ML18086A499

Forwards Draft Fire Protection Sys Section for SER Suppl 6. Requests Comments by 810512

ML18086A499
Person / Time
Site:	Salem
Issue date:	05/12/1981
From:	Tedesco R Office of Nuclear Reactor Regulation
To:	Vollmer R Office of Nuclear Reactor Regulation
References
NUDOCS 8105180464
Download: ML18086A499 (11)

Text

i

~~~~

f

_I 8105180

~------- -*=

MAY 1 2 1981 Docket No.:

50-311 MEMORANDUM FOR:

Richard H. Vollmer, Director, Division of Engineering, NRR FROM:

SUBJECT:

Robert L. Tedesco, Assistant Director,for Licensing, DL FIRE PROTECTION EVALUATION FOR SALEM-GENERATING STATION, UNIT NO. 2, FULL POWER Enclosed is a draft of the Fire Protection System section for Supplement No.

6 to the Salem 2 SER. This draft combines your previous Fire Protection review input dated April 28, 1981, with the results from the recent on-site review at Salem.

The team report, to be included as Appendix G to the Salem SER, was distributed as an attachment to NRC Meeting Summary, dated May 11, 1981, 11Summary of Meetings and Site Visit to Review the PSE&G Cable Interaction Study.

11 Please provide your comments concerning the enclosed draft evaluation by C.0.B. May 12, 1981.

We are currently reviewing the license conditions cited in the enclos~~e and anticipate that some minor wording changes may still be required.

Enclosure:

As stated DISTRIBUTION:

Robert L. Tedesco, Assistant Director for Licensing Division of Licensing Docket File 50-311 LPDR PDR NSIC TERA LB#3 Files RLTedesco FJMiraglia GCMeyer JDKerrigan

• ~~[~_*;:t.i' OFFICE~ *.°~.:~~-~~******....

l SURNAME. ~Y.~x.:jJ?...... f.~.... J.1.g........ cte.sc.o....................................................................................... ;_

DATE~ * ?!.~:::-!?.'............ ?!

.. ?!(~.~.....................-.............................................. ***.................... *_

NRC FORM 318 110/801 NRCM 0240 OFFICIAL RECORD COPY

~ USGPO: 1980-329-824

UNITED STATES

. NUCLEAR REGULATORY COMMISSION WASHINGTON, o.*c. 20555 MAY. r 2 19m

! Docket No. :

.S0'.""311.

MEMORANDUM FOR:. Richard*H. *Vollmer, Director, Division of Engineering, NRR FROM:

SUBJECT:

• .. Robert L. Tede_sco, Assistant Director for Licensing, DL FIRE PROTECTION EVALUATION FOR SALEM. GENERATING STATION~

UNIT NO. 2, FULL POWER Enclosed is. a draft of the Fire Protection System sectibn for Supplement No.

6 to the Salem 2 SER.

This draft combines your previous Fire Protection review

. inp.ut dated April 28, 1981, with the results* from the recent on-site review*

• at. Sal em.

• The t.eam. report,: to be included as Appendix G to the Sal em SER,

• was distributed as an attachment to NRC Meeting Summary; dated May 11 ~ 1981, 11Summary of Meetings and Site Visit. to Review the PSE&G Cable Interaction Study. 11

• Please provide your comments concerning the enclosed draft. evaluation by c.o.B.. May.. 12,. *1981..

.We are curre.ntlY reviewing the' license-conditions"..

cited in the enclosur-e and anticipate that some minor wording *changes may : **

,. still. be requi r.ed.

_ EnclOsure:

As stated

• Q~--P~"~ -

Robert L. Tedesco~-Assistant Director

• for Licensing Division of Licensing

9.0 AUXILIARY AND EHERGENCY SYSTEl,iS 9.7 Fire Protection System I

In Appendix E to Supplement 4 of the Safety* Evaluation Report,.dated April 1980, we presented our Fire Protection Safety Evaluation Report for Salem Units l and 2.

In this report we stated that the applicant will provide an alternate shutdown method for our review that would be independent of the relay and switchgear rooms.

We also stated that the applicant has committed to perform a fire interaction analysis on a 11 redundant systems and components necessary for safe cold shutdown which are separated only by distance and are within'2o*

of each other.

Where additional protection and/or separation is required to assure a safe shutdown condition,*the applicant has commited to:

( l}

• a chi eve a minimum of 20 *ft. separation between di visions; :or

• (2)* provide a one-hour rated.barrier to separate one train from the other and an automati~ sprinkle~ system at interactiori areas; or (3) provide an alternate shutdown method that is independent of the interaction areas.

