ML17244A186

Forwards Responses to Three of Five Questions Submitted in 781006 Ltr Re Fire Protection.Addl Time Necessary to Respond to Questions 78 & 79

ML17244A186
Person / Time
Site:	Ginna
Issue date:	10/31/1978
From:	White L ROCHESTER GAS & ELECTRIC CORP.
To:	Ziemann D Office of Nuclear Reactor Regulation
References
NUDOCS 7811060088
Download: ML17244A186 (12)

Text

0 OOQ REGU RY INFORMATXON DXSTRIBUT "0 SYSTEM ew DOCKET NBR: 50-244 RE GINNA 1 DOC DATE: 78103]

RECIPIENT- 2IEMANN D.L. ACCESSXON NBR: 8 0 ORXGXNATOR: WHITE L. D. COPIES RECEIVED:

COMPANY: ROCHESTER GAS S .ELEC LTR 1 'NCL

SUBJECT:

SIZE: 11 Forwards responses to 3 of 5 gue'stions submitted in 781006 ltr re fire protec. Addi time is necessary 'to respond to uestions 78 6 79.

DISTRIBUTION CODEX' A006 N DISTRIBUTION TITLE I QL),

NOTARIZED FIRE PROTECTION INFORMATION (AFTER ISSUANCE OF NAME ENCL'P FOR ACTION BR H F M/4 ENCL ~ ORB¹2 BC EG 'W/ENCL NRC PDR W/ENCL I L ~/2 ENCL E'ELD LTR ONLY AUXILIARY SYS BR l</2 ENCL AD FOR SYS K PROJ N/ENCl PLANT SYSTEMS BR </5 ENCL WAMSACH ~/ENCL R MURANAKA W/ENCL HANAUER H/ENCL LPDR H/ENCL TFRA "'/ENCL NSIC K/ENCL ACRS H/f6 'ENCL TOTAL NUMBER OF COP IES REAUI RFD I LTR 30 ENCI 38 NOTES:

RIa i >1 ~ Osl ar 0 ROCHE 5 T ER GAS AND EL EC T Rl C CORPORA TIDE e 89 EAST AVE'NIE, ROCHESTER, H,Y. 14649 LEON O, WHITE. JR. 'YKt.r>HO 4K VICE PRCSIOENT ARrA COOe Tie 546.2700 October 31, 1978 Director of Nuclear Reactor Regulation Attention: Nr. Dennis L. Ziemann, Chief Operating Reactors Branch No. 2 U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Fire Protection R. E. Ginna Nuclear Power Plant fjg~~~g~~;3 I'If .~~~'I jI~I." I.op)

Dear Nr. Ziemann:

This letter is in response to your letter dated October 6, 1978 which was received October 16, 1978. The attachment to this letter responds to five of the eight questions raised in your letter. We have found that, additional time is necessary to respond to questions 78 and 79 and to position 36. We will submit our answers to these three items as soon as they are com-pleted. In addition, we have found answers previously provided for positions 9 and 28.

it necessary to revise the Very truly yours, r 0 L. D. Whi , Jr.

psggQQ 00 8 F

76. In the response to our Request No. 11, you stated that there are several fire barriers in certain plant areas which have a rating of less than 3-hours. Identify all fire barriers with less than 3-hourareas rating and verify that the fire severity in fire on either side of each barrier is less than the fire resistance rating of the barrier.

Response: In our response to Staff Request No. 11, we referenced our Fire Evaluation Report, and particularly the figures included in that report, for details of the fire ratings. For the convenience of the Staff we present below a summary of all fire barriers which are or will be rated or ratable at less than 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.

Justification for acceptability of these ratings are presented in our Fire Evaluation Report. Should the Staff require additional justification, we would appreciate receiving specific requests. Specific page references to our Fire Evaluation Report are provided for each area discussed. All barriers between fire areas which are not discussed are 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> barriers.

