ML18227D388

Letter Logic Inconsistency in Two of the Computer Codes Used in Westinghouse LOCA ECCS Evaluation Model

ML18227D388
Person / Time
Site:	Turkey Point
Issue date:	04/10/1978
From:	Robert E. Uhrig Florida Power & Light Co
To:	Stello V Office of Nuclear Reactor Regulation
References
Download: ML18227D388 (48)

Text

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LETTER NOTARIZED:

NO COPIES RECEIVED SlJBJECT:

LTR 3 Ei~lCL 3 FJJRNISHING INFO CONCERNING INCONSISTENCY EXISTING IN TWO OF THE COMPUTER CQl: ES

(

SATAN-VI< 1 )

8c LOCTA-IV ( 2) )

USED Ii~1 WESTINGHOUSE LOCA ECCS EVALUATION M.iDELi WHICH HAS AFFcCT D APPLICANT"S ANALYSIS'NVOLVINGZ RCONIUM-WATEP.

REACTION HEAT GENERATION CALCU REVIEWER IiNITIAL:

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DISTR I BlJTER IllIT IAL:~

DISTRIBUTION OF THIS MATFRIAL IS AS FOLLOW PLANT NAME: TURKEY PT N3 TURKEY PT N3

'GENERAL I3I8TRIBUT'ION"FOR "AFTER 'ISSUANCE OF "OPERATI'NG LICENSE.

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April 10, 1978 L-78-127 Director of Nuclear Reactor Regulation Attention:

Mr. Victor Stello, Director Division of Operating Reactors U.

S. Nuclear Regulatory Commission Washington, D. C.

20555

Dear Mr. Stello:

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~ W B

Re:

Turkey Point Units 3 and 4

Docket Numbers 50-250 and 50-251 ECCS Anal sis Florida Power S Light Company has been informed by Westinghouse Electric Corporation that a logic inconsistency exists in two of the computer codes used in their LOCA ECCS Evaluation Model.

The SATAN-VIll] and. LOCTA-IVPj codes are the affected computer codes.

All versions of the Westinghouse Appendix K evaluation model are affectedl3I4i5I <l.

Therefore, our analysis on record is also, affected.

This logic inconsistency involves the interface between the zirconium-water reaction heat generation calculation and the heat conduction equation.

Both the zirconium-water reaction equation (Baker-Just) and the heat conduction equation are

.,solved correctly..

However,.the,,hea;t,conduction

..equation uses a volumetric heat flux from the zirconium-water reaction calcu-lation.

The" output of the zirconium-water reaction calculation is a surface heat flux.

This surface heat flux is modified to obtain a volumetric heat generation rate by dividing by the thickness of the radial mesh size between, the surface temperature node and the first node inside the clad. 'lt is this calculation which was performed incorrectly.

The inconsistency underestimates the volumetric heat generation rate due to the zirconium-water reaction by a factor of 2.'he presence of this logic inconsistency has been verified by visual inspection of the computer codes and by performing energy balances on some sample calculations.

Correction of this error will result in higher calculated peak clad temperatures.

Mr. Victor Stello Page Two April 10, 1978 L-78-127 Westinghouse Electric.Corporation has studied the effect of correcting this error on calculated peak clad temperature.

In addition to correcting this error, some beneficial model changes were also studied.

The result of their studies indicated a net increase in peaking factor from the proposed beneficial model improvements.

Some details of these calculations follow.

Westinghouse Electric.Corporation has proposed the use of the following improvements to the October 1975 version of their evaluation model:

1.

Change the transition boiling correlation used during blowdown from the W Transition Boiling Correlation to the Dougall-Rohsenow correlation.

Both correlations have been documented by Westinghousel.3) and both termed "acceptable" in Appendix E

of 1'OCFR50.46 and the NRC -SER -.for.the.Westinghouse..evaluation model.

2.

Use of an em',sqivity in the refill radiation heat transfer model of 0.9~7>.

3.

Multiply the volumetric heat generation from the zirconium-water reaction calculation by a factor of 2 to correct the logic inconsistency.

4.

Use of maxi-convqlqtion to improve the peaking factors being calculated<

5.

Use of a new 15x15 FLECHT correlationl9l.

All of these modifications were discussed by Westinghouse with the staff on March 29, 1978.

We understand that it will take the staff three months to review all of -these 'model changes.

We will work with Westinghouse and the NRC until then to arrive at a new approved LOCA ECCS Evaluation Model.,At that time, we will submit to the Nuclear Regulatory Commission a schedule for reanalysis of the present limiting break size with the new model.

A reanalysis will be performed for Turkey Point Units 3 and 4 as soon as possible following NRC approval of the Westinghouse model changes.

Until the Westinghouse model changes are approved and a new ECCS analysis can be performed for Turkey Point Units 3 and 4, Florida Power 6 Light Company will administratively limit F< for Turkey Point Unit 3 to 2.03 and to 1.91 for Turkey Point Unit 4.

