ML18139A813
| ML18139A813 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 10/09/1980 |
| From: | Varga S Office of Nuclear Reactor Regulation |
| To: | Ferguson J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| References | |
| NUDOCS 8011130154 | |
| Download: ML18139A813 (12) | |
Text
i, Docket Nos.* 50-280 and 50-281 Mr. J. H. Fetguson Executive Vice President - Power Virginia Electric and Power Company Post Office Box 26666 Richmond, Vfrginia 23261
Dear Mr. Ferguson:
October 9, 1 980
- Distri'6ution -~-*.
.. Docket File so:..2so and NRG PDRs ( 2)
. Local PDR
'*TERA NSIC
- NRR-Reading ORB1 Reading D. Ei senhut
- T. Novak S. Varga W. Ross T. Wambach C. Parrish J. Roe J. Heltemes I&E (5) -
Attorney, OELD On May 29, 1980, the Comnission published a proposed rule, a new paragraph 50.48 and ft,ppenclix R to 10 CFR Part 50, concerning fire protection, which sets forth the minimum acceptable fire protection requirements necessary to resolve contested areas of concern for nuclear power plants operating prior to_January l, 1979.
We have reviewed alr the information You have provided to date regarding your fire* protection program.
Several of the open items. indicated in our Safety Evaluation Report issued September 19, 1979 remain unresolved. presents our position on modifications that would have to be made at your facility to resolve these. open items!) in a manner that would meet the requirements of the proposed Appendix R~ presents our evaluation of items 3.1.1103), 3.1.. 18(5) and 3.l.18(16) which we find acceptable. Enclosure 3 is a tabulation showing the status of the Surry fire 1n*otection program.*
Enclosures*:
As Stated cc: w/enclosures See next page
. Si nee rely,
. Steven A. Varga, Chief Operating Reactors Branch #1 Division of Licensing NRC FORM 318 (9-76) NRCM 0240
-1'.:ru.s. GOVERNMENT PRINTING OFFICE: 1979-289-369
e e
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 Octa ber 9, l 980 Docket Nos. 50-280 and 50-281 Mr. J. H. Ferguson Executive Vice President - Power Vi rgi ni a Electric and Power Company Post Office Box 26666 Ri~hmond, Virginia 23261
Dear Mr. Ferguson:
On May 29, 1980, the. Co1T111ission published a proposed rule, a new paragraph 50.48 and Appendix R to 10 CFR *Part 50, concerning fire protection, which sets forth the minimum acceptable fire protection requirements necessary to resolve contested areas of concern for nuclear power plants operating prior to January 1, 1979.
We have reviewed a 11 the information you have provided to date regarding
- your fire protection program.
Several of the open items indicated. in our.
Safety Evaluation Report issued September 19, 1979 remain unresolved.
Enclosure l presents our position on modifications that would have to be made at your facility to resolve these open items,.in a.manner that would il1eet the requirements of the proposed Appendix R *. presents our evaluation of items 3.1.11(13); 3.1.18(5) and 3.1.18(16) whi~h we find acceptable. is a tabulation showing the status of the Surry fire protection program *.
Enclosures:
As Stated cc:
w/enclosures See next page Sincerely,
~arga *t
'Operating Reacto. Branch #1 Division of Licensing
Mr. J. H. Ferguson
. Virgi ni a Electric and Power Company cc:
Mr. Michael w. Maupin Hunton and Williams Post Offi~e Box 1535 Richmond, Virginia 23213 Mr. J. L. Wilson, Manager P. O. Box 315 Surry, Virginia 23883 Swem Library College of William and Mary Hi 11 i ams burg, Vi rgi ni a 23185 Donald J. Burke, Resident Inspector Surry Power Station
- u. s. Nuclear Regulatory Corrmission Post Office Box 959 Williamsburg, Vi'rginia 23185 e
October 9, 1'980
SURRY POWER STATION, UNITS 1 AND 2
SUMMARY
OF STAFF REQUIREMENTS TO RESOLVE OPEN ITEMS Sections 3.1.4 3.1.5 3.1.10 2
- 3. 1.25 1 3.2.3, and 3.2.4, Safe e
- 3. 1.26(3, 3.1.29 In the Surry Fire Protection SER the concern was that fires in many areas of the plant could damage reduodant safety related systems.
