ML17266A125
| ML17266A125 | |
| 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 8001140345 | |
| Download: ML17266A125 (5) | |
Text
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A REGULATO INFORMATION DISTRIBUTION STEM (RIDS) t ACCESSION NBR ~ 6001100305 DOC ~ OATEN'O/Ol/07 NOTARIZED'O FACII.;50 335 St, Lucie "Plantg Unl t ii *Floi ida Power L Light Co<
50 389 bt. Lucie P'l anti Oni t 2i Florida Power L L'ight (",o.
AUTH,NAME "
'AU'rHUA'FFILIATIUN HALCeR ~ ED Brookhaven National Laboratory AEGIp ~ SAME RKcipIEHT AFF ILIArIUA FEA( USONjR,L, "Power 'SystettIs"Branch h
SUBJECT:
Forwards review comments re SERrSection 9iFire-Watqr Supply Expresses concern that fire water storage tanks* Ievel might be drawn down to volume less thin that required to fight worse case fire. Recommends mods to provide wat'er reserve.
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Department of Nuclear Energy BROOKHAVEN NATIONALLABORATORY ASSOCIATED UNIVERSITIES, INC.
Upton, New York 11973 (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 SER Section 9.0 Item 2.
Fire Water Supply
Dear Bob:
The Brookhaven National Laboratory (BNL) letter dated June 25, 1979 ex-pressed the concern that it could be possible to draw down the level of water in the two storage tanks to a volume less than that which may be required to fight a worse case fire.
This concern was caused by the arrangement of piping from the tanks which does not physically dedicate a reserve of water for fire protection exclusively.
We recommended changes to the arrangement of the tank outlet piping in order to provide this reserve.
Section 9.0 of the SER contains this recommendation as well as the Nuclear Regulatory Commission staff's response to this item.
This 'response accepts the utility's alternate proposal to reserve one of the storage tanks for fire protection use by locking shut the valve on the domestic water outlet from the
- tank, as well as certain technical specification requirements
'and administra-tive procedures.
K The attachment sums up our position on this matter to date.
II Respectfully
- yours, obert E. Hall, Group Leader Reactor Engineering Analysis REH:EAM:sd attachment cc.:
R. Cerbone W. Kato E. MacDougall V. Panciera E. Sylvester wo/att.
sooil40
St. Lucie Fire Protection Review Fire Water Su l
4.3.1.1 9.0 Item 2 Section 9.0 of the SER contains our concern on the adequacy of the water supply for firefighting.
The fire protection water supply for the St. Lucie plant consists of two 500,000 gallon above ground steel storage tanks.
The tanks are filled through an 8-inch connection to the Ft. Pierce municipal water system and are equipped with low level alarms arranged to indicate in the control room when the level reaches 325,000 gallons in either tank.
Taps are provided near the bottom of each tank for lines leading to the fire pumps.
Taps are also provided for domestic water at the bottom of the tanks.
With this arrangement of taps to the fire water supply tanks, it is pos-sible to draw down the level of water in the tanks to a volume less than that which may be required to fight a worst case fire.
To mitigate this problem, it was our reccmmendation that standpipes or elevated taps connected to the domestic water supply be provided at an ele-vation that will assure that at least 300,000 gallons of water in each tank is reserved exclusively for fire protection.
As an alternate recommendation, one of the 500,000 gallon storage tanks may be reserved for fire protection by providing a blind flange bolted on to the domestic water outlet tap from one of the tanks.
Our reccmmendation ruled out a closed'alve secured by chains and locks as an acceptable alternate to the blind flange, since it is not a
positive method to assure the needed water supply in the event of a fire.
The licensee's proposal to meet our concern does not include providing standpipes or dedicating one tank for fire protection by cappi ng off the domestic water tap with a bolted on blind flange.
Their proposal is to main-tain the valve from one tank to the domestic water system in the closed posi-tion secured by a chain and lock.
The utility has justified their method of dedication of the water storage tank by citing other measures to i nsure de-pendability of the water supply.
The items include:
Water level supervision provided by alarm annunciation in the control room and technical specification requirements including monthly surveillance of valves.
Other features cited by the utility are modifications to the water supply which the utility agreed to make as listed in Section 3.1 of the SER.
Appendix A to BTP 9.5 1 and the draft copy, working paper C of Appendix R,
"Fire Protection Program for Nuclear Power Plants operating prior to July 1, 1976" are specific in the requirement that the minimum fire water storage shall be ensured by dedicated tanks or by means of a vertical standpipe for other water service when storage tanks are used for ccmbined service water/
fire water uses.
Our recommendation met this position by requiring standpipes
be provided for the domestic water taps or one of the tanks be dedicated for fire protection by disconnecting the existing domestic water tap and closing it off with a bolted blind flange.
The redundant water supply in this case, is provided by the second tank which will continue to have the domestic water tap but is provided with a low level alarm which will annunciate in the con-trol room when the remaining water volume reaches 325,000 gallons.
Based on a review of the water supply deficiencies discussed above, it is our conclusion that the Utility's proposed methods of meeting the consultants concern and recommendations should not be accepted.
This is based on the fact that it does not conform to the requirements of Appendix A to BTP 9.5-1 and draft Appendix R, "Fire Protection Program for Nuclear Power Plants Operating Prior to July 1, 1976.
More specifically, closing and sealing the valve in the domestic water line does not assure adequate dedication of the tank for fire protection.
Monthly surveillance can allow the valve to be open and the tank drawn down over relatively long periods of time.
The back-up features indicated by the utility for insuring the water supply are existing or have been previously agreed to by the licensee and are not considerations for mitigating the recommendation for a reliable water supply.
The concern still exists and our recommendation as stated in Section 9.0 of the SER is still applicable.