Mr. Victor Stello Page Three April 10, 1978 L-78-127 These levels are conservative since Westinghouse estimates levels of Fq of 2.21 and 2.06 respectively, when credit is taken for the proposed model improvements with the October 1975 evaluation model.

The estimates have been confirmed by many actual calculations.

The derivation of the interim values of Fq of 2.03 and 1.91 are documented in the attached two tables.

They are based on calcu-lations and sensitivity studies performed by Westinghouse and interim credits and penalties imposed by the NRC staff on the basis of these studies.

The revised Fq limits will require K(z) curves which are also attached.

The following clarification may be helpful in interpreting the

.attached.tables..

~Eizst

.of all, when.talking about, margin in the amount of steam generator tubes plugged, we are referring to the difference between the value assumed in the analysis of record and the actual percent of tubes curqengly plugged.,

'Then the Westinghouse Perturbation techniquel.10>

is used to obtain a change in peaking factor related to this difference.

The table lists the.assumed percent steam generator tubes plugged versus the actual.

You should also note that a small allowance has been made for the future possibility of having to plug additional tubes as a result of primary to secondary leakage.

Secondly, when correcting for as-built fuel temperatures, a

sensitivity of ill F initial pellet temperature per 0.1 change in peaking factor was used.

This value is based on the 37'F pellet temperature at end of blowdown per O.l change in Fq (reported to the staff on March 29, 1978) and a bounding ratio of 3'F initial pellet temperature per 1'F pellet temperature at end of blowdown.

Both sensitivities were conservative bounds of some actual calculations.

Based on Westinghouse core physics calculations, the maximum values of Fq that could occur for the remainder of the current cycles are as follows:

Turkey Point, Unit 3, Cycle 5

Max. Fq = 2.02 Turkey Point, Unit, 4, Cycle 4

Max. Fq = 1.97 For Turkey Point Unit 3, operation with a Fq less'han or equal to 2.03 is ensured by the maximum predicted Fq being 2.02.

For Turkey Point Unit 4, operation with a F~ less than or equal to 1.91 is ensured by the implementation of operating procedures as discussed below.

iver. Victor Stello Page Four April 10, 1978 L-78-,127 The actual measured value of Fq is a well behaved function of exposure for a particular base loaded plant, and for the Turkey Point.,Unit 4, cycle 4 it has been about 1.7 for equilibrium conditions.

The Westinghouse design strategy, however, is based on defining a bounding envelope of Fc's resulting from the most adverse control rod placements an8,xenon oscillations permitted by the plant's'technical specifications.

The maximum Fq predicted by this most adverse envelope of values when increased by specified uncertainty factors is generally below

,the Fq limit established by the ECCS analysis, therefore requiring only monthly surveillance.

In the interim, while the maximum predicted F

(1.97) exceeds the allowable F

(1.91),

Turkey Point Unit 4 Sill be operated as a base loade5 plant..

Procedures have been established and

.reviewed.by the.,Plant Nuclear, Safety Committee to,provide for augmented surveillance when the reactor power exceeds the ECCS threshhold power, i.e., percent power greater than 1.91/1.97x 100%.

These procedures provide for Turkey Point Unit 4 to be at steady state equilibrium conditions prior to increasing power above the threshhold.

Two incore detector thimbles will then be monitored to establish that sufficient Fq margin exists before increasing power above the ECCS threshhold.

Operation at power levels above the ECCS threshhold level will require that Bank D be inserted no more than 20 out, of 228 steps.

In the event that Bank D is inserted beyond this limit, and -moved more than an accumulated

+

5 steps, augmented surveillance, will be instituted using two incore detector thimbles.

Appropriate procedures have been established to reduce, reactor.power below the.ECCS,threshhoj.d,within.15 minutes if,.themeasured Fq exceeds the Fq limit (1.91) by

>4%. If the measured Fq exceeds the Fq limit by <4'4, power would be reduced 1% for each 1% deviation.

If the measured Fq is not within its limit within two hours, power would then be reduced below the ECCS threshhold level.

'I This matter has been reviewed by the Turkey Point Plant Nuclear Safety Committee and the Florida Power 6 Light Company Nuclear Review Board.

They have determined that operation of Turkey Point Units 3 and 4 as described herein will ensure the continued safe operation of the plant and will not endanger the health and safety of the public.

Very truly yours, PP Ro ert E.

Uhrz.g Vice President cc:

J.

P. O'Reilly, Region II Robert Lowenstein, Esquire

CURRENT ANALYSIS: 09

=

1

~ 90 Tubes-Plugged

=

15'A II.

CHANGES TO CURRENT ANALYSES PEAK CLO TENPERATURE = 2019'P Turkey Point Unit 3 MODIFICATION Fq CHANGE JUST IFICATION/BASIS 1.

Zirc/Mater Reaction Correction

0. 00 Incorporated in base case 2.

Current Analysis Margin to 2000'.

Current Analyses Margin to 2200'.00

+0.14 20 F/ 5 Fq NRC 25 F/

Fq -

NRC 4.

