ML18092A228
| ML18092A228 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 04/05/1984 |
| From: | Liden E Public Service Enterprise Group |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML18092A227 | List: |
| References | |
| GL-83-33, NUDOCS 8407110245 | |
| Download: ML18092A228 (15) | |
Text
.....
Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge. New Jersey 08038 Nuclear Department April 5, 1984
- u. s. Nuclear Regulatory Commission Region l 631 Park Avenue King of Prussia, PA 1940~
Attention:
Mr. Thomas T. Martin, Director Division of Engineering and Technical Programs Gentlemen:
NRC INSPECTION NO.
~0-272/83-37 SALEM GENERATING STATION UNIT NO. 1 DOCKET NO. 50-272 In response to your letter dated March 2, 1984, on the subject inspection., enclosed is additional infor1.,,ation on the unre-solved issues. We have also provided additional information on both Violations, one of which was previously addressed in PSE&G's letter dated January 27, 1984.
PSE&G disagrees with the classification of ~he recent exemp-tion requests as a violation.
These requests for exemptions were made pursuant to lOCFP 50.12, following the guidance of Generic Letter 83-33 and resulting from the new interpretation of Appendix R provided in the generic letter (e.g. definition of fire area, area wide detection/suppression system).
These exemptions are in areas previously reviewed by the NRC during the Unit No. 2 1 icesn ing process.
In that these exempt ion re-quests were made pursuant to 10CFRS0.12, not 10CFR50.48, and were based upon new guidance provided by the NRC, PSE&G requests that their classification as a violation be reconsid-ered.
PSE&G has performed a reanalysis of Appendix R to demonstrate compliance with Item III.G.2.
Results of this reanalysis were providerl to ONRR in a letter dated January 31, 1984.
The In-Cont~inment Analysis was submitted to you by letter dated January 27, l9R4.
Thomas 4/5/84 PSE&G believes it is important to recognize that, on good faith, we have made numerous modifications to upgrade the plant fire protection features (e.g., fire detection, suppres-sion, fire barriers, cable wraps, alternate shutdown capabil-ity) based on its own interpretation of Appendix R, and pre-vious NRC review and inspection.
Additional improvements will be made to correct the deficiencies identified during the Generic Letter 83-33 review and results of the subject inspec-tion as described in the enclosure.
With the existing upgraded fire protection features, alternate shutdown capability and plant administrative controls, we feel that the issues identified in the subject inspection do not pose any undue risk to the health and safety of the public.
~~~II
~~~~<
Sincerely,
-~A-L/?r?
E. A. Liden Manager -
Nuclear Licensing and Regulation
~~ Attachments
\\j-C Mr. James Linville Senior Resident Inspector Mr. Donald C. Fischer NRC Project Manager
~~:.:----:.~:~~-*~~**.
-~*.
Thomas BC Vice President -
Nuclear General Manager -
Nuclear Services General Manager -
Nuclear Support Gerieral Manager -
Salem Operations General Manager -
Hope Creek Operations General Manager -
Nuclear Assurance and Regulation Assistant General Manager -
Nuclear Engineering Assistant General Manager -
Engineering Manager -
Nuclear Systems Engineering Manager -
Nucl~ar Plant Engineering Manager -
Nuclear Engineering Control Manager -
Nuclear Operations Quality Assurance Manager -
Nuclear Training Manager -
Licensing and Analysis Public Affairs Manager -
Nuclear Safety Review Group Operations Assessment Engineer Station Quality Assurance Engineer Associate General Solicitor Nuclear Review Board Manager LIS (J. c. Plunkett, Jr.)
O_'l?S (D;_ C.... Aab¥e) *
-PE (w': T*. Ulir.ic'h"-).....
PL&G (T. R. Robbins)
J. Vargas M. Ranerjee R. s. Patwell File 9.5.1/18.13.2 ANl 1/11 4/5/A4 4/5/84 I. violations (50-272/83-37-01)
Auxiliary Building, Elevation 45', RHR Pump Rooms PSE&G letter dated January 27, 1984, indicated that an exemption from the explicit requirements of Section III.G.2b for an area wide detection or automatic suppression system would be requested for this area.
