ML19207A986

Safety Evaluation Supporting Amend 23 to License DPR-72

ML19207A986
Person / Time
Site:	Crystal River
Issue date:	07/27/1979
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML19207A984	List: ML19207A983 ML19207A986 ML19207A988
References
NUDOCS 7908230117
Download: ML19207A986 (60)

Text

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UNITED STATES l'

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NUCLEAR REGULATCRY COMMHSiCN

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SAFFf E'/ALUAT:CN BY THE OF ICE OF NUCLUR REACTOR REGULATI0fl SUPOCRT NG AMENCMENT NO. 23 TO LICENSE NO. JPR-72 FLORICA 70' ER CORPORATICN, E AL

, CRYS AL R!vER UNIT 3 NUCL DR GENERATING P'.At47 CCCXE NO. E0-302 Jated.

e'uly 27, 1979 79082301(7 '

.;6i,3 13

FA3LE OF CCNTENTS

? AGE 1.0 Introduction L-l 2.0 Fire Protection Guidelines 2-1 2.1 General Design Criterion 3 2-1 2.2. Supplementary Guidance 2-1 3.0 SL?."ARY OF MC'DIFICATIONS 3.1 Safe Snutdown Systems 3.

1 3.2 itre Detection Signaling System 3_,'

3.3 Fire Pump House Floor Drains 3-1 3.4 Yard Post Indicator Valves 3_t 3.5 Reactor Containment Building Standpipe System 3_t 3.6 Drip Protection 3_t 3.7 Cable Spreading Rocm Halon System 3_;

3.8 Cable Spreaning Rcom Recirculatten Fans 3_;

3.9 Control Room Portable Fire Extinguishers 3_;

3.10 Emergenc; Lighting 3_;

3.11 Portable Radici 3.12 Fire Doors 3.13 Electrical Cable and Other Penetrations 3_ _!

3.14 Cable Spreading Room Floor 3_

3.15 Automatic Fire Cetection Systems 3_;

3.le Waste Drumming Station 3_3 3.17 Fire Stops 3_3 3.18 Steam Driven Emergency Feed Pump 3_3 3.19 Control Room 3_3 3.20 Bettery Room Ventilation 3_2 3.21 Diesel Generator Rooms 3_;

3.22 Fire Alarm Casupervised Circuits 3_;

3.23 Fire Detector Locations 3_;

3.24 Interior Fire Hose Stations 3_,

3.25 Evaluations of Fire Consequences for Certain Areas 3_,

3.26 Batterv Powered Emergency Lignting 33 3.27 Auxiliary Building at Elevation 119 Feet 3.23 Auxiliary Building at Elevation 95 Feet 3_j; 3_

3.29 Make-Cp Pump Recms 3,

3.30 Intermediate Building at Elevation 119 Feet 3.j 3.31 Reactor Contain=ent Building Analysis 3_g 4.0 E7AI. CATION CF PLANT F"ATURES

.1 Safe Shutdown Systems 3_t 4.2 Fire Detect:.on and Sigatiing System

,_t 4.3 Fire Control Systems a>

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? ;c.I 4.3.1 Water Systems 2-3 4.3.1.'

Water Supply 4.3.1.2 Fire Pumps a.3.1.3 Fire Water Piping System 4.3.1.4 Interior Fire Hose Stations 4.3.1.5 Water 2icpression Systems 4.3.1.o Toam 4.3.1.7 Effr. cts of Suppression Systems on Safety Systems 4.3.2 Gas Fire Suppressica Systems

_6 4.3.3 Portable Fire Extraguishers 44 Ventilation Systems and 3reatalag Equipment

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4.4.1 Smoke Removal 3_-

a.4.2 Filters

,_7 4.4.3 Breathing Equipment

_g 4.5 Floor Drains

.2 4.e Light.naavsteta

.-o 4.s Communication avstems 4.3 Electrical Cable

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4.9 Fire Barrier Penetrations

-to 4.9.1 Fire Doors

.-l0 e.9.2 Ventilation Duct Penetrations

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• .9.3 Electrical Cable and Other Penetrations 2_;t 4.10 Separatten Criteria

,.-11

,4.11 eire Barriers 4-13

,*.12 Access and Egress 4-13

• .13 Toxic and Corrosive Cembustion Products 4.14 Nonsafety-Related Areas 7'l.

s-4.15 Instrument Air

-l 5.0 E7AI.CA~ ION OF SPECIFIC PI. ANT APS.AS 5.1 Auxiliary Building At Elevation 162 Feet 5.2 Auxiliary Suilding At Elevation 143 Feet j_?

5.3 Auxiliary Building At Elevation 119 Feet 5.4 Auxiliary Building At Elevation 95 Feet I_ ':

$~i 5.5 Auxiliary Building at Elevation 75 Feet 5.6 Containment Electrical Penetratica Area:

3-1 c.i intermediate Building At Elevation 119 Feet

.a 5.3 Intermediate Building At Elevatton 95 Feet i_'g t

5.9 Reactor 3ailding 5.10 Control Room

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._t1 5.11 Cable Spreading Room

-1 o..., 5.-.t:hgear Rooms 5.13 3atterv Rooms S,' #

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5 5.14 Diesel Generator Rocms

!3 f 19 5.15 Turbine Building 2-5.16 Yard Area 3-20 6-I 6.0 ADMINISTRATI'/E CONTROLS 7-1 7.0 TECHNICAL SPECIFICATIONS 3_t 3.0 CONCLL'SICNS 9_t 9.0 CCNSLT.TANTS' pypcg7 4

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1.0 INTRCDCCTICN Following a fire at the Browns Ferry Nuclear Station in March 1975, the Nuclear Regulator / Commission initiated an evaluation of the need for improving the fire protection programs at all licensed nuclear power plants.

As part of this continuing evaluation, the NRC, in February 1976, publisheu a report by a special review group entitled, " Recommendations Related to Browns Ferry Fire," NUREG-0050. This report recoc: mended that improvements in the areas of fire prevention and fire control be made in most existing facilities and that censideration be given to design features that wotid increase the ability of nuclear f acilities to withstand fires without the loss of important functions.

To implement the report's recommendations, the NRC initiated a program for reevaluation of the fire protection programs at all Licensed nuclear power stations and for a comp rehens ive review af all new license applications.

The NRC issued new guidelines for fire protection programs in nuclear power plants which reflect the recommendations in KREG-0050. These guidelines are contained in the following documents:

a.

" Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," KREG-75/087, Section 9.5.1, " Fire Protection."

May 1976, which includes " Guidelines for Fire Protection for Nuclear Power Plants" (3TP APCSB 9.5-1), May 1,1976.

b.

" Guidelines for Fire Protection for Nuclear Power Plants * ( Appendix A to 3TP APCS 3 9.5-1), August 23, 1976.

c.

"Supp lementa ry Guidance on Inforsacion Needed for Fire Protection Program Evaluation," October 21, 1976.

d.

" Sample Technical Specifications," May 12, 1977, e.

"Nucleat Plant Fire Protection Functional Responsibilities, Adminis-trative Controls and Quality Assurance," June 14, 1977, f.

" Manpower Requirements for Operating Reactors," memo from E. G. Case to R. Boyd, V. Stello, and R. Mattson dated May 11, 1973.

All licensees were requested to: (1) ccmpare their fire protection programs with the new guidelines; and (2) analyze the consequences of a postulated fire in each plant area.

We have reviewed the licensee's analyses and have visited the plant to examine the relationship of safety-related components, systems and structures with both combustibles and the associated fire detection and suppression systems.

Cu-.eview has been limited to the aspects of fire protection witnia.se NRC's jurisdiction.

t.e., those aspects related to the protection of public health and safety. We have not considered aspects of fire protection associated wita life safety af

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onsite personnel and with property protection unless they impact the health and safety of the public due to potential release of radioactive material.

This report sumarizes the status of our evaluation of the fire protec-tion program at Florida Power Cc poration's Crystal River Unit 3 plant.

1-2

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2.0 FIRE PRO *ECTION CUIDEI.IN_ES 2.1 Gene-al Design Criterion 3

" Fire Protectig The Ccemission's basic criterion for fire protection is set forth in General Design Criterion 3, Appendix A to 10 CFR Part 50, which states:

" Structures, systems, and ccmponents impo rtant to safety shall be designed and incated to minimize, consistent with other safety requiremen ts, the probability and effect of fires and explosions. *

"Nenccmbustible and heat resistant materials sna11 be used wherever practical throughout the unit, particularly in locations such as the centainment and the control rocm."

" Fire detection and protection systems of appropriate capacity and capability shall be provided and designed to minimize the adverse effects of fires on structures, systems, and components important to safety."

" Fire fighting systems shall be designed to assure taat their rupture or inadvertant operation does not s i gn2. fi-cantly impair the safety capability of these structures, systems, and components."

2.2 Surelementarv Guidance Guidance on the implementation of GDC-3 for existing nuclear power plants has been provided by the SC s'.af f in " Appendix A" of Branch Technical Position 9.5-1, "Guic ines for Fire Protection for Nuclear Power Plants".

Appendix A provides for a comprehensive program assuring a substan-tial level of fire protection, beycud minimums that might be deemed to satisfy GDC-3.

The overall objectives of the fire protection program embodied in BTP 9.5-1 and Appeudix A, are to:

(1) reduce the likelihood of occurrence of fires; (2) promptly detect and extinguish fires if they occur; (3) maintain the capability to safely shut down the plant if fires occur; and

6) prevent the release of a significant amount of raulcac.ive material if fires cccur.

2-t m 313

We bave used the guidance of Appendix A as appropriate in our teview. We have evaluated alternatives proposed by the licensee to various specific aspects of Appendix A using the overall objectives outlined above to assure that these objectives are met for the actual relationship of combustibles, safety-related equipment and fire protection features of the facility.

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3.1 Si.TARY CF MCDIFICATIONS s

The licensee p'ans to make certain plant modifications to ;mprove :ne t' ire pr: tev an er,e sm as 4 tesult of both his and t2e staff's eval 14::ane The pr:pused todifications are su==ari:ed below.

The isolements:ica sened-ula far :nese w difications will be proposed by the licensee wi:hin 30 :a"s from the da:e of :nis Safety Evaluation. The sectivas n :qis repcrt which discuss the aciifications are noted in parentheses.

Certain t ems listed below are marked with an asterisk ta indicate that the VRC staff will require additional information in the form of design details, test results, or acceptance criteria to assure that the design is acceptable prior to tmplementation of these modifications The balance of other modi-f; cations nas been described in an acceptable level of deta:1.

x3.1 Safe Shutdown Systems A remote safe shutdown centrol station will be installed which is independent of the control room or cable spreading room. (4.1)

(4.3.2)(5.10.6)(5.11.6) 3.2 Fire Detection Signaline Svstem Emergency power wt11 be supplied to those portions of the detection and signaling system serving areas containing safety related equipment. (4.2)(4.3.1.5) 3.3 Fire Pumu House Floor Drains The floor drain pipe trench in the fire pump house will be modified to preclude spreading of an oil spill (4.3.1.2) 3.4 Yard Post Indicator Valves Traffic guards will be installed around the yard post indicator valves. (4.3.1.3)(5.16.6)

• 3.5 Reactor Containment Building Standoice System A fire standpipe system will be installed inside the reactor con-tainment building with a suitable number of stations at each elevatic't in order that potentirl fire areas of the containment can be reached by an effective fi.e stream. (4.3.1.4)(5.9.6) 3.6 3rio Protection Drip protection will be provided for safety-related motor control centers in areas where autcmat:c sprinkler syste=s are installed.

(4.3.

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Cable Screading Rocm Halen Fi;e Protection A second set of halon storage spheres will be installed as backup to the present halon system in the cable spreading room.

(4.3.2}

(5.11.6) 3.3 Cable Soreading Rocm Recirculation t'a,cs The cable spreading room recirculation fans will be powered f ecm an emergency power source. (4.3.2) 3.9 Control Room Portable Fire Extinguishers Two water-type fire extinguishers will be ;nstal'ed ;n the ::ntroi rocm.