Use of New 15xl5 Flecht

-0.03 Included in Analysis Performed

'by Mestinghou'se

{-.03 is con-servatism imposed by NRC) 5.

.No use of Dougall-Rohsenow 0.00 NRC Interim Position 6.

No use of a=0.9 0.00 NRC Interim Position 7.

ESDR Power Used in Current Analysis 0.00 Margin already included in current analyses 8.

Margin to Amount. of Steam Generator Tubes Plugged

+0.02 (See note below)*

9.

Use of As-Built Fue1 Temperature

.0.00 10.

Margin In Containment Back Pressure'.

00 Net Change

+0.13 Current Fq plus Net Change

=

New Fq 1.90

+

+0.13

=

2.03 Actual tubes plugged on Turkey Point Unit No.

3 is 11.7% as compared to 15$ used in analyses.

Therefore, using 12.25 tubes plugged to allow some marqin for additional

plugging, a credit of.02 is applicable on'he basis of.007 units of Fq/per cent tubes plugged.

PEAK CLAD TEMPERATURE

=

2195'F I

CURRENT ANALYSIS Fq 2 05 Tubes Plugged

= 195 II.

CHANGES TO CURRENT ANALYSES Turkey Point Unit 4 MODIFICATION Fq CHANGE JUSTIFICATION/BASES 1.

Zirc/(later Reaction Correction

-0.20 NRC 2.

Current Analysis Margin to 2000'F 3.

Current Analyses Margin to 2200'F 4.

Use of New 15x15 Flecht

0. 00 0.00

+0.05 20 F/ 5 Fq NRC 25'F/ 5 Fq -

NRC (See note below)*

5.

No Use of Dougall-Rohsenow 0.00 NRC Interim Position 6.

No use of E=0.9 0.00 NRC Interim Position 7.

ESDR Power Used In Current Analysis 0.00 Margin Already Inc'luded in Current Analysis 8.

Margin to Amount of Steam Generator Tubes Plugged

+0.01 (See note below)*"

9.

Use of As-Built Fuel Temperature 0.00 10.

Margin In Containment Sack Pressure 0.00

'Net Change

-0.14 Current Fq plus Net Change

=

New F

2.05.

+

-0.14

=

1.91 Sensitivity study performed by Westinghouse indicated a

100 F benefit in PCT.

NRC converted this to +0.05 Fq benefit.

• • Actual tubes plugged on Turkey Point Unit No.

4 is 16.9Ã,as compared to 19/ used in the analysis.

Therefore, using 17.2/ tubes plugged to allow some margin for additional plugging, a credit of.Ol is applicable on the, basis of.007 units of Fq/per cent tubes plugged.

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References 1.

Bordelon, F. N., et al.,

"SATAN-VI Program:

Comprehensive Space-Time

-Dependent Analysis of Loss-of-Coolant",

MCAP-8306,, June 1974..

2.

Bordelon, F. M., et al.,

"LOCTA-IV Program" Loss of Coolant Transient Analysis", MCAP-8305, June 1974.

3.

"Mestinghouse ECCS Evaluation Model - Summary",

MCAP-8339, Bordelon, F. M.,

iMassie, H. M., and Zordan, T. A., July 1974.

4.

Bordelon, F. N.. et al., "Mestinghouse ECCS Evaluation t1odel - Supplementary Information, MCAP-8471, April, 1975, (Propriet'ary) and MCAP-8472, April, 1975 (Non-Proprietary).

5.

"Mestingkouse ECCS Evaluation Model October 1975 Version", MCAP-8622, November 1975, (Proprietary),

and MCAP-8623, November 1975, (Non-Proprietary).

6.

Letter "from C. 'Eicheldihger of '>les%i'nghouse Electric Corporation to 0.

B.

Yassallo of the Nuclear Regulatory Commission, Letter NS-CE-924, 1/23/76.

7.

"High Temperature Properties of Zircalloy - Oxygen Alloys", EPRI Report, NP-524, tIarch, 1977.

8.

Little, C.

C. et al., "Consideration of Uncertainties in the Specification of Core Hot Channel Factor Limits", MCAP-9180, September 1977.

9 10.

"Mestinghouse ECCS Evaluation Model, February, 1978 Version", MCAP-9220,

February, 1978 (Proprietary),

MCAP-9221, February, 1978 (Non-Proprietary).

Thompson, C.

M. and Esposito, V. J., "Perturbation Technique for Calculating ECCA Cooling Performance",

MCAP-8986, February 1977 (Non-Proprietary).

0 APRIL 1 0 1978 Docket Hos., 5-and 50-251 Florida Power 5 Light Company ATN:

Robert E. Uhrig, Vice President Advanced Systems 5 Technology Post Office Box 529100 Hiami, Rorwa 33152 Gentlemen:

OH Inarch 30. 1978, an II'ire Protection Team held a meeting with your representatives following an on-site revie> of your facility.

