ML20236V830
| ML20236V830 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 01/31/1998 |
| From: | BROOKHAVEN NATIONAL LABORATORY |
| To: | |
| Shared Package | |
| ML20236V827 | List: |
| References | |
| NUDOCS 9808040230 | |
| Download: ML20236V830 (6) | |
Text
l BROOKHAVEN NATIONAL LABORATORY J
Review and Evaluation of Historical Fire Protection Licensing Basis Related to Fire Areas IX, X, XI, XV, XVII and XVIII at J. A. FitzPatrick Nuclear Power Plant 1
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l January 1998 1
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l Enclosure i
900804023o 900729 PDR ADOCK 05000333 F
BACKGROUND By letter dated October 26,1992, the New York Power Authority (NYPA), licensee of the J. A.
FitzPatrick Nuclear Power Plant, submitted " Safe Shutdown Capability Reassessment 10 CFR Part 50 Appendix R" to the Nuclear Regulatory Commission's Office of Nuclear Reactor Regulation (NRR). This submittal documents the results of NYPA's reassessment of the post fire safe shutdown capability of the J. A. FitzPatrick Nuclear Power Plant. The results of the staff's review of the NYPA submittal were subsequently forwarded to the licensee in a safety evaluation (SE) dated September 5,1995.
As a result ofits review, the staff determined that the licensee's proposed use of low pressure injection systems, as a means of accomplishing the reactor coolant makeup function in the event of fire in plant locations not provided with an alternative shutdown capability, would not satisfy the technical requirements of Appendix R to 10 CFR PART 50. Specifically, the staff concluded that the licensee's proposed shutdown methodology for six fire areas (Fire Areas IX, X, XI, XV, XVII, and XVIII) did not sad fy Section III.G.1 and III.G.2 of the regulation because the proposed approach:
(a) was not capable of maintaining hot-shutdown conditions; (b) would no. assure that process system variables would remain within those predicted for a loss of the normal a.c. power source; and (c) would not maintain the reactor coolant level above the top of the core.
Based on these findings the staff recommended that NYPA either:
(a) ensure the availability of a high pressure injection system (i.e., RCIC or HPCI) as a means of accomplishing the reactor coolant makeup function in the event of fire in these areas,or (b) seek an exemption from the specific regulatory requirements not satisfied by the f
proposed approach.
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In response to the staff's findings, by letter dated January 12,1996, NYPA submitted a request for exemption to allow the use oflow pressure injection systems as a means of accomplishing the reactor coolant make-up shutdown function in Fire Areas IX, X, XI, XV, XVII, and XVIII. Specifically, the licensee requested an exemption from the following sections of Appendix R to 10 CFR 50:
(a)Section III.G.1, to the extent that the proposed approach will not be capable of achieving and maintaining hot shutdown conditions; (b)Section III.L.1, to the extent that the proposed approach is not capable of maintaining reactor coolant process variables within those predicted for a loss of normal a.c. power; and l
(c)Section III.L.2, because the propnsed approach is not capable of maintaining the reactor coolant level above the top of the core.
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At the request of NRR, the NYPA request for exemption from Appendix R to 10 CFR 50, was reviewed by Brookhaven National Laboratory (BNL). Based on our review of the NYPA submittal,it appeared that since the proposed approach was not capable of meeting the functional requirements of Sections III.G.1 and III.G.2 of the regulation,it should be considered as providing an alternative shutdown capability for the areas in question. In this manner, the defense-in-depth philosophy could be assured through NYPA's demonstration of conformance to the fire protection features delineated in Section III.G.3 of the regulation. By letter dated November 27,1996, BNL submitted a request for additional information (RAI) to NRR describing our concerns with NYPA's proposed approach.
Following its review and concurrence, by letter dated December 18,1996, this RAI was forwarded to l
the licensee by NIIR.
