Text

Safety Evaluation Re Fire Protection of Public Health & Safety from Radiological Consequences
	ML17174A561
Person / Time
Site:	Dresden
Issue date:	03/31/1978
From:	; Office of Nuclear Reactor Regulation
To:	;
References
	NUDOCS 8011210009
	Download: ML17174A561 (56)
	v • d • e

...

~

SAFETY EVALUATION REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION U.S. NUCLEAR REGULATORY COMMISSION IN THE MATTER OF COMMONWEALTH EDISON COMPANY DRESDEN NUCLEAR POWER STATION UNITS 2 AND 3 DOCKET NO. 237/249 March 1978 F

/

1 TABLE OF CONTENTS PAGE

1.0 INTRODUCTION

1-1

2. 0 FIRE PROTECTION GUIDELINES.........................................

2-1

2. l Overall Objectives........................ *....................

2-1 2.2 General Design Criterion 3 - Fire Protection..................

2-1 3.0

SUMMARY

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

3-1

3. 1 3.2 Modi fi cations.................................................

3. 1. 1 Fire Detection Systems.................................

3.1.2 Smoke Detection Systems Tests..........................

3.1.3 Fire Water Supply.......................................

3.1.4 Hose Stations..... *........................ *.............

3.1.5 Water Suppres-sfo1r Systems.~-.-~.-=-~.:-.. :.*..................

3. l.*6 Gas Suppression Systems....... ;........................

3.1. 7 Portable Extinguishers.... ;........ ;.... -...............

3.1.8 Fire Doors.................... ;.........................

3.1..9 Supervision of Fire Doors..............................

3. 1. 10 Fi re Dampers.......................................... *.

3. 1. 11 Protection *for* Structures..............................

3. 1. 12 Portable Ventilation Equipment.........................

3. 1. 13 Breathing* Apparatus....................................

3. 1. 14 Cable Tray Fire Stops..................................

3.1.15 Control of Combustibles................................

3.1.16 Water Damage Protection............ :...................

3.1:17 Enclosures... :..........................................

3. 1.18 Fire Barriers..........................................

3. 1. 19 Cable Access......... :.................................

3.1.20 Fire Retardant Coatings.......... ~******...............

3.1.21 Manual Actuatio~ Station...............................

3.1.22 Cable Separation;......................................

3. 1. 23 Yard Hydrants..........................................

Incomplete Items..............................................

3. 2. 1 3.2.2 3.2.3 3.2.4 Administrative Controls.......................... -*....

Radiological Consequences of Fires.....................

Cable Penetration Fire Barrier Tests...................

Shutdown Capabi 1 ity....................................

3-1 3-1 3-2 3-2 3-2 3-3 3-3 3-4 3-4 3-4 3-4 3;_5 3-5 3-5 3-5

3-5 3-5 3-6 3-6 3-6 3-6 3-6 3-6 3-7 3-7 3-7 3-7 3-7 3-7

TABLE OF CONTENTS (Continued) 4.0 EVALUATION OF PLANT FEATURES.......................................

4-1

4. 1 Safe Shutdown Systems.........................................

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

4-1

4. 3 Fire Control Systems...... :..... :...............................

4-2

4. 3. 1 Water Systems..........................................

4-2 4.3.1.l 4.3.1.2 4.3.1.3 4.3.1.4 4.3.1.5

4. 3. 1. 6 Water Supply..................................

Fi re Pumps....................................

Fire Water Piping System......................

Interior Fire Hose Stations...................

Automatic Sprinkler.Systems...... :............

Effects of Suppressi.on Systems on Safety Systems.....................................

4-2 4-2 4-3 4-4 4-4 4-4 4.3.2 Gas Fire Suppression Systems...........................

4-4 4.3.3 Portable Fire Extinguishers........ ~*******************

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

4-~

4. 4. 1 Venti 1 at ion Systems....................................

4-5 4.4.2 Breathing Equipment........... ~.................... *....

4-5

4. 5 Floor Drains.............. *....................................

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

4-6

4. 7 Communications Systems........................................

4-6

4. s*

Electrical Cables.............................................

4-6

4. 9 Fire Barrier Penetrations*.....................................

4-7

4. 10 Separation Criteria...........................................

4-7 4.. 11 Fi re 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 Reactor Building........................ ~.....................

5-1

5. 1. 1

5. 1. 2

5. 1. 3

5. 1. 4

5. 1. 5

5. 1.6

5. 1.7

. 5. 1. 8 Basement Floor (Elevation 476 feet)....................

Ground Floor (Elevation 517 feet)......................

Mezzanine Floor (Elevation 545 feet)...................

Main Floor (Elevation 570 feet)........................

Floor Elevation 589 feet...............................

Refueling Floor (Elevation 613 feet)...................

Corner Rooms (Elevation 517 feet)......... ;............

High Pressure Coolant Injection Pump Rooms.............

5-1 5-1 5-2 5-3 5-5 5-5 5-6 5-7

TABLE OF CONTENTS (Conttnued)

PAGE 5.2 Primary Containment...........................................

5-7

5. 3 Control Room.............................................. *....

5-8 5.4 Auxiliary Electrical Equipment Room...........................

5-10

5. 5 Sv.ii tchgea r Rooms..............................................

5-11

5. 6 Unit 2 Battery Room..........................................

5-11

5. 7 Unit 3 Battery Room............................................

5-12

5. 8 Diesel Generator Rooms...................... *....... :..........

5-13 5.9 Turbine Building..............................................

5-14

5. 9. 1 5.9.2 5.9.3 5.9.4 5.9.5 5.9.6 5.9.7 Basement Floor (Elevation 469 feet and 481 feet).......

Floor Elevation 495 feet...............................

Unit 3 Cable Tunnel....................................

Ground Floor (Elevation 517 feet)......................

Mezzanine Floor (Elevation 538 and 534 feet)...........

Floor (Elevation 549 feet).............................

Main Floor (Elevation 561 feet)........................

5-14 5-15 5-15 5-16 5-18 5-19 5-20

5. 10 Radwaste Building............................... '."............

5-21 5.11 Off-Gas Recombiner Area................... ~...................

5-21

5. 12 Pump House....................................................

5-22 5.13 Yard*Area.................. :...................................

5-23 5.14 Off-Gas Filter Building....................... *................

5-23

~:*;;:~;:::::5. 0 ADMINISTRATIVE CONTROLS................. ~..........................

6-1

---* 7. 0 TECHNICAL SPECIFICATIONS...........................................

7-1

8. 0 CONCLUSIONS.............. *....................................,.....

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

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

A-1 APPENDIX 8 CONSULTANTS REPORT... ~.................*..................... B-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, 11 Recommendations Related to Browns Ferry Fire, 11 NUREG-0050.

'This report recommended that improvements in the areas of fire preventi6n 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 1 s recomg mendations, 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 pJants which.reflect the recommendations in NUREG-0050.

These guidelines are contained in the following documents:

11Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants, 11 NUREG-75/087, Section 9.5. 1, 11 Fire Protection, 11 May 1976, which includes "Guidelines for Fire Protection for Nuclear Power Pl ants, 11 (BTP-APCSB 9. 5-1), May 1, 1976.

11Guidelines for Fire Protection for Nuclear Power Plants, 11 (Appendix A to BTP-APCSB 9.5-1), August 23, 1976.

11Supplementary Guidance on Information Needed for Fire Protection Program Evaluation, 11

September 30, 1979.

11 sample Technical Specifications, 11 Mriy l?., 1977.

11 Nuclear Plant Fire Protection Functional Responsibilities, Administra-tive Controls and Quality Assurance,~

1 June 14, 1977.

All licensees were requ~sted to:

(l) 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 1s analyses and have visited the plant to examine the relationship of safety-related components, systems and struc-tures with both combustibles and the associated fire detection and suppres-sion systems.

Our review was based upon the licensee 1 s proposed program for fire protection as described in the following docketed information:

(1) 11 Fire Protection Report, 11 dated March 29, 1977, and revision by letter dated August 19, 1977; 1-1

(2)

The fire protection review team's site visits of Jai:iuary 10 to 14, 1977.and May 23, 1977; (3)

The licensee's response to request for additional information dated July 19, August 8, September 9 and 29, Novemb~r 15, December l~ and 29, 1977, and January 25, 1978.

Our review has been 11mited to the aspects of fire protection relateq to the protection of public health and safety from the* standpoint of radio-logical cons~quences.

We have not considered aspects of fire protection associated with safety 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 results of our evaluation of the fire protection program at Commonwealth Edison Company's Dresden Units 2 and 3.

The chronology of our evaluation is summarized in Appendix A of this report.

1-2

l 2.0 FIRE PROTECTION GUIDELINES 2.1 Overall Objectives The-overall objectives of the fire protection program in a nuclear power plant are to:

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

2.2 General Design Criterion 3 - Fire Protection The Commission 1 s basic criterion for fire protection is set forth in General Design Criterion 3, Appendix A to 10 CFR Part 50; which states:

~*~----------

11Structures, systems and components important to safe.ty shall be designed and located* to minimize~ consistent with other safety require-ments, the probability and effect of fires and explosions.

11 Noncombustible and heat resistant materials shall be used wherever practical throughout the units, particularly in locations such as the containment and the ~ontrol room.

11 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.

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

11 Guidance on the implementation of General Design Criterion 3 for existing nuclear power plants is provided in Appendix A of Branch Technical Posi-tion 9.5-1, 11Guidelines for Fire Protection for Nuclear Power Plants.

11 We have used the guidance in Appendix A where appropriate.

We have also evaluated alternatives proposed by the licensee to assure that the overall obj2ctives outlined in Section 2. 1 are met for the actual relationship of combustibles, safety-related equipment, and fire protection features.

2-1

(~.-:.......

3.0

SUMMARY

OF MODIFICATIONS AND INCOMPLETE ITEMS

3. l Modifications

3. 1. 1 Th~ licensee plans to make certain plant modifications to improve the fire protection program as a result of the licensee's and the staff's evaluation.

Such 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.

AJl modifications will be completed by startup following the l979_Dresden 3 refueling outage.

Certain items listed below are marked with an asterisk to indicate that the NRC staff will require additional information in the form of design details to assure that the design is acceptable prior to actual implemen-tation of these modifications.

The balance of the other modifications has be~n described in an acceptable level of detail.

Fire Detecticin Systems~

Early warning automatic fire detection systems will be provided in the following areas.

(l) In the area of safety-related motor control centers on the reactor building ground floor (5. 1.2).

(2).In the area of the 4kV switchgear 23-1, 24-1, 33-1, and 34-1 (5. 1:3).

(3)

In the area of the 480V switchgear 28, 29, 38, and 39 (5. 1.4).

(4)

In the area of 250V DC motor control centers 2A, 28, 3A, and 38 (5.1.4).

(5)

In the area of the standby liquid control system (5. 1.5).

(6)

Reactor building refueling floor (5. 1.6).

(7)

In the consoles and control boards and in the general areas of the control room (5.3).

(8)

In the Unit 2 battery room and battery enclosures (5. 6).

(9)

In the Unit 3 battery room (5. 7).

(10) Unit 3 cable tunnel (5.9.3).

(11) In the area of 4kV switchgea~ 31 and 32 (5.9.4).

(12) In the area of 480V switchgear 25, 26, 35, and 36, the fire detection system will be extended west of switchgear 25 and 26, and east of switchgear 35 and 36 to provide detection in the areas of redundant cable trays (5.9.4).

