ML19208A601
| ML19208A601 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 08/09/1979 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19208A596 | List: |
| References | |
| NUDOCS 7909170059 | |
| Download: ML19208A601 (47) | |
Text
a FIRE PROTECTION SAFETY EVALUATION REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION U.S. NUCLEAR REGULATORY COMMISSION IN THE MATTER OF COMMONWEALTH EDISON COMPANY'S ORESDEN UNIT 1 DOCKET N0._ 50-10 6
5' 9909eo 0 Date:
August 9,1979 3511.10
(_
TA3LE OF CONTENTS PACE 1-1 1.0 INTRODUCT.0N..............................................................
2-1 2.0 FIRE PROTECTION GUIDELINES................................................
2-1 2.1 General Design Criterion 3
" Fire Protection".......................
2-1 2.2 Supplemental Guidance................................................
3-1 3.0
SUMMARY
OF MODIFICATIONS AND INCOMPLETE ITEMS.............................
3-1 3.1 Modifications.......................................
3-1 3.l.1 Fire Detection Systems.....................................
3-1 3.1.2 Fire Water System..........................................
3-2 3.1. 3 Fire Water Pump............................................
3-2 3.1.4 Hose Stations..............................................
3-2 3.1.5 Water Suppression Systems..................................
3-3 3.1.6 Foam Suppression................
3-3 3.1.7 Fire Doors.......................
3.1.8 Penetrations...............................................
3-3 3-3 3.1.9 Curbs......................................................
3.1.10 Fire Retardant Coatings....................................
3-3 3.1.11 Control of Combustibles....................................
3-4 3-4 3.1.12 Smoke Venting Equipment....................................
3-4 3.1.13 Breathing Apparatus.
3-4 3.1.14 Supervision of Fire Doors..................................
3-4 3.1.15 Cable Rerouting............................................
3-4 3.1.16 Battery Room Ventilation...................................
3.1.17 Diesel Generator Abandonment....................
3-4 3-5 3.1.18 Heat Co11ectors............................................
3-5 3.1.19 Turn Out Coats.............................................
3-5 3.1.20 Water Damage Protection....................................
3-5 3.1.21 Fire Dampers...............................................
3-5 3.1.22 Fire Stops.....................
3.1.23 Administrative Controls....................................
3-5 3-5 3.1.24 Gate Va1ves................................................
3.1.25 Interior Hose Station Nozzles..............................
3-5 3-5 3.2 Incomplete Items................
3-6 3.2.1 Detection System Tests.....................................
3.2.2 Technical Specifications for Existing Fire Protection 3-6 Systems and Hose Stations..................................
3-6 3.2.3 Fire Water System Feeds....................................
3-6 3.2.4 Exposed Structural Steel...........................
3-6 3.2.5 Emergency Condenser Valves.....................
3-6 3.2.6 Emergency Condenser Makeup.................................
3.2.7 Emergency Condenser Lev,el Indication...............
3-7 951111
a s
TABLE OF CONTENTS (Continued)
PAGE 4.0 EVA LU AT ION O F P LANT AR RANG EM EN T...........................................
4-1 4.1 Safe Shutdown Systems................................................
4-1 4.2 Fire Detection and Signaling Systems.................................
4-1 4.3 Fire Control Systems.................................................
4-2 4.3.1 Water Systems..............................................
4-2 4.3.i.1 Water Supply.....................................
4-2 4.3.1.2 Fire Pumps.......................................
4-2 4.3.1.3 Fire Water Piping System.........................
4-3 4.3.1.4 Interior Hose Stations........................
4-3 4.3.1.5 Automatic Sprinklers.............................
4-4 4.3.1.6 Foam Suppression System..........................
4-4 4.3.1.7 Effects of Suppression Systees on Safety Systems..........................................
4-4 4.3.2 Gas Fire Suppression Systems...............................
4-4 4.3.3 Portable Fire Extinguishers................................
4-5 4.4 Ventilation Systems and Breathing Equipment..........................
4-b 4.4.1 Ventilation Systems........................................
4-5 4.4.2 Breathing Equipment........................................
4-5 4.5 Floor Drains..............
4-6 4-6 4.6 Lighting Systems..........
4.7 Communication Systems................................
4-6 4.8 Electrical Cables.......
4-7 4.9 Fire Barrier Penetrations........................!...................
4-7 4.10 S e p a ra t i o n C r i t e r i a.................................................
4-7 4.11 Fire Barriers........................................................
4-8 4.12 Access and Egress....................................................
4-8 4.13 Toxic and Corrosive Combustion Products..............................
4-8 5.0 EVA LUATION O F S P ECIFIC P LANT AR E AS........................................
5-1 5.1 Containment / Reactor Building.........................................
5-1 5.2 Control Room.........................................................
5-2 5.3 North Auxiliary Bay..................................................
5-3 5-4 5.4 Battery Room.............
5.5 Switchgear Areas.................................
5-5
- 5. 6 Cable Passageway...................................
5-6 5.7 Turbine Buirding - Hydrogen Seal 01:
Area..........
5-7 5.8 Turbine Building - Primary and Secondary Feed Pump Area..............
5-7
- 5. 9 Core Spray and Post Incident Pump Area...............................
5-8 pr kt 4 o v u.
t..%
a I AllLlifL CONil NI)__(Cor!t I 3 od)
PAGE 5.10 Shop and Warehouse Area..............................................
5-9 5.11 Clean and Dirty Lube Oil Tank Room...................................
5-10 5.12 Screen House..........................................
5-11 5.13 Spent and New Fuel Building..................................
5-12 5.14 High Pressure Coolant Injection (HPCI) Building.............
5-12 5.lo A u x i l i a ry B o i l e r H o u s e.............................................
5-13 5.16 Yard Area............
5-14
- 6. 0 ADMINISTRATIVE CONTROLS.................................................
6-1 7.0 TECHNICAL SPECIFICATIONS..................................................
7-1
8.0 CONCLUSION
8-1 9.0 CONSULT ANTS ' REPORT.......
9-1 APPENDIX A CHRONOLOGY...
A-1 os-s 4 4el-u O.L.c,.3 t
e a
1.0 INTRODUCTION
Following a fire at the Brown's Ferry Nuclear Station in March 1975, the Nuclear Regulatory 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, published the report by a special review group entitled, " Recommendations Related to Browns Ferry Fire," NUREG-0050.
This report recommended that improvements in the areas of fire prevention and fire control be made in most existing facilities and that consideration be given to design features that would increase the ability of nuclear facilities to withstend fires without the loss of important functions.
To implement the report's recom-mendations, the NRC initiated a program for reevaluation of the fire protection programs at all licensed nuclear power stations and for a comprehensive review of all new license applications.
The NRC issued new guidelines for fire protection programs in nuclear power plants which reflect the recommendations in NUREG-0050.
These guidelines are contained in the following documents:
" Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," NUREG-75/087, Section 9.5.1, " Fire Protection,"
May 1976, which includes " Guidelines for Fire Protection for Nuclear Power Plants" (BTP APCSB 9.5-1), May 1, 1976.
" Guidelines for Fire Protection for Nuclear Power Plants" (Appendix A to BTP APSB 9.5-1), August 23, 1976.
" Supplementary Guidance on Information Needed for Fire Protection Program Evaluation," September 30, 1976.
" Sample Technical Specification." May 12, 1977.
" Nuclear Plant Fire Protection Functional Responsibilities, Adn.inis-trative Controls and Quality Assurance," June 14, 1977.
" Manpower Requirements for Operating Reactors," June 5, 1978.
All licensees were requested to:
(1) compare 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 struc-tures with both combustibles and the associated fire detection and suppression systems.
Our review was based on the licensee's proposed program for fire protection as described in the following docketed information:
1-1 Sis 1114
a (1) "Information Relevant to Fire Protection Systems and Programs of Dresden Nuclear Power Station Unit 1";
(2) The fire protection review team's site visit of March 19-22, 1979; and (3) The licensee's response to staff positions, dated May 1, 1979; Our review has been limited to the aspects of fire protection related to the protection of the public from the standpoint of radiological health and safety.
We have not considered aspects of fire protection associated with life safety of onsite personnel and with property protection, unless they impact the health and safety of the public due to the release of radioactive material.
This report summarizes the result of our evaluation of the fire protection program at Commonwealth Edison Company's Dresden Unit 1.
The chronology of our evaluation is summarized in Appendix A of this report.
OUN 1-2
a 2.0 FIRE PROTECTION GUIDELINES 2.1 General Design Criterion 3
" Fire Protection" The Commission'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 components important to safety shall be designed and located to minimize, consistent with other safety require-ments, the probability and effect of fires and explosions.
" Noncombustible and heat resistant materials shall be used wherever practical throughout the unit, particularly in locations such as the containment and the control room."
