ML17338A685

Safety Evaluation Supporting Amends 45 & 31 to Licenses DPR-31 & 41,respectively

ML17338A685
Person / Time
Site:	Turkey Point
Issue date:	03/21/1979
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML17338A684	List: ML17338A683 ML17338A685 ML17338A686
References
SER-790321, NUDOCS 7905080073
Download: ML17338A685 (90)

Text

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)t**g4 UNITEDSTATES NUCLfAR REGULATORY COMMISSI WASHINGTON, D. C. 20555 FLORIDA POWER AND LIGHT COMPANY DOCKET NO. 50-251 TURKEY POINT NUCLEAR GENERATING STATION UNIT NO.

4 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No.

37 License No.

DPR-41 1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by Florida Power and Light Company (the licensee) dated December 22, 1977 as supplemented on June 5 and 23, July 14, August 28, and November 7, 1978 complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.

The issuance of this am'endment will not be inimical to the common defense and security 'or to the health and safety of the public; and E.

The issuance of this amendment is in accordance 'with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

a

2.

Accordingly, the license is amended by adding paragraph 3.F.

Facility Operating License No.

DPR-41 is hereby amended to read as follows:

(F )

Fire Protection The licensee may proceed with and is required to provide a

schedule for. and to complete the modifications identified in Paragraphs

3. l. 1 through 3. 1. 19 of the NRC 's Fire Protection Safety Evaluation, dated March 21, 1979 for the facility.

These modifications are to be completed prior to December 1980.

If any modifications cannot be completed on schedule the licensee shall submit a report explaining the circumstances together with a revised schedule.

In addition, the licensee shall submit the additional information identified in Sections 3.1 and 3.2 of the related Safety Evaluation in accordance with the schedule contained therein.

In the event these dates for submittal cannot be met, the licensee shall submit a report, explaining the circumstances, together with a revised schedule.

The licensee is required to develop and implement the administrative controls which are consistent with the licensee's letters of August 28 and November"7, 1978 within three months from the date of this amendment.

3.

This license amendment is effective as of the date of its issuance.

FOR THE NUCLEAR REGULATORY COMMISSION g(ggu i CC<~.'.

Schwencer, Chief.

Operating Reactors Branch Pl.

Division of Operating Reactors Date of Issuance:

March 21 1979

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/p P fIRE PROTECTION SAFETY EVALUATION REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION U. S.

NUCLEAR REGULATORY COMMISSION IN THE'ATTER OF FLORIDA POWER AND LIGHT COMPANY k

TURKEY POINT UNITS 3 AND 4 DOCKET NOS.

50-250 AND 50-251 March 21, 1979 i cr gZo/'2 E/

DocRB~+ pgy~og oo c 3 Control 8 Date~>><-7 of0ncirme+

RFGULATGRY DOCKET FILE

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1. 0 INTRODUCTION.

2. 0 FIRE PROTECTION GUIDELINES TABLE OF CONTENTS PAGE 2-1

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

2.2 Supplemental Guidance.

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3. 0

SUMMARY

OF MODIFICATIONS.AND INCOMPLETE ITEMS 2-1 2-2 3-1 3.1 Modifications 3-1 3.1.1 3.1.2 3.1.3 3.1.4 3.1.5 3.1.6 3.1.7 3.1.8 3.1.9

3. 1. 10

3. l. 11

3. l. 12 3 ~ l. 13

3. l. 14

3. 1. 15 3 ~ 1. 16 3.1.17

3. l. 18

3. 1. 19 Fire Detection Systems Fire Water Supply Yard Hydrants Firehouse Equipment Hose Stations Water Suppression Systems..

Foam Suppression.

Portable Extinguishers Fire Doors Fire Dampers Penetrations..

Barriers'

Curbs Fire Retardant Cable Coatings Control of Combustibles............

Fire Fighting Access Smoke Venting Equipment Air Breathing Equipment.

Emergency Lighting.

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3-1 3-2 3-2 3-2 3-2 3-3 3-3 3-3 3-3 3-4 3-4 3-4 3-4 3-4 3-5 3-5 3-6 3"6 3-6 3.2 Incomplete Items 3-6 3.2.1 3.2.2

'.2.3

3. 2.4 3.2.5

3. 2.6 Smoke Detection.

Reactor Coolant Pumps Water Supply..

Auxiliary Building Corridor..

Cable Spreading Area.

Technical Specifications for Existi

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ng Equipment.....

3-6 3"7 3-7 3-7 3-7 3-8 4.0 EVALUATION OF PLANT ARRANGEMENT.

4-1 4.1 4.2 4.3 Safe Shutdown Systems Fire Detection and Signaling Systems Fire Control System.

4-1 4" 1 4-2

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TABLE OF CONTENTS Continued PAGE 4.3.1 Water Systems 4.3.1.1 4.3.1.2

4. 3.1. 3 4:3. l. 4 4.3.1.5 4.3.1.6

4. 3.'l. 7 Water Supply Fire Pumps Fire Water Piping System....

Interior Hose Stations Fixed Water, Suppression Systems..

Foam Suppression Systems Effects of Suppression System on Safety Systems 4-2 4-3 4-3 4-4 4-4 4-4 4-5 4.3. 2 Gas Fire Suppression Systems 4.3. 3 Portable Fire Extinguishers 4.4 Ventilation Systems and Breathing Equipment.

4. 4.

1 Ventilation Systems 4.4.2 Breathing Equipment.

4.5 Floor Drains 4.6 Lighting Systems....

4. 7 Communication Systems....

4.8 Electrical Cables 4.9 Fire Barrier Pen'etrations

4. 10 Separation Criteria.

4. 11 Fire Barriers.....

4. 12 Access and Egress

4. 13 Toxic and Corrosive Combustion Products 5.0 EVALUATION OF SPECIFIC PLANT AREAS 4-5 4-5 4-5 4-5 4-6 4-6 4-6 4-7 4-7 4-7 4-7 4-8 4-8 4-9 5"1 5.

1 Control Room..

5. 2 Cable Spreading Room.

5. 3 Inverter and Battery Rooms...........

5.4 Motor Generator Set and Battery Rooms 5.5 Rod Control Equipment Rooms...

5.6 Switchgear Rooms 5.7 Diesel Generator and Day Tank Rooms

5. 8 Auxiliary Building..

5. 9 Containment Penetration Rooms..

5. 10 Containment.......,..........

5. 11 Radwaste Building.

5. 12 Turbine Area.

5. 13 Yard Area.

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5-1 5-2 5-4 5-5 5-5 5"6 5-7 5-8 5-10 5-11 5-12 5-12 5-14

TABLE OF CONTENTS (Continued)

6. 0 ADMINISTRATIVE CONTROLS PAGE 6" 1

7. 0 TECHNICAL SPECIFICATIONS

8. Q CONCLUSION..

9. 0 CONSULTANTS'EPORT..

APPENDIX A CHRONOLOGY

'APPENDIX B DISCUSSION OF CONSULTANTS'EPORT 7-1 8-1'-1 A-1 B-1

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1. 0 INTRODUCTION Following a fire at the Brown's 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, "Recommendations Related to Browns Ferry Fire," NUREG-0050.

This report recommended that improvements in the areas of fire prevention 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 impo'rtant functions.

To implement the report's recommendations, 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.

4 The NRC issued new guidelines for fire protection programs in nuclear power plants which reflect the recommendations in NUREG-0050.

These guidelines are contained in the following documents:

"Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants,"

NUREG-75/087, Section 9.5. 1, "Fire Protection,"

May 1976, which includes "Guidelines for Fire Protection for Nuclear Power Plantb" (BTP APCSB 9. 5-1),

May 1, 1976.

"Guidelines for Fire Protection for Nuclear Power Plants" (Appendix A

to BTP APCSB 9.5-1),

August 23, 1976.

"Supplementary Guidance on Information Needed for Fire Protection Program Evaluation',"

September 30, 1976.

"Sample Technical Specifications,"

May 12, 1977.

"Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and equality Assurance,"

June 14, 1977.

"Manpower Requirements for Operating Reactors" Jupe 5,

1978.

All licensees were requested to:

(1) 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's analyses and have visited the plant to examine the relationship of safety-related components, systems. and structures with both combustibles and the associated fire detection and suppression systems.

Our review was based on the licensee's proposed 1-1

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program for fire protection as described in the following docketed information:

(1)

"Fire Protection Report," dated February 25, 1977; (2)

The fire protection review team's site visit of March 27-30, 1978; (3)

The licensee's response to staff positions, dated July 14, 1978.

Our review has been limited to the aspects of fire protection related to the protection of the public from the standpoint of radiological health and safety.

Me have not considered aspects of fire protection associated with life safety of onsite personnel 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 result of our evaluation of the fire protection program at Florida Power and Light Company's Turkey Point, Units 3 and 4.

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

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2.0 FIRE PROTECTION GUIDELINES 2.1 General Desi n Criterion 3 - "Fire Protection" The Commission's basic criterion for fire protection is set forth in General Design Criterion 3, Appendix A to 10 CFR Part 50, which states:

"Structures,

systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions.

"Noncombustible and heat resistent materials shall be used wherever practical throughout the unit, particularly in locations such's the containment and the control room."

0 2.2 "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."

