ML11286A038

OL - Draft RAIs on Fire Protection - Group 8

ML11286A038
Person / Time
Site:	Watts Bar
Issue date:	09/30/2011
From:	Office of Nuclear Reactor Regulation
To:	Division of Operating Reactor Licensing
References
Download: ML11286A038 (6)

Text

WBN2Public Resource From: Poole, Justin Sent: Friday, September 30, 2011 9:08 AM To: Arent, Gordon; Bryan, Robert H Jr Cc: Milano, Patrick; WBN2HearingFile Resource

Subject:

DRAFT RAIs on Fire Protection - Group 8 Attachments: WBN group 8 RAIs.docx

Gordon, In reviewing the latest fire protection report, the staff has come up with the attached questions. Please review to ensure that the RAI questions are understandable, the regulatory basis is clear, there is no proprietary information contained in the RAI, and to determine if the information was previously docketed. If further clarification is needed, and you would like to discuss the questions in a conference call, let us know. Please also let me know how much time Tennessee Valley Authority (TVA) needs to respond to the RAI questions.

This email does not convey a formal NRC staff position, and it does not formally request for additional information.

Justin C. Poole Project Manager NRR/DORL/LPWB U.S. Nuclear Regulatory Commission (301)415-2048 email: Justin.Poole@nrc.gov 1

Hearing Identifier: Watts_Bar_2_Operating_LA_Public Email Number: 538 Mail Envelope Properties (19D990B45D535548840D1118C451C74DA9DDA112BD)

Subject:

DRAFT RAIs on Fire Protection - Group 8 Sent Date: 9/30/2011 9:08:25 AM Received Date: 9/30/2011 9:08:29 AM From: Poole, Justin Created By: Justin.Poole@nrc.gov Recipients:

"Milano, Patrick" <Patrick.Milano@nrc.gov>

Tracking Status: None "WBN2HearingFile Resource" <WBN2HearingFile.Resource@nrc.gov>

Tracking Status: None "Arent, Gordon" <garent@tva.gov>

Tracking Status: None "Bryan, Robert H Jr" <rhbryan@tva.gov>

Tracking Status: None Post Office: HQCLSTR02.nrc.gov Files Size Date & Time MESSAGE 835 9/30/2011 9:08:29 AM WBN group 8 RAIs.docx 26535 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

REQUEST FOR ADDITIONAL INFORMATION OPERATING LICENSE APPLICATION WATTS BAR, UNIT 2 DOCKET NO.: 50-391 TAC NO.: ME3091 Office of Nuclear Reactor Regulation Division of Risk Assessment Fire Protection Branch

• A number of the information requests may involve modifications to the fire protection report (FPR). This status is indicated at the end of the specific requests.

• References to the FPR refer to the August 2011 as-designed version of that document.

RAI number format Example: [RAI FPR V-1]

RAI - RAI FPR - topic or document from which the comment originates V - Section of the document Sequential comment for that section RAI FPR I-4 The separation requirements of Appendix R to 10 CFR 50 are applicable in areas containing redundant trains of fire safe shutdown (FSSD) equipment or cables. However, this information does not appear to be readily available in the FPR in an easily identifiable format. For instance, Table I-1 indicates which rooms contain safe shutdown equipment but does not indicate whether these rooms contain credited or redundant trains of equipment or both. Additionally, Part III, Section 10.3.1, of the FPR states that TVA performed an evaluation for each analysis volume to ensure compliance with Appendix R Section III.G.2.

Identify all rooms and analysis volumes containing redundant trains of FSSD equipment or cables and state whether they comply with the requirements contained in Section III.G.2 of Appendix R. Where explicit compliance is not provided, describe the method used to achieve an equivalent level of protection to that intended by Appendix R. Include a description of the spatial separation between redundant trains, proximity to in situ and transient combustibles, automatic fire detection and suppression systems, and installed fire barriers.

RAI FPR IV-5 Part VI of the FPR lists alternate shutdown operator manual actions for a fire in Fire Area 48.

The feasibility criteria for these manual actions are not explicitly described in Part IV, Alternate Shutdown Capability. Part V, Manual Actions, Repairs, and Emergency Lighting, Section 2.1.2, does include operator manual action acceptance criteria, but it is not clear to the staff reviewers that alternate shutdown operator manual actions are included in that review.

Confirm that operator manual actions for alternate shutdown have been evaluated using the feasibility and reliability analysis criteria in Section 2.1.1 of Part V, and that the evaluation used

the acceptance criteria in Section 2.1.2 of Part V. Also, confirm that the walk downs described in Section 2.2.1 of Part V have been performed for alternate shutdown operator manual actions and that the timing of those walkdowns has considered that the control room operators will need to travel from the Main Control Room to the Auxiliary Control Room as part of the timeline.

If the above confirmations cannot be provided, provide a description of the feasibility criteria for operator manual actions performed for alternative shutdown. The discussion should confirm that these operator manual actions have been walked down and confirm that travel time from the Main Control Room to the Auxiliary Control Room has been considered.

RAI FPR V-17 Part V, Section 2.2, item 5, states, For a fire located in the control building . . ., notify Appendix R AUOs to report to the control room . . . Section 2.2.2 states that operators performing manual actions are dispatched, . . . from the Auxiliary Control Room for Control Building fires.