The licensee has not respond~d to this concern.
In order to meet the requirements of Section II.A and III.G of the proposed Appendix R to 10 CFR Part 50, the Jicensee will.be required to show that adequate consideration has been given to preserving the operability of one division of safety-related systems required to achieve and maintain safe cold shutdown conditions given a fire in permanent or transient combustibles in any area of the plant.
All areas which contain redundant safe shutdown systems which are not separ-ated by 3-hour fire-rated barriers sbould be provided with an automatic, wet-pipe sprinkler system designed to cover the entire area as well as an early warning smoke detection.system.
In addition, to a1low for possible thermal lag failure of the suppression system in those areas where the redundant systems are separated by less than 20 feet of clear, open air space, an ASTM E-119 rated fire barrier which will completely enclose one of the redun-dant systems should be provided.
The barrier should protect the circuit integrity/equipment availability of that system for one hour under fire con-ditions.
Where safe shutdown capability cannot be assured.by barriers, suppression and detection systems, the licensee should provide an alternate shutdown system.
- At Surry this includes areas such as the control room, cable spreading room, emergency switchgear and relay rooms, the containment penetration areas, cable tunnels and service building cable vaults and mechanical equipment room number 3. The alternate shutdown system should be completely independent of the area for which it is being provided such that a fire in either area which damages redundant systems will not affect the
- shutdown capability from the other area.
Such a system should comply with Section III.L of the proposed Appendix R.
Section 3. 1.q, Fire Detection Systems In the Surry Fire Protection SER the conc~rn was that the lack of early warriihg fire detection systems would allow fires to become fully developed 2.nd cause damage to safety-re lated systems.
The 1 i censee has not r*esponded to this concern.
To meet the requirements of Section II.A of the proposed Appendix R to 10 CFR Part 50, the licensee should install additional early warning fire detection in the following areas:
(1)
Areas of the control room complex adjacent to the main control room.
(2)
In the vertical boards located in the main control room and at the ceiling of the main control room near the air fla.v return.
e
- (3)
Ventilation exhaust ducts of each battery room.
(4)
The auxiliary building general area exhaust ventilation ducts.
(5)
The ceiling of the spent fuel pool pump area.
(6)
At the ceiling of the 19 feet 6 inches elevation of the safeguards equipment building.
(7)
The emergency switchgear room and the relay rooms of each unit.
(8)
The solid waste drumming room.
(9) The ventilation exhaust ducts from the containment spray pump and auxiliary feedwater pump building.
(10) The containment recirculation ventilation system and in the cable penetration areas inside containment.
(11) Ventilation exhaust system of mechanical equipment room #3.
(12) The_charging pump exhaust ventilation ducts of the.auxiliary building, elevation 13 feet.
(13)
Both fire pump rooms.
Section 3.1.10(1), Fire Barriers In the Surry Fire Protection SER the concern was that a fire could propagate from one fire area to another through the open passageways between the switch-gear rooms and between the switchgear room and the relay room.
The licensee has not responded to this concern.
To meet the guidelines of Section F.5 of Appendix A to BTP 9.5-1, the licensee should close the openings between these rooms v1ith 3-hour fire-rated penetra-tions seals which have been tested in accordance with ASTM E-119, including the passage of cable through the seal.
Section 3. 1. 16(2), Gas Suppression Systems In the Surry Fire Protection SER the concern was that_the high pressure carbon dioxide systems could fail becasue alarms are not provided in the control room to alert the operators to a lov1 pressure condition in the pilot bot\\le for the system.
The licensee has not responded to this concern.
