ML18092A289

Forwards Summary Reflecting Util Understanding of 840919 Meeting W/Nrc in Bethesda,Md Re Compliance w/10CFR50,App R Concerning Fire Protection.Concurrence Requested

ML18092A289
Person / Time
Site:	Salem
Issue date:	09/24/1984
From:	Liden E Public Service Enterprise Group
To:	Varga S Office of Nuclear Reactor Regulation
References
NUDOCS 8410020186
Download: ML18092A289 (8)

Text

Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038 Nuclear Department September 24, 1984 U. S. Nuclear Regulatory Commission Off ice of Nuclear Reactor Regulation Division of Licensing Washington, D. c. 20555 Attention: Mr. Steven A. Varga, Chief Operating Reactors Branch, No. 1

Dear Mr. Varga:

NOTES OF MEETING ON FIRE PROTECTION SALEM GENERATING STATION UNITS *NO. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 A meeting was held with the NRC on September 19, 1984, at the Maryland National Bank Building to discuss PSE&G's compliance with Appendix R to 10CFR50. Attached for your information is a copy of the notes taken at this meeting. These notes reflect our understanding of the discussions that took place.

We would appreciate your concurrence with regard to the accuracy of these notes.

Should you have any questions, please contact us. A prompt reply would be appreciated.

Sincerely, E. A. Liden Manager - Nuclear Licensing and Regulation Attachment The Energy People 95-2168 (25M) 6-84

Mr. Steven A. Varga 9/24/84 C Mr. Donald c. Fischer Licensing Project Manager Mr. James Linville Sr. Resident Inspector

ATTACHMENT The purpose of the meeting was to seek resolution of all fire protection open items and assurance from the NRC regarding the acceptability of PSE&G's approach. The major difficulty that PSE&G encountered was the perceived conflict between the interpretation of the fire protection rules during 1979 - 1981 time frame (pre and post Appendix R issuance) and the issuance of Generic Letter 83-33 "NRC Positions on Certain Requirements of Appendix R to 10CFR50".

It was explained by the NRC that a steering committee is presently reviewing the interpretation of Generic Letter 83-33. Their recommendation will be submitted to the Commission during October 1984. Based on this recommendation the Commission will issue, during November 1984, the NRC's position on interpretation of this generic letter.

The following details direction provided by the NRC along with PSE&G's commitment for acceptable resolution of open items and exemption requests:

1) Unrated Oversized and Watertight Doors/Doors with Security Modifications:

For the unrated watertight doors in the intake structure service water pump MCC area, the NRC will accept the exemption request (reference PSE&G's January 31, 1984 letter) based on the existing fire protection features and low fire load in the area.

The unrated oversized doors and doors with security modifications in the Auxiliary Building are presently being evaluated by UL and will be upgraded as needed.

2) Charging Pump Area:

The NRC will accept the wet pipe sprinkler system and grant the exemption request on separation distance of the charging pumps based on the expanded suppression system in the charging pump area. PSE&G will modify the splash shields on the charging pump motors to prevent suppression water from impinging upon the pump motors.

3) Upper Electrical Penetration Area:

It was explained by PSE&G that this area contains no vital equipment that would be needed for safe shutdown during a fire*. PSE&G will clarify the exemption request in a follow-up letter.

• Subsequent to the meeting, it was identified that source range flux monitor cables are located in this area, one train of which is completely wrapped wall to wall.

>-. . ~

4) Auxiliary Feed Water Pump Area:

PSE&G explained that the auxiliary feed water turbine trip and stop valves for the steam driven auxiliary feed water pump is the only shutdown equipment installed in panel 207. These valves fail in the safe position upon loss of power. A hot short to the DC power cable, however, could render the valve closed. PSE&G will install measures to prevent a hot short, thereby ensuring that a spurious signal will not prevent operation of the steam driven auxiliary feed water pump. The NRC (Mr. T. Wambach) noted that this position was found acceptable on Waterford. The NRC (Mr. J. Stang) indicated that the fire wraps on panels 207 and 213 were not needed and could be removed.

The auxiliary feed water pump area sprinkler system is acceptable to the NRC provided it meets NFPA 13 or 15 Code. PSE&G submittal will address this.

The NRC will also accept the existing partial height concrete walls and 3/16" steel plate surrounding the steam driven auxiliary feed water pump as fire barrier based on existing active and passive protection features (redundant suppression system, detectors, fire brigade) and small fire load.

5) Component Cooling Water Pump Area:

PSE&G committed to upgrade the wall separating the two component cooling water pump/heat exchanger cubicles by filling the holes and penetrations. For the ducts penetrating this wall, the NRC suggested investigating a study recently performed by T~xas Utilities justifying duct integrity for one hour during a fire and that fire does not transport through the duct. It was suggested that PSE&G submit similar justification that a fire in one component cooling water cubicle will not propagate through the duct to the other.

6) Control Rooms:

PSE&G clarified that plant procedures require all operating personnel to report to the hot shutdown panel in the event of control room evacuation. Operating personnel of the affected control room are not required to go to the other control room to perform any plant shutdown operation.**

• • Post meeting note: The plant procedure requires the shift supervisor to set up a communication center in the unaffected control room.

