, and licensee documents referenced therein that constitute the NRR review and approval of the Fire Hazards Analysis of item A.1.a. ,* and, if spplicable, portions of
. the Facility Operating License applicable to post-fire safe shutdown.
- c. NRR Fire Protection Safety Evaluation Report and licensee documents referenced therein that constitute the NRR review and approval of modifications required to satisfy the alternative or dedicated shutdown requirement of Section III.G.3 of Appendix R.*
- d. Licensee's assessment of the plant to III.G, III.J. and III. 0 (10 CFR 50 Appendix R) requirements that identifies redundant safe shutdown systems and components, defines the fire areas, and locates the safe shutdown equipment and cables by fire area (part of this may include Item A.1.a by reference).
- e. Licensee and NRR correspondence constituting exemption requests and associated approvals.
- f. NRR memorandum from Mattson to Vollmer dated July 2,1982, "Position Statement on Allowable Repairs for Alternative Shutdown and on the the Appendix R Requirement for Time Required to Achiev( Cold Shutdown". J. H. Taylor sent copies to the Regional Division Directors on August 17, 1982.
- The dates of these items may be obtained from the NRR project manager.
A-1 Issue Date:
SAFE SHUID0ri:,, EMERGEf.;t L : 5 ~ ;',;
ADPENDIY A, 2515/62 AND OIL C0'.LEC'!O'i
- g. Memo fror .. 5. L : e.;.tir tc F. . J. f4 t ts a. ci .c Ja nua ry 7, 19f?. "State e t cf Staff Positior R c ;a -: n -
Source Range Flux, Reatter Coolant Temperature anc Stea-Generator Pressure I nd i ca ti or. to Meet Appendix R Alter-native Shutcown Capability".
- h. Licensee analysis generated in response to .the IE Information Notice No. 83-41: "Actuation of Fi re Suppression System Causin'g Inoperability of Safety Related Equipment" of June 22, 1983.
- i. Generic Letter 83-33: NRC Positions on Certain Require- '
ments of Appendix R to 10 CFR 50 of October 19, 1983.
- j. IE Information Notice No. 84-09: Lessons Learned from NRC Inspections of Fire Protection Safe Shutdown Systems (10 CFR 50 Appendix R) of February 13, 1984 and Revision 1 of March 7,1984
- k. "Interpretations of Appendix R" or similarly titled NRR Generic Letter to be generated-in Fall,1984 (Comission review required).
- 1. Generic Letter 81-12: Fire Protection Rule (45 FR 76602, Novenber 19, 1980) - Generic Letter 81-12 of February 20, 1981.
- m. Memo from R.J. Mattson to D.G. Eisenhut dated March 22, 1982 "Fire Protection Rule-Appendix R" containing clarifications of Generic Letter 81-12.
- 2. From the documentation develop the following information:
- a. Equipment required for hot shutdown.
- b. Additional equipment required for cold shutdown,
- c. Areas of the plant where alternative shutdown capability has been provided,
- d. Areas of the plant that contain components or cable runs l (control, power or instrumentation) from both redundant trains of equipment required for hot and cold shutdown.
- 3. :ne licensee should be asked to provide the following information, if it is not available in the regional office.
- a. Emergency operating procedures or equivalent that are i
used to achieve and rnaintain the plant in hot shutdown {
)
following a fire.
- b. Emergency operating procedures or ecuivalent tnat a re used to cool down the plant following a fire.
Issue Date: A-2
SU E Snv i;;W'i, EMERGEN;Y LIGHilNG,
. AN: 0!L COLLECTION APPENDIX A. 2515/62
- c. Results of tests run (if any) te verify the ability te t h i r.t a i r, tre ; i c r.t 1 r. r. :. t s r~ ;c c .. - f c i i c,.1 r c c fire . t' 2" assured less of o#fsite peaer (e.g. , naturt l cir:ule-tion test while using the atmospheric steam dumps),
- c. Any documents identifiec in Iter A.1 that were preparea by the licensee.