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In an effort to resolve concerns described in the RAI, on October 6,1997 the BNL technical specialist participated in a meeting with representatives of the licensee and NRR at NRC Headquarters, l
Rockville, MD. During their presentation, licensee representatives indicated the use oflow-pressure injection systems, as a means of satisfying shutdown system performance criteria of Sections III.G.1 l
and III.G.2, had been previously reviewed and approved by the staff for four of the six fire areas in l
question during the initial fire protection licensing reviews at FitzPatrick. Additionally, the licemee further stated that its recent (1992) re-evaluation for compliance to Appendix R had not resulted in a change in the shutdown methodology developed for these four areas. On this basis, the licensee maintained that use oflow-pressure injection systems as a meens of accomplishing the reactor coolant makeup function, was part of the current FitzPatrick licensing basis for tl.e following four (4) of the six areas being evaluated:
Fire Area IX (Reactor Building East Side, Elevation 272 ft.)- Formerly Fire Zone RBI A; Fire Area X (Reactor Building West Side, Elevation 272 ft.)- Formerly Fire Zone RBIB; Fire Area XVII (Reactor Building East Crescent Area)- Formerly Fire Zone RBIE; and Fire Area XVIII(Reactor Building West Crescent Area)- Formerly Fire Zone RB1W.
At the time of the meeting, documentation sufficient to confirm the validity of the information presented by NYPA was not available for review. As a result, NRR requested BNL to perform an historical evaluation of the fire protection licensing basis for each of the six fire areas being considered. To assist in this review, NYPA agreed to forward copies of all relevant correspondence to the BNL reviewer. This information was received at BNL on December 17,1997.
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EVALUATION Based on our review of the historicallicensing basis contained in the licensee's December 1997 submittal,it appears that as part ofits initial fire protection licensing reviews conducted in the early 1980's, the staff had,in fact, approved the use oflow-pressure injection systems (i.e., Core Spray and LPCI) as a means of satisfying Section III.G in the four plant locations described above. Specifically, to address staff concerne regarding NYPA's evaluation of all fire areas and zones in the Reactor Building, by letter dated July 13,1982, NYPA submitted a report entitled:" Reassessment of Fire Protection Features for Conformance to Appendix R 10 CFR 50" to NRR. By letter dated April 26, 1983 the staff issued its Safety Evaluation (SE) of this NYPA submittal, entitled: " Alternate Safe Shutdown Capability, Modifications and Exemptions to Meet Appendix R of 10 CFR Part 50 - Fire Protection." In its introduction, this SE was found it to state,in part,: "By submitteldatedJuly 13, 1982, the licenseeprovided the descriptions ofthe proposed modifications to the FitzPatrick plant to 2
O meet the requirements ofAppendix R to 10 CFR 50, Season III.G...Our evaluation ofthese modification andadionsfollows " In the subsequent section, the SE describes the systems to be relied on for post fire safe shutdown at FitzPatrick. In paragraph "A" of this section," Systems l
Required for Safe Shutdown," the SE states, in part: " Reactor coolant inventory can be maintained by either the reactor core isolation cooling system (RCIC); the high-pressure coolant in}edion system (HPCI); or the lowpressure coolant in}edion system (LPCI) or the core spray system (CS) in l
conjunction with the automatic depressurization system (ADS)" (emphasis added). The SE does not l
specifically define shutdown methodologies on a fire area basis. Therefore,it must be assumed that the SE considered low-pressure injection systems to be redundant to high pressure systems, and categorically approved the shutdown methodologies described in the licensee's July 13,1982 submittal.
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From a comparison of shutdown methodologies documented in the licensee's 1982 to those contained l
in its 1992 submittal, however, it was not.ed that the licensee had made certain changes from its original submittal. A summary comparison of fire area designations and shutdown methodologies described in licensee's 1982 and 1992 submittals is provided below in Table 1. As indicated in this table, the licensee has changed the shutdown methodology to be used in two of the six fire areas under l
consideration. Specifically, the licensee's 1982 submittalindicates that high pressure injection systems l
would be available in the event of fire in Fire Areas CT-3 (South Cable Tunnel ), SG-1 (Standby Gas Filter Room) and SU-1 (Torus). As part ofits revised analysis (1992 submittal), however, the licensee currently credits the use oflow-pressure injection systems in these areas. With regard to the Torus (Fire Area XV), the NRC has granted exemption from the requirements of Section III.G.2,III.G.3 and III.L. to allow use oflow pressure injections systems in SE's dated July 1,1983 and September 10, 1992. However, neither the South Cable Tunnel (FA XI) or the Standby Gas Filter Room ( SG-1) appear to have any similar exemptions. As part ofits 1992 reanalysis, NYPA has included Fire Ares SG-1 as a fire zone within Fire Area IX. In its earlier (1982) submittal, SG-1 was designated as a separate fire area, and high pressure injection systems were credited for post-fire shutdown.
