ML20151H932
| ML20151H932 | |
| Person / Time | |
|---|---|
| Issue date: | 12/15/1983 |
| From: | Mckee P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20151H089 | List:
|
| References | |
| FOIA-88-92 NUDOCS 8312230107 | |
| Download: ML20151H932 (6) | |
Text
()) i / f . 7 W I
.A aaog'o,, UNITED STATES
! n NUCLEAR REGULATORY. COMMISSION
,h I WASHINGTO N,'D. C. 20555 t- DEC 1 b 1983
[*'.". . . #
' . - .: 20 AIO : 01 MEMORANDUM FOR: Those on Attached List ,
FROM: Phillip F. McKee, Chief Operating Reactor Programs B' ranch Division of Quality Assurance, Safeguards, and Inspection Programs Office of Inspection and Enforcement
SUBJECT:
MINUTES OF NOVEMBER 15, 1983 MEETING TO DISCUSS FIRE PROTECTION OF SAFE SHUTDOWN CAPABILITY (10 CFR 50, APPENDIX R, PARAGRAPH III.G.)
Ecclosed please find an agenda, a list of attendees and meeting minutes fo'r the meeting to Discuss Fire Protection of Safe Shutdown Japability held in Bethesda, Maryland on November 15, 1983. Action items resulting from this meeting are as noted in the meeting minutes. -
[
, [ts Phillip F. McKee, Chief Operating Reactor Programs Branch Division of Quali.ty Assurance, Safeguards, and Inspection Programs Office of Inspection and Entorcement CONTACT: Leon Whitney, IE (49-29668) l l
l xr o gy %/ v '
'! . . Wl'/\
6 l
, - 2-List of Attendees Attendees Oraanization William J. Dircks* EDO Victor Stello DEDO, ROGR, EDO James H. Sniezek D. R0GR, EDO William F. Kane EDO William D. Travers EDO Richard C. DeYoung* D, IE James M. Taylor DD, IE James G. Partlow DQASIP,IE Phillip F. McKee ORPB, IE Leon E. Whitney IE Jane A. Axelrad ES, IE !
Edson G. Case DD, NRR Richard H. Vollmer J
, DE NRR j Victor Benaroya CHEB, NRR i Robert L. Ferguson tHEB,NRR .
Thomas V. Wambach ORES, NRR j Nicholas E. Fiorvante ASB, NRR j James Lieberman R0ED, ELD - 1 William M. Shields El.D Karen D. Cyr .
ELD Thomas E. Murley RARI !
Stewart D. Ebneter EPB, RI l
Clifford Anderson RI :
John Olshinski DEOP, RII !
Thomas E. Conlan RII I William H. Miller [ RII l James G. Keppler RA, RIII l R. Lee Spessard DE, RIII '
William S. Little DE, 82, RIII John T. Collins RA, RIV Thomas F. Westerman E0, RIV Michael E. Murphy -
RIV Raymond P. Mullikin RIV John B. Martin RA, RV .
l Jesse Crews DRRPE, RV j
- Partial Attendence !
1 I
l
. , , - r .- c - - -c,--_ -- ,- - , - , , , ---,-----3
,y- , y- - -- - - +
. I, Agenda for Meetin Shutdown Cacability (g10to Discuss.
CFR Fire Protection 50, Appendix R, Paragraph of Safe III.G)
I. Licensing Requirements (NRR)
A. Clarity of Requirements - Why some Licensees are not Analyzing /
Applying Rule ,
B. Application of Requirements ,
- 1. To Plants Licensed Prior to 1/1/79
- 2. To Plants Licent.ed after 1/1/79 .
C. Level of Review by NRR D. Consistency in Approving Exemptions II. Inspection Results (IE)
As Findings to Date and Their Meaning B. Information Notice and Commission Information Papey on Findings C. Approach to Future Inspections III. Enforcement (IE) ;_-
A. Enforcement Approach for 6 Facilities Inspected B. Future Enforcement Approach e
e G
\
Fire Protection of Safe Shutdown Capability Meeting November 15, 1982 Minutes The purpose of the meeting was to discuss the implications resulting fram the fire protection safe shutdown inspections conducted to date. It was stated that the inspection findings so far at 6 reactor plants indicate serious problems in licensee management implementation of the requirements of fire protection of safe shutdown (10 CFR, Appendix 't,Section III.G). It was stated that the criteria for selection of plar.ts as ready for inspection might have led to the first inspections being done at plants that had not done sufficient analyses and modifications to meet Appendix R requirements. However, several categories of the findings (and licensee response to findings) indicate potential general problems with licensee understanding of aspects of the rule.
The meeting discussions then focused on:
- 1. Clarity of Appendix R (with emphasis on Section III.G requirements)
- 2. Future inspection approach and site visit selection criteria
- 3. Enforcement approach Points raised during the discussion were:
There still appears to be considerable confusion among licensee's .
regarding the scope and deptn of reanalyses (beyond the previous BTP requirements) required with respect to Appendix R. It was stated that the requirement for licensee reanalysis was not explicitly stated in the rule, but NRR generic correspondence clearly indicated the need for reanalysis.
