ML18193B017

Safety Evaluation on Fire Protection Program

ML18193B017
Person / Time
Site:	Browns Ferry
Issue date:	03/31/1993
From:	Hebdon F Office of Nuclear Reactor Regulation
To:	Medford M Tennessee Valley Authority
Wu A
References
TAC M82687, TAC M82688, TAC M82689
Download: ML18193B017 (14)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION-3rm6FrTYHuckfNrmda t

WASHINGTON. D.C. 20555-0001 March 31, 1993 APRO05 '3 lul Docket Nos. 50-259, 50-260 and 50-296 Tennessee Valley Authority ATTN:

Dr. Mark 0. Medford, Vice President Nuclear Assurance, Licensing and Fuels 3B Lookout Place 1101 Market Street Chattanooga, Tennessee 37402-2801

SUBJECT:

FIRE PROTECTION PROGRAM -

BROWNS FERRY NUCLEAR PLANT UNITS 1, 2 AND 3 (TAC NOS. M82687, M82688 AND M82689)

By letter dated January 15, 1992, the Tennessee Valley Authority (TVA, the licensee) submitted the revised Browns Ferry Nuclear Plant (BFN) -

Fire Protection Report (FPR) for NRC staff review. The BFN-FPR contains:

(1) the "Fire Protection Plan," (2) the "Fire Hazards Analysis," (3) the "Safe Shutdown Analysis," and (4) the "Unit 2 Appendix R Safe Shutdown Program."

TVA requested staff review of the BFN-FPR in order to consolidate the BFN Fire Protection Program into a single document and to remove the fire protection requirements from Technical Specifications (TS) in accordance with the guidelines of NRC Generic Letters (GLs) 86-10 and 88-12. TVA's license amendment request to remove the BFN fire protection TS requirements was submitted by letter dated April 13, 1992, and will be addressed by the staff under separate correspondence.

The staff conducted a site visit on October 14-16, 1992, to discuss and observe salient fire protection features. In addition, several foi'owup telephone conferences were conducted on January 14, 1993, and February 11, 12, 16 and 17, 1993.

Furthermore, a final meeting was also held at NRC Headquarters on March 2, 1993, to discuss outstanding issues.

The staff's safety evaluation (SE) of the BFN-FPR "Fire Protection Plan" and "Fire Hazards Analysis" is enclosed. In this SE the staff did not review the BFN-FPR, "Safe Shutdown Analysis" and "Unit 2 Appendix R Safe Shutdown Program."

Both of these had been previously reviewed and approved by the staff in SEs dated December 8, 1988, November 3, 1989, and March 6, 1991.

TVA's fire protection program, as described by the BFN-FPR, has been reviewed and found acceptable. The only exception being that the staff was unable to confirm BFN conformance with the National Fire Protection Association (NEPA)

Code 30, "Flammable Combustible Liquid Code," and 24, "Outside Protection."

In GL 86-10, TVA was requested to identify and justify NFPA Code Deviations.

By letter dated August 3, 1988, TVA reviewed certain NFPA codes and identified many deviations. These NFPA code deviations were reviewed and accepted by the Tab 006

Dr. Mark 0. Medford staff in its SE dated November 3, 1989. However, TVA may not have adequately addressed all applicable NFPA codes, such as NFPA 24 and NFPA 30.

In the meeting of March 2, 1993, as documented in the meeting summary dated March 5, 1993, TVA committed to revisit these and any other relevant NFPA codes to determine if additional code review and documentation is warranted to assure conformance. This action by TVA to re-look at applicable NFPA Codes is subject to future NRC audit or inspection.

Sincerely, Frederick J. Hebdon, Direlor Project Directorate II-4 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation

Enclosure:

Safety Evaluation cc w/enclosure:

See next page

Tennessee Valley Authority Browns Ferry Nuclear Plant ATTN:

Dr. Mark 0. Medford cc:

Mr. John B. Waters, Chairman State Health Officer Tennessee Valley Authority Alabama Dept. of Public Health ET 12A 434 Monroe Street 400 West Summit Hill Drive Montgomery, Alabama 36130-1701 Knoxville, Tennessee 37902 Mr. J. R. Bynum, Vice President Regional Administrator Nuclear Operations U.S.N.R.C. Region II 38 Lookout Place 101 Marietta Street, N.W.