Therefore, the staff's prior approval oflow-pressure injection systems in the event of fire in fire zone l
RBI A does not appear to bound the licensee's current shutdown methodology for this location.
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1982 1992 Submittel Submittal Reactor Building {
, 'M of thrw Fire Areas (RB-1, SG-1 and Reactor Bulkling comprised of six separate fire '
SU 1)with RB-1 beving Five Fin Zones:
areas. Fin Ane SG-1 considend as Zene within RB Fire Ana IX 1982 Designation Description Makeup Capsbuity 1992 Designation Makeup Capability Credited Cndited SG-1 Seby Cas Futer High Pressure Ane SG-1 redesignated low Pnesure -
Roesa, El 272' (RCIC/HPCT) as " Zone" within FA IX Core Spray - Div A SU-1 Torus High Pressun XV, Torus Low Pressun (RCIC/HPCI)
LPCI-Div A and LPCI Div B CT3 Cable Tunnel 3 High _*ressun XI Low Pnssur<
(South)El 286' (RCIC)
Con Spray Div A South RB-1 Fin Zones RBIE Crescent Ana low Pnesure XVH Low Pnssure East EL 227' ADSrLPCI Div A ADS /LPCI Div A
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RBlW Crescent Ane low Pressure XVH1 low Pressure West ADS /LPCI-Div B ADS /LPCI Div B El 227' RBIA E1272' East; le w Pressure IX Low Pnesure El 300' SE ADS'LPCI-Div A Con Sprey - Div A Entire El326' thru El 369' 4
RBIB E1272' West Low Pressun X
Low Pnssure El 300' SW ADS'LPCI Div B Core Spray - Div B RBIC El 300' NE High Pressun VIII High Pressure El300 NW RCIC RCIC Table 1: Comparison of RB Fire Area Designations and Shutdown Methodologies l
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9 CONCLUSIONS Based on a review of historical licensing documents related to the fire protection features provided for Fire Areas IX, X, XI, XV, XVII, and XVIII,it appears that the use oflow pressure injection systems as a means of satisfying the post-fire safe shutdown performance criteria of Section III.G of the regulation, has been previously reviewed and approved by the staffin the event of fire in Fire Area X, I
l XV, XVII, and XVill. As described below, however, the staffs prior approvals do not appear applicable for Fire Areas IX and XI.
Fire Areas X. XVII and XVIII Based on the above evaluation,it appears that while the licensee has changed the designations used for these areas from those presented in its 1982 submittal, the post-fire safe shutdown methodology has not changed from those which were reviewed and approved by the staffin its SE dated April 26,1983.
l Therefore, the use oflow-pressure injection systems as a means of satisfying the safe shutdown criteria of Sections III.G.1 and III.G.2 of Appendix R to 10 CFR 50 appears to within the licensee's current licersing basis for Fire Areas X, XVII and XVIII.
Torus Fire Area XV In SE's dated July 1,1983 and September 10,1992, the staff has granted exemption from the requirements of Section III.G.2,III.G.3 and III.L. to allow use oflow pressure injections systems.
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l Fire Area IX As a result ofits 1992 reanalysis NYPA has reconfigure this fire area to include a formerly independent fire area (Fire Area SG-1) as a " zone" within fire this area. Since high pressure injection systems were previously credited for shutdown in the event of fire in SG-1,it does not appear that the staffs prior approval of the use oflow-pressure injection systems in RBI A adequately bounds the current plant configuration. Therefore,it appears that NYPA should either seek an exemption from Sections III.G.1,III.G.2 and III.L to allow their use in this fire area, or designate the area as an area l
requiring an alternative shutdown capability, and demonstrate conformance to the fire safety features of Section III.G.3.
Fire Ares XI. South Cable Tunnel Prior staff approvals of the use oflow-pressure injection systems in Fire Areas IX, X, XVII and XVIII l
do not bound this fire area. Therefore,it appears that NYPA should either seek an exemption from l
Sections III.G.1,III.G.2 and III.L to allow their use in this fire area or designate the area as an areas requiring an alternative shutdown capability and demonstrate conformance to the fire safety features of Section III.G.3.
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