(4.3.3) 3. '. )

Emergency Lizhting Emergency lighting will be installed in the makeup pump areas.

(4.6) 3.11 Portable Radios At least 2 portable radios will be reserved for use of fire brigade semcers. (4.7) 3.12 Fire Dcors 3.12.1 A 3-hour fire dcor will be installed in the wall opening separating the shop facilities from the auxiliary building. (4.9.1) 3.13 Electrical Cable and other Penetrations All openings in the fire wall between the turbine and intermediate buildings will be upgraded to at least a three-hour fire rating.

(4.9.3)

• 3.14 Cable Screading Rocm Floor and ceiling Tae cable spreading room floor will be coated / insulated to provtde a one-hour fire resistance. The metal plates in the ceiling will be coate: with a three-hour fire resistance rated material.

(4.11)

• 3.15 Autematic Fire Detectica Svstems Automatic fire detection systems wtli be installed in the following areas:

a.

Auxiliary building-elevation 119 feet in :cces 1, 5. 7, 13, 25 and 26.

(5.3.6)(5.6.6.)

b.

Auxiliary butiding-elevation 95 feet in :enes 17,

'S, and 32.

f5.4.6)

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c.

Auxilia ry building-elevation 73 feet in :enes 1 and 2.

(5.5.6) d.

Intermediate butiding-elevation 119 feet, in the pressurtzer control cabinet atea and in the containment personnel access area, and zones 1 and 4 (5.7.6)(5.o.6) e.

Intermediate building-elevation 95 feet for the steam driven auxiliary feedwa ;er pump area. (5.3.6) f.

In the reactor containment building in the vicinity of the reactor coolant pumps, in ventilation units, and near cable concentrations, throughcut the reactor building. (5.9.o) 3.16 Waste Drummine Station The waste drumming station and/or hose reel will be relacited to permit free access to the fire hose reet in tae area. (5.3.6)

• 3.17 Cable Trav Fire Stops Cable Tray ! ire stops will be installed in the following areas:

a.

Auxiliary building at elevation 95 feet in :ones 5 and 13.

(5.4.6) b.

Contaiament electrical penetration areas on the non-safe-guards instrumentatica cable runs between safeguards chaanels A and 3.

(5.6.6) c.

On elevations 95 and 119 feet in the reactor building.

(5.9.6)

• 3.18 Steam Driven Emergenev Feedwater pumo An automa'. Lie fire detector system id suitable fire b:rrters will be installed to protect safety-related cables in the emergency feedwater pump area. (5.3.6) 3.19 Control Rocm 3.19.1 Combustible supplies in the control rocm will be removed or properly stored in metal cabinets. (5.10.6) 3.19.2 The kitchen stove in the control rocm will be acved to a nonsafety-related area and/or discoanected. (5.10.6) 3.19.3 Continuous observation by the security guard will be maintained on the control room leor until the station security system ts completed. At that time the door will be equtpped wtth automatic 3-3

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closure and will require key cards for opening f rom the outs tde.

The guard has been instructed to close this door in the event of

' fire. (5.10.6) 3.20 Batterv Room Ventilation The battery room exhaust ducts will be relocated near the ceiling.

One monitor for each battery room shall be provided to locally indicate ventilation flow. (5.13.6) 3.21 Diesel Generator 3coms 3.21.1 Curbs will be provided at doorways in the diesel gene:ator rooms.

(5.14.6) 3.21.2 The diesel generator floor drain system will be modified by installation of weirs to eleminate this avenue of potential fire spread. (5.14.6) 3.21.3 The Smoke detectors in the diesel generator control rocms will be relocated tc improve the response time. (5.14.6) 3.21.4 A sump alarm will be provided to ensure that the control room perscanel are alerted to a potential diesel oil fuei leak.

(5 !4.6) 3.22

[3pa Alarm Unsucervised Circuits

!!onthly testing will be required on unsupervised circuits leading from the fire alarm control panel to the annunciator panel.

(4.2)

• 3.23 Fire Detector Loc;tions Provide drawings for staff review on locations of new fire detectors.

(4.2) 3.24 Interior Fire Hose Station Verify that all safety-related areas including the control complex can be reached with at least one effective fire hose stream etilizing no more than 100 feet of hose. (4.3.1.4)

• 3. 25 Evaluation and Corrective Action For Fire Consecuences In Certain Areas Evaluate the fire consequences in certain areas of tne auxiliary and intermediate buildings wcich contain redundant safe shutdown electrical cables. In some of these areas automatic water suppres-sion systems and/or barrie:s wtll be required to prevent unaccept-able fire damage, the design of vnich will be examined by the 3-e

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staff prior to its implementation.

( a. 3.1. 5 )

i.'io t e :

Items 3.23, 3.29, 3.31 and 3.32 are related to the abcNe evalaatton and corrective actions) 3.26 Battery Power Emerzencv Lighting Battery powered lighting units will be provided for areas 1, 5, 7, and 13 in auxiliary building elevatica 95. (a.6) 3.27 Auxiliarv Building at Elevation 119 Feet Protective measures for safe shutdown systems will be provided in fire zones 1 (west end), 7, and 13 by one of the f-:llowing measures:

(1) reroute certain cables required for safe snutdown; '2 provide a wet pipe fastble link water spray system to protect safe snutdcwn cables in the area; (3) provide a fire wall to protect circuits required for safe shutdown.

The east end of fire zone 1 and all of zone 5 vill be protected against postulated fires from transient combustibles with wet pipe fusible link sprinkler systems with *.he sprinkler heads located below the cable trays. (5.3.6)

• 3.23 Auxiliarv Building at Elevation 95 Feet Protective measures for safe shutdown systems will be provided in fire zones 1, 5,13 and 16 by one of the following measures: (1) reroute certais cables required for safe shutdown: (2) provide a wet pipe fusible link water spray system to protect safe sautdcwn cables in the area; or (3) provide a fire wall to protect circuits required for safe shutdown. (5.4.6) v3.29 Make-Up Pump Rooms An automatic detection system and suitable fire barriers around safety related cables will be provided for the make-up pump rooms. (5.4.6)

• 3.30 Intermediate Building at Elevation 119 Feet Protective measures for safe shutdown systems.ill be provided in fire zone 5 by the installation of a wet pipe fusible link sprinkler system to extinguish postulated fires in clothing, paper or transiest materials.

Reduadan. safety related caoles in the area will be examined to determine the effects on safe shutdcwn capability of ne loss of all cables. If this examination shows that safe shutdcwn capabi-lity will be lost, one of the following appropriate measures w;11 3-5 3bA. -, <My -

be taken: (1) reroute certain cables required for safe snutacwn; or (2) provide a wet-pipe' fusible-1:nk water spray system ta protect against fires in clothing and other <naterials and to pro-tect redundant safe shutdown cable trays tn the area.

(5.7.6;

• 3.31 Reactor containment Building Analysis The results of a analysis for ::oce 1 in the reactor butiding wtil be provided which demonstrates that redundant safe shutdown systems will not be damaged by an unsuppressed f tre.

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TA3LE 3.1 s

IMPLE.ENTATION DATES FOR PROPOST.D MCDIFICATIONS MCDIFICATION IMPLEMENTAT!0N DATE3 "3.1 Safe Shutdown S'.rstem TO 2E PRCEOSED 3.2 Fire Detec ton Signaling System 3.3 Fire Pump House Floor Drains 3.1 l'ard Post Indicator Valves

'3.5 Reactor Containment Building staalp.pe Syste:

3.6 Drip Protection 3.7 Cable Spreading Room Halon Etre Protection 3.3 Cable Spreading Rocm Recirculation Fans 3.9 Control Room Portable Fire Extinguishers 3.10 Emergency Lighting 3.11 Portaole Radios 3.12 Ftre Doors 3.13 Electrical Cable and Other Penetrations

• 3.14 Cable Spreading Roco Floor and Ceiling

• 3.15 Automatic Fire Detection Systems 3.16 Waste Druming Station and/or Hose Statica Relocation 3. '. 7 Fire Stops

• 3.13 Steam Driven Emergency Feedwater Pump 3.19 Control Rocm 3.20 Battery Roca Ventilation 3.21 Diesel Generator Rooms 3.22 Fire Alarm Unsupervised Circuits

• 3.23 Fire Detector Locations 3.24 Interior Fire Hose Stations

• 3.25 Evaluation of Fire Consequences in Certain Areas

• 3.26 Loss of Normal and Emergency Lighting Evaluation

• 3.27 Auxiliary Building at Elevation 119 Feet

• 3.23 Auxiliary Building at Elevation 95 feet

• 3.29 Make-Cp Pump Rocms

• 3.30 Intermediate Building at Elevation 119 Feet

• 3.31 Reactor Containment Building Analysis 3-7 hp.,, < r~s t)M I

4.0 EVALUATION OF PLANT FTA33ES s

4.1 Safe Shutdown Systems There are several arrangements of safe shutdown systems which are capable of achieving safe shut down subsequent to a fire. The exact arrangement available in a fire situation will depend upcn the effects of the fire on such systems, their power supplies, control stations, and interconnecting control and instrumentation cabling.

To preclude single event from affecting redundant systems, a

these systems are separated into two safety divisions, eitner of which would be capaole of achieving safe shutdown.

During or subsequent to a fire, safe shutdown could be achieved asing safety-related equipment such as.

the reactor trip system; the borated water tank, makeup pumps, and parts of the letdown and makeup and chemical additive systems for volume and reactivity control; emergency feedwater system; condensate storage tank; decay heat removal system; and steam relief. These safety-related systems could be used to bricg the reactor down to hot shutdown conditions, and then be used for cooldown to cold shutdown condi-tions. Supporting systems and equipment such as the emergency diesel generators, engineered safety features batteries, and cooling water systems would also be required.

We have evaluated the separation between redundant safe shutdown systems and components to determine that they are either separated from each other or protected by suppression systems such that a fire will not affect redundant equipment, and therefore a suffi-cient number of systems and components will be available to perform their shutdown function following a fire. The adequacy of separation between redundant shutdown equipment is discussed in other sections of this report.

We have also evaluated those control and indication functions necessa ry to properly and efficiently accomplish remote safe shutdown follo,ing a fire involving safety-related equipment in the control room or cable spreading rocm. This evaluation con-sidered equipment location, accessibility, redundancy, cable routing, and com=unication. The present remote shutdown capability appears to be inadequate to accomplish proper and efficient safe shutdown for the following reasons:

Power supplies for instrumentation necessary for safe shutdcwn a.

are presently located in the control room.

b.

Control and instrumentat;on cables necessary for safe shutdeva are presently routed from the controi roco througn the caole 9 6u.3d

spreading room to the remote shutdown panel or switcagear with no : solation capacility.

c.

Sufficient control and parameter monitoring capability does not presently exist at the remote shutdown panel.

d.

Local feedwater and steam relief control stations are rela-tively inaccessible and capability for control of taese necessary functions from the remote shutdown panel presently does not exist.

The licensee has committed to upgrading the remote safe shutdown system to satisfy the above concerns. The proposed design changes will be submitted for review and 3cceotance by the SEC staf f prior to the tmplementation of these modifications.

'4e find that, subject to implementation of the above descr: bed modifications, the safe shutdown systems satisfy the objectives identified in Section 2.2 of this report and are, therefore, acceptable.

4.2 Fire Detectica and Siznaline Svstem The plant has a protective signaling system that transmits fire and supervisory signals to the control room where audible and visual alarms are provided. The system transmits alarm signals it:m actuation of area and ventilation system fire detectors, actuation of automatic suppression systems (sp rinkle rs, water spesy, Halon and carbon dioxide), fire pump running, and manual pull stations. Supervisory signals are transmitted from tamper switches on some water suppression system control valves, fire pump trouble and low fuel, fire water tank low level, and carbon diox:de system high and low pressure.

Portions of the fire detection and signaling system are not provided with an emergency power supply on loss of offsite and station power. The licensee has proposed to provide emergency power to those portions of the detectors and signaling system serving areas containing safety-related equipment. Circuits in the fire detection and signaling system are electrically supervised and alarm in the control room except for the circuits leading from the control panel to the annunciator panel. The annunciator panel in the control room is not listed for signaling system use by a recogni:ed national testing lace ra to ry.

