ML19209A154
| ML19209A154 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 09/14/1979 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19209A153 | List: |
| References | |
| NUDOCS 7910030021 | |
| Download: ML19209A154 (95) | |
Text
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pa "E cog UNITED STATES
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NUCLEAR REGULATORY COMMISSION y
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WASHINGTON, D. C. 20555 5
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%9.....,o SAFETY EVALUATION REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION U.S. NUCLEAR REGULATORY COMMISSION IN THE MATTER OF BALTIM0RE GAS AND ELECTRIC COMPANY CALVERT CLIFFS NUCLEAR POWER PLANT UNITS 1 AND 2 DOCKET N05. 50-317 AND 50-318 Dated: September 14, 1979 1084 118 7 91003002 /
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TABLE OF CONTENTS Pag 1-1
1.0 INTRODUCTION
2-1 2.0 FIRE PROTECTION GUIDELINES...............
2-1 General Design Criterion 3
" Fire Protection"......
2-1 2.1 2.2 Supplementary Guidance...........
3-1
SUMMARY
OF MODIFICATIONS, INCOMPLETE ITEMS AND REQUIREMENTS...........
3.0 3-1 3.1 Modifications.................................................
3-1 3.1.1 Curb in Diesel Room.............
3-1 3.1.2 Additional Fire Fighting Equipment.......
3-2 Fire Water System 0verpressurization...................
3-2 3.1.3 3.1.4 Marking of Fire Water Valves..
3-2 Breathing Apparatus Recharging System......
3-2 3.1.5 Automatic Fire Suppression in Cable Spreading Rooms.....
3-2 3.1. 6 3.1.7 Fi re Mater System Val ves................................
3-2 3.1.8 Miscellaneous Usage of Fire Water.......................
3-2 3.1.9 Low Wa ter Tank Level Interlock..........................
3-3 3.1.10 Single Isolation in Fire Water Piping System............
3-3 3.1.11 Portable Smoke Ejectors.................................
3-3 3.1.12 Battery Room Ventilation................................
3-3 3.1.13 Emergency Communication.................................
3-3 3.1.14 Hydrogen Piping.........................................
3-3 3.1.15 Addition of Curbs.......................................
3-3 3.1.16 Control of Combusti bl es.................................
3-3 3.1.17 Dedicated Ladders.......................................
3-4 3.1.18 Miscellaneous Protection for Control Room...............
3-4 3.1.19 Fire Detection in Safety-Related Areas..................
3-4 3.1.20 Unprotected Doorways....................................
3-4 3.1.21 Manual Hose Coverage....................................
3-4 3.2 Incomplete Items..................................................
3-5 3.2.1 Fire Hazards Analysis...................................
3-6 3.2.2 Adequacy of Detector Installation.......................
3-6 3.2.3 Fire Pump Flow Test.....................................
3-6 3.2.4 Ventilation Duct Penetrations...........................
3-6 3.2.5 Ba ck fl ow Prot ec ti on.....................................
3-7 Electrical Penetration Fire Resistance..................
3-7 3.2.6 3.2.7 Piping Penetration Fire Resistance......................
3-7 3.2.8 Radiological Consequences of Fire.......................
3-7 Effects of Fire on Radiation Monitors...................
3-7 3.2.9 3.2.10 Fire Water Drainage...........................
3-7 3.2.11 Control Air....................................
1084 119
TABLE OF CONTENTS (Continueu) 3-8 3.3 Unresolved Issues...........................................
3-8 3.3.1 Halon System Backup Power...............................
38 3.3.2 Emergency Lighting................................
3-8 3.3.3 Fire Door Supervision...................................
3-8 3.3.4 RC Pump Lube Oil Collection System...................
3-8 3.3.5 Fire Pump Separation....................................
3-9 3.3.6 Fi re F i g h ti ng Stra teg i es...............................
3-9 3.3.7 Quality Assurance.......................................
4-1 4.0 EVALUATION OF PLANT FEATURES...
4-1 4.1 Safe Shutdown Systems.
4-5 4.2 Fire Detection and Signalling Systems....
4-6 4.3 Fire Control Systems........
4-6 4.3.1 Water Systems..
4-11 4.3.2 Gas Fire Suppression Systems..
4-12 4.3.3 Portable Fire Extinguishers..
4-12 4.4 Ventilation Systems and Breathing Equipment.
4-12 4.4.1 Smoke Control...........
4-14 4.4.2 Filters......
4-14 4.4.3 Breathing Equipment....
4-14 4.4.4 Battery Room Ventilation..
4-15 4.5 Floor Drains and Curbs..
4-16 4.6 Lighting System....
4 16
- 4. 7 Communications..
4-17 4.8 Electrical Cables........
4-18 4.9 Fire Barrier Penetrations.....
4-19 4.9.1 Doorways..
4-19 4.9.2 Ventilation Duct Penetrations..
2-19 4.9.3 Electrical Penetrations.......
4-20 4.9.4 Piping Penetrations.......
..t..
4-20 4.10 Cable Separation..
4-21 4.11 Fire Barriers..
4-22 4.12 Access and Egress..
4-23 4.13 Toxic and Corrosive Combustion Products.
4.14 Nonsafety-Related Areas.
4-23 4-23 4.15 Instrument and Control Air....................
1084 120
TABLE OF CONTENTS (Continued)
Page 5.0 EVALUATION OF SPECIFIC PLANT AREAS.........
5-1 5.1 Safety Injection Pump Rooms...
5-1
- 5. 2 Charging Pump Rooms...
5-2 5.3 Waste Processing Area.
5-3 5.4 Component Cooling Pump Rooms.
5-4 5.5 Service Water Pump Rooms...
5-6
- 5. 6 Mechanical Piping Area.................
5-7
- 5. 7 Radiation Exhaust Vent Equipment' Rooms....
5-3
- 5. 8 Chemical and Volume Control Area..
5-3
- 5. 9 Balance of Auxiliary Building at Elevation 5'-0" 5-11 5.10 Cable Spreading Pooms.
5-12 5.11 Battery Rooms..
5-13 5.12 Switchgear Rooms.
5-14 5.13 Cable Chases...
5-15 5.14 Purge Air Supply Rooms..
5-16 5.15 Area West of Spent Fuel Pool at Elevation 27'-0"......
5-17 5.16 Control Room Complex.....
5-18 5.17 Electrical Penetration Rooms......
5-19 5.18 Diesel Generator Rooms..............
5-20 5.19 Containment...
5-21 5.20 Area West of Spent Fuel Pool at Elevation 45'-0".....
5-23 5.21 Intake Structure.
5-24 5.22 Pefueling Pump and Heat Exchanger Rooms...
5-25 5.23 Health Physics Area....
5-26 5.24 Ventilation Equipment Rooms...........
5-27 5.25 Spent Fuel Pool and Fuel Handling Area....
5-28 5.26 Electrical Rooms....
5-28 5.27 Auxiliary Feed Pump Rooms...
5-29 5.28 Turbine Building......
5-30 5.29 Fire Pump House...
5-32 5.30 Yard Area..
5-32 6.0 ADMINISTRATIVE CONTROLS.......
6-1 6.1 Fire Fighting Strategies........................................
6-1 6.2 Quality Assurance.................................................
6-1 7-1 7.0 TECHNICAL SPECIFICATIONS.....
8.0 CONCLUSION
S..
8-1 9-1 9.0 CONSULTANTS' REPORT..........................
A-1 APPENDIX A CHRONOLOGY..
APPENDIX B DISCUSSION OF CONSULTANT'S REP 0RT................................
B-1 1084 121
1.0 INTRODUCTION
Following a fire at the Browns 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 withstand fires without the loss of important fanctions.
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 a com-prehensive review of all new licensee 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 APCSB 9.5-1), August 23, 1976.
" Supplementary Guidance on Information Needed for Fire Protection Program Evaluation," September 30, 1976.
" Sample Technical Specifications," t;ay 12, 1977.
" Nuclear Plant Fire Protection Functianal Responsibilities, Administra-tive Controls and Quality Assurance," vune 14, 1977.
" Manpower Requirements for Operating Reactors," May ll, 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 structures with both combustibles and the associated fire detection and suppression systems.
Our review was based on the fire protection review team's site visit of November 27-December 1, 1978 and the licensee's proposed program for fire protection as described in the following docketed information:
1084 122 1-1
(1) Final Safety Analysi:., Report, Calvert Cliffs Nuclear Power Plant, Units 1 and 2.
(2) " Fire Protection Program Evaluation, Calvert Cliffs Nuclear Power Plant, Units 1 and 2, dated March 15, 1977.
(3)
Licensee respon es to requests for additional information and staff position, dated July 11 and October 20, 1978, March 22 and April 19, 1979.
(4) Licensee's submittals dated August 6, 17 and 29, 1979.
Our review has been limited to the aspects of fire protection with the NRC's jurisdiction, i.e., those aspects related to the protection of public 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.
i This report summarizes the results of our evaluation of the fire protection program at Baltimore Gas and Electric Company's Calvert Cliffs Nuclear Power Plant.
The chronology of our evaluation is summarized in Appendix A of this report.
1084 123 1-2
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.
Non-combustible and heat resistant materials shall be used wherever practical throc'hout the unit, particelarly in locations such as the containmeni and :ontrol 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.
Firefighting systems shall be de-signed 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 GDC 3 for existing nuclear power plants has been provided by the NRC staff ir. " Appendix A" of Branch Technical Position 3.5-1, " Guidelines for Fire Protection for Nuclear Power Plants."
Appendix A provides guidance on the, referred and, where applicable, acceptable alternatives to fire protaction design for those nuclear power plants for which applications for crastruction 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 guidance which provides clarification of fire protection matters has been provided 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.
" Nuclear Plant Fire Protection Functional Responsibilitias, Administrative Controls and Quality Assurance," June 14, 1977.