To meet the requirements of NFPA 12 and Section E.5 of Appendix A to BTP-9.5-1, the licensee should provide a monjtoring device for the high pressure CO2 systems pilot bottles such as providing an alarm in the control room to signal an inadequate pressurization condition.
e*
e Section 3.1.16(3), Gas Suppression Systems In the Surry Fire Protection SER the concern was that the CO2 systems pr_ovided in tbe outside containment cable penetration vaults did not. provide total area coverage.
The licensee has not responded to this concern.
To meet the requirements of NFPA 12 and Section E.5 of Appendix A to BTP 9.5-1, the licensee should provide additional nozzles for the CO2 total flooding systems.
Section 3.1.18(1), (3), (7), and (8), Hose Stations In the Surry Fire Protection SER the concern was_that the number and location of manual hose stations is not sufficient to provide an effective hose stream to a 11 rooms and areas of the plant.
By letter dated June 30, 1980, the licensee provided a description of four new hose stations which have been installed in the Units 1 and 2 turbine buildings.
Further, the licensee stated that additional_hose is presently being installed io the turbine building hose racks, and verification that all areas defined above can be reached by fire hoses will be reported at a later date.
We find that, even though four new hose_stations are being provided in the turbine building, the licensee has not verified that all areas of the plant are covered with effective manual hose stream capability from the interior standpipe system v1ith a maximum of 100 feet of hose at each station. Since the licensee's response did not_address the concern for all*areas of the plant, we conclude that the present level of protection provided by the manual hos~
stations is unacceptable.
To meet the guidelines of Section E.3(d) of Appendix A to BTP 9.5-1, the licensee should_ install standpipe and hose station throughout the plant so
. that.an effective hose stream can reach all areas of the plant with a maximum of 100 feet of hose at each station.
Section 3. 1.24, Penetrations In the Surry Fire Protection SER the concern was that the penetration seals provided at Surry are not adequate to prevent a fire in one area from pro-pagating to adjacent areas. The licensee has not responded to this concern.
To meet the requirements of Section D.l(j) of Appendix A to BTP 9.5-1, the licensee should upgrade all unsealed or inadequately sealed penetration open-ings to provide a 3-hour ASTM E-119 fire rated penetration seal where the fire rating of the barrier penetrated would be 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.
For those barriers with less than a 3-hour rating exclusive of the penetrations, appropriate penetra-tion seals should be provided to-maintain the b~rrier fire rating.
Particular areas of concern include:
e*
e (a)
The boundary surroundjng the outside containment penetration vaults; cable tunnels and service building.cable vaults; and each battery room.
(b)
The control room complex barriers (including floor and ceilings).
(c)
Between the auxiliary building, elevations 13 feet and 27 feet, 6 inches, and other fire areas.
(d)
Between the auxiliary building, elevation 45 feet, 10 inches, and the fuel building.
(e)
The wall between the safeguards equipment building and the containment spray pump and auxiliary feedwater. pump building.
(f)
The walls of the mechanical equipment room #3.
(g)
Penetrations in barriers in the cable tray room should be sealed to provide a three-hour resistance to fire.
Section 3. 1.25(2) _Safe Shutdown In the Surry Fire Protection SER the concern,was that fires in several areas could render the charging pump service water system for either unit inoperable.
By letter dated June 30, 1980, the licensee indicated that a cross ~onnection would be provided between the fire water system and the charging pump service water system so that the fire pumps could be used as a backup to the charging pumps in the event of a loss of all charging pump service water pumps.
We find that the licensee's proposal is unacceptable.
The.licensee has not considered if the fire pumps have adequate capacity to provide both fire fighting water demand and charging pump requiremeots simultaneously~
In addition, utilizing the fire water system for service water is not in accord-
. ance with Section E.2.(a) of Appendix A to BTP 9.5-1.
