ML13326A552

Safety Evaluation Supporting Amend 44 to License DPR-13

ML13326A552
Person / Time
Site:	San Onofre
Issue date:	07/19/1979
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML13326A550	List: ML13326A549 ML13326A551 ML13326A552 ML13326A553
References
TAC-48143, NUDOCS 7908170094
Download: ML13326A552 (42)

Text

FIRE PROTECTION SAFETY EVALUATION REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION U.S. NUCLEAR REGULATORY COMMISSION IN THE MATTER OF SOUTHERN CALIFORNIA EDISON COMPANY SAN ONOFRE NUCLEAR GENERATING STATION UNIT 1 DOCKET NO. 50-206 Date: July 19, 1979 7908170011

TABLE OF CONTENTS Page 1..0 INTRODUCTION 2.0 FIRE PROTECTION GUIDELINES....................................

2-1 2.1 General Design Criterion 3 -

"Fire Protection"..............

2-1 2.2 Supplementary Guidance......................................

2-1 3.0

SUMMARY

OF MODIFICATIONS AND INCOMPLETE ITEMS...............

..... 3-1 3.1 Modifications.........................................

3-1 3.1.1 Fire Detection Systems............................. 3-1 3.1.2 Fire Water Supply...................................

3-3 3.1.3 Yard Hydrants........................................

3-3 3.1.4 Hose Stations.................................... 3-3 3.1.5 Water Suppression Systems...........................

3-3 3.1.6 Foam Suppression Systems...........................

3-4 3.1.7 Gas Suppression Systems.............................

3-4 3.1.8 Portable.Extinguishers............................. 3-4 3.1.9 Fire Doors......................................

3-4 3.1.10 Supervision of Fire Doors..........................

3-4 3.1.11 Fire Barriers.......................................

3-4 3.1.12 Fire Dampers.....................................

3-5 3.1.13 Fire Barrier Penetrations...........................

3-5 3.1.14 Water Damage Protection.....I.......................

3-5 3.1.15 Control of Combustibles.............................

3-5 3.1.16 Isolation Devices.................................

3-6 3.1.17 Emergency Lighting.................................

3-6 3.2 Incomplete Items.......................................

3-6 3.2.1 Alternate Shutdown Capability........................

3-7 3.2.2 Smoke Detection Systems............................

3-7 3.2.3 Turbine Building Structure.........................

3-7 3.2.4 Cable Spreading Area..............................

3-7 3.2.5 Containment........................................

3-7 4.0 EVALUATION OF PLANT ARRANGEMENT.................................

4 4.1 Safe Shutdown Systems.......................................

4-1 4.2 Fire Detection and Signaling Systems........................

4-1 4.3 Fire Control System.........................................

4-2 4.3.1 Water Systems...................................

4-2 4.3.1.1 Water Supply.

............................4-2 4.3.1.2 Fire Pumps...............................

4-2 4.3.1.3 Fire Water Piping Systems..................

4-3 4.3.1.4 Interior Hose Stations.....................

4-4

TABLE OF CONTENTS (Cont'd)

Page 4.3.1.5 Fixed Water Suppression Systems............

4-4 4.3.1.6 Foam Suppression Systems..................

4-4 4.3.1.7 Effects of Suppression System on Safety Systems...............................

4-5 4.3.2 Gas Fire Suppression Systems.......................

4-5 4.3.3 Portable Fire Extinguishers.......................

4-5 4.4 Ventilation Systems and Breathing Equipment................

4-5 4.4.1 Ventilation Systems..............................

4-5 4.4.2 Breathing Equipment..............................

4-6 4.5 Floor Drains................................................

4-6 4.6 Lighting Systems.............................................

4-6 4.7 Communication Systems.......................................

4-7 4.8 Electrical Cables...........................................

4-7 4.9 Fire Barrier Penetrations...................................

4-7 4.10 Separation Criteria.........................................

4-8 4.11 Fire Barriers...............................................

4-8 4.12 Access and Egress.....................................

4-8 4.13 Toxic and Corrosive Combustion Products......

4-9 5.0 EVALUATION OF SPECIFIC PLANT AREAS.............................

5-1 5.1 Control Room...........................................

5-1 5.2 4160 Volt Switchgear Room...................................

5-2 5.3 480 Volt Switchgear Room....................................

5-3 5.4 DC Switchgear Room and Battery Room.........................

5-4 5.5 Auxiliary Building..........................................

5-5 5.6 Turbine Building...........................................

5-6 5.7 Diesel Generator Building...................................

5-8 5.8 Containment.................................................

5-9 5.9 Yard Area...................................................

5-10 6.0 ADMINISTRATIVE CONTROLS......................................

6-1 7.0 TECHNICAL SPECIFICATIONS.....................................

7-1

8.0 CONCLUSION

S......................................................

8-1 9.0 CONSULTANTS' REPORT........

9-1 APPENDIX A CHRONOLOGY........................................

A-1

1.0 INTRODUCTION

Following a fire at the Browns Ferry Nuclear Station in March 1975, the Nuclear Regulatory Commission initiated an evaluation of the need for improving the fire protection programs at all licensed nuclear power

.plants. As part of this continuing evaluation, the NRC, in February 1976, published the report by a special review group entitled, "Recommendations Related to Browns Ferry Fire," NUREG-0050. This report recommended that improvements in the areas of fire prevention and fire control be made in most existing facilities and that consideration be given to design features that would increase the ability of nuclear facilities to withstand fires without the loss of important functions. To implement the report's recommendations, the NRC initiated a program for reevaluation of the fire protection programs at all licensed nuclear power stations and for a comprehensive review of all new licensee applications.

The NRC issued new guidelines for fire protection programs in nuclear power plants which reflect the recommendations in NUREG-0050. These guidelines are contained in the following documents:

"Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," NUREG-75/087, Section 9.5.1, "Fire Protection,"

May 1976, which includes "Guidelines for Fire Protection for Nuclear Power Plants" (BTP APCSB 9.5-1), May 1, 1976.

"Guidelines for Fire Protection for Nuclear Power Plants" (Appendix A to BTP APCSB 9.5-1), August 23, 1976.

"Supplementary Guidance on Information Needed for Fire Protection Program Evaluation," September 30, 1976.

"Sample Technical Specifications," May 12, 1977.

"Nuclear Plant Fire Protection Functional Responsibilities, Administra tive Controls and Quality Assurance," June 14, 1977.

"Manpower Requirements for Operating Reactors," June 8, 1978.

All licensees were requested to: (1) compare their fire protection programs with the new guidelines; and (2) analyze the consequences of a postulated fire in each plant area.

We have reviewed the licensee's analyses and have visited the plant to examine the relationship of safety-related components, systems and structures with both combustibles and the associated fire detection and suppression systems. Our review was based on the licensee's proposed program for fire protection as described in the following docketed information:

(1) "Fire Protection Program Review," dated March 1977; 1-1

(2) The fire protection review team's site visit of July 10-13, 1978; (3) The licensee's response to staff positions.

Our review has been limited to the aspects of fire protection related to the protection of the public from the standpoint of radiological health and safety. We have not considered aspects of fire protection associated with life safety of onsite personnel and with property protection, unless they impact the health and safety of the public due to the release of radioactive material.

This report summarizes the result of our evaluation of the fire protection program at Southern California Edison Company's San Onofre Nuclear Generating Station Unit 1. The chronology of our evaluation is summarized in Appendix A of this report.

1-2

2.0 FIRE PROTECTION GUIDELINES 2.1 General Design Criterion 3 - "Fire Protection" The Commission's basic criterion for fire protection is set forth in General Design Criterion 3, Appendix A to 10 CFR Part 50, which states:

"Structures, systems and components important to safety shall be designed and located to minimize, consistent with safety require ments, the probability and effect of fires and explosions."

"Noncombustible and heat resistant materials shall be used wherever practical throughout the unit, particularly in locations such as the containment and the control room."

"Fire detection and protection systems of appropriate capacity and capability shall be provided and designed to minimize the adverse effects of fires on structures, systems and components important to safety."

"Fire fighting systems shall be designed to assure that their rupture or inadvertent operation does not significantly impair the safety capabilityof these structures, systems and components."

2.2 Supplementary Guidance Guidance on the implementation of GDC-3 for existing nuclear power plants has been provided by the NRC staff in'"Appendix A" of Branch Technical Position 9.5-1, "Guidelines for Fire Protection for Nuclear Power Plants."

