ML060690159

Memo from W. Johnston, NRR, to T. Novak, NRR, Supplemental Safety Evaluation Report on Fire Protection

ML060690159
Person / Time
Site:	Wolf Creek, Callaway
Issue date:	03/28/1984
From:	Johnston W Division of Engineering
To:	Novak T NRC/NRR/ADES
References
FOIA/PA-2006-0095 NUDOCS 8404160195
Download: ML060690159 (19)

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JAR2 8 1984 r I MEMORANDUM FOR: Thomas M. Novak, Assistant Director for Licensing Division of Licensing FROM: William V. Johnston, Assistant Director Materials, Chemical & Environmental Technology Division of Engineering \

SUBJECT:

SUPPLEMENTAL SAFETY EVALUATION REPORT ON FIRE PROTECTION WOLF CREEK NUCLEAR POWER PLANT, CALLAWAY NUCLEAR POWER PLANT Plant Name: Wolf Creek Nuclear Power Plant/Callaway Nuclear Power Plant Docket Nos.: t% M821481M Licensing Stage: OL Responsible Branch & Project Managers: J. Holonich, P. O'Connor CMEB Reviewer: R. Eberly Requested Completion Date: ASAP Review Status: Complete In our SERS, we stated that there were' six unresolved items. Two of these were concerned with our on-going review of the fire protection for safe shutdown capability and of the alternate shutdown system for the control room.

The enclosed Fire Protection Supplemental Safety'Evaluation Report, prepared by ASB, provides our evaluation of the two safe shutdown items.

Between October 17 and 20, 1983, we conducted our fire protection site audit.

As a result, we reached several agreements with theappllcant concerning the adequacy of the fire protection program. We also expressed a number of concerns pertaining to previous applicant commitments and the degree of compliance with our fire protection criteria. These lssues were delineated Inour trip report of December 21, 1983.

By letters dated February 1,24 and March 14, 1984, and FSAR Revisions.12 & 14, the applicant provided additionallnformation'in response to our concerns.

Based on our evaluation, we conclude that the tire protection proiram with the accepted deviations, meets the guidelines of BTP CMEB 9.5-i, sect ons II.G, III.J, and 111.0 of Appendix R to.10 Cl:R 50, and GOC3.and is,therefore, .

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bUR 2~ 1984 Thomas H. Novak 2 Attached is our evaluation, the protection program, and our SAl.P proposed license condition for the fire input per Office Letter No. 44.

William V. Johnston, Assistant Director Materials, Chemical & Environmental Technology Division of Engineering

Enclosure:

As stated

Contact:

R. Eberly x24302 cc: R. Vollmer D. Eisenhut V. Benaroya Distribution R. Ferguson Docket File T. Wambach CMEB Reading R. Eberly CMEB Plant S. Pawlicki T. Sullivan F. Rosa

0. Parr B. J. Youngblood J. Holonich P. O'Connor M. Srinivadan V. Panclera J. Taylor S. Ebneter, Region I T. Conlon, Region 11 C. Norellus, Region III E. Johnson, Region IV 4 .. . .

D. Kirsch, Region V 9.

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..Chemical Engineering EBranch/Fire Protection Section Supplemental Safety Evaluation Report Wolf!Creek Nuclear Generating Station,

'Callaway Nuclear Power Plant

'Docket Nos. 50-482/483 VI. Fire Protection For Safe Shutdown Capability VIMA Safe Shutdown Capability Our review of the SNUPPS fire protection of safe shutdown capability included the list of equipment and components identified in Section 3.11(B) of the SNUPPS Final Safety Analysis Report (FSAR) as being necessary for hot and/or cold shutdown, the safe cold shutdown analysis in FSAR Section 5.4A, the remote shutdown capability described in FSAR Section 7.4, the cable separation discussed in FSAR Section 8.3 and the fire hazards analysis and design com-parison with Appendix R In FSAR Section 9.5. We also reviewed the control room fire hazards analysis submitted by letter dated November 15, 1982.

