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4 UNITED STATES
~ *0, NUCLE AR REGULATORY COMMISSION
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e WASHINGTON, D. C. 20555 i
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October 1,1936 d 00i 7 Al0 : 45 i
MEMORANDUM FOR: Those on Attached List FROM:
James G. Partlow, Director Division of Inspection Programs Office of Inspection and Enforcement
SUBJECT:
COMMENT ON POST-FIRE SAFE SHUTDOWh INSPECTION PROCEDURE TI-2515/62, Revision 2 has been rewritten into the standard inspection procedure format. The enclosed inspection procedure is intended to be used for the inspec-tion of all operating and near-term operating reactor facilitics. Changes in approach arising from the Comission's approval of SECY-85-306, SECY-85-306B and Generic Letter 86-10 have been incorporated. A periodic post-fire safe shutdown reverification program has been added to Section 03.01. The periodicity of the reverification inspection is envisioned to be between three and ten years.
Your co r.ents on the necessity, adequacy, and periodicity of this type of an inspection are desired.
Changes, additions, and deletions are indicated by "Rs" in the right margin.
Please review the enclosed IP and submit comments within four weeks of the date of this memorandum.
If you have only minor comments or no coments, a phone call is sufficient. If you have questions regarding thA matter, contact Leon Whitney on FTS 492-9668.
f A1.
n, Pyrtlow, Director ca James Divisjon of Inspection Programs Office of Inspection and Enforcement
Enclosure:
IP 64100 cc w/ encl:
W. Kane, RI R. Walker, Rll i
C. Norelius, RIII i
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u Addressees for Memorandum dated 10/1/86 Stewart D. Ebneter, Director Division of Reactor Safety Region !
Albert F. Gibson, Director Division of Reactor Safety Region !!
Carl J. Paperiello, Director Division of Reactor Safety Region 111 Eric H. Johnson, Director Division of Reactor Safety and Projects Region IV Dennis F. Kirsch, Director Division of Reactor Safety and Projects Region V Edward L. Jordan, Director Division of Energency Preparedness and Engineering Response Office of Inspection and Enforcement 4
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INSPECTION PROCEDURE 64100 POST-FIRE 5AFE SHUTDOWN, EMERGENCY LIGHTING AND OIL COLLECTION CAPABILITY AT OPERATING AND NEAR-TERM OPERATING REACTOR FACILITIES PROGRAM APPLICABILITY: 2513, 2514, 2515 (BASIC) 64100-01 INSPECTION OBJECTIVES The prirary objective of this inspection procedure is to obtain sufficient R information to determine whether a reactor facility is capable of achieving R post-fire safe shutdown. A closely related objective is to detemine R whether the post-fire safe shutdown physical configuration and procedures R are sufficiently well documented to permit the licensee to naintain the R established capabilities over the reactor plant's operating life. A third R objective is to periodical.ly reverify that the licensee has properly main
- R tained the post-fire safe' shutdown capability achieved during the initial R validation / revisit / full reinspection process.
R 64100-02 INSPECTION REQUIREMENTS Since post-fire safe shutdown requirements deoend on the date of issue of a R reactor plant's full-power operating license (see Sections 03.01 a and b R below),and since these requirements are very consistent between plants R licensed prior to January 1, 1979, the inspection requirements provided in R i
- nis section and Appendix A to this procedure are written for pre-79 reac-R tor plants. When used to assess the capabilities of a post-79 reacter R plant, these requirements should be modified in accordance with that R plant's specific licensing requirements.
R 02.01 Section III.G.2, Redundant Train Safe Shutdown Capability a.
Functional Requirements. Verify that-l 1.
The reactivity control function shall be capable of achieving and maintaining cold shutdown reactivity conditions.
2.
The reactor coolant makeup function shall be capable of main. R taining the level within the level indication of the pressurizer R (or solid plant) for PKPs.* For BWR's, the NRC has approved R partial short tem core recovery using ADS and LPCI. Note that k j
Tee reference 04.11 R
Issue Date:
l J
this option eliminates the need for the hot shutdown ma;t.tenance R capability of Section ll!.G.I.a. of Appendix R.
R J
3.
The reactor heat removal functicn shall be capable of achieving /
and maintaining decay heat removal.