Appendix A provides guidance on the preferred and, where applicable, acceptable alternatives to fire protection design for those nuclear power plants for which applications for construction permits were docketed prior to July 1, 1976.

Although this appendix provides specific guidance, alternatives may be proposed by licensees. These alternatives are evaluated by the NRC staff on a case-by-case basis.

Additional guidance which provides clarification of Fire Protection matters has been provided by the NRC staff in the following documents:

"Supplementary Guidance on Information Needed for Fire Protection Program Evaluation," October 21, 1976.

"Sample Technical Specifications," May 12, 1977.

"Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance," June 14, 1977.

2-1

"Manpower Requirements for Operating Reactors," June 8, 1978.

When the actual configuration of combustibles, safety-related structures, systems or components, and the fire protection features are not as assumed in the development of Appendix A or when the licensee has proposed alterna tives to the specific recommendations of Appendix A, we have evaluated such unique configurations and alternatives using the defense-in-depth objectives outlined below:

(1) reduce the likelihood of occurrence of fires; (2) promptly detect and extinguish fires if they occur; (3) maintain the capability to safely shut down the plant if fires occur; and (4) prevent the release of a significant amount of radioactive materials if fires occur.

In our evaluation, we assure that these objectives are met for the actual relationship of combustibles, safety-related equipment and fire protection features of the facility.

Our goal is a suitable balance of the many methods to achieve these individual objectives; increased strength, redundancy, performance, or reliability of one of these methods can compensate in some measures for deficiencies in the others.

2-2

3.0

SUMMARY

OF MODIFICATIONS AND INCOMPLETE ITEMS 3.1 Modifications The licensee plans to make certain plant modifications to improve the fire protection program as a result of the licensee's and the staff's evalua tion. The proposed modifications are summarized below. Further detail is provided in the licensee's submittals. The sections of this report which discuss the modifications are.noted in parentheses. The schedule for the implementation of these modifications is given in Table 3.1.

Certain items listed below are marked with an asterisk to indicate that the NRC staff will require additional information in the form of general design parameters to assure that the design is acceptable prior to actual implementation of these modifications. The balance of the other modifica tions have been described in an acceptable level of detail.

3.1.1 Fire Detection Systems Early warning automatic fire detection systems will be provided in the following areas:

(1) In the vital bus cabinet in the control room (5.1).

(2) Above the motor control center in the lower area of the auxiliary building (5.5).

(3) In the solid waste baling room in the auxiliary building (5.5).

(4) In the pipe tunnel to the auxiliary building (5.5).

(5) Additional smoke detectors will be provided in the turbine lube oil reservoir area of the turbine building (5.6).

(6), In the oil -storage shed in the east feedpump area of the turbine building (5.6).

(7) In the west feedpump area of the turbine building above the instru ment air compressors (5.6).

(8) In the battery room located in the diesel generator building (5.7).

(9) In the area of the residual heat removal pumps and third reactor coolant pump in the containment (5.8).

(10)

In the area of the electrical penetrations in the containment (5.8).

(11)

Additional fire deteqtion systems will be provided for areas as indicated in the licensee's fire hazards analysis.

3-1

Item Implementation Schedule By End of Core 8 Refuelinq Integrated with SEP**

1.

Fire Detection 3.1.1(1) and (5)

Others Fire Water Supply 3.1.2 None Yard Hydrants 3.1.3 None

4.

Hose Stattons (a) 3.1.4 None

5.

Water Suppression Systems for Area 9A Others

6.

Foam Suppression; Systems; 3.1.6 None

7.

Gas Suppression Systems for 4Kv Room For 480v Room

8.

Portable Extinguishers(b) 3 8

NOTe

9.

Fire Doors 31.9 None

10.

Supervision of Fire Doors(c} !3.1.l0

..None

11.

Fire Barriers(c)

Between Test Pump and Charging Pump.

At In other Areas North Wall of Area 9A.

12.

Fire Dampers In Control Room Ventilation Opening.

In other Rooms

13.

Fire Barrier Penetrations 3.1.1.3(1), (2) and (5)

Others

14.

Water Damage Protection None 3.1.14

5.

Control of Combustibles 3.1.15 None

16.

Isolation Devices 3.1.16 None

17.

Emergency Lighting(d )3..7 None

• Presently scheduled for Spring 1980.

• The items in column "Integrated with SEP" are not needed to protect equipment associated with the existing safe: shutdown capability. The licensee has stated that these modifica tions may be impacted by possible modifications resulting from the ongoing Systematic Evaluation, Program (SEP The staff concurs.

Therefore, deferral of implementation to the SEP wifl. insure an integrated long-term resolution of these fire protection modifi cations with the results from our SEP review.

(a) Pressure Test Hose Station(s) - Completed (b) Completed

( Completed

(

Handlights -

Completed 3-2

3.1.2 Fire Water-Supply Test features will be provided for the fire pumps which meets the require ments of NFPA 20 (4.3.1.2).

An isolation valve(s) will be provided in the above ground cross connection of the yard loop which is routed through the turbine building to prevent the loss of both manual and automatic water suppression due to a single impairment (4.3.1.3).

A self-actuated pressure valve or a check valve with a parallel bypass valve will be provided in the Units 2 and 3 connection to the Unit 1 fire water loop (4.3.1.3).

3.1.3 Yard Hydrants Yard hydrants and post indicator valves near roadways will be protected by adequate barricades to prevent physical damage. Hydrants.will be checked to insure that grade elevation is above the lower flange of the break off riser (4.3.1.3).

A number of hydrants will be relocated to insure accessibility and operability (4.3.1.3).

A second fire water feed will be provided to the administration/control building header from the northeast portion of the yard water main. Isolation valves will be provided for maintenance (4.3.1.3).

3.1.4 Hose Stations An isolation valve will be provided on the standpipe riser for the administra tion and control building (4.3.1.4).

The most hydraulically remote hose station(s) have been checked to verify that a residual pressure of 65 psig can be provided at the nozzle (4.3.1.4).

A hose reel will be provided at the southeast entrance to the 4160 volt switchgear room (5.2).

A hose reel will be provided at the southwest entrance to the 480 volt switchgear room (5.3).

A hose reel will be provided with access to the pipe tunnel (5.5).

3.1.5 Water Suppression Systems The east wall of the 480 volt switchgear room will be protected by a directed water spray system (5.3).

A sectionalized directed water spray system will be provided to protect the large concentration of cable trays in the north turbine building area.

Actuation of the system will be provided by the use of line type temperature detectors placed in the cable trays (5.6)

(Area 9A).

3-3

The north wall and structural steel members in the turbine lube oil area will be protected by a directed water spray system (5.6) (Area 9A).

A fuse link wet-pipe area sprinkler system will be provided for the large concentration of combustibles in the north turbine area (5.6) (Area 9A).

The deluge system protecting the hydrogen seal oil unit will be replaced with an automatic foam or water suppression system (5.6).

3.1.6 Foam Suppression Systems The deluge system for the lube oil reservoir and conditioner will be modified to provide an automatic foam suppression system (5.6).

3.1.7 Gas Suppression Systems An automatic total flooding Halon 1301 gas suppression system will be provided for the 4160 volt switchgear room. The system will be designed to permit a second application of the suppression agent (5.2).

An automatic total flooding Halon 1301 gas suppression system will be provided for the 480 volt switchgear room (5.3).

3.1.8 Portable Extinguishers Mounting brackets will be provided for the Halon 1211 extinguishers in the control room (5.1).

3.1.9 Fire Doors The double doors in the east wall of the 480 volt switchgear room will be replaced with 3-hour fire rated doors (5.3).

A one-hour fire rated door will be provided between the solid waste baling area and the boric acid injection pump room in the auxiliary building (5.5).

3.1.10 Supervision of Fire Doors Fire doors in safety-related areas will be inspected semiannually to verify that self-closing mechanisms and latches are in good working order.

Unsupervised and unlocked self-closing fire doors for safety-related areas will be inspected monthly to verify that they are being maintained in the closed position (4.9).

3.1.11 Fire Barriers A fire shield will be provided between the test pump and north charging pump in the auxiliary building (5.5).

Fire stops will be provided for cable trays at the entrances to the pipe tunnel (5.5).

3-4

The north wall of the turbine lube oil area will, be upgraded to provide a one-hour fire rating (5.6).