" Fire detection and fighting systens 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 that their rupture or inadvertent operation does not significantly impair the safety capability of these structures, systems and components."
2.2 Supplementary Guidance Guidance on the implementation of General Design Criterion 3 for existing nuclear power plants is provided in Appendix A of Branch Technical Position 9.5-1, " Guidelines for Fire Protection for Nuclear Power Plants."
Appendix A provides guidance on the preferred and, where applicable, acceptable alternatives to fire protection design for those nuclear power plants for which applications for construction permits were docketed prior to July 1, 1976.
Although this appendix provides specific guidance, alternatives may be proposed by licensees.
These alternatives are evaluated by the NRC staff on a case-by-case basis.
Additional guicance which provides clarification of fire protection matters has been providad by the NRC staff in the following documents:
" Supplementary Guidance on Information Needed for Fire Protection Program Evaluation," October 21, 1976.
" Sample Technical Specifications," May 12, 1977.
2-1 gg111g
" Nuclear Plant Fire Protection Functional Responsibilities, Adminis-trative Controls and Quality Assurance," June 14, 1977.
" Manpower Requirements for Operating Reactors," June 5, 1978.
When the actual configuration of combustibles, safety-related structures, systems or components, and the fire protection features are not as assumed in the developnalt of Appendix A or when the licensee has proposed alterna-tives to the specific recommendations of Appendix A, we have evaluated such unique configurations and alternatives using the defense-in-depth objectives outlined below:
(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 (4) prevent the release of a significant amount of radioactive materials if fires occur.
In our evaluation, we assure that these objectives are met for the actual relationship of combustibles, safety-related equipment and fire protection features of the facility.
Our goal is a suitable balance of the many methods to achieve these indi-vidual objectives; increased strength, redundancy, performance, or reliability of one of these methods can compensate in some measures for deficiencies in the others.
2-2 3U1117
3.0
SUMMARY
OF MODIFICATIONS AND INCOMPLETE ITEMS
'.1 Modifications 3
The licensee plans to make certain plant modifications to improve the fire protection program as a result of both his and our evaluations.
These proposed modifications are summarized below.
The sections of this report which discuss the modifications are noted in parentheses following each item.
Further detail is contained in the licensee's submittals.
The schedule for implementation of these modifications is given in Table 3.1.
Certain items listed below are marked with an asterisk to indicate that we will require additional information in the form of design details to assure that the design is acceptable prior to actual implementation of these modifications.
This information should be submitted within six mcaths of the issuance date of this Safety Evaluation.
The balance of the other modifications has been described in an acceptable level of detail.
3.1.1 Fire Detection Systems Early warning fire detection systems will be provided in-the following areas:
(1)
In the control room (5.2).
(2)
In the sphere penetration area (5.1).
(3)
In the battery room (5.4).
(4)
In the vicinity of 480V switchgear 16 and 17 and Power Centers 25 and 26 (5.3).
(5)
In the instrument shop area adjacent to the battery room off the north auxiliary bay (5.3).
(6)
In the vicinity of 4KV switchgear 11 and 12, 480V switchgear 14 and 15, power cent?rs 19 and 20, and adjacent 125V DC control panel (5.5).
(7) In the vicinity of spent fuel pool (5.13).
3.1.2 Fire Water System The licensee will provide an additional sectional control valve in the fire water loop which will allow an impaired section to be-isolated so as to retain the capability of feeding the HPCI building from the fire system (4.3.1.3).
t 3-1 351118
The globe valves in the fire water system in the High Pressure Coolant Injection building will be replaced with OS&Y gate valves (5.14).
3.1.3 Fire Water Pump A 2500 gpm diesel driven fire water pump will be provided to replace the existing fire pump, and will be installed in conformance with the require-ments of NFPA-20.
The screen wash pumps are isolated from the fire system by a check valve (4.3.1.2).
3.1.4 Hose Stations Booster hose stations will be provided in the containment (5.1).
Additional hose will be provided for hose stations to reach all areas of the cable passageway (5.6).
3.1.5 Water Suppression Systems The sphere cable penetration area will be protected by an automatic deluge system (5.1).
A sprinkler system will protect areas of high cable concentration in the north auxiliary bay to include the cable riser area to the cable passageway in the northwest corner of the feed pump area (5.3) 5.8).
The hydrogen seal oil area will be provided with an automatic water deluge system (5.7).
The cable passageway has been provided with an automatic water spray pre-action sprinkler system.
The design drawing for this system will be reviewed (5.6).
The Unit 1 trackway sprinkler protection will be extended to include the corridor to the laundry storage area and the welding shop (5.8).
The diesel fire pump installation in the screen house will be protected by an automatic water suppression system (5.12).
The core spray and post incident pump areas of the access control area will be protected by an automatic water suppression system (5.9).
The new fuel receiving area will be protected by the installation of a water sprinkler system (5.13).
The bus duct penetrations and door in...e.. orth auxiliary bay wall will be protected by water suppression deluge system whose feed is independent from the transformer deluge system (5.16).
3-2 351119
An extra hazard sprinkler system will be provided for the clean and dirty oil storage room (5.11).
3.1.6 Foam Suppression Portable foam equipment including pickup tubes and foam concentrate will be provided for use by the fire brigade (4.3.1.6).
3.1.7 Fire Doors Fire doors will be provided with class A ratin;s at the following locations:
(1) control room access doors (5.2)
(2) the access door to the north auxiliary bay from the reserve auxiliary transformer (5.3)
(3) the west wall of area 8.4.2 (condensate pumps and hydrogen seal oil unit area) will be upgraded to provide a class A 3-hour fire door (5.7)
(4) the diesel fire pumo area doors to the service water pump area in the screen house (5.12)
(5) the battery room door leading to the north auxiliary bay (5.4).
3.1.8 Penetrations Penetrations will be upgraded to 3-hour ratings for the following areas:
(1)
In the area between the fire pumps and the service water pumps in the screen house (5.12).
(2) Electrical and pipe penetrations in the west wall of the condensate pumps and hydrogen seal oil unit area (5.7).
3.1.9 Curbs Curbs will be provided at the doors in the screen house to prevent diesel fuel from flowing into the service water pump area from the diesel fire pump area (5.12).
3.1.10 Fire Retardant Coatings Where two divisions of safety-related cables are routed in close proximity without conduit in the containment, the cables will be covered with a flame retardant coating.
Where two divisions of safety-related cables are routed in close proximity in conduit, flame retardant coatings will be required for cabling where the combustible loading is sufficient to damage the cable in the conduit (5.1).
3-3 3511'd0
3.1.11 Control of Combustibics The wood used as partition supports for the walls of the instrument cali-bration area of the control room has been removed or treated to increase its fire resistance rating (5.2).
The control room false ceiling will be replaced with a ceiling of non-combustible construction (5.2).
The carpeting in the control room has been replaced with suitable fire resistant material (5.2).
The contents of the warehouse will be removed from the shop and warehouse area into a new warehouse building under construction (5.10).
3.1.12 Smoke Venting Equipment fortable ventilation equipment has been provided and procedures have been developed and implemented for its use by the fire brigade such that smoke can be vented from enclosed areas to permit access for manual fire fighting (4.4).
3.1.13 Breathing Apparatus The supply of breathing apparatus for the fire brigade and control room personnel ~is being upgraded to provide a minimum of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> (4.4).
3.1.14 Supervision of Fire Doors Fire doors protecting safety-related areas will be electrically supervised, locked closed, or administratively controlled to insure that they will be effective to limit fires from spreading between fire areas (5.16).
3.1.15 Cable Rerouting Dresden Unit 1 is undergoing an extensive modification associated with cable routings for the reactor protection system (4.10).
3.1.16 Battery Room Ventilation The 125V battery room in the turbine building will be provided with an alarm in the control room which gives indication of a loss of ventilation (5.4).
3.1.17 Diesel Generator Abandonment Following the installation of the essential service auxiliary power diesel generators, the existing diesel installation located in the north auxiliary bay will be abandoned.
The diesel fuel and lubricants will be removed from the area so as not to expose safety-related equipment (5.3).
3511'd1 3-4
e
- 3. 6. i d Heat Lollectors Heat collectors will be provided for the temperature sensors used to actuate the CO system for the primary feed pump area (5.8).
2 3.1.19 Turn Out Coats Ten flame resistant coats will be provided for fire brigade access to fires (4.12).
3.1.20 Water Damage Protection Water damage protection will be provided over the switchgear centers (5.3)
(5.5).
3.1.21 Fire Dampers Fire dampers will be provided at the following locations:
In the penetrations to the control room (5.2)
In the penetrations to the battery room (5.4).
3.1.22 Fire Stops The cable risers whose length exceeds 20' which are located inside containment will be provided with fire stops.
Where fire stops are provided, they shall be placed at 15-foot maximum intervals (5.1).