4.
The process monitoring function shall be capable of 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 15 not required for BWRs.
5.
The supporting fynctions shall be capable of providing the process cooling, lubrication, and other services necessary to permit the operation of the equipment used for safe shutdown functions.
b.
Verify, on a sample b'as'*., that plant fire areas (bounded by 3-hour-rated walls or equivalent approved by hRR) which contain components from both redundant trains of safe shutdown equipment meet one of the following:
1.
requirements of Section Ill.G.2 of Appendix R, or 2.
an alternative or dedicated shutdown capabilit;. meeting the requireeents of III.G.3 and III.L of Appendix R as described in the safety evaluation report (SER) issued by NRR or licensee documents referenced therein*, or 3.
requirements of approved exemption requests.
c.
Verify that cables (safety-related and nonsafety-related) and equip-R ment in s11ected fire areas have been identified and analyzed by the licensee to show that they would not prevent safe shutdown operation because of hot shorts, open circuits, or shorts to ground.
Verify circuit breaker coordination and fuse protection has been analyzed R and provided as necessary.
R d.
Verify, on a sample basis, that the installation of necossary fire detectors and automatic fire suppression systems required by Section III.G.2 of Appendix R has been accomplisheJ.
In addition, R
<erify that the installed automatic suppression systems would ade-auately suppress fires associated with the hazards of each area.
e.
,erify, on a sample basis, that redundant trains of systems required for hot shutdown l<>cated in the same fire area are not subject to damage from fire suppression activities or frcn the rupture or inadvertent operation of fire suppression systems.** p termine each R of the following:
R 1.
whether a fire in a single.scation could, indirectly, through the production of smok2, heat, or hot gases, cause actisation
- See Section 02.02 below for inspection requirements if alternative or dedicated post-fire safe shutdown capability is proviued.
- See references 04.16 and 04.?7.
R
'esue Date: 64100
of potentially damaging fire suppression for all redundant trains.
1 2.
whether a fire in a single location (or inadvertent actuation or rupture of a fire suppression system) could, through local fire suppression activity, indirectly csuse damaqe to all redundant trains (e.g., sprinkler caused ficoding of other than the locally affected train).
3.
whether, in respense to a fire in a single location, the utili-zation of manually controlled fire suppression systems could cause damage to all redundant trains.
02.02 Sections III.G.3 and ll1.L, Alternative anc Dedicated Shutdown i
a.
Review the systems and equipment used to meet the alternative or dedicated shutdown requirements.
Verity they meet the following functional requirements:
1.
The reactivity control function shall be capable of achieving,
)
monitoring, and maintaining cold shutdown reactivi'.y conditions.
2.
The reactor coolant makeup function shall be capable of main-taining the reactor coolant level above the top of the core for BhRs or be within the level indication in the pressurizer (or J
solid plant) for PWRs.*
3.
The reactor heat removal function shall be capable of achieving and maintaining decay heat removal.
4.
The process nonitoring functions shall provide direct reading of the process variables necessary to control the functions in R Items a.1., a.2., and a.3., above.**
b.
Verify that alternative or dedicated shutdown capability is in cori.
formance with applicable NRR SERs and their supplements, or other R applicable licensing documents.
c.
Exanine alternative or dedicated shutdown equipment. Verify that it is independent of the fire area, room or zone under consideration and that electrical isolation is provided as described in the applicable NRR, SERs, and their supplements or..her applicable R licensing ducuments.
R d.
Review the licensee's testing program for ensuring reliable opera-R tion of alternative or dedicated shutdown equipment. Establish tnai a well controlled post-fire safe shutdown has been shown to be achievable from outside of the control room.
Further, verify that it ensures, at a minirrum, that equipment operates from the alterna-tive or dedicated control station, but cannot be operated from the control room when the local transfer or isolation switch is placed R
- See referance 04.13
- See reference 04.04 64100 Issue Date:
e-g e-w e,
in the "local position.
Also verify that equipment operates from the control room, but cannot be operated from the alternative or dedicated control station when the local transfer 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 or dedicated safe shutdown capability.
R f.
Verify that personnel required to achieve and maintain the plant in hot shutdown following a fire using the alternative shutdown system can be provided from normal onsite staff, exclusive of the fire R
- brigade, g.