The roof and door of the oil storage shed in the east feedpump area of the turbine building will be replaced to provide a 3-hour fire rating (5.6).

Fire stops will be provided in cable trays which are routed between redundant divisions of cable trays in the containment (5.8).

3.1.12 Fire Dampers Three-hour rated fire dampers will be provided in the ventilation penetra tions from the 4160 volt switchgear room (5.2).

Fire dampers will be provided in the ventilation openings from the 480 volt switchgear room (5.3).

Fire dampers will be provided in the ventilation penetrations to the battery room (5.4).

3.1.13 Fire Barrier Penetrations Fire barrier penetrations will be sealed to provide a 3-hour fire rating or a rating commensurate with the fire hazards for the following areas:

(1) Cable penetrations for the control room (5.1).

(2) Cable penetrations for the 4160 volt switchgear room (5.2).

(3) Cable penetrations for the 480 volt switchgear room (5.3).

(4) Cable penetrations from the dc switchgear room to the administration and control building (5.4).

(5) Cable penetrations in the north wall of the turbine lube oil area in the turbine building (5.6).

3.1.14 Water.Damage Protection Water spray shields will be provided for electrical equipment in the 4160 and 480 volt switchgear rooms to prevent water damage due to the use of hose streams to combat fires in cable trays above the equipment (5.2),

(5.3).

3.1.15 Control of Combustibles Alhydrogen monitor will be provided for the battery room with a remote reading in the control room (5.4).

Curbs or drain pans will be provided at the base of the charging pumps and test pumps to contain oil spills (5.5).

3-5

A curb will be provided around the hydrogen seal oil unit to contain lubricating oil spills (5.6).

Curbing will be provided to contain an oil spill within the air intake filter rooms or fire detection will be provided in the area (5.7).

An oil collection system will be provided for the reactor coolant pumps (5.8).

A curb will be provided around the clean and dirty lube oil storage tanks in the yard area. The volume will be sufficient to contain the contents of the tank plus an allowance for fire extinguishing media (5.9).

The station service transformers will be curbed to contain an oil spill (5.9).

The oil in the station service transformer will be replaced with a silicone base oil or an automatic deluge system will be provided to protect transformers 2 and 3 (5.9).

The doorway of the 480 volt switchgear room facing the station service transformers will be filled in to provide a fire barrier rating equivalent to the west wall of the room (5.3).

A curb will.be provided to contain a gasoline spill at the engine driven screen wash pump (5.9).

3.1.16 Isolation Devices An isolation device will be provided between the control room panel steam dump controls and the auxiliary panel to prevent fire damage at the auxiliary panel from having an impact on the normal steam dump control (5.6).

3.1.17 Emergency Lighting Fixed battery pack lighting units will be provided for the stairwell to the lower level in the auxiliary building and in the stairwell access routes to the control room in the administrationbuilding (4.6).

An additional quantity of administratively controlled hand lights will be provided for the contingency of loss of station lighting (4.6).

3.2 Incomplete Items In addition to the licensee's proposed modifications, several incomplete items remain,.as discussed below. The licensee will complete the evalua tions necessary to resolve these items in accordance with the schedule contained in Table 3.2. This schedule has been established such that should these evaluations identify the need for additional modifications, they can be implemented oh a schedule consistent with completion of the modifications identified in Section 3.1.

We will address the resolution of these incomplete items in a supplement to this report.

3-6

3.2.1 Alternate Shutdown Capability The licensee is evaluating alternate methods for safe shutdown which are not dependent upon the chemical and volume control system test pump. The consideration for the availability of offsite power will also be addressed in the evaluation of shutdown alternatives (4.1).

3.2.2 Smoke Detection System Tests The licensee is evaluating a method to conduct in situ tests with a suit able smoke generation device to verify that a fire would be promptly detected by installed smoke detectors and that ventilation air flow patterns in the area do not significantly reduce or prevent detection response.

Bench tests will be conducted to verify that smoke detectors will provide prompt response and have adequate sensitivity to the products of combustion for the combustibles in the area where smoke detectors are installed. If any fire detection systems are found to be inadequate, appropriate modifica tions will be made to provide adequate performance (4.2).

3.2.3 Turbine Building Structure The licensee is evaluating the effect of a fire involving the hydrogen seal oil system on the structural steel of the turbine building without the benefit of a fire suppression system (5.6).

3.2.4 Cable Spreading Area We have recommended the use of flame retardant coatings for cables or the installation of fire barriers between cable trays and fire stops in cable trays in the cable spreading area of the 4160 volt switchgear room. We will address the resolution of this recommendation with the resolution of alternate shutdown capability noted in Section 3.2.1 above (5.2).

3.2.5 Containment We have recommended that fire stops be located in cable trays which provide a continuity of combustibles between redundant cable trays. We will address the resolution of this recommendation with the resolution of any problems which develop as a result of.the Systematic Evaluation Program review (5.8).

3-7

Table 3.2 Item Schedule 1.. Alternate Shutdown Capability.................. submitted January 15, 1979

2. Smoke Detection System Tests................... March 1980

3. Turbine Building Structure..................... submitted May'15, 1979

4. Cable Spreading Area........................... dependent on resolution of item 1

5. Containment.................................... deferred to SEP review 3-8

4.0 EVALUATION OF PLANT ARRANGEMENT 4.1 Safe Shutdown Systems There are several combinations of safe shutdown systems which are capable of shutting down the reactor and cooling the core during and subsequent to a fire. The licensee identified safe shutdown systems in his fire hazards analysis. The combinations available in a fire situation will depend upon the effects of the fire on such systems, their power supplies, and their control stations.

Many of the systems required for safe shutdown are located in separate fire areas to preclude fire damage to redundant systems. In some areas of the plant, the physical separation of redundant safe shutdown systems is inadequate to prevent fire damage to redundant systems. The licensee has taken action to mitigate these consequences of fires and to improve the capability of controlling and extinguishing fires in these areas as noted in Section 5.0 of this report.

Due to the unacceptable consequences of a major fire in the 4160 volt switchgear room, measures have been taken, on an interim basis, to provide an additional offsite power source to insure safe shutdown capability.

Additional modifications have been made as noted in Section 5.0 of this report to permit safe shutdown independent of fire damage in the 4160 volt switchgear room.

We find.that, from a review of the recent modifications for insuring the capability for safe shutdown and with the improvements implemented for the fire protection program, an adequate basis has been provided to assure that the plant can be maintained in a safe condition during the interim period until final fire protection modifications have been completed.

With respect to safe shutdown capability following this interim period, the licensee will propose further alternate methods for safe shutdown following ongoing investigations. We will address the resolution of this subject in a supplement to this report.

4.2 Fire Detection and Signaling Systems Fire detection and signaling systems are provided which transmit alarm.and supervisory signals to the control room. The fire detectors are powered from the 120v.ac utility bus. This bus is connected to the diesel generators and is supplied power upon the loss of offsite power.

Visual and audible annunciation is provided in the control room for detection actuation, pump supervisory signals and deluge actuation.

The plant presently does not have complete fire detection coverage and some areas containing or exposing safety-related systems do not have-fire detection systems. To protect these areas, smoke detectors will be provided in a number of safety-related areas as noted in Section 5.0 of this report.

4-1

In situ tests will be conducted with a suitable smoke generation device to verify that a fire would be promptly detected by installed smoke detectors and that ventilation air flow patterns in the area do not significantly reduce or prevent detection response. Bench tests will be conducted to verify that smoke detectors will provide prompt response and have adequate sensitivity to the products of combustion for the combustibles in the area where smoke detectors are installed. If any fire detection systems are found to be inadequate, appropriate modifications will be made to provide adequate detection performance.

We find that subject to implementation of the above modifications and tests, the fire detection system will provide prompt response to fires.

This satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

4.3 Fire Control System 4.3.1 Water Systems 4.3.1.1 Water Supply The fire-water supply consists of a 3,000,000 gallon capacity service water reservoir at Unit 1 of which 300,000 gallons is dedicated to fire water use and two 300,000 gallon fire water tanks at Units 2 & 3. The Unit 1 fire pumps take suction from the service water reservoir through a single 8-inch feed. The Units 2 and 3 fire pumps take suction from two ground level fire water storage tanks. The piping is so arranged that each pump can take:suction from either of the fire water tanks.