3-1

3. l.3 3.1".4 (13) In the area of 4kV switchgear 21, 22, 23, 24, 33, and 34 (5.9.5).

Smoke Detection Systems Tests The licensee will confirm that the preoperational tests demonstrate.

the adequacy of smoke detection systems or in situ tests will be con-ducted with a suitable smoke generation device to verify that a fire would be promptly detected by installed smoke detectors and that venti-lation air flow pattern*s in the area do not significantly reduce or prevent detection response.

Bench tests will be conducted to verify that smoke detectors wi 11 provide prompt response and have adequate sensitivity to the products of combustion for the combustibles in the area where smoke detectors are installed (4.2).

Fire Water Supply*

Additional fire pump capacity will be provided to supplement the Unit 1 fire pump such that the capability exists to meet the largest Unit 2 and 3 water demand plus 750 gprn for hose streams with the shortest leg of the fire water piping system out of service (4.3. 1.2).

All shutoff, isolation, and sectionalizing valve~ which would isolate the water supply to hose stations or fixed ~uppre~sirin systems in the fire water system will be either locked open or provided with tamper proof seals.

These valves will be periodically checked to insure that they are open (4.3.1.3).

A means of leak detection for the fire water system will be provided (4.3.1.3)..

Hose Stations Additional hose stations will be provided ~t the following locatfons:

(1) *Column row 43N on the reactor building main floor (5.1.4).

(2)

At the entrance to the control room (5.3).

(3)

At the entrance to the auxiliary electrical equipment room (5.4).

(4)

In the area adjacent to the Unit 2 battery room (5.6).

(5)

Near the swing diesel generator room (5.8).

(6)

In the area of switchgear 23 and 24 (5. 9. 5).

(7)

Column 55 and turbine building centerline on the mezzanine floor (5.9.5).

(8)

Turbine building floor elevation 549 feet (5.9.6).

3-2

j'

3. 1. 5

3. l.6 Additional hose will be added to the hose stations near the following locations~

(1)

Column row 45N and 44L on the reactor building main floor (5. 1.4).

(2)

Column row 49E on the turbine building basement floor (5.9. 1).

(3)

Near the Unit 2 and Unit 3 feedwater pumps (5.9.3).

Water Suppression Systems (1) A water deluge system will be installed in the high pressure coolant injection room (5. 1.8).

(2)

The turbine building wet pipe sprinkler system at elevation 495 feet will be extended to cover the control rod drive feed pumps and the containment cooling service water pumps (5.9.2).

(3)

The sprinkler system in the Unit 3 cable tunnel will be modified to adequately protect the cables in this area (S.9.3).

(4) A fixed water suppression system will be installed in the vi ci n*i ty of the Unit 2 and Unit 3 trackways (5.9.~).

(5) A fixed water suppression system will be installed in the vicinity of the EHC oi 1 reservoirs (5.9.4).

(6) A fixed water suppression system will be installed in the vicinity of the Unit 2 instrument air compressor (5.9.4).

(7)

The existing sprinkler system will be extended to provide adequate coverage for the cable concentrations along the east end of the south wall (5.9.5).

(8)

A spray nozzle will be provided to ~over the pump on Unit 3 hydrogen seal oil unit (5.9.5).

(9)

A sprinkler system will be installed to cover the fire pump diesel and fuel oil storage tank (5. 12).

(10) The bus duct penetration nearest to the reserve auxiliary transformers*

22 and 32 will be protected with a directed water spray system whose feed is independent of the feed to the existing deluge systems (5. 13).

Gas Suppression Systems The auxiliary electrical equipment and computer rooms will be protected by an automatic Halon suppression system and will be backed up by a manually actuated carbon dioxide suppression system (5.4).

3-3

'I

... 3. 1. 7

3. 1. 8

~

.~:-~:-~~~:_:_J

1. 9

3. 1. 10 Portable Extinguishers Portable extinguishers suitable for fighting Class A hazards will be pro-vided at the entrance to the auxiliary electrical equipment room (5.4).

Fire Doors Fire doors will be provided with Clas: A ratings at the following locations:

( 1)

(2)

(4)

(5)

(6)

(7)

(8)

Between the Unit 2 and Unit 3 reactor buildings (5. 1.2) (5. 1.3)

(5.1.4) (5.1.5).

Between the corner rooms and the high pressure coolant injection pump rooms (5. 1. 7)_.

Control room (5.3).

Auxiliary electrical equipment room (5.4).

Diesel generator.rooms (5.8).

Between the turbine building and radwaste building (5.9.4) (5:.9.*5)_. --

Between the turbine building and reactor building (5.9.7).

Turbine building access to transformers 21 and 22 (5. 13).

Supervision of Fire Doors Fire doors protecting safety-related areas will be electrically supervised, locked closed, or administratively controlled to insure that they will be effective to limit fires from spreading between fire areas (4.9).

Electrical supervision will be provided to actuate an alarm for doors to areas protected by automatic gas suppression systems (4.3.2).

Fire Dampers Ventilation openings in fire barriers protecting safety-related areas will be modified to provide protection equivalent to the fire barrier or a maximum fire rating of three hours.

The following areas will be provided with fire dampers:

(1)

Control* room (5.3).

(2)

Computer room (5.4).

(3) Auxiliary electrical equipment room (5.4).

(4)

Turbine building - clean and dirty oil room (5.9.4).

(5)

Diesel generator rooms (5.8).

(6) Off-gas recombiner area (5. 12).

The fire damper located in the ventilation duct above the roof of the Unit 2 diesel generator room will be relocated to the fire barrier opening or 3-4 L_ ______

3. 1. 11 3.1.12

3. 1. 13

3. 1. 14 3.1.15 3.i.16 three-hour fire rated protection will be provided for the vent duct to the fire damper (5.8).

Protection for Structures Structural steel supporting the walls and ceiling of the diesel generator rooms will be coated to provide three-hour fire protection (5.8).

Exposed structural steel in the floor of the control room will be coated*

with a flame retardant coating (5.3).

Portable Ventilation Equipment Portable ventilation equipment will be provided and procedures will be developed for its *use by the fire brigade such that smoke can be vented from enclosed areas to permit access for manual fire fighting (4.4).

Breathing Apparatus The supply of breathing apparatus for the fire brigade or control room personnel is being upgraded to provide a minimum of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> (4.4).

Cable Tray Fire Stops Fire stops will be. installed in cable trays which provide a continuity of combustibles between two different divisions of safety-related cables.

Fire retardant coatings will be applied to cables on each ~ide of the fire stops for a distance of three feet in horizontal trays and five feet in vertical trays, where stacked or open cable trays exfst (4.10).

Control of Combustibles The false ceiling and th~ rug in the control room will be replaced with suitable.fire resistant materials (5.3).

Curbs will be provided at the entrance to the auxiliary electrical equip-ment room (5.4).

Air flow alarms will be provided to alarm loss of Jentilation air flow from the battery rooms (5.6) (5.7).

Curbs will be provided for the diesel generator room and day tank room doors (5.8).

Curbs will be provided for the motor generator set areas (5.9.7).

Water Damage Protection The top of electrical equipment located near a redundant division of cable

trays will be sealed to prevent water damage (4.3.1.7) (5.1.2) (5.1.4)

(5.4) (5.9.4) (5.9.5).

3-5

3.1.17 3.1.18

3. 1. 19

3. 1.20

3. 1. 21

3. 1.22 Enclosures An enclosure of one-hour fire rated construction will be installed to enclose the batteries from the rest of the Unit 2 battery room (5.~).

Fire Barriers The barrier wall at elevation 545 feet between switchgear numbers 23 and 24, 33 and 34 will be extended to the underside of the metal* water shield (5.1.3).

The entrance to the Unit 3 cable tunnel will be isolated from the auxiliary electrical equipment room by a 3-hour fire barrier (5.4).

Piping penetrations in the diesel generator rooms including the Unit 2 and Unit 3 diesel generator exhaust duct will be sealed (5.8).

The louvered doors to the diesel generator rooms will be protected with a 3-hour fire barrier (5.8).

Cable Access Access will be provided to permit the appl1cation of extinguishing agents on cables in risers in the control room (5.3).

A fire ladde~ will be provided in the controi room to provide access to cable tray fires (5.3).

Fire Retardant Coatings Fire retardant coatings will be applied to cables in the auxiliary elec-trical equipment room and at 4KV and 480V switchgear and motor control centers where the separation of redundant cables is less than five feet vertically and three feet horizontally (5.4) (5.9.4).

Manual Actuation Station The push button station for the manual initiation of the Hydrogen Seal Oil deluge system will be relocated away from the fire area (5.9.5).

Cable Separation The DC feed cable from the Unit 3 battery to the Unit 2, Division 2 DC bus will be rerouted (4.10).

The cable from the shared battery charger to the Unit 3 battery will be disconnected and a spare charger provided for the Unit 3 battery (4. 10).

The reserve DC fe-eds to equipment will be maintained deenergized at the supply and load end of the circuit (4:10).

3-6

3. 1.23 3.2

3. 2. 1 3.2.2 3.2.3 3.2.4 Yard Hydrants Where the location of post indicator valves limits the rotation of a hydrant stem wrench, a ratchet stern wrench will be provided.

The hydrant stern nuts will be replaced where they are damaged.

Damaged barricades protecting hose houses and post indicator valves will be repaired.

Hose houses will be equipped in accordance with the recommendations of NFPA-14 (4.3.1.3).

Incomplete Items In addition to the licensee's proposed modificationsj 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 Tabl~ 3.1.

T~is schedule has been established such that should these evaluations identify the need for additional modifications, they can be implemented on 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.

Administrative Controls The licensee will provide _a descr.iption of~his administrative cont.rols fo_r fire protection.

Following the receipt of this information, an evaluatfon will be made by the staff (6.0).

Radiological Consequences of Fires The licensee will provide an analysis of the radiological consequences of fires in off-gas filter area (5. 15).

Cable Penetration Fire Barrier Tests The licensee will provide a description of the test program for cable penetration fire stops and subsequent test results.

Shutdown Capability The licensee will confirm that the capability exists to safely shutdown in areas where redundant systems could be damaged by fires or an alternate means for safe shutdown will be provided (4. 1).

3-7

(

Table 3. 1 Schedule of Licensee Submittals item 3.2. 1 Administrative Controls 3.2.2 Radiological Consequences of Fires 3.2.3 Penetration Fire Barrier Tests

a.

b.

Test Program Test Results 3.2.4 Shutdown Capability 3-8 Schedule June 1, 1978 June l, 1978 April 15,' 1978 July l, 1978 July 1, 1978

l 4.0. EVALUATION OF PLANT FEATURES

4. 1 Safe Shutdown Systems 4.2 There are several arrangements *of safe shutdown systems which are cap2ble of shutting down the reactor and cooling the core during and subsequent to a fire.

The exact arrangement available in a fire situatioh will depend upon the effects of the fire on such systems, their power supplies, and control stations.

To preclude a single event from affecting redundant systems, these systems are separated into two or more safety divisions either of which would be capable of achieving safe *shutdown.

During or subsequent to a fire, safe shutdown could be achieved using safety-related equipment such as:

the reactor trip system; the isolation condenser cooling system or the high pressure core injection system; the depressurization system; demineralized water storage tank; and the contain-ment cooling service water system.