1084 124
" Manpower Requirements for Operating Reactors," May ll, 1979.
When the actual configuration of combustibles, safety-related structures, systems or components, and the fire protection features are not as assumed in the development of Appendix A or when the licensee has proposed alter-natives 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 individual oLjectives; increased strength, redundancy, performance, or reliability of one of these methods can compensate in some measures for deficiencies in the others.
!084 125 2-2
3.1 Modifications The licensee nas proposed the following modification to irrprove the fire protection program as a result of his evaluation.
The proposed modificatton is summarized below.
Further detail is provided in the licensee's submittals.
The section of this report which discusses the modification is noted in parentheses.
The schedule for completion of the modification is listed in Table 3.1.
The licensee has agreed to this schedule.
Certain items listed below are marked with an asterisk to indicate that the NRC 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 actual implementation of these modifications.
The balance of other modifications has been described in an acceptable level of detail.
3.1.1 Curb in Diesel Room (4.5, 5.18)
The licensee has provided information showing that the curb will prevent a pe;sible communicatinn of spilled oil between two ad.iacent diesel rooms in Unit 1 area.
The staff will address its evaluation in a supplen.ent to this report.
3.1.2 Additional Fire Fighting Equipment (4.3.1.3, 4.3.1.4)
The licensee will provide the following additional hose and equipment:
(1) For each exterior hose cabinet (a) 200' of 2 " fire hose (single jacket. lined, synthetic)
(b) One 2 " x 1 " x 1 " gated wye (c) One 2 " combination fog / straight stream nozzle rated at least 250 gallons per minute (d) One 1 " fog / straight stream nozzle rated at 60-90 GPM (e) Two each of 2 " and 1 " gaskets (2) For each portable equipment cabinet (a) 50' of 2 " fire hose (b) One Halligan type forcible entry tool (c) 100' of 1 " fire hose (3) For each interior hose station (a) One universal type hose spanner that can be used as a hose valve wrench and as a hose coupling spanner for both 2 " and 1 "
hoses.
(4) At a suitable central location (a) One heat sensing device (b) 10 sets of fire fighting protective clothing; each set includes ore turnout coat with removable liner, one helmet, one pair of boots and one pair of gloves.
1084 126 3-1
3.1.3 Fire Water System Overpressurization (4.3.1.3)
The licensee will identify and correct the cause of the fire water system overpressurization.
3.1.4 Marking of Fire Water Valves (4.3.1.3)
The licensee will provide identification tags clearly marking post-indicator valves and control valves for fire protection water systems so that reference to written descriptions or reference number i' not necessary to identify the systems or are,as each valve controls.
3.1.5 Breathing Apparatus Recharging System (4.4.3)
The licensee will:
(1) relocate the recharging system from the present location in warehouse No. 1 to a suitable central location within the Unit 1 - Unit 2 operating area, (2) provide cooling water tank for each cascade system for air cylinders being recharged.
3.1.6 Automatic Fire Suppression in Cable Spreading Rooms The licensee will install an automatic fire suppression system in each cable spreading room.
3.1.7 Fire Water p stem Valves (4.3.1.1, 4.3.1.3)
The fire water tank discharge valves arc locked open.
The fire water tank interconnection valve has been locked closed.
All locked valves in the fire protection system will be checked monthly to verify their position.
3.1.8 Miscellaneous Usage of Fire Water (a.3.1.1)
An additional centrifugal pump, taking suction from the fire water tank standpipe and discharging to the fire protection system header, will be installed with adequate capacity to meet the intermittent use of fire water for purposes other than fire protection.
Administrative procedures will be implemented to limit such usage of fire water to a single 1-1/2" hose stream at any time.
In the event of a fire, nonfire fighting water usage will be terminated immediately.
~
3.1. 9
- Low Water Tank Level Interlock (4.3.1.2)
The fire pump controller will be modified to remove the fire water storage tank low level interlock from the control logic.
Alarms will be provided to annunciate, in both the control room and the fire pump house, low level in fire water storage tanks.
1084 127 3-2
3.1.10 Single Isolation in Fire Water Piping System (4.3.1.3, 5.18, 5.30)
A 2-1/2" hose connected to Hydrant No. 5 will be prelaid to provide hose coverage for Diesel Generator Room No. 21, when the fire water supply to the automatic sprinkler system and manual hoses stations protecting these areas are valvedout simultaneously.
3.1.11 PortabJe Smoke Ejectors (4.4.1)
Three portable smoke ejectors and associated portable ducting will be provided to aid in manual smoke removal.
The ejectors will be of the explosion-proof type that are used for fire fighting and have a minimum combined capacity of 17,500 CFM.
3.1.12 Battery Room Ventilation (4.4.4, 5.11)
Telltales haw teen installed at the exhaust and supply air grills in each battery room and the air flow is being verified twice each shif t.
3.1.13*
Emergency Communication (4.7)
Communication equipment will be provided which is capable of maintaining communication between the control room and all areas of the plant, including the interior of containment, considering possible damage due to a single fire.
3.1.14*
Hydrogen Piping (5.4, 5.8, 5.9)
An excess flow stop valve will be installed in the line to the hydrogen supply to auxiliary t,uilding to automatically secure hydrogen to the building in the event of a piping system rupture.
3.1.15*
Addition of Curbs (5.9)
The licensee will provide means to curb or contain a possible oil / solvent spillage in the hot machine shop and in the hot instrument shop.
3.1.16 Control of Combustibles (5.9, 5.24, 5.26)
All combustibles that are not required for the routine operation and maintenance of the plant will be removed from all safety-related plant areas.
Storage of combustible materials necessary for the routine operation or maintenance of the plant will be limited to approximately one week's supply. Metal cabinets, removed from the vicinity of any safety-related cables / equipment will be provided for such storage.
3.1.17 Dedicated Ladders (5.10)
The licensee has provided a dedicated ladder of fiberglass construction in each cable spreading room to provide access to the areas above the battery rooms and the overhead cable chases.
1084 128 3-3
3.1.18 Miscellaneous Protection for Control Room (5.16)
(1) The licensee has provided a fog nozzle for the manual hose protecting the room.
(2) All wooden furniture and shelves will be removed from the control rorm complex except for work benches in the Log and Test Instrument Room.
(3) Metal partitions will be provided to separate the adjoining panels from the computer terminal in the middle of the main panel.
3.1.19*
Fire Detection in Safety-Rela ced Areas (4.2, 5.1, 5.2, 5.3, 5.4, 5.5, 5.6, 5.7, 5.8, 5.9, 5.14, 5.19, 5.21, 5.27)
The licensee has proposed to install appropriate fire detection devices in some additional safe +;-related areas.
He will further evaluate this modification when the design details become available.
3.1.20*
pnprotected Doorways (4.9.1, 5.1, 5.2, 5.4, 5. 5, 5.7, 5.16, 5.18, 5.22)
UL or FM listed fire doors of appropriate ratings will be installed, or acceptable alternate provided to prottet the unprotected doorways in fire barriers separating various safety-related plant areas, including five doorways in the computer rooms currently provided with nonfire rated bullet-proof doors.
3.1.21*
Manual Hose Coverage (4.3.1.4, 5.6, 5.12, 5.17, 5.19, 5.21, 5.24, 5.25, 5.26, 5.28)
The licensee has performed hose reach tests and proposed to provide several additional hose stations.
We will further evaluate this modifi-cation when the design details become availabic.
3.2 Incomplete Items In addition to the licensee's proposed modifications, several incomplete items remain, as discussed below.
The licensee will complete the evalua-tions necessary to resolve these incomplete items.
The sections of this report which discuss these incomplete items are noted in parentheses; plant areas related to these sections were identified to have the specific concern from the staff's evaluation of information submitted by the licensee.
The licensee is to verify if there may be other plant areas which could have the same concern. He will address the resolution of in-complete items in a supplement to this report.
The schedule for the com-pletion of the licensee action on these incomplete items is given in Table 3.2.
This schedule will permit any additional modifications, such as may be required, to be implemented on a' chedule which is consistent with that noted in Section 3.1 of this report.
3-4 1084 129
3.2.1 Fire Hazards Analysis (4.1, 5.1, 5.2, 5. 3, 5.4, 5. 5, 5.6, 5. 7, F.8, 5.9, 5.10, 5.12, 5.13, 5.14, 5.15, 5.16, 5.17, 5.19, 5.20, 5.21, 5.23, 5.24, 5.27, 5.28,5.30)
The licensee will provide the results of an analysis to:
(1) demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance, (2) identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area, (3) identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient com-bustibles which may be introduced into or moved through the area, (4) identify the worst damage that could result from such fire, and (5) demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environ-ment.
The analysis will, as a minimum, include the following considerations:
(1) The possibility that redundant cables (in trays or in conduits)/
equipment may be involved in an exposure fire due to fixed or transient combus tibles.
(2) Effects of the fire and possible explosion, and fire fighting activities.
(3) Shutdown capability without offsite power.
(4) Safe shutdown consequences of possible system transients resulting from a fire induced faulting of electrical cables.
Where assumptions are made, such as operability of damaged cabling / equip-ment, or effectiveness cf protection, etc., they will be substantiated by the results of tests and/or analyses.
In those plant areas where it cannot be demonstrated that safe shutdown capa-bility can be preserved during and following the postulated fire, appropriate modification (s) will be provided to assure that the plant's shutdown capability will meet the following criteria as the minimum:
(1) Following any fire, the plant can ba brought to hot shutdown conditions using equipment and systems that are free of fire damage.
(2) The plant shall be capable of maintaining hot shutdown conditions for an extended time period significantly longer than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
~5
.1084 130
(3) Fire damage to systems necessary to achieve and maintain cold shutdown conditions shall be limited so that repairs can be made and cold shutdown conditions achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
(4) Repair procedures for cold shutdown systems shall be prepared now and material needed for such repairs shall be on the site.
