ML17206A718

Forwards Responses to NRCs Onsite Review of Fire Protection Plan.Will Forward Implementation Schedule at Later Date

ML17206A718
Person / Time
Site:	Saint Lucie
Issue date:	04/03/1979
From:	Robert E. Uhrig FLORIDA POWER & LIGHT CO.
To:	Reid R Office of Nuclear Reactor Regulation
References
L-79-82, NUDOCS 7904060257
Download: ML17206A718 (52)

Text

>>k RE ATORY INFORMATION DISTRIB ION SYSTKM (RIDS)

ACCESSION NBR:7904060257 DOG BLOATED 79/04/03 NOTARIZED<<

NO FACIL:50 335 ST ~

LUCIK PLANT UNIT 1

FLORIDA POWER 6 'LIGHT CO ~

AUTH ~ NAME AUTHOR AFFILIATION UHRIGF R ~E<<FLORIDA POSER 5 LIGHT CO ~

REC IP ~ NAME RECIP IENT AFFILIATION REIDFR ~ WE "OPERATING REACTORS BRANCH DOCKET 05000335 l

1

SUBJECT:

FORWARDS RESPONSES TO NRC'S ONSITE REVIEW OF FIRE PROTECTION PLAN WILL FORWARD IMPLEMENTATION SCHEDULE AT LATER DATE ~

DXSTRISUTXON CODE:

AOOSS COPIES RECEIVED;LTR" ENCL SIZE'ITLE i FIRE'ROTECTXON INFORMATION (AFTER ISSUANCE OF DP ~ LIO ~ )

NOTES<<

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RECIPIENT ID CODE/NAME ACTION:

05 SC OF>>B +XI COP IES LTTR ENCL 4

REC IP IKNT IO CODE/NAME COPIFS LTTR ENCL INTERNAL<<

09 I8E 12 AUXIL SYS BR 19 WAMBACH 21 AD SYS/PROJ 1

2 2

2 2

1 1

1 1

02 NRC PDR ll TA/KOO 14 PLANT SYS SR 20 MURANAKAgR OELD 1

1 1

1 5

5 1

1 1

0 EXTERNAL! 03 LPDR 22 ACRS 1

1 16 16 04 NSIC 1

1 NR 10 1S79 TOTAL NUMBER OF COPIES REQUIRED e LTTR 38 ENCL 37

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P.O. BOX 529100, MIAMI,FL 33152

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FLORIDA POWER II LIGHTCOMPANY Office of Nuclear Reaator.;Regulation Attention:

Mr. R.

W. Reid, Chief Operating Reactors Branch 5'4 Division of Operating Reactors U.

S. Nuclear Regulatory Commission Washington, D.C.

20555

Dear Mr. Reid:

April 3, 1979 L-79-82 Re:

St. Lucie Unit 1

Docket No.

50-335 Fire Protection Review During the week of December 4, 1978, an on-site review of the St. Lucie Unit 1 Fire Protection Program was conducted by the NRC Staff's Fire Protection Site Review Team.

Your letter of December 29, 1978 forwarded the results of this review along with 43 staff positions and concerns.

In our letter dated January 26, 1979, FPL agreed to respond and to provide an implementation schedule by April 3, 1979.

However, during the meetings of'larch 29 and 30, 1979 with the Staff's Review Team, FPL agreed to re-evaluate three of the 43 Fire Protection Staff Review Positions (SRP).

Upon completion of this re-evaluation FPL will provide a response to these three positions.

The remaining 40 Fire Protection SRP's are enclosed with our proposed modifications:

1) Enclosure 1 - Fire Protection Staff Review Positions(agreed to at the conclusion of the on-site review).

2) Enclosure 2 - Fire Protection Staff Review Positions (FPL response to the Staff's positions and conceT'.ns).

Fi.nally, an implementation schedule will be prepared and forwarded to the Staff once FPL has been notified of the acceptability of our proposals.

Very ly yours, Robert E. Uhrig Vice President Advanced Systems 8 Technology REU/MAS/paf Enclosures cc: fir. James'P.

O'Reilly, Region II Harold F. Reis, Esquire

> 90406 0267 i

PEOPLE... SERVING PEOPLE

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ENCLOSURE NO.

1 RESULTS OF STAFF SITE VISIT MEETINGS FIRE PROTECTION STAFF REVIEW POSITIONS.(SRP)

WHICH LICENSEE AGREED TO IMPLEMENT ST.

LUCIE UNIT 1

DOCKET NO. 50-335 SRP-3 SRPW SRP-5 SRP-10 SRP-11 SRP-12 SRP-15 SRP-19 SRP-21 SRP-28 SRP-31 SRP-34 SRP-35 SRP-36 SRP-39 SRP-41 SRP&3 Fire Pump Operating Characteristics Fire Pump Control Valves Position Indication Fire Pump Control Valve Locks Fire Hydrant Hose Valves Fire Hydrant Installation Fire Pump, Fire Hydrant and Post Indicator Valve Traffic Guards Fire Protection Systems Control Valve Supervision Fire Alarm System Circuit Supervision Fire Extinguishers for Control Room Fire Door Repairs Flammable Gas Piping Identification Fuel Oil Storage Tank Dikes Gas Cylinder Storage Control of Smoking Containment Area Combustible Storage Control Room Record Storage Ladder Access to Cable Trays

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Page 1 II Results of Staff Site Visit Meetings, Enclosure No.

1 FPL RESPONSE TO NRC STAFF POSITIONS

& CONCERNS SRP-3 Fire Pum 0 eratin Characteristics Staff Concern:

Water at an adequate volume and pressure should always be available to the fire protection systems for use in the event of fire.

The review team was unable to determine from the drawings of the power and control circuits for the fire pumps that these pumps would operate when the emergency diesel generators are operating or on loss of offsite power once the emergency diesel generators were operating.