1101 Market Street Suite 2900 Chattanooga, Tennessee 37402-2801 Atlanta, Georgia 30323 Mr. Charles Patterson Site Licensing Manager Senior Resident Inspector Browns Ferry Nuclear Plant Browns Ferry Nuclear Plant Tennessee Valley Authority U.S.N.R.C.

P.O. Box 2000 Route 12, Box 637 Decatur, Alabama 35602 Athens, Alabama 35611 Mr. 0. J. Zeringue, Vice President Site Quality Manager Browns Ferry Nuclear Plant Browns Ferry Nuclear Plant Tennessee Valley Authority Tennessee Valley Authority P.O. Box 2000 P. 0. Box 2000 Decatur, Alabama 35602 Decatuar, Alabama 35602 Mr. M. J. Burzynski, Manager Nuclear Licensing and Regulatory Affairs 5B Lookout Place Chattanooga, Tennessee 37402-2801 TVA Representative Tennessee Valley Authority 11921 Rockville Pike Suite 402 Rockville, Maryland 20852 General Counsel Tennessee Valley Authority ET 11H 400 West Summit Hill Drive Knoxville, Tennessee 37902 Chairman, Limestone County Commission P.O. Box 188 Athens, Alabama 35611

pJR REGO, UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 ENCLOSURE SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION FIRE PROTECTION PROGRAM BROWNS FERRY UNITS 1. 2 AND 3 DOCKET NOS. 50-259. 50-260. AND 50-296

1.0 INTRODUCTION

Generic Letter (GL) 86-10, dated April 24, 1986, which was approved by the Commission, provided guidance for acceptable methods of satisfying Commission regulatory requirements. The generic letter allowed incorporation of the licensee's (previously approved) fire protection program into the Final Safety Analysis Report (FSAR).

By letter dated January 15, 1992, the licensee submitted the revised Browns Ferry Nuclear Plant Fire Protection Report (BFN-FPR) for NRC review and approval.

The BFN-FPR contains four principal parts: (1) the "Fire Protection Plan," (2) the "Fire Hazards Analysis," (3) the "Safe Shutdown Analysis," and (4) the "Unit 2 Appendix R Safe Shutdown Program."

The staff has already conducted a review of the Unit 2 Appendix R Safe Shutdown Program and Safe Shutdown Analysis as documented in safety evaluations (SE) dated December 8, 1988, November 3, 1989, and March 6, 1991.

The following SE documents the staff's review of the Fire Protection Plan and Fire Hazards Analysis described by the BFN-FPR.

The BFN-FPR establishes the TVA fire protection program for BFN.

The licensee is responsible for meeting the requirements of the Browns Ferry Fire Recovery Plan that was reviewed and approved in the Restart Safety Evaluation Report (SER) for Units 1 and 2 (dated February 23, 1975), and Supplements 8 and 9 (dated July 2, 1976 and August 2, 1976) of the SER for Unit 3. The Safety Evaluation dated August 23, 1988, titled, "Report in Regard to Volume III of the Browns Ferry Nuclear Performance Plan, Chapter 5.0 Fire Protection Improvement" indicated that the licensee committed to replace the Fire Recovery Plan with a new Fire Protection Plan.

As part of its BFN-FPR submittal, the licensee has compared their new Fire Protection Program against Branch Technical Position (BTP) Chemical and Material Engineering Branch (CMEB) 9.5-1, "Guidelines for Fire Protection for Nuclear Power Plants," dated July 1981.

2.0 EVALUATION The staff has reviewed the licensee's fire protection program (i.e., BFN-FPR) for conformance with BTP CMEB 9.5-1, "Guidelines for Fire Protection for Nuclear Power Plants," dated July 1981 (Refer to sections 2.1 to 2.24 below).

2.1 Fire Protection Program The fire protection program is described in the section titled "Fire Protection Plan" of the licensee's submittal dated January 15, 1992. The program establishes policy for the protection of structures and components important to safety. As requested, the licensee provided the staff with a Fire Protection Organizational Chart.