3.1.23 Administrative Controls The licensee will provide quarterly fire training for each fire brigade.
3.1.24 Gate Valves Gate valves will be provided on each hydrant port (5.16).
3.1.25 Interior Hose Station Nozzels The licensee has agreed to provide spray type nozzles for medium voltage areas (4.3.1.4).
3.2 Incomplete Items In addition to the licensee's proposed modifications, a few incomplete items remain, as discussed below.
The sections of this report which
-The licensee discuss these incomplete items are noted in parentheses.
will complete the evaluations necessary to resolve these items in accord-ance with the schedule contained in Table 3.2.
This schedule has been established such that should these evaluations identify the need for additional modifications, they can be implemented on a schedule consistent We will with completion of the modifications identified in Section 3.1.
address the resolution of incomplete items in a supplement to this report.
3-5 3511.2r?,
3.2.1 Detection System Tests In situ tests will be conducted with a suitable smoke generation device to verify that the products of combustion from a fire would be promptly detected by installed smoke detectors and that ventilation air flow patterns in the area do not significantly reduce or prevent detection response.
Bench tests will be conducted to verify that smoke detectors will provide prompt response and have adequate sensitivity to the products of combustion' for the combustibles in the area where smoke detectors are or will be installed.
If any fire detection systems are found to be inadequate, appropriate modifications will be made to provide adequate detection system perf0rmance (4.2).
3.2.2 Technical Specifications for Existing Fire Protection System ar je Stations The licensee will provide a list of hose stations and automatic systems which will be a part of technical specifications for safety-related areas.
3.2.3 Fire Water System Feeds We have requested the licensee to separate the feeds for hose stations from the feeds for fixed suppression systems in the post incident-core spray area, Unit 1 cable passageway, the North Auxiliary Bay, and primary and secondary feed rump areas.
The licensee will evaluate this concern.
3.2.4 Exposed Structural Steel We have requested that the exposed structural steel in the north auxiliary bay above the large concentration of cables in the area be provided with flame retardant coatings.
The licensee will evaluate this neqcern.
3.2.5 Emergency Condenser Valves We have requested that the emerge,cy condenser condensate return valves be placed on independent power sources and their control and power cables be physically separated from each other.
The licensee will evaluate this concern.
(5.1) 3.2.6 Emergency Condenser Makeup We have requested that the licensee evaluate providing an additional means to permit makeup to the emergency condenser independent of the existing makeup valve (5.1).
The licensee will evaluate this concern.
3-6 51123
3.2.7 Emergency Condenser Level Indication We have requested that redundant level indication for makeup control be provided for the emergency condenser which is physically separated by separate fire areas or an additional means be provided to indicate level which is independent of fire damage to the existing level indication (5.1).
The licensee will evaluate this concern.
3-7 0011,34
Table 3.1 Schedule of Implementation Prior to Startup of Dresden 1 3.1.1 Fire Detection Systems...................
Prior to Startup of Dresden 1 3.1.2 Fire Water System........................
Prior to Startup of Dresden 1 3.1.3 Fire Water Pump..........................
Prior to Startup of Dresden 1 3.1.4 Hose Stations............................
Prior to Startup of Dresden 1 3.1.5 Water Suppression Systems................
3.1.6 Foam Suppression.........................
Completed Prior to Startup of Dresden 1 3.1.7 Fire Doors...............................
Prior to Startup of Dresden 1 3.1.8 Penetrations.............................
Prior to Startup of Dresden 1 3.1.9 Curbs....................................
Prior to Startup of Dresden 1 3.1.10 Fire Retardant Coatings..................
Prior to Startup of Dresden 1 3.1.11 Control of Combu sti bl es..................
Prior to Startup of Dresden 1 3.1.12 Smoke Venting Equipment..................
Prior to Startup of Dresden 1 3.1.13 Breathing Apparatus......................
Prior to Startup of Dresden 1 3.1.14 Supervision of Fire Doors................
Prior to Startup of Dresden 1 3.1.15 Ca bl e R e rou t i ng..........................
Prior to Startup of Dresden 1 3.1.16 Battery Room Ventil ation.................
Prior to Startup of Dresden 1 3.1.17 Diesel Generator Abandonment.............
Prior to Startup of Dresden 1 3.1.18 Heat Collectors..........................
Prior to Startup of Dresden 1 3.1.19 Turn Out Coats...........................
Prior to Startup of Dresden 1 3.1.20 Water Damage Protection..................
Prior to Startup of Dresden 1 3.1.21 Fire Dampers.............................
Prior to Startup of Dresden 1 3.1.22 Fire Stops...............................
3.1.23 Admini strative Control s..................
Completed Prior to Startup of Dresden 1 3.1.24 Gate Valves..............................
3.1.25 Interior Hose Station Nozzles............
Prior to Startup of Dresden 1 o r a 9. n--
m.* O.L..t.J.os3 3-8
Table 3.2 Schedule of Licensee Submittals 3.2.1 Detection System Tests 3 months prior to the return to service of Unit 1 3.2.2 Technical Specifications for 3 months prior to the return Existing Fire Protection Systems to service of Unit 1 and Hose Stations 3.2.3 Fire Water System Feeds August 1, 1979 3.2.4 Exposed Structural Steel August 1, 1979 3.2.5 Emergency Condenser Valves September 1, 1979 3.2.6 Emergency Condenser Makeup September 1, 1979 3.2.7 Emergency Condenser Level Indicati.on September 1, 1979 3-9 35112G
4.0 EVALUATION OF PLANT ARRANGEMENT 4.1 Safe Shutdown Systems There are several arrangements of safe shutdown systems which are capable of shutting down the reactor and cooling the core during and subsequent to a fire.
The exact arrangement available in a fire situation will depend upon the effects of the fire on such systems, their power supplies, and control stations.
During or subsequent to a fire, safe shutdown could be achieved using safety-related equipment such as:
the reactor trip system; the emergency condenser cooling system or the high pressure coolant injection system; the electromatic relief valves can be used to relieve steam to the condenser; the demineralized water storage tank; and the containment cooling service water system.
Supporting systems and equipment such as the emergency essential service auxiliary power diesel generatcrs, located in the new high pressure coolant injection building, are physically separate systems which can be used to power essential services.
The licensee has conducted an analysis of critical plant areas to insure that at least one method is available to achieve safe shutdown for fire damage in any plant area.
Reactivity control is provided by the reactor trip systems.
A separate review of the proposed modifications to improve separation and channel independence is being conducted for this system.
The emergency condenser provides the simplest and most direct way of effecting decay heat removal.
Although redundant valves are provided to place this system into operation, their power and control cables are not physically separated to preclude damage of this system due to fires.
In addition, a single power source is used to initiate operation of this system.
An alternative cooling method is available by the use of the HPCI system for makeup to the primary system and decay heat removal by use of electromatic valves to bypass steam to the condenser or direct venting of steam by the reactor safety valves to the containment.
We have requested that the licensee provide an additional means to permit makeup to the emergency condenser independent of the existing makeup valve.
The licensee has agreed to evaluate this request.
We will report on the adequacy of safe shutdown systems subsequent to rs eipt of the licensee submittal.
We will report in a supplement to this report.
4.2 Fire Detection and Signaling Systems Fire detection systems are provided in conjunction with some fixed automatic extinguishing systems.
Audible and visual alarm annunciators are provided in the control room.
Sprinkler system waterflow alarm and various super-visory signals alarm in the control room.
Fire alarms are similar to other panel alarms.
3I511,W
The existing fire detection and actuation system is connected to the plant 125V DC power supply.
The DC supply is connected via the battery chargers to the station's emergency AC power system.
Early warning detectors will be installed over a number of switchgear and motor control centers, in the battery room, in the vicinity of the spent fuel pool and in conjunction with automatic extinguishing systems.
Smoke detectors will be installed behind upright control cabinets in the control '
room and also in the general area of the control room.
All new alarm systems will be interconnected to the new security system computer.
Heat collectors will be provided for the thermostats for actuation and alarm systems in the feed pump area.
In situ tests will be conducted with a suitable smoke generation device to verify that the products of combustion from a fire would be promptly detected by installed smoke detectors and that ventilation air flow patterns in the area do not significantly reduce or prevent detection response.
Bench tests will be conducted to verify that smoke detectors will provide prompt response and have adequate sensitivity to the products of combustion for the combustibles in the area where smoke detectors are or will be installed.
If any fire detection systems are found to be inadequate, appropriate modifications will be made to provide adequate detection system per'formance.
We find that, subject to the implementation of the above described modifi-cations, the fire detection systems satisfy the objectives identified in Section 2.2 of this report and are, therefore, acceptable.
4.3 Fire Cortrol Systems 4.3.1 Water Systems 4.3.1.1 Water Supply Fire water is obtained from a canal supplied from the cooling lake or from the Kankakee River.