The applicant's safe shutdown analysis and fire hazards analysis demonstrated that redundancy exists for systems needed for hot and cold shutdown. The safe shutdown analysis included components, cabling and support equipment needed to achieve hot and cold shutdown. Thus, in the event of a fire any-where in the plant, at least one train of systems would be available to achieve and maintain hot shutdown and proceed to cold shutdown.

For hot shutdown at least one train of the following safe shutdown systems would be available: Auxiliary ftedwater (AFW) system, steam generator atomspheric dump valves, reactor coolant system,.and the chemical and volume control system. For cold shutdown at least one train of the residual heat removal (RHR) system'would be available. The RHR system would be used for long-term decay heat removal and provides the capability to achieve cold shutdown within 72 h furs'Beter a&ire. The vailability of these systems includes the components, cabling and support equipment necessary to achieve cold shutdown. The support equipment lncludes the diesel generators, emergency service water system,"components cooling water system, and the necessary ventilation systems.

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- Do; i, F; The applicant's fire hazards analysis demonstrated that except for inside containment and inside the control room, redundant systems and cabling needed for safe shutdown are separated in accordance with III.G.2.a, b, or c of Appendix R. For the control room, the applicant has provided alternate shutdown capability outside the control room in accordance with III.G.3 of Appendix R.' Inside the containment there is at least 20 feet between redundant safe shutdown divisions or between diverse systems such as the letdown isolation valves and the power operated relief and block-valves. Thus, the requirements of III.G.2.d are met for separation inside containment.

The applicant performed an electrical train separation study in order to ensure that at least one train of the above equipment: is available in the event of a fire in areas which might affect these components. Safe shutdown equipment and cabling was identified and traced through'each fire area from.

the components to the power source. Additional equipment and cabling consiJp-d as associated either because of a shared common power source or common enclio re or whose fire induced spurious operation could affect shutdown were also identified. Extensive use of computer program checks were used to ensure separation. Each circuit and raceway is identified in the computer program, and the identification includes the applicable separation group. The program is used to check that cables of a particular separation group are routed through the appropriate raceways.

We have reviewed the applicant's method of determining that the separation criteria of Appendix R are met and have reviewed the associated circuits identified by the applicant and ,th'actions necessaryor'>modifications made to prevent spurious operation that we iffect safe plant shutdown.

Based on our review we conclude that the app. t has adequately addressed the effects of associated circuit interaction unu /that the necessary isolation devices and procedures areadequate? to ensure that such circuit interactions will not prevent safe shutdown. Wi further conclude that the applicant's methodology for verifying that separation is in accordance with Appendix R, Item III.G.2 is, therefore, tacceptable.

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The applicant's analysis indicated that the only area outside containment where redundant divisions are not separated by barriers in accordance with III.G.2 is the control room. Alternate shutdown measures were required for the control room in order to assure the availability of the safe shutdown systems. In the event that a fire, disables the control room the remote shutdown panel associated with train B equipment located in a separate fire area of the auxiliary building provides an alternative to fire protection separation within the control room. The control functions and indications provided at the remote shutdown panel are electrically isolated or otherwise separate and independent from the c~ontrol room. Refer to Section VI.B of this SER for further discussion of alternate shutdown capability.

Based on the above, the systems identified for achieving and maintaining safe shutdown in the event of a fire are acceptable and the methodology used to assure adequate protection of safe shutdown systems is in accordance with Section III.G of Appendix R and, therefore, is acceptable.

VI.B Alternative Shutdown Capability Section 7.4 of the SNUPPS FSAR describes the remote shutdown panel's capability.

Section 5A of the FSAR and the control room fire hazard analysis dated November 15, 1982, describe remote shutdown capability for equipment'not on the remote shutdown panel. The design objective of the remote shutdown system for the purposes of this evaluation is to achieve and maintain cold shutdown in the event of a fire in the control room. The train B remote shutdown panel will be the primary alternative shutdown panel since the necessary instruments and control on this panel are isolated or isolable from the control room.