During this meeting that team identified certain HRC staff concerns and positions.

Enclosure 1 prevides a senary of items that you agreed to complete in response to concerns raised by the staff.

Enclosure 2 provides the staff concerns and positions which remain as open items.

In order to obtain a resolution of these concerns, you are requested to address each of these items in one of the foHow)ng Mays'.

.Commit to implement the positions; 2.

Propose an alternative method to resolve the concerns; or

=

3.

ProvMe the basis by which the present fire protection program addresses the c'oncern without further action.

Your approach ta Are protection has placed a great dea't of emphasis on the capability -of the plant.to reach a safe shutdown condition despite the effects of unmitigated fires.

In general, ve concur uith the mjority of your evaluation on this aspect of the fire hazards analysis.

However, it should be painted out that the two other aspects of the "defense in depth" approach to fire protection should nat be under emphasized based upon this approach alone.

These aspects are: (l) preventing fires from starting..

and (2) detecting firas quickly, suppressing those Ares that occur, putting them out quickly, and

'timiting their damage.

These considerations are ekodied in thy require-ments of General Design Criter)a.3 of Appendix A to 10 CFR 50 'and in the guidance contained in Appendix A to Branch Technical Position 9.5-1.

Your response to the enclosed staff positions should be made with these considerations in m'Indd OFFICE~

SURNAME~

DATE~

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Florida Power 5 Light Company

~S P ss APR Il, Z 0 tg78 The ma)or)ty of the items noted in Enclosure 2 were discussed Mith you during the site visit and exit meeting.

lfe request that you meet with us during the week of Nay 7th in Bethesda to discuss your response to our concerns and to obtain resolution of these items.

Your representa-tives were not, prepared to make a commitment of manpower or dunds at the conclusion of the site visit to resolve open items.

Me request that a representative of Florida Power

5. Light Company be prepared to make such comoitem nts at the Hay meeting to permit the conc'tusion of this evaluation in a timely manner.

Sincerely, A. Schwencer, Chief Operating Reactors Branch B Divisdnn of Operating Reactors

Enclosures:

1.

Proposed Fire Protection Hodifications 2.

Statement of Staff Concerns and Positions CC w/encl'ee next page DISTRIBUTION Dockets NRC PDRs LOCAL PR ORB81 Reading ASchwencer NGrotenhuis CPanish GELD OraE(3}

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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 APRIL l 0 87S Docket Nos.

50-250 and 50-251 Florida Power 8 Light Company ATTN:

Robert E. Uhrig, Vice President Advanced Systems

& Technology Post Office Box 529100 Miami, Florida 33152 Gentlemen:

ON Narch 30,

1978, an NRC Fire Protection Team held a meeting with your representatives following an on-site review of your facility.

During this meeting that team identified certain NRC staff. concerns and positions.

Enclosure 1 provides a summary of items that you agreed to complete in response to concerns raised by the staff.

Enclosure 2 provides the staff concerns and positions which remain as open items.

In order to obtain a resolution of these

concerns, you are requested to address each of these items in one of the following ways:

l.

Commit to implement the positions; 2.

Propose an alternative method to resolve the concerns; or H

3.

Provide the basis by which the present fire protection program addresses the concern without further action.

Your approach to fire protection has placed a great deal of emphasis on the capability of the plant to reach a safe shutdown condition despite the effects of unmitigated fires.

In general, we concur with the majority of your evaluation on this aspect of the fire hazards analysis.

However, it should be pointed out that the two other aspects of the "defense in depth" approach to fire protection should not be under emphasized based upon this approach alone.

These aspects are:

(1) preventing fires from starting; and (2) detecting fires quickly, suppressing those fires that occur, putting them out quickly, and limiting their damage.

These considerations are embodied in the require-ments of General Design Criteria 3 of Appendix A to 10 CFR 50 and in the guidance contained in Appendix A to Branch Technical Position 9.5-1.

Your response to the enclosed staff positions should be made with these considerations in mind.

A

Florida Power

8. Light Company APR I L 2 0 878 The majority of the items noted in Enclosure 2 were discussed with you during the site visit and exit meeting.

We request that you meet with us during the week of Hay 7th in Bethesda to discuss your response to our concerns and to obtain resolution of these items.

Your representa-tives were not prepared to make a commitment of manpower or funds at the conclusion of the site visit to resolve open items.

We request that a representative of Florida Power 8 Light Company be prepared to make such commitments at the Hay meeting to permit the conclusion of this evaluation in a timely manner.

Sincerely, I

P,.rggCgZ 4 I

A. Schwencer, Chief Operating Reactors Branch b'1 Division of Operating Reactors

Enclosures:

1.

Proposed Fire Protection Hodifications 2.

Statement of Staff Concerns and Positions cc w/encl:

See next page

Florida Power 8 Light Company 3

APRIL '

p g78 cc:

Mr. Robert Lowenstein, Esquire Lowenstein,

Newman, Reis 5 Axelrad 1025 Connecticut

Avenue, NW Suite 1214 Washington, D.C.