One diesel driven fire pump is located in the Unit 1 crib house, which supplies water to the common yard loop system.
The total volume of water available for fire protection is adequate.
We find that the fire water supply satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
4.3.1.2 Fire Pumps A diesel-driven 2,000 gpm 0 131 psig vertical shaft fire pump is located in the Unit 2 and 3 crib house adjacent to the service water pumps.
The service water pumps maintain pressure on the fire protection system and are the first line of defense for water supply in a fire situation.
A diesel driven 1000 gpm @ 100 psig fire pump is located in the Unit 1 crib house.
The Unit I screen wash pumps provide an alternate source of fire water supply for the Unit 1 fire pump.
The Unit 1 fire pump does not have sufficient capacity to meet the largest site fire water demand.
4-2 351120
1 The licensee has proposed to provide a 2500 gpm 0 145 psig diesel driven fire pump in the Unit I crib house to replace the existing 1000 gpm pump.
A 52 gpm jockey pump will be installed to maintain supervisory pressure on the. fire loop.
The screen wash pumps are isolated from the fire system by a check valve.
We find that, subject to the implementation of the above described modifi-cations, the fire pumps satisfy the objectives identified in Section 2.2 of this report and are, there'~ ore, acceptable.
4.3.1.3 Fire Water Piping System The Unit 1 fire pump and screen wash pumps supply the 8-inch underground main which encircles Unit 1 and is connected to the 8-inch loop which encircles Units 2 and 3.
The west part of the Unit i loop runs above ground through the Unit 1 turbine building and auxiliary building.
The main feed for the fixed
r< protection system in the turbine building ana auxiliary building is connected to the above ground portion of the loop which is connected to the south underground section of the loop.
Isolation valves are provided on both sides of the connection to the loop.
We have requested the licensee to separate the feeds for hose stations from the feeds for fixed suppression systems in safety-related areas.
The licensee will evaluate this concern.
Yard hydrants have been provided at approximately 300-foot intervals around the exterior of the plant.
Hydrants have hose houses equipped with various amounts of 2-1/2-inch hose and 150 feet of 1-1/2-inch hose and other manual fire fighting tools.
The hydrant hose threads are compatible with the local fire department.
The licensee will provide an additional sectional control valve in the fire water loop to permit feeding the HPCI building in the event of an impairment in the fire water loop.
The licensee will provide additional fire fighting equipment and 2-1/2-inch gated valves on each hydrant outlet.
Upon receipt of the licensee's evaluation, we will report on the adequancy of the fire water piping systems in a supplement to this report.
4.3.1.4 Interior Hose Stations Hose stations are located throughout most areas of the plant and each is equipped with 50, 75 or 100 feet of 1-1/2-inch woven jacket rubber lined hose.
Hose stations or additional lengths of hose will be provided where interior fire hose stations do not provide adequate coverage. The licensee has agreed to replace solid rtream type hose nozzles with spray type nozzles for medium voltage areas.
We find that, subject to the implementation of the above described modifi-caticns, the interior fire hose stations satisf y the objectives identified in Section 2.2 of this report, and are, therefore, acceptable.
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4.3.1.5 Automatic Sprinklers An automatic water suppression system protects the warehouse area.
Water-flow alarm annunciates in the control room.
Various types of automatic water suppression will be provided to protect the areas or hazards identified in Section 5 of this report.
Waterflow alarms will be integrated with the security computer.
We find that, subject to the implementation of the modifications noted herein, the automatic water suppression systems satisfy the objectives identified in Section 2.2 of this report and are, therefore, acceptable.
4.3.1.6 Foam Suppression System Portable foam equipment, including two inductors and 50 gallons of foam, will be provided at a strategic location.
We find that, subject to the provisions of the above equipment, the foam suppression capability satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
4.3.1.7 Effects of Suppression Systems on Safety Systems The presently installed suppression systems do not have an adverse effect on safety-related equipment.
There are areas where new water suppression systems will be installed in the vicinity of switchgear and motor control centers.
The electrical equipment in the area of sprinkler influence will be protected at the top to prevent water damage as identified in Section 5.0 of this report.
We find that, subject to the implementation of the modifications noted herein, adequate measures will be taken to address the effects of suppression systems on safety systems.
This satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
4.3.2 Gas Fire Suppression Systems Local application carbon dioxide systems, actuated by heat detectors, protect the primary feed pumps and the secondary feed pumps.
These systems are supplied by a 4 ton bulk carbon dioxide low pressure tank.
An automatic total flooding carbon dioxide system protects the turbine lube oil room and the clean and dirty lube oil room.
Actuation of the system closes doors and ventilation openings.
This system is also supplied by the 4 ton low pressure tank.
An automatic total flooding carbon dioxide system will be provided for each side of the HPCI Building.
Sufficient high pressure carban dioxide will be provided for a double shot application for one side.
4-4 351130
We find that the gas fire suppression systems satisfy the objectives identified-in Section 2.2 of this report and are, therefore, acceptable.
4.3.3 Portable Fire Extinguishers Portable dry chemical and carbon dioxide fire extinguishers have been distributed throughout the plant.
In areas containing sensitive electri-cal equipment, carbon dioxide extinguishers have been installed.
The extinguishers are installed and maintained in accordance with NFPA 10.
We find that the portable fire extinguishers satisfy the objcctives iden-tified in Section 2.2 of this report and are, therefore, acceptable.
4.4 Ventilation Systems and Breathing Equipment 4.4.1 Ventilation Systems The plant does not have exhaust systems designed specifically for smoke removal.
The normal air handling systems in most areas can be used for smoke removal; however, their effectiveness may be limited by several factors.
The fans and other equipment in the air handling systems are not designed to withstand high temperatures, and can be rendered inoperative by the heat from a significant fire.
The capacity and configuration of the normal' air handling systems may be inadequate for effective smoke removal.
The licensee has proposed the following modifications.
Portable exhaust units and ductwork will be placed at strategic locations to aid in exhausting of smoke, and procedures will be developed for the use of this portable equipment.
Electrical supervision of the ventilation systems for battery rooms will be installed to provide an alarm on the loss of air flow to preclude the buildup of hydrogen.
We find that, subject to the implementation of the above described modifi-cations, ventilation systems satisfy the objectives identified in Section 2.2 of this report and are, therefore, acceptable.
4.4.2 Breathing Equipment The emergency air breathing apparatus at Dresden station is being upgraded to provide sufficient supply for five individuals with breathing air for six hours.
The licensee will provide 90 charged bottles for fire brigade use.
Each individual operator in the control room will have a breathing air station which will be supplied from six 300 cubic foot air bottles installed on a manifold system.
The manifold system will provide sufficient air for five individuals for six hours.
We find that, subject to implementation of the above described modifica-tions, the breathing equipment satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
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4.5 Floor Drains Floor drains from the various areas of the plant are routed according to their content.
Areas which contain flammable liquids such as the diesel generator rooms drain their oil to an oil / water separator.
The licensee will install curbs at locations where inadequacies exist at the present time for routing of drainage and to preclude the spreading of fire.
The areas where curbs will be provided are delineated in Section 5.0 of this report.
Effuents from drains in potentially radioactive areas are analyzed prior to their release.
We find that the drain systems satisfy the objectives identified in Section 2.2 of this report and are, therefore, acceptable.
4.6.
Lighting Systems The normal lighting system receives its power from the station auxiliary transformers and a backup source of power is provided by the station diesel generator.
Emergency lighting is also provided which is powered from the 125V DC station batteries.
The licensee has insured the avail-ability of adequate lighting by providing seal beam self-contained battery operated lights at strategic locations throughout the plant.
These units are equipped with carrying handles, thus making them usable as portable emergency lighting.
We find that the lighting systems satisfy the objectives identified in Section 2.2 of this report and are, therefore, acceptable.
4.7 Communication Systems Normal communication is provided by a telephone system with extension handsets at various locations throughout the plant.
A page and answer system is also provided which is connected to an emergency bus which is supplied power from a diesel generator.
A number of voice powered headset stations provided for maintenance use would be available under emergency conditions.
A radio communication system consisting of two channels for two-way voice communication and repeaters to provide reception throughout the plant is being installed.
A total of 15 handie-talkie units are available to operating persoanel in addition to units used by the plant security force.
We find that the communication equipment to coordinate fire fighting and safe shutdown activities during a fire situation satisfy the objectives identified in Section 2.2 of this report and are, therefore, acceptable.
- 4. 8 Electrical Cables The cable insulation used in the plant consists of mainly cross linked polyethylene insulated conductors with cross linked polyethylene jackets for power and control cables.
The flame test stacdard for cables, IEEE Std 383, was not in effect at the time cables were purchased and installed 4-6 l Q Q '3
s
-m
_re r at Dresden Unit 1.
Flame retardant coatings will be applied on cables as indicated in Section 3.1.10 in the containment where redundant divisions of cables are located in close proximity.