"Fire fighting systems shall be designed to assure that their rupture or inadvertent operation does not significantly impair

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the safety capability of these structures, systems and components. "

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

Appendix A provides guidance on the preferred

and, where applicable, acceptable alternatives to fire protection design for those nuclear power plants for which applications for construction.permits were docketed prior to July 1, 1976.

Although this appendix provides specific guidance, alternatives may be proposed by licensees.

These alternatives are evaluated by the NRC staff on a case-by-case basis.

Additional guidance which provides clarification of Fire Protection matters has been provided by the NRC staff in the following documents:

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"Supplementary Guidance on Information Needed for Fire Protection Pr ogr am Evaluation," October 21, 1976.

"Sample Technical Specifications,"

May 12, 1977.

"Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and equality Assurance,"

June 14, 1977.

"Manpower Requirements for Operating Reactors, June

" J 5

1978.

E When the actual configuration of combustibles, safety-related structures, systems or components, and the fire protection features are not as assumed in the development of Appendix A or when the licensee has proposed alternatives to the specific recommendations of Appendix A, we have evaluated such unique configurations and alternatives using the defense-in-depth objectives outlined below:

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

In our evaluatioh, we assure that these objectives are met for the actual relationship of combustibles, safety-related equipment and fire protection features of the facility.

Our goal is a suitable balance of the many methods to achieve these indidividual objectives; increased

strength, redundancy, performance, or reliability of one of these methods can compensate in some measures for deficiencies in the others.

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3.0

SUMMARY

OF MODIFICATIONS AND INCOMPLETE ITEMS 3.1 Modifications

3. l. 1 The licensee plans to make certain plant modifications to improve the fire protection program as a result of both his and the staff's evaluations.

These proposed modifi,cations are summarized below.

The sections of this report which discuss the modifications are noted in parentheses following each item.

Further detail is contained in the licensee submittals.

The licensee will provide a schedule for all modifications within 60 days of the issuance date of this Safety Evaluation.

All modifications will be completed by December 1980.

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Certain items listed b'elow 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.

We request that this information be sub-mit'.ted within six months of the issuance date of this Safety Evaluation.

The balance of the other modifications has been described in an acceptable livel of detail.

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Fire Detection S stems i Early warning automatic fire detection systems will be provided in the

, following areas:

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In the makeup air supply to the control room (5.1).

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(2)

In the kite.'hen area of the control room (5.1).

l (3) in the roti control equi'pment ioome (5.5).

(4)

In the s>uitchgear rooms (5.6).

(5)

In the /diesel generator rooms (5. 7).

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In thj charging pump rooms (5.8).

(7)

In the chemistry laboratories (hot and cold labs),(5.8).

(8)

In the new laundry facility (5.8).

The licensee is reevaluating this commitment as part of the issues identified in Section 3.2.4 and 3.2.5.

We will require that this, or an equivalent improvement be made.

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3.1.2 3.1.3 Modifications will be made if required to insure an unimpeded flow path for smoke for the vertical control boards and freestanding panels to the smoke detectors located in the false ceiling of the control room {5.1).

Remote alarm lamps will be provided for the smoke detectors located above the false ceiling in the control room (5.1).

A fire watch patrol will be established to inspect the lower level of the turbine area at a frequency of once per hour (5'2).

Fire Mater Su 1

An adequately-sized spool piece connection will be provided with gated valves on the fire water loop and the discharge header of the screen wash pumps.

This connection will not be permanently installed (3.2.3 and

4. 3. 1. 1).

Yard H drants A 2<-inch gate valve will be provided at the hose house for installation at one of the two outlet ports at the yard hydrants

{4.3. 1.3).

The equipment in the yard hydrant hose cabinets will be augmented by the addition of one portable'and light, a hose

clamp, one 2<-inch fog nozzle with shutoff valve, and two 1<-inch spanner wrenches (4.3. 1.3).

Firehouse E ui ment The complement of equipment in the firehouse will be augmented by the addition of eight portable han'd lights, a forceable entry tool, two 2q-inch by 2<-inch doub'}e female adaptors, and protective clothing to outfit eight men.

Storage facilities will be provided in the firehouse foi two smoke

ejectors, six air breathing units, spare fire hose,

gaskets, and nozzles 3.1.5 Interior Hose Stations Booster hose stations with low flow capacity shutoff nozzles will be provided with sufficient hose reach for all of the following areas:

{1)

Control room (5.1).

(2)

Cable spreading room (5.2).

(3)

Switchgear rooms (5. 6).

The licensee is reevaluating this commitment as part of issues identified in Section 3.2.4 and 3.2.5.

Me will require that this, or an equivalent improvement, 3-2

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3.1.6 Water Su ression 5 stems 3.1.7 Fixed automatic water spray protection will be provided for the door and ventilation openings of the switchgear rooms which face main and auxiliary transformers (5.6).

3.1.8 Portable foam suppression equipment will be provided (4.3.1.6).

A means will be provided for introducing foam from a portable foam system into the diesel generator rooms and diesel fuel oil day tank rooms (5.7).

Portable Extin uishers Two portable 2< gallon pressurized water extinguishers will be provided in the control room (5.1).

3.1.9 Fire Ooors Ooors in the following areas will be replaced with rated fire doors as noted:

(1)

Access doors from cable spreading area to turbine building - 1<-hour rating (5.2).

(2)

Access doors from switchgear room to transformer area - three-hour rating (5.6').

(3)

Access doors from switchgear room to east turbine area - 1<-hour rating with fuse link dampers, normally closed (5.6):

(4)

Access doors to diesel day tank rooms (5.7).

(5)

Corridor access doors in the auxiliary building leading to the chem-istry laboratories (hot and cold labs) and new laundry facility-three-hour rating (5.8).

(6)

Access doors to containment electrical penetration rooms 1<-hour rating (5. 9).

The licensee.is reevaluating this commitment as part of issues identified in Sections 3.2.4 and 3.2.5.

We will require that this, or an equivalent improvement, be made.

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3. l. 11 Three-hour rated fire dampers will be provided in the ventilation openings of the switchgear room which faces the transformer areas.

These dampers will be normally closed (5.6).

The chemistry laboratories (hot and cold labs) and the new laundry facility will be isolated from the auxiliary building corridor by the use of 3-hour fire dampers in ventilation openings (5.8).

The side wall vent openings in the containment electrical penetration rooms will be protected by 1<-hour fire dampers (5.9).

Penetrations The openings between the floor and south wall of the upper level of the switchgear rooms will be sealed (5.6).

Penetrations in the wall separating the diesel generator units and between the diesel generator units and day tank rooms will be sealed to provide a

three-hour rated fire barrier (5.7).

3. 1. 12 Bar riers A barrier will be constructed to impede heat and smoke from entering the diesel generator rooms via the louvered openings facing the outdoor fuel oil storage tank (5. 7).

3. 1. 13 Curbs Curbs will be provided for the doors on the lower level of the switchgear r ooms. (5. 6).

A curb will be provided at the doorway-in the west wall of the south diesel generator room (5.7).

A curb will be provided at the doorway in the north wall of the Unit 3 charging pump room (5.8).

Curbing will be provided around each auxiliary feedwater pump (5. 12).

3. 1.14 Fire Retardant Cable Coatin s

Cables in trays with safe shutdown'related cables in the following areas will be covered with a flame retardant coating:

The licensee is reevaluating this commitment as part of the issues identified in Sectio'ns 3.2.4 and 3.2.5.

We will require that this, or an equivalent improvement, be made.

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(1)

Inver ter room (5. 3).

(2)

Containment (5. 10).

(3)

Lower level of turbine area (5. 12).

(4)

Auxiliary feed pump area (5.12)

(5)

In the vicinity of the condensate storage tank and transfer pumps (5. 13):

3. l. 15 Control of Combustibles The use of the hydrogen supply lines'n the auxiliary building corridor will be discontinued and new lines will be provided for use outside of this area (5. 8).

Plastic barrels in the auxiliary building used to collect radiation protective clothing will be replaced with barrels made of a fire retardant material (5.8).

The hydraulic coupling oil cooler lines on the charging pumps will be replaced with lines made of a noncombustible material (5.8).

The control point guard house at the entrance of the auxiliary building will be replaced by a structure of noncombustible construction (5.12)

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The oil dispensi'ng station at the south end of the turbine area will be relocated to "an area which wi'}1 not expose safety-related systems (5. 12).

The flammable chemical storage located on the ground floor of the turbine area wi 11 be relocated (5. 12).

Isolation valves will be provided within the diked area of the outdoor diesel fuel storage tank for the feed lines to the transfer pumps:

Manual bypass valves will be provided for the fail-closed isolation valves (5. 13).

3. 1. 16 Fire Fi htin Access Unused portions of cable trays in the containment electrical penetration rooms will be removed to improve fire fighting access..

Fixed ladder access will be provided for all levels of the penetration rooms (5.9).

The licensee is reevaluating this commitment as part of the issues identified in Sections 3.2.4 and 9.2. 5.

Me will require that this, or an equivalent improvement, be made.

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3.1.17 Smoke Ventin E ui ment Two fire service portable'smoke ejectors of the explosion proof type with a capacity of 5,000 cfm or greater will be provided for fire brigade use (4.4.1).

3.1.18 Air Breathin E ui ment

3. 1. 19 Air breathing equipment will be augmented to provide a total of 15 self-contained'ir breathing apparatus and 30 spare air cylinders.

At least 15 of the spare cylinders will be fully charged.