Verify that adequate procedures for use of the alternative shutdown system exist.
Verify that the operators can perform the procedures within applicable shutdown time requirements.
Ensure that adequate communications are available for the personnel performing alterna-tive or dedicated safe shutdown.
The licensee can be requested to demonstrate the adequacy of the alternative shutdown procedures by "walking through" the procedural :.teps, h.
Verify, on a sample basis, that installation of necessary fire detectors and automa tic fire suppression systems required by Section III.G.3 of Appendix R is as described in hRR SERs and their supplements or other applicable licensing documents.
In addition, verify that the installation of automatic suppression systems would adequately suppress fires associated with the hazards of the areas. R 02.03 Section III.J., Emergency Lighting a.
Verify that the plant emergency lighting capabilities meet the following requirements of Section !!!.J. of Appendix R.
1.
Required Areas for Emergency Lightirc (a) control room, (b) other critical area (s) and access routes which require illumination to allow manual safe shutdown equiptrent operation or the nonitoring of safe shutdown indications.
2.
If the cmergency lights are powered from a central battery or batteries, then the distribution system must contain srch protective devices that a fire in one area will not cause a less of emergency lighting in any unaffected area needed for safe shutdown operaticns.
3.
Review the manufacturer's informatian to verify that battery power supplies are rated with at least an 8-hour capacity.
b.
In addition to the regulatory requirements of Ill.J. the following areas should be reviewed:
1.
Tour the plant and inspect the emergency lights installed in areas required for post-fire shutdown and, in the access routes to those areas. Verify the following:
Issue Date: 64100
(a) the lamps are properly aimed (b) the batteries are being properly maintained including:
charge rate indication (lamp or meter) specific gravity indication is within specification.
(c) sufficient illumination is provided to permit access for the monitoring of safe shutdown indications and/or the proper operation of safe shutdown equipment.
2.
Review the manufacturer's information to determine the periodic maintenance recommendations.
3.
Review the preventive maintenance surveillance procedure used for periodic checks of the emergen;y lights and verify that the maintenance frequencies and procedures are as specified by the manufacturar.
4.
Request that the licensee perform dn emergency lighting test for selected plant areas.
"erify that the criteria of 02.03.b.1 above are satisfied.
02.02 Section III.0, Oil Collection Systems for Reactor Coolant pumps a.
Review the drawings for the oil collection system to verify that all R potential leakage points in the reactor coolant pump oil system have R been contained and the drain line(s) have been sized to accommodate R the maximum leak rate.
R b.
Verify that the oil collection :yttem components have been designed so that there is reasonable assurance that they would withstand the safe shutdown earthquake (see Section 111.0 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 i
tank vent has a flame arrestor installed.
i d.
Verify that the licensee has a surveillance procedure for the oil l
collection system and has implemented the procedure.
The following should be included in the procedure, i
1 1.
periodic testing of the remote level indication (if installed) 2.
peiiodic visual exsmination of the oil collection system piping and tank.
e.
Verify that the collection tank is a closed, vented tank and has sufficient capacity to simultaneously collect all the oil from all
)
reactor coolar.t pumps (upper and lower lube oil syttem), or suffi-cient capacity to collect the oil from cne reactor ccolant pump and that overflow is directed to a location which does not present a fire hazard.
For the latter case, refer to applicable SERs for the specific configuration required.
f.
Inspect the reactor coolant pump oil collectint syL tea to verify 64100 'ssue Date:
that it was installed as indicated by the drawings. If seismically R designed, verify all piping is seismically supported.
64100-03 INSPECTION GUIDANCE 03.01 General Guidance a.
Requirements for Reactor Plants Licensed Before January 1, 1979.
Effective February 17, 1981, the huclear Regulatory Comission amended its regulations by aading Part 50.48 and Appendix R to 10 CFR 50 to require certain provisions for fire protection in nuclear power plants licensed to operate before 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 te a level of protection equivalent to the technical requirements of Sections Ill.G., J.
L, 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 capsbility requirements of Sections Ill.G.3. and Ill.L., or request an exemption in accordance with 10 CFR 50.48. Alternative or dedicated safe shutdown capabili-R ties twhich did not pre-date 10 CFR 50.48 and Appendix R) were R required in 10 CFR 50.48(c)(5) to be submitted to NRR for review. R NRR approvals are documented in Safety Evaluation Reports.