20036 Environmental 8 Urban Affairs Library Florida International University Miami, Florida 33199 Mr. Norman A, Coll, Esquire

Steel, Hector and Davis 1400 Southeast First National Bank Building Miami, Florida 33131 Florida Power 8 Light Company ATTN:

Mr. Henry Yaeger Plant Manager Turkey Point Plant P. 0.

Box 013100 Miami, Florida 33101

Enclosure 1

PROPOSED FIRE PROTECTION MODIFICATIONS 1.

Fire detection will.be provided in the diesel generator rooms.

2.

Penetration in the wall separating the diesel generator units will be sealed to provide a three-hour fire'rating.

3.

Penetrations between the deisel day tank rooms and diesel generator rooms will be sealed to provide a

three-hour fire rating.

,4.

Three 17 pound Halon 1211 portable extinguishers will be provided in the control room.

S.

The access doors to the control room will be replaced with a security door which will provide a substantial fire barrier.

6.

Wood storage boxes in proximity to the hydrogen trailer will be removed.

7.

Unused trays in the cable vaults will be removed to improve fire brigade access.

Eb, SURE 2

STATEMENT OF STAFF POSITIONS TURKEY POINT FIRE PROTECTION PF-1 PF-2 PF-3 PF-5 PF-6 PF-7 PF-8 PF-9 PF-10 PF-11 Smoke Detection Systems Tests Control Room Smoke Detection in Control Room Make-up Air Supply Cable Spreading Area Access Doors

'160 V Switchgear Rooms Electrical Penetration Rooms Reactor Control Rod Equipment Rooms Auxiliary Building Corridor Charging Pump Rooms Diesel Oil Storage Tank Diesel Oil Transfer Pumps PF-12 Diesel Day Tank Rooms PF-13 Diesel Generator Rooms PF-14 PF-15 PF-16 Routing of Hydrogen Lines Fire Areas 21 and 22 Control Point Guard House PF-17 New Laundry Facility PF-18 Reactor Coolant Pump Lube Oil Systems PF-19 Fire Water Supply

'PF-20 Booster Hose Stations PF-21 PF-22 Hose Cabinet Equipment Firehouse Equipment PF-23 Yard Hydrants PF-24 Portable Ventilation Equipment

PF-25 Air-Breathing Apparatus PF-26 Air-Breathing Apparatus for Control Room Operators PF-27 Emergency Lighting

STATEMENT OF STAFF POSITIONS TURKEY POINT FIRE PROTECTION PF-1 Smoke Detection Systems Tests Staff Concern:

The type and location of ionization smoke detectors may not provide p'rompt detection of fires in areas where they are used.

Ventilation air flow patterns or detector sensitivity may prevent effective fire detection.

t Staff Position:

In situ tests should be conducted with a suitable smoke generation device to verify that the products of combustion from a fire would be promptly detected by installed smoke detectors and that ventilation air flow patterns in the area do not significantly reduce or prevent detection response.

Bench tests should be conducted to verify that smoke detectors will provide prompt response and have adequate sensitivity to the products of combustion for the combustibles in the

'rea where smoke detectors are installed.

If any fire detection systems are found to be inadequate, appropriate modifications should be made to provide adequate detection system performance.

PF-2 Control Room Staff Concern:

Nine ionization and five thermal fire detectors are located at the ceiling of the control room, and one detector is provided in each of the enclosed operators'onsoles.

Separate. enclosed electrical equipment panels are provided for redundant divisions of safety-related systems and are located in the areas behind the L-shaped control boards.

These panels have locked doors for security.

Within the control boards, redundant divisions of wiring for safety-related systems 'are routed in close proximity.

The prompt detection and location of fires in, electrical equipment within the control room are necessary to permit fire extinguishment and to prevent damage to redundant systems.

Shutdown capability is provided in the event of severe fire damage.

A kitchen is located in a separate area of the control room.

Protection has not been provided to prevent smoke or a fire in this area from being an exposure hazard to the control room or its occupancy.

Staff Position:

l.

Early warning fire detection should be provided by the location of smoke detectors at the top of the control boards and in safety-related equipment panels which contain safe shutdown systems.

2.

The kitchen should be isolated from the control room by a one-hour fire-rated enclosure and fire detection provided therein.

0

STATEMENT OF STAFF POSITIONS TURKEY POINT FIRE PROTECTION PF-3 Smoke Detection in Control Room Make-up Air Supply Staff Concern:

Fires external to the control room could lead to the introduction of smoke to the make-up air supply for the control room.

The smoke detection system for. the control room would not identify the source of the smoke which could threaten the occupancy of the control room.

Staff Position:

A smoke detector should be provided in the make-up air supply for the control room.

PF-4 Cable Spreading Area Access Doors Staff Concern:

Access doors from the turbine mezzanine area to the cable spreading room are nonfire-rated.

Fires involving transients on the mezzanine level or from turbine lube oil piping systems could impact on the cable spreading room.