Six air cylinders will be stored at a readily accessible location near the control room.

A 6-bottle cascade system capable of refilling 23 air bottles will be provided (4.4.2).

Emer enc Li htin Fixed seal beam self-contained battery-operated lighting units will be provided in the control room, auxiliary building corridor, cable spreading

room, and switchgear rooms (4.6).

3.2 Portable seal beam battery-operated lights will be provided for fire brigade and emergency operations personnel use (4.6).

Incom lete Items 3.2.1 In addition to the licensee's proposed modifications, a few incomplete items remain, as discussed below.

The sections of this report which discuss these in'complete items are noted in parentheses.

We will address the resolution of incomplete items in a supplement to this report.

Your submittal should include a schedule for any additional modifications, such as may be required as a result of the resolution of the incomplete items.

Smoke Detection S stems Bench tests will be conducted on a minimum of 50% of the installed smoke detectors in each zone to'verify that the detectors will provide prompt response and have adequate sensitivity to the products of combustion for the co'mbustibles in the areas where they are installed.

If detection systems are found to be inadequate, appropriate modifications will be made

,to provide adequate detection system performance.

With regard to the adequacy of the smoke detection

systems, we have requested that in situ testing be conducted with a suitable smoke generation device to verify that the location and placement of smoke detectors is adequate to give prompt response and that the ventilation air flow patterns in the area do not significantly, reduce or prevent detection system response.

The licensee has not found a suitable means to conduct such tests 'in a manner which does not introduce further safety considerations..

Further action is being taken in the development of a suitable test method.

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However, if a practical solution to this type of testing cannot be estab-

'lished withjn six months of the date of this Safety Evalua-

tion, an evaluation by an independent registered fire protection engineer (as defined in our guidance dated February 23, 1978 attachment 1 page 3.)

knowledgeable in fire detection will be performed within nine months of the date of this Safety Evaluation to certify the adequacy of smoke detec-tion systems in lieu of in situ testing.

No additional information is requested from the licensee (4.2).

Reactor Cool ant Pum s

We have requested that an oil collection system be provided for each of the reactor coolant pumps.

The licensee has deferred action on this recommendation pending, the final resolution of an EPRI study, "Evaluation and Test of Improved Fire Resistant Fluid Lubricants for Water Reactor Coolant Pump Motors." If a suitable lubricant is not found, the licensee will provide a system to suppress potential fires or provide for the removal of potential oil leakage to a safe location by December 1980.

No additional information is required from the licensee (5. 10).

Water Su 1

We have requested that an adequate supply of water for fire protection be physically dedicated (e. g.

by 'a vertical standpipe).

We have requested that the licensee confirm his calculations on the adequacy of the screen wash pumps, as an alternate source of water for fire fighting, to meet the maximum area of demand for fixed systems.

We will request, should the screen wash pump's prove to be an adequate alternate water

source, that the spool piece, which the licensee

proposed, be permanently connected to the screen wash system to provide a completely redundant water supply.

When the above information on the water demand is available we will evaluate it arid report our findings in a supplement to this report.

This information will be provided within 60 days from the date of this Safety Evaluation (4. 3,1).

Auxi liar Buildin Corridor We have requested the installation of sprinklers to provide protection for safety-related cables from exposure fires in the auxiliary building corridor.

We have also requested additional information in our letter dated March 2, 1979 regar ding the shutdown of both units following a fire in this area.

After our review of the additional information we will report on the adequacy of the fire protection for the Auxiliary Building corridor (5.8).

Cable S readin Area It is our position that a capability independent of the cable spreading room should be provided to safely shutdown both units.

We have requested additional information from the licensee in our letter dated March 2, 1979 3-7

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3.2.6 to demonstrate that both units can be shut down independent of a fire in the cabling and equipment located in the cable spreading room.

After we have reviewed the additional information we will report on the adequacy of the fire protection plans for the cable spreading room (5. g).

Technical 5 ecifications for Existin E ui ment On November 8, 1978 amendments 42 and 34 were issued with limiting condi-tions for operation and surveillance requirements for existing fire protec-tion systems and administrative controls.

Certain exception taken by the licensee were identified as being subject to,further staff review.

The staff position in regard to those items is unchanged.

Ho additional information is required from the licensee.

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4.0 EVALUATION OF PLANT ARRANGEMENT Safe Shutdown S stems The licensee has conducted a thorough fire hazards analysis of the facility.

In each area of the plant, assessment has been made of the combustibles in the area.

An evaluation of the consequences of an unmitigated fire or the capability to achieve and maintain safe shutdown has been performed for most areas of the Plant.

The system components required for both hot and cold shutdown conditions including the routing of electrical cables were identified to assess the impact of fires on these systems.

This analysis has demonstrated that in most areas of the plant, an unmitigated fire would not threaten the capability to achieve safe shutdown.

In the remaining areas of the plant, fire detection and suppression systems are provided or have been proposed which are adequate to limit the conse-quences of fires in these ar eas with the exceptions of items identified in Section 3.2 of this report.

We find that, from our review of the plant arrangement of system components, equipment, and electrical

cables, and with consideration of the proposed improvements in the fire protection program and resolution of the open items, a sufficient basis may have been provided to assure that fire damage would not result in the loss of the capability to safely shut down and maintain the plant in a safe condition.

We will report on the adequacy of the safe shutdown systems in a supplement to this report.

Fire Detection a'nd Si nalin S stems A number of fire detection,and signaling systems are provided which transmit alarm and supervisory signals to the control room.

Supervisory signals are provided to indicate the location of the affected area or unit.

The fire detection system is powered from an AC panel backed up by station batteries on the loss of normal power.

Visual and distinct audible annunciation is provided in the control room for the detection system.

The system is divided into 12 zones.

The system meets the requirements of NFPA 720.

The plant presently does not have complete fire detection coverage and some areas containing or exposing safety-related systems do not have fire detection systems.

The licensee has proposed to install detectors in areas of concern as noted in Section 5.0 of this report.

Bench tests will be conducted on a minimum of 50'f the installed smoke detectors in each zone to verify that the detectors will provide prompt response and have adequate sensitivity to the products of combustion for the combustibles in areas where they are installed.

If detection systems are found to be inadequate, appropriate modifications will be made to provide adequate detection system performance.

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~ 1.1 Mith regard to the adequacy of the smoke detection

systems, we have requested that in situ testing be conducted with a suitable smoke genera-tion device to verify that the location and placement of smoke detectors is adequate to give prompt response and that the ventilation air flow patterns in the area do not significantly reduce or prevent detection system response.

The licensee has not found a suitable means to conduct such tests in a manner which does not introduce further safety consideration.

Furthe~

action is being taken on the development of a suitable test method.

However, if a practical solution to this type of testing cannot be estab-

lished, an evaluation by an independent registered fire.protection engineer (as defined in our guidance dated February 23, 1978 attachment 1 page 3) knowledgeable in fire detection will be performed to certify the adequacy of smoke detection systems in lieu of in-situ testing.

Me find that, subject to implementation of the above described modifica-

tions, and resolution of the open concerns on smoke detection

adequacy, the fire detection system may provide prompt response to fires.

We will report on the adequacy of the fire detection and signaling systems in a supplement to this report.

Fire Control S stems Water Su 1

Fire water is supplied to the fire water pumps from a 500,000-gallon potable raw water storage tank which is filled by a connection to the municipal water system capable of 700 gpm makeup f'low.

A 100,000-gallon elevated storage'ank is connected directly to the fire water mains.

Since both of these water sources are used for other than fire water

services, the quantity of water dedicated to fire water use is less than that required to insure an adequate fire water supply.

The licensee has agreed to administratively dedicate

.180,000 gallons of this water to fire protection purposes.

Me do not agree that administrative dedication of the fire water supply is an adequate measure of assuring that a proper fire water supply will be available.

We have requested that an adequate supply of water be physically dedicated by vertical standpipe(s).

In order to meet a longer-term demand for fire water, the licensee has proposed to provide a spool piece connection between gated valves on the fire water loop and the discharge header of the three screen wash pumps.

This connection would not be permanently installed.

Each screen wash pump is capable of supplying 1680 gallon/min and may be sufficient to meet the needs of the largest area of demand.

Me have requested the licensee to provide us with an analysis of water demand including the data for the largest area of demand, which demonstrates the adequacy of the screen wash n alternate source of fire fighting water.

If the screen wash pumps are shown to be an adequate backup water supply, we wi q

ll re vest that the spool piece connection be permanently installed..

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We find that, subject to implementation of the above described modification and resolution of the open items, the water supply may be adequate to meet the site fire water demand to protect safety-related systems.

We will report on the adequacy of the fire control systems in a supplement to this repor t.

Fire Pum s

Two horizontal shaft, electrical centrifugal fire pumps are provided in an open area adjacent to the raw water storage tank.

Each pump has a design capacity of 2000 gpm at 140 psig.

Fire pump A power is supplied from fossile Unit 2, while fire pump 8 is supplied from nuclear Unit 3.

Power can be supplied to f/re pump B from the nuclear facility's diesel generators.

t Supervisory pressure='in the fire main system is generally maintained at 125 psig to 150 psig by a service water booster pump rated at 1000 gpm at 132 psig.

Each pump is provided with an approved fire pump controller located in a weather tight enclosure adjacent to the pump.

The pressure switches to start the fire pumps're set to 75 psig for one pump and 65 psi for the second pump.