R b.
Requirements for Reactor Plants Licensed after January 1, 1979.
Plants licensed af ter 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 60.48 (a) and (e) only.
The Fire Hazards /.nalysis (FHA) (Fire Protection Review, Fire Pro-tection Evaluation) document of the post-79 reactor plants may have 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 comparison and justified FSAR or FHA differences from specific provisions of Appendix R).
It is also possible that post-79 licensee submittals were reviewed under Standard Review Plan h0 REG-0800 and Branch Technical Position CMEP 9.5-1 (formerly BTP ASB 9.5-1) "Guidelines for Fire Protection for Nuclear Power Plants," Rev. 2 of Julv 1981 (in which case, licensee submittals were reviewed against requirements which closely paralleled the provisions of Append u R).
i The actual fire protection requirements applicable to a given reactor plant licensed af ter January 1,1979 arise from the pecific license conditions in the Facility Operating License.
These li-cense conditions refer to 3ERs and their supplements.
Section 9.5 i
of the SER will delineate which licensee sut,mittals were reviewed (e.g., a Fire Hazard:, Analysis vould' be such a submittal).
The plant configurations and procedures described in these submittals are "requirements of the license."
Answers to questions raised in the SER review process would be termed "licensir.g comi tment s. "
These "licensing commitments" are "requirements of the license" Issue Date: 64100
if referenced by or appended to SERs which are, in turn, referer.ced within the Facility Operating License.
c.
Types of Post-fire Safe shutdown Inspections R
1.
Initial Validation.
Post-fire sa fe shutdown capability is typically verified during a one-time initial validation inspec-tion of a reactor plant's procedures, physical configuration and supporting documentation.
It should be noted that for near term operating licenses, the inspection is normally conducted prior to the granting of a full-power operating license.
2.
Revisit.
It is not always possible to fully verify a reactor plant's post-fire safe shutdown capabilities during the initial validation inspection.
A second, more i.arrowly focused inspec-tion may be required. At this later time, outstanding technical issues may have been resolved or more complete infonnation may have become available.
The final determination of the reactor plant's post-fire safe shutdown capability would then be possi-ble.
3.
Interim Compensatory Measures.
To ensure adequate levels of afety during long perloos of post-fire safe shutdown design, procurement and implementation activity, it may be appropriate to determine whether interim compensatory measures 6re ade-quately implemented.
The end product of an interim compensa-tory measures inspection would be a determination that the reactor plant can be safety shutdown, although permanent post-fire safe shutdown procedures and physical barriers are not in place.
4.
Conceptual Review.
It is hRC policy that regions are to inspect reactor plants whare post-fire safe shutdown implementation problems are believed to exist.
Another reason for inspecting a reactor plant "in process" nay be a request by the licensee for o review of its design or implementation decisions.
In both cases, costly design or implementation errors and associ-ated delays in achieving permanent post-fire safe shutdown capability may be avoided, l
5.
Full Reinspection.
Subsequent to an' initial validation inspec-tion or a revisit, a region may determine that a licensee has essentially failed to provide the capability to conduct a controlled, successful post-fire safe shutdown.
Such failed l
inspections will be followed by a full reinspection when the licensee has conducted the 1ecessary post-inspection reanalyses, design, procurement and implementu ion activities. Power opera-tion prior to the full reinspection would be conducted with appropriate interim compensatory measures in effect.
6.
Periodic Reverification. A reactor plant's or station's mechan-R 1 cal and electrical configuration and operating procedures are R to be periodically rereviewed to verify that the licensee ros R maintained established post-fire safe shutdown capabilities. R Refer to Appendix A of Manual Chapter 2515 for the required R periodicity. Section 03.01.e.3 of this procedure describes the R activities conducted during a periottic reverification inspection. R 64'00 64100
d.
Inspection Team StructJre 1.
A minimum inspection team consists of the following members:
(a) Team Leader - leads discussion with licensee at entrance and exit interview.
Should be a region-based inspector.
Also participates in inspection effort.