Supporting systems and equipment such as the emergency diesel generators, engineered safety features batteries, service water system,.* di ese 1 generator bui..l ding vent i 1 at ion system, and containment room coolers would also be *required.

The major safety-related components required for safe shutdown are separated to prevent damage.to redundant equipment due to a fire.

However, there are areas of the plant where the physical separation for essential supporting systems or e 1 ectri ca 1 cab 1 es does not pro vi de assurance that redun.dant systems* would not be damaged by a fire.

Although modifications have been proposed to improve the fire protection in these areas, we conclude that

there is a potential risk for fire damage to redundant systems.

The licensee has not determined the consequences of fire damage in such are~s and its impact on the capability for safe shutdown.

These areas will be reviewed for the consequences* of fire damage to redundant systems.

The licensee will confirm that the capability for safe shutdown exists which is independent of systems which could be damaged by a fire in the area or an a 1 ternate means for safe shutdown wi.11 be provided.

These areas are discussed in Section 5.0. of this report.

Fire Detection and Signaling Systems A fire detection and signaling system is provided which transmits alarm and supervisory signals to the control room.

Supervisory signals are provided to indicate the location of affected areas or units.

A backup power source is available to a11 systems from the 125V DC power supply.

The DC supply is connected via the battery chargers to the station 1s emergency AC power supply.

At present, there are a variety of detectors, from fixed temperature to smoke detectors.

The only system designed solely for fire detection is in the control room where smoke detectors are installed in the heat~ng, ventilation and air conditioning system above the control room ceiling.

4-1

1--,

4.3

4. 3. 1 4.3.1. l 4.3~ 1.2 The rema1n1ng detection systems are tied into extinguishi.ng systems.

Thermostais are used for the actuation of deluge systems or co2 systems, with an alarm signal being transmitted to the control room.

Early warning detectors will be ins~alled over a significant number* of switchgear and motor control centers where both divisions are in close proximity to each other.

Smoke detectors will be installed in the cabi-nets and consoles of the control room and also in the general area of the control room.

The licensee will confirm that the preoperational tests demonstrate the adequacy of smoke detection systems or 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 i nstal 1 ed.

We find. that subject to the implementation of the modifications, the fire detection systems satisfy the objectives identified in Section 2. 1 of this report and are, therefore, acceptable.

Fire Control Systems Water Systems Water Supply Fire water is obtained from a canal supplied from the cooling lake or the Kankakee River.

One diesel driven fire pump is located in the Unit 1 crib house, which supplies water to the common yard loop system feeding all three units on the site.

The other diesel driven fire pump is located in the Unit 2/3 crib house which supplies the-same yard loop system.

The total volume of water available for fire protection is adequate.

We find that the fire water supply satisfies the objectives identified in Section 2. 1 of this report and is, therefore, acceptable.

Fire Pumps A diesel-driven 2,000 gpm @ 131 psig vertical shaft fire pump is located in the Unit 2 and 3 crib house adjacent to the service water pumps.

The service water pumps maintain pressure on the fire protection system and are the first line of defense for water supply in a fire situation.

The remaining diesel-driven 1,000 gpm@ 100 psig fire pump is located in the Unit 1 crib house.

The Unit 1 screen wash pumps provide an alternate source of fire water supply for the Unit 1 fire pump.

The Unit 1 fire pump does not have sufficient capacity to meet the largest fire water demand for Units 2 and 3.

The licensee has proposed the installation* of additional fire water pump capacity to supplement the Unit 1 fire pump such that the system has the capability to meet the largest fire water demand for Units 2 and 3, plus 750 gpm for hose streams with the shortest leg of the fire water piping system out of service.

4-2

1-,

4.3.1.3 I '.

We find that, subject to the implementation of the above described modification, the fire pumps satisfies the objectives identified in Section 2.1 of this report and are, therefore, acceptable.

Fire Water Piping System The Unit 1 diesel fire pump and. screen wash pumps supply the 8-inch under-*

ground main which encircles Unit 1, and is connected to the 8-inch loop which encircles Units 2 and 3.

The Unit 2 and 3 diesel fire*pump and service water pumps supply the 8-inch underground main which encircles Units 2 and 3.

A 10-inch discharge feeds directly into the turbine building.

All yard fire hydrants and hose stations in the reactor building are fed from the underground loop.

Manual and automatic water suppression systems in the turbine building are fed by a 10-inch underground main directly from the crib house with a connection to the reactor building Unit 2 and Unit 3 fire water distribution system.

Sectionalizing valves of the post-indicator type are provided on the fiTe loop to provide some degree of flexibility during impairment of the loop.

Outside stem and yoke valves controlling extinguishing systems are electrically supervised.

Remaining valves will be administratively controlled by the use of locks or seals and periodic inspections will be made to verify that the valves are in the proper position.

Yard hydrants have been provided at approximately 300-foot* intervals around the exterior of the plant.

An auxiliary gate valve or sectionaliz-ing valves are provided to permit isolation of each of the hydrants encircling Units 2 and 3.

Hydrants have hose houses equipped with various amounts of 2-1/2 11 hose and 150 feet of 1-1/2 11 hose and other manual fire fighting tools.

The hydrant hose thr~ads are compatible with the local.

fire department's.

Where.the location of post indicator valves limits the rotation of a hydrant stem wrench, a ratchet stem wrench will be providedo The hydrant stem nuts will be *replaced where they are damaged.

Damaged barricades protecting hose houses and post indicator valves will be repaired.

Hose houses will be equipped in accordance with the recommenda-tions of NFPA-14.

The licensee will provide a means of leak detection and will preclude unauthorized usage of the fire water system by administrative control.

The fire water system shall be dedicated to emergency or unusual occur-rences of an infrequent nature.

The fire water system will not be used.

for convenience and house services of a frequent and ongoing nature.

We find that, subject to implementation of the above described modifica-tions, the fire water piping systems satisfy the objectives identified in Section 2. 1 of this report and are, therefore, acceptable.

4-3

4.3.1.4

4. 3. 1. 5 4.3.2 Interior Fire Hose Stations Hose stations are located throughout the pla~t and each is equipped with 50, 75 or 100 feet of 1-1/2 11 woven jacket rubberlined hose.

Some areas are not protected by hose stations.

Hose stations or additional lengths of hose will be provided where interior.fire hose stations do not provide adequate coverage.

We find that, ~ubject to the i~plementation of the above described ~edifica tions, the interior fire hose stations satisfy the objectiv~s identified in Section 2. 1 of this report and are, therefore, acceptable.

Automatic Sprinkler Systems Automatic water suppression systems protect a number of specific hazards in various parts of the plant and a number of general areas in the plant.

Automatic deluge systems protect the yard transformers and oil system equipment in the turbine building.

Automatic sprinkler systems protect certain areas of the turbine building and the cable tunnel.

Modifications to and additional sprinkler systems will be provided as noted in Section.3. 1.5 of this report.

The design of the automatic sprinkler and water spray systems comply with t_he requirements of NFPA standards 13 and

15.

We find that the fi.re protection sprinkler systems satisfy the objectives identified in Section 2. 1 of this report and are, therefore, acceptable.

Effects of *suppression Systems on Safety Systems The presently installed suppression systems will not have an adverse effect on equipment if the system is actuated accidentally or by failure

.of the equipment.

There are areas where the application of water from hose streams to extinguish a fire involving electrical cables in cable trays of one safety-related division may result in water damage to the other division of safety-related electrical equipment.

Where such condi-tions exist, protection will be provided to prevent water damage to safety-related electrical equipment as identified in Section 5.0 of this report.

We find that, subject to the implementation of the above described modi-fications, the effects of suppression systems on safety systems satisfy the objectives identified in Section 2. 1 of this report and are, therefore, acceptable.

Gas Fire Suppression Systems A total flooding automatic carbon dioxide system protects each of the three diesel generators.

The carbon dioxide system is of the low pressure type with a manifold and selector valves for the various areas.

Each of the diesel generators is widely separated from its redundant counterpart.

4-4

L 4.3.3 4.4 4.4. 1 4.4.2 A total flooding automatic halon 1301 system will be installed in the auxiliary*electrical equipment room with a manual carbon dioxide backup system.

Since containment of the suppression agent is essential to the effective extinguishment of fires in these areas, the doors to these areas will be electrically supervised to actuate an alarm, after a suit-able time delay for access or egress.

We find that, subject to the implementation of the above described modi-fications, the gas fire suppression systems satisfy the objectives identifed in Section 2. 1 of this report and,are, therefore, acceptable.

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

In areas containing sensitive electrical equipment, carbon dioxide extinguishers have been installed.

An adequate number of portable fire extinguishers have been provided.

We find that the portable fire extinguishers satisfy the objectives identi-fied in Section 2. 1 of this report and are, therefore, acceptable.

Ventilation Systems and Breathing Equipment 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 by several factors.

The fans ~nd other equipment in the air* handling systems are not des.igned to withstand high temperatures, and can be. rendered inoperative by the heat from a significant fire.

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

The licensee has proposed.the following modjfications.

Portable ~xhaust units and ductwork will be placed at strategic locations to aid in exhiusting of smoke, and procedures will be developed for the use of this portable equ1"'p~ent.

Electrical supervision of the ventilation systems for battery rooms will be installed to provide an alarm on the loss of air flow to preclude the buildup of hydrogen.-

We find that, subject to the implementation of the above described modi-fications, ventilation systems satisfy the objectives identified in Section 2. 1 of this report and are, therefore, acceptable.

Breathing Equipment The emergency air breathing apparatus at Dresden station is being upgraded to provide sufficient supply for five individuals with breathing air for six hours.

The licensee will provide 90 charged bottles for fire brigade use.

Each individual operator in the control room will have a breathing air station which will be supplied from six 300 cubic foot air bottles installed on a manifold system.

The manifold system will provide sufficient air for five individuals for eight hours.

4-5

4.5 We find that, subject to implementation of the above described modifica-tions, the breathing equipment satisfies the objectives identified in Section 2. 1 of this report and is, therefore, acceptable.

Floor Drains Floor drains from the various areas of the plant are routed according to their content.

Areas which contain flammable liquids such as the diesel generato*r rooms drain their oil to an oil/water separator.

The licensee will install a number of curbs at various locations where inadequacies exist at the present time for routing of drainage and to preclude the spreading of fire.

Drains from potentially radioactive areas are analyzed prior to their release.

We find the drain.systems satisfy the objectives identified in Section 2. 1 of this report and are, therefore, acceptable.

4.6 Lightino Systems 4.7 The normal lighting system receives its power from the station auxiliary transformers and a backup source of power is provided by the station diesel generators.

Emergency lighting is also provided which is powered from the 125V DC station batteries.

The licensee has insured the avail-ability of adequate lighting by providing seal beam self-contained battery operated lights at strategic locations throughout the plant.

These units are equipped with carrying handles, thus making them usable as portable emergency lighting.

We find that th~ lighting-systems satisfy the objectives identified in Section 2. 1 of this report and are, therefore, acceptable.

Communication Systems Normal communication is provided by a telephone system with extension handsets at various locations throughout the plant.

A page and answer system is also provided which is connected to an emergency bus which is supplied power from a diesel generator.

A number of voice-powered headset stations provided for maintenance use would be available under emergency conditions.

A radio communication system consisting of two channels for two-way voice communication and repeaters to provide reception throughout the plant is being.installed.

A total of 15 handie-talkie units are available to operating personnel in addition to units used by the plant security force.