Increased testing of this panel and the unsupervtsed circuits leading to it is being required.

Area fire detection is provided on all six levels of the control

omplex, the office bu;1 ding, the taroine bu;1 ding heater bay.

and the fire pu=p house.

The ventilation sysr>;s in var:ous porticas af the plant are also provided w :n fire detectors.

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n WG y M1 Fire detectors providing area coverage tre ionizatian smoke detectors; detectors in the ventilacion systems are both toni:a-tica smoke detectors and rate-compensation heat detectors. The automatic water spray, pre-action sprinklers and carbon dioxide systems are actuated by rate-compensation heat detectors; the Halon system in the cable spreading room is actuated by a cross-

oned smoke detection system; the charcoal filter water spray systems are actuated bv fixed-temperature heat detectors.

There are areas in the auxiliary, intermediate and reactor build-ings wnich contain safety-related equipment and electrical cables which are not provided with fire detection. The licensee has proposed to install fire detectors in most of these areas. During the fire protection review, certain other areas were identified 2s requiring fire detection.

The licensee has agreed to provide detectors in these areas. The licensee has also been asked to provide drawings on the proposed new fire detector locations.

We find that, subject to implementation of the above der:ribed modifications, the fire detection and signaling system satis fies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

.3 Fire Control Systems 4.3.1 Water Systems e.3.1.1 Water Sucoly Water for fire protection is supplied by three Lire pumps taking suction from two ground level storage tanks. The tanks each have a capacity of 360,000 gallons and are reserved for fire protec-tion use only. In addition, an emergency connection is provided so that the Unit 3 nuclear plant can be supplied from the adjacent Unit 2 fossil fuel plant fire water system.

We find that the fire water system satisfies the objectives identified in Section 2.2 of this report and is therefore, accept-able.

4.3.1.2 Fire Pumus The three fire pumps each have a capacity of 2,000 gpm at 125 psi. Two of the pumps are diesel engine driven 2nd the third is electric motor driven. A small electric jockey pump is provided to maintain pressure on the fire water system; the f:re pumps are arranged to start autcoatically vnen a large water demand causes a drop in the system pressure.

The capacity of any two of the fire pt=ps is adequate to provi2e the largest design water demand

~

.-3 h 330

f cm automatic suppression systems plus hose streams for manual firefightig.

The capacit'f of one pump is adequate for fire suppression in safety-related areas.

In the fire pump house, a floordrain pipe trench extends the full length of the building and a diesel oil spill fire could damage all three pumos or their control systems. The licensee has proposed to modify the pipe trench to preclude such damage.

We find that, subject to the implementation of the acove described modification, the fire pumps satisfy the objectives of Secti:n 2.2 of this report and are, therefore, acceptabla.

4.3.1.3 Fire Water piping Svstem The fire pumps discharge into an underground fire loop that encircles the plant supplying fixed water suppression systems, interior fire hose stations, and exterior fire hydrants.

The suction and discharge piping and valves at the fire punp are arranged so that a single pipe break will not cause less of supply fr:m all three fire pumps. Sectionalizing valves of the post indicator type are provided on the fire loop to allow isola-tion of various sections for maintenance or repair. Scme of the sectionali:ing valves are exposed to vehicular traffic damage and the licensee has proposed to install guard posts.

Fire hydrants are strategically placed ar:und the exterior of the plant. Each hydrant lateral is provided with an auxiliary gate valve to permit the hydrant to be repaired without shutting off a section of the fire loop. A hose house with 250 feet of 2 -inch and 200 feet of 1-1/2-inch woven jacketed fire hose, nozeles and other manual firefighting tools is provided at eacs hydrant.

Certain interior control valves on automatic sprtskler systems are electrically supervised; however, valves on the exter:.or fire loop and some interior valves are not supervised. The valves on the fire water system are provided with plastic seals and are periodically inspected.

We find that subject to the implementation of the above described modification, the fire water piping system satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

+. 3. '.. a Interior Fire Hose Stations Hard rubber 1-1/2-inch fire hose in 30-feet lengths has been provided on reels in the turbine, intermediate, auxiliary and shop buildings.

!.:.nen fire hose in 50-feet lengths has been pr:vided :n the office building. Cott:n jacketed, rubcer lined

'ieo331

fire hose has been provided outside the cable spreading rocn.

The interior fire hoses are equipped with electrical type fog noz:les.

There is insufficient fire hose on the reels to rea-h all areas; however, plant firefighting procedures call for the fire brigade to respond with 2dditional woven jacketed fire hose to be attached to the hard rubber hose if necessary to provide adequate length.

The licensee has verified that, with this arrangement, all safety-related areas, including the control complex, can be reached with at least one effective fire hose streaa util: zing no more than 100 feet of nose.

The licensee has proposed to install a standpipe with a suitaole number of stations inside the reactor builhag.

We find that, subject to the above described modification, the interior fire hose stations satisfy the objectives identified in Section 2.2 of this report and are, therefore, acceptable.

a.3.1.5 Water Suceression Systems Automatic wet pipe sprinklers are provided in the two lower levels of the turbine building, the office building record storage vault, and the fire puep house. Automatic pre-accion sprinklers are provided in the diesel generator rooms, diesel generator controls rocms and elevation 95 feet of the control ccmplex.

Automatic water spray systems are pre rided on the turbine lube oil storage tank 2nd purifier, hydrogen seal oil unit, feedwater pump console, charcoal filters, yard transformers, and the turbine building wall adjacent to the yard transformers. The existing systems have been designed to provide ecceptable protection for the hazards covered.

The licensee has been :P uested to evaluate fire consequences in certain areas of the auxiliary and intermediate buildings which contain redundant safe shutdown equipment electrical caoles. In some of these areas, automatic water suppression systems will be required to prevent unacceptable fire damage, the design of which will be examined by the staff prior to its implementation.

We find that, subject to the tmplementation of the above described modifications and evaluations, the water suppression systems sa:iafy the objectives identified in Section 2.2 of this report and are therefore acceptable.

a.3.1.6 Foam The plant has not been provided with fixed foam fire suppression systems and none are being required. Manual foam fire suppression is available for small fires. We find that manual foam capability 7.

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satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

e.3.1.7 Effects of Suoeression Systems on Safetv Svstems Fixed fire suppression systems have not been installed where their operation or failure could cause unacceptable jamage to safety-related equipment.

Water discharge from the pre-action autcmatic sprinkler system ta the diesel generator rooms would affect only one of the redunc; ant units.

uter used for manual firefighting will be removed by floo r drains in all areas except the control c mplex here :: wil be drained through an equipment hatch and the stair :ower, or through doorways leading into the tarbine building. The licensee will provide drip protection for safety-related motor control centers in areas where autcmatic sprinkler systems are installed.

We find that subject, to the implementation of the above described modification, the effects of suppression system operation on safety-related systems satisfies the objectives identified in Section 2.2 and is, therefore, acceptable.

4.3.2 Gas Fire Suppression Systems An automatic Halon 1301 system has been provided in the cable spreading room. The system, utilizing eleven spherical storage containers distributed throughout the room, tras been designed to meet the requirements of VF?A 12A with a minimum agent concen-tration of five percent. Fans have been provided in the cable spreading room to properly distribute the agent after discharge.

The licensee has proposed to provide emergency power to these fans.

The licensee has proposed to install a second set of Halon storage spheres as a backup agent supply.

The seconcarf supply will utilize the existing autcmatic fire detection /actuanon system with a manual throwaver to be operated af ter discharge of the primarf supply.

Because of concerns about effectiveness and reliability, gaseous fire suppression systems alone are not acceptable protection for areas containing large quantities of redundant safe-shutdown electrical cables. Therefore the licensee has proposed to provide a means to achieve safe shutdown, even if the cable spreading room or control room are lost-due to fire damage, frem remote cone.rol panel (.O located in 41c0 alt sw:.tchgear room 3A and 23.

An autcmatic carbon dioxide system has been provided to protect the turbine generator bearings and ma;n feedwater pu=ms.

The system is supplied by a 5-ton low pressure tank sac is :esigned

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to meet the requirements of NFPA 12 for local application s/ stems.

Thir system does not protect any equipmenq watch is required for safe shutdown.

We find that, subject to the implementation of the above described sodifications, the gaseous fire suppression systems satisfy the objectives identified in Section 2.2 of this report and are, therefore, acceptable.

4.3.3 Portable Fire Extinguishers Pertable fire extinguishers have been provtded throughout the plant except inside containment during power cperation, in accor-dance with the requirements of the NFPA Standard. The licensee nas provided two water type extinguishers in the centrol room to combat small deep-seated fires in electr: cal installation and ordinary combustibles.

We find that, the utilization of portable fire extinguishers satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

4.4 Ventilatica Systems and Breathing Ecuipment 4.4.1 Smoke Removal The plant does not have exhaust systems designed specifically for ameke removal except for fusible link operated roof vents in the turbine building and a smoke detector actuated exhaust uode capability in the control complex air-handling system.

The normal and/or emergency ventilation systems in most areas can be used for smoke removal; however, the effect.veness of these systems is limited because: fans and other equipment may not be able to withstand high temperatures and could be rendere t inopera-tive by heat from a significant fire; the capacity and enafigura-tion of the normal air-handling systems may preclude eifective smoke removal; heat or smoke actuated dampers may close preventing air movement; and ventilation system pcwer supplies could be affected by the fire.

In view of the potential limitations of dependence upon normal air handling systems for smoke removal, the licensee has provided portable smoke exhausters and ducting for fire brigade use which we find acceptable for nuclear pcwer facilities.

The smoke removal capability satisfies the obje:ti7es identified in Section 2.2 of this report and is, therefore, acceptable.

4.4.2 Filters Charcoal filters are enclosed in substantial metal housings and protected by aut:matic deluge water suppressi:n systems.

The filters are sepa ra ted frem ignir.ica sources and tne amount of "I'bu334 i-7

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contained radioactive material is insufficient to cause ignition.

Therefore, filter units do not present a significant fire exposure to safe shutdown systems.

We find that fire protection for the filters satisfies the objec-tives identified in Section 2.2 of this report and is, enerefore, acceptable.

4.4.3 Breathine Eouipment A sufficient number of self-contained breathing units with spare bottles and refill capability is provided at the facility to supply the operating crew and fir-brigade for a period of at least 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. We find that the breathing equipment satisfies the objectives identified in Section 2.2 of tt '.s report and is, therefore, acceptable.

4.5 Floor Drains The floor drains from the fire pumps building and the diesel generator rooms drain by long runs of piping into tue turbine building sump.

The reactoe building tendon g.ilery sump is pumped to the nuclear s:rvices seawater sump. It is then pu= ped to the turbine building sump. The turbine building sump receives all drains frem the turbine building. The turbine building sump is discharged to the settling pond which is located outside the building.

The licensee has proposed to modtfy the floor drain system in the diesel generator rooms as discussed in Sections 5.14.6.

Floor drains in the reactor containment building and the auxiliary building are treated as potentially contaminated drains. The:e drains are collected in the auxiliary building sump and are processed as nuclear waste.

We find that, subject to the implementation of the proposed modi-ficatica, tse floor drains system satisfies the objectives identi-fied in Section 2.2 of this report and is, therefore, acceptable 4.6 Eighting Svstems Normal lighting is supplied from nonsafety-related pcwer sources.

Emergency lighting is prnvided in the Reactor Building, Auxiliary Building and Turbine 3uilding.

Emergency lighting fixtures are identical to the ones which provide normal lighting but are on separate circuits. They are located throughout these buildings to provide emergency lighting for accest and egress and in acces-sible areas in which equipment used for safe snutdown is located excepu for the decay heat pits and the makeup pump rocms.

The decay beat pits are not normally occupied or entered. ?over for

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the emergency lignting circuits is automatically supplied frem the emergency diesel generator in the event of loss of normai sources.