- (b) Mechanical Safe Shutdown Specialist - identifies and exam-ines equipment and cabling necessary to achieve post-fire safe shutdown.
i
- (c) Electrical Saft Shutdown Specialist - identifies and exam-Tnes cabling and circuitry necessary to achieve post-fire safe shutdown and identifies associated circuits of con-cern, the adequacy of these circuit's electrical separa-R tion, isolction, and protective features, and circuit A breaker coordination and fuse protection.
R 1
- (d) Fire Protection Specialist inspects fire protection of the safe chutdown systems, equipment, and circuits.
j l
2.
Inspection experience to date has shown the effectiveness of adding one team member to review the licensee's alternative safe shutdown systems and procedures.
e.
Inspection Plan Preparation and Onsite Inspection Activities This is a technically complex inspection.
Because there are i
many variations in the technical details by which a facility can meet safe shutdown criteria, a site-specific inspection j
plan must be prepared.
See Appendix A for detailed guidance on the preparation of inspection plans.
2.
Certain documents approved and issued during the Spring of 1986 P have a direct effect on inspection plan preparation and onsite R inspection activities: SECY-85-306; SECY-85-306B; and a March R i
7, 1986 memorandum from Samual J. Chilk, Secretary to the Nucle-R ar Regulatory Comission, to Victor Stello, Jr., Acting Execu-R tive Director for Operations. SECY 85-306 directed the issuar.ce R l
of Generic Letter 86-10 of April 24, 1986. These documents were R discussed in detail with regional post-fire safe shutdown in-R spectors during a May 7, 1986 meeting called by the Director, R Division of Inspection Programs, Office of Inspection and R Enforcement.
Minutes at that meeting are contained in an R August 11, 1986 memorandum from Leon E. Whitney, lead Contact R for Fire Protection, DI, IE to Regional Division Directors. R This minutes memorandum provides answers to questions raised by R inspectors during the May 7, 1986 meeting.
R l
- Regions may use inspectors who have the necessary expertise, request assistance from NRR, or use available IE contractors who have the neces-sary expertise.
Issue Date: 64100
Selected inspection related matters arising from Generic Letter R 86-10 are discussed below. However, all the documents listed R above should be read and understood in full by all inspectors R and/or contractors assigned to post-fire safe shutdown inspec-R tion teams.
R
.(3 ) To minimize confusion associated with license conditions R (See Sections 03.01a, and b above) Generic Letter 86-10 R states that each licensee should place its fire protection R program and major comitments (including fire hazard R analyses and Technical Specification requirements) in its R FSAR. The fire protection program would then be subject to R changes under 10 CFR 50.59 without prior NRC approval (as R long as the licensee established that the changes would not R adversely affect the ability to achieve and maintain R post-firesafeshutdown).
k (b) The six "Interpretations of Appendix R," and the "Appendix R R Questions and Answers" of Generic Letter 86-10 provide R guidance as to acceptable methods of satisfying Comission R regulatory requirements. Other methods proposed by licen-R sees for complying with Comission regulations may also oe R satisfactory, and inspectors will consider them on their R own merits. To the extent that the guidance of "Inter-R pretations of Appendix R" and "Appendix R Questions ano R Answers" may be inconsistent with prior guidance (including R Generic Letter 83-33), it is intended that Generic Letter R 86-10 take precedence. Questbns on this matter should be R addressed to the NRC Preject Manager for the facility to be R inspected.
R (c)
Interpretations 4 and 5 of Appendix R refer to post-fire R safe shutdown analyses for fire area boundaries and fire R suppression and detection systems. Section C of Generic R Letter 86-10 provides the necessary features of such R analyses. These analyses are not required to be submitted R as exemption requests, but must be retained for review R dering "NRC audits." However, inspectors should note that R in fire areas for which neither the alternative safe R shutdown features of Section ll!.G 3 of Appendix R, nor the R redundant train separation features of Section !!!.G.2 of R Appendix R are provided, an exemption for Section III.G 2 R is required. This is implied in the wording of Interpreta-R tion 3 ("Licensees seeking exemptions from Section R lll.G.2...")and reiterated in the May 7, 1986 meeting R minutes memorandum.
R (d) Interpretation 6 of Appendix R states that alternative R shutdown equipment may be located in the same fire area as R the normal shutdown equipment for which it is required, as R long as the independent room or zone concept u.ilized is k justified by, detailed fire hazards analysis.