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The turbine driven ANW pump, train B motor driven AFW pump, associated AN controls, the atmospheric dump valves for steam generators B and 0, the group B pressurizer backup heaters, mthe and trainB letdown isolation valve can be controlled at the train B alternate shutdown panel for maintaining hot standby. Separate isolation switches provided at local stations for control of support systems and cold shutdown systems will be used in conjunction with a procedural approach using pre-planning operator actions to maintan hot standby and to achieve and maintain cold shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

The design of the remote shutdown system complies with the performance goals outlined in Section II.L of Appendix R. Reactivity control is accomplished by manual scram before the operator leaves the control room and boron addition via the chemical and volume control system using the refueling water stroage tank (RWST) and the charging pumps. The reactor coolant makeup function is also performed by thelcharging pumps and RWST.

Reactor coolant inventory Is assureid byrnaintaining reactor coolant pump seal cooling and seal injection, arnd by isolatingaill possible paths of inventory loss such as PORVs, RHR suction lines, 'normal and excess letdown lines and the reactor vessel head vent. All theseoperations including reactor scram can be accomplished from outside the control room. Reactor decay heat removal to hot shutdown is accomplishod by the AFW system through the steam generators and atmospherics ump valves. Decay heat removal to cold shutdown is achieved by the 'residual heat removal system.

The following Instruments on the alternate shutdown panel will be used to monitor process variables:

Pressurizer level Reactor coolant system pressure (wide rangje)

Steam generator level (wide range)

AFW flow Reactor coolant cold leg temperature,(Tc);

Reactor coolant hot leg temperature'(TH) ',

Source range nuclear instrument  :

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,i t\!'.1'0 The above instrumentation will all be isolated from the control the train B alternate shutdown room on panel.. Isolated valve position for the AFW system, letdown isolation indication valve, and the atmospheric dump valves are also located on the train 8 panel.

We have reviewed actions required by the procedures for achieving maintaining safe plant shutdown and following a fire. For hot standby immediate actions are mainly precautionary the measures to assure no spurious operations occur due to the control room fire. Some operations require cutting a control power cable at the equipment to ensure that the control room does not prevent a fault in certain equipment operation.

may be required for the fuel oil Such actions transfer pumps, fuel pool cooling and some ventilation dampers system that are not immediately necessary detrimental to maintaining hot for or standby conditions. These actions be described in the procedures. will For achieving and maintaining shutdown local operation of RHR cold isolation valvesiletdown valves certain CCW system valves may and be required and will be in the procedures. We have reviewed cold shutdown the proposed actions and manpower and conclude they are in accordance requirements with III.L.4 and II1.L.5 to Appendix since they can be accomplished R exclusive of fire brigade members straighitorward and uncomplicated and are such that cold shutdown can be within tZ beirs achieved Based on our review, we conclude that the alterhativeshutdown for the control capability room meets the requirementsiof Apptndix'RSection 111.1, and is therefore acceptable.

Reactor Coolant Pumps The system is designed to collect and contain lubricatlng coolant pump. The collection Foil for each reactor systems are'piped to two collection tank serves two RCPs. Each collection',tsnk tanks. Each hasa; capacityof. approximately 300 gallons. Each RCP motor contains appr'oximately 2651gallons of olI. The I I , I 11'! I II ,

collection tanks are provided 'with level Indication and high level the control room. alarm In Should the leakage exceed the'col'lection tank capacity before corrective acttons are completed, the tank a wuld overflow onto the containment This oil would not come into conteict sumps.

with hot'surfaces and would not a significant fire hazard, ' pose I

The tanks are constructed to'the requirements ofASME Section flame arrestors on the vents., VIII and have The drain piping is ANSI B31.1.

piping are seismically supported The tanks and in accordance'with tho requirements Paragraph C.2 of Regulatory Guide of 1.29.

