ML17266A124

Forwards Review Comments on Ser,Section 9 Re Fire Pump Controller & on Util 791003 Response.Util Fire Pump Controlers Did Not Meet Requirements of NFPA-20.Concludes Fire Pump Controllers Not Equal to Ul Listed Units

ML17266A124
Person / Time
Site:	Saint Lucie
Issue date:	01/07/1980
From:	Randy Hall BROOKHAVEN NATIONAL LABORATORY
To:	Ferguson R Office of Nuclear Reactor Regulation
References
NUDOCS 8001140339
Download: ML17266A124 (8)

Text

REOULATOIINFORMATION DISTRIBUTION QTEM (RIBS)

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KO CL Upton, New York 11973 Department of Nuclear Energy (516) 345- 2144 January 7, 1980 Mr. Robert L. Ferguson Plant Systems Branch U.S. Nuclear Regulatory, Commission Washington, D.C. 20555 RE: St. Lucie Fire Protection Review Item 4.3.1.2; 9.0

Dear Bob:

Attached is our ccmments on the fire pump controller for the St. Lucie plant.

Resp ctfully yours,

- obert E. Hall, Group Leader React o r Eng i neeri ng Anal ys i s REH: EAM: sd attachment cc.: R. Cerbone- wo/att.

W. Kato E. MacDougall V. Panciera E. Sylvester

LE 11 L'

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St. Lucie Fire Protection Review Fire Pum Controller 4.3.1.2 9.0 The letter to Florida Power and Light Company dated August 17, 1979 acccmpanyi ng the Safety Evaluation Report of the same date, requested the licensee to provide additional information needed to resolve issues raised by the fire protection consultant. One of these items was the staff's request that the licensee prepare a point-by-point evaluation of the St. Lucie Unit No. 1 fire pump controller in ccmparison to the requirements of NFPA No. 20, which is the standard for Centrifugal Fire Pumps. The licensee was also asked to state which parts of the controllers were U.L. listed and which parts were not.

Attachment B of Florida Power and Light's letter L-79-280 dated October 3, 1979 provides this comparison. The licensee's letter did not, however, state which parts of the existing fire pump controllers are U.L. listed and which parts are not.

Florida Power and Light's point-by-point canparison indicated several instances where the existi ng fire pump controllers did not meet the require-ments of NFPA-20 nor possess other ccmpensating characteristics in lieu of the code requirements. Specific paragraphs contained in NFPA 20 which the existing control equi pment does not meet includes: 1-5.1, 7-1.1.1, 7-1.1.2, 7-2.1, 7-3.5, 7-5.2.3 and 7-5.2.4. The licensee defended some of these dif-ferences with the code by stating that the control equi pment at St. Luci e 1 was purchased to nuclear grade IE. The licensee did not, however, explain in quiress how the Class IE requirements are more stringent than the NFPA-20 re-detail quirements.

One of the requirements of NFPA-20 contained in paragraph 7-5.2.3 states that manual control stations located remote frcm the controller must not be operable to stop the fire pump motor. Paragraph 7-2.1 of NFPA-20 also re-the controller to be located as close as practical to the fire pump motors and within sight of the motors. The existing arrangement at St. Lucie 1, however, has the control equi pment located in another area of the plant and a control switch is provided in the control room for stopping the fire pumps.

These deficienci es result in a fire protection water supply system which may not be dependable under all conditions. The licensee has also stated that the fire pumps will automatically operate upon drop of pressure in the fire water distribution system; except under engineered safety features actuation signal (ESFAS) conditions.

Based on the review of the submitted evaluation, we conclude that the existing electric motor driven fire pump controllers are not equal in reli-ability to U.L. listed units conforming to NFPA-20 requirements. Of greater importance than the technical quality level of the components, however, is the basic arrangement of the control system which could allow the fire pumps to be inoperable under some conditions. The resulting loss of fire protection water could negate both automatic and manual firefighting systems in the plant.

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In order to correct this deficiency, and to insure a dependable water sup-ply for fire protection, the existing electric motor driven fire pumps should be supplemented with an additional 2,500 gpm diesel engine driven fire pump which will be independent of the plant power systems even under ESFAS con-ditions. With the addition of this pump a redundant fire water supply is provided and the criticality of the existing electric motor driven fire pumps is reduced. Based on this, the existing electric fire pump controller is con-sidered acceptable with the implementation of the licensees proposed modifi-cation of upgrading and relocating the sensing lines and pressure switches to a location near the. pump discharge. If the recommendation for the additional diesel engine driven fire pump is not implemented, the existing controller arrangement for the electric motor driven fire pumps is not acceptable. In this case, an alternate solution would be the replacement of both existing controllers with new controllers approved by U.L. and meeting all the require-ments of NFPA-20.

The electric driven fire pumps must be available in the case of loss of off-site power. We recommend that the requirements of Section A-4 of Appendix A of BTP 9.5-1 be met.

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