R (e) Appendix R Question and Answer 3.1.1 states that fire bar-R riers established under the BTP process need not neces-E sarily be reanalyzed to meet Apoendix R requirements.
R 64100 Issue Date:
(f) The three assumptions of Appendix R Question and Answer R 5.3.10 are meant for independent use (that is, only one R assumption applies for any given configuration in a reactor R plant).
These assumptions are therefore consistent with R the established NRR review practice of requiring licensees R to analyze for any and all spurious actuations or failures R where no such spurious actuations or failures occur simul-R taneously.
R 3.
Periodic Reverification Inspection Activities. This inspection R is normally conducted in two phases:
R (a) Documents Review and Plant Tour Phase.
The regional in-R spectors familiar with fire protection and safe shutdown R requirements review plant modifications and procedure R changes accomplished since the last inspection conducted R under this procedure (or its predecessor, TI-2515/62). The R inspectors tour areas vital to post-fire safe shutdown. R The inspectors review documentation developed during pre-R vious post-fire safe shutdown inspections. They ascertain R whether changes affecting post-fire safe shutdown capabi-R lity have been routinely incorpo ated into the plant or R station's "Fire Hazards Analysis" and related documenta-R tion, technical specifications, and/or FSAR, as appropri-R ate. They also assess the adequacy of analyses conducted R by the licensee to ensure that the established post-fire R safe shutdown capability is maintained. The inspectors R spend up to one week in this effort and report their find-R ings to regional management.
R (b) Reverification Inspection Phase. Based on the report pro-R video in Section 03.01.e.3(a) above, regional management R determines whether to form a full or partial inspection R team to conduct an in-depth tcchnical review of the effect R of plant modifications and procedure changes on post-fire R safe shutdown capability). The team will be fomed as spec-R ified in Section 03.01(d of this procedure.
R f.
Inspection Credit. A list of inspection procedures for which credit R may be taken is provided below. The listed procedures may or may R not be appropriate depending on whether an operating license hac' R been issued at the time of the inspection. To avoid double account-R ing, inspection hours credited to the listed procedure should be R subtracted from the hours credited to this inspection procedure.
R Procedure Title 37301 Comparison of As-Built Plant to R
FSAR Description R
72701 Start-Up Testing New/ Modified R
37700 Design Changes and Modifications R
37701 Facility Modifications R
41400 Non-Licensed Staff Training R
41701 Licensed Operator Trainir.g R
42700 Plant Procedures R
64704 Fire Protection / Prevention Program R lssue Date: 64100
64100-04 REFERENCES 04.01 Fire Hazard Analysis and related documents prepared by the licensee.
04.02 NRR Fire Protection Safety Evaluation Reports and supplements, and licensee documents referenced therein that constitute the hRR review and approval of the Fire Hazards Analysis of Section 04.01 above,* and, if applicable, portions of the Facility Operating License relating to post-fire safe shutdown. Note that for pre-79 licenses, the redundant train R capability of Section Ill.G.2 of Appendix R is not required to be reviewed. R 04.03 NRR Fire Protection Safety Evaluation Reports and licensee documents referenced therein that constitute the NRR. review and approval of modifica-tions required to satisfy the alternative or dedicated shutdown requirenent of Section Ill.G.3 of Appendix R to 10 CFR 50.*
Note that alternative or R dedicated safe shutdown equipment provided prior to the issuance of 10 CFR R 50.48 and Appendix R need not necessarily be resubmitted to hRR for review R (as long as the licensee determines that the equipment meets the criteria R of Sections Ill.G.3. and Ill.L. of Appendix R). However, any plant modifi-R cation required to upgrade previously provided systems to meet Sections R lli.G.3, and Ill.L. of Appendix R would require submittal to NRR.
R 04.04 Licensee's assessnent of the plant to Sections Ill.G, !!!.J. and 111.0 of Appendix R that identifies redundant safe shutdown systens anc components, defines fire areas, and analyzes the separation of the identi-R fied safe shutdown equipment and their power, control and instrumentation R cables by fire area.
Note:
some of this information is likely to be in-cluded within the Fire Hazards Analysis of Section 04.01 above).