Staff Position:

Provide test data to confirm that the fire pumps will operate when (1) the emergency generators are operating and (2) on loss of offsite power with the emergency diesel generators operating.

FPL has confirmed that the fire pumps will operate when (1) the emergency generators are operating and (2) on loss of offsite power with the emergency diesel generators operating.

SRP-4 Fire Pum Control Valves Position Indication Staf f Concern:

Position of control valves on piping from fire pumps should be evident to assure that valves are maintained in required positions.

Staff Position:

Provide positive means to indicate the position of the valves control-ling flow in the fire pump headers.

Currently fire pump control valves are locked in their proper position and monthly checks are conducted to insure a positive flow of water to the fire loop system.

However, FPL will provide a means to indicate valve position.

Page 2 trit Results of Staff Site Visit Meetings, Enclosure No.

1 SRP-5 Fire Pum Control Valve Locks Staff Concern:

Valves controlling water from fire pumps should be maintained in the correct position and should also be capable of being opened or shut in the event of an emergency.

Staff Position:

Replace existing heavy duty locks on fire pump control valves with frangible type locks.

FPL has provided the frangible locks for the fire pump control valves.

SRP-10 Fire H drant Hose Valves Staff Concern:

Fire brigade and fire fighting personnel should be able to control the water flow from fire hose connected to a fire hydrant without having to close the hydrant shut-off valve.

Gated hose valves are presently not provided on the fire hydrants.

Staff Position:

Provide at least one 2~/2 inch gated hose valve within each fire hose and equipment cabinet.

FPL will provide at least one 2~/2 inch gated hose valve within each fire hose 6 equipment cabinet.

SRP-11 Fire H drant Installation:

Staff Concern:

Fire hydrants should be installed to permit the connection of 2~/2 inch fire hose to each 2+/2 inch hydrant outlet.

Presently, one 2~/2 inch outlet on fire hydrant No.

2 is not accessible due to a wall located adjacent to the hydrant.

Staff Position:

Rotate fire hydrant No.

2 as necessary to provide sufficient clearance for installation of fire hose on any of the hydrant's outlets.

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Page 3 tt Results of Staff Site Visit Meetings, Enclosure No.

1 FPL has rotated the fire hydrant No.

2 as necessary to provide sufficient clearance for installation of the fire hose.

SRP-12 Fire Pum Fire H drant and Post Indicator Valve Traffic Guards Staff Concern:

Fire protection extinguishing systems, fire hydrants, control valves and associated components should not be subject to possible vehicular damage.

The fire pump and jockey pump installation, fire hydrant No. -11 and post indicator valve Nos. V15-169, and V15-138 are subject to vehicular damage due to the lack of adequate guard posts.

Staff Position:

Provide traffic guard posts for fire pump and jockey pump instal-lation, fire hydrant No.

11 and post indicator valve Nos. V15-169 and V15-138.

FPL will provide the tpaffic guard protection for the fire pump and jockey pump, fire hydrant No.

11 and post indicator valve Nos.

V15-169 and V15-138.

SRP-15 Fire Protection S stems Control Valve Su ervision S taff Concern:

Valves controlling water supply to fire protection systems should be kept fully open to assure systems will be operational in the event of fire.

Staf f Position:

Provide supervision for all fire protection system control valves to assure that these valves will be maintained in the correct position.

Valves should be electrically supervised in the open position or locked and sealed in the open position and sufficient administrative procedures adopted to assure that valves will be maintained in the open position.

Valve supervision should comply with the criteria of NFPA-26, "Suppression of Valves".

All valves controlling water supply to fire protection systems at St. Lucie are either electrically supervised or locked in the open position.

Plant administrative procedures which comply with the intent of NFPA-26 assure that valves are maintained in the open

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Results of Staff Site V1sit Meetings, Enclosure No.

1 posit1on.

The NRC guidelines on valve supervision are given in Appendix "A" of Branch Technical Position (BTP) 9.5-1 of the Standard Review Plan.

These guidelines permit, as an alternative to electrical supervision, an administrative program to assure that valves are maintained in the proper position.

SRP-19 Fire Alarm S stem Circuit Su erv1sion:

Staff Concern:

Fire detection and alarm circuits should be electrically supervised to indicate an open or grounded circuit or other trouble condition which would result in the alarm system being unable to function upon operation of a detector or other alarm initiating device.

Staff Position:

Verify that all circuits of the fire detection and alarm system are electrically supervised to indicate an open or grounded circuit or other trouble condi,tion which would result in the alarm system being unable to function upon operation of a detector or other alarm initiation device.

The status of the fire detectors and their associated circuitry is cont1nuously supervised to ind1cate an open or grounded circuit or other trouble condition by the main fire alarm panels and local indicat1ng panels.

A detector or its circuitry going into an alarm or trouble state (an open or grounded circuit or power failure) is sensed by the main fire alarm panel which transmits that information to the Data Gathering Panels (DGP).

The DGP's are a multiplexing device which converts information from the ma1n fire alarm panels and transmits this information to the fire detection system Control Processing Unit (CPU).

The CPU continu-ously monitors the information from the DGP's.

A trouble state (open or grounded circuit or a power failure to the detectors or DGP's) 1s sensed by the CPU which sounds an alarm in the control room.

Upon acknowledgement of the alarm, the control room operator is provided with a printout of the zone from which the alarm is initiated.

Security check po1nts are also notified of these alarms by the CPU.

Loss of AC power to the main fire alarm panels results in a local aud1ble alarm.

The fire detection system is an 1ntegral part of the plant security monitoring system, The main fire alarm panels, DGP',

and CPU receive their power from the fire detection and station security vital AC cab1net.

