ML17339A969
| ML17339A969 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 04/03/1980 |
| From: | Schwencer A Office of Nuclear Reactor Regulation |
| To: | Robert E. Uhrig FLORIDA POWER & LIGHT CO. |
| Shared Package | |
| ML17339A970 | List: |
| References | |
| NUDOCS 8004290077 | |
| Download: ML17339A969 (22) | |
Text
6'11 y V IOd0 APR 03 t980 Docket Hos. 50-0 and 0-25 Dr. Robert E. Uhrig, Vice President Advanced Systems and Technology Florida Power and L]ght Company Post Office Box 529100 Niami, Florida 33152
Dear Dr. Uhrig:
He have been reviewing your submittals related to the Turkey Point Plant Unit Nos.
3 and 4 Fire Protection Program.
In Our Safety Evaluation dated Narch 21, 1979 regarding that Fire Protection program, there were modifications in Section 3.1 which required that you submit design details for staff approval.
Design details for items numbered 3.1.2, 3.1.6, 3.1.7 and 3.1.15 were submitted in your letter L-79-285 dated October 8, 1979.
Design details for items numbered 3.1.1(4) and 3.1.1(5) were submitted in your letter L-79-335 dated December 20, 'l979.
In addition, by letter L-79-128 dated Nay 21. 1979 you submitted a schedule for com-pletion of the modifications and additional information regarding the fire water supply, We have completed. our review of the design details.
Our evaluation is in Enclosure 1 to this letter.
Items 3.1.1, and 3.1.15 are acceptable, Item 3.1.6 is acceptable based on your acceptance of the staff modifications.
Item 3.1.2 is part of incomplete item 3.2.3 of our Narch 21, 1979 Safety Evaluation.
Our staff position on item 3.2.3 is indicated in Enclosure 2
(item 3.3) to this letter.
Item 3.1.7 is not acceptable pending your submittal of the information requested in Enclosure l.
Enclosure 2 is our report "Staff Positions on the Turkey Point Fire Protection Program".
In this report, staff positions are given for all incomplete items except the Fire Brigade and the Technical Specifications, That position on the Fire Brigade has been given in our letter dated August 21, 1979.
The Technical Specifications will ultimately include the Fire,'Brigade requirements and will be completed at the time the Fire Brigade issue is resolved.
. OFFICE SURNAME OATEP NRC FORM'316 (9.76) NRCM0240,',,
O'U.S;.GOVERNMENT PRINTING<<OFFICE: 1979.269Q69'
APR 03
$98D Dr. Robert E. Uhrig Florida Power and Light Company 2
w Enclosure 3 is a table giving the status of the resolution of the incomplete items remaining in our review of the Turkey Point Plant fire protection program.
We request that you respond to the above requests or staff positions within 20 days of the receipt of this letter.
Sincerely, Original Signed By
Enclosures:
1.
Fire Protection Review 2.
Staff Positions 3.
Resolution of Incomplete Items - Status A. Schwencer, Chief Operating Reactors Branch Ol Division of Operating Reactors cc:
w/enclosures See next page DISTRIBUTION Docket Files 50-250/251 NRC PDRs (2)
Local PDR TERA NSIC NRR Reading ORBl Reading D. Eisenhut W. Gammill A. Schwencer M. Grotenhuis C.
Par rish T. Wambach R.
Ferguson I8E (3)
- Attorney, OELD OFFICE SURNAME DATEf DOR:OR HGrotenhu o4/ +so S,'J 00~8+~
DOR:DRB TVWambgch PjSct)wqgcgr"-
04/ 3/Bo 04/&Bo
~ ~
~
NRC FORM,318 I9.76) NRCM 0240'
'c OU.S4.GOVERNMENT PRINTING OFFICE! 1979.289-369>
~g$\\ AK0(
~c~
Wp0
~~ +i Y~
4 C ~4
~Cy
+~
~
~D
+**<< +
Docket Nos.
50-250 and 50-251 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 APR 0 3 f980 0
Dr. Robert E. Uhrig, Vice President Advanced Systems and Technology Florida Power and Light Company Post Office Box 529100 Miami, Florida 33152
Dear Dr. Uhrig:
We have been reviewing your submittals related to the Turkey Point Plant Unit Nos.