In the control complex, redundant lighting systems are provided in all areas. Power for each lighting system is automatically supplied frem the emergency diesel generators, in the event of loss of normal sources. The Control Room, in addition to the redundant lighting systems discussed above, has a third lighting system which utilizes DC power from the plant batteries.

The licensee has proposed to install emergency lightins in the

=ake-up pump area as a result of a study of areas that must be manned for safe shutdcwn and in access and egress routes fo all fire areas.

The licensee has proposed to physically identify and mark the emergency lighting fixtures located thro _;hout the power plant.

The licensee has provided the results of a study identifytud any safety-related areas where a fire could cause loss of both normal and emergency lighting so that firefighting access would be hampered.

As a result of this study battery powered lighting units will be provided for areas 1, 5, 7 and 13 in the auxiliary building eie ration 95.

We find that, subject to implementatica of the proposed modifica-tions described above, the emergency lighting systems satisfy the objectives identified in Section 2.2 of this report and are, therefore, acceptable.

4.7 Cocmunication Svstems The plant has both a telephone type paging / call-back system for normal c:mmunications and, in lieu of a sound powered system, a separate safeguards paging / call-back system with stations located in areas containing safeguard and safe sautdown equipment. Both systems can be supplied power frem the emergency diesel generators.

Separate maintenance and reactor building jack station systems are also provided.

In addition, the plant Les portable radtos available, two of which are reserved for use of fire brigade mddbers.

We find that, the cummunication systems satisfy the objectives identified in Section 2.2 of this report and are, therefore, accep t:: ale.

a.3 Electrical Cable Electrical cables used in the plant are classified as power, centrol, 2nd instrumentatica.

23

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Power cables used inside and outside the reactor containment building are insulated with high temperature Kerite insulation and jacketed with fire retardant material of Kerite ar neoprene.

The pcwer cables outside the containment building with conductors of sine AWG No. 6 or larger have a galvanized-steel, :nterlocked armor protective cover.

Instrumentation cables for the most part use silicone rubber for insulation and jacket material.

Coaxial and triaxial cables use polyethylene insulation and most of these cables use asbestos ce glass-braid jacket.

Control cables 3 e insulated with Ker:te ER and are jacketed witn-the same material.

The licensee has performed a flame test on the cables similar to the tests required by IEEE 383-1974. The tests were performed on cable trays filled to moch up the actual in plant conditions.

All cables passed the flame test with the exception of instrumenta-tion cables manufactured by Rockbestos Ccmpany. These cables are EK-24A-916 iron constantan silicon rubber insulated. The licensee states tnat these cables represent approxmiately 2\\ percent of all cables installed in Crystal River No. 3.

We find that the electrical cable satisfies the objectives identi-fied in Section 2.2 o'f this report and is, threfire, acceptable.

4.9 Fire Barrier Penetrations 4.9.1 Fire Doors Doo rs in critical fire barriers are 3-hour rated with listed frames.

These include doors in walls separating the turbine, control, auxiliary and intermediate buildings, as well as wcils providing fire barriers around battery systems, switchgear rooms, diesel generators, the control complex s tai rwell, and other areas.

The licensee has proposed to install a 3-hour fire door in the wall separatins -he shop facilities from the auxiliary buildinr.

We find that, subject to the implementation of the above modifica-tion, the protection of doorway penetration in fire barriers satisfies tse objective identified in Section 2.2 of this repcet and is, therefore, acceptable.

4.9.2 Ventilation Duct Penetration 2 7entilation ducts through critical fire barriers are provided wtth dampers having a 3-hcur fire rating.

The iampers close

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9 automatically on operation of a fusible link, and scme lampers in the control complex, intermediate building, diesel gene ra to r rooms and turbine building switchgear rocms are operated by scoke and/or heat detections systems.

~4e find that the ventilation duct pene tra tion.4 t.

fire barriers satisfy the objectivec of Section 2.2 of this report and are, therefore, acceptable.

4.9.3 Electrical Cable and Other Penetrations Electrical cable penetrations in fire barriers are sealed with assemblies utilizing nneral insulation, inorgan:c board, metal plates and fire retardant mastic.

Small cable cpenings tn the control room floor are packed with uneral insulation and covered with flame retardant mastic.

The licensee has clartfied the details of the cable penetration seal construction and provided test data to substantiate that adequate fire resistance is provided.

The licensee has proposed to upgrade any deficient seals.

The licansee has proposed to upgrade openings in the : ce wall between the turbine and intermediate buildings and in tne floor between the cable sprez;ing room and control room.

We find that, subject to the above describe modification, the electrical cable and cther penetrations satisfy the objectives identified in Section 2.2 of this report and are, therefore, acceptable,

. 10 Seoaration Criteria The licensee has stated that cable and cable trays serving engi-neered safeguards and nuclear instrumentation and protection functions are separated by channels in accordance with the following criteria:

(1) Cables for redundant channels or equipment are run in separ:te trays, conduits, ducts or penetrations.

(2) Cables, trays, conduit, etc., which are a part of safeguards or protective systems are color coded. A different color is used for each channel.

(3) Horizontal distance between redundant safeguards channel trays is three feet. Were this spatial separation cannot be main-tained, a physical barrier is provided. Were hori: ental trays cross, the barrier consists if an inverted peaked cover under the upper tray, with a peaked cover over tne lower tray. These covets are coated with a fire retardant coattag. A non-comoust-ible asbestos-silicic board is used ac a barrier bet.een pa.allel horicontal or 7ertical cable tray runs.

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(4)

'le rti cal separation between redundant channel trays is provided by use of barriers between trays. The vertical distance bet.een power, control, and instrumentation trays of the same channel is nine inches between the top of the lower tray and the bottom of the upper tray.

(5) Separate cable trays are used for 69CO-volt and 4160-volt power cables. No other types of cable is carried in the same tray with 480-volt and DC power cables.

(6)

'a erever possil.le redundant safeguards cable trays do not pass through po.ential missile producing are:s.

If these areas are unavoidable, either protecti>;e shielding is provided for redundant cable trays, or only one safeguards cable tray is allowed to occupy the area.

(7)

In sece cases a non-designated tray will run between redundant traf systems.

In these areas the licensee has proposed to provide fire stops to prevent spread of fire from one safe-guards tray Jystem to the other safeguards tray system.

(8) In cases where it is impractical because of terminal equip-ment arrangement To provide separate wireways, cables for mutually redundant or backup equipment are separated by physical barriers or conduit.

19) Instrumentation cable trays may also contain telephone and low-level paging circuits.

No other types of cables are included in these trays.

(10) Redundant safeguards cable trays in the cable spreading room are separated by one foot horizontally and three feet verti-cally. Where this separation cannot be maintained, a physical barrier is provided.

(11) Protection systems, safety feature systems, and electrical system components are mounted on control boards, panels, and relay racks and are designed for operator convenience 2nd physical separation between redundant wiring and components.

Generally, redundant channel wiring ;,ters the control panels in conduits.

The bulk of reos dant wiring inside control panels are separated by metal barriers. However, wiring which is cocnon to two different redundant channels exists. The conduit is terminated or the wires are taped as close as posJible to the device to whico these vices are enanected.

The seperation criteria does not preclude the :rossing of such cables nor does it consider the possibilityef heat buildup in a rocm.

The licensee has perf armed a detailed

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fire hazards taalysis for each area of the plant containing safety-related equipment to determine the possible ef fects of fires on safe plant shut down. Each of the safety-related areas is discussed in more detail in Section 5 0 of this report.

In various areas the licensee has proposed certain modifications where the existing cable separation was found inadequate to assure that fire will not cause damage to redundant safety-related equipment.

The specific areas where this additional protection is to be provided is identi-fied in Section 5.0 of this report.

We find that, subject to implementation of the modifications described in other sections of this report, the sepa: ation criteria satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

a.ll Fire Barriers Substantial fire barriers have been provided throughout the plant. 1he licensee

• s fire hazard analysis concludes that basic wall, floor and ceiling structures are adequate, based on the contained fire load, to prevent the spread of an unsuppressed fire througn the barriers.

The licensee verified that the wall separating the turbine building from safety-related areas is free-standing with respect to fire-caused structural collapse of the turbine building. The licensee has propoced to upgrade the cable spreading rocm floor to provide 1-hour fire resistance.

We find that, subject to implementation of the above described mocification, the fire barriers satisfy the objectives identified in Section 2.2 of this report and are, therefore, acceptable.

4.12 Access and Egress Most areas of the plant are reasonably accessible for manual firefighting.

Access to tha control complex and inte rmedia te building is limited; howe'e r, light fire loadings in most of these areas will not result in severe manual firefignting demands.

In the cable spreading room, congestion caused by the cable trays could hamper manual fire control and delays could be experienced in entering the reactor building for firefighting purposes.

There are two access doors in the main control room with normal access through the control complex, one of which is en emergency door between the turbine building and the control room. Entrance into the control race by this door is by key lock.

The cable spreadiug roco normal access is through the control complex. There is an emergency trap doce from the cable spreading roce into the control room.

'ib6340

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The reactor containment building access is normally througn the personnel access hatch. Emergency access can be made througn One personnel and equipment hatch.

Access to elevations in the containment building is by two stairwells.

There ts also an elevator in the containment building.

With the satisfactory resolution of otner concerns and modifica-tions relating to the cable spreading room and the reactor building, access and egress for manual firefighting in safety-related areas, we find the access and egress to plant areas satisfy the objectives identified in Section 2.2 of this report and are, therefore, acceptable.

.13 Toxic and Corrosive Combustion Producta

.he product; sf combustion of many polymers are toxic to humans and corrosive to metals. Prompt fire detection and extinguishment are relied upon to minimize the generation of such products. la addition, portable smoke removal equipment has been provided for fire brigade use and emergency breathing air is availaole for fire brigade znd operating personnel.

We find that the provisions for handling toxic and corrosive combustian praducts satisfy he oojectives identified in Section 2.2 of this raport and are,- S refore, acceptable.

a.14 hansafetv-Related Areas Wich the implementation of the other required modifications, non-safity-related areas will be adequately separated by distance or fire barriers from safety-related systems so that fire damage which could adversely affect safe shutdown will be prevented.

The licensee has evaluated the radiole;ical consequences of fires in radwaste areas and areas containing contaminated materials and determined that fires in these areas would not result in a rr. lease of radioactive materials in excess of 10 CFR 20 limits.

a.15 Instrument Air Instrument and control air is supplied by oil free instrument air cempressors. There are certain air operated ccatrol valves which are required for sy. tem alignment functions during safe shut down operations.

These valves are equipped wita air accumulators which hold reserve air supply sufficient for at least 3 complete valve operati:ns.

The valves can also be operated manually.

Fires in other areas which could cause the loss of instrument and control air would not preclude the operation of these valves as required for safe shut down.

-iz h 341

'4e find that the instrument and control air system satisfies tne objectives identified in Section 2.2 of this report and s,

therefore, acceptable.

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5.0 Evaluation of Soecific Plant Areas The licensee has performed a fire hazard analysis of the f acility to deter-mine the fire loading of various plant areas, to identify the consequences of fires in safety-related and adjoining nonsafety-related areas, and to evaluate the adequacy of existing and proposed fire protection systems. We have evaluated the assumptions, methocology, and conclusions of the fire hazards in detail, as well as supplemental drawings showing cable routing and separation. The results of the fire hazards analysis, other docketed information and site visit observations were used in the staff's evaluation of specific plant areas to assure that the objectives identified in Section 2.2 were met. The staff's evaluation of specific areas is discussed in the following subsections.

5.1 Auxiliarv Buildine - Elevation 162 Feet 5.1.1 Safetv-Related Eouipment This area contains the new fuel storage, spent fuel storage, and fuel handling equipcent.

The effects of a fire in this area would not affect safe plant shutdown.

5.1.2 Combustibles Combustibles in this area include a small quantity of paper, plastic and wood.

5.1.3 Consecuences if no Fire Protectica An unmitigated fire in this area is mainly limited by the low combustible loading which can serve as fuel. There is no safety-related cabling in the area.

5.1.a Fire Protection Systens There is no fire detection or automatic suppression for this area.