By letter.dated November 5, 1979, the applicant made these commitments, stated his criteria for the fire interaction analysis and provided preliminary descriptions of the type of modifications he proposed.

The applicant also stated that additional information would be provided to the staff when the analyses and the design changes are finalized.

jhe staff required that the results of the licensee's f1re interaction analysis be reviewed prior to issuance of a full power license.

In order to expedite this action a NRC fire protection review team was assembled for the purpose of conducting an on-site review for Salem Units l and 2.

The objectives of this team were to:

(i) make a finding on the adequacy of the licenee's cable separation study.and the

~*. ' -

plrogram used to _implement the results of,-thaf study; and (2) make. a-Jin.ding on the adequacy 00f the corrective' actions impi'emented as a result of the cable 1nteraction program~ These findings woul~ be limited to the adequacy.

of the fire protection measures on an interim basis.

The adequacy of-the

_--_ measures on a 1 ong term basis wou1 d be covered by the staff in its review of the 1 i censee.

1 s compliance. with App. R as docuni-ented in its. response to. NRC _* s

.G~neric lett~r 81-lt.

-_ -~ The on'-site fire protection review was COf1dUcted from April 30, '19.81.to May 7 ' -

-1981.

The team's report -fs attached as Appendix G to the report.

The team

-~oncl uded that "the* fl re, protection measures are adequ-ate fq'r :contfnued operation of Unit 1 and for issuance of a (full pbwer) license with appropriate license conditions-for Unit 2 *. *

• 11 The 11 cense con di tiOns resulting. from* this review -

ar~*Jisted at_ the cooclusi.on of this section.

During ihe*course:of the st-aff-is 'on-sfte'revie"w*,, one* are~"i~<the--480/230.VAC_-_ -

1'

-switchgear room on -elevation.84 1 in, the Au:xiliary*Building* was fden-t-i-fieci in*

- _which a sirigle postulated 20-foot diameter fire-could pofentiaily.fai-ra-11 i nst~ument channels' including the i ndepe~dent safe s'hut~own i n-strumentati on provided fof ~lternative shutdown.

The review team ~oncluded ihat this presented an i mrnedi ate safety concern.

Accordingly, the Offi~ce of Inspection _and _

Enforcement obtai.ned, ~nd docum~nted in correspondence dated May 5, 1981, a licensee commi tmenf to take immediate corn~cti ve actions._ This commitment -

-; s reflected 1 n the license con di ti ons 1 i sted at the conclusion of :this section.

Toe :'resul.ts of the on-s.ite review were-based upon.a fifty percent audit _

of *the licensee'_s interaction analysis. All identified deficiencies were

• _related ba~k to specific basic assumptior:1s and criteria used i ncorisi stently or incorrectly. by the licen.see for the. interaction analysis.

To ensure that a 11 ad di 'ti ona 1 r~ 1 ated defi ci enci e's' if any' are i d~ntifi ed and corrected the licensee shall be_ required -to_- review.his.Fire Interaction ana1ysis in

• 1i~ht:cif the NRC'~ review team's findings.and report! correct all additional def i ci end es by

~*-

.e.

oh Nov.emberl9, 1980, the Commission published an amendment to-its regulations which required.SaTem Unit l_to_complywith Sections III.G, III.J,and.IiI.O of Appendix R to IO CFR Part 50.

As indicated in-Supplement 5 to our SER,

• January 1981, _the applicant committed, by letter_ *d_ated December 1, 1980 -to.

• • implement in Salem Unit 2 any changes required for Salem Unit. 1 to comply with Appendtx R requi~ements-By letter* dated March. 19, 1_981,- the applicant requested several exemptions from

~.

• .the requirements of~ppen~ix R. ;Our revie~ of these exemption requests ar~ being delayed pending receipt of the* final. design descrip_tions of the modifications

_made Jo provide fire-protection for shutdown systems and the alternative-shutdown capabi 1 i ty *

. By 1 etter dated Apri 1 22, 1981,.. the licensee committed to comply with Appendix R.

_Sec.ti on I II ~L *with respect: to alternative _shut~owr:i. capa_~i 1 ity and. ta* pr6vi de-

.. the *1 ~formation we: re qui re to complete* our 1-rev:i ew: by May 19,. 1981 *. -. :.we _app'roved *

• • a -.slip. in this. s:chedule to.

.. ::*

• because of the requifement Jar PSE&G: fo.**

<support the staff's on-site-fire protection rev.iew.

