ML18040B100
| ML18040B100 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 04/18/1985 |
| From: | Novak T Office of Nuclear Reactor Regulation |
| To: | Curtis N PENNSYLVANIA POWER & LIGHT CO. |
| References | |
| GL-85-01, GL-85-1, NUDOCS 8505010378 | |
| Download: ML18040B100 (18) | |
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UNITEDSTATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 APR 18 1985 Docket Nos. 50-387/388 Mr. Norman W. Curtis, Vice President Engineering and Construction Pennsylvania Power
& Light Company 2 North Ninth Street Al 1 entown, Pennsylvania 18101
Dear Mr. Curtis:
SUBJECT:
RESULTS OF THE MARCH 18-21, 1985 SUSQUEHANNA FIRE PROTECTION PROGRAM DOCUMENTATION AUDIT In a meeting held on February 26, 1985, between the NRC staff and PP8L the results of the recent Region I Appendix R fire protection inspection at SSES were discussed.
The staff informed you that it was our position that the SER and Supplements did not approve PPSL's fire protection program as satisfying Appendix R, Sections III.G., J.
and. 0.
On March 18-21, 1985 the NRC staff visited the SSES site to audit the documen-tation supporting the Susquehanna Fire Protection Program to enable PP8L to present supplementary information that was not readily available during the previous inspection.
The results of,the March 18-21, 1985 visit are contained in the enclosed trip report.
We find that PP8L's supplementary information has not demonstrated compliance with Section III.G. of Appendix R.
Also, the non-rated walls and floor/ceilings in the Reactor Building will not limit fire propagation.
If fire spread occurs beyond these assemblies, loss of redundant shutdown capability may occur.
We also determined that the post-fire safe shutdown capability may not be adequate in the event of a control room fire.
During our post-audit exit briefing, PP8L committed to respond to our control room findings.
In 'your letter of April 8, 1985, you stated that you will re-access the adequacy of non-fire-rated construction.
However, this response does not adequately address our concerns because it does not establish that PP8Ls future efforts will conform with staff guidance documents or past precedent.
We are providing the following guidance for formulating your response to our site audit concerns:
1.
The Fire Protection Review Report should be revised to reflect, in a compre-hensive
- manner, the degree to which SSES conforms with the technical require-ments of Sections III.G.; J.
and 0. of Appendix R to 10 CFR 50, as committed in your letter of March 26, 1981.
(The staff understands that Section J.
and 0 compliance is not in question'.)
For each fire area, identify and justify the deviations from these requirements.
This effort should reflect recent staff guidance as presented in our fire protection workshop and as contained in Generic Letters 83-33 and 85-01.
2.
The Control Room analyses should assume complete loss of function of control room systems after manual scram of the reactor.,
This analysis, 4 &>5'o>erg
along with the analyses of associated circuits throughout the plant, should conform to the guidance provided in Generic Letter 81-12 and its supplementary clarification.
3.
The re-assessment of non-rated construction should be in accordance with guidance presented at the site audit.
That is, to provide reasonable assurance that fire propagation will not occur beyond non-fire-rated zone boundaries, the boundaries should be upgraded to be continuous barriers with a fire rating sufficient to. withstand the effects of a fire involving in-situ and transient combustibles, with conservative margins.
If boundary construction is not upgraded, your re-"asses'sment'hould assume that fire spread will occur into the next most immediate fire-zone (horizontally and/or vertically).
i In addition, it has become appar'ent that'he fire protection license condition for SSES Units 1 and 2 are not in conformance with the Commission's policy.
We request that such conditions be revised to be in conformance with the NRCs standard fire protection license condition as stated in GL 85-01.
If you have any questions relating to this subject:.please contact the Licensing Project Manager, Mari-Josette Campagnone (301) 492-"7235.-
Sincerely, cc:
See next page
Enclosure:
As stated Thomas M. Novak, Assistant Director for Licensing Division of Licensing Distribution: <Docket File, NRC PDR Local PDR PRC System NSIC LB¹2 Reading EHylton MCampagnone Goldberg,OELD ACRS (16)
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i g if along with the analyses of associated circuits throughout the plant, should conform to the guidance provided in Generic Letter 81-12 and its supplementary clarification.
3.
The re-assessment of non-rated construction should be in accordance with guidance presented at the site au'dit.
That is, to provide reasonable assurance that fire propagation will not occur beyond non-fire-rated zone boundaries, the boundaries should be upgraded to be continuous barriers with a fire rating sufficient to withstand the effects of a fire involving in-situ and transient combustibles, with conservative margin.