A detailed justification for this exemption request is as follows:
A.
B.
- c.
- .. *D.
E.
F.
Fire detection exists around the RHR pumps located on elevation 45'.
Hose stations are located on elevation 55' within reach of the RHR pumps.
Component cooling valves which control component cooling water flow to the RHR heat exchangers can be manually aligned to the proper cold shutdown position. *
- .The.. combustibl.e loading.. on el>evat*ion
- 5.5.i *is 2,,78_5 *.
- .aTUfsq;* *ft.~ *wttiC:h,* ff totaily consumed, would correspond to a fire severity of *about 2 minutes.
The physical separation between the RHR pumps is approximately twenty feet with a concrete wall separating the two pumps.
The power cables for the RHR pumps are routed in conduit and are separated by appr~ximately twenty feet at the point of closest interaction.
The cables are also separated by the concrete wall which separates RHR pumps.
With this exemption, the RHR pump rooms will comply with Section III.G.2.
Auxiliary Building, Elevation 84' Charging Pump Area As explained in PSE&G letter dated January 27, 1984, a wet pipe system provides better protection in that it provides a fast and positive response (only one operation is required, i.e., fusing of one sprinkl~r head for wet pipe rather than two heads for a pre-action dry pipe system).
I.
Viola~i'an*
Auxil Area Elevation A review of the area drainage system ensures adequate drainage capability so that accidental discharge or damage will not create local flooding.
This system will be expanded to provide area wide coverage, and will be implemented within 6 months after NRC approval.
Intake Structure, Service Water MCC Bays The doors of the MCC bays have been posted as fire barriers and added to the list of doors to be checked by fire door watch.
Since the redundant components are separated by a 3-hour barrier (with exemption) an automatic suppression system is not provided.
Containment Refer to PSE& G letter dated January 2 7, 198.4 *
- P.1.1xi:1ary
- Ruild irig;
- Ele.~at'ion ~f4 *,
- 460v i23ov. AC* swi.tchgear Room The original fire hazards analysis did not consider horizontal, IEEE 383 qualified cables as intervening combustible.
The analysis assumed that cables will burn but will not support combustion.
Therefore, there is assumed to be no further propog at ion of fire along a horizontal cable tray once the fire s~urce is removed.
This criteria was reviewed and approved by the NRC, via.
In light of the recent clarification issued by the NRC via the Generic Letter 83-33, we have performed a review treating the IEEE cable as intervening combusti-
- bles whenever a fire source was present for safe shutdown
.areas.
The review revealed that cables in three areas (Electrical Penetration CCWP Cable at elevation 64', DG cables at elevation 100') are required to be wrapped.
These modifications will be completed during the Sixth Refueling Outage.
..... 4/5/84 I.
VIOLA'r!ONS (50-272/83-37-01)
Auxilarf Building, Elevation 84', 460V/230V AC Switchgear
~ Continued)
The 460 volt Switchgear.Room, which utilized partial height barriers to protect floor mounted equipment, has been classified as an Appendix R III.G.2 and III.G.3 area. A systems review reveals that any one of the three 4 60/2 30 VAC sw~ tchgear groups will be adequate *for safe shutdown.
A detailed discussion *of the intervening combustibles, suppression/detection system and appropri-ate exemption request has been forwarded to the ONRR for review (refer to PSE&G letter January 31, 1984, Fire Area 1FA-AB-84A).
II.
UNRESOLVED ITEMS Auxiliary Building, Elevation 100', Corridor Area (50-272/83-37-01)
- .R~pa ir *.o~.*the. prot~ct}ve.f.ii;'e*. c.oating over.. stru~tlir_a~ ** *
. "ste"el. has. been completed *.
Auxiliary Ruilding, Elevation 84' Auxiliary Feedwater Area (50-272/83-37-03)
The Auxiliary Feedwater Pump bay area utilizes redundant pre-action closed head dry pipe sprinkler systems.
The two sprinkler headers are located approximately ten (10) feet above the elevation 84' floor le~el.