Pump start is annunciated in the control room.

A 500 gpm gasoline-powered portable pump is provided which can take draft from the cooling canal or intake to provide an'additional sources of fire water.,

The licensee wil"I provide additional information regarding the largest area of demand for fire water.

The fire pumps may have adequate capacity to satisfy the site fire water demand.

After our review of the additional information we will report on the adequacy of the pumps to satisfy the site fire water demands in a supplement to this report.

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Fire Water Pi in S stem The fire pumps discharge into two separate 10-inch connections to the underground loop which encircles the nuclear units and fossil Units 1 and 2 with a cross-connection between the nulqar and fossil units.

The fire loop encircling the nuclear unit is 10-inch cast iron.

All yard hydrants, automatic and manual water systems pre supplied by the fire loop.

Sectionalyzinq valves of the post-indicator type are provided to isolate various sections of the loop.

Hydrants are all provided with sectional valves on the yapd loop for isolation of the hydrants in case of repair or maintenance.

All post-indicator valves are administratively controlled by the use of seals and periodic inspections made to verify that the valves are in the proper position.

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Yard hydrants are strategically located around the exterior of the plant.

Five hose houses are provided, each equipped with most of the necessary items for manual fire fighting.

A few additional items will be provided.

The hydrant hose threads are compatible with the local fire department.

A 2<-inch gate valve will be provided for each hydrant.

This will permit an additional hose to be connected to the hydrant without the need to shut down the hydrant.

Additionally, a hose clamp will be provided in each of the hydrant hose cabinets.

The existing equipment in the hydrant hose cabinets will be augmented by the addition of one portable hand light one 2<-inch fog'nozzle with shutoff valve, and two 1<-inch spanner wrenches.

We find that, subject to implementation of the above described modifications, the fire water system is adequate to supply the fixed fire water suppression systems and manual hose stations.

This satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

4.3. 1.4 Interior Hose Stations There are 21 interior hose stations strategically located throughout the

plant, Host hose stations are of the hose reel type equipped with 75 feet of 1<-inch woven jacket lined fire hose.

All areas are accessible, within 20 feet of the fog nozzle, when hose lines are laid out.

One-inch booster hose reels with low capacity nozzles and shutoff valves will be provided with sufficient hose reach for all areas of the control room, switchgear

rooms, and cable spreading room.

We find that, subject to implementation of the above described modification, the interior hose stations are adequate to provide manual'fire water suppression capability.

This satisfies the objectives identified in Section

2. 2 of this report and is, therefore, acceptable.

4. 3. l. 5 Fixed Water Su ression S stems Various areas of the turbine building are protected by a hydraulically-designed sprinkler system.

Specific hazards, such as turbine lube oil storage and hydrogen seal oil units, are protected by automatic deluge systems.

The transformers in the yard area are protected by automatic deluge systems actuated by heat detectors.

Each system is fed directly from the underground water mains.

We find that the fixed water suppression

systems, are adequate to suppress fires.

This satisfies the objectives identified in Section 2.2.of this report and is, therefore, acceptable.

4.3.1.6 Foam Su ression Portable manual foam suppression equipment will be provided to protect the diked area of the diesel oil storage tank and for,other possible oil fires at various locations within the plant,

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We find that, subject to implementation of the above described modification, the foam suppression is an additional effective capability to suppress combustible liquid fires. 'h'is satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

4.3. 1.7 Effects of Su ression S stems on Safet S stems 4.3.2 Inadvertent operation of a fire protection system will not adversely affect safety-related equipment.

A low flow capacity hose station with shutoff nozzle will be provided at the entrance to the control

room, switchgear room and cable spreading room which will minimize the potential for water damage to electrical equipment.

Gas Fire Su ression S stems 4.3.3 An automatic total flooding Halon 1301 system is installed in the document control center.

Fixed gas suppression systems are not used to protect any safety-related areas.

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

The fire extinguishers meet the require-ments of the National Fire Protection Association.

Two portable 2< gallon pressurized water extinguishers will be provided in the control room.

4 4 4.4.1 We find that, subject to implementation of the above described modification, the portable fir'e extinguishers provide adequate initial fire suppression capability for small fires.

This satisfies the objectives identified in Section

2. 2 of this report and is, therefore, acceptable.

Ventilation S stems and Breathin E ui ment Ventilation S stems 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, The fans and other equipment in the air handling systems are not designed 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..

Two fire service portable smoke ejectors of the explosion-proof type with a capacity of 5,000 cfm or greater will be provided for fire brigade use.

We find that, subject to implementation of the above described modifica-tion, 'the capability for smoke and heat venting satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

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4.5 Breathin E ui ment Existing air breathing equipmept will be supplemented to provide a total of 15 self-contained air breathing apparatus and 30 spare air cylinders.

Six air cylinders will be stored pt a readily accessible location near the control room as replacement for the three apparatus located therein.

A six-bottle cascade system capable of refilling 23 air bottles will be provided.

Additional backup capability for air breathing requirements can be provided by responding offsite fire assistance groups.

We find that, subject to implementation of the above described modifications, the air breathing equipment capability is adequate to insure that fire fighting access can be provided in a hostile environment.

This satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

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

The licensee analyzed the capacity of the drains in each area of the plant to assure that they were adequate.

Curbs will be provided for several areas to limit the spread of oil spill fires as noted in=

Section 5.0 of this report.

We find that, subject to the modifications noted herein, the floor drain system is adequate to remove fire suppression water and combustible liquid spills to prevent damage to safety-related equipment.

This satisfies the objectives ident'ified in Section

2. 2 of this report and is, therefore, acceptable.

4.6 Li htin S stems The normal lighting system receives its power from the station auxiliary transformers.

Upon the loss of these

sources, standby sources are made available from the station batteries and the diesel generators to provide an uninterrupted supply of power.

The licensee has proposed to provide fixed seal beam self-contained battery-operated lighting units in the control room, auxiliary building corridor, cable spreading

room, and switchgear rooms.

In addition, portable seal beam battery-operated lights will be provided for fire brigade and emergency operations personnel use.

We find that, subject to implementation of the above described modifica-

tions, the emergency lighting provided for both operating personnel and

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the fire brigade is adequate to deal with emergency conditions.

This satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable,,

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4.7 4.8 Communication S stems Normal communication within the plant is provided by two installed systems.

The first is a page and answer system with stations loca/ed throughout the plant.

Backup power is provided for this system.

A second system consists of telephone stations located throughout the plant.

Portable walky-talky units are also provided for emergency use.

We find that the communications are adequate to coordinate fire fighting and safe shutdon activities.

This satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

Electrical Cables The cable insulation used in the plant consists of butyl rubber and polyeth-ylene insulated conductors.

Cables routed in the containment have cross-

'Iinked polyethylene insulated conductors.

Most cable jackets are polyvinyl

~chloride with some cables having neoprene jackets.

The flame test standard

'Ifor cables, IEEE Std. 383-1974, was not in effect at the time cables were

,'urchased and installed.

Flame retardant coatings have been used exten-sively and in,all areas of high cable concentration to reduce the fire.

,<<hazards associated with combustible insulation materials.

I We find that the use of fire retardant coatings adequately addresses the combustible characteristics of cable insulation materials in some areas.

With the exception of the open items (3. 2. 4,

3. 2. 5) this satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

We 'will report on these open items in a supplement to this report.

Fire Barrier Penetrations Fire barriers are penetrated by doorways, ventilation ducts, electrical

cables, piping and conduit.

Tests have been conducted to demonstrate the adequacy of electrica'1 penetration seals.

The licensee has proposed to replace existing doors with fire rated doors and upgrade other openings where exposure. fire hazards exist, as noted in Section 5.0 of this report.

We find that, subject to implementation of the modifications for fire barrier penetrations as summarized in Section 3.0 of this report, the fire barrier penetrations are adequate to prevent the spread of fires.

This satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

4. 10 Se aration Criteria Cable trays for redundant divisions of safety-related cables are physically separated by a distance of one foot in some areas of the. plant..

The cables in these areas and other areas of large cable concentration have 4-7

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been covered with a fire retardant coating.

This protection reduces the hazards associated with the combustible cable insulation.

As noted in Section

4. 1, the licensee's fire hazards analysis has addressed the impact of unmitigated fires on the capability to achieve safe shutdown.

With the existing fire protection measures and proposed improvement in the fire protection program, adequate measures will be provided to insure that the plant can be safely shut down and maintained in a safe condition for any potential fire situation subject to the resolution of the open items identified in Section 3.2 of this report.

We find that the fire protection program may adequately address the physical separation of redundant systems.

With the exception of the open items (3.2.4, 3.2.5) this satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

We will report on these open items in a supplement to this report.

Fire Barriers I

The licensee's fire hazards analysis addressed fire barrier requirements by consideration of the combustibles in each fire area.

The potential energy release for all combustibles in an area was calculated to determine the fire severity and duration to evaluate the adequacy of fire barriers.~

With the exception of fire barrier penetrations noted earlier in Section 4.9, the fire barriers consisting of walls, floors, and ceilings are adequate for the combustible loading in the area.

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We find that the fire barriers are adequate to prevent the spread of fire.

This satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

Access and E ress Access to most areas of the plant is relatively easy due to the lack of an enclosure around the turbine.

Open stairs to the outside provide access to the cable spreading room and control room.