The licensee relies on portable extinguishers and base stations located in the area for fire fighting.

5.1.5 Adequacy of Fire Protection Manual suppression would be adequate to extinguish fires in these

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5.1.6

fodifications No modifications are proposed for this area. Ve find that fire protection for this area satisfies the objectives ident fied in Sect

en 2.2 of this report and is, therefors, acceptable.

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5.2 Auxiliarv Buildine at Elevation 143 Feet 5.2.1 Safety-Related Eouiement This elevation is divided into safety-related areas and nonsafety-related areas. The safety-related areas are separated from the adjacent nonsafety-related areas by reinforced concrete walls.

the building exterior wall is metal with no a/ : 3 cent buildi.,ss.

The safety-related areas contain the chemics mixing equipment (boric acid minng tank, sodium thiosulphate tank and pumps,

caustic mixing tank and pumps, lithtum hydroxide mixing tank and pumps, ventilation equipment, and a portable resta hopper).

The auxililry building exhaust fans, auxilia ry building main exhaust charcoal filters 2.4, 3, C and Ds the reactor butiding purge exhaust filter fans and the reactor building purge exhaust charcoal filters are located adjacent to tne chemical mixing area. These areas are separated by reinforced concrete walls.

The charcoal filters are housed in metal enclosures and have automatic deluge water system installed for fire suppression.

The remaining area on this elevation is classified as nonsafety-related and is bounded by the reactor containment building and the control complex by reinforced concrete walls with metal outside walls with no adjacent buildings.

This area contains the spent fuel coolers and filters and the plant vent shaf t.

There are no safety-related cable trays in this area.

5.2.2 Cor bustibles The significant combustible material in this area consists of a large quantity of electrical cable insulation in cable trays, a large amount of resin in an enclosed container, a small amount of paper and plastic, a small amount of Lubricating oil, and a large amount of charcoal enclosed in filters which have automatic water suppression systems.

5.2.3 Consecuences of no Fire Suceression The licensee has evaluated the consequences of fires in these rooms and has shown that spread of fire is limited by bounding walls and low combustible loading which can serve as fuel. Most of the equipment is nonsafety-related. Loss of a single charcoal filter could result from a fire, but spread to other filters and equipment is limited by sietal enclosures.

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s 5.2.4 Fire Protection System Thare is no fire detection or autocatic suppression system for this area other than the charcoal filters vnich are enclosed and have automatic detection and suppression systems. The licensee relies on portable extinguishers and hose stations located in the area for fire fighting.

5.2.5 Adecuacy of Fire Protection Due to the limited amount of combustibles, manual suppression should be adequate to control fires in these areas.

5.2.o Modifications No modifications are proposed for this area.

We find that the fire protection for this area satisfies the objectives of Section 2.2 of this report and is, therefore, acceptable.

5.3 Auxiliarv Buildine at Elevation 119 Feet 5.3.1 Safety-Related Eouipment This area is adjacent to the reactor building and the intermediate building on one side with the emergency diesel generator rooms and the hot machine shop on the other side. There are doorways from the auxiliary building into these adjacent areas. This area contains safety-related equipment as well as nonsafety-related equipment. The safety-related equipment in this area consists of spent fuel coolant pumps, filters, demineralizers, and heat exchangers; boric acid storage tank and pumps, reactor coolant bleed tanks, nake-up and purification filters and demineralizers, and engineered safeguards motor control centers 3A2, 331 and 3A3.

The safety-related equipment is located in separated reinforced concrete rooms with 3-hour fire rating. The safety-related areas on tais elevation contain safety-related cables; a few of these areas contain redundant safe shutdown cables. Some of the safety-related areas contain only channel A or channel 3 safety-related cable trays. In areas where both channel A and channel 3 cable trays are present they are separated by a combination of distance and/or barriers. There are some areas which contain safety-related cable trays A and 3 as well as a nonsafety-related cable tray.

In these arear the licensee has proposed to install additional fire stops on consafety-related trays at the crossovers and automatic fire detection systems. The arear on this elevation wnich are designated as consafety-related do not contain safety-related cable trays. These areas are separated from safety-related areas by reinforced concrete walls with offsets.

(Note: See Section 5.6 for containment penetrations. )

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o 5.3.2 Combustibles The significant combustibles in these areas consist of cable insulation, a small amount of lubricating otl, and a small amount of paper and plastic.

5.3.3 Consequences if no Fire Sucaression The licensee has evaluated the consequences of fires in these areas and shown that, in most areas, the separation of redundant cables frcm combustibles or the separation between redundant cables is such that it ts highly unlikely that an unmitigated fire would involve redundant cables.

5.3.a Fire Protection Sestem There are no automatic fire detection devices in this area of the auxiliary building.

hanual hose stations and portable fire extinguishers are available for fighting fires in this area.

However, a waste drumming station is located adjacent to the interior hose station outside the diesel generator room door.

Material waiting to be procersed was stacked ta front of the hose station at the time of the site review.

5.3.5 Adecuacy of Fire Protection With prompt detection, manual suppression would be adequate to control fires in these areas and limit the effects of the fire.

Lack of detection may allow the fire to continue unnecessarily.

5.3.6 Modifications The licensee has proposed to install additional fire stops on nonsafety-related cable trays, automatic fire detection systems in various areas of safety and naasafaty-related areas. These areas include zone 1, 5, 7, 13, 25 and 26.

The hose station adjacent to the waste druccing station has been relocated to permit free access to the fire base reel in the area. Administra-tive controls have been instituted to prevent the accumulatica of solid waste near the fire hose reel and the safety-related motor control center.

The licensee has proposed to provide automatic sprinkler protection beneath cable trays and to protect against fires and transient combustible materials in :enes 1 (east end) and 5; the dry cleaning station in race 13 will be provided with a suitable sprinkler system or removed from the area.

The licensee has been asked to provide the results of an analysis whica demonstrates that redundant safe snutdown systems nil not be damaged by an unsuppresst ! fire in zones '. (west end), 7 ind 13.

If the results of tais analysis indicates tnat safe shutdown 3~

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s capacility will be lost, the licensee has pecposed to provide one of the following modifications:

(1) reroute certain cables required for safe shutdown; (2) to provide a wet-ptpe fusible-link water spray system; or (3) to provide 2 fire wall, as necessary, to protect redundant cables required for safe shutdown. The east end of fire zones 5 and 7 will be protected against postulated fires from transient combustib'e with wet pipe fusible link sprinkler systems wl.th the sprinkler heads located below the cable trays.

Subject to implementation of the above modifications and a review of :he information requested, we find that fire protectica for these tress satisfies the objectives identified in Section 2.2 of this report and is therefore, acceptable.

5.4 Auxiliarv Building at Elevation 95 Feet

5..1 Safetv-Retited Equi: ment The area is adjacent to the Reactor Containment building and the incermediate builczag on one side with all outer w.11s of reinforced concrete.

The entire elevation is made up of compartments of reinforced concrete rooms which house acd separate both safety-related and acasafety-related equipment. The wall penetrations are filled to a minimum seven feet height. Scme walls in this area are ten faec high. A considerable quantity of safety related and nonsafety-related cables are in open trays and conduits.

4100 Volt power cables for channels A and 3 are presect, but each is enclosed in interlocked armour and the trays for the two channels are separated by distance. Safety-related systems that potentially could be affected hfa fire are reactor building spray, decay heat, reactor makeup and purification, nuclear services and decay heat seawater, and nuclear services and decay heat closed cycle cooling water systems.

5.4.2 Combustibles The significant ceabustible material in this area cocaists of a large quantity of electrical cable insulatica in open cable trays, a modcrate amount of lubricating oil in each makeup p' ump, a small amount of lubricating oil in other areas, and a small amount of paper and plastic.

5.4.3 Consecuences if no Fire Protection The licensee has evaluateu the loss of cables in these areas and has found that cables from only one safety divisi:n are present in eleven areas and fire spread to redundant divisional cabling is prevented by distance. In three of these areas, the licensee has proposed to install aut:matic fire detecti:n systems. There are twelve other areas wnich c:ntain both enaanel A sad 3 cable trays.

The licensee nas proposed to install aut:matic fire 3-3 Us

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detection systems in six areas and additional fire stops in t'.o areas. The channel s and B cable trays are separated by distance or barriers. The licensee has evaluated the loss of cables in these areas and has found that complete loss of channel A or channel 3 cables would not atfect redundant safe shutdown equipment.

5.4.6 Fire Protection Svstems Automatic fire detection systems or automatic suppression equipment have not been provided in these arecs. Portable extinguisners are located within and adjacent to these areas.

Interior hose stations are located throughout the area. '4ith prompt detection, manual suppression would be adequate to control fires in these areas and limit the effects of the fire.

Lack of detection systems may allow the fire to continue unnecessarily.

5.4.5 Adecuacy of Fire Protection Due to the low combustible loading, other than cabling, manual fire protection using portable extinguishers would be adequate

o extingui'h fires in these areas and to prevent the loss of recun-dant safe shutdown equipment. However, without adequate detection in these areas, fires could proceed undetected and cause damage to safety-related equipment.

Some of this equipment could be used for safe shutdown.

5.e.o Mndifications The licensee has proposed to install autcmatic fire detection systems in the following areas:

Zone 4 Makeup and purification pu=o rooms.

Zone 7 Safety related hallway which contain safety-related channel A cabla trays.

Zone 17 Se: water pump room.

Zone 13

.Vuelear service booster pump room.

Zone 32 Pump and tank room.

The licensee has propose; to install automatic sprinkler protec-tion for cable trays and other combustibles in zones 1 and 5.

The licensee has been asked to provide drawings and the results of an analysis which demonstrates that redundant safe shutdown systems will not be lamaged by an unsuppressed fire in zones 13 and lo.

If the results of this anc.lys is indicate that safe shutdown capability will be lost. the licensee has proposed to provide one of the foll: win; nodifiestion:

(1) reroute certa:n cables required for safe shutdown; (2) to provide a wet p;pe fus ble-link water spray system; or (3) to provide a fire wall, 3-6

%8u348

as neces sa ry, to protect redundant caoles required for safe shutdown reinforced concrete rooms.

We find that, subject to implementation of the above described modification and/or a review of the above analysis, the fire protaction for these areas satisfies tae objectives identified in Section 2.2 af this report and is, therefore, accept ible.

5.5 Auxiliarv Building at Elevation 75 Feet 5.5.1 Safety-Related Equipment The safety-related reactor building spray pumps. decay heat pumps and decay heat removal heat exchangers are located in this area.

The 'A and 3" trains of pumps and heat e:echangers are located in separate reinforced concrete rooms.

At least one decay heat removal pump 2hould be available.

5.5.2 Combustibles The significant combustibles in these rocms is a small imount of lubricating oil and cable insuiation.

5.5.3 Consecuences of No F;re Suoeression Due to the low combustible contents and the separation of the areas, caly one train would be affected by an unmitigated fire.

5.5..

Fire Protection Systems There is no automatic fire detection or suppression systems for this area. Portable fire extinguishers and interior hose st:tions are available in adjacent areas.

5.5.5 Adequacy of Fire Protection With prompt.tre detection, manual suppression capa lity provided would be adequate to suppress fires in the area oefore either train A or B is last. The lack of detection would allow the fire to continue unnecessarily.

5.5.6

. Modifications The licensee has proposed to add automatic fire detection systems in :ones 1 and 2 to provide prompt notification locally and in the control room for fires ta these areas. Subject to implemen-tation of this modification, we find that fire protection for these areas conforms to the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

5.5 Containment Electrical Penetratton Areas 3-7 5mlM9 m

5.6.1 Safetv-Related Eauicment The containment electrical penetrations areas are located in the auxiliary building and the intermediate building. These areas are safety-related and are bordered by three-hour fire cated walls. One area contains safety-related cable trays for channel A; the other area conc.ztns channel A and channel 3 safety-related cable tray systems.

There is one cable tray which centains non-safeguards instrumentation cables. This non-safeguard; cable tray runs between the safeguards channel A and 3 cable trays.