An automatic fire damper will be installed over the opening for the spent fuel pool charcoal filter in the wall between the auxiliary building and the intermediate building (p 4.2-11). We will attempt to provide a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> barrier,be possible.

however, due to space limitations, this may not it If is not possible, equivalent protection will be provided for the safety-related cables above the opening.

2. A portion of the wall between the intermediate building and the service building is a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> barrier (p 4.3-7). This is acceptable based on the low fire loadings.

3. The wall separating the control building and the turbine building at the lower two elevations is a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> barrier (p 4.4-1). See the Fire Evaluation for justification.

The wall between the A battery room and the mechanical equipment room is ratable as a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> barrier. The door in that wall and the damper in the ventilation duct have or will have a 1', hour rating (p 4.4-3).

The wall between the A battery room and the B battery room is ratable as a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> barrier. The door in that, wall and the damper in the ventila-tion duct have or will have a 1~~ hour rating (p 4.4-5).

The dampers in ducts between the turbine building and the A battery room, the B battery room, and the mechanical equipment, room have or will have 1~ hour ratings.

The doors from the relay room to the computer room, the stair tower and the turbine hall will be replaced with B-labeled 1', hour rated doors (p 4.4-9).

Fire dampers in the computer room ducts will have a 1', hour rating (p 4.4-10). The ceiling of the computer room will be replaced with a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> barrier (p 4.4-11).

The control room turbine building wall will be protected with a water curtain (p 4.4-13).

The opening from the cable tunnel to the inter-mediate building will be closed by a barrier (p 4.7-2). It is likely that this will not. carry a rating since it must be custom designed.

be designed to be equivalent to a 3 hour It will barrier.

The door between the service building and the turbine building at the 271'-0" level will be left unrated since neither structure contains safety related equipment (p 4.9-1).

The door from the turbine oil storage building to the turbine building is a B-labeled, l~ hour door (p 4.11-1).

The wall between the nitrogen storage building and the auxiliary building will be 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rated (p 4.14-1).

The floor construction in the control building is 6 inch reinforced concrete on unprotected structural steel. The steel prevents the floor from being ratable as a 3-hour fire barrier (p 4.4-1). Pro-tection of the steel is being addressed under Staff Position PS.

The doorway from the standby auxiliary feedwater pump building (SAF) to the unrated access structure does not have a rated door (Drawing D-024-017).

A rated door is not required for the following

I reasons. The area of the auxiliary building in the immediate vicinity of the doorway does not contain either combustibles or safety related equipment, (see Drawing D-024-010 and FSAR Figure 1.2-12). The standby system is required only in the event of unavailability of the auxiliary feedwater system. Thus a fire in the SAF will not, affect. safe shutdown or damage any other safety related equipment. A fire in the auxiliary building that could affect, the SAF is not reasonable to postulate based on auxiliary building equipment configuration and low level of combustibles in the SAF.

77.

Response

h or list Your response areas not provided automatic of such fire plant d

with d h either detection areas and be ll~f-to our Request No. 13 did not address the your lack of such fire protection measures.

automata.c identified.

l d justification Our response to Staff Question No. 13 committed to suppression Provide of a

the providing early warning detection systems in all areas that, contain safe shutdown equipment or cables. We also referred the Staff to our Fire Protection Evaluation, submitted February 24, 1977 for a discussion of areas which did not contain automatic suppression. Lack of automatic suppression in certain areas was justified on the basis of low fire loading.

The following areas contain safe shutdown or safety related cables or equipment:

Area Safet -Related Safe Shutdown

1. Containment Yes Yes

2. Auxiliary, all levels Yes Yes

3. Intermediate building

a. Sub-basement No No

b. 253'6" South Yes No

c. 253'6" North Yes Yes

d. 271'0" South Yes No

e. 278'4" North Yes Yes

f. 293'0" South No No

g. 298'4" North Yes No

h. 315'4" North No No

4. Control Building

a. A/B battery rooms Yes Yes

b. Mech. equip. room Yes Yes

c. Relay room Yes Yes

d. Computer room No No

e. Control room Yes Yes

5. Diesel Generator

a. A/B diesel room Yes Yes

b. A/B cable vault Yes Yes

6. Screen House

a. Basement Yes Yes

b. Main floor Yes Yes

7. Cable Tunnel Yes Yes

8. Turbine Building No No

9. Service Building No No

10. Standby Aux FW building Yes Yes

11. Turbine Oil Storage Area No No

12. H Storage Area No No

13. A'5T building No No

14. N2 Storage building No No

Detection will be provided in every area which contains safety-related equipment. Detection is assumed to be provided to the area of a specific piece of equipment or length of cable fire in the vicinity if it of will detect and annunciate a that piece of equipment or length of cable. Automatic suppression will be pro-vided to the extent, previously discussed.

80. The fire hazards analysis for the turbine building does not include all combustibles in the area (e.g., Hydrogen for the generator cooling). Provide the results, of revised analysis which includes all combustibles in the turbine building.

Response: This question was apparently prepared before the Staff had an opportunity to review our submittal of September 22, 1978. The turbine building fire loading is described in detail, including the hydrogen for the generator cooling in that submittal.

l ~ ~ ~ ~~

81. In your response to our Request No. 37, remote shutdown stations were identified and the procedures to shut down the plant from these stations were discussed. However, our concern that a fire in these areas may impair the control from the control room and at the same time pre-vent the local control of safe shutdown system(s) was not addressed. Provide the results of such an analysis in any areas from which shutdown and cool down operation outside the control room could be effected.

Response: In the response to positions P6, P7 and P10 in our letter of September 22, 1978 we described an analysis currently underway to ensure that Ginna can be taken to cold shutdown following any "major" fire. This analysis will address the Staff concern raised in question 81. The analysis will be submitted to the Staff for review when completed.

P-35 In addition to the alternate shutdown capability specified in Staff Position No. 7, all cables in the relay room (cable spreading room) should be provided an appropriate flame retardant coating. An alternative (to the coating) of providing a fixed piping, manually operated water suppression system, as specified in Section F.3.(b).(3) of appendix A to BTP 9.5-1, is acceptable.

Response: Either a manually operated water suppression system will be installed in the relay room or all cable trays in the relay room will be provided with an appropriate flame retardant coating. If a water suppression system is installed, it will be isolated with a manual valve to preclude inadvertent operation.

P9 Emer enc Li hts 8-hour rated fixed, sealed beam emergency lighting units should be provided in safety-related areas and other areas which contain major fire hazards to facilitate the emergency operation, manual fire fighting, and access to, and egress from, each fire zone.

Response: In our letter of September 1, 1979, we agreed to this position. Since that time we have reviewed the emergency lights on the market and have found an alternative light-ing concept that we believe meets the requirements. The alternate is not specifically of sealed beam design. It is a high efficiency halogen lamp which provides 25%

more light with half the power requirement than the com-parable sealed beam unit. Thus, we propose to use either the sealed beam unit or the alternate described here.

P28 Shift, Fire Brigade (second half)

The Shift Foreman should not be a member of the fire brigade because his presence will be necessary in the control room or other areas critical areas of the plant.

if fires occur in certain Response: In our letter of September 22, 1978, we committed to having an operator who has a Senior Reactor Operators (SRO) license who is not a member of the fire brigade at all times. Further review has revealed that this may not be possible during certain times of the year.

Throughout most of the year, we will comply with our September 22, 1978 commitment. We occasionally find that the Shift Foreman or the SRO is on vacation or otherwise not on shift and there is not another SRO available. In these cases, one of the operators who holds a Reactor Operators license is upgraded. Before being upgraded, this person must be qualified through on-the-job training. He accomplishes this through training under the direction of the SRO and Shift Foreman until he satisfies the Shift Foreman that he is qualified to be upgraded. In addition, the normal classroom training for Reactor Operator is identical to that for Senior Reactor Operator. He would be the person, then, to direct. the shutdown of the plant.