ML18139A974
| ML18139A974 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 11/24/1980 |
| From: | Eisenhut D Office of Nuclear Reactor Regulation |
| To: | VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| References | |
| NUDOCS 8101130717 | |
| Download: ML18139A974 (8) | |
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UNITED STATES' NUCLEAR REGULATORY COMMISSION -
WASHINGTON, 0, C. 20555 Dock et :;o.
Plant 'ia::ie:
50-280/281 Surry l and 2 November 24, i980
- TO ALL POWER REACTOR LICENSEES WITH PLANTS LICENSED PRIOR TO JANUARY 1, 1979
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The*Conmission published on November 19, 1980 (45 FR 76602), a revised
.Section 10 CFR 50.48.and a new Appendix R to 10 CFR 50 regarding fire prctection features of nuclear power plants. The revised Section 50.48 anc.!-.ppendixR will become effective February 17, 1981, which is 90 days af:er publication.
-A copy of the Federal-Register Notice is enclosed (Er.closure l).
The provisions of Appendix R that are applicable to the fire prote~tion fec.::.:res of your facility.can be divided into two categories. The first ca:egory consists of those provisions of the Appendix that are required to be backfit in -their entirety by the new rule, regardless of whether or not alternatives to the specific requirements of these Sections have been*
previously approved 'by the NRC staff. These requirements are set forth in Sections III.G~ Fire Protection of Safe Shutdown Capability; III-J, Emergency L igtiting; and III-0, Oil Collection Systems for Reactor Coolant Puf!':?.
The fire protection features of your facility must satisfy the specific requirements of these three Secti ans by the dates established by ~aragraph 50.48(c), unless an exemption from the Appendix R requirements is a;proved by the Commission.
You should note the provisions for tolling the time for completing the modifications required by these three Sections of.A.ppendi_x R set forth in Paragraph 50.48(c)(6).
The second category of Appendix R provisions app 1 i cable to the fire protection features of your facility consists of requirements concerning the 11open 11 items of previous NRC staff fire protection reviews of ycur facility.
An open item is defined as a fire protection feature that has not been previously approved-by the NRC staff as satisfying the provisions of Appendix A to Branch Technical Position BTP PCSB 9.5-1, as reflected in a staff fire protection safety evaluation report. The fire protection features of your facility that are in this category must satisfy the specific requirements of Appendix R by the dates established-by Paragraph 50.48{c), unless an exemp-t i en f ram the Appendix R requirements on those features is approved by the Conni ssion. is a summary listing of the open items concerning the fire protection features of your facility based on a review of our records.
Also incl~ded is our position on the specific requirements that 111.lSt be satisfied in order to resolve these open items. If you have any questions or disagree-rne~:s with this enclosure, please advise us within 30 days. of your receipt of th~s ietter.
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- 2 With regard to the fire protection modifications that have Deen previously approved by the NRC staff, Par*agraph S0.48(d) specifies anew schedule for their con;iletion.
This paragraph, when it becomes effect~ve, will supersede the currently effective section of the regulations that temporarily suspends CO!Tl)letion dates for previously approved fire protection r.-odifications that are given. in facility license conditions (45 FR 71569, October 29, 1980).
The Conmission expects that all such modifications will be completed in accordance with this new schedule, unless an extension has been requested and granted by the Director of the Office of Nuclear Reactor Regulation
[see Paragraph S0.48(d)], or an exe~tion has been requested and granted by the Coirmission pursuant to Section 50.12 of the Conmission's regulations.
If you have previously requested extensions of* dates for completion of modifications that are required by license conditions for your facility which were not approved, and you have determined that these extensions are still necessary and justifiable, it will be necessary for you to reapply for any such extensions in accordance with the provisions of Paragraph 50.48(d}.
All requests for Corrmission action resulting from this rule are subject to the.schedule of fees specified in 10 CFR 170.21.
If you have any q~estions*concerning the subject matters of this letter, please contact the NRC Project Ma*nager _for your facility.
Enclosures:
- 1.
Notice - Fire Protection Rule
- 2.