Each sprinkler system utilizes a different means of activation.
The first system is quickly acativated by smoke detectors located on the Auxiliary Building ceiling while the second system is activated by a heat sensitive fusable-link detection system located at the same elevation as the sprinkler heads.
The activation of any detector will open its respective deluge valve thereby, filling the piping system with fire protection water.
The ceiling height in this location is twenty feet and is obstructed hy items such as room coolers, ducting and piping that are supported from the ceiling.
We believe that better response to a fire will result with the sprinklers located below the ceiling congestion as heat generated from a fire on the floor or floor mounted equipment must first pass by the sprinklers where it will open the sprinklers before it rises to the ceiling where it will spread out and tend to dissipate.
It will also provide a better water distribution over the protected area because of the absence of obstructions.
4/5/84 Feedwater Area-Eac:fl~.redundant sprinkler system has been designec;! ~o provide sufficient coverage of Auxiliary Feedwat.er*:.. pump Bay Areas including the hallway and panels.
It should be noted that the turbine driven Auxiliary Feedwater Pump and accessories have been further protected by one-hour barrier enclosures with exemption.
Since the major source of a potential fire is transient combustibles, the sprinkler systems have been designed for floor-coverage and thus, are more than sufficient to perform the intended function.*
Auxiliary Building, Elevation 122', Control Rooms for Units 1 and 2 (50-272/83-37-08)
During the inspection, combustibles were found in the corridor between the two control rooms.
The carpeting material has been evaluated and found to have a flame spread rate, fuel contribution and smoke generation rate
.. _ qf' ~5 or Jess as. detertr!-i~ed. Qy the. AS'l'M Test-.E.;.84 *. The
<-.: :twel)t"y c;ia:i.:ions*: o*f: *c:::arpe*t. adhesive ts* 'no_n-c_omb:ustib'le *and the *associated four pints of methyl ethyl ketone is less than the allowable amount of combustible material considered for a transient fire (five gallons of heptane).
These four pints were each in a sealed non-combustible container.
The carpeting installation was finalized and the remnants were removed by the end of the shift.
We believe that the installation of tne carpeting material resulted in an insignificant increase in the fire loadings for the control room area.
An exemption will be requested from the explicit requirements of 10CFR50 Appendix R Section III.G.2.a to the extent that the Units No. 1 and 2 Control Rooms are not separated by 3-hour barriers.
The technical justification for the exemption request is as follows:
- 1)
An area-wide detection system is presently installed in the Main Control Room.
- 2)
An area-wide detection system will be installed in peripheral rooms.
Specifically, detection will be installed in the shift supervisors' office, corridor surrounding the control rooms, janitor's equipment room and the women's rest room.
-g ass wtlI; be inatalled* in place of the
- lnrz plane-gla** located bet.ween the two control
- and:' will be-expanded to include the shift a
rvlsors* office.
This glass will prevent any
- potential shattering and will minimize the propagation of smoke and gases generated during a control roam fire.
- The lower portions of the wire mesh glass assembly consists of louvered metal panels which are required for equipm~nt ventilation.
However, should a fire occur in the Unit No. 1 Control Room, the probability of fire propagation through the twelve foot ~orridor and into the Unit No: 2 Control Room is minuscule.
In order to enhance fire detection capabilities, an area wide detection system will be installed in the corridor.
- 4)
Suppression in the control room consists of a portable suppression system and hose station.
- 5)
The control room area~ are col'lstantly manned as_suring
. qui'ck*. response. ~o a_oy* f_ire* iri *th-a~ -are~.,*
- 6)
The Salem Unit No. 1 has been des~gned to permit an orderly shutdown independent of the control room.
Alternate shutdown procedures have been developed and are in place for plant operation personnel use.
Additional fire detectors and wire mesh glass on the control room wall will be installed within 6 months of NRC approval.
Due to the twelve feet wide corridor in between the two control rooms, upgraded detection and existing suppression system, wire mesh glass in the separating walls, it is PSE&G's position that for all practical purposes, fire in a control room will not affect the habitability of the other control room.