If boundary construction is not upgraded, your re-assessment should assume that fire spread will occur into the next most immediate fire zone (horizontally and/or vertically).
In addition, it has become apparent that the fire protection license condition for SSES Units 1 and 2 are not in conformance with the Commission's policy.
We request that such conditions be revised to be in conformance with the NRCs standard fire protection license condition as stated in GL 85-01.
If you have any questions relating to this subject please contact the Licensing Project Manager, Mari-Josette Campagnone (301) 492-7235.
Sincerely, cc:
See next page
Enclosure:
As stated Thomas M. Novak, Assistant Director for Licensing Division of Licensing
4
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~5h Mr. Norman W. Curtis Vice President Engineering and Construction Pennsylvania Power 5 Light Company 2 North Ninth Street Allentown, Pennsylvania 18101 Jay Silberg, Esq.
Shaw, Pittman, Potts, 5 Trowbridge 1800 M Street, N.
W.
Washington, D.C.
20036 Edward M. Nagel, Esq.
General Counsel and Secretary Pennsylvania Power 8 Light Company 2 North Ninth Street Allentown, Pennsylvania 18101 Mr. William E. Barberich Manager-Nuclear Licensing Pennsylvania Power 5 Light Company 2 North Ninth Street Allentown, Pennsylvania 18101 Mr. R. Jacobs Resident Inspector P.O.
Box 52 Shickshinny, Pennsylvania 18655 Mr. E. B. Poser Project. Engineer Bechtel Power Corporation P. 0.
Box 3965 San Francisco, California 94119 Mr. Thomas M. Gerusky, Director Bureau of Radiation. Protection Resources Commonwealth of Pennsylvania P. 0.
BOx 2063 Harrisburg, Pennsylvania 17120 Mr. N. D. Weiss, Project Manager Maile Code 391 General Electric Company 175 Curtner Avenue San Jose, California 95125 Robert W. Alder, Esquire Office of Attorney General P.O.
Box 2357 Harrisburg, Pennsylvania 17120 Mr. William Matson Allegheny Elec. Coorperative, Inc.
212 Locust Street P. 0.
Box 1266 Harrisburg, PA 17108-1266 Mr. Anthony J. Pietrofitta, General Manager Power Production Engineering and Construction Atlantic Electric 1199 Black Horse Pike Pleasantville, NJ 08232
Enclosure Chemical Engineering Branch/Fire Protection Section Susquehanna Steam Electric Station, Units 1
& 2 Docket Nos.
50-387/388 The Region I fire protection inspection during the week of February ll, 1985, identified potential violations and deviations from the commitments contained in the licensee's fire protection program.
At the licensee's
- request, a meeting was held on February 26, 1985, in Bethesda, Md. to discuss the SSES fire protection requirements and commitments.
PP&L expressed their opinion that they were in compliance with the NRC's requirements and cited as the basis for this position the information contained in Revision 2 to PP&L Fire Protection Review Report and the staff's SER and Supplements.
Following the discussion, the staff provided PP&L with the following staff position:
1.
PP&L should not construe our SER and supplements as explicitly or implicitly approving PP&L's fire protection program as satisfying Appendix R Sections III.G, J and 0.
2.
To the extent PP&L chooses to use the analysis, either in whole or in part, that formed the basis for the Appendix A fire protection evaluation, PP&L should be cognizant that the staff indicated during its audit that the Appendix A evaluation would not be sufficient to demonstrate compliance with Sections III.G of Appendix R.
3.
The staff suggested that to the extent that PP&L needs to go beyond their Appendix A fire protection evaluation to demonstrate compliance with Section III.G, then the scope and completeness of any re-analysis should be in accordance with the guidance presented in the regional fire protection workshop.
During the week of March 4,
- 1985, PP&L indicated that they had some additional analysis to supplement their Appendix A evaluation and requested that a staff review team be sent to the site during the week of March 18, 1985.
On March 18, 1985, the. staff review team met with PPSL representatives to establish the purpose of this site visit and on March 21, 1985, to present the results of our audit.
The participants in these meetings are listed in enclosures 1
and 2.
The purpose of this site audit was to enable the licensee to demonstrate compliance with Section III.G. on the basis of information that was not readily available at the time of the original Region I inspection.
The licensee's supplemental information consisted of two calculations:
1.
"Justification for 45 min rating equivalent - non-rated walls",
DK-C-DJK-009, D.J.
Kahn, March 15, 1985.
2.
"Structural evaluation of Reactor Bldg, Floor Slabs with Beams at 1500'F",
FK-C-JDV-031, J.