3 and 4 Fire Protection Program.
In Our Safety Evaluation dated March 21, 1979 regarding'.that Fire Protection
- program, there were modifications in Section 3.1 which required that you submit design details for staff approval.
Design details for items IIumbered 3.1.2, 3.1.6, 3.1.7 and 3.1.15 were submitted in your letter L-79-285 dated October 8, 1979.
Design details for items numbered 3.1.1(4) and 3.1.1(5) were submitted in your letter L-79-335 dated December 20, 1979.
In addition, by letter L-79-128 dated May 21, 1979 you submitted a schedule for com-pletion of the modifications and additional information regarding the
~ fire water supply.
We have completed our review of the design details.
Our evaluation is in Enclosure 1 to this letter.
Items 3.1.1, and 3.1.15 are acceptable.
Item 3.1.6 is acceptable based on your acceptance of the staff modifications.
Item 3.1.2 is part of incomplete item 3.2.3 of our March 21, 1979 Safety Evaluation.
Our staff position on item 3.2.3 is indicated in Enclosure 2
(i tem 3;3) to this letter.
Item 3.1.7 is not acceptable pending your submittal of the information requested in Enclosure 1.
Enclosure 2 is our report "Staff Positions on the Turkey Point Fire Protection Program".
In this report, staff positions are given for all incomplete items except the Fire Brigade and the Technical Specifications.
That position on the Fire Brigade has been given in our letter dated August 21, 1979.
The Technical Specifications will ultimately include the Fire Brigade requirements and will be completed at the time the Fire Brigade issue is resolved.
Dr.
Ro ber t E. Uhrig Florida Power and Light Company Enclosure 3 is a table giving the status of the resolution of the incomplete items remaining in our review of the Turkey Point Plant fire protection program.
Me request that you respond to the above requests or staff positions within 20 days of the receipt of this letter.
Sincerely,
Enclosures:
1.
Fire Protection Review 2.
Staff 'Positions 3.
Resolution of Incomplete Items - Status A. Schwencer, Chief Operating Reactors Branch 81 Division of Operating Reactors cc:
w/enclosures See next page
Pobert E. Uhrig Florida Power and Light Company April 3, 1980 cc:
Mr. Robert Lowenstein, Esquire Lowenstein,
- Newman, Reis and Axelrad 1025 Connecticut
- Avenue, N.W.
Suite 1214 Washington, 0.
C.
20036 Environmental and Urban Affairs Library Florida International University Miami, Florida 33199 Nr'. Norman A. Coll, Esquire
- Steel, Hector and Oavis 1400 Southeast First National Bank Building Miami, Florida 33131 Nr. Henry Yaeger, Plant Manager Turkey Point Plant Florida Power and Light Company P. 0.
Box 013100 Miami, Florida 33101 Nr. Jack Shreve Office of the Public Counsel Room 4, Holland Building Tallahassee, Florida 32304 Administrator Department of Environmental Regulation Power Plant Siting Section State of Florida 2600 Blair Stone Road Tallahassee, Flori da 32301 Resident Inspector Turkey Point Nuclear Generating Station U. S. Huclear Regulatory Comnission Post Office Box 971277 quail Heights Station Miami, Florida 33197
Enclosure 1
APR 03 Beg TURKEY POINT Fire Protection Review Item 3.1.1 Fire Detection S stem The SER states early warning automatic fire detection systems will be provided in the switchgear rooms and in the charging pump rooms.
The licensee's submittal with a cover letter dated December 20, 1979 provided design details for asterisked items 3.1.1(4) and 3.1.1(5) as noted in the SER.
The information is in the form of layout drawings and manufacturers equipment descriptions.
The areas addressed by this submittal are the diesel generator rooms and the switchgear rooms.
The majority of fire detection heads are of the ionization high voltage type.
A flame detector will be installed in the diesel generator room and a heat detector in the diesel day tank room.
The diesel generator rooms are zoned on a single zone with remote lamps at a zone control panel.