(5) The hot shutdown condition shall be achieved with power f rom the of fsite power system, and upon its loss, with power from the onsite power system.
A dedicated power supply may be substituted for the onsite power systems.
(6) The power needed to achieve the cold shutdown condition may be obtained from any one of the offsite power, onsite power, and dedicated power systems.
(7) When these minimum systems are provided, their adequacy shall be verified by a thorough evaluation of:
(a) Systems required for hot shutdown; (b) Systems required for cold shutdown; (c) Fire damage to power distribution systems; and (d)
Interactions caused by fire damage to power and water supply systems and to supporting systems, i.e., component cooling water supply.
3.2.2 Adequacy of Detector Installations (4.2)
The licensee will provide the results of a study or tests to verify that proper consideration has been given to such factors as ceiling height and configuration, ventilation air flow rate and pattern, location and arrangement of plant equipment and combustibles, etc., in determining the type, number and location of the existing and the proposed fire detector ins talla tions.
3.2.3 Fire Pump Flow Test (4.3.1.2)
The licensee will perform full scale pum; tests and furnish the results of such tests.
3.2.4 Ventilation Duct Penetrations (4.4.1, 4.9.2, 5.4, 5.5, 5.6, 5.9)
The licensee has verified that all ventilation duct penetrations of fire barriers are protected with UL or FM listed fire dampers which will close automatically in the event of a fire, and the gaps between the ducts and the barriers are sealed.
Fire rating of the dampers will be evaluated and appropriate modifications provided as necessary.
3.2.5 Backflow Protection (4.5, 5.2)
The licensee will provide the results of an analysis, including drawings or sketches of the drain systems as necessary, to demonstrate that the design of existing drain systems can prevent the backflow of combustible liquids to other safety-related areas, or to provide additional modifi-cations to prevent such possibilities.
1084 131 3-6
3.2.6 Electrical Penetratinn Fire Resistance (4.9.3, 5.4, 5.5, 5.6, 5.9)
The licensee will provide the results of a standard ASTM E 119 test to demonstrate the adequacy of fire resistance of the Calvert Cliffs electrical penetrations.
3.2.7 Piping Penetration Fire Resistance (4.9.4, 5.4, 5.5, 5.6, 5.9)
The licensee will provide the results of a standard ASTM E-119 test to demonstrate that piping penetrations have fire resistance ratings commensurate with fire hazards on both sides of the barriers.
3.2.8 Radiological Consequences of Fire (4.14, 5.3, 5.7, 5.9, 5.20, 5.24, 5.25)
The licensee will provide the results of a study of radiological con-sequences of a fire in areas containing radioactive materials (including a fire in a charcoal or a HEPA filter), or other areas where a fire could cause the release of radioactive materials.
Additional nodifi-cations will be provided in areas where a fire could cause the release of radioactive materials that could preclude the normal usage or occupancy of areas surrounding the plant.
3.2.9 Effects of Fire on Radiation Monitors The licensee will provide the results of a study to demonstrate that the radiation monitor will remain. operational when exposed to smoke and/or heat of a potential fire.
3.2.10 Fire Water Drainage (4.5)
The licensee will perform an additional study, following the completion of hose reach tests and addition of interior hose stations and other automatic water systems, to verify that fire water drainage in all safety-related areas is adequate and possible fire water accumulation in any safety-related area will be acceptable.
3.2.11 Control Air (4.15)
Loss of control air to the salt water system valves causes the service water heat exchanger and the component cooling water heat exchanger inlet and outlet valves to fail open.
The licensee will provide the results of his study to verify that possible over-cooling of service water and/or component cooling water will not have 6dverse effects on the plant safety.
1084 132 3-7
3.3 Unresolved Issues As a result of our evaluation, we have found that the licensee must make additional nodifications to improve the fire protection program.
Such modifications are sunmarized below.
The sections of this report which discuss these unresolved items are noted in parentheses.
These items will be resolved in separate licensing actions pending the outcome of a October 2,1979 meeting with the licensee.
3.3.1 Halon System Backup Power (4.3.2)
The licensee has not provided sufficient justification for not providing backup power for the Halon suppression systems.
3.3.2 Emergency Lighting (4.6)
The licensee has not provided sufficient justification for not replacing the existing 1-1/2 hour rated batteries of the emergency lighting units with those of 8-hour rating. The distribution of existing emergency lighting units has not been demonstrated to provide adequate lighting for shutdowr. operation and fire emergency responses.
3.3.3 Fire Door Supervision (4.9.1)
The licensee has not provided sufficient justification for not providing electrical supervision or locking closed those fire doors which are presently not supervised or locked.
3.3.4 RC Pump Lube Oil Collection System (5.19)
The licensee has not provided sufficient justification to demonstrate that:
(a) The existing system provides a complete containment for all potential leakage points which include lif t pump and piping, external oil cooler, flanged connections, drain plugs, fill points, uppe and lower reservoirs, sight glasses and over-flow lines.
(b) The copper drain tubing does have adequate capacity to accommodate drainage of a large oil leak.
(c) Draining co".iected oil on the t.
'itainment floor is safe.
(d) The effects of a seismic event on this system will not adversely affect the plant safety.
3.3.5 Fire Pump Separation (4.3.1.2)
The licensee has not demonstrated that the sprinkler system installed in the fire water pump house provides equivalent protection to the 3-hour fire barrier in limiting the effect of a fire at the diesel fire pump, or its fuel tank, on the electric fire pump.
1084 133 3-8
3.3.6 Fire Fighting Strategies '.'.1)
The licensee has not provided sufficient justification that the fire fighting strategies he has developed for seven areas in the plant are adequate for all plant areas.
3.3.7 Quality Assurance (6.2)
The licensee has not provided the comparison of his quality assurance program and the guidelines.
1084 134 3-9
TABLE 3.1 IMPLEMENTATION DATE FOR MODIFICATIONS DATE ITEM 3.1.1 Curb in Diesel Room Completed 3.1.2 Additional Fire Fighting Equipment November 1979 3.1.3 Fire Water System Overpressurization October 1980 3.1.4 Marking of Fire Water Valves December 1979 3.1.5 Breathing Apparatus Recharging Systen January 1980
6 Automatic Fird Suppression in Cable Spreading Rooms October 1980 3.1.7 Fire Water System Valves Completed 3.1.8 Miscellaneous Usage of Fire Water December 1979 3.1.9*
Low Water Tank Level Interlock January 1980 3.1.10 Single Isolation in Fire Water Piping System Completed 3.1.11 Portable Smoke Ejectors November 1979 3.1.12 Battery Room Ventilation Completed June 1980 3.1.13*
Emergency Communication October 1980 3.1.14*
Hydrogen Piping 3.1.15*
Addition of Curbs June 1980 3.1.16 Control of Combustibles November 1979 3.1.17 Dedicated Ladders Completed 3.1.18 Miscellaneous Protection for Control Room October 1980 3.1.19*
Fire Detection in Safety-Related Areas October 1980 October 1980 3.1.20*
Unprotected Doorways October 1980 3.1. 21
- Manual Hose Coverage TABLE 3.2 SUBMITTAL AND IMPLEMENTATION DATE FOR INCOMPLETE ITEMS SUBMITTAL IMPLEMENTATION ITEM DATE DATE 3.2.1 Fire Hazard Analysis November 1979 October 1980 3.2.2 Adequacy of Detector Installations November 1979 October 1980 3.2.3 Fire Pump Flow Test November 1979 N/A 3.2.4 Ventilation Duct Penetrations November 1979 October 1980 3.2.5 Backflow Protection November 1979 October 1980 3.2.6 Electrical Penetration Fire Resistance November 1979 February 1980 3.2.7 Piping Penetration Fire Resistance November 1979 February 1980 3.2.8 Radiological Consequences of Fire November 1979 October 1980 3.2.9 Effects of Fire On Radiation Monitor November 1979 October 1980 3.2.10 Fire Water Drainage November 1979 October 1980 3.2.11 Control Air November '979 October 1980 1084 135 3-10
4.0 EVALUATION OF PLANT FEATURES 4.1 Safe Shutdown Systems There are several arrangements of safety-related systems which can be used to shutdown the reactor and cool 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.
The general functional requirements for safe shutdown and the systems auxiliaries, and major components required to fulfill these requirements are as follows:
(1) Primary System Coolant Inventory Control Following a reactor trip, the primary coolant temperature will be reducing causing the primary water volume to contract.
To maintain a proper coolant inventory, makeup is required to the primary coolant system.
The primary system coolant inventory is maintained by controlling the level in the pressurizer.
The charging pumps in the chemical and volume control system provide makeup to the primary system.
The pumps take suction from the volume control tank, or the refueling water tank when the level in the volume control tank is low.
Excess water in the primary system is bled off through the chemical and volume control letdown valves.
(2) Decay Heat Removal Following a normal plant shutdown, the steam bypass control system bypasses steam to the condenser to dissipate decay heat.
If the steam bypass system or the condenser is not available, atmospheric steam dump valves can be opened automatically or remote manually to provide an alternate means of heat removal.
Steam generator feedwater is normally delivered by steam generator feed pumps supplied from the condenser hotwell via the condensate system.
On the loss of offsite power, or when the condenser or the condensate system is unavailable, steam turbine-driven auxiliary feed pumps provide alternate means of feedwater supply to the steam generators.
Auxiliary feed pumps take suction from a condensate storage tank which has a capacity to provide more than 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> water supply for the cooldown of both units.
For a cooldown of the reactor coolant below 300 F, the shutdown cooling system is used.
The system utilizes the low pressure safety injection pumps to circulate the reactor coolant through the shutdown heat exchangers, returning it to the primary coolant system through the low pressure injection header.