D. Vernan, February 22, 1985.
The licensee provided a copy of three of the fourteen references to calculation 1 above.:
2)
Technical Report, "Evaluation of Selected Fire Door and Door Frame Assemblies",
FM Under No. 38492.55,
'S.M. Knight, January 1985.
9)
"Fire Research for Steel HVAC Systems, NFPA Fire Journal", Vol.,78, No. 6, R.
G. Gewain, November 1984 (13)
"Fire and Hose - Stream tests of Seismic Gap Simulation Test No. 1",
M. Gillen and M. Abrams, Construction Technology. Laboratories, August 1979.
The licensee also. provided a copy of the following:
')
'ire and Hose-stream tests of Seismic Gap Simulation Test No. 2",
M. Gillen and M. Abrams, Construction Technology Laboratories, October 1979
B.
Ltr to A. Zaccaria,
- Bechtel, from G. Buxton, Middle South Services, Re.
ANl Approval of Seismic Joint Seals, November 7, 1980, Attached was "Fire Test of Sanolastic Sealant Material, Bechtel Power Corporation, August 11, 1980.
The staff evaluated the following specific concerns during the site audit to determine compliance with Section III.G.:
2.
3.
4.
5.
6.
Unrated fire zone boundaries Criteria for',fire protection of safe shutdown systems within a fire zone which do not comply with the requirements of Section III.G.
The independence of the Alternate Shutdown Capability from the Control Room The analysis of associated circuits within fire zones.
The safety significance of deviations The conformance of the re-analysis to the workshop guidance.
The results of the staffs review team's evaluation is summarized as follows:
Unrated fire zone boundaries Some fire zones are bounded by floors, ceilings and walls which are not rated as fire barriers.
A number of these assemblies do not have rated fire doors, fire proofing on structural steel, penetration seals in pipe and ventilation duct penetrations, or fire dampers in ventilation ducts.
In addition, the sealing of seismic gaps between such assemblies varies from open space to a full depth of rodofoam.
The licensee has stated that the unrated assemblies would be equivalent to a fire resistance of 45 minutes.
The staff reviewed the licensee's justification for the unrated assemblies:
The walls, floors, and ceilings are constructed of concrete that varies from'" concrete block to 24" reinforced concrete.
The staff finds this acceptable.
The unrated fire doors vary in construction details.
The licensee has had some of these doors evaluated by the Factory Mutual Research Corporation (FM).
FM concluded that labeled fire doors are expected to provide the level of fire resistance stated on the label.
The staff finds this acceptable.
FM did not clearly state their decision on unlabeled doors.
The staff finds this unresolved pending clarification by FM.
FM did not evaluate the hollow core metal doors which are also located in the subject walls.
Tpe licensee justifies these doors on the basis of solid wood doors being listed by UL with 20 and 30 minutes fire ratings.
The licensee simply concludes that the hollow core metal doors would have a rating of at 45 minutes, if tested.
The staff does not agree that this is a valid method for assessing the rating of these hallow core doors.
The HVAC ducts are not sealed into the assemblies.
The licensee's calculation does not address this issue.
The staff finds this unacceptable.
All HVAC ducts in the unrated walls do not have a fire damper.
The licensee justifies this in the basis that (1)
NFPA 90A, 1981, does not require fire dampers in all penetrations and (2) fire tests have shown that 24 gauge sheet metal ducts without openings will pass NFPA 251 for one hour.
The licensee has not shown that his penetration openings are within the size limitations of NFPA 20 or are without openings within the fire zone.
The staff finds this unacceptable.
The cable and conduit penetration are sealed with 3-hour rated fire seals.
The staff find this acceptable..
Some moveable pipe are provided with boot seals but are not fire rated.
The licensee justifies this on the basis that:
a.
The space 'between the pipe and the assembly is relatively small (i.e.,
13" annulus or less) and 21 to 24" 1'ong.
b.
Cable fires within these fire zones would not cause temperatures to be greater than 325~F on the unexposed side.
The staff does not agree that this is a valid method for assessing the fire rating of such seals.
The structural steel supporting the assemblies is unprotected.
The licensee's calculation proposes to show that if the steel reaches 1500OF it retains 20K of its original strength and that strength is adequate to support the loads during a fire.
Since the air temperature in the room would not reach 1500'F for 30 minutes, if the temperature follows the standard time temperature
- curve, the licensee assumes a 45 minute fire resistance because of the conservative assumption.
The staff finds this issue unresolved pending completion of the staff's evaluation of the calculation.