On March 2, 1993, the licensee agreed to incorporate the fire protection organizational chart into the Fire Protection Plan or FSAR as indicated by the BTP CHEB 9.5-1 Section C.1.a.(4).

The staff finds that the format of the fire protection program meets the NRC guidelines of BTP CMEB 9.5-1, Section C.1, and is therefore acceptable.

2.2 Fire Hazard Analysis The licensee submitted a Fire Hazards Analysis as part of its January 1992 submittal.

The staff's evaluation of this fire hazard analysis is contained in the balance of this report. As part of this submittal, the licensee also provided a safe shutdown analysis and safe shutdown program for Unit 2. The staff has previously reviewed and accepted the licensee's Unit 2 safe shutdown program and analysis as mentioned above.

2.3 Alternative Shutdown Alternative shutdown for Unit 2 was previously evaluated in the staff SE dated November 3, 1989.

2.4 Administrative Controls The administrative controls for fire protection consist of the fire protection organization, the fire brigade training, controls for combustibles and ignition source, the pre-fire plans and procedures for fighting fires, and quality assurance. The licensee has implemented the staff supplemental guidance, "Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance" dated June 14, 1977, including control of combustibles, control of ignition sources and quality assurance in their corporate document titled, "Standard 12.15 -

Fire Protection". Based on the licensee's incorporation and implementation of this document, the staff concluded that administrative controls meet the guidance of BTP CMEB 9.5-1, Section C.2, and are therefore, acceptable.

2.5 Fire Brigade and Fire Brigade Training A site fire brigade will be maintained with a minimum of five members per shift.

Fire brigade members will receive training in accordance with staff guidance.

Based on the licensee's January 1992 submittal, the staff concluded that the fire brigade and the training of the fire brigade meet the guidelines of BTP CMEB 9.5-1, Section C.3, and are therefore acceptable.

2.6 Building Design The licensee indicated in the BFN-FPR that fire rated compartmentation is in accordance with the guidelines set forth in Section III.G of Appendix R to 10 CFR 50.

The Fire Hazards Analysis and Safe Shutdown Analysis provide engineering evaluations for defining and/or justifying fire areas and fire resistive barriers. On March 2, 1993, the licensee agreed to incorporate additional instructions into the BFN-FPR to clarify that the use af OL 86-10 guidance for evaluating deviations is not an acceptable methodology for justifying inadequate or unprotected openings in fire barriers between redundant or alternative trains of safe shutdown equipment.

The staff SE dated November 3, 1989, on post-fire safe shutdown systems indicated that the licensee had submitted various engineering evaluations in accordance with GL 86-10 to address certain BFN fire protection deficiencies.

These evaluations justified the use of non-three-hour rated fire doors in the reactor building fire area, lack of automatic suppression and detection on the refuel floor, lack of three-hour rated HVAC dampers in the reactor building boundaries, and use of draft stops and water curtains around openings in lieu of one-hour or three-hour barriers. All of TVA's evaluations were reviewed and found acceptable as documented in the November 3, 1989 SE.

The staff SE dated November 3, 1989, on post-fire safe shutdown also referred to the results from Inspection Report (IR) 50-259/89-28, 50-260/89-28 and 50-296/89-28 dated September 15, 1989. As documented in this IR, the following fire areas (walls, floors, roofs/ceilings) were inspected to verify they met the requirements for a three-hour fire rating or a rating which exceeds the maximum anticipated combustible fire loading within the areas:

Fire Area No.

Designation 2

Unit 2, Reactor Building 4

Unit 1, 4kv Shutdown Board Room-b S

Unit 1, 4kv Shutdown Board Room-a 8

Unit 2, 4kv Shutdown Board Room-d 9

Unit 2, 4kv Shutdown Board Room-c 10 Unit 2, 480v Shutdown Board Room-2a 11 Unit 2, 480v Shutdown Board Room-2b 12 Unit 3, Shutdown Board Room-F 17 Unit 1, Battery and Battery Board Room and dc Equipment Room 18 Unit 2, Battery and Battery Board Room and dc Equipment Room 20 Unit 1 & 2, Diesel Generator Building 21 Unit 3, Diesel Generator Building 22 Unit 3, 4kv Shutdown Board Rooms 3 ea & 3 eb 23 Unit 3, 4kv Shutdown Board Rooms 3 ec & 3 ed 24 Unit 3, 4kv Bus Tie Board Room Furthermore, the licensee has committed to install additional detection and suppression systems in many of these fire areas as part of its "Fire Protection Upgrade Program" described in the BFN-FPR.