The majority of the cable trays are of expanded metal construction.
Ladder rung trays are used primarily where cables enter motor control centers and switchgear.
The fire protec-tion system, including proposed modifications, gives due consideration to the combustibility of electrical cables.
We find that the fire protection for electrical cables satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
4.9 Fire Barrier Penetrations Fire barriers are penetrated by doorways, ventilation ducts, electrical cables, piping and conduit.
The licensee has successfully conducted a test program to test electrical penetration seals for fire resistance based on typical plant arrangements and designs.
Fire doors for safety-related areas will be either locked closed or administratively controlled to assure that they are maintained in the closed position.
The adequacy of fire barrier penetrations has been addressed in a test report submitted by the licensee.
We find that the fire barrier penetra-tions are adequate and satisfy the objectives identified in Section 2.2 of this report and are, therefore, acceptable.
4.10 Separation Criteria At the time of construction of Dresden Unit 1 there was no separation criteria in effect.
The licensee has undertaken a major revision to the reactor protection system cables to separate these circuits.
In addition, the licensee is considering rerouting of cables used to provide power and level indication for the emergency condenser system.
As noted in Section 4.1, the licensee has confirmed the capability for safe shutdown independent of fire damage in any plant area.
W'e conclude that the physical separation criteria in itself is inadequate to provide protection for redundant safety-related systems from the stand-point of potential fires.
Subsequent sections of this report address existing fire protection measures and the licensee's modifications for upgrading of fire protection in specific areas.
We find that, subject to implementation cf the modifications identified in Section 3.0 of this report, adequate meastres have been taken to compensate for the inadequacies of physical separation.
This satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
4.11 Fire Barriers Fire areas are enclosed by floors, walls and ceilings which have a 3-hour rating with a few exceptions.
In some areas walls are being upgraded to 4-7 OU1130
i 3-hour rating.
Areas not having a 3-hour rating are found acceptable on the basis of a light combustible loading or that redundant safety-related equipment will not be jeopardized.
Further detail is provided in Section 5.0 of this report as to which barriers will be upgraded.
We find that, subject to implementation of the modifications noted herein, fire barriers satisfy the objectives identified in Section 2.1 of this report and are, therefore, acceptable.
4.12 Access and Egress Access to most areas of the plant presents little problem due to the size of the facility and the number of elevations.
Access to a fire can be affected by the lack cf proper wearing apparel.
The licensee will provide 10 flame resistant turn out coats for fire brigade use.
We find that the provisions for access and egress satisfy the objectives identified in Section 2.2 of this report and are, therefore, acceptable.
4.13 Toxic and Corrosive Combustion Products The products of combustion for many plastic materials are toxic to humans and corrosive to metals.
Prompt fire detection fire stcps and extinguish-ment are relied upon to minimize the quantities of such products.
Additional means of smoke removal will be provided as an aid in smoke removal as
'~
noted in Section 4.4 of this report.
The fire brigade is provided with and trained in the use of emergency breathing apparatus for fighting fires involving such materials.
We find that the subject of toxic and corrosive products of combustion has been adequately addressed.
This satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
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5.0 EVALUATION OF SPECIFIC PLANT AREAS The licensee has performed a fire hazards analysis of the facility to determine the fire loading of various plant areas and to evaluate the adequacy of existing and proposed fire protection systems The results of the fire hazards analysis, other docketed information, an-site visit observations were used in our evaluation of specific plant areas.
Our evaluation of specific plant areas is discussed in the following sections.
5.1 Containment / Reactor Building 5.1.1 Safety-Related Equipment The safety-related equipment in the containment / reactor building include the emergency condenser, scram dump tank, poison storage pumps, reactor enclosure cooling heat exchangers and cooling water pumps, the unloading pumps, and the safety-related cables for this equipment.
In addition, the containment contains the reactor vessel, the steam generators and major equipment of the primary system.
5.1.2 Combustibles The combustibles in containment consist mainly of cable insulation, wood, plastic sheets, and a small amount of lubricating oil associated with the unloading pumps.
5.1.3 Consequerces if No Fire Suppression An unmitigated fire in the containment could damage systems required to safely shutdown.
The emergency condenser condensate return valves are supplied power from common power centers and their cables are not physically separated.
There is only one method to permit makeup to the emergency condenser.
Redundant level indication for the emergency condenser is not adequately separated to prevent their loss due to fire damage.
5.1.5 Adequacy of Fire Protection The fire protection systems inside containment are not adequate to protect all areas of the containment.
The cable penetration area has a large con-centration of cable insulation.
Cable risers are not protected with fire retardants or fire stops.
There are no hose stations inside containment.
Cable separation inside containment is not adequate to prevent fire damage to redundant systems.
5.1.6 Modifications The licensee has proposed the following modifications.
An automatic fire detection and water suppression system will be provided in the cable pene-tration area of the containment.
Flame retardant coatings will be provided, 5-1
$51.1.3[3
as indicated in Section 3.1.10, where two divisions of safety-related cables are routed in close proximity.
Fire stops will be provided in cable risers as appropriate.
Fire stops will be provided at the 15-foot and 30-foot level in cable risers whose length exceeds 20 feet as indicated in Section 3.1.10, to reduce the combustible loading inside containment.
The licensee will provide 1-inch booster hose stations fed from demineralized water connections inside containment.
We have requested that the emergency condenser condensate return valves will be placed on independent power sources and their control and power cables physically separated.
We have requested an additional means be provided to permit makeup to the emergency condenser independent of the existing makeup valve.
We have requested that the redundant level indication for the emergency condenser be physically separated by separate fire areas or an additional means should be provided to indicate level for makeup control which is independent of potential fire damage to the existing level indication.
The licensee has agreed to evaluate these requests and we will report on these items in a supplement to this report.
5.2 Control Room 5.2.1 Safety-Related Equipment The control room contains the controls necessary for station operation and for safe reactor shutdown.
Operating indication, controls and alarms are mounted on vertical control boards and an operator's console.
The control room for Unit 1 is a shared control room, common for Units 2 and 3.
5.2.2 Combustibles The combustibles in the control room consist of electrical cable insulation, electrical wiring within the control boards, floor covering, a luminous false ceiling, wood partitions associated with the instrument shop, and paper consisting of operating procedures.
Some paper is located in sheet metal filing cabinets.
5.2.3 Consequences if No Fire Suppression An unmitigated fire in the control room has the potential for damaging safety-related equipment within both divisions of safety-related systems.
5.2.4 Fire Protection Systems Smoke detectors are located in the heating and ventilating return air duct from the control room and above the luminous ceiling.
Portable C0 fire 7
extinguishers and a 10 pound portable Halon fire extinguisher are provided in the control room.
Additional extinguishers are located in close proximity outside the control room including a dry chemical and a 2-1/2 gallon water tank pump unit.
A fire water hose reel station is located outside the control room.
The control room will be provided with a fire water booster hose station with a low flow nozzle to reach all areas of the control room.
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[$1,1.36
5.2.5 Adequacy of Fire Protection The present fire protection for the control room is inadequate.
The false ceiling and floor covering both present an unnecessary contribution to the fire loading in the area.
The present fire detection system is inadequate to provide prompt response to permit extinguishment to limit potential damage to safety-related systems.
Door cp01ings and ventilation penetra-tions of the control room fire area boundary are inadequate to prevent an exposure fire from entering this area.
5.2.6 Modifications The licensee has proposed the following modifications.
The floor covering and false ceiling will be replaced with suitable fire resistant materials.
An engineered fire detection system will be installed in the consoles and control boards and in the general areas of the control room.
Access doors will be replaced with 3-hour fire rated class A doors.
Fire dampers will be installed in ventilation ducts penetrating the area fire barriers.
CECO will consider coating exposed structural steel in the floor with a flame retardant.
We find that, subject to the implementation of the above described modifi-cations, the fire protection for the control room satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
- 5. 3 North Auxiliary Bay 5.3.1 Safety-Related Equipment The safety-related equipment in this area includes 480V switchgear 16 and 17, power centers 25 and 26, demineralizer water jockey and supply pump, diesel generator, and makeup system pumps.
'5.3.2 Combustibles Combustibles in this area includes a high concentration of cables, 165 gallons of lubricating oil in the diesel engine and 275 gallons of diesel fuel.
5.3.3 Consequences if No Fire Suppression An unmitigated fire in this area could adversely affect the makeup pumps to the isolation condenser, the majority of the cables entering the control room, and the 480V switchgear and power centers.
5.3.4 Fire Protection Systems Hose stativ.ns and portable extinguishers protect this area.
An automatic local application carbon dioxide system protects the diesel generator.
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5.3.5 Adequacy of Fire Protection Due to the lack of early warning detection over the switchgear and power centers, a fire could develop which could cause extensive damage to this equipment.