By letter dated March 14, 1984, the applicant committed to provide collection system that has been an oil seismically analyzed and qualified functional after the SSE. Based to remain on this commitment, we conclude provided for the reactor coolant that protection pumps will meet the guidelines of BTP CMEB 9.5-1 (Section 111.0 of Section C.7.a of Appendix R to 10 CFR 50), and acceptable. is, therefore, 9.5.1.1 Fire Protection System Description and Evaluation (Wolf Creek Only)

Water Supply System The water supply system consists ofitwo tire pumps -separately connected buried, 12-inch pipe loop aroundithi to a plant.! There, are two 100 percent fire pumps. One pump Is electricm'otordriven capacity and the other Is'diesel engine driven. The fire pumps are located In circulatinglwater screen house electric-ffre pump separated by with the a ire-rated wall from the'diesel fire pump and controllers are Undenmriter'sjLaboratory pump.' The pumps will be installed and tested Listed.. Controllers and ln accordaincewith National Fire Standard (NFPA) 20. Protection

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7-A separate jockey pump maintains the yard fire main pressure. If the fire main pressure drops, the electric motor driven fire pump will automatically start.

The diesel engine driven fire pump will start automatically if the pressure drops to below the settings of the electric pump. Separate audible and visual alarms are provided in the control room for each pump to monitor pump operation, drive motor availability, power failure, and failure of a fire pump to start.

The pumps take suction from a common wet pit sump in the circulating water screen house. Two traveling water screens and bar'grill are located at the inlet to the sump serving the fire pumps. The greatest water demand for the fixed fire suppression systems is 2300 gpm that, coupled with 1000 gpm for hose streams, creates a total water demand of 3300 gpm at a residual pressure of 80 psig. The staff finds that the water supply system can deliver the required water demand with one pump out of service.

By letter dated February 24, 1984, the applicant committed to either electrically supervise all essential valves in the fire water supply system or to lock them in the open position under a periodic visual supervision program conforming to the Standard Technical Specifications.

Based on this commitment, we conclude the Fire Protection Water Supply System will meet Section C.5.a of BTP CMEB 9.5-1 (Section IILA of Appendix R to 10 CFR 50), and Is, acceptable.

Fire Barriers and Fire Barrier Penetrations.

Where safe shutdown equipment is enclosed by a fire barrier, all walls, ceilings, floors, and associated penetration which enclose thi quipment have a minimum fire rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> with the folloviing exceptions': 1l/2-hour elevator doors, pressure, watertight, and missilleresistant doors, and equipment hatches in the auxiliary building. For fire treas that do not have a 3-hour-fire-rated

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assembly, due to the installation of the preceding doors, each was evaluated with respect to individual area its fuel load, fi e suppression systems, and proximity to safe and detection shutdown equipment to determine assemblies provided are adequate if fire-rated ror the areas affected and meet in Section 0.1.j of Appendix A the guidelines I to BTP7ASB 9.5-1. Based on this found the 1-1/2-hour fire barriers; evaluation, we for these areas acceptable, The applicant has agreed to provicre 3-hour UL designs for all fire seals used in the penetation penetration cablet trays, conduits, and piping penetration qualification tests which pass the including the time-temperature curve specified by ASTM E-119, exposure fire "Fire Test of Building Construction and Materials."

By letter dated February 1, 1984, the applicant stated that the for the penetration qualification acceptance criteria test was In excess of the 325°F temperature permitted on the unexposed maximum side by ASTM E-119, "Fire Test Building Construction and Materials." of The applicant stated that thetacceptance criteria used was a maximum temperature rise on the unexposed surface fire stop of 325°F above ambient. of the In addition, at no time during i the test period did any visible flaming occur on the unexposed side of the test assembly' and no openings permitted the hose stream test developed that to penetrate the seals.

Although the penetration seals do not meet the specific ASTH E-l19 7-'

rise limitations, the test results temperature showed that fire would not spread unexposed side of a protected fire tolthe ibarrier durn9 nga3 hour test period.i Few, if any areas in the plant contain a 3-hour cobustible'loaIng. Wse have reasonable assurance that the I therefore, IntegrityI and , -Iti! , , II .

temperature transmisslon I. I I the penetration assembly will not through affect the capability toiachlesiand safe shutdown considering the eftects maintain of afire involving fixed and potential transient combustibles inthe plant I j i j'j'1I '

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By letter dated February 24, 1984, the applicant committed to protect cable tray or conduit supports to achieve the same rating as the protected cable

'tray or conduit. We find this acceptable.

