ML20207D125
Text
L. L 5pead
'c,
[
-4
..c'i
.)
UNITED STATES NUCLE AR REGULATORY COMMISSION hhC N-W ASHNGToN. o. C. 20555 C
- c. l 3' .....v '
e _
AUG 171382 I? M W '- Q :,!
s FCA.
Thomas T. Martin, Director l-- Division of Engineering and Technical Programs, Region I
.. I John A. Olshinski, Director 1-~~~$
, . T ', , _ __ , . Division of Engineering and Technical Programs, Region II Charles E. Norelius, Director
~ ~ ~ '
c/h7 t' ' ~~~3~
" ~d Division of Engineering and Technical Programs, Region III
_ , .,_ ___ . James E. Gagliardo, Director
"' ~ M
'f . _ _ . _ _
Division of Resident, Reactor Project and Engineering "j - , '~ ~ , ~ M ' ~Jesse D _Programs,
.' Crews, L.
Region IV Director g Division of Resident, Reactor Project, and Engineering
- J7(,:{~~g
. ). p '
Programs, Region V j ' M' 5
FROM: James M. Taylor, Director h .
Division of Reactor Programs s Office of Inspection and Enforcement
SUBJECT:
10 CFR 50 APPENDIX R Enclosed is a July 2, 1982 memorandum from R. J. Mattson, Director, Division of Systems ' Integration, Office of Nuclear Reactor Regulation (NRR) to R. .
61Tme , Director, Division of Engineering, NRR. This memorandum is f ga r - ' or your information. The provisions of this memorandum are being consi~dered in conjuncti~ o n with our develooment of inspection procedures for fire protection backfit requirements.
A anie s i.
o$ Director D4' vision of eactor Programs V0ffice of Inspection and Enforcement
Enclosure:
Memcrandum from R. J. Mattson to R. H. Volmer, dated July 2, 1982 cc: R. W. Starostecki, RI R. C. Lewis, RII l R. L. Spessard, RIII / g R. C. DeYoung, IE E. L. Jordan, IE
\ N
CLGACT: J. Stone, IE (49-29656) pyyt Y13 J. Kearney, IE (49-29679) 8808150263 880705 , o t Of ,
& .)
d,s j' H '. . q'C, UNITED STATES j' '
~
[. , , :. .i NUCLE AR REGULATORY COMMISSION WASHINGTON, D. C. 20555
( 'J
- ,' ~ . . l t 4
,C
.Jjl 2 F32 MEMORANDUM FOR: Richard H. Vollmer, Director, Division of Engineerini; FROM: Roger J. Mattson, Director, Division of Systems Integration
SUBJECT:
POSITION STATEMENT ON ALLOWABLE REPAIRS FOR ALTERNATIVE SHUTDOWN'AND ON THE APPENDIX R REQUIREMENT FOR TIME REQUIRED TO ACHIEVE COLD SHUTDOWN -
Some licensees have experienced difficulties in interpreting two areas of Sections III.G and III.L. The purpose of this memorandum.is to infore you of these two areas and interpretations wh.ich we believe are needed. These
- interpretations pertain to the (1) allowable repairs to achieve safe shutdown e s and (2) . allowable time to achieve safe shutdown. The interpretations which follow are not new. We request your concurrence in this matter.
Allowable Recairs to Achieve Safe Shutdown Section III.G.1 of Appendix R s'.at'es that one train of systems needed for hot shutdown must be free of fire damage. Thus, one train of systems needed for hot shutdown must be operable during and following a fire. Operability of the hot shutdown systems, including the ability to overcome a fire or fire suppressant induced maloperation of hot shutdown equipment and the plant's power distribution system, must exist without repairs. Manual operation of valves, switches and circuit breakers is allowed to operate equipment and ,
isolate systems and is not considered a repair. However, the removal o^f. fuses ,
for isolation i s not permitted. All manual operations must be achievable prior to the fire or fire suppressant induced maloperations reaching an unre-coverable plant condition.
Modifications, e.g., wiring changes, are allowed to systems and/or components not used for het shutdown, but whose fire or fire suppressant induced malopera-tions may indirectly affect hot shutdown. These repairs must be achievable prior to the maloperations causing an unrecoverable plant condition.
Repairs for cold shutdown systems are allowed by Section III.L.S of Appendix R. For cold shutdown capability repairs, the removal of fuses for isolation and the replacement of cabling is permitted. Also, selected equipment replace-ment, c.g., such as replacing a valve, pump, control room controls and instru-ments, will be reviewed on a case-by-case basis to verify its practicality within the appropriate time constraints. Procedures for repairing damaged equipment should be prepared in advance with replacement equipment (i.e., cables
Contact:
G. Harrison, DSI:ASB X-27970
i Richard H. Vollmer ' '
JUL 2 1932 made-up with terminal lugs attached) stored onsite. All repairs should be of sufficient quality to assure 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 will have to demon-strate that sufficient time is available to allow the area to be re-entered and
, that expected fire and fire suppressant damage will not prevent the repair from taking place and that repair procedure will not endanger operating systems. In addition, wr.itten procedures must exist for the orderly transfer of control from the control room and the remote shutdown stations and vice versa. The repairs to cold shutdown spams are considered to be an upper limit. The licensee may design the plant so that cold shutdown can be achieved without repair.
[, Allowable Time to Achieve Safe Shutdown Section III.G of Appendix R states that fire damage to cold shutdown capability must be limited to damagei that can be repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.Section III.L.1 i of Appendix R states that the alternative shutdown capability shall be able to achieve cold shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Further Section III.L.5 of Appendix R states that fire damage shall be limited so that the systems can be made operable i and cold shutdown achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Sections III.L.1 and III.L.5 state that a plant must be capable of achieving cold shutdown using only onsite power prior to the elapse of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.Section III.L.5 also clearly states that off- ;
site power is assumed restored after 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in that equipment and systems not '
needed until 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> may be powered by offsite power only.
We have been using and propose to continue to use Sections III.L 1 and III.L.5' '
in our evaluations. Thus, a licensee should have the capability of repairing equipment and achieving cold shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> using only onsite power. ;
The 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is considered an upper limit; a licensee may limit the repairs and achieve cold shutdown in a shorter time frame. '
We have applied the interpretations of Sections III.L.1 and III.L.5 of Appendix R to approximately twenty plant fire protection reviews. We propose to continue to use the interpretations discussed above for future alternative shutdown re-views. If you agree, then please indicate your concurrence at the bottom of this page and return to me.
Roger J. ttson,k Director Division of Systems Integration Approved: _
~
/ Richard H. Vollmer, Director Division of Engineering cc: See next page.
\
. i
, i, .
Richard H. Vollmer I cc: L. Rubenstein ,
O. Parr V. Panciera - -
W. Johnston V. Benaroya ' -
R. Ferguson i I
T. Wambach .
- N. Fioravante G. Harrison J. Taylor .
W. Shields J. Stone, I&E
- 5. Trubatch ..- .
T. Sullivan . .
H. Denton ~ '
!3 '
E. Case '
O. Eisenhut '
S. Hanauer H. Thompson
- e 4 g O S i
',h*
I e
- i i ,
1 I
l 1
1
! . 1 l
\