ML050380473

E-mail from K. Sullivan to C. Smith; Hatch Question - Multiple Circuit Faults

ML050380473
Person / Time
Site:	Hatch
Issue date:	12/10/2003
From:	Sullivan K Brookhaven National Lab (BNL)
To:	Casey Smith NRC/RGN-II/DRS/EB
References
FOIA/PA-2004-0277
Download: ML050380473 (3)

Text

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I Caswell SrnJth lL CA

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From: 'Sullivan, Kenneth* <ks@bnl.gov>

To: "'CFS1@nrc.gov'" <CFSI @nrc.gov>

Subject:

Hatch Question - multiple circuit faults Date: Wed, 10 Dec 2003 11:18:45 -0500 MIME-Version: 1.0 X-Mailer Internet Mail Service (5.5.2657.72)

Content-Type: text/plain; charset="Iso-8859-l" X-BNL-MaiIScanner Found to be clean Caswell To my knowledge, the Hatch Licensing Basis does not EXPLICITLY endorse the assumption that only one fire induced failure will occur as a result of fire damage. If the licensee is making this claim I would ask to see the SE.

Per industry's own (NEI) inspection guidance, the SE must EXPLICITLY approve such assumptions for them to be considered part of the licensing basis.

During the inspection we had a discussion regarding multiple spurious actuations ...At that time licensing reps used words like "GL 86-10 is part of our licensing basis...based on our interpretation of GL 86-10 Q 5.3.10 we only need to assume one spurious actuation per fire event' I remember pointing out to the licensee that 0 5.3.10 is only applicable to alternative shutdown capabilities (Not III.G.2 Areas) - Just read the question....it clearly states 'when considering the design of alternative shutdown..." Q 5.3.10 is an alternative shutdown design criterion (i.e.,, the ASD capability must be capable of mitigating one worst case spurious actuation -

prior to isolation of circuits at the remote SD panel) IT IS NOT A FIRE DAMAGE/CIRCUIT ANALYSIS CRITERION. Over 1600 cables were damaged at Browns Ferry...what basis would the staff have to endorse an assumtion of a single failure due to fire?

Such an assuption is inconsistent with the Hatch SSAR. For Example:

Section 0

Introduction:

An analysis of each fire area was done to assure that the plant could be shut down safely using path 1, 2, or 3 equipment, assuming a fire in that fire area and loss of all equipment and circuits in the fire

F . - ._ _ I II t'--11ii Cry4h - MAim, %A99 IlQVV 5 *1 El - 15155 I l % Paqu z area. If a circuit in that area was required to remain functional, it had to be either re-routed out of the fire area, have a fire rated enclosure added around the affected raceways within the area and the enclosed portion changed to an opposite shutdown path area, have a manual action to offset the loss of the circuits, or have an exemption to Appendix R requested.

0.1.5 ANALYSIS BY FIRE AREA For a postulated fire in each area, all fire-induced circuit faults (hot shorts between multiple conductors within a single cable, open circuits, and shorts to ground) and their effects on the safe shutdown equipment identified in [the Safe Shutdown Equipment List] were determined I can come up with more examples if needed Ken

! =_, .,-.

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Subject:

RE: Hatch Question - multiple circuit faults Creation Date: Thu, Dec 11, 2003 10:46 AM From: "Sullivan, Kenneth" <ksgbnl.gov>

Created By: ks~bnl.gov Recipients nrc.gov ATL PO.ATL DO CFS I (Caswll Smith)

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