R 04.05 Licensee and NRR corresponcence constituting approved exempticr. re-quests.
04.06 "Shutdown and on the Appendix R Requirement for Time Required to Achieve Cold Shutdown."
04.07 Memorandum from L. S. Rubenstein to R. J. Mattson dated January 7, 1983, "Statement of Staff Position Regarding Source Range Flux, Reactor Coolant Temperature and Steam Generator Pressure Indication to Meet Appen-dix R Alternative Shutdown Capability."
04.08 Licensee analyses generated in response to the IE Information Notice 83-41 dated June 22,1983, "Actuation of Fire Suppression System Causing Inoperability of Safety Related Equipment."
04.09 Generic Letter 83-33 dated October 19, 1983, "NRC Positions on Cer-tain Requirements of Appendix R to 10 CFR 50."
04.10 IE Information Notice 64-09 dated February 13, 1984 and Revision 1 dated March 7,1984, "Lessons Learned from NRC Inspections of Fire Protec-
+ian Safe Shutdown Systems (10 CFR 50 Appendix R)."
- The cates of these itecs may be obtained from the hRR project oanager.
64100 Issue Date:
g
-+
+, -
04.11 Memorandum from L. S. Rubenstein to R. J. Mattson dated December 3, R
1982, "Use of the Automatic Depressurization System (ADS) and Low Pressure R Coolant Injection System (LPCI) to meet Appendix R Alternate Shutdown R Goals."
R 04.12 Generic Letter 81-12 dated February 20, 1981, "Fire Protection Rule (45 FR 76602, November 19,1980).*
04.13 Memorandum from R. J. Mattson to D. G. Eisenhut, March 22, 1982, "Fire Protection Rule-Appendix R," containing clarifications of Generic Letter 81-12.
04.14 Memorandum from V. A. Moore to V. Benaroya, October 11, 1984, "Emer-i gency Lighting Illumination Standards."
04.15 Memorandum from D.
G.
Eisenhut to J. A. Olshinski, February 16, 1984, "Oil Collection System Reactor Coolant Pumps Florida Power and Light Company, St. Lucie Unit 2, Docket No. 50-389."
{
04.16 IE Information hotice 83-41, "Actuation of Fire Suppression Systen, R Causing inoperability of Safety Related Equipment," dated June 22, 1983. R 04.17 IE Information Notice 85-85," Systems Interaction Event resulting in R Reactor System Safety Relief Valve Opening Following a Fire-protection R Deluge System Malfunctier.," dated October 31, 1985.
R 04.18 SECY-85-306 dated September 17, 1985; SECY-85-3068 dated December R.
19, 1985; memorandun from Samuel Chilk, Secretary to the Nuclear Regulatory R Connission to Victor Stello Jr., Acting Executive Director for Operations R dated March 7, 1986; and Generic Letter C6 10 "Implementation of Fire Pro-R tection Requirements" dated April 24, 1986.
R 04.19 Memorandun from Leon E. Whitney, Lead Contact for Fire Protection, R DI, IE to Regional Division Directors August 11, 1986, Minutes of May 7 R
1986 Meeting to Discuss the Effect of SECY-85-306, Appendix R Post-Fire R Safe Shutdown."
R l
04.20 Licensee prepared documents Emergency operating procedures for achieving and maintaining post-a.
fire hot shutdown.
(
b.
Emergency operating procedures for achieving post-fire cold shut-
- down, c.
Fire pre-plans for critical areas, if developed.
d.
Results of any tests conducted to verify the capabilities and opera-R bility of post-fire safe shutdown equipment.
R Results of qualification and/or acceptance tests for special fea-e.
tures provided for post-fire safe shutdown.
END Appendix A Issue Date: 64100
APPENDIX A INSPECTION PLAN PREPARATION A.
Equipment Identification.
Develop the following information freni the licensee developed and other plan; specific documents of Section 04:
1.
The equipment, controls and instrumentation required for hot shutdown 2.
The equipment, controls and instrumentation required for cold shutdown 3.
Locations within the plant for which an alternative safe shut-down capability has been provided, and a listing of the alterna-tive equipn.ent provided for these locations 4.