These NFPA upgrades will be completed during the Unit 2 Cycle 6 Refueling Outage.

However, walls separating the battery, battery board and DC equipment rooms for each Unit (Fire Areas 17, 18 and 19) from the control building (Fire Area

16) did not appear to meet the required fire rating. Consequently, the licensee committed to install additional layers of gypsum wallboard on the corridor side of the wall panels. This modification would increase the fire resistance ratings of these walls. The NRC inspection team concluded that this modification would be acceptable and identified this issue as Unresolved Item (URI) 89-28-01. This URI was subsequently closed out in IR 90-11 dated May 11, 1990.

Fire Area, Unit 2 Reactor Building, is divided into six fire zones for compliance with 10 CFR 50 Appendix R. Water curtains and draft stops are utilized as a means to separate each fire zone at the following locations:

Elevation Location 565 Feet Unit 2 Reactor Building at R8-T and R14-I 593 Feet Unit 2, Reactor Building at R9-U 621 Feet Unit 2, Reactor Building at R9-U, R-13U 639 Feet Unit 2, Reactor Building at R9-U A walkdown inspection of these zones (see IR 89-28) found that the separation of each zone conforms to the description in TVA's evaluation document (i.e.,

Appendix G of Volume III of Appendix R Engineering Evaluations).

Electrical and mechanical penetrations of the reactor building floors are sealed with fire-rated seals. In addition, the November 3, 1989 SE discussed the Heating Ventilation and Air Conditioning (HVAC) duct penetrations through floor slabs that are provided with fire dampers having at least a 1-1/2 hour fire rating.

2.7 Safe Shutdown Capability The staff SE dated November 3, 1989, approved the licensee's shutdown methodology for Unit 2. This SE considered the use of certain equipment in Units 1 and 3 for the shutdown of Unit 2 and assumed that Units 1 and 3 were shut down with no irradiated fuel in their cores.

2.8 Alternative Shutdown Capability The staff SE dated November 3, 1989, approved the licensee's alternative shutdown methodology for Unit 2.

2.9 Control of Combustibles In general, the licensee has isolated or separated safety-related systems from combustible materials (by design or administrative procedures) or has provided special protection to prevent a fire from defeating the safety system. The licensee has protected the emergency diesel generators with an automatic carbon dioxide fire suppression system to limit the damage from an oil fire.

The turbine lube oil tanks expose a single train of safety related cables along the south wall of the turbine building. The lube oil tanks are protected by water spray systems.

The recirculation pumps are located in primary containment, which is inerted during unit operation. The associated motor-generator (MG) sets also contain large quantities of oil and are protected by an automatic aqueous film forming foam (AFFF) fire suppression system. Adequate curbing is provided around the MG sets to contain a spill of oil.

Based on the licensee's submittal, the staff concluded that combustibles have been separated from safety-related systems or provided with suppression in accordance with the guidelines of BTP CMEB 9.5-1, Section C.5.d. and such separation, therefore, is acceptable.

Flammable and combustible liquids are strictly controlled. The licensee committed to re-examine their response to BTP CMEB 9.5-1 that indicated that flammable and combustible liquids are well removed from structures containing safety-related equipment and generally follows the basic guidelines of National Fire Protection Association (NEPA) Code 30. Both the staff and the licensee were uncertain as to what was meant by "generally" conforms to NFPA

30.

By letter dated August 3, 1988, "Summary of Deviations From National Fire Protection Association (NFPA) Code," the licensee provided the results of its review of BFN's conformance with NFPA Codes 12, 13, 14, 15, 16A, 20, and 24.

On March 2, 1993, the licensee agreed to re-visit NFPA 24 and 30 to determine if additional review and documentation is warranted, including whether other NFPA codes should also be reviewed. The licensee's actions in this regard may be subject to future NRC audit or inspection.

2.10 Electric Cable Construction, Cable Trays, and Cable Penetrations Cables installed after 1977 meet the requirements of IEEE 383.