We find that the communication equipment to coordinate fire fighting safe shutdown activities during a fire situation satisfy the objectives identified in Section 2. l of this report and are, therefore, acceptable.

4.8 Electrical Cables The cable insulation used in the plant consists of mainly butyl rubber insulated conductors with polyvinylchloride jackets for power and control 4-6.

cables.

The flame test standard for cables, IEEE Std 383, was not in effect at "the time cables were purchased and installed at Dresden Units 2 and 3.

Flame retardant coatings will be appliad on cables in the cable spreading area.

The majority of the cable trays are of solid pan construc-tion.

Ladder rung trays are used primarily where cables enter motor control centers and switchgear.

The fire protection system, including proposed modifications, gives due consideration to the combustibility of electrical cables.

We find that the fire protection for electrical cables satisfies the objectives identified in Section 2.1 of this repor~ and is, therefore, acceptable.

4;9 Fire Barrier Penetrations Fire barriers are penetrated by doorways, ventilation ducts, electrical cables, piping and conduit.

The licensee will conduct a test program to test electrical penetration seals for fire resistance based on typical plant arrangements and designs.

Fire doors for safety-related areas will be either locked closed or administratively controlled to assure that they are maintained in the closed position.

The adequacy of fire barrier penetrations will be addressed in a supple-ment to this report fQllowing the completion of the above described test program.

4.10 Separation Criteria The licensee 1s separation criteria rely upon vertical separation of five feet and horizontal separation of three feet for cable trays.

The criteria relies upon that protection afforded by conduit and sheet metal barriers.

The separation criteria did not limit the routing of nonsafety-related cables to a single separation division.

In some locations a single tray changes classification from one safety-related division to another and non safety-related cables are routed to provide a continuity of combustibles between divisions.

Fire stops will be installed in all such cable trays to prevent a fire in one division from propagating to the other division.

In other situations, nonsafety-related trays join or are routed below two divisions of safety-related trays.

Fire stops will be installed in all such cable trays which form a continuity of combustibles such that fire could spread between two divisions of safety-related trays.

Fire retardant coatings will be applied to cables on each side of the fire stops for a distance of three feet in horizontal trays and five feet in vertical trays, where stacked or open cable trays exist.

The essential power system utilizes two batteries to provide a redundant DC power source which is common to both Units 2 and 3.

Since the essential loads connected to a single battery are assigned to the opposite separation divisions for each unit, the failure to maintain separation between the same division on a unit basis could result in essential cables powered from both batteries being located in the same raceway.

A fire involving the one separation division common to both units could result in 4-7

4. 11

4. 12 the loss of redundant power sources fof both units where credit is not assumed fbr isolation devices operated by fault current.

The licensee has indicated that safety-related cables were separated on a unit basis to prevent such failure modes.

However, in reviewing the separation of cables associated with the shared DC systems, the licensee has noted that the cable which provides power from the Unit 3 battery to the Unit 2, Division 2 DC bus has been routed in the wrong division of cable trays.

This cable will be rerouted to correct this error.

The cable from the spare battery charger to the Unit 3 battery has been found to be incor-rectly routed.

The licensee has proposed to disconnect this cable and to provide a spare battery charger for the Unit 3 battery.

Investigations have been made by the licensee into other areas of the DC system cable routing.

These studies indicate that routing of reserve DC feeds to equipment have not been separated from normal feeds to preclude the potential of fire damage to cables connected to the redundant power sources.

The licensee has proposed to correct this by keeping these cables deenergized at both the source and load end of the cables.

We conclude that the physical separation criteria in itself is inadequate to provide protection for redundant safety-related systems from the stand-point o1 potential fires.

Subsequent sections of this report address existing fire protection measures and the licensee 1 s modifications for upgrading of fire protection in specific areas.

We find that, subject to implementation of the ~edifications identified in Section 3.0 of this report, adequate measures have been taken to compensate for the inadequacies of physical separation.

This satisfies the objectives identified in Section 2.1 of this report and is, theref6re, acceptable.

Fire Barriers Fire areas are enclosed by floors, walls and ceilings which have a 3-hour rating with a few excepti~ns.

In some areas walls are being upgraded to 3-hour rating.

Areas not having a 3-hour rating are found acceptable on the basis of a light combustible loading or that redundant safety-related equipment will not be jeopardized.

Further detail is provided in Sec-tion 5.0 of this report as to which barriers will be upgraded.

We find that, subject to implementation of the above described modifica-tions, fire barriers satisfy the objectives identified in Section 2. 1 of this report and are, therefore, acceptable.

Access and Egress Access to the reactor building is provided by two elevators and three open stairwells.

The elevators are enclosed in 1-hour fire rated construction.

The reactor building is divided by a concrete wall by unit except for the refueling floor elevation which is one contiguous area.

Access openings between units will be protected by 3-hour fire rated doors.

With this separation, adequate protection is afforded to the fire brigade to reach any floor involved in a fire.

In the turbine building access to the various floors is by three open stairwells and one enclosed stairwell.

Due to the distance between stairs, access to various areas is adequate for manual fire fighting and evacuation in all safety-related areas.

4-8

4. 13 We find that the provisions for access and egress satisfy the objectives identified in Section 2. l of this report and are, _therefore, acceptable.

Toxic and Corrosive Combustion Products The products of combustion for many plastic materials are toxic to humans and corrosive to metals.

Prompt fire detection and extinguishment are relied upon to minimize the quantities of such products.

Additional means of smoke removai will be provided as an aid in smoke removal as noted in Section 4.4 of this report.

The fire brigade is provided with and trained in the use of emergency breathing apparatus for fighting fires involving such materials.

We find that the $Ubject of toxic and corrosive products of combustion has been adequately addressed.

This satisfies the objectives identified in Section 2. 1 of this report and is, therefore, acceptable.

il-0

5.0 EVALUATION OF SPECIFIC PLANT AREAS

5. 1 Reactor Building

5. 1. 1 5.1.1.1 5.. 1. 1. 2 5.1.1.3 5.1.1.4 5.1.1.5 The following evaluation is ap~licable to the Unit"2 and Unit 3 reactor buildings.

Basement Floor (Elevation 476 feet)

Safety-Related Equipment Division I and II* cable trays are located in this area.

Combustibles Combustibles in this area consist of electrical cable insulation.

Consequences if No Fire Suppression An unmitigated fire in this area would not~result in the loss of redundant safety-related electrical *cables since *the cable trays are widely separated.

Fire Protection System Fire protection is provided by *hose sta~ions and portable fire extinguishers..

Adequacy of Fire Protection The fire suppression for this area is adequate to control and to suppress a fire in this area.

5. 1. 1.6 Modifications

5. 1. 2 5.1.2.1 5.l.2.2 No modifications have been proposed for this area.'

We find that the fire protection for the reactor building basement floor satisfies the objectives identified in Section 2. 1 of this report and is, therefore, acceptable.

Ground Floor (Elevation 517 Feet)

Safety-Related Equipment The safety-related equipment located in this area includes instrument panels, shutdown cooling pumps, control rod drive hydraulic control units,

. Division I and II cable trays, and motor control centers.

Combustibles Combustibles in this area include cable insulation and lubricating oil.

5-1

5.1.2.3 5.1.2.4 5.1.2.5 Consequences if No Fire Suppression An unmitigated fire in this area could result in the loss of redundant safety-related electrical equipment and cables.

Fire Protection Systems Fire protection is provided by hose stations and portable fire extinguishers.

Adequacy of Fire Protection The manual and portable extinguishing systems are adequate to control a fire in the area.

Motor control centers 28-7 and 39-7 could be damaged by water use to suppress fires in the redundant division of cable trays.

The lack of fire detection prevents prompt response to fires.

As noted in Section 4. 1 of this report, the physical separation for essential supporting systems or electrical cables does not provide assurance that redundant systems would not be damaged by a fire.

The consequ~nces of fire damage in such areas and the impact on the capability to safely shutdown have not been determined.

These conditions exist in the area near the motor control ceriters 28-7 and 39-7.

5.1.2.6. Modifications The licensee has proposed the following modifications.

An.early warning

/,..

fire detection system will be installed in the areas of safety-related motor control centers.

A Class A fire door will be installed between the Unit 2 and 3 reactor buildings.

The top of motor control centers 28-7 and 39~7 will be sealed to prevent water damage.

5. 1. 3 5.1.3.l Where fires could damage redundant safety-related systems, the consequences will be determined to confirm that the capability to safely shutdown exists or an alternate means for safe shutdown will be provided.

We find that, subject to the completion of the modifications and evaluation described above, the fire protection for the reactor building ground f:oor satisfies the objectives identified in Section 2.1 of this report and is, therefore, acceptable.

Mezzanine Floor (Elevation 545 Feet)

Safety-Related Equipment The safety-related equipment in this area includes shutdown heat exchangers, reactor building closed cooling water pumps and heat exchangers, 4kV switchgear, and Division I and II cable trays.

5.1.3.2 Combustibles Combustibles in this area include electrical cable insulation, lubricating oil and paper.

5-2

l

5. l. 3. 3

5. l.3.4 Consequences if No Fire Suppression An unmitigated fire in this area could result in the loss of redundant safety-related equipment and cables.

Fire Protection Systems Fire hose stations and portable ~o 2 extinguishers are located in this area.

5. 1.3.5 Adequacy of Fire Protection 5.1.3.6

5. 1. 4

5. l. 4. l The existing hose stations and portable extinguishers are adequate to control a fire in this area.

The barrier wall between redundant switchgear does not provide an effective fire barrier to prevent a fire from affecting both divisions.

The lack of fire detection prevents prompt response to fires.

As noted in Section 4.1 of this report, the physical separation for essential supporting systems or electrical cables does not provide assurance that redundant systems would not be damaged by a fire.

The consequences of fire damage in such areas and the impact on the capability to safely shutdown have not been determ.ined.

These conditions exist in the area near the 4kV switchgear.

Modifications The license has proposed the following modifications.

An ear1y warning fire detection system wi11* be installed near the 4kV switchgear 23-1, 24-1 33-1, and 34-1.

A Class A fire door will be installed between Units 2 and 3 reactor buildings.

The barrier wall between switchgear numbers 23-1 and 24-1 and 33-1 and 34-1 will be extended to the underside of the metal water shield.

Wher*e fires could damage redundant safety-related systems, the consequences will be determined to confirm that the capability to safely shutdown exists or an alternate means for safe shutdown will be provided..

We find that, subject to the completion of the modifications, and evaluation described above, the fire protection for the reactor building mezzanine floor satisfies the objectives identified in Section 2.1 of this report and is, therefore, acceptable.

Main Floor (Elevatio~ 570 Feet)

Safety-Related Equipment The safety-related equipment within this area includes 480V switchgear, reactor building cooling water expansion tank, and Division I and II cable trays.

5-3

5.1.4.2 5.1.4.3 Combustibles Combustibles in this area include electrical cable insulation.

Consequences if No Fire Suppression A fire in this area could result in the loss of redundant safety-related equipment and cables.

5. 1.4.4 Fire Protection Systems Hose stations and portable co2 fire extinguishers are provided in this area.

5. 1.4.5 Adequacy of Fire -Protection

5. 1. 4. 6 The existing hose stations are adequate to control a fire in this area and to prevent a fire from spreading to other areas, with the exception of two hose stations which have insufficient hose reach and one hose station which was removed.

The lack of fire detection prevents prompt response to fires.. The-480V switchgear could be damaged by water used to suppress fires in the redundant division of cable trays.