The Units 2 and 3 supply tanks are valved to insure that a leak in one tank would not cause the loss of the remaining tank. A break in the 8-inch supply to the Unit 1 fire pumps would place both pumps out of service; however, with isolation of the break the separate feed from the Units 2 and 3 fire system provides an alternate fire water source for Unit 1.

We find that the water supply is adequate to meet the site fire water needs for all potential fires. This satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

4.3.1.2 Fire Pumps Two horizontal shaft, electric centrifugal fire pumps are provided for Unit 1 fire system. These pumps are located outdoors, west of the 480 volt switchgear room. Each pump has a design capacity of 1,000 gpm at 120 psig.

Power for the Unit 1 pumps are supplied from two different buses of the 480-volt plant auxiliary power system which can be supplied by the diesel generators. Fire pump power, pump running and failure to start are supervised and annunciated in the control room. The pumps are started manually in the control room. Test features will be provided for the fire pumps which meet the requirements of NFPA 20.

The Units 2 and 3 fire pumps consist of two electric motor driven 1500 gpr and one 2500 gpm diesel driven fire pump. The pumps start automatically on low system pressure. With the Units 2 and 3 fire pumps, adequate volume and pressure will be supplied to the Unit 1 system.

4-2

We find that the fire pumps have adequate capacity to supply the site fire water demand. This satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

4.3.1.3 Fire Water Piping System The Unit 1 fire pumps discharge directly into the above ground cross connection which runs through the turbine building. This cross connection supplies the manual and automatic fire protection for the turbine and administration/control buildings. An isolation valve(s) will be installed in this cross connection, to prevent the loss of both manual and automatic fire suppression in a fire area due to a single impairment.

The Units 2 and 3 fire system is interconnected through a 12-inch connection to the Unit 1 loop. Presently the two valves between the systems are normally closed. A self-actuated pressure valve or a check valve with a parallel bypass valve will be provided in the Units 2 and 3 connection to the Unit 1 fire water loop and the isolation valves maintained open.

All yard hydrants are supplied from the Unit 1 fire loop. The hydrants do not have curb box valves for isolation of the hydrant for maintenance and repair. However, the hydrants are protected by an automatic check valve which would close if the hydrants were struck by a heavy object. A break off riser is provided between the hydrant and check valve. The hydrants will be checked to insure that grade elevation is above the lower flange of the break off riser. Sectional valves are strategically located to isolate various sections of the mains to keep impairment of systems to a minimum. Hydrants and post indicator valves near roadways will be protected by adequate barricades to prevent physical damage. A number of hydrants will be relocated to insure accessibility and operability in an emergency situation.

All post indicator valves and isolation valves in the fire water piping system are electrically supervised or administratively controlled by the use of locks or seals and periodic inspections are made to verify that the valves are in the proper position. The valves have been tagged to indicate the valve service. The fire water system is dedicated to fire water service but emergency use may be allowed for short durations.

Yard hydrants are strategically located around the exterior of the plant with two hose houses located at opposite ends of the plant. Additional manual fire fighting tools will be provided in each-hose house. The hydrants hose threads are compatible with the local fire department.

A second fire water feed will be provided to the administration and control building header from the northeast portion of the yard water main and isolation valves will be provided for maintenance.

We find that, subject to the implementation of the above described modifi cations, the fire water piping system is adequate to supply the fixed fire water suppression systems and manual hose stations. This satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

4-3

4.3.1.4 Interior Hose Stations Interior hose stations are strategically located throughout most areas of the plant. Hose stations are of the rack type and are equipped with 75 feet of single jacket rubber lined hose except for a few hose stations with unlined linen hose. The linen hose at the hose stations near the control room has been replaced with single jacketed rubber lined hose with adjustable flow fog nozzles. An isolation valve will be provided on the standpipe riser for the administration and control building. The most hydraulically remote hose station(s) have been checked to verify that a residual pressure of 65 psig can be provided at the nozzle.

We find that, subject to implementation of the above described modifica tions, the interior fire hose stations are adequate to provide manual fire water suppression capability. This satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

4.3.1.5 Fixed Water Suppression Systems Fixed water suppression systems are provided for -the containment, diesel generator building, and the turbine building. The containment system is an open head deluge system which is manually actuated. It is supplied water from the refuelingwater pumps, independent of the fire water system.

The manual deluge system protecting the lube oil reservoir and conditioner

• in the turbine building will be modified to provide an automatic foam suppression system. Within this same area, a.directed water spray system actuated by line type temperature detectors in the cable trays will be provided to protect the cable trays. For both of these fire hazards, a back up area fuse link sprinkler system will be provided. The manual deluge system protecting the hydrogen seal oil unit in the turbine building will be replaced with an automatic water or foam suppression system.

A preaction closed head sprinkler system protects the diesel generator rooms. A combination of flame detection and ionization detection is provided to actuate the deluge valve.

We find that, subject to implementation of the above described modifi cations, the water suppression systems are adequate to suppress fires for the hazards where provided. This satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

4.3.1.6 Foam Suppression Systems Automatic foam suppression systems will be provided as noted in Section 4.3.1.5 above. Foam application nozzles and foam concentrate is provided in the hose houses to provide an additional suppression capability for oil fires.

We find that, subject to implementation of the above described modifications, the foam suppression systems provide an additional effective capability to suppress combustible liquid fires. This satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

4-4

4.3.1.7 Effects of Suppression Systems on Safety Systems The design of the fixed water suppression system protecting the diesel generator building includes fuse link sprinkler heads and a deluge valve actuated by flame and smoke detectors. These features reduce the potential for inadvertent operation which could potentially impact on the operation of a diesel generator unit. As noted in Section-5.0 of this report, modifications will be provided to prevent water damage to electrical equipment due to operation of fixed water suppression systems and additional protection will be provided to reduce the potential of water damage from manual hose streams.

We find that, subject to the implementation of the modifications noted herein, adequate measures have been taken to protect electrical equipment from water damage. This satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

4.3.2 Gas Fire Suppression Systems Automatic total flooding Halon 1301 suppression systems will be provided for the 480 volt and 4160 volt switchgear rooms. These systems will be capable of manual operation. The system protecting the 4160 volt'switchgear room will be designed to permit a second application of the suppression agent (double shot system).

• Wefin tha, sbjet totheimpementation of the above described modifica We find hat, suprotecting imhe tions, the gas suppression systems are adequate to suppress fires for the hazards whereprovided. Thi's satisfies thewobjectives identified ind Section 2.2 of this report and is, therefore,.acceptable.

4.3.3 Portable Fire Extinguishers Portable dry chemical and carbon dioxide have been distributed throughout the plant.

The fire extinguishers meet the general intent of the National Fire Protection Association. The extinguisher selection was made in accordance withthe type of hazard to be protected. All fire extinguishers are maintained fully charged, tagged, and dated including contractors' units.

We find that the portable fire extinguishers provide adequate initial fire suppression capability for small fires. This satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

4.4 Ventilation Systems and Breathing Equipment 4.4.1 Ventilation Systems The plant does not have exhaust systems designed specifically for smoke removal. The normal air handling systems in most areas can be used for smoke removal; however, their effectiveness may be limited. The fans and other equipment in the air handling systems are not designed to withstand high temperatures, and can be rendered inoperative by the heat from a 4-5

significant fire. The capacity and configuration of the normal air handling systems may be inadequate for effective smoke removal.

Portable smoke venting equipment has been provided for fire brigade use as a backup.to installed systems.

We find that the capability for smoke and heat venting is adequate to permit fire fighting access. This satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

4.4.2 Breathing Equipment Self-contained air breathing equipment is provided consisting of six Survivair packs and about 30 spare air cylinders. Air distribution manifolds are provided in the control room and hose houses. About eight air masks are provided in each hose house with air tubing. The control room air breathing equipment has been consolidated in a single, orderly, and sanitary location.

We find the breathing equipment is adequate to insure that fire fighting access can be provided in a hostile environment. This satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

.4.5 Floor Drains Floor drains have been provided in all areas protected by fixed water suppression systems. Drainage is also provided in areas where manual hose lines would be.used. Water use in areas that do not have drainage systems would be used selectively to prevent water accumulation.