All non-IEEE 383 qualified cables in open cable trays in the secondary containment of the reactor building, cable spreading rooms, diesel generator buildings, intake pumping station, and cable tunnel to the intake pumping station have been coated with a flame retardant.

Only metal is used for cable tray construction. Flexible metal components are used in lengths of six feet or less.

Thin wall metallic tubing is not used.

Separation and fire protection features for those cables required to achieve and maintain safe shutdown are in compliance with the requirements of Section III.G of 10 CFR 50 Appendix R.

2.11 Ventilation Smoke removal is accomplished by existing HYAC exhaust systems in the reactor, turbine, and diesel buildings; shutdown board rooms; and cable spreading rooms. Portable smoke ejectors are available for backup. Smoke removal alternatives are addressed in the licensee's pre-fire plans.

The reactor, control and diesel generator building are safety-related areas provided with air intakes. Air intakes are either widely spaced or arranged such that contamination from the exhaust is highly unlikely.

2.12 Lighting and Communication The licensee has provided fixed emergency lighting with sealed beams and 8-hour minimum battery power supply in access routes and areas required for safe shutdown. The licensee conducts monthly and yearly tests on all Appendix R emergency lights.

Licensee has provided normal and emergency communications for fire fighting in the plant. A portable radio communication system is provided for use by the fire brigade and operational personnel.

In addition, a sound-powered telephone system is also provided throughout safety-related areas.

2.13 Fire Detection Systems Fire detection systems are provided when required to meet the separation requirements of 10 CFR 50.48 and 10 CFR 50 Appendix R, as identified in Table 9.3.11.a of the licensee's Fire Protection Plan included in the BFN-FPR.

The licensee will be upgrading fire detection systems in the following areas:

Unit 1 Reactor Building Unit 2 Reactor Building Unit 3 Reactor Building Control building (including Cable Spreading Rooms)

Units 1/2 Diesel Generator Building Unit 3 Diesel Generator Building Intake Pump Station The new fire detection systems will be installed as part of the Fire Protection Upgrade Program as documented in the BFN-FPR.

2.14 Fire Protection Water Supply Systems Fire protection water supply consists of four fire pumps connected to a 14-inch cement lined underground fire main that supplies all three Units. The electric driven fire pumps are rated at 2500 gallons per minute at 130 pounds per square inch.

The diesel driven fire pump is rated at 2500 gallons per minute at 147 pounds per square inch. The diesel fire pump is located in a separate building from the three electric fire pumps. All fire pumps and controllers shall be maintained according to NFPA Code 20. All new installations shall conform to NFPA Code 20.

Each pump is designed to supply the most hydraulically remote safety-related area.

The diesel fire pump and controller are listed by an accredited laboratory (e.g., UL listed).

The electric fire pumps and controllers are not listed. This was previously reviewed and found acceptable by the staff SE dated November 3, 1989.

In its August 3, 1988 submittal, the licensee indicated that the high pressure fire pumps do not automatically start upon the loss of system pressure. "The fire pumps are started automatically upon actuation of the fire detection system. Once the first electric fire pump starts, additional fire pumps will start every 15 seconds if the pressure on the system is below 120 psi."

The licensee provides the following justification:

"The high pressure fire pumps do not start upon the loss of system pressure since the system is a combined fire protection and raw service water system. The raw service water pumps and head tanks maintain system pressure as service water loads vary and would not allow automatic fire pump starts on low pressure unless a combined fire suppression and service water demand exceeded the capacity of the raw service water pumps. While the fire pumps do not automatically start upon the loss of pressure in the system, there are automatic fire pump start commands sent by the actuation of a sprinkler/spray system and there are manual pump start switches located throughout the plant area. These switches are not supervised. However, periodic testing of the switches is conducted to ensure operability. The fire pumps can also be started manually from the control rooms. This provides an additional factor of safety, in that upon a fire alarm, an operator can manually start the fire pumps in the event they fail to start automatically."

This arrangement was previously reviewed and found acceptable by the staff SE dated November 3, 1989.

Each fire pump has audible and visual control room indication for operating (red), off (green) and indication for motor/pump overload condition.

Valves in the fire protection water supply system are locked and checked at least monthly.