To meet the requirements of Sect~on II.A aod III.G of the proposed Appendix R to 10 CFR Part 50, the licensee should provide for alternate shutdown inde-pendent of mechanical equipment room number 3 so that.a fire which damages all systems in that room, including the charging pump service water system, will not adversely affect safe plant shutdm*:n.
(See requirement for SER Section 3.1.10(2)).
Section 3.1.26(1), Water* Suppression Systems In the Surry Fire Protection SER the concern was that a gaseous *suppression system would not be capable of suppressing a deep-seated charcoal filter fire in the auxiliary building ventilation system charcoal filters.
The licensee has not responded to this' concern.
To provide adequate.suppression capability for the charcoal filters, the licensee should provide an automatic sprinkler system for each new* filter unit added to the auxiliary building ventilation system.
Settion 3.1.26(2), Water Suppression Systems In the Surry Fire Protection SER the concern was that the automatic sprin installed under grating walkways would not operate unless they were equipped with heat collector plates. The licensee has not responded to this concern.
To assure that the automatic sprinklers in such locations will operate in a timely manner, the licensee should provide heat collector plates over the sprinkler heads in the turbine building which are installed under grating v1alk11ays and not presently equippped with special heat collector deflectors.
Section 3. 1.30, Technical Specifications In the Surry Fire Protection SER the concern was that the Surry Technical Specifications did not provide for adequate minimum operating conditions for safe shutdown capability for the charging pumps and the auxiliary feedwater pu~ps.
The licensee has not responded to this concern regarding charging pumps.
The licensee should provide the follov;ing changes to their technical speci-fications.
(1)
Charging Pumps - The licensee should propose a technical specification that will.require that at least one charging pump from the opposite unit must be available at all times during operation of either unit.
Section 3.2. 1, Auxiliary Boiler.Room In the Surry Fire Protection SER the concern was that fuel oil leakage in the auxiliary boiler room could spread to other plant areas via the floor
~rain system.
The licensee has not ~esponded to this concern.
To meet the requirements of Section J. 1.(f) of Appendix A to BTP 9.5-1, the licensee should modify the drain system from the auxiliary boiler room so that a fuel oil leakage will not be spread to other plant areas through the floor drain system.
Section 3.2.2, Fire Dampers In*the Surry Fire Protection SER the concern was that a.fire in the turbine building could affect safe-shutdown syste~s located in mechanical equipment ro~m number 3 because of the lack of 3-hour fire ratings for the dampers which seal the duct penetrations of the wall between these areas.
The licensee has not responded to this concern.
- To meet the requirements of Section D. l(j) of Appendix A to BTP 9.5-1, the licensee should provide 3-hour ASTM E-119 fire rated fire door dampers in the duct penetrations of the walls of mechanical equipment room number 3.
Section 3.2.5, In-Situ Testing In the Surry Fire Protection SER the concern was that the smoke detectors might not respond to the products of combustion for the combustibles in the areas where smoke detectors are installed.
We were also concerned that ventilation air flow patterns in the area might reduce or prevent detector response and we recommended that the licensee perform an in-situ smoke detector test. The SER required that the licensee preform in-situ smo:<e detector system tests and bench tests to verify the adequacy of the detectors.
The licensee has not responded to this concern.
The required methodology for an in-situ smoke detector test is beyond the current state-of-the-art and, therfore, an in-situ test cannot be performed at this time.
To adequately address the concerns of the staff and assure that the detection system will provide timely detection of any fires, the licensee sbould conduct bench tests of the detectors to verify that they will be responsive to the products of combustion of combustibles, including transient combustibles, in each area where the detectors are installed.
- ADDITlONAL FIRE -PROTECTION-INFORMATION REVtEw**---
SURRY POWER STATION, UN IT NOS. 1 AND 2 DOCKET NOS. 50-280 AND 50-281 Fire Doors, Section 3.1.11(13)
In the SER the concern was that administrative controls cannot assure closure.
of the.door between the main control room.and the control room annex; thus permitting smoke and other products of combustion from a fire in the control room annex to enter the control room.