B. Inspections of Hot Shutdown Capability
- 1. Sy s tem / Equ i pme n t/ I n s t rume n ta t i o n
- a. From the list of systems, equipment, and instrumentation required to achieve and maintain hot shutdown, select a' sample for indepth review. For example, in a PWR the following could be selected:
(1) reactivity control - boration capability, (2) reactor coolant makeup - charging pump, (3) reactor. pressure control --pressurizer heaters, (4) decay heat removal - auxiliary feedwater pump, (S) process monitoring instrumentation - reactor tempera-ture and steam ganerator level (see Item A.1.f for complete list),
(6) support - onsite AC power and its distribution system.
gn o s p.: c o) Cysr!~s The six amea+, identified above generally define the 4ren of concern following a fire. Selection of one or two com-ponents from each ameer should be an adequate sample size.
b.
Mrem For the systems, equipment, and instrumentation selected in Item B.1.a. perfom the following:
(1) Using the licensee's cable routing drawings or analysis, identify the areas of the plant traversed by the cables of the redundant trains of hot shut-down equipment. The cables should include:
1 (a) power (nomal and emergency),
(b) control, (c) instrumentation, (d) associated circuits of concern, 4 D.Ne o b<-"'
s e x - a i -i z, A-3 Issue Date:
1 l
SAFE SHUTDOWN, EMERGEh0Y LIGHTIhG l APPEhDIX A, 2515/62 AND OIL COLLECTION *
(E) ;cintiy tti arec3 cf the glar.; tnat ccr tain the ec ip.
rent cf tne recuncant trcins reovirec for het sLtdoc..
(3) Wnere recifications have been required to meet the requirements of III.G.2, review the modification packages for adequacy of licensee review and appro-val, including 10 CFR 50.59 aspects.
(4) Inspect the areas of the plant and verify that the selected equipment and cables c/ the redundant trains meet the separation requiremencs of Section III.G.2 of Appendix R (i.e., separation by a 3-hour fire barrier,'
or separation by a horizontal distance of 20 (eet with no intervening combustibles with fire detection and automatic fire suppression in the area, or enclosure of the cables and equipment in a 1-hour fire barrier with fire detection and automatic fire suppression in the l area) or verify that appropriate deviations or exemp-tions approved by NRR exist for the areas being re-viewed.
- 2. Inspection of Alternative or Dedicated Hot Shutdown Capability
- l
\
- a. From the licensee's analysis, identify the fire aread for I which alternative shutdown has been provided or a dedicated shutdown system has been provided,
- b. From that analysis, select a sample of the areas and/or equipment for indepth review as follows:
(1) Select three or more areas of the plant (including the control room) where alternative shutdown has been provided, or '
(2) If a dedicated shutdown system is installed, select a sample of systems (see Item B.I.a for an example of equipment and instrumentation).
- c. For the areas and/or equipment selected in Item B.2.b, perfonn the following:
(1) Using the licensee's cable routing drawings or cable analysis, identify the protective measures isolating the cables that could' affect the alternative shutdown capability for that area. These cables should include:
- 1f the separation criteria of III.G.2 cannot be met for system, equipment, or instrumentation required for not sht.tdown, then alternative or cecicated shutdown provisions must be provided.
Issue Date:
A-4 l
- _ _ _ - -~. _ _ - . . . . . _ . _.
SAFE SHUTDOWN, EMERGEfC LIGHTING, AND Olt COLLECTION APPENDIX A. 2515/62 (a) poc r (r.crT.31 a.: e r ;e O ;,
(b) control, (c) instrumentation, (d) associated circuits of concern.
(2) Identify the location of the equipment necessary to provide alternative or ' dedicated shutdown capability.
(3) Verify- that the areas for wh',ch alternative or dedicated shutdown has been provided are protected' by fire detection and a fixed fire suppression system.
(4) Where modifications have been required, review the modification packages for adequate licensee review and approval, including 10 CFR 50.59 review. l (5) Inspect the areas of the plant to verify that the comitments of the SER have been met for the equipment and cables selected above.
- d. Where procedures have been developed, request that appro-priate licensee personnel conduct a walkthrough of the alternative shutdown procedures.