Based on the inspections so far, licenses confusion was particularly apparent in the following areas:
- 1. Definition of fire zones and fire areas
- 2. 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> repair capability requirements for cold shutdown
- 3. Applicability of Appendix R,Section III.L
- 4. Possible ambiguity of oil collection tank sizing requirements -
. 1
)
L
. The lack of licensees reanalyses has caused confusion during each inspection with respect to identification of safe shutdown systems and, when required, alternative systems.
It was stated that with respect to individual findings during an inspection, imediate attention should be given to resolving resultant significant safety issues.
- It was stated that degree of licensee management effort, along with the safety significance' of individual findings, has been, and should be, a major factor in determining the level of enforcement action.
For facilities that may have extended schedules for completing modifications with respect to Appendix R, it was suggested that interim compensatory measures might be imposed. Also, there may be a need for inspection of these interim compensatory measures.
The following decisions were reached:
guidance letter or notice to pre-1979 licensees will be developed and issued which discusses specific post-fire safe shutdown inspection findings and the background information which could ha/e been utilized in avoiding the items of noncompliance. The guidance letter or notice
, will be jointly prepared by NRR and IE and not contain new interpretations, but will use a lessons learned approach. The Regions will provide Anput for use in the letter or notice.
The draft Commission Information Paper curreptly out for coment is cancelled. Once the above clarification information has been developed, a Comission Paper will be developed that discusses the results of the inspections to date and include, as an attachment, the guidance letter or notice. ,,
The Regions and NRR will work closely to ensure co'nsistent NTOL Fire Protection comitments, including Regional participation on NRR NT0L Audits.
1 ELD will research the applicability of Appendix R.Section III.L. as a requirement for pre-1979 Licensees.
Inspections should continue using the present inspection readiness criteria. The Regions and NRR will provide input to DQASIP, IE on possible expansion of inspection readiness criteria for pre-1979 licensees. In general, it was agreed that inspection readiness criteria might be expanded to include several plants which have received long term schedular exemptions. These additional inspections would focus in a detailed manner on the direction of a plant's Appendix R compliance program and the adequacy of interim compensatory measures.
~
The regions will provide input to the Director of the Enforcement Staff, .
IE regarding the proposed enforcement guidance table submitted by Region I.
. Subsequent to the issuance of the guidance letter or notice to the 1.icensee's, HQs will assist the Region in conducting workshops for all pre-1979 licensees. The workshop schedule will be included in the Coninission Information Paper.
4 l
1
.. i
- ^
. .Y 'g ' UNITED STATES p , T. /
b y//} 'V j '.i .
' . hj NUCLEAR REGULATORY COMMISSION
. j g.,(% h/e WASHINGTON, D. C. 20555
%, / December 20, 1983 f
LS05-83-12-029 N-PEPORANDUf! FOR: John A. 01shinski, Director 7// w e [ '
Division of Enoineering and , j Operational Prograns, Region II ,[ '
FROM: Darrell G. Eiienhut, Director Division of Licensing Office of Nuclear Reactor Regulation
SUBJECT:
PHYSICAL INDEPENDENCE OF ELECTRICAL SYSTEMS (TASK INTERFACE AGREEMENT #83-53)
Reference:
Meno to D. Eisenhut, dated 4/13/83 frcn J. 01shinski, Physical Independence of Electrical Systems In the reference memorandum-it was pointed out that several licensees and tU Region il personnel have questioned the need for both 10 CFR 50 Appendix R and Reculatory Guide 1.75 separation requirements. In response to the sub,iect TIA and the reference nemorandum, the following response is provided.
Item (1) of the reference menorandum requested that a staff positicn be established on the minimum separation requirements between all redundant trains and division components.
U As stated in the introduction section of Appendix R, "Because fire may affect safe shutdown systems and because the loss of function of systems used to mitigate the consequences of design basis accidents under post fire conditions does not per se impact public safety, the need to limit fire damage to systems required to achieve and maintain safe shutdown conditions is greater than the need to limi. fire damage to those systems required to mitigate the consequences of design basis accidents. Three levels of fire damage limits are established according to the safety functions of the structure, systems or components. /
Hot Shutdown One train of equipment necessary to achieve hot shutdown...
- rust be maintained free of fire damage by a single fire including an exposure fire Cold Shutdown - Both trains of equipment necessary to achieve cold shutdown may be damaged by a single fire, including an exposure fire, but damage...can be repaired or made operable within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />...
Cesign Basis Accident -
Enth trains of ecuipment necessary for mitigation of consecuences following design besis accidents may be damaged by a single exposure fire."
q l
f
,/ W
~--y nonn jo pl
~ _=
34)
I schn A. 01shinski. Director -
2- December 20, 1983 ,
I t _
Redundar.c systems used to miticate the consequences of other design basis accidents but not necessary for safe shutdown may be lost to a single execsure fire. However, protection shall be provided so that a fire within only one such system will not damage the redundant system. Therefore, the
, separation criteria of Appendix R applies only t, the electrical cabling i needed to support the systens which are used foi safe shutdown. All other redundart Class IE and associated electrical cab.es must at Icast neet the separattun criteria of Regulatory Guide 1.75.
Whereas the more stringent separation requirements of Appendix R for safe shutdown systens are based on exposure fires, the separation requirements o- R.G.1.75 are based on fire initiated by faults and failures internal tt the electrical equipment or circuits only.