The remote lamps divide the diesel generator building into two mirr or images with a diesel generator and its associated day tank on a single remote lamps The zone con-trol panel is located between the Rod Control Drive Rooms.
The switchgear rooms are divided by elevation and division.
Each switchgear room associated with a unit (either Unit 3 or 4) has its own zone.
The zone is then divided into three remote lamp annunciation at the zone panel.
On drawing 5177-100-E-12, the plan view shows detector 16-1 and 16-6 as DFS-10 Pyrotronics flame detectors while the electrical systematic at the top of the page labels these detectors as DTF136P Pyrotronics Thermal detectors.
The flame detector should be installed in the diesel generator room.
Based on the above review and comment, the preliminary plans and equipment are acceptable.
Any significant changes in the preliminary submittal should be reviewed and approved by the NRC.
Item 3.1.2 Fire Water Su 1
3.2.3 In the SER dated March 21, 1979, Item No. 3.1.2 "Fire Water Supply" requires the licensee to provide an analysis of the fire water demand at the plant.
This analysis would demonstrate the adequacy of the screen wash pumps to provide adequate back-up to the fire pumps.
The SER also required, if the analysis proved favorable, that the spool piece connection between the screen wash pump.and the fire protection system be permanent.
An analysis submitted under cover letter dated May 21, 1979 is inadequate.
No substantiating calculations have been submitted to verify numbers given.
APR 0 3 580 A revisit to the plant in October, 1979 verified that the curb would prevent oil from entering the condensate pit and the heat from the postulated fire would not actuate sprinklers in the pit.
Also during our visit various deluge systems for the hydrogen seal oil unit, for the auxiliary transformer and for the main transformer were noted in the area where a
common fire could create the maximum fire water demand.
All these deluge systems have to be taken into consideration when calculating the fire water demand because they could be set off by a common fire.
With the addition of these deluge systems to the fire water demand, the screen wash pump rated at 1680 gpm at 84.4 psi cannot meet this requirement.
The licensee's proposal to use the screen wash pump as a.backup to the fire pumps is unacceptable.
If the pumps could meet the demand, the connection be-tween the screen wash system and fire protection system would have to be permanent.
Based upon the, above review, the evaluation documented in the May 21, 1979 letter and the proposed modification documented in the October 8, 1979 letter are unacceptable.
Please refer to Section 3.2.3 (Fire Water Supply) in our SER dated March 21',
1979.
3.1.6 Water Su ression S stems The SER states that fixed automatic water spray protection will be provided for the door and ventilation openings of the switchgear rooms which face main and auxiliary transformers.
The licensee submittal dated October 8, 1979 provided design details for asterisked item 3.1.6 "Water Suppression Systems" as noted in the SER.
The areas addressed by this submittal are the water curtains for Unit 3 Switchgear Room Door and Vent and for Unit 4 Switchgear Door and Vent.
Two sidewall heads protect the louvered opening while one head protects the door opening.
The basic design criteria appears adequate but we recommend that the following changes be made.
1.
Minimum pipe size should be one inch.
2.
No bushings should be used.
3.
Heat collectors should be provided on sprinkler heads.
4.
A waterflow switch should be provided on feed with annunciation in the control room.
5.
The feed for these sprinkler heads should be independent of the feeds for the deluge systems.
Based upon the above review, the general criteria is acceptable but we request that the design be modified as indicated above.
Overall approval of the NRC is based on the
~ implementation of these changes by 'FPL, 3.1.7 Foam Su ression The SER states that portable foam suppression equipment will be provided and that 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.
The licensee under cover letter dated October 8, 1979, submitted the design details for the implementation of SER item 3.1.7 "Foam Suppression."
The SER requires the utility to provide access for introducing foam into the diesel generator rooms and diesel generator day tank rooms without opening doors to expose fire brigade personnel to a fire atmosphere.
The design consists of two (2) four-inch sleeves through the wall and one four-inch opening in the door for each diesel generator room.
The location of openings appear to be placed to provide complete coverage of the diesel generator area.
We request that the licensee confirm that the penetrations are of sufficient size to accommodate the portable foam equipment purchased by the plant.