Based on our evaluation, we conclude the protection provided for fire barriers and fire barrier penetrations isan'acceptable deviation from our guidelines inSection C.$ of BTP CMEB 9.5*1,, and is,therefore,' acceptable.

Fire Protection for Safe Shutdown

1. Component Cooling Pumps The component cooling water pumps are located on the 2026' elevation of the auxiliary building. Partial sprinkler systems are provided for the corridor area around the pumps, however, 'there Isa non-sprinklered area between the pumps which contains interve ning'c'ombustibles, i.e.,

balance-of-plant (BOP) cable trays. This configuration isnot in accordance with Section C.5.1b of BTP CMEB 9.5-1.' The applicant, by letters dated February 1 and 24, 1984, committed to provide fire stops in the intervening cable trays, adjacent to one of the sprinklered zones by October 1,1984;at the Cal laway Plant and by fuel load at Wolf Creek.

Due to the nature and configuration of combustibles in this area, the fire stops would effectively prevent a fire fromls'p'reading to redundant trains. Based on this commitment, wefind that the protection provided for the component cooling water pumps meets our guidelines in Section C.s.b at BTP CME59.5-1, and Isl therefore, acceptoablel be

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2. Hatchways 7 auxiliary building is provided with two sets of equipment The hatchways in the northern and southern ends of the auxiliary building corridors. A monorail hoist serves each set of hatchways to allow equipment to be moved from o1ne location to another. Steel hatch covers £ and automatic sprinkler water curtains are provided for each hatchway at elevations 2000'-0", 20261-0", and 2047'-0" to separate the corridor fire areas.

At elevation 2000'-0" in the center of the auxiliary building, two adjacent hatchways are provided above the RHR and containment spray valve encapsulation tanks located on elevation 1988'-0". These two hatchways are covered with a 3-hour rated material.

Oue to the low fuel loading and configuration of equipment in these areas, we find the water curtains and steel covers provide a level of safety equivalent to the technical rnquirements of Section 111.G.

3. Containment Penetrations

• Tho reactor containment walls are penetrated by numerous mechanical and electrical penetrations, as well as a personnel hatch, and a fuel transfer tube.

The containment wall is four feet thick reinforced concrete with a continuous 1/4 inch thick steel liner. The construction is capable of withstanding a 60 psig ove:pressure without fallure.

Due to the construction of the containment wall and the special nuclear safety-related purposes these penetrations serve, w,',consider them equivalent to the technical requirements of Section III.C.

4. Fuel Buildina Root

• No fireproofing Is provided on the underside of the fuel building roof. The root is missile proof, 2 f*et thick reinforced concrete.

Oue to the low fuel loadng in this area, we find the level of tire protection acceptable

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5 Trench Cover - In the fuel building Fire Area F-29 the floor is on grade with the exception of a small pipe trench which opens into the room and connects with the radwaste tunnel. The trench opening in this room is closed by a heavy steel cover plate approximately 4 feet x 8 feet. This area is separated by over 50 feet with no intervening combustibles. Due to the separation distance and low combustible loading, we find the level of protection acceptable.

6. Main Steam and Feedwater Valve Compartment - (Fire Area A-23)

This fire area Is separated from all adjoining areas and buildings by 3-hour-rated fire barriers. Tho fire area is divided into two compartments by a 2-foot-thick concrete wall. A 9-foot x 24-foot vent opening is located at the ceiling of each compartment. The barrier wall between the two compartments has a 27-foot wide x 23-foot high vent opening located approximately 34 feet above the floor. These vent openings are required to prevent overpressurization of the compartment in the event of a postulated break of main steam piping. Due to the existence of the vent opening, the barrier wall cannot be fire rated.

All other penetrations through the fire barriers are fitted with 3-hour-rated penetrations seals. Three-hour-rated fire dampers1 are installed in all HVAC ducts penetrating the fire barriers.

Due to the low combustible loading and configuration of valves in this area, we find this level of protection acceptable.