Auxilary Building, Elevation 122', Peripheral Rooms (50-272/83-37-09)
Subsequent to above exemption request approval the detection system in the peripheral roo~s will be expanded to include the shift supervisors' office, corridor
~urrounding the control rooms, janitors equipment room and the women's rest room.
Some of the walls in-between the control room and the peripheral rooms consist of the back of the cabinets and can not be replaced with one hour rateo walls.
The adoitional detectors (provided in lieu of one hour walls) will alarm the control room
- --~--
l
Auxilfi (50-2
.j;r 4/5/84
- &utldin, Elevation 122', Peri heral Rooms 3-37-09) (Continued) personnel" in case of a fire* in these peripheral rooms.
In the extremely unlikely event of peripheral room fire spreading into the control room, the alternate shutdown procedures will be utilized to bring the plant to safe shutdown condition.
Alternate Shutdown Procedure - Diesel Generator Control circuits (50-272/83-37-10)
The Diesel Generator control circuitry will be modified in order to provide for a quick start.
The control transfer switches will be installed for Emergency Diesel Generator operation.
These switches will bypass the control and relay rooms so that startup and control could be performed locally.* This change is presently scheduled to be installed during the Sixth Refueling Outage.
Alternate Shutdown Procedure - Reactor Hot Leg (Th) and
. :*... _,_.. ::**.. ':~:-~*~~~~~~Ja.~!.~-~~i~~-P~~-~tu~~, ~:-~t_r~m~n~~~:~~n..
The reactor Th and Tc indications will* be modified to assure availability without repairs from the *remote shutdown panel.
This modification will be installed during the Sixth Refueling Outage.
Potential S~curity Door Access Problem (50-272/83-37-12)
The Security Department will maintain the necessary keys in the hot shutdown panel on the al tenate shutdown panel key rings and also in the Central Alarm Station.
Administrati.ve controls pertaining to the keys is appl ieperat:*ion: *Thes~"revis*ions to the procedures will be.finalized before the.end of the present Unit No. 1 Outage.
Surveillance for Repair Material (50-272/83-37-15)
Surveillance procedure will be developed to ensure complete inventory of the repair materials and necessary tools for alternate shutdown near the hot shutdown panel area.
This procedure will be implemented by June 30, 1984.
Requalification of Fire Doors Mofified for Security Features (50-272/83-37-16)
Various minor fire door modifications have been performed for security purposes.
The modifications resulted in the addition of a cross-bar for locking purposed and an electrical detection system for door opening status indications.
We are presently persuing this generic issue with the fire door manufacturer.
We will have all modified fire doors reviewed by the rating agency (U.L.)
for requalification purposes.
Upon completion of the inspection programs, the affected doors will either be replaced or modified to restore the original rating.
.. 4/5/84 Impact of Recent Testing on 3M Fire Barrier Materials used in the Plant (50-272/83-37-17) 3M, by a letter dated February 15, 1984, informed us that the test conducted at UL on December 22, 1982, was not representative of Salem system.
A copy of this letter is attached.
Open End on Wrapped Cable Trays (50-272/83-37-18)
The sealing of -the open ends of fire wrapped cable trays is not a viable generic practice for the Salem Generating Station.
This practice would eliminate any potential natural air circulation or any possible convective heat transfer from the cables to the outside ambient.
This decrease in heat transfer would result in an increase in cable temperature, thereby, affecting the performance of the cables in an adverse manner.
Moreover the horizontal IEEE 383 qualified cables will burn, but will not support combustion. Therefore,.fire will not propagate along the hor.izontal cable tray once the fire source is removed.
- .T~is c:r.ite_ria was r_eyiewed
"-nc;i.*app~oved by th~ NRC,-l:et_te.r*.
gated.May l 1*;**l98:L. *
(..
1 o.p.rtment/3M 3M Center St. Paul, Minnesota 551 ~
6121733 1110 February 15, 1984 Mr. Bill Pavincich Public Service Electric & Gas Co.
80 Park Plaza, T21B Newark, NJ 07101
Dear Bill:
I understand that in the NRC audit of Unit #1 a question was raised regarding the applicability of information derived from a U.L. test conducted in December of 1982 to the material installed at the Salem site.