In cases, wh;ee the electrical cabling is covered by separation criteria aquired for both cafe shutdown and accident mitigation, the nore stringent criteria of Appendix R apply. Note that compliance with Appendix R may be achicved without separetion of redundant Class 12 cabling by providing alternate or dedicated shutdown capability, however, this does not preclude the minimum reparation requirements of. R.G.1.75 for redundant Class 1E and associated cables used in accident mitigation. Therefore, in response to item (1) of the reference memorardum, the staff considers the separation recuirements of R.G.1.75 ar.d Appendix R of 10 CFR 50 to be comoatible and D estehlish minimun sepa ation requirements of redundant trains and divisional j corponents for different postulated events.
Item 2 of the reference memorandum requests the staff to "establish whether the tire barrier separation requirements of Regulatory Guide 1.75 are included as part of the fire barrier section of the Technical Specifications."
We believe that the design features permitted by R.C. 1.75 whether they be fire barriers or separation distance are physical design features of tha plant and as such are not normally included in the Technical Specificatioris.
while 10 CFR 50.36 does permit design features to be incorW ted into the Technical Srecifications they should he' limited to those of first order of safety importance whose failure represents a significant threat to the health and safety of the public. do nct believe the physical separation barrier ;f R.G. 1.75 represent a irst order of safety importance. More signifi. e m chast
- ire barriers of Appendix R which provide protection aozins' .n. o sure fv ' sffecting redundant safe shutdown capability and as such art t ed in '4 ' i hnical Specifications. Therefore, we do not bel 4ve ' . v. 'c'1 - ' icn barriers of R.G. 1.75 should be included in the L : '
<ons.
/n
~d
.. ._ _ _ .J
a?.
Jebn A 01shirski, Director -
3- December 20, 1983
- t/
We are cresently considering disseminating this infornation as well as respenses to other cuestions and requests from tne Regions for interpretation on generic fire protection issues to all licensees and applicants by neans of a generic letter. Please contact T. Wambach if you have any questions or comments. This response completes T A 83-53.
' f r ua 4 5 rre u. E's t t, i r'ector Division of Licensing .
Office of Nuclear Reactor Regulation cc: T. fiartin, Region I R. Spessard, Region III J. Gagliardo, Region IV T. Bishoc, Region V i
t e
i
.j I
, - - - - - -y c ,- ,- _. . y ,,. -
, , y -c w , , ,% ,--e. ---,.. e- ,--, , . c--.
, l
. , SSINS Ns.: 6835 IN 84-09 )
l UNITED STATES l NUCLEAR REGULATORY COMMISSION i 0FFICE OF INSPECTION AND ENFORCEMENT '
CASHINGTON, D.C. 20555 :
February 13, 1984 l IE INFORMATION NOTICE NO. 84-09: LESSONS LEARNED FROM NRC IMSPECTIONS OF l FIRE PROTECTION SAFE SHUTDOWN SYSTEMS l (10 CFR 50, APPENDIX R) l Addressees:
l All nuclear power reactor facilities holding an operating license (OL) or l construction permit (CP).
Puru se: 1 This Information Notice is provided as guidance for poser reactor facilities l conducting analyses and/or making modifications to implement requirements of l 10 CFR 50, Appendix R. It is expected that licensees will review this infor-mation for applicability to their activities. No specific action or response i is required at this time.
Description of Circumstances:
A rumber of inspections to evaluate licensee implementation of the requiren.tnts of 10 CFR 50, Appendix R have been conducted at power reactor facilities licensed before January 1, 1979. Significant items of noncompliance were found at a number of facilities. As a result of these inspections, the NRC staff has prepared the enclosed Supplemental Guidance on 10 CFR 50 Appendix R Fire Protection Safe Shutdown Requirements.
The staff intends to conduct workshops on fire proteccion safe shutdown require-ments at locations near each of the NRC's five Regional offices during the next twa months. At these workshops, an overM ew of inspection results and associated 1r ons learned will be presented and participants will be provided with the o),,,ortunity to present specifir questions concerning Appendix R requiraments.
Schedules and agenda for the rst i onal workshops will be forwarded to all utilities with nuclea'r projects in the near future.
. i l
^
r.-
^
t ff s !
M- _ f '
/ V L,/
. . -- .- . - - - - . - ~
. IN 84-09 1
Februnry 13, 1984
. - Pass 2 of 2 If you have any questions regarding this matter, please contact the Repional Administrator of the appropriate NRC regional office or this office.
Edward L. Jordan, Director Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement Technical Contacts: L. E. Whitney, IE (301) 492-9668 T. Wambach, NRR (301) 492-7072 Atta'chments:
- 1. Supplemental Guidance on 10 CTR 50 Appendix R Fire Protection Safe Shutdown Requirements
- 2. List of Recently Issued IE Information Notices t
g.
e 9
- e l
l l
l
~
l . . . . IN 84-09 Februa ry 12, 1984 Paso 2 of 2 If you have any questions regarding this matter, please contact the Regional Administrator of the appropriate NRC regional office or this office.
Edward L. Jordan, Director !
Division of Emergency Preparedness and !