The fire detection and station security vital AC cabinet can be fed from either the non-safety or safety related buses or safety related batteries.

Should the fire detection system computer become inoperative, the plant security

'system computer can perform the same function.

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>Page 5 lI Results of Staff Site Visit Meetings, Enclosure No.

1 SRP-21 Fire Extin uishers for Control Room Staff Concern:

Fire extinguishers suitable for.use on Class A, ordinary combusti-

bles, and for deep seated fires in electr1cal cabling should be provided within the Control Room.

Staff Position:

Provide at least two 2~/2 gallon pressurized water extinguishers at the entrances to the Control Room.

FPL will provide two 2~/2 gallon pressurized water extinguishers for the Control Room.

SRP-28 Fire Door Re airs Staff Concern:

Fire resistant rating of fire doors is reduced or eliminated when wire glass windows in fire doors are replaced with pla1n glass.

Staff Position:

Replace plain glass in windows of all fire doors with at least /g inch wired glass.

Particular doors of concern are those in the Auxiliary Building stairwell leading to the Control Room and Cable Spreading Room.

FPL will replace the windows on designated fire doors with wired glass.

SRP-31 Flammable Gas Pi in Identification Staff Concern:

Potential flammable mater1al pipe lines in safety-related areas have not been identified as such.

Staff Position:

Identify all hydrogen and other flammable gas piping in safety-related areas by color coding or lettered markers affixed to the piping.

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gage 6 trit Results of Staff S1te Visit Meetings, Enclosure No.

1 FPL Response:

'PL will identify the flammable gas supply lines in question.

SRP-34 Fuel 011 Stora e Tank Dikes Staff Concern':

Diked areas for flammable and combustible liquid storage tanks should be sf.zed to contain the entire capac1ty of the tank in the event of a tank rupture to prevent damage to safety-related compo-nents.

The dikes for the emergency generator fuel storage tanks contain penetrations for fuel piping which are not sealed and which reduce the capacity of the dikes to less than the maximum capacity of the tanks.

Staff Position:

Seal pipe open1ngs in the generator fuel oil storage tank dikes to prov1de suff1cient capacity within the dikes to contain contents of tank in the event of a tank rupture.

FPL will seal the one pipe opening 1n each diesel fuel oil storage tank area.

SRP-35 Gas linder Stora e

Staff Concern Potential damage to safety-related equipment or components exists from improperly stored cylinders of flammable and industrial gases.

Staff Position:

Store compressed gas cylinders 1n racks designated for that purpose.

Storage should be 1n an approved manner.

FPL has provided for the storage of gas cylinders in an approved manner.

SRP-36 Control of Smokin Staff Concern:

Smoking in safety-related.

areas should be controlled to preclude the possibilities of a fire in these areas.

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Results of Staff Site Visit Meetings, Enclosure No.

1 Staff Position:

Enforce non-smoking requirements in safety-related areas.

Of particular concern was the evidence of smoking found inside the main control panels in the Control Room.

FPL will control the smoking in the main control panels in the Control Room.

SRP-39 Containment Area Combustible Stora e

Staf f Concern:

Combustible items left within the containment area could be ignited and affect safety-related equipment and components.

Staff Position:

Provide enclosed, metal containers for storage of miscellaneous combustibles that are left inside the Containment Area.

FPL has removed the one miscellaneous combustible found 1nside the containment area.

Also additional tool lockers will be provided for the storage of materials 1ns1de the containment area.

,r SRP-41 Control Room Record Stora e

Staff Concern:

Storage of combustible drawings and records in,the Control Room could be ignited and affect safety-related equipment and components.

Staff Position:

Relocate the storage of drawings presently at entrances to main control panel in the Control Room to an appropr1ate non-safety-related area or store drawings in metal cabinets.

FPL w111 provide a metal cabinet for the storage of drawings in the Control Room.

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Results of Staff Site Visit Meetings, Enclosure No.

1 SRP-43 Ladder Access to Cable Tra s Staff Concern:

Accessibility to all cable trays in safety-related areas is required in the event of fire.

Neither fixed nor portable ladders are readily available for access to the cable tray areas in the space above the ceilings in Fire Zones 43, 44, and 54 of the Auxiliary Building.

Staff Concern:

A portable ladder dedicated for fire brigade use should be provided for access to the cable tray areas above the ceilings in Fire Zones 43, 44 and 54 of the Auxiliary Building.

FPL will install fixed ladders for access to the cable tray areas in the loft areas above Fire Zones 43 and 44 of the Auxiliary Building.

At the time of the staff's site visit Fire Zone 54 had a fixed ladder for access to the cable tray areas in the loft areas of the Auxiliary Building.

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ENCLOSURE NO.

2 RESULTS OF STAFF SITE VISIT MEETINGS FIRE PROTECTION STAFF REVIEW POSITIONS (SRP)

WHICH THE LICENSEE AGREED TO CONSIDER ST.