Decay heat is rejected to Chesapeake Bay via component cooling and salt water systems.
1084 136 4-1
(3) Reactivity Control Reactor trip is accomplished by deenergizing the control element drive mechanism coils allowing the control element assemblies to drop into the reactor core by gravity.
Following the reactor trip, soluble poison may be added to the primary system to assure subcriticality as the reactor is cooled down.
The chemical and volume control system and the boric acid system are normally used for such operaton.
(4) Instrumentation In addition to those instruments associated with the systems discussed above, the following instrumentation is needed for the safe shutdown.
- Pressurizer level and primary coolant temperature
- Steam generator level and pressure
- Source range neutron monitor (5) Power Supply Plant auxiliary power for each unit is provided by two service trans-formers which can be supplied by unit generated or offsite power.
Separation of the plant auxiliary power supplies to redundant engineered safety equipment is maintained in the 4160-volt, 480-volt and lower voltage systems.
The plant service transformers convert 500-kV power to provide 13,800-volt plant auxiliary power which supplies the reactor coolant pumps directly and 4160-volt system through unit service transformers.
There are six 4160-volt buses per unit; two of which, supplying to engineered safety (ES) features, can also be fed from onsite emergency diesel generators.
The two ES buses are redundant.
Of the three onsite emergency diesel generators, two may each supply one 4160-volt ES bus for each unit in the same division; the third may supply power to any ES buses in either unit. The service water system which is physically separated from the component cooling water system is required to provide cooling when the diesels are operating.
The 480-volt system supplies power to the 480-volt auxiliary loads from the 4160-volt system through 4160/480 unit service transformers.
Four of the unit load centers and two motor control centers supplying power to the engineered safety features are supplied from 4160-volt ES buses and are grouped in two redundant divisions.
The 125-volt DC and vital AC systems furnish continuous power to the plant vital instrumentation and control systems.
It consists of four channels per unit corresponding to four channels in the reactor protection and the engineered safety systems.
Each channel consists of one train of batteries, two battery chargers, one DC bus, multiple 1084 137 4-2
DC control panels, and two inverters.
Each inverter has an associated vital AC distribution panel board.
Power to the DC bus, DC unit control panels, and inverters is supplied by the station batteries and/or battery chargers.
For each of the two battery chargers, one is fed from Unit 1 and the other fed from Unit 2.
The plant also has a 250-volt DC auxiliary power system which supplies power to various plant backup lube oil and seal oil pumps.
There are no loads connected to the 250-volt DC system that are related to the
_ function of engineered safety features.
Much of the redundant safety equipmu L required for safe shutdown is located in the same fire area separated only by space.
Many cables from redundant divisions are separated by space, by metal conduits, or by asbestos board.
There are several safety-related plant areas that are separated from the adjacent areas by fire barriers punctuated by un-protected opening.
The licensee has taken a liberal credit for the ability of silicone rubber insulated cables used in the plant to prevent the sp-ead of a fire and to preserve the safe shutdown capability of the plaat.
The staff has evaluated the test results in the document referenced by the licensee and concluded that these test results alone did not demonstrate that the Calvert Cliffs cables, in the configuration generally observed in the plant, are adequate to assure that at least one division of safety-related cabling / equipment can be preserved for safe shutdown in the event of a fire. A detailed evaluation of the electrical cables and cable separation is presented in Sections 4.8 and 4.10 of this report.
The licensee's fire hazard analysis failed to address:
(1) The possibility that cables (in trays or in conduits)/ equipment from both safety divisions may be involved in an exposure fire due to fixed combustibles in each area and/or transient combustibles which may be brought into or moved through that area for routine operation and maintenance of the plant.
(2) The effects of a fire (including the temperature rise) and fire fighting activities (including fire water spray) on safety-related cabling / equipment.
(3) Shutdown capability of the plant without offsite power.
(4) The possible effects, on safe shutdown, of spurious system transients resulting from a fire induced faulting of electrical cables.
In their discussion of the fire hazard analysis methodology, the licensee described the design basis fire (DBF) approach which postulates all com-bustibles in the fire area under consideration to be consumed by the fire at their maximum burning rate and contended that the DBF approach they embraced for their evaluation is conservative.
However, they then went on to state that many plant areas, including those containing cabling /
equipment required for safe shutdown, were analyzed for a localized fire 1084 138 4-3
in which damage is assumed only to those components in t.ic fh' area that are directly engulfed by flame.
Loss of function is not nec(~,irily postulated for those components damaged by the fire.
The licensee will provide the results of an analysis to:
(1) demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers, with protected openings and penetrations, of appropriate fire resistance.
(2) identify the minimum separation between the redundant cables / equipment required for safe shutdown in each fire area, (3) identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient com-bustibles which may be introduced into or moved through the area, (4) identify the worst damage that could result from such fire, and (5) demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive release of radioactive materials to the environment.
The analysis will, as a minimum, include the following considerations:
(1) The possibility that redundant cables (in trays or in conduits)/
equipment may be involved in an exposure fire due to fixed or transient combustibies.
(2) Effects of the fire and fire fighting activities.
(3) Shutdown capability without offsite power.
(4) Safe shutdown consequences of possible spurious system transients resulting from a fire induced faulting of electrical cables.
Where assumptions are made, such as operability of damaged cabling / equipment, or ef fectiveness of protection, etc., they will be substantiated by the results of tests and/or analyses.
In those plant areas where it cannot be demonstrated that safe shutdown capability can be preserved during and following the postulated fire, appropriate modification (s) will be provided to assure that the plant's shutdown capability will meet the following criteria as the minimum:
(1) Following any fire, the plant can be brought to hot shutdown conditions using equipment and systems that are free of fire damage.
(2) The plant shall be capable of maintaining hot shutdown conditions for an extended time period significantly longer than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
(3) Fire damage to systems necessary to achieve and maintain cold shutdown conditions shall b limited so that repairs can be made and cold shutdown conditions achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
1084 139
(4) Repair procedures for cold shutdown systems shall be prepared now and material needed for such repairs shall be on the site.
(5) The hot shutdown condition shall be achievable with power from the offsite power system, and upon its loss, with power from the onsite power system.
A dedicated power supply may be substituted for the onsite power systems.
(6) The power needed to achieve the cold shutdown conditions may be obtained from any one of the offsite power, onsite power, and dedicated power systems.
(7) When these minimum systems are provided, their adequacy shall be verified by a thorough evaluation of:
(a) Systems required for hot shutdown; (b) Systems required for cold shutdown; (c) Fire damage to power distribution systems; and (d)
Interactions caused by fire damage to power and water supply systems and to supporting systems, e.g., component cooling water supply.
We will address the adequacy of the plant's shutdown capability in a supplement to this report.
4.2 Fire Detection and Signalling Systems The plant has a protective signalling system which transmits various fire alarm and supervisory and trouble signals to the control room.
In addition to signals from heat or smoke detectors located in selected areas of the plant, the system also transmits alarm, supervisory, and trouble signals concerning fire pump operation or impairment, Halon system actuation or trouble, oparation of the air foam systems or selected water spray, deluge, or automatic sprinkler systems, and closing of selected valves in the fire protection water system.
All signals are annunciated on a single alarm panel, except that fire pump trouble, fire pump discharge valve closure, pressure tank low pressure and low level, and diesel fire pump day tank low level signals are annunciated on a separate panel.
The licensee y
has verified that these particular alarms annunciated on the separate panel are provided with back-up power from the onsite emergency power supply system and are designed and installed in accordance with NFPA 720. The signalling system annunciated on the main alarm panel is also provided with back-up power in the event of a loss of offsite power by a connection to the emergency power supply system.
The signalling system has been designed and installed in accordance with the provisions of NFPA 72D for Class B system, except that signals are not recorded automatically.
However, we find the lack of automatic record ~ ig acceptable because plant operators keep a log of all important signalu.
1084 140 4-5
Smoke or heat detectors have been installed in selected areas of the plant following the guidelines of NFPA 74 and the manufacturers' specifications.
The licensee will install appropriate fire detection devices in some additional safety-related areas which contain fire hazards.
However, it is not clear if any safety-related areas containing fire hazards will be left without fire detec-tion af ter the proposed n'odification.
We will further evaluate this modification when the design details become available.
To ensure that proper consideration has been given to such factors as ceiling height and configuration, ventilation air flow rate and pattern, location and arrangement of plant equipment and combustibles, etc., in determining the type, number and location of fire detectors, the licensee will provide the results of a study or tests to verify the adequacy of the existing and proposed detector installations.
Additional modifications will be provided as necessary following such study / test.
Alarm, supervisory, and trouble signals are annunciated in the control room visually, and audibly by an annunciator horn and a 6-inch bell.
The bell is distinctive from other plant system alarms.
We find that, subject to satisfactory resolution of the above described concerns the fire detection and signalling system conforms to the provisions of Appendix A to Branch Technical Position 9.5-1 and is, therefore, acceptable.
- 4. 3 Fire Control Systems 4.3.1 Water Systems 4.3.1.1 Water Supply The fire protection water supply for the plant is provided by two ground level 500,000 gallon pre-treated water storage tanks located outside the fire pump house.
Pre-treated water is also used for miscellaneous services other than fire protection.
For such services, pumps take suction from a standpipe in each tank reserving 300,000 gallons of the 500,000 gallons for fire protection use.
In addition, there are 10,000 gallons of water in a pressure tank located near the warehouses.
This pressure tank is connected to the plant fire protection water system and would provide an additional source of water for fire fighting.
Pressure tank low level and low pressure conditions are alarmed in the control room.
The pressure tank level is maintained manually.
Three plant makeup wells with a nominal combined capacity of 966 gpm are provided to refill the pre-treated water storage tanks.