The seismic gaps filled with rodofoam are justified on the basis of test results of certain configurations.
The staff observed that plant configu-ration are not similar to the tested configur'ation, and, therefore, the results of the test are not directly applicable.
The staff's finds this unacceptable..
The seismic gaps with a water seal
{rubber membrane at 1/2 the assembly depth) that contain no Rodofoam are justified of the basis of their similarity to movable pipe penetrations.
The staff does not agree that this is a valid method for assessing the fire rating of such seals.
I The licensee's calculation does not address the seismic gaps that are completely open.
The staff observed one such seismic gap in an 8" concrete block wall.
The staff'inds this unacceptable.
The licensee's construction drawings which control plant features, such as penetration seals in walls and floor/ceiling assemblies, stipulate no require-ments for fire protection on these unrated zone boundaries; therefore, the fire resistance of such boundaries is due to chance rather than design.
In addition, these unrated fire zone boundaries are not included in the fire protection technical specifications.
The staff finds this unacceptable.
Criteria for fire protection of safe shutdown systems within a fire zone which do not comply with the requirements of Section III.G.
Section 2.11 Minority Division Essential Cable Protection,
- FPRR, Rev. 2, sets forth the criteria, designated as items (a) through (g), for protecting essential safe shutdown cables located in the same fire area:
"Protection of essential minority division raceway is accomplished by item (a) plus one or more of the following protective features:
(a)
Fire/smoke detection is provided in all fire zones containing safety related raceways.
(b) If redundant essential safe shutdown raceways are separated by a
horizontal distance of at least 50 feet, no further protection is provided.
(c) If redundant essential safe shutdown raceways, are separated by a hori-zontal distance of less than 50 feet, fixed automatic fire suppression shall be provided to protect an area. at least 50 feet horizontally on either side of the essential minority raceway.
(d) If redundant essential safe shutdown raceways are separated by less than 50 feet and not protected by fixed automatic fire suppression, the raceways of one division will be enclosed in a fire barrier having a
3-hour fire rating for a projected horizontal distance of 50 feet.
(Either side of the essential minority raceway).
(e) If redundant essential safe shutdown raceways are separated by less than 20 feet and protected by fixed automatic fire suppression, the raceways of one division will be enclosed in a fire barrier, having a 1-hour fire rating for a projected.horizontal distance of 20 feet.
(Either side the essential minority raceway).
(f)
Specific technical justification may be developed for special cases not covered.
7w (g) If the equivalent fire severity is less than 10 minutes and the redundant essential safe shutdown raceways are separated by less than 20 feet, the raceway of one division will be enclosed in a fire barrier having a 1-hour fire rating for a projected horizontal distance of 20 feet.
(fither side of the essential minority raceway).
Items (a) and (e) above are consistent with the licensee's commitment to meet Section III.G, the other items are not.
The other items may be justifiable crtieria for certain configurations which deviate from the Section III.G con'figuration.
However, the licensee has not adequately analyzed or documented the separation/protection of redundant shutdown systems to enable the staff to conclude that these configurations are acceptable.
These criteria are not acceptable for all configurations in the plant.
During this site audit, we did not identify any new concerns over the implementation of these criteria that are beyond those previously identified in the Region I inspection report.
The independence of the Alternate Shutdown capability from the control room.
The isolation of the Alternate Shutdown capability from the control room was evaluated.
The control circuits from the control room were satis-factorily fused with separated fused circuits or coordinated fused circuits.
The staff finds this acceptable.
The analysis of associated circuits within fire zones.
In general, only the "minority" division in any fire area was analyzed (See.FPRR, Rev. 2, pg 4.1-7):
"...The cables in all listed minority raceways are checked, and any not connected to a safe shutdown systems (as given in Table 6-4) or component
are deleted.
All cable left is reviewed for its support of the systems safe shutdown function(s) and for the effects of failure caused by fire.
These effects include open circuits, shorts to ground, and contact with live conductors..."
For such a fire area, the analysis assumes the "majority" division in the area is lost and shutdown is to be accomplished by the "minority" division.
The methodology analyses associated circuits for the "minority" division but not for the "majority" division.
The licensee's separation criteria is adequate to assure that the "minority" division is not associated electrically with the "majority" division.
However, the methodology is not adequate to identify systems interactions that could associate the "majority" division with the "minority" division shutdown capability for the area.
The licensee did analyze two special cases at high-low pressure interfaces related to RHR system and
'ADS valves.
The "minority" division analysis was not conducted for the control room fire.
In the licensee's
- FPRR, Rev.