LUCIE UNIT 1

DOCKET NO ~ 50-335 SRP-1 SRP-2 SRP-6 SRP-7 SRP-8 SRP-9 SRP-13 SRP-14 SRP-17 SRP-18

'RP-20 SRP-22 SRP-23 SRP-24 SRP-25 SRP-26 SRP-27 SRP-29 SRP-30 SRP-32 SRP-33 SRP-37 SRP-38 SRP-40 SRP-42 Diesel Driven Fire Pump Fire Pump Revisions Fire Protection Water Tanks Fire Hydrant and Water Main Isolation Valves Fire Hydrant Removal Fire Hydrant Addition Emergency Diesel Generators Automatic Sprinkler System Automatic Sprinkler System Design Data Early Warning Fire Detectors 17.1 Main Control Panels 17.2 Reactor Coolant Pumps 17.3 High Pressure Safety Injection Pumps 17.4 Low Pressure Safety Injection Pumps 17.5 Containment Spray Pump 17.6 Volume Control Tank Room Emergency Diesel Generator Building Replace Heat Detectors With Early Warning Detectors Manual Foam Fire Fighting Equipment Emergency Breathing Apparatus Fire Brigade Portable Radios Fire Loading and Fire Rated Separations Cable Spreading and Switchgear Rooms Fire Rated Barrier Drumming Room Fire Rated Separation Separation of Kitchen/Office Area From Control Room Transformer Deluge Valves Fire Barrier Emergency Diesel Generator Skid (Day) Tank Vents Reactor Coolant Pumps Oil Collection System Battery Room Ventilation Switchgear Room Computer Records Storage Trash Containers ANTI& Protective Clothing Storage Containers Foamed Plastic Pipe'Insulation

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Results of Staff Site Visit Meetings, Enclosure No.

2 SRP-1 Diesel Driven Fire Pum Staff Concern:

Water should be automatically available to the automatic sprinkler

systems, interior manual hose stations and exterior fire hydrants in the event of fire.

Presently, the electric motor driven fire pumps can only be started manually in the event of the loss of offsite power and are not arranged to take suction from both ground storage water tanks.

Staff Position:

Provide a 2,500 GPM at 100 psi diesel driven fire pump conforming to the requirements of NFPA-20, "Centrifugal Fire Pumps" and arrange to take suction from either of the 500,000-gallon ground storage tanks; or, the existing two electric motor dr1ven fire pumps should be mod1-fied to be capable to -automatically operate upon loss of offsite

power, to start upon drop of pressure in the water distribut1on

system, and to be capable of taking suction from either of the ground storage water tanks.

FPL will provide a means for the fire pumps to take suction from either of the 500,000 gallon ground storage tanks.

Also, the control circuits of the existing two electrically driven fire pumps will be modified to be capable of automatically starting upon loss of offsite power and a drop of pressure in the f1re, water distr1bution system.

When required, the fire pumps w111 be sequentially loaded onto the emergency diesel generators within one minute.

Upon receipt of an Engineered Safety Features Actuation Signal concurrent with a loss of offsite power and a drop of pressure in the fire water distribution

system, manual starting of the fire pumps will be required.

SRP-2 Fire Pum Revisions Staff Concern:

Reliability of the fire pumps starting in the event of a fire is ques-tionable.

Fire pump installation does not fully comply with NFPA-20, "Centrifugal Fire Pumps" in that standard fire pump controllers and control c1rcuits are not prov1ded and the power supply leads to the

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electric motors may not be adequate.

Staff Position:

Upgrade the existing fire pump installation to provide control and power supply features, required by NFPA-20'in conformance with TABLE 9-1, item E.2.(c),

P25 of FPL's Fire Protect1on Evaluation sub-mitted to the Commiss1on on March 31, 1977.

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Results of Staff Site Visit Meetings, Enclosure No.

2 FPL Response:

FPL feels that the control and power supply features of the existing fire pump installation are technically superior to the design recommended by NFPA-20.

To satisfy NFPA-20 and the staff's concern FPL will install pressure switches near the existing fire pumps.

Also FPL will remove the fire pump "stop" switch in the Control Room.

However in the event that a nuclear safety related concern develops, FPL must reserve the right to re-evaluate the removal of the fire pump "stop" switch in the Control Room.

SRP-6 Fire Protection Water Tanks Staff Concern:

Common tanks are provided for fire and service water.

However, vertical standpipes have not been provided to assure that at least 300,000 gallons of water within each tank is reserved for fire protec-tion.

The installation does not meet the 9.5, Appendix A guidelines, nor section 8-7.2 of, NFPA-22, Water Tanks.

Staff Position:

Provide appropriate standpipes within each ground storage water tank for supply to the service water system to assure that a minimum of 300,000 gallons per tank will be reserved exclusively for fire protec-tion.

The fire protection water at St. Lucie is provided by two 500,000 gallon City Water Storage Tanks (CWST).

A minimum contained volume of 300,000 in each CWST is administratively controlled by the Technical Specifications.

High and low level alarms for each tank annunciate in the Control Room, and at the low level set point approximately 325,800 gallons remains in the tank.

The draining of both CWST's resulting from a postulated leak in one tank or its piping is precluded by normally closed isolation valves.

The present Technical Speci,fication in conjunction with Control Room annunciation of low water level and the tank isolation valves assures sufficient water will be available at all times to meet fire fighting requirements, thus alleviating the need for standpipes within the CWST's.

Also, FPL has agreed to install for the fire pumps the capability to take suction from either of the 500,000 gallon ground storage tanks (See SRP-1 Diesel Driven Fire Pump).

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Results of Staff Site Visit Meetings, Enclosure No.

2 SRP-7 Fire H drant Isolation Valves Staff Concern:

Water main laterals supplying fire hydrants are not provided with shut-off valves and the locat1on of shut-off valves in. the remainder of the distribution system is such that a single break in the system may place a significant portion of the system out of service or disable both the automatic suppression system and backup hose station.

Staff Position:

Provide a suffic1ent number of isolation valves to laterals supplying fire hydrants and/or in the water distribution system such that shutting down a portion of the fire protection water system to service a hydrant or due to a break in the system will not depr1ve water to safety-related areas.

A review of the in situ Fire Protection System at St. Lucie was made to determine if a single break in the system could place a signif1cant portion of the system out of service or disable both the automatic suppression system and backup hose station.

This review showed sufficient loop isolation capability exists with the post indicator valve system; curb valves for each fire hydrant are unwarranted.

Attached is an analysis for loss of each fire hydrant showing valve isolation requirements and alternate suppression water available.