We find that the drainage system is adequate to handle fire suppression water to prevent drainage to electrical equipment. This satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

4.6 Lighting Systems The normal lighting system receives its power from the station auxiliary transformers. Upon the loss of these sources, standby sources are made available by transfer to the station batteries and the diesel generators to provide a supply of power. These features insure that lighting is available for emergency conditions. The licensee has further insured the availability of adequate lighting by providing fixed seal beam self-contained battery operated units at strategic locations.

Fixed battery pack lighting units will be provided for the stairwell to the lower level of the auxiliary building and in the stairwell access routes to the control room in the administration building. An additional quantity of administratively controlled portable hand lights will be provided for the contingency of loss of station lighting.

4-6

We find that, subject to the implementation of the above described modifi cations, the emergency lighting is adequate for both operating personnel and the fire brigade to deal with emergency conditions.

This satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

4.7 Communication Systems Normal communication within the plant is provided by a page and answer system with stations located.throughout the plant. Backup power is provided for this system. A second system consists of portable communications radios which are provided for emergency use. Radio communications and public telephone lines are provided for access to offsite agencies.

We find that the communications are adequate to coordinate fire fighting and safe shutdown activities. This satisfies the objectives.identified in Section 2.2 of this report and is, therefore, acceptable.

4.8 Electrical Cables The electrical cable insulation used in the plant consists mainly of.

polyvinyl chloride, butyl compound, neoprene, and other insulating and jacket materials that do not meet current flame test requirements. The new cable installations such as used for the emergency diesel generators and future changes will be made with cable that meets the requirement of the IEEE-383 flame test. Fire protection measures have been or will be provided with due consideration for the combustible nature of cable insula tion materials.

We find that, subject to the resolution of open items identified in Section 3.2 of this report, the electrical cables and fire protection measures as identified herein are adequate to satisfy the objectives identified in Section 2.2 of this report and are, therefore, acceptable.

4.9 Fire Barrier Penetrations Fire barriers are penetrated by doorways, ventilation ducts, electrical cables, piping and conduit. Fire doors for safety-related areas will be inspected semiannually to verify that'self-closing mechanisms and latches are in good working order. Unsupervised and unlocked self-closing fire

'doors for safety-related areas will be inspected monthly to verify that they are being maintained in.the closed position. To provide assurance that fire doors remain closed, signs are used on doors to indicate that doors form a fire barrier and are to be maihtained closed.

Cable and cable tray penetrations in fire barriers will be upgraded to provide a fire barrier rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> or commensurate with the fire hazards in the area. Modifications for fire barrier penetrations in specific plant areas are noted in Section 5.0 of this report.

We find that, subject to the implementation of the modifications described herein, the fire barrier penetrations are adequate to prevent the spread 4-7

of fires between isolated fire areas. This satisfies the objectives identified in Section 2.2 of this report and is, therefore acceptable.

4.10 Separation Criteria The physical separation of redundant electrical cables and components is not adequate in itself to prevent fire damage to redundant systems.

Modifications have been proposed as described herein to insure that redundant systems required for safe shutdown would not be lost due to the consequences of fire in any area of the plant. We will evaluate the licensee's proposal in conijnetion 4th the open items in Section 3.2 and address the resolution in a supplement to this report.

4.11 Fire Barriers The licensee's fire hazards analysis addressed fire barrier requirements by consideration of the combustibles in each fire area. The potential energy release for all combustibles in an area was calculated. This value was divided by the floor area to obtain a relative combustible loading for the area. Based upon this analysis modifications have been proposed to upgrade the rating of fire barriers or to provide fixed suppression systems to protect fire barriers in specific plant areas as noted in Section 5.0 of this report.

We find that, subject to the implementation of the modifications identified herein, adequate measures have been provided to prevent fire spread between protected areas of the plant. This satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

4.12 Access and Egress Access to most areas of the plant is unencumbdred due to the openness of design. Most safety-related areas have open access.

Access to the upper cable trays in the 4160 volt switchgear rooms presents the most difficult fire fighting access problem. Fire ladders are maintained in this area.

The diesel generator rooms have two direc't access means from the outside.

The two rooms are not interconnected by access doors.

We find that the provisions for access and egress are adequate for manual fire fighting and evacuation in safety-related areas. This satisfies the objectives identified in Section 2.2 of this report and is, therefore acceptable.

4-8

4.13 Toxic and Corrosive Combustion Products The products of combustion for many plastic materials, most common being cable insulation and jacket materials, are toxic to humans and corrosive to metals.

Prompt fire detection and extinguishment are relied upon to minimize the quantities of smoke generated. Portable means of smoke removal are provided as an aid in fire fighting access. The fire brigade is provided with and trained in the use of emergency breathing apparatus for fighting fires involving such materials. The openness of this plant eliminates many of the ventilation and corrosive problems involving a number of safety-related areas.

We find that adequate precautions have been taken to minimize the effects of toxic and corrosive products. This satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

4-9

5.0 EVALUATION OF SPECIFIC PLANT AREAS The licensee has performed a fire hazards analysis of the facility to.

determine the fire loading of various plant areas and to evaluate the adequacy of existing and proposed fire protection systems.

The results of the fire hazards analysis, other docketed information and site visit observations were used in the staff's evaluation of specific plant areas.

The staff's evaluation of specific areas is discussed in the following sections.

5.1 Control Room 5.1.1 Safety-Related Equipment The control room contains the controls for normal station operation and for shutdown of the plant under abnormal conditions. Operating indicators, controls, and alarms are mounted on U-shaped free standing control boards.

Auxiliary electrical equipment cabinets are located in the area behind the control boards.

5.1.2 Combustibles The combustibles in this area include electrical cable and wire insulation, and a small quantity of Class A combustibles such as log books and operating procedures.

5.1.3 Consequences if No Fire Suppression An unmitigated fire in the control room could damage redundant divisions of safety-related systems required for safe shutdown.

5.1.4 Fire Protection System Portable CO2 and Halon 1211 extinguishers are provided for manual fire suppression capability. Hose cabinets are located in the corridors outside the control room. Smoke detectors are provided at the ceiling of the control room and in the control console.

5.1.5 Adequacy of Fire Protection The fire barrier penetrations for the control room area are not adequate to prevent an exposure fire hazard from adjacent areas.

The lack of fire detection in the vital bus cabinet prevents prompt response to a fire in this area.

5.1.6 Modifications The licensee has proposed the following modifications. A fire detector will be installed in the vital bus cabinet. Cable penetrations to other areas will be provided with seals having a 3-hour fire rating. Mounting brackets will be provided for the Halon 1211 portable extinguisher units.

5-1

We find that, subject to the implementation of the above described modifica tions, the fire protection for the control room satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

5.2 4160 Volt Switchgear Room 5.2.1 Safety-Related Equipment The 4160 volt switchgear room is located directly below the control room.

The upper half of this room is the cable spreading area. Instrument,.

control, and power cables are routed through the cable spreading area.

Redundant division of 4160 volt switchgear and one division of 480 volt switchgear are located in this area.

5.2.2' Combustibles The major combustibles in the area consist of electrical cable insulation.

5.2.3 Consequences if No Fire Suppression An unmitigated fire in the area could result in the loss of the normal means of supplying both onsite and offsite power to redundant systems required for safe shutdown.

5.2.4 Fire Protection Systems Fire detection is provided by ceiling mounted smoke detectors. Portable extinguishers are located in the area. Hose stations in adjacent areas provide water suppression capability.

5.2.2 Adequacy of Fire Protection The fire protection for this area is inadequate to prevent damage to redundant systems which may be required for safe shutdown. The electrical equipment is not protected to prevent water damage from fire hoses.

5.2.6 Modifications The licensee has proposed the following modifications. An automatic total flooding Halon 1301 gas suppression system will be provided for the area.

A hose reel will be provided at the southeast entrance to the switchgear room. Water spray shields will be provided to prevent water damage to electrical equipment. Cable penetrations will be sealed to provide a 3-hour fire rating. A 3-hour rated fire damper will be provided in the ventilation penetration to the control room.

Recent modifications have been completed for the following. Power and control cables for the dc thermal barrier emergency cooling pump have been rerouted external to the 4160 volt switchgear room. The southwest door to the switchgear room has been replaced with a self-closing 3-hour fire rated door. The southeast door to the switchgear room was sealed to prevent a combustible liquid spill on the ramped accessway from entering the area.