5.6.2 Combustibles The significant combustible material in these areas consists of a moderate amount of cable insulation in open cable trays.

5.o.3 Consecuences if No Fire Protection Cables from the redundant divisions are routed through one of these areas. The licensee has evaluated the loss of cables in these areas and has found that redundant safety-related cabling is separated by distance or barriers and therefore an unmitigated fire would not affect redundant safe shutdown equipmee.t.

5.6.4 Fire Protection Systems Fire detection or automatic supp assion equipment has not been provided in these areas.

Portable fire extinguishers and nose stations are located in the area or adjacent to the areas.

5.5.5 Adecuacy of Fire Protection Due to the low combustible loading, manual fire protection would be adequate to extinguish fires f.n these areas and to prevent the loss of redundant safe shutdown equipment.

However, without 2dequate fire detection in these areas,..res could proceed

^

undetected and allow damage of safety-related equip.aent; some of which may be used for safe shutdown.

5.6.6 Modifications The licensee has proposed to install automatic fire detection systems in the areas which will alarm locally and in the control room as discussed in other sections of this report. The lice.nsee has also proposed to install fire stops on the non-safeguards instrumentation cables runs between safeguards channels A and 3 to prevent the spread of fire bet 2en channels.

Subject to the implementation cf the above modificattons, we find that the fire protection for these areas satisfies the Objectives identified in Sect:.on 2.2 af this report 2nd is, therefore, acceptable.

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5.7 Intermediate Building at Elevation 119 Feet 5.7.1 Safety-Related Eouicment This elevation of the intermediate building is bounded on one side by the reactor containment building and on the other three sides by reinforced concrete walls.

This area contains the personnel access hatch to the containment building, pressurizer control cabinets 3A and 3B, electrical and piping penetration areas. These areas contain redundant safety-celated safe shutdown cables.

5.7.2 Ccmoustibles Significant combustibles in the area taclude a large quantity of electrical cable insulation, up to 165 gallons of transient lube oil, a significant supply of anti-C clothing, paper and plastic.

5.7.3 Consecuences if No Fire Protection The licensee has evaluated the consequences of fires in these areas and shown :nat, in most areas: the separation of redundant caSles from combustibles or the separation between redundant cioles is such that it ia unitkely that an uamitizated fire would involve such cables.

In the containment personnel access area, an unmitigated fire invciving the oil and/or other combustibles stored in the area may cause loss of redundant safe shutdown systems.

5.7.4 Fire Protection Svstems There are no automatic fire detection or fire suppression systems installed in these areas.

Portable fire extinguishers and hose stations are located in and adjacent to the areas.

5.7.5 Adecuacy of Fire Protection With prompt fire detection, manual suppression would be adequate to control fires in these areas nd limit the effects of the fire, except for the containme-cess areas. Lack of detection cay allow the fire to continue unnecessarily. Without automatic suppression in the containment personnel access area, a fire may affect redundaut safe shutdown systems due to the proximity of cables to each other. In this particular area, there are portable fire extingutshers and a interior hose station. The stotage of cembustible supplies present an unnecesaary fire exposure to critical areaa.

3-9 h 351

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5.7.6 S!odifications The licensee has proposed to install automatic fire detection systems in the pressurizer control cabinet area to detect cable fires or other fires that may jeopardine safety-related equipment.

The licensee has proposed to install automatic sprinkler protection to extinguish postulated fires in clothing, paper or transient material in zone 5.

This area ontains Channet A cables, channel B cables, and non-safety-related cables. The areas inside and above the personnel air lock shield structure will not be covered by this sprinkler system. The function of the cables in this area will be examined by the licearee to determine the effects on safe-shutdcwn capability of the less of all cables.

If this examination shows that safe shutdown capability will be lost, app ropriate additional measures will be taken. These measures sill be one of the following:

(1) to reroute certain cables required for safe shutdown; or (2) to provide a wet pipe fusible-link water spray system to protect the cable trays in the area.

Subject to imple=entation of the above described modifications, and/or a review of the above analysis, the fire protection for these areas satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

5.3 Intermediate Building at Elevation 95 Feet c

5.3.1 Safetv-Related Ecuipment 7

This area is bounded on one side by the reactor containment building and on the other three sides by reinforce concrete walls.

This area contains the motor driven and steam turbine driven emergency feedwater pumps, penetration cooling fans and one of the pipe penetration areas. At least one emergency feedwater pump is required for safe shutdown.

5.3.2 Ccmbustibles The significant combustibles in this area consists of a small amount of lubricating oil associated with the pumps and moderate amount of cabl insulation in cable trays from channel A only.

5.3.3 Consecuences if No Fire Suceression There is sufficient separation between the emergency feedwater pumps that only one pump would be affected by an unmitigated fire, but the cable for the motor driven pump could be af fected by a fire in the vicinity of the steam drtven pump.

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5.3.a Fire Sucaression Systems There is no automatic fire detection or suppression systems for this area. Portable fire extinguishers and interior hose stations are available for fire suppression in this area.

5.8.5 Adeouacy of Fire Protection With prompt fire detection, manual fire suppression capability provided would be adequate to suppress fires in the emergency feedwater pump rooms and may allow suppression of a fire before either emergency feedwater pump is disabled. The lack of detection would allow the fire to continue unnecessarily.

5.S.6 Modifications The licensee has proposed to provide fire detection and suitable one hour fire barriers around safety-related cables and motor operated valves.

The licensee has propoced to install automatic fire detection systems in the area.

Subject to the implementat.on of the above described modifications,

the fire protection system for this area satisfies the objectives in Section 2.2 of this report and is, therefore, acceptable.

5.9 Reactor Building 5.9.1 Safetv-Related Eauipment Safety-related equipment in the reactor containment building includes: reactor vessel, primary coolant piping, core flood tanks, pressurizer, ins trumenta tion, containment air coolers, valres, and associated cabl:.ng.

5.9.2 Combustibles The significant comuustibles inside the reactor containment building consists of a large quantity of electrical cable tasula-tion and the lubricating oil associated with the reactor coolant pumps. The licensee has installed a oil guard leak collection system around each reacte e coolant pump. The collection system is piped to a common collection reservoir located inside the secondary shield wall. The design concept of the oil collection system is based on a failure of one reactor coolant pump oil system at any time. The oil collection reservoir coaststs of a fif ty-five gallon oil drums piped together such that the reservoir will contain the total oil capacity from one resetor coolant pumo.

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5.9.3 Consecuences if No Fire Sucoression An unsttig-ted fire involving oil from a reactor cociant pump would most likely result in damage to only one pump due to the oil collection system which limits the amount of oil available to burn to a small amount and because the pumps are widely separated in separate cubicles. The separation of cables is such that a fire in the vicinity of one pump would not cause loss of safe shutdown capability.

Two areas, elevation 95 feet and elevation 119 feet, both located outside the reactor ccmpartment, contain electrical cabling for trains A and B, and also non-designated cable trays. The licensee has reviewed these areas and find that spread af fire in these areas is limiteo by separation of major equipment, cable trays and low combustible loading which can serve as fuel.

Loss of functional capability of individual components could occur due to a fire, but loss of individual components would not preclude safe shutdown of the plant.

5.9.4 Fire Protection Systems There is no fire suppression or fire detection equipment installed inside the reactor containment building. Portable fire extinguishers are brougnt into containment as required for saintenance activities.

5.9.5 Adeauacy of Fire Protectica The reactor coolant pumps oil guard collection tanks at the bottom floor of the reactor building have sufficient capacity for leakage from a single pump even if one of the collection tanks is isolated.

Portable fire extinguishers would not be adequate to suppress cable insulation f res or oil fires at the reactor coolant pumps.

5.9.6 Modifications The licensee has been asked to provide the results of an analysis for Zone I which demonstrates that redundant safe shutdown systems will not be damaged by an ursuppressed fire. The licensee has proposed to install automatic fire detection systems in the vicinity of the reactor coolant pumps, in venti.atien units, near cable concentrations, and general areas throughout the reactor building. Fire stops will be provided to maintain separation at the two previously discussed areas :n elevation 95 feet and 119 feat. The licensee has proposed to install a standpipe system inside the containment building with a suttable number of stations at each elevation in order that all potential fire areas of the containment can be reached by an effective fire stream.

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'de find that. subject to the implementation of these modificaticas, the fire protection for the reactor building satisfies the objec-tives identified in Section 2.2 of this report and is, therefore, acceptable.

5.10 Ccstrol Room 5.10.1 Safetv-Related Eouipment The control room contains cabinets and consoles within which are components for safety-related systems, including those systems required for safe shutdown of the plant.

5.10.2 Combustibles The combustibles in this area consist mainly of electr cal wiring insulation contained within the cabinets and consoles. There are also ordinary combustibles, primarily paper for operating needs, a computer, and a kitchen area.

5.10.3 Consecuences If.Vo Fire Suceressica An unsuppressed fire in the consoles containing safe shutdown equipment could affect wiring of both redundant divisions.

5.10.4 Fire Protection Svstems Fire detection is provided by smoke detectors in the room and in the air handling systems. Portable fire extinguishers are provided for manual fire suppression; however, there are to liquid type extinguishers provided to combat deep-seated fires in ordinary combusticles.

5.10.5 Adcouaev of Fire Protection Fire detection and manual fire suppression may not o sufficient to prevent fires from danaging controls and instrumen:a; toc for both redundant divisions of systems required for safe shutdown.

The storage of combustible operating supplies and the kitchen facilities present an unnecessary fire exposure to the critical control room systems.

The lack of portable fire extinguishers suitable for deep-seated fires in ordinary combustibles could cause unnecessar7 delay in fire control, an! excessive water damage if the use of hose lines is required for suct fires.

The fire door between the control roce and the adjacent hallway is being neld open with a wedge and wculd not operate aut:matically to isolate the control room.

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5.10.o Modifications The licensee has proposed to provide the capability of shutting down the reactor safely at a location remote from the control room regardless of any damage caused by a control room or cable spreading room fire.

The licensee has provided a list of safety-related and non-safety-related cables located in the ceiling above the control rocm.

Control cables in the ceiling have been coated with a fire retardant.

A ladder for ceiling access is provided and.is stored in or immediately outside the control room.

The licensee has proposed to remove combustible supplies or store them properly in metal cabinets or under sprinkler protection, disconnect and/or remove the kitchen stove from the control room, provide liquid type fire extinguishers for the room, and provide an au' amatic closing fire door between the control room and the hallway. The licensee has proposed to provide continuous observa-tion by the security guard on the control room door until the station security system is completed.

We find that, subject to implementation of the above described modifications, the fire protection system for the control room satisfies tb4 objectives identified in Section 2.2 of this report and is, therefore, acceptable.

5.11 Cable Screading Rocm 5.11.1 Safety-Related Equioment This area located on elevation 134 feet of the control complex contains control and instrumentation cables, some of which are for safety-related systems required for safe shutdown.

3.11.2 Combustibles The significant combustible in this area is a large quantity of electrical cable in both covered and open trays, and in conduit.

5.11.3 Cons equences If No Fire Surpression Although there is some separation of redundant chaus:Is by distance and fire shields, an unsuppressed fire in the area could cause loss of control from the control room of redundant systems required for safe shutdown.

An unsuppressed ca' le spreading rocm fire could also spread to o

the safety-related 50 Volt switcagear rocm below througn the unprotected metal floor, and to tne centrol roon above through unprotected metal plates in the :oncrete ceiling.

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5.11.a Fire Protection Systems s

Automatic fire supnressten is provided by a Halon 1301 system actuated by cross-::oned detectors; operation of the system alarms in the control room. Fire base and portable fire extinguishers are available for manual fire suppression.

5.11.5 Adecuacy of Fire Protection Because of concerns for ef fectiveness and reliability, gaseous fire suppression systecs alone are not acceptable protection for areas containing large quantities of electrical cables in which deep-seated fires could develop.

5.11.6 Modifications The licensee has proposed to install a backup Halon 1301 agent supply that would allow a second manual discharge if automatte ral. ease of the primary supply is ineffective.