Engineering Response '
Office of Inspection and Enforcement i Technical Contacts: L. E. Whitney, IE (301) 492-9668 ,
T. Wambach, NRR (301) 492-7072
~
Attachments:
- 1. Supplemental Guidance on 10 CFR 50 Appendix R Fire Protection Safe Shutdown Requirements
- 2. List of Recently Issued IE Information Notices l
- SEE PREVIOUS CONCURRENCE
- L Ih'itney:Jj *S Richardson *P Mckee *J Partlow *J Taylor IE:DQASIP:0RPB IE:DQASIP:0RPB C:DQASIP:0RPB Act.D:DQASIP DD:IE
. 2/ /84 2/ /84 2/ /84 2/ /84 2/ /84
- R Vollmer .'
- EL Jordan DE:NRR D:DEPER:IE 2/ /34 2/ /84
e - ,
l . , , , Attachment 1 IN 84-09 Fsbrua ry 13, 1984 Page 1 of 9 s
SUPPLEMENTAL GUIDANCE ON 10 CFR 50 APPENDIX R FIRI PROTECTION SAFE SHVfDOWN REQUIREMENTS I. Fire Areas At one facility inspected, the licensee's fire hazards analysis had not established fire areas. Therefore, in the atsence of alternative means for safe shutdown in a separate fire area or approved exemptions, the redundant equipment within the plant was inspected for compliance with the separation requirements of Appendix R,Section III.G.2. Significant items of noncompliance were identified at this facility with respect to separation of redundant trains ef systems and components.
Footnote 3 in 10 CFR 50.48 directs attention to documents which provide basic fire protection guidance for nuclear power plants. One of these documents, j Branch Technical Position Auxiliary Power Conversion System Branch BTP APCSB 1 9.5-1, "Guidelines for Fire Protection for Nuclear Power Plants," for new l plants docketed after July 1, 1976, dated May 1976, defined e fire area as: l that portion of a building or plant that is separated from other areas by boundary fire barriers (walls, floors, or roofs) with any openings or penetrations protected.with seals or closures having ,
a fire resistance rating equal to that of the barrier.
"Supplementary Guidance on Information Needed for Fire Protection Evaluation,"
dated October 21, 1976, requested, as part of the fire hazards analysis, "plan
, and elevation views of the plant that show the plant as divided into distinct fire areas."Section III.G of Appendix R sets forth the requirements for the, fire protection of safe shutdown capability on the basis of fire areas. !
Fire areas should be delineated in each facility's fire hazards analysis.
NRC Generic Letter 83-33, dated October 19, 1983, restates NRC positions on i Appendix R requirteents regarding fire areas and the concept of "fire zones."
]
II. Fire Barrier Testina and Configuration At-some of the facilities inspected, fire barriers (both walls and one-hour firg' barriers) were installed without basis for their fire rating (such as U/L listing or testing conducted by a nationally recognized f asting laboratory for the configuration used in the plant). Fire barriers tailed to meet the requirements of Sectit. III.G.2 of Appendix R aust have t a rating. Beunda ry fire barriers may have previous NRC acceptance documented in a Safety Evaluation Report. Some one-hour enclosures or wraps inspected have not been complete.
Cable wraps which do not extend frca fare barrier to fire barrier cannot con-stitute a one-hour barrier.
. . Attachment 1 IN 84-09 FGbrua ry 13, 1984 Pasc 2 of 9 III. Protection of Equipment Necessary To Achieve Hot Shutdown a At one facility, redundant pressurizer heater control and power cables were separated by a partial horizontal pyrocrete barrier suspended from the overhead.
'At the same facility, two auxiliary feedwater pumps were located adjacent to each other and separated by a partial steel missile shield coated on one side with fire-retardant material. The separation criteria of Appendix R Section III.G.2, were not met in that the coated shield did not meet the definition of a fire barrier of BTP APCSB 9.5-1. No alternative means of feedwater supply was designated.
. At a second facility, redundant pressurizer heater load centers were located within the same cabinet. At a third facility, redundant steamline isolation valve control cables for HPCI and RCIC pumps were located in close proximity witnout a fire rated barrier.
Appe'ndix R,Section III.G.1, requires that fire protection features shall be provided for structures, systems, and components important to safe shatdown.
These features shall be capable of limiting fire damage so that one train of cystems necessary to achieve and maintain a hot shutdown condition from either the control room or emergency control station (s) is free of fire damage.
Sections III.G,2 and III.G.3 specify four alternatives that may be implemented outside of primary containment to assure that one redundant train of equipment, cabling and associated circuits necessary to achieve and maintain hot shutdown remains free of fire damage. The alternatives are:
- 1. Separatien of redundant trains of equipment, cabling, and associated circuits by a three-hour fire barrier. .
- 2. Enclosure of redundant trains of equipment, cabling, and associated circuits by a one-hour fire barrier with fire detection and automatic fire suppression systems installed in the area.
- 3. Separation of redundant trains of equipment, cabling, and associated circuits by a horizontal distance of 20 feet with no intervecing combustibles and with fire detection and automatic fire suppression systems installed in the area. ,
- 4. Installation of alternative or dedicated shutdown capability independent
^ ,of the equipment, cabling, and associated circuits under consideration,
,and installation of fire detection and fixed fire suppression systems in the area containing this alternative or dedicated shutdown capability.