Staff Position:,

Access doors to the cable spreading area from the turbine area should be replaced with one-and-a-half-hour-rated Class A

fire doors.

PF-5 4160 V Switchgear Rooms Staff Concern:

The switchgear room is divided into four separate areas with redundant 4160 V switchgear located in the lower area and separated

'y a concrete wall.

The upper area contains two sets of 480 V switchgear separated by a concrete block wall.

Each set of 480 V switchgear contains two redundant 480 V buses.

Large passageways join each area.

Cables are routed in trays above the switchgear and between these areas, and are coated with Flamemastic.

The lack of early warning fire detection in these areas prevents prompt detection of a fire therein.

Nonrated fire doors providing access to these areas and ventilation openings in the

'walls do not provide protection from exposure fires outside the area.

Startup, main, and auxiliary transformers are located in close proximity to the unprotected openings in the switchgear rooms.

The east entrance areas of the switchgear rooms are areas through which transient combustibles are moved or could exist.

Combustible liquid spill fires in these areas could flow under the doors into the switchgear area.

Staff Position:

l.

Early warning fire detection should be provided in the 4160 V

switchgear -rooms in each area and on each level.

2.

All doors to the 4160 V switchgear rooms should be r placed with three-hour fire-rated Class A doors.

The access doors on the lower level should be curbed.

3.

An L-shaped concrete barrier with a covered top should be provided at the access door adjacent to the transformer area to prevent a direct fire exposure to the access door.

4.

The covered ventilation openings in the walls of the switchgear rooms should be sealed to provide three-hour fire-rated protection.

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STATEMENT OF STAFF POSITIONS TURKEY POINT FIRE PROTECTION PF-6 Electrical Penetration Rooms Staff Concern:

Two electrical penetration rooms exist for each containment building to provide separate areas for routing elecgrical cables for redundant systems located within the containment.

Cables are routed in open cable trays and are coated with Flamemastic.

A few cables,

uncoated, are routed in enclosed cable ducts.

Fire detection is provided in each penetration room.

Access to these areas is limited and fixed ladders provide access to the upper areas of the rooms.

At some elevations, access is provided by portable ladders.

A few side wall vents are provided;

however, smoke venting would not be available for all elevations.

Vent openings and access doors are not protected to prevent fire damage" from exposure fires outside the rooms.

Transient combustibles are moved through adjacent areas.

Staff Position:

l.

Access doors should be replaced with one-and-a-half-hour fire-rated Class B doors.

2.

Fire dampers rated for one-and-a-half-hour protection should be provided in the side wall vent openings.

3.

A roof vent should be provided for each room.

4.

Fixed ladder access should be provided for each elevation of the rooms.

PF-7 Reactor Control Rod Equipment Rooms Staff Concern:

These areas contain the control rod load center equipment and cables for safe shutdown equipment.

Cables in open cable trays have been coated with Flamemastic.

These areas are enclosed in a concrete wall with a substantial fire rating; however, penetrations for these walls do not preclude the potential for an exposure fire from adjacent areas.

The lack of early warning fire detection in these areas prevents a prompt, response to control and extinguish fires and thereby limit damage to safety-related systems.

Staff Position:

Early warning fire detection should be provided in the control rod equipment rooms.

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STATEMENT OF STAFF POSITIONS TURKEY POINT FIRE PROTECTION PF-8 Auxiliary Building Corridor Staff Concern:

Redundant division of safety-related cables are routed in stacked horizontal trays with about one foot separation in the auxiliary building corridor.

Cables are coated with Flamemastic and ionization-type smoke detectors are provided in the area.

Hose stations and portable extinguishers provide manual suppression capability.

Transient combustibles are moved through the area.

A fifty-five-gallon drum of lube oil was observed in the area as well as a welding cylinder cart.

Radiation protective clothing is collected at a checkpoint in open plastic barrels.

The combustibles in this area pose an exposure fire hazard to the Flamemastic-coated cables which could exceed the protection offered by the flame-retardant

coatings, Staff Position:

An automatic sprinkler system should be installed in the auxiliary building corridor.

PF-9 Charging Pump Rooms Staff Concern:

The chargi.ng pump room contains the three charging pumps for each unit.

The hydraulic coupling and pump contain about 40 gallons of oil.

Maintenance service operations introduce additional quantities of oil and combustibles into the area.

The lack of fire detection in this area preventsprompt response to limit potential fire damage.

Staff Positions:

Fire detection should be provided in the charging pump rooms.

PF-10 'iesel Oil Storage Tank Staff Concern:

The diesel oil storage tank containing 64,000 gallons of fuel oil is enclosed in a diked area.

The perimeter of the diked area is about 25 feet from the diesel generator building air intake.

A severe fuel oil fire within the diked area may impact on the operability of the diesel generator units.

Reliance on manual fire suppression does not provide adequate assurance to prevent an exposure hazard to the diesel generator units.