3M feels that the test conducted at U.L. on December 22, 1982 was not representative of the Salem system for the following reasons:
l~. The.. ASn!' Ei.f9.. *'tiille./t:emp~ra.ture curves *were: ~at :_~o"11o~~a~-...
._and actually *exceeded those specified by.Asni Eli.9.
- 2.
A generic cable, not of the type approved at Salem, was used in the U.L. test.
- 3.
Tiie attachment methods for the materials tested at U.L. are different from those which were installed at Salem, as are the weights and therefore thermal masses of the metal backings.
- 4.
Comparative in-house testing of the Sal.em system vs. the ceramic fiber wrap system (Kaowool, which has NRC acceptance) demonstrates equivalency between the two systems.
S.
Tiie U.L. test was a generic test including many different cable protection devices vs. the site specific in-house testing which was done for Salem.
Tiius it is 3M's position that information derived from the U.L.
test should not be used to evaluate the performance of the system installed at Salem.
Enclosed is a comparison of the Salem system to the systems tested at U.L.
3M would be glad to share with PSE&G and/or with the NRC the results of the U.L. test.
v~/:,,
-~~~.f k-?---
T. E. Sheehan Market Manager Enclosure
l Internal Correspondence
~-;*:~~ /*'<~ p. a.-. *rieming~
e S. a. Forshay, 225-4N-07 A. J. Marlor J. R. Tuzinski, 260-SA-Ol To:
From:
Date:
R. R. LICHT (3-7079)
- 207-15-11 Comparf son of Salem System to Systems Tested at U.L.
February 16, 1984 3M SYSTEMS I. SALEM A.
Materials
'l.**. 3M.Materials:
3M Brand Fire Barrier Sheet FS-1q5 3M Brand F1 re Barri er Wrap* FS-195 3M Brand Fire Rarrier Caulk CP-25 3M Rrand Fire Rarrfer Putty 303
- 2.
Other Material
- Restraining wire 20 gauge galvinized sheet steel
- 3.
Cables Salem s;te Cables A.
Construction
- 1. Cable Trays = Rox with 20 gauge steel sheet a Cover Rox with FS-195, overlap design
= O~erwrap with restraining wire a Cover all edges and seams with wrap FS-195 a Cover all wrap with restraining mesh
. ~
J
T. E. SHEEHAN February 16, 1984
- 2. Conduit and Air Drop C. Testfng Wrap system using 3H Brand Fire Rarrier Wrap FS-195. *
- Facility - in-house - comparative test to Ceramic Fiber System. Test Report:
October 31, 1980.
II. U.L. Fire Test A.
r-taterials.
- 1.
3M Materials 3M Brand Fire Barrier Composite Sheet CS-195
.3M ~ra~d F~ re.. R.arri er ~a.t. M20A... *.
- 3M' Rrand '.Ff re: Rarr.i e.r Caul lc.CP,-2*5
- 3M ~rand*Fire.~afrier Putty 3b3 3M Rrand Fi re a*arri er Cord 3
- 2.
Other Materials Unistrut Rox Frame Steel Rands 5/8"
- 3.
Cables XLPE/PVC generic cable 300 MCM, 7/C 12 awg, 2/C 16 awg R.
Construction
~-----
- 1.
Cable Trays a)
Ro~ cable tray with Unistrut frame b)
Attach CS-lq5 to frame c)
Cover all seams and corners with Mat M20A.
d)
Cover all Mat with 1/2" wire c16th e)
Steel band System with 5/8" banding
~.
)...
- ~---.
. t. E. SHEEHA.."1 February 16, 01984
- 2. Air Drops and Conduit a)
Wrap System using Mat M20A C.
Testing*
. R. R. Licht RRL:ha Facility -
U. L. Full-Scale Fire Test Unlt Note:
- 1)
E-119 exceeded in thls test.
- 2) 2/C 16 awg cable main failure due to shrinkage of cable due to heat (polyester filler caused 20%
shrinkage).
...