It should be norsd that Sections III.G.2.d, e and f of Appendix R, provide additional optiou: for the separation of redundant trains of equipment and cables within non-inerted containments.
Attachm3nt 1 IN 84-09
. Tobruary 13, 1984 Page 3 of 9 In addition, a licensee may request and receive exemptions from the re'quirements of Appendix R,Section III.G, under the Appendix R review process. Such exemptions should be for configurations and/or procedures that provide an equivalent level of safety to that provided by the four alternatives above.
IV. Licensee's Reassessment for Conformance with Appendix R Problems found during the inspections with respect to providing redundant hot l shutdown capability appear to be indicative of inadequate reassessment of plant configuration by the Itcensees. Also, at each facility inspected, documentation was lacking to provide assurance that a comprehensive associated circuits j analysis had been conducted for all fire areas.
At one facility visited in FY 1983, the inspectors could find no evidence (direct or indirect) that a thorough engineering review had been conducted against the requirements of Appendix R. At most facilities visited, the analyses provided for inspector review were developed prior to the issuance i of Appendix R.
Two letters were sent by NRR to the licensees of plants licensed prior to January 1, 1979. These letters clearly stated the requirement for licensee l reassessment to ensure compliance of Appendix R, Sections III.G, III.J, and l III.0, regardless of previous reviews and approvals by the NRC (e.g. , SERs ,
issued during the BTP APCSB 9.5-1 review process). l A November 24, 1980 letter from the Director, Division of Licensing, Of fice of Nuclear Reactor Regulation, to the above licensees states, in part:
The provisions of Appendix R that are applicable to the fire protection featuu , of your facility can be divided into two categories. The first category consists of those provisions of the Appendix that are required to be backfit in their entirety by the new rule, regardless of whether or not alternatives to the specific requirements of these Sections have been previously approved by the NRC staff. These requirements are set forth it' Sections III.G, Fire Protection of liafe Shutdown Capability; III.J Emergency Lighting; and III.0, Oil Collection Systers for Reactor Coolant Pump. The fire protection features of your facility must satisfy the specific requirements of these three Sections by the dates
'- established by Paragraph 50.48(c), unless an exemption from
, the Appendix R requirements is approved by the Commission.
A Feb'ruary 20, 1981 letter from the Director, Division of Licensing, Office of Nuclear Reactor Regulation, to the above licensees states, in part:
~
Paragraph 50.48(b) of 10 CFR Part 50, which became effective on Feoruary 17, 1981, requires all nuclear plants licensed to operate prior to January 1, 1979 to meet the requirements of
\. .
l l
Attachment I l IN 84-09 l
- February 13, 1984 <
Page 4 of 9 Sections III.G, III.J. and III.0 of Appendix R to 10 CTR Part 50 regardless of any previous approvals by the Nuclear Regulatory Commission (NRC) for alternative design features for those items. This would require each licensee to resssess areas of the plant .. . where redundant trains of systems necessary to achieve and maintain hot shutdown conditions are l located within the same fire area to determine whether the requi*ements of Section III.G.2 of Appendix R are satisfied. If I not the licensee must provide alternative shutdown capability in I conformance with Section III.G.3 or request an exemption if there is some justifiable basis.
The NRC expects that, when a reassessment.has been performed at a facility, a I documented record of this engineering activity would be available within the utility. The availability of documentation of (and personnel familiar with) a licensee's reassessment activities helps to confirm the licensee's methodology I and subsequent implementation of reassessment results. Therefore, this docu- l mentation helps to confirm adequate licensee control of Appendix R reassessment !
activity.
V. Identification of Safe Shutdown Systems and Components At two facilities inspected, redundant systems and components necessary for safe shutdown (within the same fire area) were not listed or otherwise identified in the licensees' fire hazards analysis or associated documentation.
At these facilities, the inspectors used the lists of required safe shutdown systems provided in connection with the alternative shutdown analyses provided by the licensees in their original fire hazards analyses. At one of these facilities, the licensee felt the list used was too restrictive (in that it did not include existing potentially redundant systems). At another facility, the licensee felt that the list used was too broad .(in that the list contained systems that the licensee subsequently reali:ed were not actually necessary for safe shutdown). This situation should not have occurred since identification of required safe shutdown systems for each area of the plant is a logical starting point for reassessment of areas where redundant trains are located.
The systems and equipment needed for post-fire safe shutdown are those systems necessary to perform the shutdown function defined in Section III.L of Appendix R. These functions are reactivity control, reactor coolant makeup, reactor heat, removal, process monitoring, and associated support functions. The acceptance criterion for systems performing these functions is also defined in Secti,on III.L:
During the post-fire shutdown, the reactor coolant systes
. process' variables shall be maintained "ithin those predicted for a loss of norarl a.c. power, and tt e fission product boundary integrity shall not be affected; i.e., there shall be no fuel clad damage, rupture of any primary coolant boandary, or rupture of the containment boundary.
l-Attachment 1 IN 84-09 l
- Fcbruary 13, 1984 l Page 5 of 9 I These guidelines apply to the systems needed to satisfy both Section I1I.G and III.L of Appendix R.