As noted in this analysis, installation of a new post indicator valve, to the fire loop between fire hydrants

//9 and 1/10 is required.

I Rage 4 tilt Results of Staff Site Visi,t Meetings, Enclosure No.

2 EVALUATION OF ALTERNATE SUPPRESSION CAPABILITYASSUMING RUPTURE OF A FIRE HYDRANT Postulated Fixe Fire Suppression H drant Ru ture Ca abilit Loss Fire Areas Potentially Affected Appropria te Isolation Valves Alternate Suppression Following Isolation Valve Closure

//1 or f32

//3 or f14 Fire hydrant'/1 and //2 Water to ser'vice bldg.

Fire hydrants

//3 and

/i'4 Fire area 79 Fire area 4

Fire area 5

V15136 V15135 V15134 V15137 V15136 Fire hydrant

//12 is available for fire area 79 Fire hydrant f16 is available for fire areas 4

& 5 e5 ox f36 87 or 88 Fire hydrants 85 and f36 F.P. water to the blowdown treatment facility Fire hydrants i/7 and fi'8 Water to turbine lube oil fire protection system 1B Fire area 4

Fire area 5

Fire area 6

Fire area 7

Fire area 8

Fire area 6

Fire area 7

Fire area 8

V15137 V15138 V15185 V1 5140 V15142 V15618 V15617 Fire hydrant

134, is available for fire area 4

& 5 and fire hydrant

//7 is available for fire areas 6,

7 and 8 Fire hydrant

/l6 is available for fire areas 6,

7 and 8

89 Fire hydrant 89 Transformer deluge system Fire area 3

V15143 V15167 Fire hydrant 810 is available for fire area 3

//10,

!/11 or Fire hydrants

/312 10, 11 and 12 Fixe area 2

Fire area 3

Fire area 79 V15169 V15171 V15170 Hose station HS-15-3 is available for fire area 2; fire hydrant //9 is available for fire area 3 and; fire hydrant f/1 is available for fire area 79

• new post indicator valve to be added to loop between fire hydrants 9 and 10

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Results of Staff Site Visit Meetings, Enclosure No.

2 SRP-8 Fire H drant Removal Staff Concern:

One fire hydrant on the south side of Auxiliary Building is located in the construction area for Unit 2 and is subject to damage from heavy construction equipment

( i.e., large cranes).

Staff Position:

Relocate the hydrant south of Aux1liary Building which is in the con-struction area for Unit 2 so as to protect the fire hydrant and fire protection water system from possible damage; or, provide protection for the hydrant from construction equipment.

FPL feels that the fire hydrant located in the construction area for Unit 2 provides no significant impact on safety-related areas of the facility.

Also this fire hydrant could easily be isolated from the fire water loop system.

However, FPL will provide a means to protect the fire hydrant.

SRP-9 Fire H drant Addition Staff Concern:

A security wall has been erected which prevents the use of the fi.re hydrant southwest of Auxiliary Building in the event of a fire in the east portion of the Diesel Generator Building or west portion of the Auxiliary Building.

Staff Position:

Prov1de a fire hydrant in the yard area between the Auxiliary Building and Diesel Generator Building.

FPL will provide fire water suppression capabil1ties for fight1ng fires in the east port1on of the Diesel Generator Building or west portion of the Auxil1ary Build1ng.

A charged 2 1/2 inch gated fire water 11ne will be provided from the existing fire hydrant until the security wall is removed from this area.

SRP-13 Emer enc Diesel Generators Automatic S rinkler S stem:

Staff Concern:

An automat1c fire suppression system is not provided for the Emergency Diesel Generator Building.

The Emergency Generator Building consists

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Results of Staff Site Visit Meetings, Enclosure No.

2 of two rooms each of which conta1ns a generator driven by two diesel engines which are supplied fuel from a 400-gallon skid mounted diesel oil day tank.

A fire involving the fuel oil tank or the lubricating oil in one of the diesel eng1nes would probably 1nvolve all equipment in the room and also present an exposure fire hazard to the emergency generator components in the adjoining room.

Staff Position:

Provide an automatic sprinkler system for each Diesel Generator Room.

The Design Basis Fire (DBF) for each diesel generator area was evaluated in Section 8.4.1.7 and 8.4.1.8 of the Fire Protection Eval-uation Report with regard to possible fire spread hazard to adjacent

areas, hot gas radiation, and for burning liquid spread.

A fire involving all equipment in each room was evaluated.

This DBF evalua-tion considered the total energy released from burning all combustibles in each of the areas; 50 pounds celluloid air filters, 420 gallons fi'2 d1esel oil, and 510 gallons lube oil.

No exposure fire hazard was found to exist to the adjoin1ng diesel generator room.

The DBF for each area is of short duration (approximately 17 minutes) and based on the fire hazards evaluation the DBF will not impair the func-tions of the adjacent diesel generator.

However FPL has agreed to re-evaluate this position.

SRP-14 Automatic S r1nkler S stem Desi n Data Staf f Concern Insufficient information was prov1ded to evaluate the water supply requirements for the automatic spr1nkler and water spray fire protec-tion systems.

Staff Position:

Provide design data for. all automatic sprinkler and water spray fire suppress1on

systems, includ1ng "K" factor of nozzles, calculated nozzle pressures, area of application and the number of nozzles operating.

I In the Fire Protection Evaluation Report, Sec.

6, Fire Protection, FPL feels that sufficient information is provided to evaluate the fire protection systems, The fire protection systems (sprinkler and deluge) were designed and installed to satisfy the insurance require-ments for fire protection and loss prevention.

FPL must object to this needless request for additional information on the basis that the design data is not necessary for the completion of the staff's fire protection site review.

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Results of Staff Site Visit Meetings, Enclosure No.