Staff Position:

A fixed automatic foam suppression system should be provided to protect the diked area of the diesel oil storage tank.

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STATEHENT OF STAFF POSITIONS TURKEY POINT FIRE PROTECTION PF-ll Diesel Oil Transfer Pumps Staff Concern:

The diesel oil"transfer pumps are located outside of the diked area of the diesel oil storage tank and in close proximity to the diesel generator building air intake.

A failure of the o'il supply to the transfer pumps would permit oil to drain from the storage tanks outside of the diked area.

A fire in this area would cause an unacceptable exposure to the diesel generator units.

Drawings submitted with the fire hazards analysis show the transfer pumps located in proximity to the diesel oil storage tank within the diked area.

Staff Position:

The diesel oil transfer pumps should be relocated within the diked area for the oil storage tank.

PF-12 Diesel Day Tank Room Staff Concern:

The diesel day tank rooms are located at a mezzanine level at the east end of the diesel generator building.

Access is provided by an outside staircase along the outside of the building, and terminates at a small platform at the entrance door for. each room.

Access is limited for maneuvering hose lines and magnetic card key locks are provided for the doors.

An unmitigated oil spill fire in these rooms could exceed the rating of the fire barrier, isolating this area from the diesel generator rooms.

The rooms are diked to contain the contents of an oil spill; however, drains are not provided.

Staff Position:

A fixed pipe system should be provided to permit the application of foam suppression agents to the day tank rooms from the outside grade level, or drains should be'provided to collect any spilled fuel oil to remove the combustibles from the area.

PF-13 Diesel Generator Rooms Staff Concern:

The fire protection for the diesel generator rooms is provided by fire water supplied by yard hydrants and portable extinguishers.

Fire detection for the rooms is a planned modification.

The fire hazards associated with the diesel generator units consist of 250 gallons of lubricating oil and 300 gallons of diesel fuel oil.

Additional fuel oil is provided by a 4,000 gallon elevated day tank in a separate room.

A severe fire involving combustible fluids would result in damage to the diesel generator unit and present a difficult situation for manual fire fighting access.

Manual fire suppression alone does not provide an a:ceptable level of fire protection for these essential onsite emergency power sources.

Staff Position:

A fixed automatic fire suppression system should be provided to protect each diesel generator unit.

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STATEHENT OF STAFF POSITIONS TURKEY POINT FIRE PROTECTION PF-14 Routing of Hydrogen Lines Staff Concern:

Hydrogen supply lines are routed in the auxiliary building corridor in proximity of redundant safety-related cable trays.

A failure of those lines could result in an exposure fire or explosion hazard to the cables.

Staff Position:

Hydrogen lines should be rerouted outside the area of redundant safety-related cable trays in the auxiliary building.

PF-15 Fire Areas 21 and 22 Staff Concern:

Fire areas 21 and 22 are used for chemistry laboratories and storage of acetone and other combustible fluids.

These areas are adjacent to the auxiliary building corridor through which redundant safety-related cable trays are routed.

A severe fire in these areas could result in a fire exposure hazard to cables in the adjacent area.

The lack of fire detection prevents prompt response to control and extinguish fires in these area.

Staff Position:

Fire areas 21 and 22 should be isolated from the auxiliary building corridor by 3-hour-rated Class A fire doors and by 3-hour-rated fire dampers in ventilation openings in the walls.

Fire detection should be provided in areas 21 and 22.

PF-16 Control Point Guard House

'taff Concern:

The combustible construction used for the control point guard house presents an exposure fire hazard to the safety-related

, cable trays routed above its location.

Staff Position:

The guard house should be replaced with noncombustible construction or it should be removed from the area.

PF-17 New Laundry Facility Staff Concern:

A new laundry facility is being installed with the capacity to handle large quantities of radiation protective clothing.

The area is adjacent to the auxiliary building corridor through which redundant safety -related cable trays are routed, A severe fire in the new laundry facility could result in fire exposure hazard to cables in the adjacent area.

The lack of fire detection in this area prevents prompt response to control and extinguish a fi.re in this area.

Staff Position:

A 3-hour rated Class A fire door should be provided at the entrance to the new laundry facility from the auxiliary building corridor.

Yentilation openings in the wall separating these areas should have 3-hour-rated fire dampers.

Fire detection should be provided in this area.

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STATEMENT OF STAFF POSITIONS TURKEY POINT FIRE PROTECTION PF-18 Reactor Coolant Pump Lube Oil Systems Staff Concern:

The reactor coolant pumps contain approximately 200 gallons of oil each.

The fire hazards analysis indicates that there are no unacceptable

'safety consideration results from the complete combustion of the oil associated with a reactor coolant pump.

The functions involved in potential fire damage include motor-operated

valves, which can be operated

manually, and indication instrumentation.

The lack of fire detection and suitable fire suppression for oil spill fires, and the limited access due to radiation levels, prevent an effective response to fires in the area.