7. Partial Suppression & Detection System!

• Tables 9.l50-3 and 9.S5-4 list the plant areas where automatic suppression and detection systems are not provided throughout the entire fire area.

The in-situ and potential transient fire hazards foir these areas of the plant have been assessed against the requirements for automatic sprinkler protection stipulated in Section 111.0 of Appendix R. The fire hazards in most of these areas are miniml.

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-t2-Partial suppression and detecton systems are provided in areas where potential fire hazards exist.

Because of these conditions, plus availability of manual fire fighting equipment, we conclude that the installation of additional automatic sprinkler and detection systems is not necessary. The existing fire protection provides us with reasonable assurance that one shutdown-related division will remain free of tire damage, and therefore, is acceptable.

Based on our review, we conclude the fire protection provided for safe shutdown with the approved deviations meets our guidelines in Section C.5b of BTP CMEB 9.5-1 (Section I11.G of Appendix R to 10 CFR 50), and is, therefore, acceptable.

Fire Detection System In our SER, we stated that the planl; fire detection system is installed in accordance with NfPA Standard 720. During the site visit, we noted that the back-up power supply may not meet the recommendations of HFPA Standard 720.

The applicant was unable to show compliance, and verbally agreed to prepare an analysis showing how the existing primary/back-up power supply circuitry compares to the requirements of NFPA Standard 72D.

By letter dated February 1, 1984, the applicant provided the comparison. The applicant's comparison indicated that the primary and secondary power supplies comply with the provisions of NFPA STD 72D, In the event of loss of power to the remote panels, loss of automatic activation of some pro-action sprinkler would occur. Because the pro-action systems are continuously supervised, any loss of power would be alarmed In tho control room. Plant Technical Specifica-tions would then require the establinhment of a continuous fire watch. Because of the fire watch and the fact that the sprinkler systems remain manually operable, we find this to be an acceptable deviation from our guidelines. Based on our review, we conclude that the fire detection system power supply is an acceptable deviation from our guidelines InSection C.6.a of BTP CMEB 9.5-1, and is,therefore, Acceptable.

Sprinkler Systems In our SER, we stated that the automatic sprinkler would be designed to the recommendations of NFPA Standard 13. During the site visit, we noted that in some corridor area (e.g., Aux. Building corridor, elevation 1974' west side) the sprinkler heads are 'located at the ceiling, and there are a large number of cable trays, conduits, pipes, and vent duct beneath the sprinkler heads. These obstructions may render the sprinkler system ineffective against a floor level exposure fire, and are not in accordance with NFPA Standard 13, which is recommenced by Section C.6c of BTP CMEB 9.5-1.

By letter dated February 24, 1984, the applicant committed to perform the following modifications by October, 1984 at the Callaway Plant and by fuel load at Wolf Creek:

Additional sprinkler heads will be added in the Auxiliary Building on the 2000' elevation west corridor (3 tray area) and 2026' elevation north end of east corridor to protect against postulated fires in transient combustibles.

Sprinkler heads on the 1974' elevation of the Auxiliary Building west corridor which are partially obstructed by structural steel beams will be lowered to avoid spray obstructions.

Based on this commitment, we conclude the sprinkler system will meet our guidelines in Section C.6.c of BTP CMEB 9.5-1, and are, therefore, acceptable.

Control Room in our SER, we stated that ionization type smoke detectors would be installed In all control room cabinets and consoles containing redundant equipment. During our site visit, we noted that no smoke detectors are provided for tafetyorelated cabinets in accordance with Sectlon C.7.b of STP CMEB 9.5-1.

By letter dated February 1, 1984, the applicant committed to provide detectors in the control room cabinets containing redundant safe-shutdown equipment by fuel load. We find this acceptable.

In the rear of the control room complex, smoke detection is provided at the ceiling level. During our site visits, it was our concern that due to the ceiling height, a substantial time delay could occur in detecting an incipient fire.