The fire pumps take suction from a separate bay in the Intake Pumping-Station which is supplied from the Wheeler Reservoir. The Wheeler reservoir provides an unlimited supply of fire suppression water.

Non-indicator type sectional control valves are used to isolate portions of the underground main for maintenance or repair without shutting down any part of the fire water-supply system. The licensee committed as part of its NFPA code review to replace the non-indicating valves with indicating valves on an as-needed basis with the eventual goal of complete replacement.

The hose houses contain an adequate supply of hose and equipment. Yard hydrants are connected to the yard fire main at maximum intervals of 275 feet around the powerhouse. Each fire hydrant is provided with a gate valve which enables isolation of individual hydrants to facilitate hydrant maintenance and repairs without shutting down any part of the fire water supply system.

Licensee response to BIP CMEB 9.5-1, Section C.6.b, indicated that underground installation details, such as thrust blocks, clamps, etc. have not been reviewed as part of its comparison. Consequently, the staff could not conclude that the BFN fire protection water supply system fully meets Section 6.b of NRC BIP CMEB 9.5-1.

However, on March 2, 1993, the licensee agreed to re-visit its review of NFPA codes, including NEPA Code 24 (see Section 2.9 above).

2.15 Sprinkler and Standpipe Systems The automatic sprinkler systems and standpipe risers are connected to common interior water supply headers. The interior headers are fed from each end through separate supply connections that can be isolated to perform maintenance or to prevent a single break from impairing the entire distribution system. In addition, header and divisional valve arrangement is such that no single failure can impair both primary and backup fire protection systems protecting a single fire area. The water supply valves to the suppression system are locked and verified each month to be in the proper position. The sprinkler systems have water flow alarms which alarm in the control room.

The automatic sprinkler systems, wet pipe sprinkler systems, preaction sprinkler systems, water spray and manual hose stations have NFPA code deviations that were previously reviewed and accepted in the staff SE dated November 3, 1989.

The areas that have been equipped with automatic water suppression are listed in Table 9.3.11.B of the licensee's Fire Protection Plan.

Fixed water spray systems are being decommissioned after preaction sprinkler systems in the areas have been upgraded in accordance with NFPA Code 13 requirements.

The locations that have been equipped with manual hose stations are listed in Table 9.3.11.0 of the licensee's Fire Protection Plan.

2.16 Gaseous Fire Suppression Systems A halon total flooding system is used as the primary extinguishing agent in the non-safety related computer room under floor spaces. The licensee indicated that the system is designed to the requirements of NFPA Code 12A, "Standard on Halogenated Fire Extinguishing Agent Systems -

Halon 1301."

The licensee plans to conduct a fan pressurization test prior to completion of the Unit 2 refueling outage.

The carbon dioxide total flooding systems have been installed in the cable spreading rooms (which potentially involve deep-seated fires) and the diesel generator rooms (which involve surface type fires).

The licensee indicated that the pre-action water suppression system is the primary fire suppression and that no credit is given to the carbon dioxide system in the Cable Spreading Room. There is a wintergreen odorizer installed to alert personnel of carbon dioxide gas in the area in case of an activation or inadvertent operation of the carbon dioxide system. Carbon dioxide system NFPA code deviations were previously identified by the licensee in their August 3, 1988 submittal and accepted by the staff SE dated November 3, 1989.

2.17 Portable Fire Extinguishers Fire extinguishers have been provided in all areas of the plant in accordance with the guidelines of NFPA Code 10, "Standard for Portable Fire Extinguishers".

This meets the guidelines of BTP CMEB 9.5-1, Section C.6.f and is acceptable.

2.18 Containment During plant operation, a fire is not postulated since the primary containment is inerted with nitrogen.

2.19 Control Room Complex The control room complex is separated from the reactor and turbine buildings by 3-hour fire barriers. Fire dampers are provided in all ventilation openings between the control room complex and adjacent fire areas.

The control room complex is separated by a non-fire-rated reinforced concrete floor from Control Building rooms on the 606-foot elevation.

Smoke detectors are provided in some panels and at the ceiling of the control room. Smoke detectors are provided in two electrical panels in the relay room. All detectors provide alarm indication in the control room.