It is unacceptable to not take steps to reduce the impact of a fire in this area, due to its potential magnitude, and to rely upon subsequent access for operation of valves in the containment.

Staff Position:

An oil collection system should be provided for the reactor coolant pumps to permit the removal of potential oil leakage to a safe location to prevent it from being consumed in a fire.

PF-19 Fire Water Supply Staff Concern:

The fire water supply is taken from the raw water storage tank which is used for purposes other than fire protection.

This system. does not provide a dedicated source of fire water.

A back -up source of fire water is not available for the fire water pumps.

Staff Position:

An additional fire water storage tank should be provided with a minimum capacity of 300,000 gallons of water, with connections provided to the suction of each fire pump.

The existing fire water supply should have 300,000 gallons of water dedicated to fire water use by positive means such as the use of a vertical standpipe for other water services.

PF-20 Booster Hose Stations Staff Concern:

Excess water from hose lines, which flows in excess of 100 gpm, can cause unnecessary damage to electrical equipment in vital areas.

Staff Position:

Booster hose stations with low flow capacity nozzles and ball-type shutoff valves should be provided with sufficient hose reach for all areas to provide a controlled water suppression capability for the control room, switchgear rooms, 'and cable spreading room.

STATEMENT OF STAFF POSITIONS TURKEY POINT FIRE PROTECTION PF-21 Hose Cabinet Equipment Staff Concern:

Hose cabinets should include a sufficient complement of equipment to readily serve the fire brigade needs.

Staff Position:

Each hose cabinet should include the following additional items:

a)

One portable hand light; b)

One forcible entry tool, Halligan type; c)

One 2-1/2 inch fog nozzle with ball shutoff valve; and d)

Two l-l/2 inch spanner wrenches.

Hose in hose cabinets and on hose carts should be connected and racked in accordion folds with female connection to the outside.

PF-22 Firehouse Equipment Staff Concern:

Protective clothing and a portable pump unit are located in an equipment firehouse.

A sufficient complement of equipment to readily serve, the fire brigade needs should be provided.

Staff Position:

The equipment firehouse should include the following additional items:

a)

Ten portable battery-operated seal beam hand lights; b)

One forcible entry tool, Halligan type; c)

Two two-and-a-half by two-and-a-half-inch double female adapters to permit hose.connection from pump unit to yard hydrants; d)

Storage for smoke ejector; e)

Storage for six air-breathing units and spare air bottles; f)

Storage for three portable radios; g)

Storage for spare one-and-a-half and two-and-a-half-inch

hose, gaskets, nozzles, etc.;

and h)

Additional protective clothing to outfit a total of ten men.

STATEMENT OF STAFF POSITIONS TURKEY POINT FIRE PROTECTION PF-23 Yard Hydrants Staff Concern:

Provisions should be, provided to permit an additional hose to be connected to hydrant without the need to shut down the

hydrant, as well as to control hose line pressure without throttling the hydrant valve..

Staff Position:

A 2-1/2-inch gate valve should be provided at each 2-1/2-inch hydrant outlet.

PF-24 Portable Venti1 ation Equipment Staff Concern:

Ventilation systems may not provide the capability for smoke removal to permit fire-fighting access in many areas of the plant.

Staff Position:

Three fire service portable smoke ejectors of the explosion proof type with a capacity of approximately 5,000 cfm each should be provided for fire brigade use.

PF-25 Air-.Breathing Apparatus Staff Concern:

An adequate supply of breathing air should be provided for fire-fighting and emergency operations personnel.

Existing air-breathing apparatus and units on order number 15 units.

Under a

strenuous condition such as fire-fighting>the 30-minute. rated units will only supply the air rqquirements for a person for about twenty minutes.

Spare air cylinders and recharging capability are needed to ensure access in a fire emergency.

Reliance should not be placed on offsite fire departments for breathing air, since such facilities could be committed to other use.

Staff Position:

A minimum of 30. spare air cylinders should be provided to replenish air breathing apparatus.

A onsite recharging capability should be provided, which with existing apparatus and spare air cylinders is capable of meeting the needs of 10 people for 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> at a usage rate of 3 bottles per hour per person.

PF-26 Air-Breathing Apparatus for Control Room Operators Staff Concern:

Three portable air-breathing apparatus are stored in the control room for emergency users Spare air bottles should be also provided for ready use by the control room operators.

Staff Position:

At least two spare air bottles should be stored for ready access for each air-breathing apparatus provided for control room operator's use.

STATEMENT OF STAFF POSITIONS TURKEY POINT FIRE PROTECTION PF-27 Emergency Lighting Staff Concern:

Fire damage to lighting circuits can result in the loss of both normal and emerge'ncy hard-wired lighting systems.

During a fire, emergency provisions should be provided to ensure adequate lighting for access and egress.

Staff Position:

Fixed emergency lighting should be provided, consisting of sealed beam units with individual battery power supplies for the following areas:

a )

Control room; b )

Cable spreading area; c }

Switchgear rooms; and d )

Auxiliary building access corridors.

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