The drawings submitted do not show the penetrations into the diesel day tank room.
Final approval for 3.1.7 "Foam Suppression" is withheld until the penetrations for the diesel day tank room have been submitted and reviewed by the NRC.
3.1.15 H dro en Su 1
Lines The SER states that the use of the hydrogen supply lines in the auxiliary building corridor will be discontinued and new lines will be provided for use outside of this area.
The licensee.submittal, with a cover letter dated October 8, 1979, provided design criteria for asterisked item 3.1.15 concerning the rerouting of the hydrogen supply line.'resently this supply line is routed through the auxiliary building corridor thus exposing safety related equipment.
The licensee has indicated that the existing supply line will be removed and the new hydrogen line will run on the roof of the Auxiliary Building to a point near the Units 3 and 4 volume control tanks.
At this point the lines will penetrate the roof and be routed to the respective tanks.
Based on the review of the above criteria, the rerouting of the hydrogen sup-ply line outside the Auxiliary Building corridor is acceptable.
STAFF POSITIONS ON THE TURKEY POINT PLANT FIRE PROTECTION PROGRAM
CONTENTS
1.0 INTRODUCTION
- 2. 0 MODIFICATIGNS/REQUIREMENTS
- 3. 0 EVALUATION 3.1 Smoke Detection Systems 3.2 Reactor Coolant Pumps 3.3 Water Supply 3.4 Auxiliary Building Corridor 3.5 Cable Spreading Area
1.0 INTRODUCTION
Our initial safety evaluation report (SER) pertaining to the reevaluation of fire protection at the Turkey Point facility was issued by letter from A. Schwencer to Florida Power and Light Company dated March 21, 1979.
In Section 3 of the'SER, certain items were identified as incomplete and requiring further information from the licensee and evaluation by the staff.
The Florida Power and Light Company in letter(s) dated April 5, 1979 and Hay 21, 1979, submitted additional information to resolve these incomplete items.
We have reviewed this information and have found that additional modifications are required to meet the fire protection guidelines identi-fied in Section 2.0 of our SER.
Section 2.0 of this report summarizes the additional modifications proposed by the licensee and the requirements which will resolve our concerns.
Sec-tion 3.0 of this report provides the results of our evaluation.
Brookhaven National Laboratory under contract to the NRC has provided the services of fire protection consultants who participated in the evaluation of the fire protection program and in the review of information provided on incomplete items.
They have also participated in the preparation and review of this Report.
- 2. 0 MODIFICATIONS AND'E UIREMENTS 2.1 Modifications The licensee has proposed the modifications summarized below.
The implementation schedule for these proposed modifications is shown in Table 2.1.
A complete description of each proposed modification is given in the licensee's documentation.
2.1.1 Smoke Detection S stems None 2.1.2 Reactor Coolant Pum s
None 1.1.3 ~3 A curb to prevent an oil fire from flowing into the condensate pump pit to reduce the maximum water demand.
2.1.4 Auxiliar Buildin Corridor None 2.1.5 Cable S readin Area None 2.1.6 Technical S ecifications for Existin E ui ment None 2 ~ 2 Re uirements 2.2.1 As a result of our evaluation, we find that the licensee must make additional modifications to improve the fire protection program.
These modifications are summarized below.
The sections of this report which more fully describe the modifications and provide our basis for these modifications are noted in parenthesis.
Smoke Detection S stems (3.2.1)
We will require that an evaluation by an independent registered fire protection engineer (as defined in our guidance dated February 3, 1978, attachment
- 1) knowledgeable in fire detection be performed to certify the adequacy of smoke detection systems in lieu of in-situ testing.
2-1
Reactor Coolant Pum s (3.2.2)
We will require that the licensee install an oil collection system for the reactor coolant pumps.
~S1 t.2.3)
We will require a vertical standpipe for other water services be provided in the existing 500,000 gallon raw water storage tank.
We will require a new water storage tank to provide an. adequate supply of water dedicated totally to fire protection needs.
The tank will be installed in accordance with NFPA 22.
We will also require diesel driven fire pump(s) with automatic start features be installed to take suction from the new tank.