As noted in Section 4. 1 of this report, the physical separation for essential supporting systems or electrical cables does not provide assurance-that redundant systems would not be damaged by a fire.

The consequences of fire damage in such areas and the impact on the capability to safely shutdown have not been determined.

These conditions exist in the area of the 480V switchgear.

Modifications

The licensee has proposed.the following modifications.

An early warnirig fire detection system is to be installed in the area of the 480V switchgear 28, 29, 38, and 39 and in the area of the 250V DC motor control centers 2A, 28~ 3A, and 3B.

A class A fire door is to be installed between the Unit 2 and 3 reactor buildings.

An additional 50 feet of hose will be provided at hose stations located near column rows 45N and 44L.

A hose station will be reinstalled at column row 43N.

The top of switchgear 28, 29, 38, and 39 will be sealed to prevent water damage.

Where fires could damage redundant safety-related systems, the consequences will be determined to confirm that the capability to saf~ly

shutdown exists or an alternate means for safe shutdown will be provided.

We find that, subject to the completion of the modifications and evaluation described above, the fire protection for the reactor building main floor ~,

satisfies the objectives identified in Section 2.1 of this report and.is, therefore, acceptable.

5-4

5. 1. 5

.::::'.:::. 5. l. 5. l

5. 1.5.2 5.1.5.3 Floor Elevation 589 Feet Safety-Related Equipment The safety-related equipment within this zone includes the standby liquid control system tank, standby liquid control system pumps, fuel storage pool, and Division I and II cable trays.

Combustibles The combustibles in this area include cable insulation and.lubrication oi 1.

Consequences if No Fire Suppression An unmitigated fire in this zone could result in the loss of two divisions of safety-related cables or the loss of the standby liquid control system.

5. 1.5.4 Fire Protection Systems Fire hose stations and a co2 extinguisher are provided in the area.

5. 1.5.5 Adequacy of Fire Protection The existing hose stations and portable extinguishers are adequate to control a fire in the area.

The lack of fire detection in the standby liquid control area prevents prompt response to a fire.

. <....... 5.1.5:6 Modifications

5. 1. 6 5.1.6.l 5.1.6.2 The licensee has proposed the following modifications.

An early warn~ng fire detection system will be installed in the standby liquid control system.

The passageway doors between Units 2 and 3 wil*l be replaced with class A fire doors.

We find that, subject to implementation of the above described modifica-tions, the fire protection for the reactor building floor elevation 589 feet satisfies the objectives identified in Section 2. l of this report and is, therefore, acceptable.

Refueling Floor (Elevation 613 Feet)

Safety-Related Equipment The safety-related part of this area is the fuel storage pool.

Combustibles Combustibles in this zone include lubrication oil, cable insulation, duct insulation, and glass fiber roll filters.

5.1.6.3. Conseauences if No Fire Suppression A fire in this area would not affect systems required for safe shutdown.

The spent fuel pool is located in this area.

5-5

5.1.6.4 5.1.6.5 Fire Protection System Fire hose stations and co2 portable extinguishers are located in this area.

Adequacy of Fire Protection The hose stations and portable extinguishers are adequate to control any fire which might occur in this zone.

The lack of fire detection prevents prompt response to fires.

5. 1.6.6 Modifications

5. 1. 7 5.1.7.l The licensee has proposed the installation of a fire detection system to provide warning of a fire in this area.

We find that, subject to the implementation of the above described modification, the fire protection for the refueling floor satisfies the objectives identified in Section 2. 1 of this report and is, therefore, acceptable.

Corner Rooms (Elevation-517 feet)

Safety-Related Equipment Safety-related equipment in each area include core spray pump, low pres-sure coolant injection/containment cooling heat exchanger, pumps, emergency air cooler, and instrument racks.

iiiiiiiiiiiiJ.1. 7. 2 Combusti b 1 es Each ~rea contains cable insulation and some lubrication oil.

_So 1~7.3 Consequences if No Fire Suppression The fire i~ these areas could result in the loss of one train of low pressure coolant injection/containment cooling equipment.

5. 1.7.4 Fire Protection System Portable C07 and dry chemical extinguishers and a hose station are provided for each area.

5. 1.7.5 Adequacy of Fire Protection The fire suppression for each area is adequate to control a fire in the area.

The existing doors to the adjacent high pressure coolant injection pump areas are inadequate to prevent an exposure fire hazard.

5. 1.7.6 Modifications The licensee will replace the existing access doors to the high pressure coolant injection pump area with Class A fire doors.

5"-6

5. 1.8 5.1.8. l

5. l. 8.. 2

5. 1.8.3 5.l.8.4 5.l.8.5 5.1.8.6 5.2

5. 2. 1 5.2.2 We find that, subject to implementation-of the above described modifica-tion, the.fire protection for the corner rooms sat,isfies the objectives identified in Section 2.1 of this report and is, therefore, acceptable.

High-Pressure Coolant Injection Pump Rooms Safety-Related Equipment Safety-related equipment in this area include the high pressure coolant injection pumps and their auxiliary systems.

Combustibles Combustibles in this area include a large amount of lubricating oil, some duct insulation, wire mesh filters and lubricating grease.

Consequences if No Fire Suppression The consequences of an unmitigated fire in these areas would be the loss of the high pressure coolant injection system and the possible spread of fire to other areas_of the plant.

Fire Protection Systems The area is served by portable co,, dry chemical extinguishers and a hose station in the adjacent corner rooms.

Adequacy of Fire Protection The fire protection provisions in this room are not adequate to control or to prevent spread of fire to other areas of the plant.

Modifications The licensee will install a water deluge sjstem for the high pressure cooTant injection pump room.

The access doors will be replaced with Class A fire doors as noted in Section 5. 1.7.6.

We find that, subject to implementation Qf the above described modifica-tions, the fire protection for the high pressure coolant injection pump rooms satisfies the objectives identified in Section 2. 1 of this report and is, therefore, acceptable.

Primary Containment Safety-Related Equipment The safety-related equipment in this area includes control rod drives, containment isolation valves and safety/relief valves.

Combustibles Combustibles in this zone include 50 gallons of lubricating oil for each recirculation pump and cables routed in the conduit.

5-7

5.2.3 5.2.4 5.2.5 5.2.6

- -*:... 5. 3

5. 3, 1 5.3.2 5.3.3 Consequences if No Fire Suppression During normal plant ope.ration the primary containment has an inert atmo-sphere which would prevent initiation of a fire.

During refueling opera-tions, the plant is shutdown and fires would ~ot result in damage to prevent maintaining the plant in a safe condition.

Fire Protection System Fire protection for the containment is provided by hose stations and portable extinguishers located near the containmen~ entrance.

Drains are provided to mitigate the consequences of an oil spill fire.

The contain-ment sprays would be adequate to suppress an oil spill fire.

Connections are provided to a demineralized water source for temporary connections of fire hoses.

Adequacy of Fire Protection The fire protection for the containment is adequate to m1n1m1ze the poten-tial fire damage to equipment and cables in the containment.-

Modifications The 1 i censee has not proposed any modifi cations for the prima~y ~contai nme_nt.

We find that the fire protection for the primary containment satisfies the objectives identified in Section 2.1 of this ~eport and is, therefore~

acceptab 1 e.

Control Room Safety-Related Equipment Tr1e control room contains. the controls necessary for station operation and for safe reactor shutdown.

Operating indication, controls and alarms are mounted on two L-shap*ed wa l kthrough contra l boards, one for each unit.

The rear sections of the control boards include the reactor protection system.

Combustibles The combustibles in the control room consist of electrical cable insula-tion, electrical wiring within the control boards, floor covering, a luminous false ceiling and paper consisting of operating procedures.

Some paper is located in sheet metal filing cabinets.

Cables are located in trays above the control boards.

Consequences if No Fire Suppression An unmitigated fire in the control room has the potential for damaging significant amounts of safety-related equipment within both divisions of safety-related system4.

5-8

5.3.4

~:*.:::*.:::.

5. 3.. 5 5.3.6 Fire Protection Systems Smoke detectors are located in the heating and ventilating return air duct from the control room and above the luminous ceiling.

Portable CO fire extinguishers and a ten-pound portable halon fire extinguisher are2provided in the control room with additional extinguishers located in close proximity outside the control room including dry chemical and a 2-1/2 gallon water tank pump unit.

A fire water hose reel station is located outside the control room.

Adequacy of Fire Protection The present fire protection for the control room is inadequate.

The false cei 1 i ng and floor covering both present an unnecessary contribution to the fire loading in the area.

Some sections of the control board do not have barriers or sufficient separation to insure that a fire would not result in damage to redundant safe shutdown systems.

No ready means is provided to permit fire fighting access to cables installed in raceways above the control boards.

In addition to the access problem for these cable trays, a potential fire in this area would seriously threaten the occupancy of the control room.

The present fire detection system is inadequate to provide prompt response to permit extinguishrnent to limit potential damage to safety-related systems.

Door openings and ventilation penetrations of the control room fire area* boundary are* inadequate to prevent an exposure fire from entering this area.

As noted in Section 4.1 of this report, the physical separation for essen-tial supporting systems or el~ctrical*cables does not provide assurance that redundant systems would not be damaged by a fire.

The consequences of fire damage in such areas and the impact on the capability to safely shutdown have not been provided by the licensee.

Modifications The licensee has proposed the. following modifications.

The floor covering and false ceiling will be replaced with suitable fire resistant substitute materials.

A f1re ladder will be provided to permit fire fighting access to cables above the control boards.

An engineered fire detection system will be installed in the consoles and control boards and in the general areas of the control room.

Access doors will be replaced with 3-hour fire rated class A doors.

Fire rated dampers will be installed in ventilation ducts penetrating the area fire barriers.

Exposed structural steel in the floor will be coated with a flame retardant coating.

The control room will be provided with a fire water booster hose station with a low flow nozzle to reach all areas of the control room.

Access will be provided in enclosed cable risers to permit the* application of extinguishing agents on cable insulation fires.

Since fires could damage redundant safety-related systems, the consequences

. will be determined to confirm that the capability to safely shut down exists or ~n alternate means for safe shutdown will be provided.

We find that, subject to completion of the modifications and evaluation described above, the fire protection for the control room satisfies the objectives identified in Section 2. l of this report and is, therefore, acceptable.

5-9

5.4

.. :::::.. 5. 4. 1 5.4.2 5.4.3 5.4.4 5.4:5 5.4.6 Auxiliary Electrical Equipment Room Safety-Relpted Equipment The cable spreading area is located below the control room in the auxiliary electrical equipment room and includes redundant divisions of electrical cables.

The plant computer which is not safety-related is enclosed in a separate area within the room_.

Safety-related equipment located in the area includes the reactor protection and essential service motor generator sets and their associated control cabinets.

Electrical cab~nets are located in the area which contain protective relays, core cooling relays and reactor system switch centers.

Combustibles The combustibles in this area consist of a large quantity of electrical cable insulation, electrical wiring in electrical equipment panels and paper located in the plant computer room.

Consequences if No Fire Suppression An unmitigated fire in the cable spreading area would damage redundant systems required for safe shutdown with unacceptable consequences.

A.

severe fire would threaten the support of ihe control room floor due to the exposed structural steel in the cable spreading room.

Fire Protection Systems A smoke detector i~ installed in the.return ventilation duct from the area.

Portable carbon dioxide extinguishers are provided in the area.