VI. Combustibility of Electrical Cable Insulation At a number of facilities, findings of noncompliance were made because of the presence of insulated electrical cable between redundant trains of equipment necessary for safe shutdown. At one facility, the space between redundant electrical cabling at the internal and external containment electrical penetration j areas was nearly filled with a high density of insulated electrical cabling. j At anothat facility, four redundant trains of pressurizer heater control and/or l power cables were routed in trays in the overhead of one room with numerous other cables and cable trays.
Several comprehensive fla::snability tests conducted by the Electric Power Research Institute (EPRI NP-1200, EPRI EL-1263), Factory Mutual (Contract RP-1165-1), and Sandia National Laboratories (NUREG/CR-2431, among others) have shown that burning cable insulation represents a significant fire hazard. l These tests were conducted on both IEEE-383 qualified and unqualified cable. l While the qualified cable exhibited a tendency to ignite and propagate flame l less rapidly, combustion of grouped cables continued at significant levels. In j particular, grouped vertical cables which are not protected by a fire propagation )
retardant, such as metal tray covers or fire retardant coatings, can result in l rapidly developing fires with high heat release rates.
J Section III.G.2.b of Appendix R requires redundant train "separation... with no intervening combustibles...." The NRC staff position is that insulation of electrical cables, including those which are coated, should be considered as intervening combustibles.
VII. D_etection and Automatic Suppression At one facility, redundant trains of safe shutdown equipment located within the same fire area were found to be separated by at least 20 feet of horizontal empty space (no intervening combustibles). Yet, because no general area automatic fire suppression system was installed, the area was found not to meet the separation requires,ents of Appendix R,Section III.G.
NRC Generic Letter 83-33, dated October 19, 1983, restates detailed NRC positions on Appendix R requirements regarding detection and automatic suppression.
At (nother facility, soine automatic sprinkler systems were not installed in ceiling spaces occupied by obstructions such as ventilatisc equipment, cable trays */ conduit, etc. The effectiveness of these automatic sprinkler systems in extinguishing or suppressing fires in the overhead was therefore compromised.
NFPA 13 soonld be referred to when determining sprinkler arrangement.
i / \
. Attachment 1 1 l .
' IN 86-09
,- Februt ry 13, 1984 i Page 6 of 9 I l
VIII. Applicability of 10 CFR 50, Appendix R, Section III.L a Some of the inspected licensees had not considered Section III.L of Appendix R :
l when attempting to meet Section III.G. The acceptance criteria for Section TII.G.3 are listed in Section III.L. Although 10 CFR 50.48(b) does not )
specifically include Section III.L with Sect >>ns III.G., J, and 0 of Appendix R as a requirement applicable to all power reaccors licensed prior to January 1, 1979, the Appendit, read as a whole, and the Court of Appeals decision on the Appendix, Connecticut Liaht and Power, et al. v. NRC, 673 F2d. 525 (D. C. l Cir.), cert. denied (1982), does mean that Section III.L applies to the alternative I safe shutdown option under Section III.G. ;
IX. Instrumentation Necessary for Alternative Shutdown l 1
At one facility inspected, hot shutdown source range neutron flux monitor-ing, capability could not be provided until approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> subsequent to a postulated fire in the control room. At another facility inspected, no alternative hot shutdown source range neutron flux monitoring capability, cold leg temperature indication, or wide-range hot leg temperature indication was provided.
f ection III.L.1 of Appendix R requires that alternative shutdown capability achieve and maintain suberitical reactivity conditions in the reactor.Section III.L.2 requires provision for direct readings of the process variables necessary to perform and control the reactor shutdown function.
The following lists provide the minimum monitoring capability the NRC staff considers necessary to achieve safe shutdown:
Instrumentation Needed for PVRs
- a. Pressurizer pressure and level.
- b. Reactor coolant hot leg temperature or exit core thermocouples, and cold leg temperature.
- c. Steam generator pressure and level (wide range).
- d. Source range flux monitor. . ,, ,
- e. Diagnostic instrumentation for shutdown systems.(,,/,/M4--W/ %y'
."a. Reactor water'1evel and pressure.
- b. Suppression pool level and temperature.
- 6. Emergency or isolation condenser level.
- d. Diagnostic instrumentation for shutdown systems.
. e. Level indication for all tanks used.
o . 1 l
-Attachment 1 l IN 84-09
- Fcbrua ry 13, 1984 Page 7 of 9 X. Procedures for Alternative Shutdown Capability a l
At some facilities inspected, the alternative shutdown procedures have been deficient. Typical deficiencies identified have been: (1) inaccurately
' identified components, circuit breakers, wires, or terminals; (2) failure to address the effects on alternative shutdown capability of circuitry damage in the fire area; and (3) failure to identify the specific equipment and actions required to achieve cold shutdown. j Section III.L.3 of Appendix R requires that alternative shutdown precedures I be in effect which accommodate post-fire conditions, where offsite power is 1 I
available and where offsite power is not available for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
XI. Fire Protection Features for Cold Shutdown Systems 1 l
During inspection of one facility, the inspectors noted that the two residual j heat removal (RRR) pumps were located in separatt rooms in the Auxiliary '
Building. The wall separating the pumps (and other enclosing walls) had open penetrations. Also, the access doors to the rooms were constructed with non-closing ventilation louvers. Transient combustibles consisting of anti-C clothing, paper tape, etc., were stored on open shelves in the access area !
outside the RHR rooms. Also, the RHR pump power cables were not protected to l preclude the loss of both trains of equipment from a fire in either of the pump rooms or the adjacent access area. Therefore, reasonable assurance was not provided that a single fire would not damage redundant RHR components or cables.