By letter dated June 30, 1980, the licensee verified that the door between the main control room and contro1 room annex is a bullet-proof door locked closed with a card reader. In.addition, the 1icensee proposes to modify the louvers in the door so that covers can be manually installed to contro1 smoke.
The louver covers will be stored next to the door.
We find.that the Jicensee's proposal to provide manually attached covers for the louvers in the locked bullet.proof.door between the control room and the control room annex will adequately prevent smoke from entering the control room through the doorway and is, therefore, acceptable.
Hose Stations, Section 3. 1. 18(5)
In the SER the concern was that inadequate hand hose. coverage was provided irt the cable vault in each service building.
By letter dated June 30, 1980, the. licensee proposed to install a dry stand-pipe hose station in each service building cable vault. Tbe base stations
_will be provided with variable flow fog nozzles with ball va1ve shutoffs.
We find that the licensee's proposal to insta11 a standpipe hose station in each service building cab1e vau1t wi11 provide adequate hand hose coverage for the cable vaults and is, therefore, acceptab1e.
Hose Stations 7 Section 3.1.18(16)
In the SER tbe concern was that the present fire water piping configuration does not provide assurance that interior hose.station protection will be available for the auxiliary building in the event of a broken supply main or during maintenance when the single supply line will be shut off.
By letter dated June 30, 1980, the licensee proposed to provide a second feed to the auxiliary building standpipe-system. A blank flange in a 6-inch tee in the Auxiliary Building General Area Exhaust Filter Deluge System supply will be removed_and a 4-inch line will be routed from the tee verti-callyto the 62 ft.*elevation and connect to the 4-inch Auxiliary Building Fire Hose System. The.de]uge system supply is fed* from the turbine building header.
Manual isolation valves will be installed iri the riew pipe run to provide system isolation such that a f ai l.ure in one supply wi 11 not cause a loss of both systems.
We agree with the licensee's conclusion that, with the design, the Auxiliary Building fire hose stations can either supply or be supplied from the_ Unit 1 or Unit 2 Turbine Building fire suppression leader.
- 2 ~
We find that tbe licensee's proposal to install the. cross connection described above will provide a lockup feed for the auxiliary building standpipe hose system and is, therefore, acceptable.
ITEM
- 3. 1.2
- 3. 1. 3 3.1.11(13) 3.1.15.(1)(2)(3;}.
3.1.15(4) 3.1. 18(~)
- 3. 1.18(6) 3.1. 18(16)
- 3. 1. 22
- 3. 1.27
- 3. 1. 4
- 3. 1. 5
- 3. 1. 9
- 3. 1. 10
- 3. 1. 16
- 3. 1.23
- 3. 1.24 3.1.25(1)
- 3. 1. 26
- 3.1.29
- 3. 1. 30 3.2. 1 3.2.2 3.2.3 3.2.4 3.2.5 3.1. 18(1)(3)(7)(8)
- 3. 1.25(2)
- c - Closed ENCLOSURE 3 FIRE PROTECTION REVIEW STATUS SURRY POWER STATION, UNITS 1 AND 2 DOCKET NOS. 50-280 ANO 50-281 DESCRIPTION Air Flow Detectors Breathing Apparatus Fire Doors Floor Drains,. Dikes and Curbs Oil Collection Syst,m Hose Stations - Service Bldg.
Hose Stations - Containment Bldg.
Hose Stations - Aux. Bldg.
Valve Supervision Ventilation System Cable Tray Covers
. Safe Shutdown Circuitry Fire Detection Systems Fire Barriers Gas Suppression Monitoring Panels Penetrations Safe Shutdown Water Suppression Systems Water Spray Shields Technical Specifications Auxiliary Boiler Room Fire Dampers*
Safe Shutdown Charcoal Filter Hazard In-Situ Testing Hose Stations Safe Shutdown I - No information from licensee R - Requirement STATUS*
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C C
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