Adequacy of Fire Protection The fire protection for the cable spreading_area is inadequate.

The available. fire suppression is inadequate to extinguish a fire in the cable spre~ding ~rea.

The smoke detection in this area is inadequate to give early warning of a fire.

Door openings and ventilation penetrations from and to the adjacent areas are unprotected resulting in an exposure hazard.

The wall facing Unit 1 turbine building does not have a fire rating suf-ficient to prevent an exposure fire hazard from that area.

The plant computer is an exposure hazard to the safety-related cables and electrical systems in the area.

As noted in Section 4. 1 of this report, the physical separation for essen-tial supporting systems or electrfcal cables does not provide assurance that redundant systems would not be damaged by a fir.e.

The consequences of fire damage in such areas and the impact on the capability to safely shut down have not been provided by the licensee.

Modifications The licensee has proposed the following modifications.

An automatic and manual Halon suppression system will be installed in the area and will be activated by a cross zoned ionization fire detection system.

A manually 5-10

_

_:_:_::-.:-_:_::*5. 5 5.6

5. 6. 1

5. 6. 2 5.6.3 actuated co2 system will be provided for backup protection.

Portable extinguishers suitable for fighting class A fires will be provided at the entrance to the room.

All exposed cables will be coated with a fire retardant coating.

The entrance to the Unit 3 cable tunnel will be iso-lated by the addition of a 3-hour fire rated barrier.

Existing access doors will be replaced with 3-hour fire.rated class A doors.

Fire dampers will be installed in the ventilation penetrations of the area fire barrier tp provide 3-hour fire rated protection.

Exposed structural steel will be covered to increase its fire resistance rating.

The wall between the computer room and the Dresden Unit 1 turbine buil~ing will be upgraded to provide a 3-hour fire barrier.

A fire water booster hose station with a low flow capacity nozzle and sufficient hose to reach all parts of the auxiiiary electrical equipment room wi 11 be prov*i ded at the entrance to this area.

The top of the el ec-tri cal cabinets and equipment will be sealed to prevent water damage to safety-related electrical equipment.

Curbs will be provided at the entrance to the room.

Since fires could damage redundant safety-related systems, the consequences will be*determined to confirm that the capability to safely shut down exists or an alternate means for safe shutdown will be orovided.

We find that, subject to completion of the modifications and evaluation described above, the fire protection for the auxiliary electrical equip-ment room satisfies the objectives identified in Section 2.1 of this report and is, therefore acceptable.

Switchgear Rooms Switchgear rooms are not provided at Dresden Units 2 and 3.

Essential switchgear is located in the turbine and reactor buildings and is covered

in Sections 5. l and 5.9 of this report.

Unit 2 Battery Room Safety-Related *Equipment The battery room for Unit 2 is located above the control room.

related equipment includes the batteries, battery chargers, and tion panels.

Stacked horizontal safety-related cable trays are along two walls of the battery room.

Combustibles The safety-DC distribu-located The combustibles in the Unit 2 battery room consist of electrical cable insulation and battery cases.

Consequences if No Fire Suppression An unmitigated fire in the Unit 2_ battery room could cause the loss of one division of DC power for safety-related equipment in both units and cause the loss of circuits associated with cables routed through this area.

5-11

5.6.4 5.6.5 5.6.6

5. 7

5. 7. l

5. 7.2

5. 7.3

5. 7.4 Fire Protection Systems One portable co2 extinguisher is provided in the Unit 2 battery room.

Adequacy of Fire Protection In the absence of fire detection and with a single portable fire extin-guisher, the protection of the Unit 2 battery room is inadequate.

The batteries present an unacceptable exposure hazard to the safety-related cables in the area.

The lack of air flow supervision of the ventilation system is inadequate to insure against the possibility of hydrogen accumu-lation in the area.

There is no hose station nearby to aid in extinguishment.

Modifications The licensee has proposed the following modifications.

The batteries will be enclosed in a one-hour fire barrier to isolate them from the remaining area of the room.

An early warning fire detection system will be provided in the Unit 2 battery room including the battery enclosures.

Air flow alarms will be provided to insure against the possibility of undetected hydrogen accumulation in the battery enclosures.

A fire hose reel station wi 11 be provided with access to the Uni_t 2c battery room.

We find that, subject to implementation of *the above described modifica-tions, the fire protection for the Unit 2 battery room satisfies the

objectives identified in Section 2. 1 of this report and is, therefore, acceptable.

Unit 3 Battery Room Safety-Related Equipment

.The Unit 3 battery room i-s 1 ocated in the Unit 3 turbine only safety-related equipment located in the room is the DC distribution panels for the batteries are enclosed in below the battery room.

Combustibles building.

The*

batteries.

The a separate room The only combustibles in the area are the components and cases of the batteries.

All electrical cables are installed in conduit.

Consequences if No Fire Protection An unmitigated fire in the Unit 3 battery room ~ould c~use the l~ss. of one division of the DC power for safety-related equipment ln both un1ts.

Fire Protection Systems

. A portable C07 extinguisher is provided at the entrance to the battery room and a water hose station and*co2 hose reel station are located nearby.

s-12

5.7.5 5.7.6.

5.8

5. 8. 1

5. 8. 1 5.8.3 5.8.4

. 5. 8. 5 Adequacy of Fire Protection The fire protection for the Unit 3 battery room is inadequate due to the absence of any fire detection and the lack of air flow supervision for the ventilation of the battery rooms to insure against the potential for hydrogen accumulation.

Modifications The licensee has proposed the following modifications.

An early warning fire detection system will be provided for the Unit-3 battery room.

Air flow alarms will be provided for the battery room exhaust.

We find that, subject to the implementation of the above described modifi-cations, the fire-protection for the Unit 3 battery room satisfies the objectives of Section 2. 1 of this report and is, therefore, acceptable.

Diesel Generator Rooms Safety Related Equipment There are three diesel generator rooms each containing a diesel generator.

One diesel is used for one division of each unit.(swing diesel).

Combustibles The major combustible loading is the 750 gallon day tank located in a separate room ~nd the 350 gallons of lubricating oil in the diesel crankcase.

Consequence if No Fire Suppression An unmitigated fire in a diesel generator room would result in the loss of*

the emergency onsite power source to one o~ both units.

Fire Protection Systems The diesel generator rooms are protected by a total flooding co2 system.

The diesel day tank rooms are protected by a wet pipe automatic sprinkler system and the total flooding co2 system.

Adequacy of Fire Protection The fixed protection is adequate to extinguish a fire in the diesel generator room.

The structural steel in all rooms are exposed and an unmitigated fire could cause the collapse of the structure.

Adequate measures have not been provided to prevent the spread of oil spill fires to adjacent areas.

Doors and ventilation penetrations are inadequate to prevent a fire exposure to or from adjacent areas.

Louvers in the doors facing the turbine building are not fire rated.

A backup fire hose is not provided for the swing diesel generator.

5-13

5.8.6 Modifications The licensee has proposed the following modifications.

Access doors and ventilation penetrations will be upgraded to 3-hour fire rated protection.

Doors with louvers will be protected with a 3-hour fire barrier.

Piping penetrations, including the Unit 2 and Unit 3 diesel generator exhaust ducts, will be sealed.

The structural steel which is unprotected will be provided with 3-hour rated protection.

Curbs will be provided to prevent the spread of oil spill fires from the diesel generator rooms and day tank rooms.

A hose station will be installed with access to the.swing diesel generatof room.

The fire damper locate~ in the ventilation duct above the roof of the Unit 2 diesel generator room will be relocated to the fire barrier opening or three-hour fire rated protection will be provided for the vent duct to the fire damper.

We find that, subject to implementation of the above described modifica-tions, the fire protection for the diesel generator areas satisfies the objectives of Section 2. 1 of this report and is, therefore, acceptable.

5.9 Turbine Building

5. 9. 1 5.9.1.l 5.9.i".2 5.9. 1.4

5. 9. 1. 5 The turbine building is common fqr Units 2 and 3.

Baiement Floor (Elevations 469 Feet and 481 Feet)

Safety-Related Equipment

Safety-related electrical cables for both divisions are located in these areas.

Combustibles The major combustible loading is the cable insulation and lubricating oil for condensate booster pumps.

Consequences if No Fire Suppression An unmitigated fire in these areas would cause the loss of one division of engineered safeguard system cables controlling the containment cooling service water pumps.

Other equipment exposed is not required for safe shutdown.

Fire Protection Systems Fire protection is provided by an automatic wet pipe sprinkler system, hose stations, and portable extinguisher.

The sprinkler system protects the condensate pumps, condensate booster pumps and all other areas.

Adequacy of Fire Protection Due to the separation of safety-related cables in this area of the plant and the fire protection provided, the area is adequately protected.

5-14

5.9.l.6 5.9.2 5.9.2. l Modifications The licens~e will provide additional hose to the existing hose station near column row 49E in this area.

We find that, subject to the implementation of the above described*

modifications, the fire protection for the turbine building basement floor satisfies the objectives of Section 2. 1 of this report and is, therefore, acceptable.

Floor Elevation 495 Feet Safety-Related Equipment This elevation is divided into three cubicles.

One containment service water pump is located in each of the outer cubicles and two pumps located in the center one. *Two pumps are required to provide 100% cooling capacity.

Unit 2 Division I cables are routed in cable trays.

All other safety-related cables are routed in conduit.

5.9.2.2 Combustibles

. 5. 9. 2. 3 5.9.2.4 The combustible loading at this elevation consists of lubricating oil, cable insulation, and lubricating greas.e.

Consequences if No Fire Suppression An unmitigated fire in this area could damage redundant equipment and associated cables.. The loss of this equipment would result in the loss of the low pressure injection system.

Shutdown capability would be available by the use of other systems.

Fire Protection Systems Fire protection is provided by hose stations and portable fire extinguishers.

5.9.2.5 Adequacy of Fire Protection The fire protection for this area is inadequate due to the lack of fire detection and potential for damage to redundant safety-related equipment.

5.9.2.6 Modifications The licensee has proposed to provide automatic sprinkler coverage for the containment cooling service water pumps and control rod drive water pumps.

We find that, subject to implementation of the above described modifica-tion, the fire protection for the turbine building floor elevation 495 feet satisfies the objectives of Section 2. 1 of this report and is, therefore, acceptable.

5-15

5.9.3

5. 9. 3. 1 Unit 3 Cable Tunnel Safety Related Equipment This cable.tunnel contains both divisions of safety-related electrical cables.

5.9.3.2 Combustibles The combustibles in the tunnel consist of cable insulation.

5.9.3.3 Consequences if No Fire Suppression An unmitigated fire in the area could result in the loss of both divisions of electrical cables.

5.9.3.4 Fire Protection Systems Two rows of automatic sprinklers run the complete length of the cable tunnel at the ceiling level.

5.9.3.5 Adequacy of Fire Protection Due to the arrangement of-cable trays, ceiling mounted sprinklers may not control a fire in lower cable trays.

Manual fire fighting in this area would be extremely difficult.

Entrance to the tunnel is through small hatches in the top of the tunnel and from the cable spreading room.

Existing hose stations near the entrances do not have sufficient hose to reach all areas. *The lack of fire detection prevents prompt response to extinguish fires.

As noted in Section 4. l of this report, the physical separation for essen-tial electrical cables does not provide assurance that redundant systems would not be damaged by a fire.

The consequences of fire damage in this area and the impact nn the capability to safely shut down have not been determined.