The licensee has proposed to provide alternate means to achieve safe shutdown from a location remote from the control room, regardless of any fire damage in the control room or cable spreading room. The licensee has proposed to provide at least a one-hour fire resistance above the cable spreading room floor. A three-hour resistance rated material will be applied to the metal plates in the ceiling to prevent the spread of fire to the control room.

Cable spreading room fire suppression effectiveness is placed on the cable spreading room circulating fans; therefore the licensee has proposed to power the circulating fans in the cable spreading room from an essential power supply.

~4e find tha r., subject to implementatin of the above described modifications, the fire protection system for this area sattsfies the objectivts identified in Section 2.2 of this report and is, therefore, acceptable.

5.12 Switchgear Rooms 3.12.1 Safetv-Related Ecuioment The 4160 Volt and 480 Volt safety-related switchgear rooms are located in the control complex on elevations 108 feet and 124 feet, respectively. Redundant switchgear are housed in separate roams within three-hour fire ba rriers.

One of the 4160 Volt switchgear rooms contains power cables from both redundant diesel generators.

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P 5.12.2 Combust bles The significant combustible in the switcagear rooms is electrical insulation on cable and in the switchgear enclosures.

Power cables are contained in flexible metal conduit; control cables are placed in lightly loaded trays.

5.12.3 consequences If No Fire Sucoression An unsuppressed fire in three of the switchgear rooms will not affect more than one safety-related division because of the separate rooms provided. In the 41o0 'lo'.t switchgear room contain-ing both redundant power cables from the diesel generators, the roca configuration, lignt fire loading, enclosure of power cables in flexible metal conduit, and enclosure of switcagear in metal cabinets will prevent involvement of both redundant cables in a fire.

5.12.4 Fire Protection Svstems Fire detection is provided by smoke detec ces in each switchgear room. Portable fire extinguishers and hose stations are available for manual fire suppression.

5.1;.5 Adecuacy of Fire Protection The existing physical conditions and protective features will preclude loss of redundant safe shutdown systems. To effectively combat all potential fires and miaimize damage to safety-related systems, interior fire hose stations are available adjacent to the switchgear rocms.

5.12.o Modifications No modifications are recommended for these areas.

se find that, the fire protection system for the switch gear rocas satisfies the objectives of Section 2.2 of this report and is,

therefore, acceptable.

5.13 Batterf Rooms 5.13.1 Safety-Related Ecuioment Rooms containing redundant batteries, ba:.tery chargers and inverters located on elevation 108 feet of the control complex. These are systems supply DC power to safety-related systems, some of which are required for safe shutdown. All redundant systems are separated by three-nour fire barriers except that the inverter rocms contain power cables frem both redundant diesel generators, 2nd one D a tte r*7 Charger rocm Contains Cablt from *he redundant b a t t e **7 Charger roCo.

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5.13.2 Combustibles The combustibles in these rocms consist of a small amount of electrical insulation on cables and inside equipment cabinets.

Most of the electrical cable is in either rigid or flexible metal conduit; there is a small amount of open cable trays. The battery rooms contain batteries in plastic cases; hydrogen is generated during battery changing.

The station batteries at Crystal River 3 are of a type wnich has a very low hydrogen production rate when under charge. Section 3.2.2.6 of the Final Safet/ Analysis Report states in part, "under the condition that the batterv rooms were completely sealed from outside air it was calculated tuat it.ould require 210 hours0.00243 days <br />0.0583 hours <br />3.472222e-4 weeks <br />7.9905e-5 months <br /> to produce sufficient hydrogen in the rooms to yield an exploaive mixture (four percent by volume).

5.13.3 Consecuences If No Fire Superession Decause of the physical arrangement and light fire loading, an unsuppressed fire in any of these rooms would affect caly one division of safety-related equipment.

5.13.4 Fire Protection Systems Fire detection is provided by smoke detectors in each individual rocm, and portable fire extinguishers are provided for manual fire suppressica.

5.13.5 Adequacy of Fire Protection The existing fire loading and layout will preclude loss of redun-dant safe shutdown systems. To effectively combat all potential fires and minimize damage to safety-related systems, interior fire hose streams should be available to the area.

The battery room ventilation ducts for hydrogen removal are located several feet below the ceiling bays, creating an annessary fire hazard. The ventilatica system is not monitored for con-tinuous operation.

5.13.6 Modificatione The licensee has proposed to relocate the battery roem exhaust ducts near the ceiling and to provide local monitoring of ventila-tion flow for each battery rocm.

We find that, subject to implementation of the above described modifications, the fire protection system satisfies the objectives identified in See::ca 2.2 of this repor: and is, therefore, acceptable.

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5.14 Diesel Generator Rooms 5.14.1' Safetv-Related Eauioment The two redundant diesel generators are housed in individual rocas separated by a three-hour fire barrier. The controls for each diesel generator are also housed in individual rooms that are separated from the diesel generators and from each other by three-hour fire barriers. One control room contains some electrical cables associated with the redundant diesel generator.

5.14.2 Combustibles The significant comeustibles in the diesel genera or rooms are diesel fuel and lubrica:Ing oil.

The controi roc.us contata a small amount of electrical insulation on cables and ta the elec-trical cabinets.

5.14.3 Consecuences If No Fire Suceression An unsuppressed fire in ene diesel generator room will not affect the redundant unit because of the three-hour fire barriers provided.

However, there is a potential for the spread of burning combustible

',_A liquids to the redundant system via the common floor drain systam and under the fire doors.

The fire loading and physical separatica in the control room containing electrical cable from the redundant diesel generator is such that a fire in the combustibles in the rocm will not affect both divisions.

5.14.4 Fire Protection Systems The diesel generator rooms and the control rooms are protected by a preaction automatic sprinkler system actuated by rate-compensating heat detectors. In addition, the control rooms have smoke detectors that alarm in the pimt control room. Portable fire extinguishers and interior fire hose are available for manual suppression.

5.14.5 Adecuacy of Fire Protection The pre-action sprinkler system provided will reduce fire damage to safety-relar.ed diesel generator systems. The detection-actua-tion system for the pre-action sprinkler system is capable of functioning automatically on loss of station and of f-site pcwer.

The smoke detector in each control rocm is poorly positioned, vnich could result in slow detector response and delay of manual fire suppression. The design of the floor drain system and tne lack of curbs at fire door openings could allow burn:ng liquid to spread fire to -Jie redundant diesel generator or control rocm. A leak in the diesel fuel system c:uld go undetected W.a continued 3-13

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5.la.o Modifications The licensee has proposed to provide curbs at doorways in the diesel generator rooms, modify the floor drain system by the installation of weirs to eliminate this avenue of potened.a1 fire spread, relocate the control rooms' smoke detectors to improve response time, and provide a sump alarm to ensare that the control room personnel are alerted to any potential fuel leak.

We find that, subject to implementation of the above described modificatians, the fire protecti;n system satisfies the objective identified in Section 2.2 of th;.s reported and is, therefore, acceptable.

5.15 Turbine Building 5.15.1 Safety-Related Ecuioment There is no safety-related equipment or electrical cables located within the turbine building.

5.15.2 Combustibles The significant combustibles in the turbine building include lubricating oil in the reservoir, purifier and piping systems for the main turbine generator, the main faedwater pumps, and the hydrogen seal oil system; hydrogen; electrical insulation on cable and in electrical equipment; and miscellaneous ordinary combustibles such as resins wood, paper and plastic which are mostly transient.

5. 15.3 Consecuences If No Fire Suporession An unsuppressed fire is the turbine building could cause signifi-cant damage to nonsafety-related systems and structures. Safety-related systems will not be affected if tse fire barrier separating the turbine ~ building from safety-related areas maintains its integrity.

5.15.4 Fire Protection Svstems The heater bay is provided with smoke detectors. The two icwer elevations of the, turbine building are protected by autcmatic sprinklers.

The turbtne lube oil reservoir and purifier, the main feedwater pu=p oil reservoir, and the hydrogen seal oil unit are protected by automatic water spray systems. The main feedwater pu=ps and the turbine generator bearings are protected by an automatic carbon dioxide system. In erior fire nose stations and 5+

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3.15.5 Adecuacy of Fire Protection The areas and equipment containing large quantities of combustible lubricating oil are protected by automatic sprinklers, water spray or carbon dioxide systems which are designed to control anticipated fires. Areas containing safety-related systems are separated fecm the turbine building by three-hour fire barriers that will stop the spread of fire should fixed protective systems or manual fire suppression efforts fail.

The licensee has stated that "the turbine building was lesizned and constructed as a free standing structure.

It is joined to the control complex and the intermediate building only by mastic joint, therefore; the complete f ailure of the turbtne butiding will not affect the control complex or the intermediate building.

• 5.15.6 Modifications We find that ne fire protection system for tne turbine building satisfies the objective identified in Sectica 2.2 of this report and is, therefore, acceptable.

5.16 Yard Area 5.16.1 Safety-Related Eauipment Safety-related equipment in the yard area taciudes the condensate storage tank, the borated water storage tank and the underground fuel oil tanks for the emergency diesel generators.

5.16.2 Combustibles The combustibles which were considered for their potent:21 to exposure safety-related syste=s include oil-filled transformers, the underground turbine lube oil storage tank, and the underground diesel fuel oil tanks.

5.16.3 Consecuences If No Fire Sucoressicu An unsuppressed fire in the yard area would not present a signifi-cant exposure to safety-related systems because of intervening distances or barriers.

5.16.a Fire Protection Svstems The oil-filled trans fo rme rs are protected by automatic water spray systems actuated by rate-compensatica heat detectors. Yari fire hydrants and fire hcse are available for manual fire suppres-s:ca in the yard area.

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3.16.5 Adecusev of Fire Drotection Ccasidering the yard layout, existina fire suppression systems provide acceptable protection for safe shutdown equipment.

Several of the pcst indicator valves in the yard area were act protected from vehicular traf fic.

5.16.6 Mjf.fications Tht licensee has proposed to provide traffic guards around post-ir dicator valves exposed to the vehicular traffic.

!e find that, subject to the above modification, the yard area fire protection system satisfies the oojectives tcentified La Sectica 2.2 of this report and is, therefore, acceptable.

5-2; E 003

t 6.0 ADMINISTRATIVE CCNTROLS The administrative controls for fire protection consist af the fire protec-tion organi:atton, the qualifications and training for fire protection personnel, the controls to be exercised over combustibles and ignitica sources, plans and procedures for fighting fires in the various plant areas, and the quality assurance provisions for fire protection.

The licensee has provided a detailed description of proposed administrative controls. Plans and procedures stipulating the management and staf f organi-

atica and its qualifications; the fire brigaqe training program; controls ever :cebustibles and ignition sources; and tne pref:re p'ans :or f4htine e.

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pr:cedures are provided b'r 'e::ers from :he lic nsee da. d June 22, 197~ as surr.ecen:e: cy '.e::ers ca:.ed Jub 11, 1977, Neencer

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1975, June 23, i975 and ' ::er f reponse dated January 26, i979.

We have reviewed the administrative controls for fire protection and find that, :hia fire protection program, except as noted below, satisfies the Objectives identified in Section 2.2 of :his recor and is, therefore, acceptable. We w;.1 reper: :n :he resci;: ion af :he fire bri;ala ?.anocwer

'uirement in a supplerent :o this Safety Ivalua:i:n.

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J 7.0 TEC.{NICAL SPECIFICATIONS

?he rechnical Specifications have previously been modified to incorporate interim Technical Specifications which include limiting conditions for operation and surveillance requirements for existing fire protection systems and administrat.ive controls. The licensee will propose a Technical Specifi-cation change to require that at least four individuals with fire protection training be <an site at all times. The proposed Technical Spectif cations will include the requirement for a call-back program to assure that ene or

.nore offsite fire brigade members will be readily available in the event of fire emergency. We find the change acceptable pending resolution of the a

question of minimum belgade size acceptable to the Co ai ssion. Following the implementation of the modifications of fire protet stems resultin; from this review, the Tecanical Specifications will be similarly modified to incorporate the Ibniting conditions of operation and surveillance require-ments for these modifications.