Confirm that the statement in Section 2.2.2 is the appropriate statement. If not, provide an explanation of how Appendix R AUOs are assured access to the control room since access to the control room could be impeded by fire, fire products, or gaseous suppression system actuation.

In either case, correct the inconsistency.

RAI FPR VII-27 Part VII, Section 6.2 Justification for Fire Damper Surveillance Requirements, of the FPR states that the surveillances cannot be performed because of ALARA concerns. Examination of Part VI, Section 3.22.1, indicates that these dampers are in ducts that connect rooms 737.0-A5 and 737.0-A1 (damper 0-ISD-31-3846) or rooms 737.0-A5 and 729.0-A6 (dampers 0-ISD 3847 and 0-ISD-31-3828). None of these three rooms is on the list of inaccessible high radiation areas in Part II of the FPR.

1. More clearly describe the nature of the ALARA concern for performing these surveillances.

2. The descriptions of the locations of the fire dampers are confusing. More clearly describe the physical location of the dampers. For example, are they located in the wall of room 737.0-A5?

3. Where is the collector box identified as the start of the duct in Section 6.2.2.1 located? For example, is it in the wall of the fuel transfer canal?

4. Is the fuel transfer canal (Section 6.2.2.1) the same location as the Spent Fuel Pit (Section 6.2.2.2)?

5. Is the large (64 inch by 54 inch) duct mentioned for each of the three dampers the same duct?

6. Examination of Part VI, Section 3.22.1 reveals other dampers (specifically -3845 and -3849) that superficially match those that are evaluated in Section 6.2. Confirm that all of the dampers covered by the ALARA concern identified in Section 6.2 have been evaluated.

7. The evaluations in Section 6.2 seem to be focused on Unit 1 (room 737.0-A5 is the Unit 1 Ventilation and Purge Air Room). Will there be a corresponding Unit 2 evaluation? If so, when will that be submitted to the NRC?

It would be appropriate to modify the FPR to incorporate the answer to this RAI.

RAI FPR VII-28 Part VII, Section 2.7, of the FPR indicates that the hand-held portable lanterns, provided in lieu of installed emergency lights, are dedicated and maintained.

Provide the methods used to ensure that the portable lanterns are dedicated for manual actions in containment and for other post-fire manual actions. Additionally, provide the methods used to maintain the lanterns to ensure that they will provide sufficient lighting for operators to perform the manual actions.

RAI FPR VII-29 The evaluation of penetration seal surveillance requirements in Part VII, Section 6.4.2.3, of the FPR, states that there is no safe shutdown equipment in the Waste Holdup Tank Room. This appears to contradict Table I-1 and Section 3.1.1 of Part VII, which indicate that there is safe shutdown equipment installed in this room.

Resolve this apparent conflict.

RAI FPR VII-30 Part VII, Section 4.3 Manual Hose Stations, of the FPR, states that hose stations that are equipped with more than 100 feet of hose have had their pressure tested at the standpipe to compensate for additional lengths of hose. The implication is that the static pressure was tested at the standpipe, not the more appropriate dynamic pressure.

Provide a description of how TVA assures that the sufficient flow and pressure is available at the nozzles for these extended lengths of hose for fire fighting purposes.

Additionally, for each of the hose stations with these longer hoses, identify the rooms or portions of rooms that each hose station is relied upon to protect.

RAI FPR VII-31 Part VII, Section 2.6.3.2.b, of the FPR, states, in part: Sheet metal ducts that are not provided with fire dampers are identified on the Fire Compartmentation drawings (see Part II of this Report). They are constructed of minimum 22 gauge sheet metal and will provide a 1-hour

equivalent level of protection. Similar statements are made in sections 6.2.2.1 and 6.2.2.2 of Part VII.

Provide a technical basis for the claimed fire endurance rating for sheet metal ducts.

RAI FPR VII-32 Part VII, Section 3.2, of the FPR, states, in part: A flexible connection is provided between the purge air duct and the embedded containment duct penetration. The flexible connection is protected with 3M M20A fire barrier mat to give a 3-hour rating to the connection.

Provide a technical basis for the fire endurance rating for the sheet metal ducts. For example, is this a tested configuration?

RAI FPR VII-33 Section 3.1.2 of Part VII of the FPR states that portions of Room 713.0-A1 lack automatic fire suppression but then the discussion for this deviation appears to credit an automatic suppression system in the immediate vicinity of the area.

Justify the statement that automatic suppression in nearby areas will serve as a form of suppression for an unprotected area and explain how this is consistent with the underlying purpose of the rule.

RAI FPR X-5 Part X of the FPR states that CO2 systems were evaluated against NFPA-12, 1973 Edition, and then discusses any deviations that might exist. However, the FPR does not discuss the fact that several of the rooms protected by these systems have doors installed to swing in the direction of discharge. For instance, the diesel generator rooms have double doors that swing out of the rooms.

Confirm that all door assemblies for rooms containing gaseous suppression systems have been designed, installed, and tested in accordance with the appropriate design standards, or otherwise evaluated, to ensure that appropriate concentrations and soak times can be achieved and maintained for the systems to perform as intended.