The installation will be in accordance with NFPA 20.
We will require that the connection to the yard main from the new pump(s) and tank will be separated from the existing connection by a substantial distance.
Proper valving adjacent to this connection shall also be installed.
Auxiliar Buildin Corridor (3.2.4)
We will require the installation of an automatic sprinkler system in the auxiliary building corridor to protect the cable trays from exposure fire.
We will require the licensee to provide those items for the auxiliary building corridor for which he has indicated a reevaluation as follows:
We will require fire detection systems in the chemistry laboratories (hot and cold labs) and in the new laundry facility.
We will require 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated fire doors in the auxiliary building for the chemistry laboratories (hot and cold labs) and new laundry facility.
We will require 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated fire dampers for ventilation ducts in the chemistry laboratories (hot and cold labs) and the new laundry facility to isolate these areas from the auxiliary corridor.
We will requir plastic barrels in the auxiliary building corridor used to collect radiation protective clothing be replaced with barrels made of a fire retardant material.
We will require alternate shutdown capability independent of the auxiliary building corridor.
Cable S readin Area We will reouire the installat";on of an automatic gas suppression system in the cable spreading room.
2-2
We will require a booster hose station for the cable spreading room.
We will require that access doors from the cable spreading area to the turbine building have a 1-1/2 hour rating.
We will require alternate shutdown capability independent of the cable spreading area.-
2-3
3.0'VALUATION 3.1 The following provides our evaluation of the incomplete items.
Numbers in parenthesis following each heading refer to the sections of our previously issued SER which address these incomplete items.
Smoke Detection S stems (3.2.1)
Our SER noted that bench tests would be conducted on a minimum of 505 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 combustibles in the areas where they are installed.
If detection systems were found-to be inadequate, appropriate modifications would be made to provide adequate detection system performance.
With regard to the adequacy of the smoke detection
- systems, we 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.
A practical solu-tion to this type of testing is not yet available to determine prompt response.
We indicated in our previous SER that an'evaluation.by an inde-pendent registered fire protection engineer (as defined in our guidance dated February 3, 1978, attachment
- 1) knowledgeable in fire detection be performed to certify the adequacy of smoke detection systems in lieu of in-situ testing.
The NRC is currently developing alternate acceptance criteria fot the detector installation.
We will address this issue when such criteria become available.
3.2 Reactor Coolant Pum s (3.2.2)
Our SER noted that we had requested that an oil collection system be provided for each of the reactor coolant pumps.
The licensee had 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."
We indicated that if a suitable lubricant was not found, the licensee would provide a system to suppress potential fires or provide for the removal of potential oil leakage to a safe location by December 1980.
We have not received any new information from the licensee;
- however, we have discussed the results of the study with Mr. Roy Swanson of EPRI, who is the project manager in charge.
Mr..Swanson has indicated that the study may reach a favorable conclusion and that a non-combustible lubricating oil for installed reactor coolant pumps will be available in the immediate 3-1
future.
However, this will"require careful monitoring to assure the integrity of the oil.
The monitoring will require the installation of remote capability to perform the monitoring.
Because such an installation will require much greater risks and controls associated tn assuring the integrity of the oil,,the staff does not deem this a viable approach at this time or for the near term future.
Me will, therefore, require that the Reactor Coolant Pump lubrication system be protected by either an oil collection system, or an automatic fire suppression system.
Oil collection systems shall be capable of collecting lube oil from all potential pressurized and unpressurized leakage sites in the reactor coolant pumps'ube oil systems and drain the oil to a vented closed container.
Requirements for a flame arrestor in the vent shall be determined on the basis of flash point characteristics of the oil involved.
Leakage points to be protected shall include lift pump and piping, overflow lines, lube oil cooler, oil fill and drain lines and plugs, flanged connections on oil lines and lube oil reservoirs where such features exist on the reactor coolant pumps.
Leakage shall be collected and drained to a closed container that can hold the entire lube oil system inventory.
The drain line shall be large enough to accommodate the largest potential oil leak.