In SER Supplement No. 5, w~ stated that the alternate shutdow*n c'apability to*

achieve hot shutdo~n from outside th~ tonttol room is now o~erational. This statement was in error; As stated above, the applicant has not yet submitted a description of this capabi 1 i ty *.

At present, we are developing a_ program for evaluating Appendix R exem-ption *requests for. all operating pl~rits*.

~le w_ill.be completing our_evaltiation of the fire pro-tection programs at Salem Units 1 and 2 as part of thai program.

In Supplement No. 5 to the Salem Unit 2 SER, we also stated that an action item yet to be completed was the wrapping of several cable trays with a* mineral wool blanket.to give a* 1-hour fire barrier bet\\veen divisions _separate_d by less than 20 ft.

We concll.ided that it was reasonable tov1ait until Mar~h 20; 1981_, to wrap these cable tray~~ By letter dated April 22, 1~81, the

• 1. l~ censee informed. us that, the wrappi.ng of cable trays was delayed because they were unable~*to obtain adequate quantities of the mineral wool from the. vendor.

The licensee stated that as of April 22, 1981 they would have 40% of all trays wrapped 'and. that. the wrapping would,be -109~ complete by.

June' 15-, 1981.

A further deTay~ unti1

, resulted from the requirement for PSE&G to support the staff on-site fire protection review.

We have* concluded that the licensee is making a reasonable effort to complete*

this item and their schedule is acceptable.

The full power license wi11 be conditioned with.a.requ:irement*to complete thisitem by*

Wef~n~ that the fire ~rotection ~rogram for the S~lem Nuclear Generating*Station is adequate at the present. time, me~ts* the requfrements of GDC-3; *and *with the licensee's commitments and scheduled modifications, meets the guidelines contained in Appendix* A to BT~ 9.5-1. Until the. committed fire protection system improvements

• are operational, :we.consider the; existing~ fire detection and SUppJ".eSSio~ systems;._

. the:existing* barriers between fire *areas; ;mpr_oyed administrative procedures fo~-.

cont~ol*.of comblistibl,es a*nd i.gn_ition-sources; the: trained* o~site f.irehridage;

. :the.capabi'lity to extinguish 'fire-manually; and the fir~ prote~t1ori 'tech~ical

• specificatiOns provide *adequate protection against a. fire*-that woul.d threaten safe* shutdown.

On :this basis we conclude that Sale~ Unit l'is acceptable for full~*power operation subject to license conditions listed below ~/hich will assure the.timely *compietion_

of sche~ule modifications.

• Full~ powe.r license conditions:

1.

P~ior to exceeding* five percent rated thermal power, PSE&G shall~

a.

Wrap_ the pri.mary. feeds for 125 volt DC control power. to the 4160 volt~ 460 volt and ~30 volt switchgear located above the 4160 volt*swjtchgear at elevation 64.

.e

- 5

.I.

b.

c:orrect._}:~e.following materiaT:.and procedural deficiencies associated with the alternative shutdown capability:

• ( 1)

}he* 1 ack of coordination in. the procedures to ensure applicatiori of the,appro~riate alternative method when*

dictated* by pl ant circumstance or c.ondi ti ans..

( 2)

The 1 ack of direction to the Senior Shi ft Supervisor.as.

~:

to when c'ontrol.room evacuation is dictated,_ and lack of definition as to wh.ich procedur~s, keys*, operator aids,.*

• • and equ'ipment will be required_ in the new control location; th.e l ack"of discussion of shift organization and personnel deployment for remote ope\\ation *

~...

(3), Most.local operati_ng ;ns:tructions"require the *use of special*

~equipment or* tools.~ *..* Th~se'* items ~~e~.specificallY. identifi~d.*..

in the procedure but have not been pre.;.. staged i rl 'a: defi r:ied locati_on. *These items include hand tools, pneumatic jumpers, prepared. electrical *jumpers, and diesel control power cables..

(4)

No meGhanism is provided to maintain system status once local operation has been initiated *. No proyisionto restore normal*

function to disturbed control. systems has been' defi n'ed.

(5)

No indi~ation of reactor flux level i~ provided for the dedicated alternate shutdown syst~m: Accordingly, guidance for ensuring 6r'.

verifying adequate shutdown margin when outside the control room should be provided

• j,*,.