2.20 Cable Spreading Rooms A separate cable spreading room is not provided for each redundant division.

Cable spreading rooms are shared between units. The two cable spreading rooms are not separated from each other or from other areas of the control building by 3-hour barriers. The cable spreading rooms are separated by 3-hour barriers from the reactor building and turbine building. Preaction sprinkler systems provide primary suppression with backup hose stations. In the event of a major fire involving the cable spreading room, the licensee plans to utilize remote shutdown panels to control and shut down the reactors. The staff SE dated November 3, 1989, evaluated the Unit 2 safe shutdown program assuming Units 1 and 3 were shut down with no irradiated fuel in their cores.

The licensee's revised safe shutdown analyses/programs to accommodate multi-unit operation are scheduled for future NRC review and inspection prior to restart of Units 1 and Unit 3. The Unit 2 remote shutdown panel and related safe shutdown equipment is physically and electrically isolated from the cable spreading room.

2.21 Switchgear Rooms Safety-related switchgear is located in the shutdown board rooms and separated from other plant areas by 3-hour barriers. Area-wide detection is planned for Units 1, 2, and 3 shutdown board rooms. The shutdown board rooms have separate exhaust fans which can be used for venting smoke.

10 -

Fire hose stations and extinguishers are available outside the shutdown board rooms. Floor drains have been provided for the shutdown board rooms on elevations 593 feet and 621 feet of the reactor building to remove water from fire fighting activities.

2.22 Safety Related Battery Rooms The three safety-related plant battery rooms are separated from each other and other areas of the control building by fire barriers of at least one hour rating. The licensee indicated that the rated barriers will be capable of withstanding the maximum anticipated combustible loading on the other side of the wall.

The control building is separated from the turbine building by three-hour fire-rated barriers.

2.23 Emergency Diesel Generator Rooms Each of the two separate diesel generator buildings contain four emergency diesel generators. The diesel generator rooms are separated from each other by non-fire-rated reinforced concrete walls. All rooms within a single diesel generator building are considered the same fire area.

Each diesel generator room and fuel oil transfer pump rooms is protected by an automatic carbon dioxide suppression system. Preaction sprinkler systems are installed in the pipe and electric tunnels outside the diesel generator rooms.

Automatic fire detection is provided for the diesel generator rooms, fuel oil transfer pump rooms, and pipe and electric tunnels for suppression system actuation.

2.24 Remote Safety-Related Panels Redundant shutdown capability was previously evaluated by the staff SE dated November 3, 1989.

3.0 CONCLUSION

S The BFN-FPR contains four principal parts: (1) the "Fire Protection Plan," (2) the "Fire Hazards Analysis," (3) the "Safe Shutdown Analysis," and (4) the "Unit 2 Appendix R Safe Shutdown Program."

The licensee's Fire Protection Plan and Fire Hazards Analysis described in BFN-FPR was reviewed and found acceptable. The only exception was that the staff's review of BFN conformance with NFPA Code 30, "Flammable Combustible Liquid Code," and NFPA Code 24, "Outside Protection," could not be completed. GL 86-10 requested the licensee to identify and justify NFPA Code Deviations.

By letter dated August 3, 1988, the licensee reviewed certain NFPA codes and identified many deviations. These deviations were reviewed and accepted by the staff in its SE dated November 3, 1989. However, the licensee may not have adequately addressed all applicable NFPA codes, such as NFPA Code 24 and NFPA Code 30. The licensee has committed to revisit these NFPA codes to determine if further review and documentation is warranted, and whether any additional NFPA codes should also be reviewed, to assure conformance. This commitment by the licensee is considered sufficient to resolve the staff's concern. The licensee's actions taken as a result of this commitment is subject to future NRC audit or inspection.

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The licensee's Safe Shutdown Analysis and Unit 2 Appendix R Safe Shutdown Program were previously reviewed and approved by the staff as documented in SEs dated December 8, 1988, November 3, 1989, and March 6, 1991.

Consequently, based on this SE and the SEs mentioned above, the staff concludes that TVA's fire protection program described by the BFN-FPR submitted on January 15, 1992, conforms with BTP CHEB 9.5.1 and is therefore acceptable.

Principal Contributor: J. Holmes Date: March 31, 1993