The licensee had not perforced an analysis to determine the limits of RKR system fire damage, the associated onsite repair material storage require- ;
ments, or the time required to complete necessary repairs.
Section III.G.I.b requires that fire protection features for cold shutdown l systems be capable of limiting fire damage so that systems necessary to achieve and maintain cold shutdown from either the control room or emergency control ;
station (s) can be repaired in 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. To setisfy this requirement, the i licensee should have an analysis which supports conclusions that the design )
features provided will limit the fire damage. The requirements for such repairs specified in Section III.L.5 should also be met:
Materials for such repairs shall be readily available on site
' ,and procedures shall be in effect to implement such repairs.
Rereirs for cold shutdown systems are allowed by Section III.L.5 of Appendix R.
For c,old shutdown capability repairs, the removal of fuses for isolation and the replacement of cabling is permitted. Also, selected equipment replacement (e.g. , such as replacing a valve, pump or control room controls and instruments) should be reviewed on a case-by-case basis to verify its practicality. Procedures for repairing damaged equipment should be prepared in advance with replacement l equipment (i.e., cables made up with terminal lugs attached) stored on site in i a controlled manner. All repairs should be of sufficient quality to assure 1
1 l
__ ,- _- . _ - - - - , -. . . - - - _ . - .., -...-.- -. .b
- '6
. J.
Attachment 1 IN 84-09 Februa ry 13, 1984 Page 8 of 9 safe operation until the plant is restored to an operating condition.' Repairs not permitted include the use of clip leads in control panels (which means that hard-wired terminal lugs must be used), and the use of jumper cables other than
,those fastened with terminal lugs.
When repairs are necessary in the fire area, the licensee should demonstrate that sufficient time is available to allow the area to be re-entered, that expected fire and fire suppressant damage will not prevent the repair from taking place, and that the repair procedure will not endanger operating systems.
The licensee may, at his option, modify the plant so that cold shutdown can be achieved without reliance on repairs.
XII. RCP Oil Collection Systems At some facilities, the lube oil collection systems for the reactor coolant pumps were not sized to accept the entire lube oil inventory from all reactor coolant pumps without overflow. This does not protect against the consequences of simultaneous failure of more than one lube oil system during a seismic event.
Section III.0, Oil Collection Systems for Reactor Coolant Pump, is written for a single pump. The collection container is required to hold the entire inventory of the oil system of the pump. It follows that if additional pumps are present they would each be provided full collection capacity. There are usually from 2 to 4 reactor coolant pumps in a platt. The oil inventory of one large pump is approximately 275 gallons. Some licensees have provided several containers connected in parallel for each pump.
The NRC staff position on the capacity of a reactor coolant pump oil collection system which meetsSection III.0 of Appendix R to 10 CFR 50 is:
One or more tanks need to be provided with sufficient capacity to collect the total lube oil inventory from all reactor coolant pumps draining to the container.
- Alternatives which have been found acceptable under the exemption process are
- 1. One or more tank.s need to be provided with sufficient capacity to hold the total lube oil inventory of one reactor coolant pump with margin if the tank (s) is/are located such that any overflow from the tank (s) will be
' , drained to a safe location where the lube oil will not present an exposure
. fire hazard to or oth?rwise endanger safety-related equipment; or
- 2. Nhere the RCP lube oil system is showc, by analysis, to be capable of withstanding the safe shutdown earthquake (SSE) (eliminating the con-sideration of simultaneous lube oil system ruptures from a seismic event),
, protection is required for random leaks at mechanical joints in the lube oil system (e.g. flanges, RTD connections, sightglasses). Alternative methods of protection say bo deemed acceptable for such designs. In RCP lube oil collection systems of suen designs, one or more tanks need to be
-. ., --._.~._,.,.__m.-,_.,-,m.,, ,m._,__,,_,._~ . . , . , , , _ , ._.m. ,~,-,,.,_,,.._.,,.m__,_mm,.-
~ '
Attechnent 1 IN 84-09 Fahruary 13, 1984 Page 9 of 9 provided with sufficient capacity to hold the total lube oil inve'ntory of one reactor coolant pump with margin. Because protection is required only against possible leakage resulting from random leaks from the one pump at a time, any overflow from the tanks need not be considered; or
- 3. For those pumps where the lube oil is contained entirely within the pump casing, an oil collection system may'not be required, provided it can be shown that there are no potentially significant leakage points.
O ge e
e e ,
1 / '
SSINS No.: 6835 IN 84-09, Rsv. 1
~ I UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT WASHINGTOW, D.C. 20$$5 March 7, 1984 IE INFORMATION NOTICE NO. 84-09, REVISION 1: LESSONS LEARNED FROM NRC ;
INSPECTIONS OF FIRE PROTECTION SA.YI SHUTDOWN SYSTEMS (10 CFR 50, !
APPENDIX R) {
l l
Addressees: l All nuclear power reactor facilities holding an operating li ense (OL) or construction permit (CP).