C.*

2 *. By

~ 6 -

( 6)

Dedicated a 1 tern~te shu_tdown instrumentation does not include 1 oop 0

or ~qre temperature. 'In.order to achieve cooldown, direct

. temperature information from the hot and cold legs should be required and can be achieved, if not otherwise available, by

• irtsta 11 ation of temporary instrumentation to the detector lead in the penetration area~

• (7) *.Adequate measures shou.ld be implemented to ensure that effective comm~nications with alternative shutdown control stations can be established.

(8)

Adequate 8 hciur emergency lighting, independent of plant power systems should be installec:t at.all lo.cations which may be requ1red to be manned diJri ng the alternate shu.tdown procedure as well as at all avenues of entrance to and egrees from. tho.se i

>areas *

(9) *Minimum staffing requireme~ts p'resently do. not. inc-lude all of the following i ndi vi duals; *2 Senior Reactor Operators,* 4-t~Licl ear Co.ntrol Operators, 10 Equ i pment/Util i tY Ope_rators, the Shift Te~hnical Adv1scir, and one maintenance electrician~ This*.

staffing level is necessary, on shift, to support a workable alternate.shutdown capability.*

This would necessitat~ adding

an additional two people no_t currently on shift.

1981, PSE&G shall:

a.

Modify or extend existing barriers in 4160 volt switchgear room in order to protect redun~ant ~ontro~ and power cables currently located ~bo~~ fire barrier;

.e

b.

Provide a one-hour barrier for the cable trays associated with the turbi ne-}lr:-i ven auxiliary feedwa.ter pump in the au xi 1 i ary feedwater pump room;

c.

Provide a one-hour barrier around.one of the redundanf cables*

. associated with power, instrumentation, and control* for the diesel generators. (located in the proximity of the* diesel.generators) where*

separatfon is less than 20 feet.

d.

Provide smoke detectors in the area of the power feeds to redundant diesel generators in the 4 ft. wide hallway near the waste gas tanks.

• e.

Wrap redundant cables supplying power to. the* 4 kv switchgear* from the

• diesel generators.. in the 4 kv switchgear room where sepa_ratibns.. ;s Tess: than 20. feet.

f'*

Wra,p* re.qundant. cabl.es supplying.. power from 230 volt. switchgear to the battery chargers where separation is. 1 ess than 20 feet *

. g.

Raise barriers separating equipment needed for shutdown so that the top of the barrier is above the top of the redundant raceways or wrap both redundant raceways in the following areas:

460-230 volt switchgear, 125 volt D-C switchgear, the valve motor control centers located in the electrical penetratiory area, and the pressurizer heaters buses located in the electrical penetration

. area.

h.. Extend barrri ers in an "L" shape configuration for.the following equipmeni: the 4160 vo]t switchgear, 460-230 volt switchgea~,

the 125 V DC switchgear, the valve motore control centers, and the pressurizer heater buses.

J.

.., 8 -

1 i. Wrap one of.the redundant poweF cables from the diesel generators l ocatec;l. tn* the fuel oil storage tank room.

j... Provide on~ hour fire* barrier for the 208 panel or the turbine

• driven au xi 1 i ary feedwater.control cabinet.

k.

Provide a one hour fire barrieF fbr the remote shutdown panel.

1 *.

PSE&G. shall review its Fire Interaction analysis for any additional

• areas imp acted by the as sump ti ons and criteria i denti fi ed in the NRC revtew team's. report as. being incons.istently or inaccurately applied.

PSE&G shall report the results of thi~ review.and complete all addi-.

tionaT corrective actions by 3* *.

• By* June 5~. 1981, PSE&G shall: :

a'..

• Re'."'route*. the alternate* shutdown power*. feed _in* order to: provide. *.

protettion for thi~ table from a fire affecting the normal instrument t~ains., UntiT th~s.modific~tion is complete~ continuous fire watch.shall be stationed in the* elevation 84 s1-.1itchgear room.. During th~ peri~d when riew.leads ~re b~ing landed, and no power feed to the

• alternate shutdown instruments is available, an additional fire watch sha 11 be stationed continuously in the Re-1 ay Room.

. b.* Complete final* engineering verifiction of the fire-protection analysis*

and corrective act~qns.

4. *ouri rig the performances *of Startup Pro.cedure SUP 82.5? Shutdown From

. Outside Control Room, PSE&G.shall satisfactorily demonstrate the follo~ing additional operations:

a.* Local start of d1esel genertor using alternative control* power source.

... b.

Local op~ration of 4 KV breaker~

c.

Local start of th~ containment fan cooler unit.

d.

Local operation of a motor operated and an air operated valve.

~-

Local control of charging.

5.

Prior to wrapping.

, PSE&G shall complete all required cable