5-2

Due to the high fire loading and the difficulty which could be encountered in manually combating an electrical cable fire in the area, we have recommended the use of flame retardant coatings for cables or the installation of fire barriers between cable trays and fire stops in cable trays. As noted in Section 4.1 of this report, the licensee is investigating other alternatives for safe shutdown independent of this area. We will address the resolution of this recommendation and the alternatives for safe shutdown in a supplement to this report.

5.3 480 Volt Switchgear Room 5.3.1 Safety-Related Equipment Two separate buses of the 480 volt switchgear are located in the area.

Redundant equipment for safe shutdown is located in the 4160 volt switch gear room.

5.3.2 Combustibles The major combustibles in the area consist of electrical cable insulation.

5.3.3 Consequences if No Fire Suppression An unmitigated fire in the area could result in a loss of one division of safe shutdown equipment 5.3.4 Fire Protection Systems Fire detection is provided by ceiling mounted smoke detectors. Portable extinguishers are provided in the area. Hose stations in adjacent areas provide water suppression capability.

5.3.5 Adequacy of Fire Protection The fire suppression capability for this area is inadequate to control and suppress a major fire. The electrical equipment is not protected to prevent water damage from fire hoses. The door and wall to the adjacent turbine lube oil area is inadequate to prevent an exposure fire hazard from this area.

5.3.6 Modifications The licensee has proposed the following modifications. An automatic total flooding Halon 1301 gas suppression system will be provided for the area.

A hose reel will be installed at the southwest entrance to the room.

Water spray shields will be provided to prevent water damage to electrical equipment. Cable penetrations will be sealed to provide an appropriate fire rating. Fire dampers will be provided in the ventilation openings to adjacent areas. The double doors in the east wall will be replaced with 3-hour rated fire doors. The east wall will be protected by a directed water spray system. The doorway facing the station service transformers will be filled in to-provide a fire barrier rating equivalent to the west wall of the room.

5-3

Recent modifications have been completed for the following. A 12kV line was installed with a connection from the offsite power system to a 12kV/480 volt transformer. The low side of the transformer has been connected to a spare breaker location to provide-an alternate power source for safe shutdown using equipment supplied power from the 480 volt switchgear room. Level indications for the volume control tank have been provided at the test pump switchgear location to permit control of primary coolant make up flow during an emergency condition. The.south door to the switchgear room has been replaced with a self-closing 3-hour fire rated door.

We find that, subject to the implementation of the above described modifica tion, the fire protection for the 480 volt switchgear room satisfies the objectives identified in Section 2.Z of.this report and is, therefore, acceptable.

5.4 DC Switchgear Room-and Battery Room 5.4.1 Safety-Re ated Equipment The battery chargers and dc distribution switchboard for one of two redundant dc power systems are located in the dc switchgear room.at the south end of the administration and control building. The batteries for the associated dc bus are located in an adjacent room.

5.4.2 Combustibles The combustibles in the dc switchgear room consist of electrical cable and wire insulation. The combustibles in the battery room consist of wood battery racks and plastic battery cells-a' 5.4.3 Consequences if No Fire Suppression An unmitigated fire in either area could result in a loss of one of the two redundant dc power sources.

5.4.4 Fire Protection Systems Smoke detectors are provided at the ceiling in each area. Portable extin guishers are located at the entrance to the dc switchgear room. A hose station in an adjacent area provides water suppression capability.

5.4.5 Adequacy of Fire Protection The cable penetrations for the switchgear room are not adequately sealed to prevent the spread of a fire. The ventilation penetrations for the battery room are not protected to prevent an exposure from adjacent areas.

5.4.6 Modifications The licensee has proposed the following modifications. The cable penetra tions from the dc switchgear room to the administration and control building will be sealed to provide an appropriate rating. Fire dampers will.be provided in the ventilation penetrations to the battery room. A hydrogen 5-4

monitor will be provided for the battery room with a remote reading in the control room.

We find.that, subject to the implementation of the above described modifica tion, the fire protection for the dc switchgear room and battery room satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

5.5 Auxiliary Building 5.5.1 Safety-Related Equipment The volume control tank and boric acid injection tanks and pumps are located in separate rooms at grade elevation in the auxiliary building.

The lower level of the auxiliary building has a separate room housing the charging pumps and the test pump. A motor control center and gas radwaste systems are located on lower level. A pipe tunnel terminates at the auxiliary building which is used for cable routing to this area.

5.5.2 Combustibles The combustibles in the area consist of electrical cable insulation, lubricating oil in pumps and oil storage, and miscellaneous transient combustibles. Solid wastes are handled in a baling room adjacent.to the boric acid injection pump room. Unprotected transient combustibles which were stored under the stairwell and in other areas have been removed.

5.5.3 Consequences if No Fire Suppression An unmitigated fire could threaten the availability of redundant safety related systems used for safe shutdown.

.5.5.4 Fire Protection Systems Smoke detectors are provided over the boric acid batch tank and transfer pumps. In the lower areas, smoke detectors are provided in the charging pump area, in the radwaste control board, the motor control center cabinet and in the main room at this elevation. Hose stations are provided on each elevation of the auxiliary building. Portable fire extinguishers are available for all areas.

5.5.5 Adequacy of Fire Protection Measures have not been provided to contain lubricating oil spills in the charging pump area. The lack of fire detection prevents prompt response to cable fires in the pipe tunnel.

The lack of readily available hose stations prevents prompt effective extinguishmeht of fires in the'pipe tunnel.

5.5.6 Modifications The licensee has proposed the following modifications. A fire detector will be installed over the motor contr6l center in the lower area. Curbs or drain pans will be provided at the base of the charging pumps and test 5-5

pump to contain lubricating oil spills. A fire shield will be provided between the test pump and north charging pump. Fire detection will be provided in the radwaste baling room and a one-hour fire rated door will be provided between this area and the boric acid injection pump room. A hose reel will be provided with access to the pipe tunnel manholes. Fire stops will be provided for the cable trays which enter the pipe tunnel.

Fire detection will be provided in the pipe tunnel.

We find that, subject to the implementation of the above described modifi cations, the fire protection for the auxiliary building satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

5.6 Turbine Buildin 5.6.1 Safety-Related. quipment The turbine building is divided into five major areas. At the upper elevation the turbine generator deck is open to the environment and forms a ceiling to the remaining areas below. The north area of the lower elevation contains the turbine lube oil systems and is adjacent to.the 4160 volt and 480 volt switchgear rooms. The safety-related equipment in this area consists of a large concentration of electrical cables. The feedwater pumps are located in the east and west areas. The west area also includes the auxiliary feedwater pump and instrument air compressors.

The hydrogen seal oil unit is located in the south area. The safety-related equipment in this area consists of the auxiliary control panel, a motor control center, and electrical cables.

5.6.2 Combustibles The largest concentration of combustibles exist in the turbine lube oil area which contains 15,000 gallons of lube oil and a large quantity of electrical cable insulation. An oil storage shed is located in the east feedpump area. The major combustibles in this area consist of*530 gallons of lube oil and cable insulations. The west feed pump area contains a like quantity of cable insulation and about 40 gallons of lube oil, the majority of which is associated with the feedpump. The major combustibles in the south area are cable insulation and 300 gallons of oil associated with the hydrogen seal oil unit.

5.6.3 Consequences if No Fire Suppression An unmitigated fire in the turbine lube oil area could result in the loss of redundant safe shutdown systems and could spread to the adjacent switchgear rooms and north to the containment penetration areas. An unmitigated fire in the hydrogen seal oil unit.area would damage control functions performed from the auxiliary control panel.

5.6.4 Fire Protection Systems The turbine lube oil reservoir and conditioner are protected by a manual water deluge system. A manual water deluge system is also provided for 5-6

the hydrogen seal oil unit. Smoke detectors are provided over the.lube oil reservoir and conditioner, and over the major cable concentrations in this area. Smoke detectors are also provided in the south end of the building in the exciter area. All areas of the turbine building are protected.by hose stations and portable extinguishers.

5.6.5 Adequacy of Fire Protection The fire protection systems and features are inadequate to prevent major damage to the turbine building structure or to prevent unacceptable damage to electrical cables.