By letter dated February 1, 1984, the applicant committed to provide a duct detector in the control room HVAC exhaust duct by October 1, 1984 at the Callaway Plant and by fuel load at Wolf Creek. The duct detector will provide enhanced detection capability and compensate for the lack of low level detectors, because the HVAC exhaust inlets are near the floor level. Based on these commitments, we find the detection for the control room will meet our guidelines in Section C.7.a of BTP CHEB 9.5-1, and is, therefore, acceptable.

Diesel Generator Rooms In our SER, we stated that sprinkler systems would be installed in accordance with NFPA Standard 13. During our site visit, we noted that a pro-action sprinkler system Is provided for the protection of the diesel generators. A large vent duct passes directly beneath many of the sprinkler heads. The sprinkler piping arrangement is not in accordance with NFPA Standard 13, and BTP CMEB 9.5-1, Section C.6.c.

By letter dated February 1, 1984, the applicant committed to change the layout of the sprinkler piping to bypass the HVAC duct work. Based on this commitment, we conclude that the sprinkler systtas in the diesel generator rooms will comply with our guidelines in Section C.6. c of BTP CHEB 9.5-l, and are, therefore, acceptable.

t.5-The diesel fuel oil day tanks are located in each diesel generator room. In our SER, we stated that a containnment dike would be provided beneath each day tank to contain 110% of the fuel oil, however, during our visit, we noted that the top of the dike is beneath the tank. It was our concern that not all leaks would be contained by this configuration and that the applicant should modify the dike to provide a more positive collection ability, such as by completely surrounding the day tank, in accordance with Section C.7.1 of BTP CMEB 9.5-1.

By letter dated February 1, 1984, lthe applicant indicated that: The existing fuel tank and all piping is Seismic Category 1. The fuel oil system is a gravity feed type system, therefore?, no pressurized sprays will occur from a leak. The floor area adjacent to the dike is provided with floor drains. The day tank is provided with level indication which alarms in the control room if more than 3 gallons of leakage occur.

Based on this information, it is the applicant's opinion that the current design of the tank is adequate. We agreewith the licensee that the current design is adequate. If any leaks should occur, they would be promptly detected, and the floor chains would collect the majority of the leakage.

Based on our review, we conclude that the diesel fuel day tank and dike assembly meats our guidelines in Section C.7.1 of BTP CMEB 9.5-1, and is, therefore, acceptable.

Sumnary of Deviatlons:

(1) Penetration Seals acceptance criteria - BTP CMEB 9.5-1, Section C.5 (2) Unrated, missile-resistant doors - BTP CMEB 9.5-1, Section C.5.a (3) Fire Detection Power Supplies - BTP CMEB 9.5-1, Section C.6.a.

Conclusion Based on our evaluation, we conclude that the fire protection program with the accepted deviations meets the guidelines of BTP CMED 9.5-1 and GDC-3 and is, theretore, acceptable.

Fire Protection License Condition The licensee shall fully implement and maintain all provisions of the approved fire protection program. (PM should list all the NUREG documents where the approved fire protection program is described, including those sections issued by CMEB, ASB, EPLB, LQB and QAB).

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Input to the SALP Process A. Functional Area: Fire Protection

1. Management involvement in assuring quality: Throughout the review process, the applicant's activities exhibited evidence of prior planning and assignment of priorities.

Decisions which were made were usually at a level that ensured adequate management review.

Management was aware oi' the Importance of fire protection and took steps to see that our review and site audit went well, including making contractor representatives available as needed.

Rating Catecory 2

2. Approach to resolution of technical issues: During the various meetings, telecons, and in the several documents submitted in conjunction with the resolution of our site audit issues, the applicant's representatives displayed a clear understanding of our concerns with the level of fire protection. The applicant's additional fire protection commitments revealed a conservative approach toward providing an adequate level of safety. The Justification provided 1n support of the applicant's fire protection program were based on sound fire protection engineering principles.

Ratfna Catecory 2

3. Responsiveness to NRC Initiatives:

With few exceptions, the applicant provided timely oral responses to our requests for information.

Although most of the proposals offered to resolve our fire protection concerns could be construed as viable, our effort to resolve issues required a number of written some submittals before acceptable resolution was achieved.

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