The auxiliary building is basically one story with a main corridor providing access directly to most of the safety-re]ated equipment.

The most difficult access is to the residual heat removal pumps which are at a low level in the axuiliary building.

Open stairs lead

'down from above directly into the room.

Due to very low combustible loading, fire fjghting access is acceptable.

The electrical penetrations rooms have difficult access to the upper levels due to cable tray obstructions and the lack of permanent ladders.

The licensee will eliminate some cable tray obstructions an) install, permanent ladders to upper areas.

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We find that subject to implementation of the above described modifications, the provision for access and egress are adequate for manual fire fighting and evacuation in safety-delated areas.

This satisfies the objectives identified in Section

2. 2 of this report and is, therefore, acceptable.

Toxic and Corrosive Combustion Products The products of combustion for many plastic materials, most common being cable insulation and jacket materials, are toxic to humans and corrosive to metals.

'Fire retardant coatings, fire detection and extinguishment are relied upon to minimize the quantities of such products.

Additional means of smoke removal wi 1.1 be provided as an aid in fire fighting access as noted in Section 4.4.

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

Many areas of the plant are open to the atmosphere and therefore toxic materials would be dissipated quickly.

We find that adequate precautions have been taken to minimize the effects of toxic and corrosive products.

This satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

5.0 EVALUATION OF SPECIFIC PLANT AREAS The licensee has performed a fire hazards analysis. of the facility to determine the fire loading. of various plant areas, to identify the consequences of fires in safety-related and adjoining nonsafety-related

areas, and to evaluate the adequacy of existing and proposed fire protec-tion systems.

The results of the fire hazards

analysis, other docketed information and site visit observations were used in the staff's evaluation of specific plant areas.

The staff's evaluation of specific areas is discussed in the following sections.

Control Room Safet -Related E ui ment The control room contains the controls for normal station operation and for shutdown of the plant under abnormal conditions.

Operating indicators,

controls, and alarms are mounted on an operations console and an L-shaped, open back control board for each unit.

Reactor protection and auxiliary electrical equipment, enclosed in free-standing

panels, are located in the area behind the control boards.

Combustibl es The combustibles'n the area consist of electrical wire and cable insula-tion materials and miscellaneous items used to support operations.

A small kitchen is located in one area of the room.

Conse uences if No Fire Su ression An unmitigated fire in the control room has the potential for damaging redundant divisions of safety-related equipment.

Isolation switches have been provided, remote from the control room, which may be used to isolate vital equipment from the effects of damage due to a fire.

The capability exists for safe shutdown independent of fire damage in the area.

Fire Protection S stem Fire detection is provided in the area by five thermal detectors and nine ionization smok'e detectors mounted at the ceiling of the area.

A smoke detector is provided in each of the reactor operator's consoles.

Portable CO extinguishers are provided in the control room and additional units ar('ocated in adjacent areas.

Hose stations are located on the turbine deck nearby.

Cables routed above auxiliary panels are coated with a fire retardant coating.

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Ade uac of Fire Protection The present means to extinguish potential fires in the control room are inadequate.

Smoke detection devices located above the false ceiling are not readily visible to permit the identification of the detector location which could have initiated an alarm.

The kitchen area of the control room presents a

smoke hazard which was not addressed in the licensee's fire hazards analysis.

Adequate assurance has not been provided to establish the adequacy of the existing fire detection system.

Modifications The licensee has proposed the following modifications.

Two portable 24 gallon pressurized water extinguishers will be provided in the control room.

A booster hose station with a low flow capacity shutoff nozzle will be provided with sufficient hose reach for all areas of the control room.

A smoke detector will be provided in the makeup air supply to the control ri.m.

Remote alarm lamps will be provided for the smoke detectors and installed to be visible from the area below.

Modification will.be made if required to ensure an unimpeded flow path for smoke from the vertical control boards and freestanding panels to the smoke detectors located in the false ceiling area.

The in situ testing program (3.2. 1) will determine the need for any additional modifications.

Fire detection will be provided in the kitchen area.

We find that, subject to implementation of the above described modifications',

the fire protection for the control room satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

Cable S readin Area Safet -Related S stems The shared cable spreading room for Units 3 and 4 is located below the control room.

The area houses the reactor protection system instrument

racks, and cables are routed in the area which terminate at the control room control boards and panels, and at electrical equipment enclosures within the cable spreading room.

Combustibles The combustibles in the area consist of electrical wire and cable insula-tion materials and a small quantity of paper associated with the plant computer.

Conse uences if No Fire Su ression An unmitigated fire in the cable spreading room could effect more than one division of safety-related equipment.

All cables routed.through the area have been coated with a fire retardant coating which minimizes the rate of fire spread should a fire occur.

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5.2.4 Fire Protection S stems Fire detection is provided throughout the area by ionization smoke detectors.

A portable dry chemical extinguisher is provided in the area and additional portable fire extinguishers are located in nearby 'areas.

Two hose stations located on the turbine mezzanine deck serve the area.

5.2.5 Ade uac of Fire Protection Nonrated doors provide access to the cable spreading area from the adjacent turbine area.

This presents a potential exposure hazard to the cable spreading room.

The two hose stations accessible to this area have water flow capacities of 100 gpm and 75 pgm, respectively.

For this area, with its existing protection provided by flame retardant coatings, the fire hoses do not provide a controlled water suppression capability which is needed to reduce the potential for water damage to electrical equipment.

The licensee has assumed that cables coated with flamemastic are removed from the combustible inventory.

We do not agree with this assumption because we cannot confirm that the flamemastic provides sufficient protection for the existing separation and combustible content of the room.'lame retardant coatings provide a measure of protection for grouped cables.

However, tests have shown that exposure fires with 'flame retardant coatings applied to non-IEEE 383 cables do propagate given the

~ rig'ht fire conditions of geometry, spatial separation and fire loading.

It is our position that a capability independent of the cable spreading room be provided for bot units.

We have requested the 1'icensee to provide task/manpower analysis that shows the station has the manpower and procedures to simultaneously shut down both units independent of cabling and equipment in the cable spreading room.

5. 2.6 Modifications 1

The licensee has proposed the following modifications.

Access doors from the turbine area will be replaced with 1<-hour rated class B fire doors.

A booster hose station with a low flow capacity shutoff nozzle will be provided which is capable of reaching all areas of the cable spreading room.

The licensee has assumed that cables coated with flamemastic are removed from the combustible inventory.

We do not agree with this assumption because we cannot confirm that the flamemastic provides sufficient protec-tion for the existing separation and combustible content of the room.

We have requested the licensee to provide an evaluation that shows the plant has the manpower and procedures to shut down independent of unmitigated fire damage in the cable spreading room.

The licensee is reevaluating this commitment as part of the issues identified in

. Section

3. 2. 4 and 3. 2. 5.

We will require that this, or an equivalent improvement, be made.

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5. 3.1 We wi,ll address the adequacy of the fire protection for the cable spreading room in a supplement to this report.

Inverter and Batter Room Safet -Related E ui ment The inverter room is located adjacent to the control room and provides access go two separately enclosed battery rooms.

The inverter room houses battery chargers and two OC motor control centers, for one division of safety-related equipment for each unit.

Three divisions of inverters for each unit are located in the area.

5.3.2 Combustibles The combustibles in the area consist. of electrical wire and cable insula-tion materials.

533 Conse uences if No Fire Su ression An unmitigated fire in the area would be limited to a single division of safety-related equipment.

Cables routed in the area have been covered with a fire retardant coating.

The impact of a fire in either battery room would be limited to the damage of a single division of batteries located therein.

5.3.4 Fire Protection S stems Fire detection i's provided in the inverter room by ionization smoke detec-

tors, and heat detectors are provided in each battery room.

A ceiling vent is provided in each battery room with a direct exhaust to outside the building to preclude the accumulation of hydrogen within the battery rooms.

A portable CO>extinguisher is provided in the area and additional portable fire extinguishers are provided nearby.

5.3.5 Ade uac of Fire Protection

5. 3.6 The fire protection provided for the inverter and battery rooms is adequate to limit 'the consequences of fires in these areas.

Modifications The licensee has proposed to cover all cable in trays with safe shutdown related cables in the inverter room with a flame retardant coating.

We find that, subject to implementation of the above described modifica-tion, fire protection provided for the inverter and battery rooms satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

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~ 5.4.1 5.4.2 Motor Generator Set and Batter Rooms Safet -Related E ui ment I

Two motor generator set

rooms, one for each unit, are located adjacent to the cable spreading area.

These rooms provide access to two enclosed battery rooms.

The motor generator set rooms contain a

DC motor control center and battery charger associated with each battery.

Combustibles The combustibles in the areas consist of electrical insulation materials and a few gallons of oil associated with the motor generator sets.

Conse uences if No Fire Su ression 5.4.4 An unmitigated fire in the motor generator set or battery rooms would be confined to the area involved and damage would be limited to a single division of safety-related systems.

Fire Protection S stems Fire detection is provided in the motor generator set rooms by ionization smoke detectors, and heat detectors are provided in each battery room.

A ceiling vent is provided in each battery room with a direct exhaust to outside the building to preclude the accumulation of hydrogen within the battery rooms.

Portable COzextinguishers are provided in the areas and additional fire extinguishers are located nearby.

All cable trays in the motor generator set rooms have been covered with a fire retardant coating.