5.6.6 Modifications The licensee has proposed the following modifications. The deluge system for the lube oil reservoir and conditioner will be modified to provide an automatic foam suppression system. Smoke detectors *in this area will be relocated and additional detectors will be installed to provide improved detection for the fire hazards. A sectionalized directed water spray system will be.provided to protect the large concentrations of cable trays in the north turbine building area. Actuation of this system will be provided by the use of line type temperature detectors placed in the cable trays. A fuse link wet pipe sprinkler system will be installed to provide area backup suppression for the large concentration of combustibles in the north turbine area. The north wall of the turbine lube oil area will be upgraded to provide a one-hour fire rating. The north wall and structural steel in the area will be protected by a directed water spray system.

Electrical cable penetrations in the north wall will be sealed to provide one-hour fire rating.

Fire detection will be provided in the oil storage shed in the east feed pump area. The roof and doors of the oil storage shed will be replaced to provide 3-hour rated protection. Fire detection will be provided in the area of the instrument air compressors in the west feedpump area.

The deluge system protecting the hydrogen seal oil unit will be replaced with an automatic foam or water suppression system. A curb will be provided around the hydrogen seal oil unit to contain lubricating oil spills..

Isolation devices will be provided between the steam dump controls of control room panel and the auxiliary control panel to prevent fire damage at the auxiliary control panel from having an impact on the normal steam dump controls. An analysis will be made to evaluate the effect of a fire involving the hydrogen seal oil system on the structural steel of the turbine building without the benefit of a fire suppression system.

Recent modifications have been initiated or completed in the following areas. A dyke has been installed to enclose the lube oil reservoir and conditioner to prevent an oil spill from covering the entire area. Due to the potential for fire damage to instrument air lines in the vicinity of the lube oil reservoir, modifications have been made to permit the restora tion of air to critical components required for safe shutdown. An air 5-7

accumulator has been providedto insure the operability of salt water cooing pump discharge valve.

An alternate source of instrument air has been piped at the locations to permit a readily available backup source -o instrument air to the auxiliary feedpump steam control valve:, auxiliary control panel, and as a source of motive air to two of the steam dump valves. The control air signal tubing for the operation of the steam dump valves from the auxiliary control panel has been rerouted.outside the areas of the lube oil reservoir.

We find that, subject to the implementation of the above described modifica tions,. the fire protection for the turbine building satisfies the objectives identiffed in Section 2.2 of this. report and is, therefore, acceptable.

5.7 Diese! Generator Building 5.7.1 Safety-Related Equipment The dIesel generators,, starting air systems and control equipment are, located itn separate rooms in' the diesel generator building.

The redundant 125 volt dc bus, distribution equipment, and, battery charger is located in the north:diesel generator room. A separate room., therein, encloses the dc batteries.. Two small rooms are provided for the diesel air intake filters fn each diesel generator room.

5-.7.2 Combustibles.

The major combustibles consist of 550 gall1ons of fuel oil in the diesel day tanks and 2500 gallons of lube oil for each diesel generator. The diesell aim intake filters contain about 80 gallons of oil each.

5.7.3 Consequences) if No Fire Suppression An, unmitigated fire in the area couiTd result in the loss of a diesel generator unit. The wall separating the, two units would prevent fire damage to the adjacent unit.

In the north room, fire damage could result in the loss of one of the plant dc power, systems.

5.7.4 Fire Protection Systems Each room'fs protected by a dry pipe preaction sprinkler system with fuse

ink heads. A combination of smoke and flame detection signals is used to operate the water supply valves. The detection systems actuate an alarm in the control room. The water supply includes local and remote flow alarms. Recent modifications have been made to maintain the OS&Y valves, supplying these systems, in a locked open position.

5.7.5 Adequacy of Fire Protection The lack of fire detection prevents prompt response to fires in the battery room. Measures have not been provided to detect or contain fires in the air intake filter rooms.

5-8

5.7.6 Modifications The licensee has proposed the following modifications. A fire detector will be provided in the battery room. Curbing will be provided to contain an oil spill within the air intake filter rooms or fire detection will be provided in these rooms.

We find that, subject to the implementation of the above described modifica tions, the fire protection for the diesel generator building satisfies the objective identified in Section 2.2 of this report and is, therefore, acceptable.

5.8 Containment 5.8.1 Safety-Related Equipment The equipment located in containment includes two residual heat removal pumps and heat exchangers, letdown heat exchangers, piping, valves and electrical cables.

5.8.2 Combustibles The major combustibles inside the containment consist of 225 gallons of lubricating oil for each of the three reactor coolant pumps, 1200 lb of charcoal in the atmospheric cleanup system, and electrical cable insulation.

5.8.3 Consequences if No Fire Suppression An unmitigated fire could result in the loss of redundant electrical cables due to the continuity of combustibles which exist by the routing of cables between redundant cable trays. A major oil spill fire could result in damage to shutdown systems.

5.8.4 Fire Protection Systems Smoke detectors are provided over each steam generator, two of the three reactor coolant pumps, and under the pressurizer. Two flame detectors are located on the crane rails above the operating floor. Two manually operated deluge sprinkler systems using borated water from the refueling water pumps are located in the containment. Open head spray nozzles are located above each of the reactor coolant pumps and residual heat removal,pumps.

A hose reel station with 150 feet of hose is located on the refueling floor and is supplied water from the refueling water pumps. Portable extinguishers are located in many areas.

5.8.5 Adequacy of Fire Protection The lack of fire detection in the residual heat removal pump area and at the containment electrical penetration area prevents prompt response to fires in these areas. Adequate means have not been provided to contain oil leakage which could.result in a major fire in the primary coolant pump area. Measures have not been provided to prevent cable fires from propagating to redundant divisions of cable trays.

5-9

5.8.6 Modifications The licensee has proposed the following modifications. Fire detectors will be provided over the residual heat removal pumps, the third reactor coolant pump, and at the containment electrical penetration areas. An oil collection system will be provided for the reactor coolant pumps.

The staff has recommended that fire stops be provided in cable trays which are routed between redundant cable trays. The licensee has proposed to defer action on this recommendation pending the completion of the Systematic Evaluation Program review. We will address the adequacy of the fire protection for the containment upon completion of this review.

5.9 Yard Area 5.9.1 Safety-Related Equipment The safety-related equipment in the yard includes the condensate storage tank, component cooling water pumps and heat exchangers, refueling water storage tank and refueling water pumps, spent fuel pumps, safety injection pumps, station service transformers, and salt water cooling pumps.

5.9.2 Combustibles Combustibles in the yard area include the hydrogen storage system, clean and dirty lube oil storage tanks, oil in transformers, buried fuel oil tanks, a 26-gallon gasoline tank, storage warehouse, trailers, construction equipment, wood sheds and miscellaneous storage.

5.9.3 Consequences if No Fire Suppression An unmitigated oil spill fire in the area of the lube oil storage tanks could result in damage to safety injection pumps and other components in the area. An unmitigated fire at the station service transformers could result in damage to electrical cables and the fire water pumps in this area. The location of the gasoline engine driven screen wash pump presents an exposure hazard to the salt water cooling pumps.

5.9.4 Fire Protection Systems Protection for the yard area is provided by yard hydrants and hose stations for those areas adjacent to the turbine building. A wheeled unit fire extinguisher in the yard area and portable extinguishers are available.

5.9.5 Adequacy of Fire Protection Measures have not been provided to limit the spread of an oil spill fire in the lube oil tank storage area. The station service transformers present an unacceptable exposure fire hazard to safety-related cables and systems.

5-10

5.9.6 Modifications The licensee has proposed to provide the following modifications. A curb will be provided around the clean and dirty lube oil tanks. The volume will be sufficient to hold the contents of the tanks plus an allowance for fire extinguishing media. The station service transformers will be curbed to contain an oil spill.

The combustible oil in the station service transformers will be replaced with a silicone base oil or an automatic deluge system will be provided to protect transformers 2 and 3. A curb will be provided to contain a gasoline spill at the engine driven screen wash pump.

We find that, subject to implementation of the above described modifications, the fire protection for the yard area satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

5-11

6.0 ADMINISTRATIVE CONTROLS The licensee's description of the administrative controls for fire protec tion as contained in his fire hazards analysis report is not sufficient to permit a conclusion by the.staff. We have subsequently recommended that the licensee's administrative controls follow.the NRC guidelines set forth in "Nuclear Plant Fire Protection Functional Responsibilities, Administra tive Controls, and Quality Assurance."