5.9.3.6 Modifications The licensee has proposed the following modifications.

The sprinkler system in the tunnel will be modified to adequately protect the cables in this area.

An early warning fire detection system will be provided for the cable tunnel.

Additional hose will be provided at the hose stations located near the Unit 2 and Unit 3 feedwater pumps to provide adequate hose coverage for the cable tunnel.

Where fires could damage redundant safety-related systems, the ccnse-

~~en~es will be determined to confirm that the capability to safely shut down exists or an alternate means for safe shutdown will be provided.

5-16

1--.-

5.9.4

5. 9. 4*. l 5.9.4.2 5.9.4.3

.5. 9.4.4 We find that, subject to completion of the modifications and evaluation described above, the fire protection for the Unit 3 cable tunnel satisfies the objectives of Section 2.1 of this report and is, therefore, acceptable.

Ground Floor (Elevation 517 Feet)

Safety-Related Equipment The ground floor area contains redundant electrical cable trays, switch-gear and motor control centers.

Combustibles The combustible loading in this area consists of cable insulation, lubrica-ting oil and trans1ent materials. This elevation also contains the clean and dirty oil storage room.

Consequences if No Fire Suppression An unmitigated fire in many areas would cause damage to both divisions of safety-related electrical equipment and cables.

Fire Protection Systems Fire protection in this area is provided by automatic wet-pipe sprinklers.

over the reactor feed pumps and in the oil storage room, by carbon dioxide hose reels, portable extinguishers and water hose stations.*

-:::*:::.:.;:: 9. 4. 5*

Adequacy of Fi re Protection 5.9.4.6 In a number of areas, cable separation is not adequate to prevent both divisions from being involved in a single fire due to fix~d and transient fire loads.

Fire detection is inadequate to permit prompt response by the fire brigade.

Motor contra l center 29-2 is inadequately protected from water damage which could result from the use of hose steams to combat a fire in a redundant division cable tray.

Ventilation penetrations for the oil storage rooms are inadequately protected to prevent an exposure hazard to safety-related systems located outside this area.

As noted in Section 4. l of this report, the physical separation for essen~

tial supporting systems or electrical cables does not provide assurance that redundant systems would not be damaged by a fire.

The consequences of fire damage in such areas and the impact on the capability to safely shut down have not been determined.

The conditions exist where redundant divisions of electrical equipment or cables are in close proximity.

Modifications The licensee has proposed the following modifications.

A fixed water suppression system will be installed in the vicinity of the Unit 2 and Unit 3 trackways, the el ectrohydraul i c contra l oil reservoirs, and the Unit 2 instrument air compressor.

Early warning fire detection systems will be provided in the vicinity of 4 kV switchgear 31 and 32 and 430 V 5-17

5. 9.-5

5. 9. 5. 1 switchgear 25, 26, 35 and 36.

The fire detection system will be extended west of switchgear 25 and 26, and east of switchgear 35 and 36 to provide detection ifl the area of redundant divis;ion cable :trays.

The top of motor control center 29-2 will be sealed to provide water damage protec-tion.

Fire dampers will be installed in the ventilation penetrations for the clean and dirty oil storage room.

A fire door with a Class A rating will be provided in the passageway between the turbine building and the radwaste building.

Fire retardant coatings will be applied to cables at 4 kV and 480 V switchgear and motor control centers where the separation of redundant cables is lesi than five feet verticallv and three feet horizontally.

~

Where fires could damage redundant safety-related systems, the consequences will be determined to confirm that the capability to safely shut down exists or an alter~ate means for safe shutdown will be provided.

We find that, subject to implementation of the above described modifica-tions, the fire protection for the turbine building ground floor satisfies the objectives of Section 2. l of this report and is, therefore, acceptable.

Mezzanine Floor (Elevations 538 and 534 feet)

Safety-Related Equipment This area contains standby gas treatment units, instrument racks, 4 kV switchgear, motor control centers and both divisions of electrical cables.

5.9,5.2 Combustibles 5.9.5.3 5.9.5.4 5.9.5.5 The combustibles in this area consist of cable insulation, lubricating oil, charcoal, and high efficiency particulate air filters.

Consequences if No Fire Suppression An unmitigated fire iD this area would damage redundant divisions of elect~ical equipment and cables.

Fire Protection Systems Automatic deluge systems protect the turbine oil reservoirs, and hydrogen seal oil units.

Automatic sprinklers protect the general areas of the mezzanine floor.

Manual carbon dioxide and water hose stations are pro-vided at various locations throughout the area.

Portable extinguishers are provided in these areas.

Adequacy of Fire Protection The lack of adequate fire detection prevents early detection of fires which could result in damage to redundant electrical equipment and cables.

A large concentration of redundant cable trays are routed along the east end of the south wall which are not protected by a fixed suppression system.

The deluge system for the hydrogen seal oil unit does not provide adequate water coverage in the area of the seal oil pump.

The manual 5-18

-~--

~ -----------

5.9.5.6 5.9.6

5. 9. 6. l actuation station for the hydrogen seal oil deluge system is located in the fire area.

Electrical cables are routed above or near redundant electrical.equipment.

In such areas, the use of water to extinguish cable fires involving one division could result in watef damage to equipment of the redundant division.

Hose reach is inadequate in the area of switch-gear 33.

As noted in Section 4. l of this report, the physical separation for essen-tial supporting systems or electrical cables does not provide assurance that redundant systems would not be damaged by a fire.

The consequences of fire damage in such areas and the impacton the capability to safely shut down have not been determined.

These conditions exist in the cable routing area at the east end of the south wall and in the vicinity of switchgear 23 and 24.

Modifications The licensee has proposed the following modifications.

Early warning fire detection systems will be provided in the vicinity of 4 kV switchgear 21, 22, 23, 24, 33 and 34.

The existing automatic sprinkler system will be extended to provide adequate coverage for the cable concentrations along the east end of the south wall.

A spray nozzle will be added to the deluge system for the Unit 3 hydrogen seal oil unit to provide water coverage for the pump.

The manual actuation station for the hydrogen seal oil deluge systems will be relocated away from the fi.re area.

A booster hose station with a low flow nozzle will be provided in the area of switchgear 23 and 24.

The top of switchg~ar 23 and 24 and motor control centers 28-3 and 29-3 will be sealed to prevent water damage.

A Class A fire door will be provided in the passageway between the turbine building and radwaste building.

A hose station will be located at column 55 and the turbine centerline to protect switchgear 33.

\\~here fires could damage redundant safety-re 1 ated sys terns, the conse-.

quences will be determined to confirm that-the capability to safely shut down exists or an alt~rnate means for safe shutdown will be provided.

We find that, subject to implementation of the above described mqdifica-tions, the fire protection for the turbioe building mezzanine floor satis-fies the objectives of Section 2. l of this report and is, therefore, acceptable.

Floor Elevation 549 Feet Safety-Related Equipment The safety-related equipment fn this area consists of the control room air conditioning return fan, ~ontrol room air handling unit and Division I and II cable trays.

5.9.6.2 Combustibles The combustibles in this area consist of cable insulation heating ventila-tion and air conditioning filters and vinyl covered insulation.

5-19

1-.

5.9.6.3' Consequences if No Fire Suppression

_:_(_:_:_:_:_:::

An unmitigated fire could result in the loss of both divisions of cables.

Manual operation of motor operated valves would be necessary for plant shutdown.

The loss of the air handling unit would not adversely affect habitability of the control room.

5.9.6.4 Fire Protection System Portable extinguishers are provided in this area.

5.9.6.5 Adequacy of Fire Protection Portable fire extinguishers do not provide adequate protection in this area.

5.9.6.6 Modifications 5.9. 7

. ;- I:.. 9. 7. l

5.9.7.2 The licensee will provide a standpipe with sufficient hose to cover the entire area.

We find that, subject to implementation of the above described modifica-tions, the fire protection for the turbine building floor elevation 549 feet satisfies the objectives identified in Section 2. 1 of this report and is, therefore, acceptable.

Main Floor (Elevation 561 Feet)

Safety-Related Equipment No safety-related equipment or cables are located in this area.

Combustibles The combustibles in this area consist of lubricating oil from the motor generator sets.

5.9.7.3 Consequences if No Fire Suppression An unmitigated fire in this area could cause the cbllapse of the turbine building roof.

5.9.7.4 Fire Protection Systems Automatic wet-pipe sprinkler systems are provided for the Unit 2 and Dnit 3 bearing lift pumps and for the motor generator sets.

Manual carbon dioxide and water hose stations are located throughout the area.

5.9.7.5 Adequacy of Fire Protection Systems No safety-related equip*ment is exp.osed by a fire in this area.

Provisions have not been provided to limit the spread of an oil spill fire.

Non-rated doors provide access to the reactor building.

5-20

5.9.7.6

5. 10

5. 10. l

5. 10.2

. 5. 10. 3

5. 10.-4

5. 10.5

5. 10.6 Modifications The licensee has proposed the following,modificat~ons. A curb will be provided around the motor generator sets to contain any oil spill to within the area protected by automatic sprinklers.

A Class A fire door will be provided in the passageway between the turbine building and reactor building.

We find that, subject to implementation of the above described modifica-tions, the fire protection for the turbine building main floor satisfies the objectives identified in Section 2.1 of,this report and is, therefore, acceptable.

Radwaste Building Safety-Related Equipment There is no safety-related equipment which is used to shut down the reactor in this area.

Combustibles Combustibles in the area include dry low contaminated waste in 55 gallon drums, cable insulation, spent and dry resins, filters.

Consequences if No Fire Suppression The consequences of no fire suppression in this area would. not result in the release of radioactive material to the environment in excess of 10 CFR 20 limits.

Fire Protection Systems There are fire hose stations and portable ~o 2 fire exti~guishers located on various levels of the radwaste building.

Adequacy of Fire Protection The fire hose stations and portable extinguishers are adequate to control a fire in the area.

Modifications The licensee has not proposed any modifications for this area.

We find that the fire protection for the radwaste building satisfies the objectives identified in Section 2. l of this report and is, therefore, acceptable.

5-21

/,

5. 11

5. 1 i. 1

5. li. 2

5. 11. 3

5. 11. 4 5.11.5

5. 11. 6

5. i 2

5. 12. l

5. 12.2

' 5. 12. 3 Off-Gas Recombiner Area Safety-Related Equipment There is no equipment located in this area which is safety related or is used to shut down the reactor.

Combustibles There are no significant combustibles in this area.

Consequences if No Fire Suppression The consequences of an unmitigated fire in this area would result in damage to the off-gas recombiner equipment Fire Protection Systems There are fire hose stations and portable co2 extinguishers in this area.

Adequacy of Fire Protection The fire protection systems in this area are adequate to control any fire that might occur in this area.

Modifications The licensee will provide a rated fire damper in the ventilation penetra-tion to this area.

We find that, subject to the implementation of the above described modifica-tion, 'the fire protection for the off-gas recombiner area satisfies the

.objectives identified in Section 2.1 of this report and is, therefore, ac,:ceptable.

Pump House*

Safety-Related Equipment The crib house contains the diesel-generator cooling water pumps and both divisions of safety-related cables.

Combustibles The combustibles in this area consist of lubricating oil and diesel fuel oil.

Consequences if No Fire Suppression A fire in this area could adversely affect the service water pumps, diesel fire pump, circulating water pumps, the diesel-generator cooling water pumps and both divisions of safety-related cables.