- 3. Procedure for Hot Shutdown
- l
- a. Review the procedure that the licensee uses for bringing l the plant to hot shutdown in the event of a fire in the (1) cable spreading room, (2) control room,** l (3) other selected critical areas. l
^
- Procedures for bringing the plant to hot shutdown in the event of a fire should consider both the use of only onsite power and the use of offsite power. Credit taken for the failed position of some equipment on loss of offsite power must be addressed when offsite power is not lost. Addi-tionally, some "associated circuits of concern" may require procedures to detect and correct spurious operations of these circuits. These pro-cedures should also be included in the review.
- Credit is given for manual scram from the control room prior to evacu-ation.
A-5 Issue Date:
__ . , - - . . _ _ . _ . _ _ . _ _ _. ~ _ , _ . _
l SAFE SHUT 00Wri, EMERGEfCY L G C;hG l
APPENDIX A, 2515/62 AND OIL COLLECTION i
- b. Deterr r.e :re feasitiiity of performin; tre ;ro:e:<= ,r case o' fire b a walkthrough of specific set:im cf t r. (
,, #,, ' # procedure. ;
f, , * ,f Fay particular attention to prescribed modifications (e.g. ,
f, @.s
< / ,, ' , . . Q. J '* lifting leads, pulling fuses) (if any) that must be made in
,y
.c so
. , /' o rder to achieve or maintain the plant in het shutdonn.
/' - 4. Staffing
.,0', :,
r e, a. Detennine if there are enough qualified personnel avail- l able on shift to perform the operations necessa ry to maintain the plant in hot shutdown and staff the' five-person brigade,
- b. Verify that comunications capability between the various control stations is adequate for shutting down anc maintaining the hot shutdown condition.
1 Training 5.
- a. Verify that the licensee's training program includes instruction, on a periodic basis, in the use of the procedure for hot shutdown following a fire.
- b. Interview a sample of operators and assess the adequacy of j training that has been conducted on the existing procedure.
-C -
g ;;, c. 7 Inspection of Cold Shutdown Capability i
l
- 1. Sy s t ems / Eq u i pme n t/ I n s t rume n ta t i o n
- a. From the list of additional systems, equipment, and )
instrumentation required to cool the plant from hot '
shutdown to cold shutdown, select a sample for indepth review. For example, in a PWR, the following could be selected:
(1) reactor coolant system pressure reduction - auxi-liary spray line valve controls,
)
(2) decay heat removal - RHR pump, (3) support - onsite power. .
l The above three items represent equipment, in addition to the equipment required for hot shutdown, necessary for l cold shutdown. Selection of at least one or two components l from each area should provide an adequate sample size.
- b. For the systems, equipment, and instrumentation selected in item C.I.a. perform tne following:
Issue Date: A-6
SAFE SHUT 00Wri, EMERGENCY LIGHTING, AND OIL COLLECTION APPEN0!X A, 2515/62 l (1) for pcsa.lttec fir ( cau;e , ca r.mia the fea s it ilit., l cf repair and ccol dowr. v.ithir, 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. I (2) Determine that any ma te rial required to repair the ,
damaged area is available on site, 50 that the 72-hour limitation can be met.
(3) Review the licensee's procedure for effecting repairs to the damaged area.
(4) Inspect the areas of the plant containing the ,
equipment, systems, and instrumentation required :
to cool down the plant. '
- 2. Procedure for Cooldown
- a. Review the procedure that the licensee uses for bringing i the plant to cold shutdown conditions in the event of a l fire in the (1) cable spreading room. -
. (2) control room
- b. Detemine the feasibility of perfoming the procedure in case of fire by a walkthrough of specific sections of the procedure,
- c. Pay particular attention to repairs that must be made in order to cool the plant to cold shutdown conditions.
- 3. Training
- a. Verify that the licensee's training program includes instructions, on a periodic basis, for the use of the cooldown procedure following a fire.
- b. Interview a sample of operators and assess the adequacy of training that has been conducted on the existing procedure.
l l
1 A-7 Issue Date:
1 1
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