2 SRP-17 Earl Warnin Fire Dectectors Staff Concern:

Fire/smoke in safety-related areas containing significant quantities of combustible materials could go undetected and cause major damage to safety-related equipment or components.

Staff Position:

Provide early warning fire detectors for the following:

1.

Within Main Control Panels in the Control Room 2.

Above Each Reactor Coolant Pump'.

Above High Pressure Safety Injection Pumps (Fire Zone 35) 4.

Above Low Pressure Injection Pumps (Fire Zone 35) 5.

Above Containment Spray Pump (Fire Zone 34) 6.

Volume Control Tank Room Over Safety-Related Cables (Fire Zone 49)

Installation of detectors should conform to NFPA-72D, "Proprietary Signaling Systems" and NFPA-72E, "Automatic Fire Detectors" and should give visual alarm and annunciation in the Control Room.

SRP-17-1 FPL wi,ll provide early warning fire detectors within the main standup control panels (RTGB) in the Control Room.

SRP-17-2 FPL will provide early warning fire detectors adjacent to each reactor coolant pump motor.

SRP-17-3, 4,

5 FPL will provide early warning fire detectors in the ventilation duct for SRP 3, 4, 5.

SRP-17-6 FPL will not provide an early warning detector in the VCT Room because there are no exposed safety related cables in the VCT Room.

SRP-18 Emer enc Diesel Generator Buildin Re lace Heat Detectors With Earl Warnin Detectors Staff Concern:

The existing heat detectors in the Emergency Diesel Generator Building will not provide an early warning in the event of fire.

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2 Staff Position:

Replace existing heat detectors in Emergency Diesel Generator Building with early warning type detectors.

FPL w111 replace in the Emergency Diesel Generator Building a portion of the existing heat detectors with early warning type fire detectors.

SRP-20 Manual Foam Fire Fi htin E ui ment Staff Concern:

Foam fire fighting equipment for use on flammable or combustible liquid type fires has not been provided.

Staff Position:

Provide manual foam fire fighting equipment and foam concentrate for use in fighting flammable and combustible liquid type fires.

Foam application equipment should 1nclude in-line foam 1nductor sized for connection to 1 l/2-inch f1re hose and at least 50 gallon's of foam con-

centrate, such as AFFF, should be available.

FPL w1ll provide portable foam equipment for manual fire fighting.

SRP-22 Emer enc Breathin A

aratus Staff Concern:

Prov1sions are not provided at the site to recharge the emergency breathing cylinders.

The supply of available spare full cylinders does not meet the BTP 9.5.1, Appendix A guidelines.

Staff Position:

The air breathing apparatus used by the fire brigade and emergency control personnel (i.e., the complement'f air breathing apparatus, spare cylinders, and recharging capability) should be sufficient to meet the needs of ten people for a period of six hours at a usage rate of three air cylinders per hour per person.

We agree that adequate breathing air should be provided for fire-fighting and emergency operations personnel, and that under strenuous conditions, a 30 minute rated unit will only supply air requirements for a person for about twenty minutes.

We have reviewed our equipment

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Results of Staff Site Visit Meetings, Enclosure No.

2 requirements and our agreements w1th support agencies against the types of emergencies postulated in Regulatory Guide 1.101 and have determined that the equipment on site and on order provides adequate protection for all postulated emergencies.

Supporting our determinat1on are (1) the open-air plant structures such as the Turbine Structure and Intake Structure where "air Packs" would not be

required, (2) the lack of any unacceptable safety consequences as demonstrated in the Fire Protection Evaluation Report, (3) the limited number of people actually required to wear breathing apparatus during an emergency, and (4) the response and equipment capability of off-site support agencies.

The proposed equipment for the site will consist of twenty-two complete air pack units, twenty spare bottles (at least ten of the spares will be filled at all times),

and a s1x bottle cascade system capable of refilling twenty-thre'e bottles.

Th1s capability w111 provide an on-site supply of a1r of a duration between six and seven hours for three persons.

In addition back-up capabil1ty for air breathing requirements can easily be provided by responding offsite assistance groups.

SRP-23 Fire Bri ade Portable Radios Staff Concern:

The provisions of adequate and rel1able two-way vo1ce communication is vital to safe shutdown and emergency response in the event of fire.

Staff Pos1tion:

Insure that at least two portable radios are readily available for use by the fire brigade.

Provide, if necessary, repeaters/antenna wire to ensure that all safety-related areas can communicate with Control Room.

Currently there are a number of communicat1on systems and portable radios available for emergency notification and response.

FPL will meet the intent of the'taff's position.

SRP-24 Fire Loadin and Fire Rated Se arations Staff Concern:

Fire rated enclosures, and/or enclosures having a low fire resistant rating are utilized in a number of areas within the plant that contain combustible materials which present an exposure hazard to safety-related equipment and components.

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Page '10 Results of Staff Site Visit Meetings, Enclosure No.

2 Staff Position:

Evaluate the fire rating of each fire area and fire zone door.

Upgrade these doors, as necessary, to contain a fire involving the maximum possible fire loading, including trans1ent items.

FPL Res nse The Design Basis Fire as discussed in Section 5 of the Fire Protection Evaluation Report is conservatively based on the actual combustible loading 1n each fire area and the burning rate of the combustibles in the area.

Inplant combustibles within each fire area were utilized in the fire hazards evaluation.

They were determined from actual in-plant surveys. 'See Section 7 of the Fire Protection Evaluation Report).

These conditions typically reflect actual plant conditions including the random distribut1on of transient combustible

sources, that is, 1'tems essential to normal plant operation and maintenance.

The fire load of an area can be related to a standard time/temperature curve and the fire barrier rating required to contain the area fire potential can be determined.

Areas with a fire load of 40,000 Btu/ft require 1/2 hour fire barriers.