3 (12/84) the only fire postulated is in a single tray or single panel fire (ONLY 1 DIV. LOST).
In the sample component cables reviewed two problems were identified for a control room fire:
4 Loss of 40 H.P. diesel generator HVAC fuses.
These are required for safe shutdown.
A control room fire would cause the control fuse to blow bringing about the loss of these fuses.
The licensee has not provided an analysis showing the D.G's would survive the subsequent temperature rise in the D.G.
room.
Spurious signal (hot shorts/grounds) would cause the loop A and loop B
ESW inlet water D.G. valves to close.
This would cause the
loss of water cooling to the D.G's.
The licensee stated that three procedures, i.e., E0-024-001, EO-100-030 and E0-200-030, would be used and this would resolve this problem.
These procedures are in addition to the three procedures walked down during the recent Appendix R inspection.
There was not enough time to walk down these procedures during this inspection.
Other problems may exist that have not been analyzed by the licensee.
Zone Fires Zone 1-36-Access Area.
The RHR valves (027A, 8 and 028 A, B) were selected as samples to review.
These.are RHR suppression pool return valves that are used for safe shutdown and are all located in Zone 1-3c.
Our concern is that they are not shown in the FPAR, Rev.
3 with other components needed for safe shutdown.
(See pg. 4.3-30).
It appear that they were missed in the analysis.
Zones 2-4A and 2-5A were reviewed to see the effect of a fire through the hatchway joining these zones.
The redundant cooler within 50 feet of the hatchway in Zone 2-5A would be lost with the loss of the majority cables in Zone 2-4A with no adverse effect on safe shutdown.
Zones 1-20 and 2-2A were reviewed to address the concern of a fire in this area from an associated circuits point of view.
The principal component that can be controlled from this panel (ES>l valves Div. II, RHR valves Loop B) were reviewed and their circuits were traced from the valves to the poHer source and to the remote shutdown panel.
The circuit did not go through any zones where a fire could affect safe shutdown.
The safety significance. of deviations.
The post fire shutdown capability may not be adequate in some cases because of: (1) the lack of a systematic analysis of the "majority" division system interaction with the "minority" division shutdown system; (a) the lack of an associated circuits analysis for the control room and (2) the loss of certain support systems during control room fire.
The licensee agreed to scope this problem and inform the staff within a week.
The licensee agreed. to develop interim emergency operating procedures as problems are identified until resolution is achieved.
The redundant division of RHR may be involved in a single fire if the associated non-rated fire zone boundary does not contain the effects of a fire.
The conformance of the re-analysis to the workshop guidance.
The guidance for re-analysis given at the workshops was summarized in GL 85-01.
Me found the licensee's re-analysis deficient in many aspects.
1.
- FPRR, Rev. 2, Section 4.0, states that evaluation was done using Appendix A to BTP APCSB 9.5-1.
There is no mention of a re-analysis to the require-ments of Section III.G of Appendix R.
2.
The licensee stated there was no additional analysis other than the aformetioned calculations.
3.
The licensee had no ongoing analysis at the time for the site audit.
4.
The control room fire and the associated circuits analyses are not adequate.
5.
The*justification of un~ated fire zone boundaries is not adequate.
6.
The re-analysis contains no justifications for partial coverage suppression systems.
Based on the above, we conclude that the re-analysis does not conform to the workshop guidance;
Enclosure 1
SUSQUEHANNA R.L. Ferguson Dennis Kubicki L. S.
Weed C. T. Coddington S.
Y. Pullani T. Baileys E.
D. HacDougall Rick Jacobs Llyod Smith Don Kohn Ken Backenstoe Bill Williams R. J.
Prego R. Byram NRR/DE/CMEB NRR/DE/CMEB PP&L PP&L
.NRC/RO: I PP&L/P.S.
BNL NRC/SRC Bechtel PP&L PP&L NPE-Elect.
PP&L Licensing QA SUPV-OPS PP&L
~
~.
Enclosure 2
Attendance NRR Fire Protection Program NAME Pre resentin R. Paley S.
V. Pullani L. G. Smith R. Jacobs Ed. MacDougall L. E. Whitney Dennis Kubicki Don Kohn Ken Backenstoe R. S. Prego Bill Williams C. T. Coddington T. Baileys D. J.
Thompson M. Campagnone PPSL NRC/RO: I Bechtel NRC BNL NRC/IE NRC/NRR PPE(L PPSL.NPE gA SUPV-OPS/PP&L PPSL Licensing PP8L Licensing PP8L/Plant Staff Assist.
Sup of Plant NRC/Project Manager