Purpose:
This Information Notice is a revision to IE Information Notice No. 84-09 issued on February 13, 1984. Attachment I to this revision is a replacement page ,
which will accomplish a needed correction to subparagraph 4 of Section III of IE Information Notice 84-09. The revision on page 2 is indicated in comparative text and in the margin to highlight the change. Licensees should add the replacement page 2. No specific action or response is required as a result of this replacement.
If you have any questions regarding this matter, please contact the Regional Administrator of the appropriate NRC regional office or this office.
I l
Edward L. Jordan, Director Division of Emergency Preparedness and Engineering Response ,
Office of Inspection acd Enforcement Technical Contacts: L. E. Whftney. IE (301) 492-9668 T. habach, NRR (301) 492-7072 Attachments:
- 1. Supplemental Guidasce on 10 CFR 50 Appendix R Fire 7
Protection Safe Shutdown Requirements, Replacement page 2
- 2. List. of Recently Issued IE Information Notices V .
, . . SSINS N3.3 6835 IN 84-09, R:v. 1
- - UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENTORCIMENT WASNINGTON, D.C. 20555 March , 1984 IE INFORMATION NOTICE NO. 84-09, REVISION 1
- LESSONS LEARNED FROM NRC INSPECTIONS OF FIRE PROTECTION SAFE SNUTDOWN SYSTEMS (10 CFR 50, APPENDIX R)
Addressees:
All nuclear power reactor facilities holding an operating license (OL) or construction permit (CP).
Pu rpose:
This Inforet*. ion Notice is a revision to IE Information Notice No. 84-09 issued on Februsc. 13, 1984. Attachment t to this revision is a replacement page which wi: .ccomplish a needed correction to subparagraph 4 of Section III of IE Information Notice 84-09. The revision on page 2 is indicated in comparative text and in the margin to highlight the change. Licensees should add the replacement page 2. No specific action or response is required as a result of this replacement.
If you have any questions regarding this matter, please contact the Regional Administrator of the appropriate NRC regional office or this office.
Edward L. Jordan, Director Division of Emergency Preparedness and l
Engineering Response l Office of Inspection and Enforcement l 1
Technical Contacts: L. E. Whitney, IE (301) 492-9668 T. Wambach, NRR
.(301) 492-7072 l
Attachments: l
- 1. Supplemental Guidance on 10 CFR 50 Appendix R Fire Protection Safe Shutdown Requirements, Replacement page 2 l
- 2. List of Recently Issued IE Information Notices l 1
- SEE PREVIOUS CONCURRENCE
- L Whitney:jj *S Richardson *P Mckee *J Partlow *J Taylor IE:DQASIP:0RPB IE:DQASIP:0RPS C:DQASIP:0RPB Act.D:DQASIP DD:IE l 2/ /84 2/ /84 2/ /84 2/ /84 2/ /84
- R Vollmer *JN Grace *EL Jordan DE:NRR D:DQASIP:IE D:DEPER IE 2/ /84 2/ /84 2/ /84 I
l
\
- - . - - - . , - , _ - . . . - _ - - , . , - , - - _ - - . , _ - , ., ,..,, n----,-_,,a. ,,-.w.- - ~- - v--_-,,---n~
.
- Attcchment 1
, IN 84-09, Ray. 1 March , 1984 Page 2 of 9 III. Protection of Equipment Necessary To Achieve Hot Shutdown At one facility, redundant pressurizer heater control and power cables were separated by a partial horirental pyrocrete barrier suspended from the overhead.
At the same facility, two auxiliary feedwater pumps were located adjacent to each other and separated by a partial steel missile shield coated on one side with fire-retardant material. The separation criteria of Appendix R,Section III.G.2, were not met in that the coated shield did not meet the definition of a fire barrier of BTP APCSB 9.5-1. No alternative means of feedwater supply was designated.
At a second facility, redundant pressurizer heater load centers were located within the same cabinet. At a third facility, redundant steamline isolation valve control without a firecables rated for HPCI and RCIC pumps were located in close proximity barrier.
Appendix R,Section III.G.1, requires that fire protection features shall be provided for structures, systems, and components important to safe shutdown.
These features shall be capable of limiting fire damage so that one train of systems necessary to achieve and maintain a hot shutdown condition from either the control room or, emergency control station (s) is free of fire damage.
Sections III.G.2 and III.G.3 specify four alternatives that may be imple.mented cabling and associated circuits necessary to achieve and ma remains free of fire damage. The alternatives are:
1.
Separation of redundant trains of equipment, cabling, and associated circuits by a three-hour fire barrier.
2.
Enclosure of redundant trains of equipment, cabling, and associated circuits by a one-hour fire barrier with fire detection and automatic fire supptession systems insts.11ed in the area.
3.
Separation of redundant trains of equipment, cabling, and associated circuits by a horizontal distance of 20 feet with no intervening corsbustibles and in thewith fire detection and automatic fire suppression systems installed area. l 4.
Installation of alternative or dedicated shutdown capability independent of the equipment, cabling, and associated circuits under consideration, and installation of fire detection and fixed fire suppression systems in the area under containing-this-siternative-er-dediested-shandown-espabilityr consideration.
l R1 It should be noted that Sections III.G.2.d. e and f of Appendix R, provide additional options for the separation of redundant trains of equipment and cables within non-inerted containments.
. gemme a