Fire areas that contain power, control or instrumentation cables and/or equipment for both redundant safe shutdown trains 5-Listings of associated circuits of concern and methods identi-R fied for cealing with spurious sign 61s resulting from postulatec R fires R
6.
Provisions for circuit breaker coordination and fuse protection R
~
B.
Redundant Hot Shutdown Equipment Selection.
From the information developed in Section A.1 above, select specific hot shutdown equip-ment, instrumentation and cabling for review.
Selection of one or two components in each functional area should be an adequate sample size. For example:
1.
reactivity control boration pumping or injection equipment 2.
reactor coolant makeup - charging pumps 3.
reactor pressure control - pressurizer heaters 4.
decay heat removal - auxiliary feedwater pumps 5.
Process monitoring instrumentation * - reactor temperature and steam generator level indications.
6.
Support Systems - onsite AC power and its distribution systen,
- See the listings of reference 04.07 64100 A-1 Issue Date:
i
i C.
Inspection of Selected Redundant Hot Shutdown Equipment.
1.
Detemine the routing of redundant hot shutdown equipment and R power, control and instrumentation cables. Both normal and R emergency power sources should be considered.
R 2.
Review the completeness and actual fire rating of barriers k provided in accordance with Section Ill.G.2 of Appendix R.
R l
10 CFR 50.59 analyses conducted by the licensee in the process R of trecting barriers may be reviewed in this effort. Ensure R redundant hot shutdown equipment within the same fire area are R provided with barriers which meet the separation requirements of R Section III.G.2, or that appropriate exemptions have been ap-R proved by NRR.
3.
Review the poss.ible effects of spurious signals from associated R circuits of concern and the necessity for circuit breaker R coordination and fuse protection. Review procedures to detect R and correct spurious operations arising from associated circuits R of concern.
R D.
Inspection of Alternative or Dedicated Hot Shutdown Equipment 1.
NRR review and approval of alternative and dedicated hot shut-R down equipment and procedures is required. SER's documenting R these reviews and approvals should be compared to the actual R configurations established by the licensee.
R 2.
For areas provided with alternative or dedicated hot shutdown R capability, select a sample of systems controlled from backup R control panels or by local operations.
R 3.
Ensure that selected backup control systems and/or locally con-R trolled hot shutdown systems or equipment are independent of the R effects of the postulated fires for which they were provided. R Review power, control and instrumentation cables, potential R spurious signals from associated circuits of concern and circuit R breaker coordination and fuse protection. Review procedures to R detect and correct spurious operations arising from associated R circuits of concern.
R 4.
Verify that selected areas for which alternative or dedicated hot shutdown equipmen; has been provided are protected by fire detection sensors and a fixed fire suppression system.
I 5.
Review selected 10 CFR 50.59 analyses conducted by the licensee R in establishing the alternative or dedicated shutdown systers R and procedures.
R 6.
Alterative or Dedicated Safe Shutdown procedures.
Request that appropriate plant operators conduct a walkthrough of the alter-native or deoicated hot and cold shutdown procedures for fires
!ssue Date:
A-2 64100 l
E.
Cold shutdown Equipment Selection.
From the information developed in Section A.2 above, select specific cold shutdown equipment, instrumentation and cabling for review.
Selection of one or two components in each functional area should be an adequate sample size.
These items, in addition to the equipment required for hot shutdown, are those necessary to achieve cold shutdown.
For exan-ple, for a PWR:
1.
reactor coolant system pressure reduction - auxiliary spray line valve controls 2.
decay heat removal - RHR pump 3.
support systems - onsite power F.
Inspection of Selected Colo Shutdown Equipment Repair Capability 1.
The inspector should note that Section III.G.1.b of Appendix R requires that fire damage to cold shutdown equipment be capable of repair within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
2.
The licensees analyses and/or submittals should clearly identify R which cold shutdown equipmerit could be damaged in a postulated R fire in each fire area.
R 3.
For postulated fires in selected fire areas, assess the accuracy of the licensees listing of cold shutdown equipment damage.
4.
Material required for cold shutdown equipment repair should be demonstrated to be available onsite.
5.
Tne cold shutdown equipment repair procedures should be clearly achievable within the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> limitation of Section F.1 above.
END l
l Issue Date:
A-4 64100 i
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