To provide adequate protection for an SSE, one of the following shall be provided:
(a)
The lube oil system components whose failure could result in leakage shall be designed to withstand an SSE without leakage; and, the drop-ping of oil collection system components during an SSE shall not cause loss of operability of safety-related equipment; or (b)
The oil collection system shall be designed to withstand an SSE and continue to be able to collect and drain leakage that may occur during an SSE.
In this case the oil collection system shall be adequate to collect oil from any external lube oil piping not designed to withstand an SSE, in addition to leakage from points identified above.
If an automatic fire suppression system is selected, either the automatic and manual fire suppression system or the lube oil system components whose failure could result in leakage shall be designed to withstand the SSE.
3.3 Our SER noted our requests that (a) an adequate supply of water for fire protection be physically dedicated (e.g.,
by a vertical standpipe},
(b) confirmation of the licensees 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, and (c} should the 3-2
screen wash pumps prove to be an adequate alternate water source, that the proposed unconnected spool piece (Nc te:
The licensee now proposes a rolled up section of hose in lieu of a spool piece.}
be permanently connected between the screen wash and fire water systems.
By letter dated May 21, 1979, the licensee indicated he would preclude an unmitigated fire from flowing flammable liquids into the condensate pump pit and thereby reducing the area of demand from 3945 square feet to 2685 square feet.
The licensee concludes that since the area is reduced by curbing, the demand is reduced and he concludes that, therefore, the screen wash pumps and fire pumps do provide adequate capacity to satisfy the largest area of demand with the modifications of curbs.
Me agree that the curb would prevent oil from flowing into the condensate pump pit and would likely prevent the opening of sprinkler heads located in the lower pit area; however, the curb will not prevent the heat from reaching the adjacent transformer and hydrogen seal oiI areas where the sensing line from the transformer deluge system is located.
Thus, the deluge systems from the auxiliary, main transformers, and the hydrogen seal oil and the turbine building system could be set off by a
single large fire, resulting in an overtaxed water supply.
Further, the information provided 'is not sufficient to permit our independent determination of the adequacy of the screen wash pumps.
Because the present water supply is not physically dedicated and because of the overlapping demand of fire areas described above, i.e.,
one fire pump (with one pump out of service) or alternatively the screen wash pumps cannot meet the maximum water demand.
The licensees Fire Hazards Analysis indicates that the two electrically powered fire pumps are supplied power as follows:
(a)
One pump (A) derives its power from fossil unit 2 load center 2C, and (b)
One pump (8) derives its power from nuclear unit 2 load center 3C.
The licensee further states that power can be supplied to fire pump B from the nuclear facilities diesel generators.
It is apparent that a loss of offsite power would cause the loss of function of both fire pumps.
It appears that a fire in the transformer area could cause 'this same event.
However, the staff has not been able to confirm this because of the absence of specific information of the fire pump cable routing.
Although the diesels can be connected to.upply power to fire pump B, this operation would have to be manually accomplished.
The time required to restore power to fire pump B is not certain.
There is presently no procedure which would require the operator'to restore power to one of the pumps nor is it apparent that he would immediately recognize'he need to perform this function.
The staff requires that "each supply of the fire water distribution system shall be capable of providing for a period of two hours, the maximum expected water demands as determined by the fire hazards analysis for safety related areas or other areas which present a fire exposure hazard to safety related areas."
To comply with these requirements, the staff will require the following modifications to the licensee's present water supply system:
3-3
(a)
We will require a vertical standpipe for other water services be provided in the existing 500,000 gallon raw water storage tank.
(b)
We will require an additional water supply for the fire water loop.
This supply shall consist of:
(1)
A new water storage tank with sufficient storage capacity to adequately serve the overlapping. demand described above for a period of two hours.
This tank shall comply with the requirements of NFPA 22.
(2)
Automatic starting diesel fire pump(s) with adequate capacity and pressure dedicated solely for fire protection.
The fire pump(s) shall be designed and installed in accordance with NFPA 20.
(3)
The connection to the yard main from the new pump(s) and tank shall be separated from the existing connection by a substantial distance.
Proper valving adjacent to this connection shall also
- be installed to permit isolatiori in the event of a line break.