The 300,000 gallons reserved for fire protection use in one tank can be replenished by these wells in about 5.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
The lead well water pump is arranged to start when less than 456,000 gallons of water is in either tank; when less than 313,000 gallons of water is in either tank the miscellaneous service pumps are arranged to trip, and a low level alarm is arranged to sound in the control room when the level in a tank drops below 303,000.
The licensee has provided the results of an analysis which demonstrate that the 300,000 gallons reserved for fire protection in one of the two 500,000 gallon water tanks would provide an adequate water supply for a 2-hour operation of the largest sprinkler system in safety-related areas with an additional 1,000 gallons per minute capability reserved for manual hose application.
1084 141 4-6
Because a valve in the piping in the fire pump house interconnecting the tanks is currently maintained open, a leak in one tank or its piping could cause both tanks to drain. The licensee will maintain this valve locked shut except when the interconnection is necessary in case of fire.
The licensee has also verified that provisions to prevent freezing in the pre-treated water storage tanks are adequate.
During the site visit, it was observed that water was being drawn through the fire protection water pioing system for unidentified purposes other than fire protection.
This practice could result in less than 300,000 aallons being available for fire fighting from either tank, and frequent starting of fire pumps.
The licensee will provide an additional centrifugal pump, taking suction from the fire water tank standaipe and discharging to the fire protection system header, with adequate capacity to mee t the intermittent use of fire water for purposes other than fire pro-tection.
Administrative procedures will be implemented to limit such usage of fire water to a single 1 1/2" hose stream at any time.
In the event of a fire, non-fire fighting water usage will be terminated immediately.
We find that, subject to implementation of the above described modifications, the water supply conforms to the provisions of Section 2.2 of this report and is, therefore, acceptable.
4.3.1.2 Fire Pumps The water supply is developed by two horizontal shaft centrifugal fire pumps, each with a rated output of 2500 gpm at 125 psig.
The pumps, which take suction from connections to the pre-treated water storage tanks mentioned above, are located in the undivided sprinklered fire pumo house along with the fuel tank for the diesel engine driven pump.
The licensee has not demonstarted that the sprinkler system installed in.the ' ire, Dumo house provides equivalent protection to the 3-hour fire barrier in limiting the effect of a fire at the diesel fire pump, or its fuel tank, on the electric fire pump.
The most recent full range fire pump tests were made in November 1977. The tests were scheduled to be performed again in August of 1979.
Results of the tests will be furnished for the staff's review.
A UL listed automatic fire pump controller is located in the same area with each fire pump.
Each pump can be manually started from the control room or at the individual controller, but can be manually stopped only at the controller.
Pump running, driver nonavailability, and pump driver trouble signals are annunciated in the control room.
Additional annuncia-tion is provided at each fire pump controller.
The electric motor driven pump will start automatically if the pressure in the loop yard main falls below 95 psig.
The diesel engine driven pump will start automatically if the pressure falls below 85 psig, and on loss of power to the electric motor driven pump.
1084 142 4-7
Power for the electric motor driven fire pump is supplied from the normal AC system.
Sufficient fuel to operate the diesel engine driven fire pump for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> is stored in a fuel tank next to the engine.
The fuel tank is in a drained, curbed area of sufficient volume to contain the entire tank contents.
A 30 gpm automatic electric driven centrifugal jockey pump located in the same area as the two fire pumps takes suction from the pre-treated water storage tank discharge piping in the fire pump house to miintain the pressure of about 125 psig in the fire water system yard loop.
The fire pumps discharge into the yard main through 12-inch diameter underground lines separated from each other by about 7 feet.
The depth of cover is about 6 feet.
A 12-inch line *nside the fire pump house also connects the fire pump discharge lines to one another.
Appropriate valves are installed to isolate either pump discharge line.
The licensee has provided the results of an analysis which demonstrates that a single fire pump is capable of meeting the combined demand (flow and pressure) for any fixed water fire suppression system in safety-related areas plus 1,000 gpm for hose streams, taking into account the pressure drop between pump discharge and the suppression system, and minimum presst os required for effective sprinkler discharge and manual hose application.
The fire pumps are arranged to shut-off when the level of water in both of the pre-treated water storage tanks is 12 inches above the tank bottom.
This arrangement is not permitted by NFPA 20. The licensee will replace this interlock with alarms which sound in the control room and in the fire pump house.
We will address the acceptability of the fire pumps in a supplement to this report.
4.3.1.3 Fire Water Piping System A separate 12-inch discharge line from each pump supplies the 12-inch underground loop main which encircles the, plant.
All yard fire hydrants, automatic and manual water suppression systems, and interior hose stations are supplied by this loop main.
Post indicator valves subdivide the loop into a number of sections so that a single section could be isolated without impairing the entire system.
However, the licensee has identified that the isolation of certain sections of the yard main could impair the availability of both automatic sprinklers and the backup hose stations prntecting Diesel Generator Room No. 21. An administrative procedure will be implemented to prelay a 21/2" hose connected to Hydrant No. 5 to provide the manual hose coverage through the duration of such impairment. The licensee has performed a similar study for all fixed fire suppression systems in safety-related areas to verify that back up hose coverage is always available to these areas.
Electrical supervision is provided for valves controlling waterflow into sprinkler or deluge systems, for suction and discharge valves associated 1084 143 4-8
with the fire pumps, and for the motor operated valves controlling waterflow into the containment standpipe systems.
Post indicator valves on the underground loop main, pre-treated water storage tank discharge valves, the valve in the fire pump house connecting the two pre-treated water storage tanks, and sectionalizing valves inside the plant are locked open with strict key control and checked semiannually. The licensee will lock closed the valve in the fire pump house piping which interconnects the two pre-treated water storage tanks.
The position of all locked valves will be checked at least monthly.
Yard fire hydrants have been provided at intervals of approximately 250 feet around the exterior of the plant.
The lateral to each hydrant is controlled by a key operated (curb) valve.
Each fire hydrant is provided with a hose house containing hose, hydrant wrenches, hose nozzles, and other equipment.
There are also three portable fire equipment cabinets containing similar materials.
The licensee will provide the following addit'onal hose and equipment for each exterior hose cabinet:
(J) 200' of 2 " hose (single jacket, lined, synthetic)
(2) One 2 " x 1 " x 1 " gated wye (3) One.2h" combination fog / straight stream nozzle rated at least 250 GPM (4) One 1 " fog / straight stream nozzle rated at 60-90 GPM (5) Two each of 2 " and 1 " gaskets The licensee will also provide the following additional hoses and equipment to each of the portable equipment cabinets:
(1) 50' of 2 " fire hose (2) One Halligan type forcible entry tool (3) 100' of 1 " fire hose Threads on hydrant outlets and hose connections throughout the plant are compatible with those of offsite fire departments which serve the plant.
Post indicator valves and control valves for fire protection water systems are not labelled to indicate the system (s) or areas of the plant they serve.
The licensee will provide identification tags clearly marking these valves to indicate the systems or areas they control, so that reference to written descriptions or reference numbers is unnecessary.
During the site visit, pressures of up to 275 psig were observed in the sprinkler systems in the turbine building, the fire pump house, and else-where, but shut-off head on the fire pumps is 175 psig.
The cause of such 1084 144 4-9
abnormally high pressure in the fire water system is unknown, and could be detrimental to the system.
The licensee will identify and correct the cause of the observed overpressurization.
We find that, subject to implementation of the above described modifications, the fire water piping system complies with the guidelines of Appendix A to BTP 9.5-1 and is, therefore, acceptable.
4.3.1.4 Interior Hose Stations Interior hose stations equipped with 1\\-inch diameter fire hose are provided in many areas of the plant. Where they are provided they meet the Class III service requirements of NFPA 14.
Additional hose on reels is provided in three portable fire equipment cabinets in the plant. The licensee will provide for each interior hose station one universal type hose spanner that can be used as a hose valve wrench and as a hose coupling spanner for both 21/2" and 1 1/2" hoses.
During the site visit, it was observed that many plant areas are beyond the reach of presently provided interior hose stations. The licensee has performed hose reach tests, and will provide several additional hose stations.
However, it is not clear if all points in safety-related areas, and other plant areas which contain major fire hazards, can be effectively reached by at least one hose stream after the proposed modification. We will further evaluate this modification when the design details become available.
Electrically safe hose nozzles are provided for interior hose stations located to protect areas containing electrical equipment.
The normally closed motor operated valves which isolate the containment hose stations can be operated manually in event of loss of power to the motor operator.
We find that, subject to sa.tisfactory resolution of the above described concern, the interior fire hose stations conform to the provisions of Appendix A of Branch Technical Position 9.5-1 and are, therefore, acceptable.
4.3.1.5 Fixed Water Suppression Systems Wet pipe automatic sprinkler systems have been provided in the turbine building basement, auxiliary boiler room, baling and drumming room, lube oil room, service building warehouse, construction warehouses, and fire pump house.
Automatic water spray o' deluge systems have been provided to protect the oil-filled transformers located outside of the turbine building, the steam generator feed pumps, and the hydrogen seal oil unit.
Automatically actuated preaction sprinkler systems are provided in the emergency diesel generator rooms.
Manually actuated preaction sprinkler systems are installed to protect the turbine generator bearing systems.
Automatically actuated dry pipe sprinkler systems are installed to protect the equipment hatch access buildings.
I084 kE 4-10
The main control valve for each sprinkler, deluge, or water spray system is electrically supervised.
Valve closure is alarmed and annunciated in the control room.
Waterflow in these systems is also alarmed and annunciated in the control room.
The licensee has studied the fire water piping system and identified that there is a plant area (Diesel Generator Room No. 21) in which isolation of a single pipe section could impair the fire water supply for both the primary (fixed automatic suppression system) and the backup (interior hose station) fire protection to that area.
A prelaid 2 1/2" hose connected to Hydrant No. 5 will be installed to provide manual hose coverage through the duration of such impairment.