5. 4.5 Ade uac,of Fire Protection Me find that the fire protection provided for the motor generator set and battery rooms satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

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5. 5.1 Rod Control E ui ment Rooms Safet -Related E ui ment The rod control equipment rooms house the control rod gquipment panels and a motor control center.

Cables for safety-related and shutdown. systems are routed through the area.

5.5.2 Combustibles The combustibles in the area consist of'electrical wire and cable insula-tion.mater ials.

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Conse uences if No Fire Su ression An unmitigated fire in the area could damage circuits for remote operated valves.

Valves could be operated locally to provide the desired function.

Loss of control rod equipment functions would result in rod insertion.

Fire Protection S stems Portable extinguishers and hose stations are provided in adjacent areas.

All cable trays have been covered with a fire retardant coating.

Ade uac of Fire Protection The lack of fire detection prevents prompt response to fires in this area.

Modifications The licensee has proposed to provide smoke detectors in the rooms.

We find that, subject to implementation of the above described modifica-tion, the fire protection for the rod control equipment rooms satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

Switch ear Rooms Safet -Related E ui ment A separate switchgear room is provided for each unit.

The switchgear rooms are divided into four basic areas with redundant 4160V switchgear located at grade elevation which is separated by a concrete wall.

A passageway joins the two areas.

A mezzanine level is provided above one of the 4160V switchgear with an opening to the other 4160V switchgear area.

The mezzanine level is divided into two areas with a passageway joining each area.

Each area of the mezzanine level contains two sets of redundant 480V switchgear.

Cable trays are routed throughout each area.

Combustibles The combustibles in these areas consist of electrical wire and cable insul ati on materi al s.

Conse uences if No Fire Su ression An unmitigated fire in any of the four separate areas would be limited to that area.

Fire damage would be limited to a single division of 4160V switchgear or one set of redundant 480V.switchgear on the mezzanine level.

However, safe shutdown equipment would be operable from the other set of redundant 480V switchgear in the adjacent area.

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Fire Protection S stems Portable extinguishers and hose stations are located in adjacent areas.

All cable trays have been covered with a fire retardant coating.

Ade uac of Fire Protection The 1ack of fire detection prevents prompt response to fires in these areas.

The main power transformer and startup transformers are located in-close proximity to nonrated access doors'nd ventilation penetrations for the switchgear rooms.

Nonrated access doors in the east end of the switch-gear rooms provide access from the turbine area.

Nodifications The licensee has proposed the following modifications.

Smoke detectors will be provided in each area of the switchgear rooms.

The doors facing tl =. transformers will be replaced with three-hour fire rated doors.

Three-hour fire rated Class A dampers will be provided in the ventilation openings adjacent to the transformers.

Fixed water spray protection will be provided for the doors and ventilation openings facing the transformer areas.

The doors in the east wall of the switchgear rooms will be replaced with 1<-hour fire rated Class 6 doors with louvered openings.

The louvers in the doors and ventilation openings will be closed except when emergency ventilation is required for cooling the rooms.

Fuse links will provide for automatic closure to protect these openings.

Curbs will be provided at the doors on the lower level of the switchgear rooms.

Booster hose stations with a 'low flow capacity shutoff nozzle will be provided with sufficient hose to reach all areas of the switchgear rooms.

The openings between the floor and the south wall of the 480V switchgear areas will be sealed.

Me find that, subject to implementation of the above described modifications, the fire protection for the switchgear rooms satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

Diesel Generator Rooms and Da Tank Rooms Safet -Related E ui ment Each of the two diesel generators, including associated control panels, and the fuel oil day tanks are located in separate roops in a freestanding structure, A 275-gallon day tank is an integral part of the diesel gener-ator.

One diesel generator is capable of supplying power for safe shutdown upon the loss of offsite power.

A 4000-gallon diesel day tank is located in a separate room above each of the diesel generators.

Combustibles Each integral diesel day tank contains 275 gallons of diesel fuel and the crankcase contains 250 gallons of lubricating oil.

The 4000-gallon day tank supplies fuel to the integral tank by gravity feed.

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Conse uences if No Fire Su ression An unmitigated fire in a diesel generator room would cause the loss of the diesel generator and cou'Id affect the adjacent unit via unprotected pene-trations in the fire wall separating the two units.

Fire Protection S stems Fire fighting equipment consists of portable fire extinguishers and a

hydrant with hose house outside the building.

Ade uac of Fire Protection The lack of fire detection prevents prompt response to fires in this area.

The penetrations in the walls common to the day tank and diesel generator rooms are inadequate to prevent the spread of a fire between these areas.

A ~ire in the diked area of the outdoor fuel oil storage tank has the po..ntial of causing a hazard through the vent openings in the diesel generator rooms.

Access to the day tank rooms is from an elevated platform from a stairwell on the oustide of the building.

As such, ready access is not available to apply extinguishing agents to a fire in the day tank rooms.

Hodifications The licensee has proposed the following modifications.

Fire detection will be provided in the diesel generator rooms.

Penetrations in the wall separating the d'iesel generator units and between the diesel generator units and day tank rooms will be sealed to provide 3-hour rated protec-tion.

A curb will be installed at the doorway in the west wall of the south diesel generator room.

The existing doors to the day tank rooms will be replaced with fire rated doors.

A portable foam system will be provided to augment the fire brigade equipment to enhance the ability of fighting flammable liquid fires in these areas.

A means will be provided for introducing foam into the day tank and diesel generator rooms; A

barrier will be constructed to impede heat and smoke from enterin'g the diesel generator rooms via the louvered openings facing the outdoor oil storage tank.

We find that, subject to implementation of the above described modifica-

tions, the fire protection for the diesel generator and day tank rooms satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

Auxi')iar Bui ldin Safet -Related E ui ment A north-south and an east-west corridor provide access to separate rooms within the auxiliary building and are used for routing of electrical cables to these individual areas.

Separate rooms are provided for different systems such as charging

pumps, residual heat removal pumps and exchangers, 5-8

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safety injection pumps, and component cooling water pumps and exchangers.

l1otor control centers are located in the corridor areas.

5.8.2 Combustibles 5.8.3 The combustibles in the area consist of electrical wiring and insulation materials, lube oil, hydrogen lines, and radiation protective clothing which is collected at selected control points.

Liquid combustible agents are used in the radiochemistry laboratory.

Transient combustibles are moved through the corridor area as needed.

Conse uences if No Fire Su ression An unmitigated fire in the area could result in damage to control cables for safe shutdown systems routed in the corridor areas.

Safe shutdown could be achieved by operation of breakers at switchgear since power cables for essential functions are routed in underground ducts.

Local operation of valves provides an alternate method of valve lineup if the control functions are lost due to fire.

5.8.4 Fire Pr otection S stems 5.8.5 Ionization smoke detectors are located in access corridors.

Hose stations and portable fire extinguishers provide manual suppression capability for the auxiliary building.

Additional water suppression capability could be provided from yard hydrants.

All cable trays have been covered with a firg retardant coating.

Ade uac of Fire Protection 5.8.6 The lack of fire detection in the charging pump rooms prevents prompt response to fires in these areas.

The hydrogen line routed through the auxiliary building corridor poses a potential fire hazard to safety-related cables in the area.

The chemistry laboratory (hot and cold lab) contains combustibles which are an exposure hazard to safety-related cables routed in the adjacent corridor.

The new laundry poses a similar hazard.

Modifi'cati ons The licensee has proposed the following modifications.

Fire detection will be provided in the charging pump rooms.

The use pf the hydrogen lines in the area of redundant safety-related cable trays in the auxiliary building corridor will be discontinued and new lines will be installed outside the areas.

The chemistry laboratories will be isolated from the auxiliary building corridor by three-hour rated fire doors and fire dampers.

The licensee is reevaluating some of these commitments as part of the i'ssues identified in Sections

3. 2. 4 and

3. 2. 5.

We will require that these, or equivalent improvements, be made.

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Fire detectors will be provided in these laboratories.

The new laundry facility will be isolated from the auxiliary building corridors by 3-hour rated fire doors and fire dampers.

Fire detection will be provided in the new laundry facility.

Plastic barrels used to collect radiation protec-tive clothing will be replaced with barrels made of a fire retardant material.

The hydraulic coupling oil cooler lines on the charging pumps will be replaced with lines made of a noncombustible material.

A curb will be installed at the doorway in the north wall of the Unit 3 charging pump room.

We have requested sprinkler protection for the safety related cables sufficient to cope with exposure fires.

We have also requested a

task/manpower analysis to show that the plant has adequate procedures and mynpower to shut down both units independent of cabling in the auxiliary building corridors.

We find that, subject to implementation of the above described modifications and satisfactory resolution of the open items concerning sprinkler protection and shutdown independent of the cabling in the areas of the auxiliary building corridor we find the fire protection for the auxiliary building acceptable.

We will report on these open items in a supplement.to this report.

Containment Penetration Rooms Safet -Related E ui ment r

Two containment penetration rooms are provided for each containment building through which cables are routed and terminate at containment electrical peqetrations.

Each room is accessible from an entrance at grade elevation.

Platforms are pr'ovided at various elevations within each room.

Combustibles The combustibles in the area consist primarily of electrical cable insul ati on.

Conse uences if No Fire Su ression An unmitjgated fire in the containment penetration rooms may result in damage to redundant divisions of safety-related cables.