3.4 Auxiliar Buildin Corridor Our SER noted that we requested the installation of sprinklers to provide protection for redundant safety related cables from exposure fires in the auxiliary building corridor.
We also requested additional information in our letter dated March 2, 1979 regarding the shutdown of both units following a fire in this area.
The licensee's submittal dated April 5, 1979, addressed this topic by referring to his Fire Hazards Analysis, L-77-51, dated February 25, 1977.
The licensee implies that the fire hazards analysis demonstrates the capa-bility of Turkey Point Units 3 and 4 to achieve safe shutdown conditions notwithstanding the effects of design basis fires.
By letter dated April 5, 1979, the licensee has withdrawn certain commitments detailed in Enclosure 2
of oi>r letter of March 2, 1979 pending his reevaluation of protection for the auxiliary building corridor.
We have reviewed the Fire Hazards
- Analysis, and we do not find it adequate to demonstrate the plants capability to safely shutdown both units indepen-dent of fire damage in the auxiliary building corridor.
Tl e Fire Hazards Analysis does not specifically address the question of task/manpower in relation to a fire in the auxiliary building corridor to show that the plant has adequate procedures and manpower to shutdown both units indepen-dent of cabling therein.
It assumes that a fire which endangers redundant cables in this area cannot occur.
Our SER noted that the separation between 3-4
redundant divisions of cables required for safe shutdown was still under review by the NRC.
The adequacy of separation in certain fire areas was left open by the SER for further staff review.
During the week of Octo-ber 16, 1979, NRC personnel visited the plant site to review the Auxiliary Building corridor and the Cable Spreading Room.
The minimum distance separating redundant divisions of safety-related cable trays at Turkey Point is 12 inches vertically, 5-1/2 inches horizontally.
In safety-related areas of the plant, all.or most of the cables are coated with a fire retardant material.
Tests run by the licensee showed very little, if any; flame propagation along coated cables of the type used at the facility.
The results of these tests are used by the licensee to jus-tify the, lack of suppression systems and solid barriers between redundant divisions of cables.
The fire retardant coating used at Turkey Point has also been tested at Sandia Laboratories.
The Sandia tests-subjected coated cables to a larger exposure fire than that used in the licensee tests.
The cable tray directly exposed to the fire in the Sandia tests suffered considerable damage and burned for approximately 42 minutes.
Coated cables in a tray 10-1/2 inches above the exposed tray were also damaged.
Although the cables in the upper tray did not burn, propagation of flames to the upper tray would have occurred if a larger exposure fire had been used, if the cables had been energized at rated current or if the coating had been applied and the cables arranged to simulate more closely a field installation.
It is therefore concluded that the combination of fire retardant coating and the minimum separation permitted between redundant divisions of cables at Turkey Point is not acceptable fire protection to assure safe shutdown capability.
It has been shown repeatedly that coated cables directly exposed to a flame (for several minutes) will be damaged and will ignite.
Although flame propagation is retarded by the coating, coated cables will burn and add their heat of combustion to the heat input to a compartment in a fire.
The lack of adequate separation between redundant divisions of safe shutdown cables at Turkey Point could result in damage to both divisions from from direct flame impingement from an exposure fire.
Transient combustibles are moved through the area.
A fifty-fivegallon drum of lube oil was observed in the area as well as a welding cylinder car t.
Radiation protective clothing is collected at a checkpoint in open plastic barrels.
The combustibles in this area pose an exposure fire hazard to the Flamemastic-coated cables which could exceed the protection offered by the flame retardant coatings.
Although administrative control of com-bustibles will generally limit-the size of exposure'fires, it is not acceptable to rely on administrative controls to assure safe shutdown of the plant.
Because the licensee has not demonstrated that. the plant can be safely shutdown after sustaining fire damage in the auxiliary building corridor, we will require the installation of an automatic sprinkler system designed to prevent exposure damage to cable tray systems in this area.
In addition, 3-5
we will require implementation of the recommendation in enclosure 2 of our letter of March 2, 1979.
The specific items are as follows:
(a)
We will require fire detection systems in the chemistry laboratories (hot and cold labs) and in the new laundry facility.