The licensee has performed an analysis which demonstrates that rupture or accidental spraying of extinguishing agents from fixed suppression systems will not cause damage or failure of safety-related equipment required for safe shutdown.
Also, there are no safety-related systems or their auxilia-ries which are interlocked to and could be disabled by operation of a fire fighting system.
We find that, subject to implementation of the above described modifications, the fixed water suppression systems conform to the provisions of Appendix A of Branch Technical Position 9.5-1 and are, therefore, acceptable.
4.3.1.6 Foam The two outdoor fuel oil storage tanks are protected by manually actuated fixed air foam systems designed and installed in accordance with NFPA 11.
Two foam pickup tubes and applicator nozzles for 1 -inch hose are provided for manual fire fighting in the area.
We find that the foam suppression systems conform to the provisions of Appendix A of Branch Technical Position 9.5-1 and are, therefore, acceptable.
4.3.2 Gas Fire Suppression Systems Total flooding Halon 1301 suppression systems are provided for each of the relay racks and individual panels in the cable spreading room of each unit, the interior of computer cabinets and the underfloor area in the computer room of each unit, and the QC vault. The relay racks are for turbine generator control and are not safety-related.
They are open-back type racks located in a separate part of the 15-foot high cable spreading room, partitioned off by a wall about 7 feet high.
Fixed-temperature type heat detectors in each of the protected areas automatically actuate the systems. Manual pull stations are also provided near the protected areas for system actuation.
Both automatic and manual operations of the Halon system require electric power.
It was observed during the site visit that heat detectors in the safety-related cabinets appeared to be installed in a dead air space in each cabinet, which could permit a fire in a cabinet to become large before be -
ing detected. As a part of their generic commitment to verify the adequacy of detector installation, the licensee will verify by test or analysis that an installed detector will actuate the installed suppression system 1084 146 4-11
in time to prevent fire damage to redundant safety-related divisions of cables or equipment.
The Halon suppression systems are electrically powered by the 125-volt AC system without backup power. The licensee has not provided sufficient justification for not providina backup power for the Halon suppression systems. We will resolve this issue in a separate action.
The control unit for each system supervises the detecto and initiator circuits and the alarm relay.
Visual and audible alarms are provided locally and in the control room.
We will address the adequacy of gas fire suppression systems in a supple-ment to this report.
4.3.3 Portable Fire Extinguishers Portable fire extinguishers have been distributed throughout the plant in accordance with the provisions of NFPA 10.
We find that the type and distribution of portable fire extinguishers conforms to the provisions of Appendix A of Branch Technical Position 9.5-1 and are, therefore, acceptable.
4.4 Ventilation Systems and Breathing Equipment 4.4.1 Smoke Control Ventilation systems are provided for almost all indoor plant areas.
These systems are not specifically designed for smoke removal although they are capoble of exhausting limited volumes of smoke, generally directly to the outside.
Only the control room and._cabl.e_ spreading rooms are_provided with a separate system designed specifically for smoke removal.
Detection of a fire in one of thest three areas by smoke detectors in the return duct from each area would auto-matically close isolation dampers located in both the supply and return ducts for that area.
A manually actuated system, consisting of a 3100 CFM exhaust fan and motor operated dampers, is provided to remove smoke from and supply fresh air to the fire area after it has been isolated from the normal HVAC system.
1084 147 4-12
The cable tunnels (horizontal cable chases) on Elevation 82'9" of the auxiliary building are provided only with gravity roof vents.
The discharoe from the auxiliary building and waste processing area exhaust fans is monitored continuously for radioactivity.
Smoke from a fire in most areas of the auxiliary building would thus be monitored for radioactivity.
In addition, the main plant event effluent is mon-itored continunusly.
Each of these monitors is equipped with audible and visual alarms which annunciate in the control room.
Actions to be taken in the event of an alarm depend upon the estimated potential offsite radiation dose.
The containment purge system, if operating, would close upon receipt of a containment radiation signal.
The control room and cable spreading rooms, the battery rooms, the diesel generator rooms, switchgear rooms, intake structure, and turbine building have separate ventilation system exhausts to the atmosphere.
It is not known what effect a potential fire could have on the function of these radiation monitors. The licensee will provide the results of a study to demonstrate that the radiation monitors will remain operational when exposed to smoke and/or heat of a potential fire.
Information provided by the licensee indicates that all ventilation duct penetrations of fire barriers are protected with UL or FM listed fire dampers which will close automatically in the event of a fire, and the gaps between the duct and the barrier are sealed.
The licensee is evaluating the adequacy of fire resistance of these dampers.
Heat actuated dampers in fire barriers may clcse automatically to prevent fire spread but this may also preclude smoke removal using the ventilation system.
To aid in smoke removal operations, the licensee will provide three portable explosion-proof smoke ejectors, with a minimum combined capacity of 17,500 CFM, of the type used for public fire fighting, and portable ducting to transport smoke from the fire area to the outside of the plant or other areas to which it is safe to vent the smoke.
4-13 1084 148
We find that, subject to implementation of the above described modification, and satisfactory resolution of the above discussed concerns, the smoke control capability of the plant is adequate to facilitate emergency responses in the event of a fire.
4.4.2 Filters A total of 16 charcoal filters are installed in the plant:
six inside con-tainment, two in the control room HVAC system, four in the penetration room exhaust systems, two in the fuel pool exhaust system, and two in the ECCS pump room exhaust systems.
The filters in containment, and those for the penetration room exhaust system, are used during post-accident condi-tions.
The control room filters are used only on detection of high radiation in the control room ventilating system.
The other filters are normally bypassed.
The containment filters are provided with high temperature monitors anJ manually actuated emergency cooling water suppression systems.
Charcoal filters are contained in steel casing.
No ignition sources are located near the charcoal filters nor can the buildup of radioactive products generate sufficient heat to cause ignition.
The amount of com-bustibles in the area of these filters, other than the filters themselves, is also low.
HEPA and other filter media used in the plant are of noncom-bustible construction.
We find that fire protection for the filters satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
4.4.3 Breathing Equipment Ten self-contained breathing units with three spare bottles per unit are provided at the facility dedicated to emergency use.
The licensee has installed a compressor which is capable of recharging both the cascade system bottles and recharging the spare air bottles directly at a rate sufficient to supply breathing air for 10 men for 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> at the rate of three ( -hcur rated) bottles per man per hour.
The recharging system is currently located in warehouse No. I that is separated from the plant buildings by a fence.
The licensee will relocate the recharging system to a suitable central location within the Unit 1-Unit 2 operating area.
A cooling water tank will be provided for each of two cascade systems.
We find that breathing equipment conforms to the provisions of Appendix A of Branch Technical Position 9.5-1 and is, therefore, acceptable.
4.4.4 Battery Room Ventilation Continuous ventilation is necessary to prevent a possible accumulation of hydrogen in station battery rooms.
The ventilating system for the four station battery rooms consists of an air supply fan, a separate exhaust fan, and common ductwork connecting the battery rooms in parallel.
Supply and exhaust duct penetrations of fire barriers are equipped with
~
1084 149 4-14
fire dampers.
The intake air fan is supplied with air from either the plant exterior or the Unit 1 main plant exhaust equipment room.
The licensee's fire hazard analysis indicates that the two fans are associated with redundant load groups; simultaneous loss of both fans is unlikely. The licensee will install telltales at the exhaust and supply air grills in each battery room and verify the air flow twice each shift.
We find that, subject to implementation of the above described modification, the battery room ventilation conforms to the provisions of Appendix A of Branch Technical Position 9.5-1 and is, therefore, acceptable.
4.5 Floor Drains and Curbs The floor drains are sized to remove fire fighting water flow in those areas where fixed water suppression systems are located.
The maximum water accumulation in any one of these areas was evaluated and found acceptable.
Adequacy of floor drains in all other areas where hand hose lines may be used were verified.
Except cable chases lA, 18, 2A, and 28, all plant areas containing equipment required for safe shutdown are provided with adequate floor drains.
Fire protection of cable chases are discussed in Section 5 of this report.
In general, equipment throughout the plant is installed on pedestals, and curbs are provided as required to contain water and direct it to the floor drains.
It was observed during the site visit that many safety-related areas are not provided with the coveraae of interior hose lines and the licensee is conducting the hose reach test and will install additional interior hose stations (4.3.1.4).
The licensee's fire hazard analysis addressed fire water drainage only in those plant areas which are presently provided with fixed water suppression systems or interier hose stations.
We will require the licensee to perform additional study, following the addition of interior hose stations, to verify that fire water drainage in all safety-related areas is adequate and possible fire water accumulation in any safety-related area will be acceptable.
All interior plant areas containing combustible liquids have floor drains.
The licensee has indicated that inside areas which may contain significant amount of combustible liquids drain to one of the following four areas:
hydraulic fluid waste sumps 11 and 21; diesel generator room oil interceptor and waste oil collection tank; yard oil interceptor and waste oil collection tank; and ECCS room sumps 12 and 22.
Although the licensee proposed to provide a curb to prevent a possible communication of spilled oil between two adjacent diesel rooms in the Unit 1 area, his fire hazard analysis did not address the possibility that combustible liquids may backflow into other safety-related areas via the 4-15 084 150
interconnected drain systems.
The licensee will provide the results of an analysis, including drawing or sketches of the drain systems as necessary, to demonstrate that the design of existing drain systems can prevent the backflow of combustible liojids to other safety-related areas, or provide additional modifications '.o prevent such possibilities.
The licensee also stated that the ECCS room sumps could receive oil drainage from a failed reactor coolant pump.
Uc have verified that only one of the two ECCS rooms in each unit could be affected.
We will address the adequacy of drains and curbs in a supplement to this report.
4.6 Lighting System The normal lighting throughout the plant is fed from the station auxiliary transformers.
The control room has a permanently installed emergency lighting system which is supplied from the 125-volt station batteries.