The NRC will accept the existing fire protection measure provided in the control room area and grant the requested exemption (PSE&G letter dated April 5, 1984) pending confirmation of the following:

i) Control room area ventilation system does not permit smoke in one control room to propagate to the other control room.

ii) Supervision of control room doors leading to the corridor to provide assurance that the doors will remain closed.

iii) Addition of fire detectors in the control room corridor and peripheral rooms.

7) Openings On Auxiliary Building Stairway Walls:

PSE&G will close openings on Auxiliary Building stairway walls.

8) Equipment Hatches in the Auxiliary Building:

PSE&G will submit to the NRC a description of the redundant equipment (including cable trays) located on both sides of the hatches. PSE&G will investigate the viability of an analysis to show that assuming worst case fire, with hatch open, heat from one level will not propagate through the open hatch to the other level causing another fire. The justification will address walls and barriers that prevent propagation of fire and will not be based on fire size only.

The NRC (Mr. J. Stang) stressed that water curtains (side wall coverage) on the hatches is acceptable in lieu of the above analysis.

9) 460 Volt Switchgear Room:

It was explained by PSE&G that power cables to the switchgear and power feed cables for valve operation enter and exit from the bottom of the switchgear. Control cables exit at the top of the switchgear. However, all necessary cables at the top are provided with alternate shutdown capability. A written justification for adequate fire protection acceptable to the NRC must include the following:

i) commitment to extend the existing automatic halon suppression system in the relay room to the 460 V switchgear room;

ii) partial height barriers will prevent a floor based fire from damaging redundant floor mounted equipment until the automatic halon suppression system actuates; iii) alternate shutdown capability is provided for ceiling mounted shutdown cable trays; and iv) the cables used are qualified to IEEE standard 383, therefore fire will not propagate across the partial height barriers protecting the floor mounted equipment. This will allow ample time to actuate the proposed automatic halon suppression system and initiate backup action of the fire brigade thereby assuring protection of the floor mounted equipment.

10) Cable Wrap:

The NRC was looking for cable wrap to provide 1-hour protection against exposure fires and propagation of fires for specific applications; e.g., open ended cable tray wraps, air drops from trays, and cables propagating fire from floor mounted equipment and into the trays. The NRC (Mr. J. Stang) initially questioned the acceptability of FS-195 manufactured by 3M Company or any other fire wrap available to the industry. In light of the past NRC acceptance of the 3M cable wrap (R. L. Tedesco - NRC to R. L. Mittl - PSE&G, dated March 18, 1981 and the license condition on Unit No. 2 to wrap certain diesel control cable trays with FS-195 dated August 30, 1984) and PSE&G's concern with regard to the significant expenditures already incurred on tray wrap, the NRC will re-evaluate all information available on the docket and advise PSE&G.

At the end of the discussion, the NRC (Mr. Stang) stated that FS-195 would most likely be found acceptable.

Sprinklers on cable trays in lieu of wrapping is an acceptable resolution to the NRC.

PSE&G was advised to review the NRC response on Kaowool provided at the NRC fire protection workshops for additional guidance.

11) Wall to Wall Cable Tray Wrap and Open Ended Cable Trays:

It was explained that PSE&G's decision not to wrap cable trays wall to wall was based on an assumption that fire does not propagate horizontally in a cable tray (also accepted by the NRC during 1981 plant inspection).

However, the NRC pointed out that as of this date they have not granted any exemptions to the criterion that a large concentration of cables constitutes intervening combustibles.

PSE&G identified areas where cable trays are not wrapped wall to wall. The 4 kv switchgear room being one of these areas, PSE&G agreed to transmit to the NRC the following drawings for the 4 kv switchgear room:

i) drawings showing safe shutdown trays, balance of plant trays and protected trays.

ii) Plan and elevation drawings of 4 kv switchgear room.

For open ended cable trays, PSE&G was advised to investigate closure of the open ends or extending the tray wraps from wall to wall. NRC recognized the concern with r2R losses and cautioned that certain plants have experienced insulation failure.

12) In Containment Analysis:

The NRC's only concern was separation of cables at the panel 335. Active protection provided by a halon bottle located inside the panel would be an acceptable resolution. The NRC will review PSE&G's January 27, 1984 submittal and advise.

ATTENDANCE NAME D. c. Fischer DL/ORB #1 J. Stang DE/CM EB T. Wambach DL/ORB #5

w. Pavincich PSE&G Engineering E. Siegel PSE&G Systems Engineering J. Bailey PSE&G Systems Engineering T. Lupold PSE&G Systems Engineering T. Storey PSE&G Site Protection M. Platt PSE&G Salem Operations

w. Reiber PSE&G Systems Engineering M. Levine PSE&G Systems Engineering L. A. Reiter PSE&G Nuclear Engineering E. A. Li den PSE&G Nuclear Licensing and Regulation M. Banerjee PSE&G Nuclear Licensing and Regulation R. Ferguson DE/CM EB (PT. Time)