(b)
We will require 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated fire doors in the auxiliary building for the chemistry laboratories (hat and cold labs) and new laundry facility.
(c)
We will require 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated fire dampers for ventilation ducts in the chemistry laboratories (hot and cold labs) and the new laundry facility to isolate these areas from the auxiliary corridor.
(d)
We will require plastic barrels in the auxiliary building corridor used to collect radiation protective clothing be replaced with barrels made of a fire retardant material.
We will require that alternate shutdown capability be provided which is independent of the auxiliary building corridor.
3.5 Cable S readin Area (3.2.5)
We noted in our SER that a capability independent of the cable spreading room should be-provided to safely shutdown both units.
We requested infor-mation in our letter dated March 2, 1979 to demonstrate that both units can be shutdown independent of a fire in the cable spreading room.
The licensee by letter dated April 5, 1979 addressed this topic by referring to his Fire Hazards Analysis, L-77-57 dated February 25, 1977.
The licen-see implies that the fire hazards analysis demonstrates the capability of
.Turkey Point Units 3 and 4 to achieve safe shutdown conditions notwith-standing the effects of a design basis fire.
By letter dated April 5, 1979, the licensee withdrew certain commitments detailed in Enclosure 2 of our letter of March 2, 1979 pending his reevaluation of protection for the cable spreading area.
We will require the implementation of these withdrawn commitments.
We have reviewed the fire hazards analysis and we do not deem it adequate to demonstrate the capability to shutdown both units independent of fire damage in the cable spreading room.
The Fire Hazards Analysis does not specifically address the task/manpower required to cope with a fire in the cable spreading room.
It does not show that the plant has adequate proce-dures and manpower to shutdown both units independent of cabling in the cable spreading room.
The cable spreading room is shared by both units.
It is located below the control room.
The area houses the reactor protection system instrument 3-6
- racks, and cables are routed in the area which terminate at the control room control boards and panels, and at electrical equipment closures within the cable spreading room.
The combustibles in the area consist of
. electric wire and cable insulation materials and a small quantity of paper associated with the plant computer.
All cables routed through the area have been coated with a fire retardant coating.
An unmitigated fire in the cable spreading room could affect more than one division of safety-related equipment.
The licensees Fire Hazards Analysis indicates 12 inches vertically and 5-1/2 inches horizontally is represen-tative of the A to B tray spacing.
,A common tray is used for cables from one division of both units.
Generally, cables from one unit are at one end of the tray, the other units cables are the other end;
- however, some cables cross from one end to the other and some cables leave the tray near the center and rise vertically adjacent to similar cables from the other division of both units.
Fire detection is provided throughout the area by ionization smoke detectors.
A portable dry chemical extinguisher is pro-vided 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.
For the same reasons we have noted in Section 3.4 herein, the licensee has not demonstrated that the plant can be safely shutdown.
We will, therefore, require the installation of an automatic gaseous suppression system for the cable spreading room and an alternate shutdown capability independent of the cable spreading room.
We will require a booster hose station for the cable spreading room.
We will'equire that access doors from the cable spreading area to the turbine building have a l-l/2 hour rating.
3-7
nclosure 3
TURKEY POINT UNITS 3
& 4 RESOLUTION OF INCOMPLETE ITEMS - STATUS Staff Evaluation Licensee Staff 3.1.1 Fire Detection Systems 3.1.2 Fire Water Supply 3.1.6 Mater Suppression Systems 3.1.7 3.1.15 Foam Suppression I
Hydrogen Supply Lines 3.2.1 Smoke Detection System 3.2.2 Reactor Coolant Pumps 3.2.3 Water Supply 3.2.4 Auxiliary Building Corridor 3.2.5 Cable Spreading Room 3.2.6 Technical Specifications Acceptable Requirement Requirement Requirement Acceptable Acceptance Criteria Requirement Requirement Requirement Requirement Ongoing 03/1 5/79 f;ate 30 days 30 days None 30 days 30 days 30 days 30 days 60 days 60 days 60 days 04/28/80 60 days 60 days 60 days 60 days 60 days