The lack of automatic suppression in the high cable concentra-tion in this area could lead to the loss of the majority of these cables.
Manual fire fighting would be very difficult in this area due to cable tray arrangement.
The lack of smoke detectors in the instrument repair shop would allow a fire to progress to a size where damage could occur to the cables above the metal ceiling.
5.3.6 Modifications The licensee has proposed the following modifications.
Upon completion of the addition of new diesel generators, the existing emergency diesel generator will be abandoned in place.
All the diesel fuel and lubricating oil will be removed.
Smoke detection will be provided in the instrument repair shop and over the switchgear and the power centers in this area.
An automatic water suppression system will be provided to protect the high concentration of cables in the north auxiliary bay to include the cable risers into the cable passageway.
The top of the electrical equipment will be sealed to reduce the potential of water damage from hose streams or sprinkler systems.
We find that, subject to the implementation of the above described the modifications, the fire protection for the north auxiliary bay satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
5.4 Battery Room 5.4.1 Safety-Related Equipment The batteries in this room supply DC power to safety-related motor operated valves and pumps.
5.4.2 Combustibles The majority of the combustibles are in the battery casing with minor amounts of cable insulation.
5.4.3 Consequences if No Fire Suppression An unmitigated fire in this area could result in the loss of the DC power sources to valves and motors.
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5.4.4 Fire Protection Systems Fire protection is provided by fire extinguishers and hose stations.
5.4.5 Adequacy of Fire Protection Due to the lack of early warning detection, a fire in this area could damage safety-related equipment.
An exposure fire in the battery room could affect the adjacent area through the nonrated door and vent openings.
The lack of air flow supervision on the exhaust fan could lead to hydrogen buildup if the fan failed.
5.4.6 Modifications The licensee has proposed to provide air flow supervision on the exhaust system and suoke detection in the room.
Three hour doors and dampers will be installed in the door and vent openings.
We find that, subject to the implementation of the above described modifi-cations, the fire protection for the battery room satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
5.5 Switchgear Areas 5.5.1 Safety-Related Equipment Switchgear are located in several areas of the plant.
The 4KV switchgear area is located on the control building mezzanine floor adjacent to the control room.
The 480V switchgear is located in the mezzanine mechanical equipment room and in the north auxiliary bay.
The latter is discussed in Section 5.3.
5.5.2 Combustibles The combustibles in the switchgear areas consist of cable insulation.
5.5.3 Consequences if No Fire Suppression An unmitigated fire in switchgear areas can result in the loss of redundant safety-related equipment.
5.5.4 Fire Protection Systems The switchgear areas are protected by portable extinguishers and hose stations.
5.5.5 Adequacy of Fire Protection Fire detection is not provided near switchgear centers to give prompt warning of a fire.
Water damage could result from the use of hose streams to combat cable tray fires.
ff51139 5-5
5.5.6 Modifications The licensee has proposed to provide early warning fire detection in the area of 4KV switchgear 11 and 12 located on the control building mezzanine floor.
Early warning fire detection will be provided in the area of 480 volt switchgear 14 and 15, power centers 19 and 20, and 125 volt control panels in the mezzanine mechanical equipment room.
The top of the electrical equipment will be sealed to reduce the potential of water damage from hose streams.
We find that, subject to the implementation of the above described modifi-cations, the fire protection for the switchgear areas satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
5.C Cable Passageway 5.6.1 Safety-Related Equipment Redundant divisions of safety-related cabling from the control roo.m and switchgear to the containment run in this passageway.
5.6.2 Combustibles The only combustible in this area consists of cable insulatien.
5.6.3 Consequences if No Fire Suppression A firt in this area could damage redundant divisions of safety-related cables.
5.6.4 Fire Protection Systems The area is protected by a preaction water suppression system.
Actuation of the deluge valve is by heat detectors installed in the cable trays passageway.
Water is discharged from individual spray nozzles upon actuation of the fusible link of each head.
Hose stations and portable extinguishers protect the majority of the area.
5.6.5 Adequacy of Fire Protection Hose stations do not have adequate reach to protect all areas of the cable tunnel.
The cable passageway suppression system drawings will be reviewed for adequacy of spray coverage to protect cables in this area.
5.6.6 Modifications Additional hose stations will be provided to reach the entire length of the cable tunnel.
We fiaa that, subject to the implementation of the above described modifi-cation, the fire protection for the cable passageway satisfies the objec-tives identified in Section 2.2 of this report and is, theref,re, acceptable.
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5.7 Turbine Building - Hydrogen Seal Oil Area 5.7.1 Safety-Related Equipment This area contains the emergency primary feed pump.
5.7.2 Combustibles The combustibles include some cable insulation, hydrogen seal oil, and lubricating oil.
5.7.3 Consequences if No Fire Suppression An unmitigated fire could lead to loss of the emergency primary feed pump.
5.7.4 Fire Protection Systems Hose stations from nearby areas and portable extinguishers are available to fight fires in this area.
5.7.5 Adequacy of Fire Protection The fire protection for the hydrogen seal oil area is not adequate t9 control a fire in the area.
The west wall of the hydrogen seal oil area has penetrations and a door which are not adequate to contain a fire in the area and fire detection is not provided.
- 5. 7. 6 Modifications The licensee has proposed the following modifications.
The hydrogen seal oil area will be protected by the installation of an automatic water deluge system actuated by heat detectors.
The penetrations and doors in the west wall of the seal oil area will be upgraded to provide a 3-hour rating.
We find thut, subject to the implementation of the above described modifi-cations, fire protection for the turbine building - hydrogen seal oil area satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
5.8 Turbine Building - Primary and Secondary Feed Pump Area 5.8.1 Safety-Related Equipment The safety-related equipment in the area includes the 480V switchgear, cable systems, makeup pumps, demineralized water jockey pump, supply and makeup system pumps.
- 5. 8. 2 Combustibles Combustibles in this area include lubricating oil, cable insulation, diesel fuel, and vehicles parked in the turbine trackway.
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5.8.3 Consequences if No Fire Suppression An unmitigated fire in the area could result in the loss of the capability to safaly shutdown.
5.8.4 Fire Protection Systems Hose stations and portable extinguishers are located throughout the area.
A local flooding C0 syrtem protects the primary and secondary feed pumps.
7 The turbine trackway on the east end of this fire zone is provided with sprinkler protection.
5.8.5 Adequacy of Fire Protection The heat detectors for the low pressure CO, system in the feed pump area extend down from the ceiling so that detector response to a fire would be delayed.
The northwest corner of the feed pump area exposes safety related cables in the cable chase leading up to the cable passageway.
The laundry storage area and welding shop off the trackway are not provided with sprinkler protection.
5.8.6 Modifications The licensee has proposed the following modifications.
Heat collectors will be provided for the detectors in the feed pump area.
The primary and secondary feed pump area is an exposure hazard to the cable chase and will be provided with sprinkler coverage in the northwest corner; an extension from the north auxiliary bay sprinkler system will be provided to cover this area.
The Unit 1 trackway sprinkler protection will be extended to include the welding shop and the laundry storage area.
We find that, subject to the implementation of the above described modifi-cations, fire protection for the ground floor of the turbine building satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
5.9 Core Spray and Post Incident Area
- 5. 9.1 Safety-Related Equipment The safety-related equipment located in this area includes the core spray pumps, post incident pumps, heat exchangers, fans, motor control centers and both divisions of electrical cables.
5.9.2 Combustibles Combustibles include cable insulation and 15 gallons of lubricating oil.
5.9.3 Consequences if No Fire Suppression An unmitigated fire in the core spray pump area could damage both divisions of safety-related equipment.
The warehouse adjacent to this area is an exposure fire hazard.
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5.9.4 Fire Protection 3
Hose stations and portable extinguishers are provided for the area.
5.9.5 Adequacy of Fire. Protection The core spray pump area is not adequately protected to prevent fire damage to both divisions.
5.9.6 Modifications The licensee has proposed to provide an automatic water suppression system for the core spray and post incident pump area.
We find that, subject to the implementation of the above described modifi-cation, the fire protection for the post incident pump and core spray area satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
5.10 Shop and Warehouse Area 5.10.1 Safety-Related Equipment This area contains one division of cables for the core spray pumps and valves.
5.10.2 Combustibles The combustibles in the warehouse consist of plastics, paper products, lubricants, oil, gases, flammable liquids and small amounts of cable insulation.
5.10.3 Consequences if No Fire Suppression A fire in the warehouse could adversely affect the post incident system, the core spray system, and the spent fuel area.
5.10.4 Fire Protection Systems An automatic sprinkler system protects the warehouse area.
An automatic carbon dioxide system protects the paint storage room.
Portable fire extinguishers and hose stations are also provided for this area.
5.10.5 Adecuacy of Fire Protection Due to the high fire loading a fire in this area may not be controlled by the auto.natic sprinkler system.