5-22

5. 12.4

5. 12.6

5. 13

5. 13. l

- ====s: 13. 2

5. 13. 3

~- 13.4

5. 13. 5 Fire Protection Systems Portable f~re extinguishers and a hose station are provided in this area.

Adequacy of Fire Protection Before manual fire fighting could be initiated in this area, substantial fire damage could occur.

The existing protection is not adequate to prevent the loss of safety~related equipment and cables or damage of the fire pump.

Provisions have not been provided to limit an oil spill fire.

Modifications The licensee will provide an automatic sprinkler system over the diesel fire pump and fuel_ oil tank and will provide curbs for the tanks to preclude the spread of a diesel fuel oil spill fire.

We will require the installation of a fire detection system in this area.

We find that, subject to the implementation of the above described modifica-tions and staff requirement, the fire protection for the pump house satisfie*s the objectives of Section 2. l of this report and is, therefore, acceptable.

Yard Area Safety-Related Equipment The safety-related equipment in the yard area includes four 250,000 gallon demineralized water tanks, one condensate storage tank and three buried 15,000 gallon diesel fuel oil storage tanks.

Combustibles Combustibles in the yard include gas cylinders, fuel oil, H? storage tanks, propane tanks, transformer oil and mjscellaneous storage.*

Consebuences if No Fire Suppression T~e consequences of an unmitigated fire in the yard area could impact safe shutdown of safety-related-systems through some of the non-rated turbine building penetrations adjacent to the reserve auxiliary transformers.

Fire Protection The fire protection systems for the yard area include automatic deluge systems on the transformers and hose houses on the hydrants for manual fire fighting.

The fuel oil storage tanks are surrounded by a berm of sufficient height to contain the entire contents of the tank.

Adequacy of Fire Protection The yard area fire protection systems are adequate except for the wall penetration by the bus duct for the reserve auxiliary transformers.

The doors leading to transformers 21 and 22 are not fire rated.

5-23

5. 13. 6

5. 14

5. 14. l

5. 14.2

5. 14. 3

~. 14. 4

5. 14.5

5. 14. 6 Modifications The bus duct penetration nearest to the reserve auxiliary transformers 22 and 31 will be protected by an automatic directed.water spray system.

The water supply to the spray system will be independent of the feed to the transformer deluge system.

The outside door to transformers 21 and 22 will be modified to a 3-hour Class A fire door.

We find that, subject to implementation of the above described modifica-tions, the fire protection for the yard area satisfies the objectives of

- Section 2. l of this report and is, therefore, acceptable.

Off-Gas Filter Building Safety-Related Equipment No safety-related.equipment is located in the off-gas filter building.

Combustibles The combustibles in the area consist of a small quantity of cable insula-tion and charcoal in the off-gas filter units.

Consequences if No Fire Suppression The consequences of a-fire in the off-gas fi 1 ter uni ts has not been deter-mined by the licensee.

Fire Protection Systems A fire detection system is provided in the area.

Two hose stations-and portable fire extinguishers provide fire suppression capability.

Adequacy of Fire Protection We have requested thal the licensee provide an analysis of the conse-quences of a fire involving the charcoal filters.

Modifications No modifications. have been proposed for this area.

The adequacy of the fire protection for the off-gas filter building will be addressed in a supplement to this report.

5-24

6.0 ADMINISTRATIVE CONTROLS The licentee 1 s description of the administrative controls is not adequate to permit a conclusion by the staff.

We have recommended that the licensee's administrative controls follow the guidelines set forth in 11 Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance.

11 Our eyaluation of the administrative controls for fire prot~ction will be issued in a supplement to this report.

6-1

r--,

7.0 TECHNICAL SPECIFICATIONS The Technical Specifications have been modified to include limiting condi-tions for operation and surveillance requirements for existing fire protec-tion systems and administrative control~.

Following the implementation of the modifications of fire protection systems and administrative controls resulting from this review,- the Technical Spec.ifications will be similarly modifi~d to incorporate the lim~ting conditions for operation and surveil-lance requirements for these modifications.

7-1-.

8. 0 CONCLUSION 1ne licensee has performed a fire hazards analysis and has proposed certain modifications to improve the fire protection program.

Additional modifica-tions have been proposed by the licensee during the course of our review of the fire hazards analysis and our ons~te evaluation of the fire protec-tion program.

These proposed modifications are summarized in Sec~ion 3. l.

In addition, we hav~ concluded that the licensee implement certain evalua-tions or improvements related to the fire protection protgram.

These are summarized* in Section 3.2.

In summary, significant steps are being taken to provide additionai assurance that safe shutdown can be accomplished and the plant can be maintained in a safe condition in response to 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 the Dresden facilities will satisfy the provisions*

which the Staff has established for satisfactory long-term fire protection.

We find that the licensee's proposed modifications described hereiri are acceptable both with respect to the improvements in the fire protection

--~rggram _th_~_Lthe~_ Pl"_O_vj_~~-~nd __ wi_th_ re~p-~c~ "t:~ _sa fE? __ ()p§_ra_ti Or:}_ 9f th_e __ _

facilities, while the remaining items are completed.

. 'Iri the -re-port-of-the Sp-ec1a1 -Rev few -Grou*p on --the. Browns-Ferry-FTre.. ( 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 frbm the report summarize the basis for 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.

11A probabi"lity assessment of public safety or risk in quantitative terms is given in the Reactor Safety Study (WASH-1400).

As the result of the calculation based on the Browns Ferry fire, the study concludes that the potential for a significant release of radioactivity from such a fire is about 20% of that calculated from all other causes analyzed.

This indicates that predicted potential accident risks from all causes were not greatly affected by consideration of the Browns Ferry fire. This is one of the reasons that urgent action in regard to reducing risks due to potential fires is not required.

The study (WASH-1400) also points out that 1 rather straightforward measures, such as may already exist at other nuclear plants, can significantly reduce the likelihood of a potential core melt accident that might result from a large fire.

1

Fires occur rather frequently; however, fires involving equipment unavailability comparable to the Browns Ferry fire are quite infre-quent (see Section 3.3 of [NUREG-0050i]).

The Review Group believes that steps already taken since March 1975 (see Section 3.3.2) have reduced this frequency significantly.

8-1

11 Based on its review of the events trans pi ring 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 opera-tion of nuclear power plants for public saf~ty. However, it is clear that much can and should be done to reduce even further the 1 i kel i-hood of disabling fires and to improve assurance of rapid extinguish-ment of fires that occur.

Consideration should be given also to features that would increase further the ability of nuclear facil-ities to withstand large fires without loss of important functions should such fires occur.

11

~le have determined that the 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 sta~dpoint of environmental impact and, pursuant to 10 CFR §51.5(d)(4), that an environmental impact statement or neaative declaration and environmental impact appraisal need not be prepa~ed in connection with the issuance of this amendment.

8-2

9.0 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 an.d in the preparation of. this report.

Their report, "Fire Protection in Operating Nuclear Power Stations - Dresden Units 2 and 3.

Safety Evaluation Report Review dated February 13, 1978, discusses severa 1 matters wh1 ch have been addre*s-sea*1 n*- thTs report.

The elements of the consultants recommendations which we have not adopted are identified in Appendix 118 11 along with our bases therefor.

9-1

APPENDIX A CHRONOLOGY In Febr_u_~ry 1976 the report by the NRC Speci a 1 Review Group was issued as NUREG-0050, 11 Recommendations Related to the Browns Ferry Fire.

11 On Mayl-,-1976, Standard Review Plan 9.5. l 11 Fire Protection 11 was issued, incor-porating the various recommendations contained in NU~~G-6ci~o.

By letter dated May 11; 1976, Commonwealth Edison Company--was--requested to compare the existing fire protection provisions at their facilities with new NRC guidelines as set forth in Standard Review Plan 9.5. 1 11 Fire Protection 11 dated May l, 1976 and to describe (l) the implementation of the guidelines met, (2) the modifications or changes underway to meet the guidelines that will be met in the near future, and (3) the guidelines that will not be met and the basis therefor.

By letters of.September 30, 1976 and October 1, 1976, Commonwealth Edison Company was requested to provide the results of a fire hazards analysis and propose Technical Specifications pertaining to fire protection.

Commonwealth Edison was also provided a copy of Appendix A to BTP 9.5-1 which includes acceptable alternatives to the guidelines cf SRP 9.5-1.

By letter of December 1, 1976 ~e provided model Technical Specifications and requested submittal of fire protection Technical Specifications.

On Oct.ober 1, 1976, December 28, 1976, and August 19, 1977, Commonwealth Edison Company provided submittals responding to our requests of May 11, 1976.

On January 10 to 14, 1977, the DOR fire protection review team visited the *Dresden Units 2 and 3 facility.

On March 29, 1977 the licensee submitted additional information replying to our request of May 11, 1976.

On May 23, 1977 members of the NRC staff and their consultants met with the licensee at the Dresden

_facilities to clarify positions and questions which were submitted earlier on May 10, 1977.

On June 23 and 24 members of the NRC staff met with the licenser:

in Bethesda, Maryland to discuss staff concerns and positions.

The licensee submitted on July 19, 1977 further information in re~ponse to the staff 1 s concerns and positions.

A letter forwarding the administrativ~ controls for fire protection was for-warded to the licensee on July 23, 1977.

On October 5, 1977 members of the staff met with the licensee in Silver Spring, MD to discuss unresolved issues which had been forwarded earlier.

On December l, 1977 the licensee submitted his response to fire protection positions which were a result of the staff's November 8, 1977 telecon with the licensee.

A-1

I

~

I On December 13, 1977 the licensee submitted~ summary of the planned modifica-tions concerning fire protection.

On December 29, 1977 and January 25, 1978 the licensee submitted responses to staff positions and requests for additional information.

A-2

.Jllf.

. t.

~-

APPENDIX B DISCUSSION OF CONSULTANT'S 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 1 s fire protection program and in the preparation of the safety evaluation report (SER).

Their

letter, 11 Fire Protection in Operating Nuclear Power Stations - Dresden 2

& 3 Safety Evaluation Report Review, 11 dated, February 13, 1978, concurs with the staff conclusions noted in the SER.

The consultant's recommendations which we have not adopted, along with our basis therefore, is as follows:

Consultant's Recommendation:

11 Electrical valve supervision should be provided on all valves controlling fire water systems and sectionalizing valves.

The present proposal of administrative contra 1 s or 1 ocks wi 11 increase the probability of suppres-sion system fai 1 ure on demand.

11 Staff Response:

The NRC guidelines on valve superv1s1on are given in Appendix 11 A 11 of.

Brarich Technical Position (BTP) 9.5-1 of the Standard Review Plan.

These guidelines permit, as an al:ternative to electrical supervision, an adminis-trative program to assure that valves are maintained in the proper position.

Such a program includes locking valves with strici 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.

Thes~ measures are consistent with the requirements imposed fo0 super-vising val~es in safety~related systems; and provided adequate assurance that valves are maintained in the appropriate position.

The licensee's program for valve supervision is consistent with NRC guidelines (see SER Section 4.3. 1.3).

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 valv~s controlling fire water systems and sectionalizing valves.

B-1

ML17174A561

Contents

Text

1.0 INTRODUCTION

SUMMARY

1.0 INTRODUCTION

SUMMARY

Navigation menu

ML17174A561

Text

1.0 INTRODUCTION

SUMMARY

1.0 INTRODUCTION

SUMMARY

Navigation menu

Search