All safety areas of the plant contain fixed, sealed beam emergency lighting units supplied by individually contained batteries which automatically actuate upon the loss of normal AC lighting power.
It was determined during the site visit that many of the batteries of these emergency lighting units have only a 1 -hour power rating as compared to 8-hour rating specified in our guidelines.
Considering the fact that the stored battery will gradually lose its charge, the staff does not feel assured the 1 1/2-hour rated batteries will provide adequate emergency lighting. The licensee has not provided sufficient justification for not replacing the existing batteries with those of 8-hour power rating. Moreover, the licensee has not verified that the distribution of existing lighting units provides adequate lighting for shutdown operation and fire emergency responses.
We will resolve this issue in a separate action and address the adequacy of lighting systemsin a supplement to this report.
4.7 Communications The plant's internal communication is provided by a 5-channel page/ party system, a sound powered telephone system, and portable radios.
The page/ party system is connected to the vital AC bus and is thereby backed up by the inverter and station batteries.
Both hard-wired systems cover the general plant area including inside the containment.
However, they are located in a common cabinet in the control room and run in a common conduit into the containment so that they are subject to simultaneous damage by a fire.
The licensee has committed to provide communication equipment which is capable of maintaining communication between the control room and all areas of the plant, including the interior of containment, considering possible damage due to a single fire.
4-16 1084 151
We will address the adequacy of emergency communication in a supplement to this report.
4.8 Electrical Cables Control and small power cables are silicone rubber insulated with an asbestos jacket except a few special cablesifor nonsafety-related equipment and control cables in underground ducts.
The majority of instrumentation cables areinsulated with cross-linked polyethylene; the remainder with silicone rubbec insulation and chlorosulfonated polyethylene jacket.
Medium ar.d large power cables have ethylene propylene rubber or cross-linked polyethylene insulation and neoprene, hypalon or chlorosulfonated polyethylene jacket.
Flame propagation tests that are significantly different from those of IEEE Standard 383 were conducted in the process of selecting such cables for these services.
The procedures and the results of the tests were summarized in the paper titled, " Flame Propagation Tests on 600 Volt Control and Power Cables in Trays for Calvert Cliffs Nuclear Power Plant,"
which was submitted to IEEE International Symposium on January 28, 1971.
This paper was referenced on page D-29 of the licensee's submittal, "The Fire Protection Program Evaluation."
The flame propagation tests were conducted on single tray and horizontal stacked tray (2 trays) configurations which include an 8-foot horizontal section with a 4-foot vertical section on each end.
Each tray was loaded with one layer of test cables, one-half diameter apart and subjected to 5-minute exposure to transil oil fire in a 5 gallon open-top can.
" Circuit integrity" was indicated by measuring leakage currents in open circuits.
Among the major conclusions of these various tests are:
(1) Silicone rubber cables can maintain the " circuit integrity," provided no water spray is applied, under the fire condition for 40 minutes or more when energized with 120V circuit fused for one ampere.
(2) Silicone rubber burns but produces less visible smoke than other con-vertional power plant cables.
(3) Under the test condition (maximum of 2 tray stacking, one layer cable fill, 5 minute exposure) silicone rubber cables exhibited a limited flame propagation and self-extinguished 20-25 minutes after the ignition source was removed.
(4) Metal conduits delayed, but could not prevent failure of contained cables.
4-17 1084 152
t (5) With properly applied flame retardant coating, the cable fire self-extinguished under the test conditions as soon as the fire source was removed while the uncoated silicone rubber cable fires generally lasted 20-25 minutes after the ignition source was removed.
The 'icensee cites these test results as justification for taking exceptions to guidelines of Appendix A to BTP 9.5-1.
The staff has reviewed the report cited above and concluded that these test results alone do not provide adequate justification for taking such exceptions.
Specifically, the licensee contends that silicone rubber cables are difficult to ignite, slow to propagate fire, and self-extinguishing in the absence of an ignition source.
Consequently, the silicone rubber insulated cable provides adequate fire protection all by itself and additional fire protec-tion is not necessary unless other fire hazards are present.
While these observations concerning the burning characteristics of silicone rubber cables may be true for the test configuration, they may not be true for the actual plant configuration.
In the configuration observed in certain plant areas, large concentrations of cable are present in confined
~
spaces (stacks of 5-6 trays, less than 1 foot between trays, up to and exceeding 100% tray fill).
A fire involving cables in such a configuration is likely to be prolonged and sustained because of a heat energy feedback to the fire that is higher than that of the test configuration.
The licensee's tests do not establish that such a cable fire would self-extinguish.
While the tests showed ttat when silicone rubber cables are exposed to a fire, they maintain the test current of less than 1 ampere at 120 volts until sprayed with water, these tests do not demonstrate that silicone rubber cables involved in a fire are capable of actually carrying loads at rated voltage required by their functions for an extended period of time during and following a fire.
Moreover, the presence of other conventional cables that are susceptible to fire damage was not addressed.
The licensee's contention that the circuit integrity can be maintained to preserve the safe shutdown capability in event of a fire, therefore, is unsubstantiated.
Furthermore, the licensee has not shown that he has casualty procedures that benefit from such circuit continuity or how fire fighting effort would be affected by such procedures.
The adequacy of electrical cables in Calvert Cliffs facilities is further discussed in Section 4.10 of this report together with the cable separation in the plant.
4.9 Fire Barrier Penetrations Fire barriers are penetrated by doorways, ventilation system ducts, electrical cables, conduit, and piping.
Tn! means of preventing a fire from crossing a fire barrier through these various penetrations is discussed below.
1084 153 4-18
4.9.1 Doorways Fire barriers separating various fire areas are penetrated by numerous doorways.
Three-hour rated UL listed fire doors are provided for many of these penetrations.
Fire barrier penetrations protected by listed doors with less than 3-hour ratings have been evaluated and found acceptable based on the combustible loading in the adjacent areas.
There are, however, a number of doorways, especially at elevations 10'-0" and 5'-0" of the auxiliary building, which are either provided with unrated doors or not provided with doors at all. The licensee will install UL or FM listed fire doors of appropriate ratings, or provide acceptable alternates, to protect the unprotected doorways in fire barriers separating various safety-related areas, including five (5) bullet-proof donrs without fire resistance ratings installed in the computer rooms, control room, and stair tower in the control room area.
Fire doors in the plant are either normally closed, locked, or electrically supervised to alarm in the control room. There is no assurance that fire doors which are not locked or supervised will be kept closed. The licensee has prnvided a list of those fire doors which are not electrically supervised or locked closed and combustible loading on both sides of each door.
- However, safe shutdown consequences of fire damage in these areas were not discussed.
We will resolve this issue in a separate action.
We will address the acceptability of protection of doorways in a supplement to this report.
4.9.2 Ventilation Duct Penetrations UL or FM listed fire dampers which close automatically in the event of fire are installed in ventilation duct penetrations through rated fire barriers in various parts of the plant, but their fire resistance ratings have not been provided by the licensee.
The licensee is evaluating the adequacy of fire ratings of fire dampers. Appropriate modifications will be made as necessary following the on-going fire hazard analysis.
We will address the adequacy of protection of ventilation duct penetrations in a supplement to this report.
4.9.3 Electrical Penetrations A typical floor electrical penetration c.sists of a vermiculite or pearlite void fill with flame retardant coating on both sides of the penetration.
Horizontal penetrations are not provided with void fill.
Cable trays at the penetration ar,e covered with a mineral wool blanket and solid tray 4-19 1084 154
covers which extend on both sides beyond the surface of the barrier.
Conduit and wireway penetrations through the control room floor consist of vermiculite void fill with a " asbestos board or a 3/8" dry thickness of flame retardant coating on top and bottom.
The licensee will conduct a standard ASTM E-119 test and provide the test results, to demonstrate the adequacy of fire resistance of the electrical penetrations.
We will address the adequacy of the electrical penetrations in a supplement to this report.
4.9.4 Piping Penetrations Piping penetrations through fire barriers, except for those in the reactor building, are provided with pipe sleeves.
The annular space around the The pipe is caulked with asbestos rope packing or similar material.
licenses has not indicated the fire resistance rating of these penetrations.
The licensee will provide the results of a standard ASTM E-l!9 test to demonstrate that piping penetrations have acceptable fire resistance ratinas.
We will address the adequacy of piping penetrations in a supplement to this report.
4.10 Cable Separation Safety-related electrical circuits are divided into many independent and physically separated channels which are grouped into four separatior, groups; two redundant divisions.
Separation and independence is maintained between cable trays of different separation groups.
Nonsafety-related cables are allowed to be routed in safety-related raceways but with a single safety separation group only.
The basic criterion for separating redundant cable trays, as prescribed by the licensee, is 3 feet borizontally and 5 feet vertically with the following exceptions:
(1) The redundant trays are allowed to be routed as close as 1 inch of each other if the fire barrier is provided.
4-20 4
1084 155
-inch asbestcs board A typical vertical fire barrier consists of a Double ast'estos that extends 1 foot above and 1 foot below the tray.They are placed either boards provide the horizontal fire barrier.
on both top and bottom of one tray, or one below the top tray and one The boards are flush with the width of the above the bottom tray.
tray (s') and extend about 2 feet beyond the point of crossover, or the ends of overlap, of redundant trays.
In the containment cable penetration rooms, the prescribed separation (2) is 3 feet horizontally and 3 feet vertically.
Isolation between redundant circuits is considered to be adequate where physical separation is less than that indicated above and when (3) one of the circuits is routed in steel conduit or wireway.
Even without these deviations, recent tests have demonstrated that the 3-foot and 5-foot separation prescribed by the licensee is inadequate to The licensee orevent redundant cables from being damaged by a single fire.
has proposed a test and evaluation program as described below:
The licensee will provide the results of tests to demonstrate that (1) silicone rubber cables which are installed in steel conduit -are adequate to preserve the plant's safe shutdown capability.