Fire Protection S stems Smoke detectors are provided in the containment penetration rooms.

Portable extinguishers and hose stations are located in nearby areas.

Ade uac of Fire Protection Access to the cable penetration areas above grade level is obstructed by unused cable trays.

Some areas do not have fixed ladder.access.

The area is exposed to external hazards due to unprotected ventilation openings and nonrated fire doors.

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Modifications The licensee has proposed'the following modifications.

Unused cable trays in the electrical penetrations rooms will be removed to improve fire brigade access.

Fixed ladders will be provided for access to each eleva-tion in the room.

Access doors will be replaced with 14-hour Class 8

doors.

Fire dampers rated for 1<-hour protection will be provided in the side wall vent openings of the room.

Me find that, subject to implementation of the above described modifica-tions, the fire protection for the containment penetration rooms satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

Containment Safet -Related E ui ment The safety-related equipment in the containment includes valves, controls, instrumentation, and electrical cables.

Combustibles The combustibles inside containment include 200 gallons of lube oil for each reactor coolant pump, electrical cable insulation and charcoal filters.

Conse uences if Ho Fire Su ression An unmitigated fire in the containment could damage redundant divisions of safety-related systems required for safe shutdown.

Fire Protection S stems Fire protection inside containment consists of portable dry chemical and carbon dioxide extinguishers.

Fire detection is provided at the cab]e penetration areas.

Fire retardant, coatings have been provided for cables at the penetration opening.

Ade uac of Fire Protection The lack of coatings on some of the cables adjacent to.the penetration area could allow the spread of fire along the tray to adjacent areas.

An adequate means has not been provided for the reactor coolant pump to contain a lube oil spill and keep it from spreading to other areas.

Modifications The licensee has proposed to coat the remaining cable trays with safe shutdown related cables with a fire retardant coating.

The staff has 5-11

requested that an oil collection system be provided for each of the reactor coolant pumps.

The licensee has deferred action on this request pending the final resolution of an EPRI study, "Evaluation and Test of Improved Fire Resistant Fluid Lubricants for Water Reactor Coolant Pump'otors."

If a suitable lubricant is not found, the licensee will provide a system to suppress potential fires or provide for the removal of potential oil leakage to a safe location.

5. 11 5.11.1

5. 11. 2

5. 11. 3 We find that, subject to implementation of the above described modifications, the fire protection for the containment satisfies the objectives identified in Section

2. 2 of this report and is, therefore, acceptable.

Radwaste Bui ldin Safet -Related E ui ment No safety-related equipment is located in the radwaste building.

Cu; buetiblee The combustibles in the area include dry low level contaminated

waste, small quantities of cable insulation, plastic sheeting materials, dry

resins, and filters.

Conse uences )f No Fire Su ression An unmitigated fire in the area would not result in damage to systems required for safe shutdown.

Fire damage would be limited to control or power circuits for waste processing systems and would not result in the release of radioactive materials, exceeding those previously analyzed for radwaste systems.

5. 11.4 Fire Protection S stems

5. 11. 5 Hose stations and portable extinguishers are located in the area.

Ade uac of Fire Protection

5. 12

5. 12.

1 We find that fire protection provisions for the radwaste building satisfy the objectives of Section 2.2 of this report and are, therefore, acceptable.

Turbine Area Safet -Related E ui ment The turbine generator units are mounted on a pedestal with the main deck forming a roof over the mezzanine area below.

All equipment is located in an outdoor environment.

The only safety-related components are electrical cables routed between the switchgear rooms and control complex, and the auxiliary feedwater pumps.

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5. 12. 3 Combustibl es

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The major combustibles in the turbine area consist of the turbine generator lube oil and hydrogen sea') oil systems.

Oil and chemicals are stored in the turbine area.

The control point guard house at the entrance to the auxiliary building is of wood construction.

Conse uences if No Fire Su ression An unmitigated oil spill fire in the turbine area has the potential of spreading to areas which could damage safety-related cables.

5. 12.4 Fire Protection S stems A wet pipe sprinkler system provides area'coverage for the ground'level of the turbine area.

Hose stations and yard hydrants provide fire water for ma ual fire suppression.

Portable extinguishers are located in the area ana adjacent areas.-

5.'l2.5 Ade uac of Fire Protection Oil and chemicals stored in the turbine area are an exposure hazard to cable trays in the turbine area.

Likewise, the control point guard house at the entrance to the auxiliary building creates an exposure hazard.

The lack of fire detection in the lower area of the turbine prevents prompt response to fires which could damage safety-related cables.

5.'12.6 Modifications The licensee has proposed the following modifications.

All cable trays with safe shutdown related cables in the lower level of the turbine area

'and auxiliary feed pump area will be covered with a flame retardant coating.

Curbing will be provided around each auxiliary feedwater pump.

The existing control point guard house will be replaced by a structure of noncombustible construction.

The oil dispensing station at the south end of the turbine area will be relocated to an area to remove the fire exposure hazard to safety-related cables.

Likewise, the flammable chemical storage located on the ground floor of the turbine area will be relocated.

A fire watch patrol will be established to inspect the lower level of the turbine area at a frequency of once per hour.

The licensee has not shown that the water supply is adequate for the water demand in the turb'ine. building. If the water demand cannot be met for the turbine building, the licensee must show that safety-related systems are not endangered by the loss of the turbine building.

We will report on this subject in a supplement to this report.'e find that, subject to implementation of the above described modifications and fire watch patrol, the fire protection for the turbine area satisfies the objectives identified in Section 2.2 of this report and is., therefore, acceptable.

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5. 13 5.13.

1 Yard Area Safet -Related E ui ment The safety-related equipment in the yard area includes safety-related

cables, service water pumps, and condensate storage tanks.

Fire pumps are located in the open area adjacent to the raw water storage tank.

5. 13.2 Combustibles 5.13. 3 Combustibles in the yard area include transformer oil, hydrogen storage, gas cylinder storage, and the 60,000-gallon fuel oil storage tank.

Conse uences if No Fire Su ression

5. 13. 4 Due to the close proximity of the 60,000-gallon fuel oil storage tank to the diesel generator air intakes, an unmitigated fire in this area may t.~ve an adverse effect on the diesel generators.

The main and auxiliary t.lnsformers are located in close proximity of a louvered access door to the switchgear rooms.

Failure of the deluge systems to mitigate a fire at the transformers could lead to an exposure to the switchgear.

Fire Protection S stems The transformers are protected by automatic deluge systems actuated by heat detectors.

The transformers are located in either diked areas with drains or on crushed stone with dpainage.

Fire water from pard hydrants is provided for manual fire fighting.

Fire fighting equipment is located in hose houses located around the yard loop and an equipment fire house.

5. 13. 5 Ade uac of Fire Protection As noted in Sections 5.6 and 5.7 of this report, modifications have been proposed to reduce the exposure hazards to the switchgear rooms and diesel generators including the provisions of manual foam suppression equipment.

The fuel oil tank is located in a diked area; however, the transfer pumps are located outside the diked area.

A. failure in the pump or feeds could allow oil in the tank to spread over the yard area outside the diked area adjacent to the diesel generators.

The fire house does not contain an adequate complement of equipment which is readily avai)able for the fire fighting needs in the area.

5.13. 6 Modifications The licensee has proposed the following modifications.

All cable trays with safe shutdown related cables in the vicinity of the condensate storage tanks and transfer pumps will be covered with a flame retardant coating.

Isolation valves will be provided within the diked area for the fuel oil 5-14

lines to the transfer pumps.

Manual bypass valves will be provided for the fail-closed isolation valves.

The complement of equipment in the fire house will be augmented by the addition of eight portable hand lights, a

forceable entry tool, two 2<-inch by 24-inch double female adaptors to permit hose connection from the pump unit to yard hydrants, and protective clothing to outfit eight men.

Storage facilities will be provided in the fire house for two smoke ejectors, six air breathing units, spare fire

hose, gaskets, and nozzles.

Me find that, subject to implementation of the above described modifica-tions, the fire protection for the yard area satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

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6. 0 ADMINISTRATIVE CONTROLS The licensee's description of the administrative controls for fire protec-tion as contained in his fire hazards analysis report is not sufficient to permit a conclusion by the staff.

We have subsequently recommended that the licensee's administrative controls follow the NRC guidelines set 'forth in "Nuclear Plant Fire Protection Functional Responsibilities, Administra-tive Controls, and guality Assurance."

In responses dated June, 5, and 23, 1978 the licensee has stated that his program for administrative controls is in conformance with the NRC guidelines, except for a few specific areas where deviations were noted and a justification, therefor, was provided.

Following our'review of the justification for deviations, we concluded that sufficient bases had not been provided by the licensee for some of these exceptions.

In responses dated August 28, and November 7, 1978 the licensee subsequently proposed to revise his administrative controls in resp..nse to the staff concerns.

We find that, subject to the, modification of administrative controls as noted in the licensee's letters of August 28, 1978 and November 7,

1978, the administrative controls for the fire protection program are acceptable.

We will report on the resolution of the fire brigade manpower and training requirement, which is still under review as indicated in our letter dated November 8,

1978 transmitting amendments 42 and 34, in a supplement to this report.

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7. 0 TECHNICAL SPECIFICATIONS The Technical Specifications tq include limiting conditions for operation and surveillance requirements for existing fire protection systems and administrative controls were issued on November 8, 1978.