All fire areas with the exception of the d1esel generator areas have fire loads less than 40,000 Btu/ft (See Table 8-4.)

The DBF's are short-lived; the majority last for less than 10 minutes.

F1re areas, assuming no credit for the non-fire rated doors, were evaluated with respect to possible fire spread hazard to adjacent

areas, hot gas radiation, or burning liquid spread.

The maximum fire loading including transient 1tems in each area was evaluated.

Each area will contain its DBF.

No exposure or fire spread hazard was found to exist, thus, upgrading or installing of fire zone doors for St. Luc1e is not required.

However, FPL has agreed to re-evaluate this position.

SRP-25 Cable S readin and Switch ear Rooms Fire Rated Barrier Staf f Concern:

The cable Spreading Room 1s in open communication with the Switchgear Room contrary to section F.5 of Appendix A, BTP 9.5.1 guidelines.

A fire in one area could spread to the adjacent area.

Staff Position:

Provide a three-hour fire rated barrier between cable Spreading Room (Fire Zone 57) and Switchgear Room (Fire Zone 56).

The Cable Spreading Room (Area 57) and B Switchgear Room (Area 56) were evaluated in the Fire Protection Evaluation Report assuming the

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Results of Staff Site Visit Meetings, Enclosure No.

2 Design Basis Fire (DBF) burned for its full duration.

The fire area opening between these areas was evaluated with respect to possible fire spread hazard and hot gas radiation.

No fire spread hazard was found to exist.

Area 57 contains no combustible sources and Area 56 is characterized as one of low fire hazard.

Thus the Staff's proposed three-hour fire rated barrier is not required.

However FPL has agreed to re-evaluate this position.

SRP-26 Drummin Room Fire Rated Se aration Staf f Concern:

A standard fire rated separation is not provided between the Drumming Room (Fire Zone 51) and the Main Hallway (F1re Zone 55).

The Drumming Area contains a s1gnificant quantity of combustible material which if ignited, would damage the safety-related

cables, equipment and components located in the Main Hallway.

Staff Posit1on:

Provide an automatic self-closing, three-hour fire door in the doorway between the Drumming Room (Fire Zone 51) and the Main Hallway (Fire Zone 55).

FPL will provide an automatic self-closing, three-hour fire door in the doorway between the Drumming Room and the Main Hallway.

SRP-27 Se aration of Kitchen/Ofice Area from Control Room Staff Concern:

The cooking operations 1n the kitchen and the combustible mater1als in the Kitchen/Office Area present an unprotected fire hazard exposure to the safety-related equipment and components in the Control Room.

Staff Position:,

Provide a one-hour fire rated self-closing door at the entrance to the corridor serving the Kitchen/Office Area.

The cooking operations 1n the kitchen area is recognized as presenting an inherent fire hazard potential.

Therefore plant procedures assure that the combustible inventory in the kitchen area 1s maintained to a minimum value consistent with plant operational requirements.

In addition, fire detection at the ceiling of this area is provided, portable fire extinguishers are readily available, and immediate response would be expected from the continuously manned Control

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Page 12 t Results of Staff Site Visit Meetings, Enclosure No.

2 Room.

This along with the location of the kitchen area in relation to Control Room safety-related equipment provides sufficient protection to prevent a fire 1n the kitchen presenting a fire exposure hazard to the safety-related equipment and components in the Control Room.

SRP-29 Transformer Delu e Valves Fire Barrier Staff Concern:

The deluge valves for protection of the outdoor oil cooled transformers are located adjacent to and in direct communication with the transformers.

These valves are exposed to probable damage in the event of a transformer fire.

Staff Position:

Provide an adequate fire barrier or separation wall between deluge sprinkler system valves and transformers.

FPL cannot understand the staff's position and concern for non-safety-related equipment and areas of the plant.

The deluge systems for the outdoor o11 cooled transformers were installed to satisfy an insurance requirement.

The potential impact of a transformer fire on safety-related equipment was addressed in the Fire Protection Evaluation Report.

SRP-30 Emer enc Diesel Generator Skid (Da ) Tank Vents Staff Concern:

The vents from the sk1d (day) tanks located 1n the Emergency Diesel Generator Building terminate ins1de the building resulting in the possibility of discharging fuel oil into the building should the high level switch fail to shut down the fuel oil supply pumps.

Also, an excessive discharge of flammable and combustible vapors will be discharged into the building from vaporization of the liquid in the tanks.

Staff Position:

Provide adequate sized vent 11nes terminating outside of the building for each emergency dr1ven generator skid (day) tank.

The design and installation of the vent piping should conform to NFPA-30, "Flammable and Combustible Liquid Code".

FPL will relocate existing diesel generator skid tanks vents to the outside.

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2 SRP-32 Reactor Coolant Pum s Oil Collection S stem Staff Concern:

An oil leak from a reactor coolant pump in the Containment Area could result in a f1re which could damage safety-related equipment.

Staff Position:

Prov1de an oil collection system for the lube oil system to each reactor coolant pump.

The oil collection system should be piped to an oil collection tank located at the lowest level and sized to contain the maximum quantity of oil that could escape from the pumps in the event of a rupture.

As an alternative, provide an automatic suppression system for potential fires.

The DBF for the containment at St. Lucie was evaluated by dividing the containment into 26 fire zones centered around each potential combustion source.

Each RCP was evaluated as a separate fire zone for two cases; a

10 gpm leak assumed to be consumed as it was released from the pump and the 190 gallons of oil 1n each RCP assumed to spill, immediately spread to cover 20 ft /gallon and ignite.

The safe shutdown equipment and electrical cables potentially affected by this zonal fire are listed in the Fire Protection Evaluation Report, Section 8.4.1.10, Zonal Analysis Table (p.8-74).