Summary of Staff Require-ments to Resolve Open Items cc w/enclosures:
See next page Sincerely,
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I f' Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation
SUMMARY
OF STAFF REQUIREMENTS TO RESOLVE' OPEN ITEMS SURRY POWER STATION UNITS 1 AND 2 Sections 3.1.4, 3.1.5, 3.1.10(2), 3.1.23, 3.1.25(1), 3.1.26(3), 3.2.3 and Safe Shutdown In the Surry Fire Protection SER the concern* was that fires in many areas of the plant could damage redundant safety related systems.
The licensee has not responded 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 licensee 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 comb~stibles in any area of the plant.
All areas which contain redundant safe shutdown systems which are not separated by 3-hour fire-rated barriers should 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 allow for possible thermal lag failure of the suppression system in those areas where the reaundant 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 redundant systems should be provided.
The barrier should protect the circuit integrity/equipment availa.bility of that system for one hour under fire conditions. 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 shut-down 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 Appendix R.
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 switchgear rooms and between the switchgear room and the relay room.
The licensee has not responded to this concern.
To meet the requirements of Section III.M of Appendix R to 10 CFR 50, the licensee should close the openings between these rooms with 3-hour fire-rated penetrations seals which have been tested in accordance with ASTM E-119, including the passage of cable through the seal.
e 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 because alarms are not provided in the control room to alert the operators to a low pressure condition in the pilot bottle 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 monitoring device for the high piessure co2 systems pilot bottles such as providing an alarm in the con-trol room to signal an inadequate pressurization condition.
Section 3.1.16(3), Gas Suppression Systems In the Surry Fire Protection SER the concern was that the CO2 systems provided in the 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 tota 1 flooding systems.
Secti.on 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 all 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 in 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 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 with a maximum of 100 feet of liose at eacli statton.
Since th.e licensee's response did not address the concern for all areas of the pl ant, we conclude that the present 1 evel of protectfon provided by the manual hose stations is unacceptafil e.
To meet the guidelines of Section E.3(dl of Appendix A to BTP 9,5-1, and Section III.D of Appendix R to 10 CFR 50, th.e 1 icensee 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.
e 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 con-cern.
To meet the requirements of Section III.M of Appendix R to 10 CFR 50, the licensee should upgrade all unsealed or inadequately sealed penetra-tion openings 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 3-hour rating exclusive of the penetrations, appropriate penetration seals should be provided to maintain the barrier fire rating. Particular areas of concern include:
(a)
The bounda.ry surrounding the outside containment penetration vaults; cable tuRnels and service building cable vaults; and each battery room.
(b)
The control room complex barriers (including floo~ and ceilings).
(c)
Between the auxiliary building, elevation 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 cof!nection 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 requirements simultaneously.
In addition, utilizing the fire water system for service. water is not in accordance with Section E.2.(a) of Appendix A to BTP 9.5-1.
e To meet the requirements of Section II.A and III.G of the proposed Appendix R to 10 CFR Part 50, the licensee should provide for alternate shutdown independent 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 shutdown..
(See require-ment for SER Section 3.1.10(2).)
The licensee submitted additional information by letter dated October 29, 1980 which is still under review.
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 auxi1i:a,~y 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.
Section 3.1.26(2), Water Suppression Systems In the Surry Fire Protection SER the concern was that the automatic sprinkler 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 walkways and not presently equipped 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 pumps.
The licensee has.not responded to this concern.
The licensee should provide the following changes to their Technical Specifications.
(l) Charging Aumps - The licensee should provide 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.
e 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 perform in-situ smoke 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, therefore, 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 should 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.
I UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 November 25, 1980 TO ALL POWER REACTOR LICENSEES WITH PLANTS LICENSED PRIOR TO JANUARY 1, 1979 The Federal Register Notice enclosed with my letter dated November 24, 1980 has a typographical error in the effective date.
The effective date should be February 17, 1981.
A correction will be published in the Federal Register in the near future.
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-\\. '\\.l(b Ct Darrell G. Eis.enhut. Director
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Division of Licensing
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