Mhen the Technical Specifications were issued for the existing fire protection systems and administrative controls except>ons'aken by the licensee were noted as a

subject for further staff review.

The staff position in regard to those exceptions is unchanged.

Following the implementation of the modifications of fire protection systems and administrative controls resulting from this review, the Tech-nical Specifications will be similarly modified to incorporate the limiting condi tions for operati on and survei 1 1 ance 'equirements for these modifications.

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8. 0 CONCLUSION The 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, which are based upon the fire hazards analysis and our onsite evaluation of the fire protection program.

These proposed modifications are summarized in Section

3. 1.

In addition, we have concluded that the licensee should implement certain evaluations or improvements related to the fire protection program and there are certain Technical Specifications which require resolution.

These are summarized in Sections

3. 2 and 7. 0.

Significant steps are being taken to provide additional assurance that safe shutdown can be accomplished and the plant can be maintained in a safe condition dur in('nd following 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 Turkey Point facility will satisfy the provisions of BTP 9. 5-1 and Appendix A

thereto, which the staff has established for satisfactory long-term fire protection.

We find that the licensee's proposed modifications described herein are acceptable both with respect to the improvements in the fire protection program that they provide and with respect to continued safe operation of the facility, while the remaining items are completed.

In the report of the Special Review Group on the Browns Ferry Fire (NUREG-0050) dated February 1976, consideration of the safety of operation of all operating nuclear power plants pending the completion of bur detailed fire protection evaluation was presented.

The following quotations from the report summarize the basis for the Special Review Group's conclusion that the operation of the facility need not be restricted for public safety:

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

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

"Based on its review of the events transpiring 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 operation of nuclear power plants for public safety.

However, it is clear that much can and should be done to reduce even further the likelihood of disabling fires and to improve assurance of rapid extinguishment of fires that occur.

Consideration should be given also to features 8-1

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that would increase further the ability of nuclear facilities to withstand large fires without loss of important functions should such fires occur,"

We recognize that the "Risk Assessment Review Group Report to the U.S.

Nuclear Regulatory Commission,"

NUREG/CR-0400 (The Lewis Committee Report),

states that this Review Group is unconvinced of the correctness of the WASH-1400 conclusion that fires contribute negligibly to the overall risk of nuc1ear plant operation.

In the Commission's Policy Statement dated January 18, '1979, "NRC Statement on Risk-Assessment and the Reactor Safety Study Report (MASH-1400) in Light of the Risk-Assessment Review Group Report",

the Commission indicated on page 3 that it "accepts the Review Group Report's conclusion that absolute values of the risks presented by WASH-1400 should not be used uncritically either in the regulatory process or for public policy purposes and has taken and will continue to take steps to assure that any such use in the past will be corrected as appropriate.

In particular, in light of the Review Group conclusions on accident probabilities, the Commission does not regard as reliable the Reactor Safety Study's numerical estimate of the overall risk of reactor accident."

In summary, it is our conclusion that the operation of the facility, pending resolution of the incomplete item and the implementation of all facility modifications, does not present an undue risk to the health and safety of the public based on our concurrence with the Browns Ferry Special Review Group's conclusions identified above, (giving due consideration to the Commission Policy Statement) as well as the significant improvements in fire protection already made at the facility since the Browns Ferry fire.

These include establishment of administrative controls over com-bustible materials and use of ignition sources, training and staffing of a fire brigade, and issuance of technical specifications to provide limiting conditions for operation and surveillance requirements for fire protection systems.

Me have determined that the licensee 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 standpoint of environmental impact and pursuant fo 10 CFR Section 51.5(d)(4) that an environmental impact statement, or negative declaration and environmental impact appraisal need not'be'repared in connection with the issuance of this amendment.

Me have concluded, based on the considerations discussed above, that:

(1) because the amendments do not involve a significant increase in the probability or consequences of accidents previously considered and do not involve a significant decrease in a safety margin, the amendments do not involve a significant hazards consideration, (2) there is. reasonable assurance that the health and safety of the public will not be endangered 8-2

by operation in the proposed

mannen, and (3) such activities will be conducted in compliance with the Commission's regulations and the issuance of these amendments will not be inimical to the common defense and'securi y

,or to the health and safety of the public.

Dated:

March 21, 1979 8"3

9.0 CONSULTANTS'EPORT 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 and in the preparation of this report.

Their letter, "Fire Protection in Operating Nuclear Power Stations Turkey Point Nuclear Plant Safety Evaluation Report Review," dated December 6,

1978, discusses several matters which 'have been addressed in this report.

The elements of the consultants'ecommendations which we have not adopted are identified in Appendix "8" along with our bases therefor.

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APPENDIX A CHRONOLOGY In February 1976, the report by the NRC Special Review Group was issued as NUREG-0050, "Recommendations Related to the Browns Ferry Fire."

On May 1,

1976, Standard Review Plan 9. 5. 1, "Fire Protection,"

was issued, incorporating the various recommendations contained in NUREG-0050.

By.letter dated May ll, 1976, Florida Power and Light 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, "Fire Protection,"

dated Mav 1,

1976, and to describe (1) the implementation of the guidelines

met, (2) the modifications or changes under way 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 letter dated September 30, 1976, Florida Power and Light Company was requested to provide the results of a fire hazards analysis and propose Technical Specifica-tions pertaining to fire protection.

Florida Power and Light Company was also provided a.copy of Appendix A to BTP 9.5-1 which includes acceptable alternatives to the guidelines of SRP 9.5-1.

By letter dated February 25, 1977, Florida Power and Light Company submitted their report entitled, "Fire Protection - A Reevaluation of Existing Plant Design Features and Administrative Controls," in response to the staff's request of May 11 and September 30, 1976.

By letter dated August 8,

1977, the staff fot warded to Florida Power and Light Company supplemental guidance entitled, "Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls, and guality Assurance."

By letter dated November 25,

1977, the staff provided Flor ida Power and Light Company proposed interim Technical Specifications for fire protection.

By letter dated December 22,'1977, Florida Power and Light Company applied for an amendment to implement interim Technical Specifications for fire protection.

By letter dated February 3,

1978, the staff requested Florida Power and Light Company to provide the. results of a review of their fire protection program for conformance to the

.NRC guidelines, "Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls, and guality Assurance."

By letter dated March 2,

1978, the staff forwarded to Florida Power. and Light Company a request for additional information and staff position resulting from our initial reviews of their fire protection program.

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On March 27 through 30,

1978, the staff's fire protection review team visited

.the Florida Power and Light Company Turkey Point Units 3 and 4 site.

By letter dated April 10, 1978, the staff forwarded to Florida Power and Light Company staff concerns and positions which were identified during the site review of Turkey Point Units 3 and 4.

By letter dated June 5,

1978, Florida Power and Light Company provided a response to the staff's request on administrative controls by our letter dated February 3,

1978 By letter dated June 5,

1978, the staff forwarded to Florida Power and Light Company a document 'titled "Manpower Requirements for Operating Reactors."

By letter dated June 23, 1978, Florida Power and Light Company provide a response to the staff guidelines on manpower requirement.

By letter dated June 30,'978, the staff forwarded to Florida Power and Light Company the staff's positions on administrative controls resulting from a review of the exceptions taken to the NRC guidance noted in their letter of June 5,'978.

N On May 9 and June 26,

1978, the staff met with the licensee in the NRC offices in Bethesda, Maryland, to discuss staff concerns and positions.

By letter dated July 14, 1978, Florida Power and Light Company provided a

response to 'the staff's positions on fire protection.

By letter dated August 28, 1978, Florida Power and Light Company provided a

response to the staff's positions on administrative controls.

By letter dated October 16, 1978,.the-staff forwarded to Florida Power and Light Company and request for additional information on manpower requirement.

t By letter dated November 7, 1978, Florida Power and Light Company provided a

response to the staff's request for additional information on manpower require-ments.

On November 8,

1978, Amendment Nos.

42 and 34 were issued to Facility Operating License Nos.

34 and 41 to incorporate limiting conditions for operations and surveillance requirement for-existing fire protection systems and administra-

,tive controls for Turkey Point Units 3 and 4.

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APPENDIX B DISCUSSION OF CONSULTANTS'EPORT

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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 consultants who participated in the evaluation of the.licensee's fire protection program and in the prepara-tion of the Safety Evaluation Report

{SER).

Their letter, "Fire Protection in Operating Nuclear Power Stations

- Turkey Point Nuclear Power Plant Safety Evaluation Report Review," dated December 6, 1978, concurs with the staff conclusions noted in the Safety Evaluation Report.

The consultants report reflect, additional concerns which are identified in Section 3.2 of this report.

Tge consultants'ecommendation, which we have not adopted, along with our basis therefor, is as follows; Consultants'ecommendation:

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

The present proposal of administrative controls or locks is unacceptable."

~fff R 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 admin-istrative program to assure that valves are maintained in the proper position.

Such a program includes locking valves with strict 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.

These measures are consistent with the requirements imposed for supervising va'tves in safety-related

systems, and provide adequate assurance that valves are maintained in the appropriate position.

The licensee's program for valve supervision is consistent with NRC guidelines.

In addition, the plant technical specifications were revised to require a monthly check of

'll valves in the flow path to'ir e suppression systems.

We find that a

significant increase in plant safety would not result from the use of electrical supervision of all valves controlling fire water systems and sectionalizing valves,

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