Safe shutdown related cables within conta1nment are routed in well separated, Flamemastic 71A coated cable trays or in electrical conduits which provide adequate'ire protection.

The DBF for each of the RCP zonals 1s of short duration (< 2.5 minutes),

and the zone of influence associated with these fires did not adversely affect other RCPs.

Thus the DBF involving an RCP does not present an unacceptable nuclear safety concern.

FPL is deferring action on this Staff Posit1on and Concern pend1ng the final resolution of the EPRI study, "Evaluation and Test of Improved Fire Resistant Fluid Lubricants for Water Reactor Coolant Pump Motors." If a suitable lubricant is not found, FPL will provide a system to suppress potential fires or provide for the removal of potential oil leakage to a safe location.

SRP-33 Batter Room Ventilation Staff Concern:

Failure of the exhaust ventilation system 1n the battery rooms could lead to buildup of explosive hydrogen concentrations.

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t Results of Staff Site Visit Meetings, Enclosure No.

2 I

Staff Posi.tion:

Provide a ventilation air flow monitor in the exhaust duct from each battery room to alarm and annunciate in the Control Room upon loss of air flow.

The battery room ventilation supply is provided by the Reactor Auxiliary Building Electrical Equipment and Battery Room Ventilation System redundant supply fans (HSV-5A, HSV-5B).

These supply fans are connected to separate emergency buses and are automatically connected to the on-site emergency diesel generators upon loss of off-site power.

In the event of failure of one supply fan, the second fan operates at two thirds capacity, which is sufficient to cool all three electrical equipment rooms and both battery rooms.

The battery room exhaust ventilation system consists of 18" X 18" exhaust fan and vent in the ceiling of each battery room (RV-l, RV-2).

Each battery room exhaust fan is connected to separate emer-gency buses and is automatically connected to the emergency diesel generator upon loss 'of off-site power.

In the event of failure of an exhaust fan, current design allows gravity dampers in the exhaust fan vent opening to close, thus eliminating this ceiling path.

Nevertheless, some air exchange would be expected due to the normal air supply system and the louvered battery room doors.

Each battery room (1A and 1B) has 60 cells of lead-calcium batteries.

The batteries are maintained at a floating charge level in accordance with the manufacturer's recommendation.

The hydrogen generation rate of these batteries is approximately 0.00188 ft /hr/cell at the floating charge level.

The time required to accum-ulate a hydrogen concentration of 2/ per room volume assuming no air exchange was conservatively calculated to be 41.45 days for 1A and 53.38 days for 1B.

After the battery capacity test, which is normally performed a minimum of every 18 months during shutdown, the batteries are maintained at an equalization level for approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

At equalization charge level, the )ydrogen generator rate of these batteries is approximately 0.00864 ft. /hr./cell.

The time required to accumulate a hydrogen concentration of 2/ per room volume assuming no air exchange was conservatively calculated to be 9.02 days for 1A and 11.61 days for 1B.

Since the St. Lucie Unit 1 Technical Specifications require the batteries to be checked at least once every seven days and additional traffic due to operator surveillance or electrical maintenance would be expected, excessive hydrogen build-up will not occur.

However in order to provide further assurance that hydrogen buildup will not occur the gravity dampers in the exhaust fan vent openings will be removed.

It is our position that this will completely alleviate your concern of hydrogen buildup, hence the addition of other design

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<4'age 15 Results of Staff Site Visit Meetings, Enclosure No.

2 modifications, such as air flow switch annunciat1ons, is not justified.

SRP-37 Switch ear Room Com uter Records Stora e

Staff Concern:

The storage of combustible computer printout data paper, charts, records, etc.,

1n open cabinets in the Switchgear Room presents an unprotected fire exposure hazard to safety-related equipment and components.

Staff Position:

Utilize enclosed metal cabinets for the storage of computer printout data and other combustible records located in the Switchgear Room (Fire Zone 56).

FPL will utilize the present metal cabinets for storage of combustibles located in the Switchgear Room.

SRP-38 Trash Containers Staff Concern:

Combustible material in open trash containers could be ignited and affect safety-related equipment and components.

Staff Position:

Replace existing open trash containers in safety-related areas with metal or noncombustible containers with swing tops.

In the Fire Protection Evaluation Report, FPL addressed combustibles 1n safety-related areas and discarded combustibles were included in the evaluation.

FPL showed that burning combustibles in safety-related areas would not adversely affect safety-,related equipment or components.

However, FPL will provide detachable self-closing drum covers for the existing open trash conta1ners.-

SRP-40 ANTIW Protective Clothin Stora e Containers Staff Concern:

Containers for discarding combustible Anti-C protective clothingyare located beneath cable trays and adjacent to equipment which are

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2 safety-related.

The material in these containers could be ignited and affect safety-related equipment and components.

Staff Position:

All containers for discarding Anti-C protective clothing should be removed from beneath safety-related cable runs and adjacent to safety-related equipment or metal covers should be provided for the containers.

In the Fire Protection Evaluation Report FPL addressed combustibles in safety-related areas and the discarded Anti-C protective clothing was included in the evaluation.

FPL showed that'burning combustibles in safety-related areas would not adversely affect safety-related equipment or components.

However, FPL will provide detachable self-closing drum covers for the existing containers.

SRP&2

. Foamed Plastic Pi e Insulation Staff Concern The foamed plastic (polyurethane) insulation used on piping in safety-related areas presents an unprotected fire exposure hazard to the equipment and components in the area.

Staff Position:

All foamed plastic (polyurethane) insulation used in safety-related areas should be painted with an intumescent coating or covered with metal.

FPL feels that the small amount of insulation foam would not impact on any safety-related components.

However, FPL will cover the insulation foam with Flamemastic.

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