The licensee, by letter dated May 19, 1978, has stated that his program for administrative controls is in conformance with the NRC guidelines, except for a few specific areas where deviations were noted and a justification therefor was provided. By letter dated June-21, 1978 we identified staff concerns and positions on exceptions to the staff guidelines taken by the licensee. During the site visit exit meeting on July 13, 1978, the licentee accepted the staff positions on administrative controls.

We find that the administrative.controls for the fire protection program satisfy the objectives identified in the staff guidelines. This satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

6-1

7.0 TECHNICAL SPECIFICATIONS The Technical Specifications for fire protection were previously modified by Amendment No. 31 issued on March 8, 1978, to include limiting conditions for operation and surveillance requirements for existing fire protection systems and administrative controls. The Technical Specifications have been revised to provide.a five man fire brigade and to permit only the use of the Unit 2 and 3 fire water system in the event that the normal water supply or either of the Unit 1 fire pumps is unavailable. Use of the Unit 1 screen wash pumps as parts of an alternate fire suppression water system has been deleted.

Following the implementation of the modifications of fire protection systems resulting from this review, the Technical Specifications will be similarly modified to incorporate the limiting conditions for operation and surveillance requirements for these modifications.

7-1

8.0 CONCLUSION

The licensee has performed a fire hazards analysis and has proposed certain modifications to improve the fire protection program. Additional modifications have been proposed by the licensee during the course of our review, which are based upon the fire hazards analysis and our onsite evaluation of the fire protection program.

These proposed modifications are summarized in Section 3.1.

In addition, we have concluded that the licensee should implement certain evaluations or improvements related to the fire protection program. These are summarized in Section 3.2. Significant steps are being taken to provide additional assurance that safe shutdown can be accomplished and the plant can be maintained in a safe condition during and following potential fire situations. Additional evaluation of incomplete items, discussed in the preceding sections, will be necessary before we can conclude that the overall fire protection at'ffi San _Oofre 1 facility will satisfy the provisions of BTP 9.5-1 and Appe dix A thereto, which the staff has established for satisfactory long-term fire protection.

We find that the licensee's proposed modifications described herein are acceptable both with respect to the improvements in the fire protection program that they provide and with respect to continued safe operation of the facility, while the remaining items are completed.

In the report of the Special Review Group on the Browns Ferry Fire (NUREG-0050) dated February 1976, consideration of the safety of operation of all operating nuclear power plants pending the completion of our detailed fire protection evaluation was presented. The following quotations from the report summarize the basis for the Special Review Group's conclusion that the operation of the facility need not be restricted for public safety:

"Fires occur rather frequently; however, fires involving equipment unavailability comparable to the Browns Ferry fire are quite infrequent (see Section 3.3 of [NUREG-0050)). The Review Group believes that steps already taken since March 1975 (see Section 3.3.2) have reduced this frequency significantly."

"Based on its review of the events transpiring before, during and after the Browns Ferry fire, the Review Group concludes that the probability of disruptive fires of the magnitude of the Browns Ferry event is small, and that there is no need to restrict operation of nuclear power plants for public safety. However, it is clear that much can and should be done to reduce even further the likelihood of disabling fires and to improve assurance of rapid extinguishment of fires that occur. Consideration should be given also to features.

8-1

that would increase further the ability of nuclear facilities to withstand large fires without loss of important functions should such fires occur."

We recognize that the "Risk Assessment Review Group Report to the U.S.

Nuclear Regulatory Commission," NUREG/CR-0400 (The Lewis Committee Report),

states that this Review Group is unconvinced of the correctness of the WASH-1400 conclusion that fires contribute negligibly to the overall risk of nuclear plant operation. In the Commission's Policy Statement dated January 18, 1979, "NRC Statement on Risk-Assessment and the Reactor Safety Study Report (WASH-1400) in Light of the Risk-Assessment Review Group Report", the Commission indicated on page 3 that it "accepts the Review Group Report's conclusion that absolute values of the risks presented by WASH-1400 should not be used uncritically either in the regulatory process or for public policy purposes and has taken and will continue to take steps to assure that any such use in the past will be corrected as appropriate. In particular, in light of the Review Group conclusions on accident probabilities, the Commission does not regard as reliable the Reactor Safety Study's numerical estimate of the overall risk of reactor accident."

In summary, it is our conclusion that the operation of the facility, pending resolution of the incomplete items and the implementation of all facility modifications, does not present an undue risk to the health and safety of the public based on our concurrence with the Browns Ferry Special Review Group's conclusions identified above,giving due consideration to the Commission Policy Statement, as well as the significant improvements in fire protection already made at the facility since the Browns Ferry fire. These include establishment of administrative controls over com bustible materials and use of ignition sources, training and staffing of a fire brigade, and issuance of technical specifications to provide limiting conditions for operation and surveillance requirements for fire protection systems.

We have determined that the license amendment does not authorize a'change in effluent types or total amounts nor an increase in power level and will not result in any significant environmental impact. Having made this determination, we have further concluded that the amendment involves an action which is insignificant from the standpoint of environmental impact and pursuant to 10 CFR 51.5(d)(4) that an environmental impact statement, or negative declaration and environmental impact appraisal need not be prepared in connection with the issuance of this amendment.

We have concluded, based on the considerations discussed above, that:

(1) because the amendment does not involve a significant increase in the probability or consequences of accidents previously considered and does not involve a significant decrease in a safety margin, the amendment does not involve a significant hazards consideration, (2) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (3) such activities will be conducted in compliance with the Commission's regulations and the issuance 8-2

9.0 STAFF RESPONSE TO CONSULTANTS' REPORT Under contract to Nuclear Regulatory Commission, Brookhaven National Laboratory has provided the services of fire protection consultants who participated in the evaluation of the licensee's fire protection program and in the preparation of the Safety Evaluation Report (SER). Their letter, "Fire Protection in Operating Nuclear Power Stations - San Onofre Unit 1 - Safety Evaluation Report Review," dated January 31, 1979, concurs with the staff conclusions noted in the Safety Evaluation Report.

The consultants' recommendations, which we have not adopted, along with our basis therefore are as follows:

Consultants' Recommendation:

"Electrical valve supervision should be provided on all valves controlling fire water systems and sectionalizing valves. The present proposal of administrative controls or locks is unacceptable."

Staff Response:

The NRC guidelines on valve supervision are given in Appendix "A" of Branch Technical Position (BTP) 9.5-1 of the Standard Review Plan. These guidelines permit, as an alternative to electrical supervision, an administrative program to assure that valves are maintained in the proper position. Such a program includes locking valves with strict key control or sealing valves with tamper proof seals. Periodic inspections are to be performed to verify that the method of securing the valve is intact.

These measures are consistent with the requirements imposed for supervising valves in safety-related systems, and provide adequate assurance that valves are maintained in the appropriate position. The licensee's program for valves supervision is consistent with NRC guidelines. In addition, the plant technical specifications were revised to require a monthly check of all valves in the flow path to fire suppression systems. We find that a significant increase in plant safety would not result from the use of electrical supervision of all valves controlling fire water systems and sectionalizing valves.

Consultants' Recommendation:

"The portable smoke venting equipment is a single large industrial blower and not portable smoke ejectors approved for fire fighting activity. We have recommended two 5000 CFM fire fighting smoke ejectors of the explosion.proof type."

9-1

Staff Response:

The licensee obtained a blower for smoke venting in conformance to the staff guidelines noted in Section 2.2 of this report. Smoke venting capability also would be provided by offsite fire assistance units and the general open construction of the plant reduces the need for such equipment. Therefore, the staff concludes that a significant difference in smoke venting capability would not be provided by conformance to the consultants' recommendation.

9-2

On October 19, 1978, a site visit was made to survey the containment area.

By letter dated October 31, 1978, we sent the licensee a request for action on casualty procedures.

By letter dated October 30, 1978, the licensee responded to the staff request of October 31, 1978.

On October 19, 1978, a site visit was made to survey the containment area.

By letter dated October 31, 1978, we sent the licensee a request for action on casualty procedures.

By letter dated October 30, 1978, the licensee responded to the staff request of October 31, 1978.

By letter dated December 1, 1978, the licensee responded to the staff request of November 17, 1978.

By letter dated January 11, 1979, the licensee provided confirmatory additional information including schedule of final fire protection modifications.

By letter dated January 15, 1979, the licensee provided the conceptual plan for safe shutdown and the implementation schedule for associated plant modifications.

By letter dated January 31, 1979, we received the consultant's Fire Protection Report.

A-3