This could adversely af fect the spent fuel pool area and the post incident-core spray area.
5-S 951143
5.10.6 Modifications The licensee plans to move the contents of the warehouse out of this area into a new building under construction.
The warehouse will be converted to a light hazard occupancy.
The lower level will consist of a machine shop and the upper elevation will be converted to a lunch room area.
The sprinklers on both elevations will be retained as presently installed with minor modifications to the piping to accommodate the change in occupancy.
We find that, subject to the above described modifications, the fire protection for the shops and warehouse area satisfies the objectives of Section 2.2 of this report and is, therefore, acceptable.
5.11 Clean and Dirty Lube Oil Tank Room 5.11.1 Safety-Related Equipment There is no safety-related equipment in this area.
5.11.2 Combustibles The room contains two tanks with a storage capacity of 8500 gallons of lubricating oil in each tank.
5.11.3 Consequences if No Fire Suppression A fire in this area could affect the supporting columns for the contain-ment.
The metal sphere comprising the containment would also be exposed by a fire in this ares.
5.11.4 Fire Protection Systems An automatic total flooding carbon dioxide system protects this room.
The system is actuated by Fenwal thermostats.
The fire door and fire dampers close automatically upon system actuation.
Manual protection is provided by portable extinguishers and hose stations in the north corridor.
5.11.5 Adequacy of Fire Protection Manual fire fighting is not adequate as the only means of backup protection to prevent damage to the supporting columns or the steel containment wall for a severe fire in this area.
5.11.6 Modifications The licensee has proposed to provide an extra hazard automatic sprinkler system for this area.
351.LM 5-10
We find that, subject to the implementation of the above described modifi-cation, the fire protection for the clean and dirty lubricating oil tank room satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
5.12 Screen House 5.12.1 Safety-Related Equipment The screen house contains three service water pumps, two screen wash pumps and switchgear associated with these pumps.
The diesel fire pump is located in this building.
5.12.2 Combustibles The main combustible in this building is the 75 gallon fuel oil tank associated with the diesel fire pump.
The size of the required fuel oil storage will increase when the new 2500 gpm diesel fire pump replaces the existing fire water pump.
5.12.3 Consequences if No Fire Suppression A fire in the fire pump room could adversely affect the service water and screen wash pumps in the adjacent rooms.
5.12.4 Fire Protection Systems Portable fire extinguishers and a hose station are provided to protect this area.
5.12.5 Adequacy of Fire Protection Due to the lack of 3-hour fire resistive construction, a fire in the diesel fire pump room could affect safety-related equipment.
The lack of curbs at the doors could allow an oil spill to spread to adjacent rooms.
A fire in the pump area could be difficult to fight manually due to access to this area.
5.12.6 Modifications The licensee has proposed to provide an automatic sprinkler system to protect the fire pump area.
The penetrations, including doors, in the fire pump room will be upgraded to a 3-hour fire rating.
Curbs will be provided at the doors to prevent an oil spill from entering adjacent rooms.
We find that, subject to the implementation of the above described modifi-cations, the fire protection for the screen house satisfies the objectives identified in Section 2.2 of this report and 1s, therefore, acceptable.
5-11 351145
5.13 Spent and New Fuel Building 5.13.1 Safety-Related Equipment The only safety-related equipment is that associated with the spent fuel pool.
5.13.2 Combustibles Transient combustibles such as boxes, crates, flat bed truck, and cherry picker are found in this area.
5.13.3 Consequences if No Fire Suppression A fire in this area could threaten the load carrying capability of the structural steel in toe building.
5.13.4 Fire Protection Systems Portable extinguishers and a hose station outside the area provides protec-tion for the combustibles within.
5.13.5 Adequacy of Fire Protection Due to the lack of automatic suppression over the fuel receiving area, a fire in the transient combustibles could have an adverse impact on the structural steel.
The lack of early warning detection in the building could result in a fully developed fire by the time personnel discovered the fire.
5.13.6 Modifications The licensee has proposed to install automatic cprinklers in the fuel receiving area and provide smoke detection throughout the remainder of th building.
We find that, subject to the implementation of the above described modifi-cations, the fire protection for the spent and new fuel building satisfies the objectives identified in Section 2.2 of this report end is, therefore, acceptable.
5.14 High Pressure Coolant Injection (HPCI) Building 5.14.1 Safety-Related Equipment The safety-related equipment in this area includes the water storage tank, HPCI pumps, motors and diesels, oil transfer pumps, air starting system, service water pumps, and essential service auxiliary power diesel generators.
The two high pressure coolant injection systems are separated by 3-hour rated fire barriers.
The HPCI facility is under construction, therefore, the fire protection systems are not yet completed.
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5.14.2 Combustibles Combustibles in the area will consist of diesel oil, cable insulation and i
lubricating oil.
5.14.3 Consequences if No Fire Suppression The consequences of an unmitigated fire in this area would be the loss of a cingle division of the high pressure coolant injection system.
The alternate division would remain functional and available for shutdown needs.
5.14.4 Fire Protection Systems A total flooding C0 system will protect the main HPCI diesel room and willprovidesecond$ryprotectionforthedieseldaytankroom.
The diesel day tank room will be provided with automatic sprinkler protection.
All areas will be protected with portable extinguishers and hose stations.
5.14.5 Adequacy of Fire Protection
+
The valves in the fire water system for the HPCI system are globe valves instead of OS&Y gate valves which are approved for this type of service.
5.14.6 Modifications The licensee has proposed to replace the valves for the fire water system with OS&Y gate valves.
We find that, subject to the above described modifi-cation, the fire protection for the HPCI facility satisfies the objectives of Section 2.2 and is, therefore, acceptable.
5.15 Auxiliary Boiler House 5.15.1 Safety-Related Equipment The auxiliary boiler house is located on the northeastern edge of the turbine building adjacent to the dirty and clean lube oil tank rooms.
The facility has no safety-related equipment.
5.15.2 Combustibles The auxiliary boiler area contains 100 gallons of diesel oil in the boiler startup day tank.
5.15.3 Consequences if No Fire Suppression The consequences of an unmitigated fire in the auxiliary boiler house does not impact safe shutdown.
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5.15.4 Fire Protection Systems Portable extinguishers are provided within the area and hose stations from adjacent yard areas could be utilized to fight fires in the area.
5.15.5 Adequacy of Fire Protection The fire protection for the auxiliary boiler house is adequate for safety-related consequences.
5.15.6 Modifications The licensee has proposed to install an automatic sprinkler system in the auxiliary boiler house for property protection reasons.
We find fire protection for the auxiliary boiler house satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
5.16 Yard Area 5.16.1 Safety-Related Equipment The safety-related equipment in the yard includes the condensate storage tanks.
5.16.2 Combustibles Combustibles in the yard include gas cylinders, fuel oil, hydrogen storage tank, propane tanks, transformer oil and miscellaneous storage.
5.16.3 Consequences if No Fire Suppression An unmitigated fire in transformer 11 could impact safety-related equip-ment and cables in the north auxiliary bay through nonrated fire doors and unprotected bus ducts.
5.16.4 Fire Protection The fire protection systems for the yard include automatic deluge system on the transformers and hose houses on the hydrants for manual fire fighting.
The fuel oil tank is surrounded by a berm of sufficient height to contain the entire contents of the tank.
5.16.5 Adequacy of Fire Protection The yard area fire protection is adequate except for the door opening and duct penetrations adjacent to transformer 11.
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5.16.6 Modifications The door adjacent to the transformer will be upgraded to a 3-hour fire rating.
The door and the duct penetrations will be protected by an automatic water spray system whose feed will be independent from the existing deluge system protecting the transformer.
The door will be electrically super-vised with key card access.
The hydrant ports on the yard loop will be provided with 2 " gate valves on each hydrant port.
We find that, subject to the implementation of the above described modifi-cations, the fire protection for the yard area satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
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6.0 ADMINISTRATIVE CONTROLS The licensce's description of the administrative controls contained in his fire hazards analysis is not adequate to permit a conclusion.
We have recommended thac the licensee's administrative controls follow the guidelines set forth in " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls, and Quality Assurance."
The administrative controls for all three units at the Dresden site will conform to a common set of controls.
Our concerns about the administrative controls resulting from our review of Units 2 and 3 are contained in letters to the licensee dated January 12, 1978 and June 5, 1978.
The licensee's responses are contained in letters dated August 1, 1977, February 24, 1978, March 20, 1978, July 27, 1978, January 31, 1979, and May 30, 1979.
In addition our site visit of March 20-22, 1979 covered such subjects as fire brigade training, physical examination for fire brigade members, and fire fighting plans.
We have found that the licensee's responses have adequately addressed our concerns on the administrative controls for fire protection, and that the administrative controls for fire protection meet the objectives of Section 2.2 of this report and are, therefore, acceptable.