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l jf 3.0 CONClCSIONS The licensee has performed a fire ha:ards analysis aad has proposed certain modifications to improve the fire protection program. Additional modifica-tions have been proposed by the licensee during the course of our review, l which are based upon the fire hazards analysis and our onsite evaluation of the fire protection program. These proposed modifications are summarized in Section 3.0.

In addition, we have cencluded that the licensee should implement certain evaluations or improvements related to the fire protec. en program. These are summarized in Section 3.0.

Significant steps are being taken to provide additional assurance that safe snutdcwn can be 2ccomplished and that the plant can be maintained in a safe concnion dur:ng 2nd fol-lowing potential fire situations. Upon impiementation of the licensee's proposed modifications and satisfactory completion of remaining evaluations, we find that the ab.4ectives identified in Section 2.0 will be satisfiec.

We find that the licensee's proposed modifications described herein are acceptable both with respect to the imp ro cements in the fire protection program that they provide and with respect to continued safe operation of the facility, while the remaining items are completed.

In the report of the Special Review Group on the Browns Ferr/ Fire NTdG-0050) dated February 1976, consideration of the safety of operatic a all operating nuclear power plants pending the completion of our detailed fire protection evaluation was presented.

The following quotations frem the report summartre the basis for the Special Review Group's catclusion that the operation,f ne facilit.y need not be restr cted for public safety:

" Fires occur rather frequently; however, fires involving equipment unavailability comparable to the Browns Ferry fire are quite infrequent (see Section 3.3 of (STREG-1050 ]).

The Review Group believes that steps already taken since March 197L (see Section 3.3.2 of [5TREG-0050 } )

have reduced this frequency significantly."

" Based on its review of the events transpiring before, dur:.ng and after the Browns Ferry fire, the Review Group cone '.: s that tae probability of disruptive fires of the Browns Ferry e.e.t is small, and that there is no aced to restrict operation of nuclear power plants for public safety.

However it is clear that much can and should be done to reduce events which further the likelihood of dis-abling fires and to improve assurance of rapid extinguishment of fires that occur. Consideration should be given also to features tnat would increase further the ability of nuclear facilities to withstand large fires vnhout loss of i:~rtant functions should such fires occur."

We recognize that the " Risk

• ssment Review Group Report to the U. S.

Nuclear Regulatory Commissica

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states that the Review Gr:up :s unconvinced of the correctness of the 3-;

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.o 3,1 Unidd i WASH-la00 conclusion that fires contribute negligibly to the overall risk of nuclear plant operation.

In the Commission's Policy Statement dated January 13, 1979, "NRC Statement on Risk-Assessment and the Reactor Safet; Study Report (WASH-1400) in Light of the Risk-Assessment Revtew Group Report", the Comission indicated on page 3 that it " accepts the review Grot.p Report's conclusion that absolute values of the risks presented by WASH-1400 should not be used uncritically either in the regulatory process or for public policy purposes and has taken and will continue to take steps to assure that any such use in the past will be corrected as appropriate.

In particular, in light of the Review Group conclusions on accident procabi-11 ties, the Commission does not regard as reliable the Reactor Safety Study's numerical estimate of the overall risk of reactor accident.

• In su:: mary, it is our conclusion that the operation of the facilit/, pending resolution of the incomplete items and the implementation of all facility modifications, does not present an undue risk to the health and safety of the public based on our concurrance with the Browns Ferry Special Review Group's conclusions identified above, (giving due consideration to the Commission Policy Statement) as well as the significant improvements in fire protection already made of the 'acility since the Browns Ferry fire.

These include establishment of administrative controls over combustible materials and use of ignition sources, training and staf fing of a fire brigade, and issuance of technical specifications to provide limiting conditions, operation and surveillance requirements for fire protection systems.

We have determined that the license amendment does ac:. authorine a change in ef fluent types or total amounts nor an inc:. ease in power level and wtll not result in any significant enviconmental impact.

Having made this determination, we have further concluded that the amendment involves an action which is insignificant frem the standpoint of environmental impact and pursuant to 10 CFR, Section 51.5(d)(4) that an environmental impact statement, or negative declaration and environmental impact appraisal need not be prepared in connection with the issuance of this amendment.

We have concluded, based on the consideration discussed above, that:

(1) because the amendments do not involve a significant increase in the probability or consequences or accidents previously cons:.dered and do not involve a significant decrease in a safety margin. the amendments do not involve a significant hanards consideration, (2) there is reasonable assu-rance that the health and safety of the public will not be endangared by operation in the proposed manner, and (3) sucn activities will be conducted in cocpliance with.he Comission's regulations and the issuance of these amendments wi'.1 not be inimical to the comon defense :nd see trity 3r the health and safety of the public.

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9.0 CONSi'LTANTS ' REPCRT I:nder contract to Nuclear Regulatory Commission, Brookhaven National Labora-tory has provided the sr vices of fire protection consultants who partteipated in the evaluation of the licensee's fire protection program and in the preparation of the safety evaluation report (SF.R ).

Their report, Fire Protection Evaluation-Crystal River 3 Nuclear Station, dated Decemoer 29, 1978, discusses several matters which have been addressed in the SER. The consultants' report contains recommendations wnich have, for the most part, been implemented duri.g our evaluation. The consultants ' recommendations which we have not adopted, along w:.th our basis, therefore, is as foilcws:

1.

Consultants

• Comments: Valve Suoervision SER Item 4.3.1.3 indicates that the position of fire protection sys:.em valves will be controlled by locks or seals with periodic inspections.

Locking or sealing programs depend upon ongoing administrative controls that are subject to human failure.

Locks c:a also preent p romp t water shutoff if piping ruptures.

It is recommended that electrical supervision be required on all control valves for fire protection systems protecting areas containing or exposing safety-related equipment.

Staff Response The guidelines of Appendix A to BT? 9.5-1 allow electrical super-vision, locking or sealing with tamper proof seals with periodic inspection as means of assuring that valves in fire pr-tection water systems are in the correct position. Valves on othe systems in the plant are presently under similar administrative control. The plant Technical Specifications require a monthly check of all valves in the flow path to fire suppression systems.

A review by the staff of Li ensee Event Reports for all plants using such periodic checks indicates that valves being in the incorrect position have not been a significant contributor to valve related failares.

Additionally, standing water as a result of failure of suppression system piping will n.ot damage safety-related equipment dae to curbs, drains, mounting of equipment above the floor level, grating and doorways. To date, the staff has not found any data that indicaces that electrical valve supervision will significantly improve the availability of fire suppres-sion systems for nuclear plants.

2.

Consultants

• Comment-Secke Removal SER hem 4.4.1 indicates that portaole fans and ducts will be accepted as the means for rascving smoke fr,m many plant areas.

Fires in electrical insular.ica can generate cc.7 ous amounts of dense smoke i

which hamper fire control efforts by rendering the atmosphere toxic and reducing vis bility in the area.

Properly used, self-contained breathing apparatus can minimize the problem of toxic atmospnere, but httle can be done to improve visibi.ity except to remove tne smoke f rom the bu:.iding.

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.k mutu$l'd Massive changes will be required in most areas of the plant ii effective permanent smoke removal systems are required, the design of which would also have to include consideratica of radioactive releases.

Wile portable fr.a. and ducts may be effective for smoxe control in many instances, tnere is concern that they will be sufficient for a major fire in some areas of the plant.

It is recommended tnat this item be held open until better guidelines are developed for the evalu-atton of smoke generation potential and smoke removal system design.

Staff Response Additional info rmation and imp roved equipment would provide scme benefit in the design and construction of ::xed ventilation systems to be used for smoke removal in future plants. However, a massive plant redesign of current plant ventilation systems is not warranted because portable smoke removal aquipment can be used in those areas with inadequate fixed smoke removal systems. Pottable smoke removal units have been used in fire service for a sufficient length of time so that the limits of their use is well understood.

In plants where smoke removal is dependen on such equipment, smoke removal is not genera.ly initiated until the room atmosphere is cooled sufficiently, by fixed sprinkler operation or manual hose fogging to pe rmit entry by fire fighting persor.nel. The current fire service portable smoke removal units hava s suf ficiently high temperature capability to remove cmoke when cue hot gasses are cooled enough for fire brigade entry. !ne manual fire fighting consultants nave made their evaluations of the fire capabilities of a number of plants and have recommcnded use of the artable smoke exnaust systems. U require the licensees to develop pre-fire plans, which include the proper use of ventilation equipment in each plant area of concern.

This is addressed in our Administrative controls review.

Consequently, there is adequate inf armation available at this time to continue to evaluate plant smoke removal capability.

The use of emergency breathing equipment, fire suppressica equipment, fire barriers, and other protective measures are evaluated based on the need for immediate access into an area and the limitations imposed by tne currently availabla portable smoke removal units. These concerns are evaluated on an area basis at each plant with due constderation of the advice of the manual fire fighting consultant (s).

3.

Consultants' Comments: Minimize Fire Effects SF.R Item 3.0 concludes that fire detection and suppression will naimi:e the effects of fire on safety-related systems. The consultant does not concur in this conclusion. There are usually several protectrie approaches that can be utilized for a given fire hazard, with each approach offer:ng certain advantages and dis. rantages in terms of limit;ng the fire extent. damage fue to tne fire suppression a gents emelayed, reliability, and cost effectiveness.

In most cases, it is

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technically possible to reduce the damage potential to a very '. o w level, but cost penalties of ten become severe.

The fire protection systems that are be ' ig provided and reccc: mended are to assure safe shutdown capabilit' and will not necessarily minimize fire damage to all safety-related systems.

Staff Resconse

'w'e agree with the consultants

• comments that additional steps could always be taken to further reduce physical damage to structures, systems and c c:ponents important to safety. However. -e are ustag in our terms " minimize in the Context of its use in Appendix A to STS 9.3-1 and GEC-3 where it means a general level of deteetton and suppress:en.

Thts level of protection is afforded to all safety systems, act only where required to prevent loss of safe shutdown capab '.ity.

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%Qlur APPENDIX A Correspondence from the Nuclear Regulator'/ Ccmmission to Florida Power Corporation Letter of:

May 3, 1976 Transmittal of Standard Review Position 9.5-1 Septemcer 30, 1975 Transmittal of Appendix A to AFCSS 9.5-i and Supplemental Cuidance December 17, 197f, Transmittal of Standardized Technical Specifications and Errata Sheet June 16, 19

Transmittal of Sample Technical Specification August, 1977 Transmittal of " Nuclear Plant Fire Protectron Functional Responsibilities, Administrative Controls and Quality Assuranc3" November 29, 1977 Transmittal of Tecnnical Specification Feb rua r/ 3, 1973 Transmittal of Amencment No. 13 March 23,1978 Transmittai of missing pages to Amendment No. 13 June 5, 1973 Transmittal of " Manpower Requirements for Operating Reactors" November 14, 1973 Transmittal of Fire Review Plan Questions Correspondence from Florida Power Corporatica

.o :he Nuclear Regulatorf Coc::nission Letter of:

October 26, 1976 Regarding Fire Protectica Program Review April 23, 1977 Regarding Fire Protectica Program Reevaluatica June 22, 1977 Transmittal of " Tire Protection Program Review

Juif ' 1, 197-Transmi :al of Technical Spec:.fication Chaage Request No. 4

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boendix A

~^ December 19, 1977 Regarding objection to Section 6.2.2.f of the proposed interim Technical Specifications.

May 30, 1978 Regarding FPC respcase to NRC Guidelines on Fire Protection.

June 23, 1973 Regarding NRC guidance document " Manpower Requtrements for Operating Reactors."

Janua r/ 9, 1979 Transmittal of response to tne Staf f $;te.isit posttions and questions.

Januarf 26, 1979 Transmittal of response to the Staf f Site lisit positions and questicus.

February la, 1979 Transmittal of response to : e Staff Site 7isit positicas and questicas.

Februa ry 27, 1979 Transmittal of respense to the Staf f Site ilisit positions and questicas.

April 5, 1979 T-ansmittal of response to the Staf f Site 'lisit positions and questions.

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