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a 7.0 TECHNICA_L_ SPECIFICATIONS The Technical Specifications to include limiting conditions for operation and surveillance requirements for existing fire protection systems and administrative controls were issued on March 22, 1978.
Following the implementation of the modifications of fire protection systems and administrative controls resulting from this review, the Techni-cal Specifications will be similarly modified to incorporate the limiting conditions for operation and surveillance requirements for these modifica-tions.
We have requested that the licensee ' propose technical specifications for hose stations and automatic systems.
The licensee has agreed to provide a list of hose stations and systems to be covered by technical specifications.
We will review this item upon receipt of this information from the licensee.
We will report on these modifications in a supplement to this report.
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8.0 CONCLUSION
The licensee has performed a fire hazards analysis and has proposed certain modifications to improve the fire protection program.
Additional modifi-cations have been proposed by the licensee during the course of our review, which are based upon the fire hazards analysis and our onsite evaluation of the fire protection program.
These proposed modifications are summarized in Section 3.1.
In addition, we have concluded that the licensee should implement certain evaluations or improvements related to the fire protection program and there are certain Technical Specifications which require resolution.
These are summarized in Sections 3.2 and 7.0.
Significant steps are being taken to provide additional assurance that safe shutdown can be accomplished and the plant can be maintained in a safe condition during and following potential fire situations.
Additional evaluation of incomplete items, discussed in the preceding sections, will be necessary before we can conclude that the overall f[re protection at the Dresden Unit 1 facility will satisfy the provisions of BTP 9.5-1 and Appendix A thereto, which the staff has established for satisfactory long-term fire protection.
We find that the licensee's proposed modifications described herein are acceptable both with respect to the improvements in the fire protection program that they provide and with respect to continued safe operation of the facility.
The licensee began a prolonged maintenance and refueling outage on October 31, 1978.
In addition to other maintenance activities, the licensee has committed to complete all of the fire protection modifi-cations identified in Table 3.1 prior to startup of Dresden Unit No.1.
In addition to the proposed modifications, the licensee will complete the evaluation of the few incomplete items in accordance with the schedule contained in Table 3.2.
It is our intent to resolve these incomplete items also prior to startup of Dresden Unit No.1.
We will address the resolution of incomplete items, secticn 3.2, in a supplement to this report.
We have determined that the licensee amendment does not authorize a change in effluent types or total amounts nor an increase in power level and will not result in any significant environmental impact.
Having made this determination, we have further concluded that the amendment involves an action which is insignificant from 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 considerations discussed above, that:
(1) because the amendments do not involve a significant increase in the proba-bility or consequences of accidents previously considered and do not involve a significant decrease in a safety margin, the amendments do not involve a significant hazards consideration, (2) there is reasonable assurance that the health and safety of the public will nct be endangered by operation in the proposed manner, and (3) such activities will be conducted in compliance with the Commission's regulations and the issuance of these amendments will not be inimical to the common defense and security or to the health and safety of the public.
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V d.L.c U N
9.0 CONSULTANTS REPORT Brookhaven National Laboratory under contract to the NRC has provided the services of fire protection consultants who participated in the evaluation of the fire protection program.
They have also participated in the preparation and review of this safety evaluation report. Their report, Fire Protection in Operating Nuclear Power Stations - Dresden 1 SER Review dated July 3,1979, discusses items which have been addressed in this report. The consultants recommer.dations which we have not totally adopted are discussed below.
Our basis for not adopting these recommendations are given below.
Consuhants Recommendations Not Adopted 1.1 Valve Supervision
" Electrical valve supervision should be provided on all valves controlling fire water systems and sectionalizing valves.
The present proposal of administrative controls or locks is unacceptable.
Staff Response: The NRC guidelines on valve supervision are given in Appendix "A" of Branch Technical Position (BTP) 9.5-1 of the Standard Review Plan.
These guidelines permit, as an alternative to electrical supervision, an administrative program to assure that valves are maintained in the proper oosi tica.
Such a program includes locking valves with strict key control or sealing valves with tamper proof seals.
Periodic inspections are to be performed to verify that the method of securing the valve is intact.
These measures are consistent with the requirements imposed for supervising valves in safety-related syste'is, and provide adequate assurance that valves are maintained in tne appropriate position.
The licensee's program for valve supervision is consistent with NRC guidelines, see SER Section 4.3.1.c.
In addition, the plant Technical Specifications are being revised to require a monthly check of all valves in the flow path to fire suppression systems.
We find that a significant increase in plant safety would not result from the use of electrical supervision of all valves in the fina water systems.
1.2 Ve_ntilation System Tne present portable system consists of two 5200 CFM fans with ducting, and additional portable units available from the local fire department.
BNL reconmends an additional 5200 CFM-blower be on hand to be more consistent with the BNL recommended minimum portable ventilation.
Staff Response: The licensee has agreed to provide three 5200 CFM supervac units.
The local fire department which is within 20 minutes of the plant has additional units which would be available i f necessary.
We find that this satisfactorily resolves our concern of providing adequate portable ventilation equipment.
351153
,s 1.3 In_t_erior Hose Station Nozzles BNL recommends replacing the 1 1/2" nozzles with " Class C, all spray electric type nozzles" where electrical shock hazard is a consideration for personnel safety. A suitable alternative is 1 1/2" adjustable nozzles providing a spray stream pattern without going through the straight stream mode to open or close the nozzles.
Staff Response:
The licensee has agreed to provide increased training in the use of nozzles and indicates further that the nozzles in use at Dresden 1 The licensee employ a deflector which prevents a pure solid stream.
has agreed to provide spray type nozzles for medium voltage (4KV and above) areas where the danger from electrical shock hazard is predominant.
We find that this satisfactorily resolves our concern of providing safe nozzles for electrical areas.
351154
, s APPENDIX A CHRONOLOGY In February 1976, the report by the NRC Special Review Group was issued as NUREG-0050, "Recommendaticns Related to the Browns Ferry Fire."
On May 1,1976, Standard Review Plan 9.5.1, " Fire Protection," was issued, incorporating the various recommendations contained in NUREG-0050.
By letter dated May 11, 1976, Commonwealth Edison Company was requested to compare the existing fire protection provisions at their facilities with new NRC guidelines as set forth in Standard Review Plan 9.5.1, " Fire Protection," dated May 1, 1976, and to describe (1) the implementation of the guidelines met, (2) the modifications or changes underway to meet the guidelines that will be met in the near future, and (3) the guidelines that will not be met and the basis therefor.
By letter dated September 30, 1976, Commonwealth Edison Company was requested to provide the results of a fire hazards analysis and propose Technical Specificat. ions pertaining to fire protection.
Commonwealth Edison Company was also provided a copy of Appendix A to BTP 9.5-1 which includes accept-able alternatives to the guidelines of SRP 9.5-1.
By letter dated October 8, 1976, Commonwealth Edison provided a partial response submittal in conformance to standard review plan 9.5-1.
By letter dated November 30, 1976, Commonwealth Edison informed the staff of delays to their scheduled response to the staff's requests as a result of the hiring of a qualified fire protection consulting firm for the Fire Hazards Analysis.
By letter dated December 28, 1976, Commonwealth Edison provided a second partial submittal in conformance to standard review plan 9.5-1.
By letter dated March 17, 1977, the licensee provided reasons for why technical specifications should not be imposed on fire protection systems.
By letter dated March 29, 1977, the licensee submitted the fire hazards analysis entitled "Information Relevant to Fire Protection Systems and Programs Dresden Nuclear Power Station Unit 1."
By letter dated June 16, 1977, the staff provided the interal distribution of positions as a result of the trip to the Dresden facility of January 4-8, 1977.
By letter dated May 10, 1977, the staff provided the licensee with a list of staff positions and questions on the Dresden Units 1, 2 and 3.
351155 A-1
On May 24 and 25th, 1977, the staff met with the licensee to discuss unresolved issues in Bethesda, Maryland.
By letter dated July 19, 1977, the licensee provided answers to requests for information and staff positions raised during the staff's previous site visit.
By letter dated June 5,1978, the licensee was advised of the need for additional information and positions on administrative controls.
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By letter dated March 20, 1979, the licensee forwarded the Fire Protection Safe Shutdown Analysis for Dresden Station 1.
On March 20-21, 1979, the staff visited the Dresden Unit 1 station and conducted the site review.
By letter dated May 1,1979 the staff provided the licensee with a trip report discussing the fire protection commitments, staff positions and status and a request for information.
On May 8,1979, the staff met with the licensee in Bethesda, Md. to discuss the status of open issues and incomplete items including requests for information.
By letter dated May 30, 1979, the licensee provided further information to staff positions and questions requested May 1, 1979.
By letter dated July 5, 1979, the licensee provided drawings to show cable routing of power for the sphere service water booster pump.
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