Cables other than silicone rubber which are installed in conduit (2) will be protected where shown to be necessary by the fire hazards analysis by materials which have been proven by test to provide adequate protection to preserve the plant's safe shutdown capability.
Where shown to be necessary by fire hazards analysis, cables which (3) are installed in cable trays will be protected by materials which have been proven by test to provide adequate protection to preserve the plant's safe shutdown capability.
We will address the adequacy of cable separation in a supplement to this report.
4.11 Fire Barriers Fire areas are enclosed by floors, walls, and ceilings which generally have 3-hour fire resistance ratings.
However, there is some unprotected 4-21 1084 156
structural steel in several plant areas. At our request, the licensee has verified that there are no fire barriers supported by unprotected structural steel at Calvert Cliffs Nuclear Power Plant.
We find that the design of fire barriers satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
4.12 Access and Egress Most safety-related areas are reasonably accessible for manual fire fighting.
Two enclosed stairways join all levels, and two more join the upper three levels of the auxiliary building.
Additional access to the auxiliary building is also possible from the turbine building and from the yard The intake structure has good access from either the turbine area.
building or the yard.
There are, however, a few safety-related plant areas where access for fire fighting is difficult.
During normal operation, the containment is sealed.
Access and egress is cvailable through an interlocked double-door air lock at elevation 69'-0".
Special procedures must be followed to gain access.
Portions of the cable spreading rooms located above the battery rooms are inaccessible for fire fighting because of the lack of stairways or ladders.
A single access is available via a ship ladder to each of the horizontal cable chases.
The access is partially obstructed by piping and structural steel making it difficult for a fire fighter carrying either a portable extinguisher or a fire hose to negotiate through.
There are two vertical cable chases for each unit; both have a doorway at the elevation 45'-0" and the "A" chase has an additional opening at the elevation 69'-0".
The chases, however, extend downward to the elevation 27'-0" and the fire fighter's access is limited to a small platform, with an approximate floor area of 4'x6', inside each chase beyond the doorways at the elevation 45'-0".
Fighting a fire in a vertical cable chase from this platform is not considered feasible.
In these safety-related plant areas where access for manual fire fighting is limited, additional protection will be required to compensate for such shortcoming.
These protections are discussed in Section 5 of this report.
It is concluded that, subject to the satisfactory resolution of tne above described concerns, access and egress to various plan't areas are adequate for fire protection. This satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
4-22 4
1084 157
4.13 Toxic and Corrosive Combustion Products The products of combustion of many polymers are toxic to humans and corrosive to metals.
Prompt fire detection and extinguishment are relied upon to reduce the quantity of such products produced during a fire.
Mean< Of smoke removal, as discussed in Section 4.4.1, are provided as an aid in fire fighting access.
Members of the fire brigade will be provided with, and trained in the use of, emergency breathing apparatus for fighting fires involving such materials.
We find that the above described provisions are adequate to reduce the effects of toxic and corrosive combustion products to facilitate the fire emergency responses. This meets the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
Nonsafety-Related Areas _
4.14 The licensee is continuing with his fire hazards analysis.saich, among othe will establish the adequacy of separation between various plant areas.
We will address the adequacy of protection against the effects of fire in nonsafety-related areas in a supplement to this report.
4.15 Instrument and Control Air Instrument air consists of two full capacity compressors which discharge to a single header.
An emergency backup tie from the plant air header provides an automatically controlled backup. A separate control air system is provided for each unit for saltwater system valve control.
There is concern that a fire in certain plant areas could disable the instrument or the control air system, In response to the staff's request for additional information, the licensee ider:tified two safety-related functions that may be affected by the failure air systems, but were not analyzed previously in the of the These are the operation of Calvert Cliffs final safety analysis report.
charging system valves, the control of saltwater valves at the discharge of the service water, and the component cooling water heat exchangers.
The licensee has verified that:
9 4-23
(1) Charging system valves which could be affected by the failure of the instru-ment air system are the charging system loop isolation valves CVC 518 and CVC 519.
Both valves fail open upon loss of instrument air.
Additionally, CVC 519 is in parallel with a flow actuated bypass check valve sized to pass full charging flow.
Safe shutdown, therefore, will not be pre-vented by loss of pneumatic control to these valves.
(2) Loss of control air to the salt water valves causes the service water heat exchanger and component cooling water heat exchanger inlet and outlet valves to fail open. The maximum salt-water flow from one pump is verified to be still within the range of the manufacturer's certified pump performance; therefore, extended operation of the salt-water pump is assured in the event of delay of operator's action.
The licensee, however, is still studying if over-cooling of service water and/or component cooling water could have any adverse effect(s) on the plant safety.
We will address the adequacy of fire protection for the control air system in a supplement to this report.
D 4-24
5.0 EVALUATION OF SPECIFIC PLANT AREAS The licensee has performed a fire hazard analysis of the facility to determine the combustibles present in various plant areas, to discuss the consequences of postulated fires, and to evaluate the adequacy of fire protection systems.
The results of this analysis, other docketed information, and site visit observations were used in the staff's evaluation of specific plant areas which is discussed in the following sections.
The licensee has committed to perform additional studies on issues listed in Section 3.2 of this report. He has proposed to perform the study only for those plant areas identified by the staff for each issue.
Because the staff identified these plant areas from evaluating the submitted information which we cannot assure ourselves to be complete, the licensee is requested to verify for each issue whether there may be additional plant area (s) with the same concern.
5.1 Safety Injection Pump Rooms (100, 101, 102, 103, 118, 119, 120, 122)*
5.1.1 Safety-Related Equipment Safety-related equipment in the. area includes low pressure safety injection pumps and associated piping, cabling and other accessories.
Control and power cables for the charging pumps are also routed through the area.
5.1.2 Combustibles combustibles in these areas consist of several gallons of lube oil and snubber oil in each pump room, and a large quantity of electrical cable insulation.
Reactor coolant pump lube oil leakage is drained to sumps in some of these pump rooms.
5.1.3 Consequences if No Fire Suppression Redundant low pressure safety injection pumps are located in separate rooms.
However, all four rooms (two units) are joined to a common corridor via doorways with unrated doors.
A fire in any room or the corrider, therefore, could affect all low pressure safety injection pumps for both units.
The pumps are needed for shutdown cooling.
Furthermore, redundant cables for the control and power of charging pumps could also be damaged by a fire in these areas.
Reactor coolant pump lube oil which may leak out of pump / motor is drained to two of the four rooms.
5.1.4 Fire Protection Systems Manual hose stations and portable extinguishers are available for manual fire fighting.
- Numbers noted in parentheses following the title of each section correspond to plagt area numbers in the licensee's fire hazards analysis submittal dated March 1977.
1084 160 5-1
5.1.5 Adequacy of Fire Protection Fire protection in the safety injection pump room area is inadequate.
Separation of redundant equipment / cabling is inadequate to assure that the shutdown capability of the plant can be preserved in the event of a fire in these areas. A fire in these areas will go unnoticed because there is no fire detector in these areas.
5.1.6 Modifications The licensee will:
(1)
Replace all unrated doors in these areas by UL or FM listed fire doors of a fire resistance rating commensurate with fire hazards on both sides of the barrier, or provide acceptable alternate protection.
(2)
Install fire detectors in each pump room and in the corridor areas.
(3)
Separate, by additional barriers or by rerouting, redundant cables required for safe shutdown, or demonstrate the adequacy of cable separation in preserving safe shutdown.
The licensee has also demonstrated that oil drainage from a failed reactor coolant pump could affect only one ECCS room in each unit.
We will address the adequacy of fire protection in this area in a supple-ment to this report.
5.2 Charging Pump Rooms (105, 115) 5.2.1 Safety-Related Equipment Safety-related equipment in these areas includes the charging pumps and associated piping and cabling.
A channel of cabling for the auxiliary feedwater pump room fan is also routed through these areas.
5.2.2 Combustibles Combustibles in these areas consist of 10 gallons of lube oil in each room and electrical cable insulation.
5.2.3 Consequences if No Fire Suppression All three charging pumps for each unit are located in the same room separated only by a partial partition.
Each pump is provided with a steel channel dike to contain oil spill from the pump.
The room is separated from the outside corridor area by an unrated door.
An unmitigated fire involving fixed combustibles in the room or possible transient combustibles could affect all three pumps by the rising temperature in the room or direct engulfing of cables in the fire.
4 1084 161 5-2
5.2.4 Fire Protection Systems A manual hose station and portable extinguishers are available for manua!
fire fighting.
5.2.5 Adequacy of Fire Protection Fire protection for these areas is inadequate.
The unrated door is inadequate to separate the rcomsfrom other plant areas.
A fire in the areaswill not be detected because of the lack of fire detectors.
Separation of charging pumps and associated cables may not be adequate to assure at least one charging pump will be available for safe shutdown in the event of a fire in these areas.
5.2.6 Modifications The licensee will:
(1) Replace the unrated doors by UL or FM listed fire doors of a fire resistance rating commensurate with fire hazards on both sides of the barrier, or provide acceptable alternate protection.
(2)
Install fire detectors in each charging pump room.
(3) Provide a sprinkler system in each room to preserve the function of at least one charging pump for each unit in the event of a fire.
(4) Verify that drains from different charging pump compartments are not interconnected, or the drain system is provided with protection to prevent backflow of leaked oil in one compartment into another via the drain system.
We will address the adequacy of fire protection for this area in a supplement to this report.
5.3 Waste Processing Area (104, 106, 107, 108, 109, 110, 111, 112, 113, 114) 5.3.1 Safety Related Equipment Safety-related equipment in this area includes the liquid waste processing system.
Redundant cables associated with auxiliary pump room fans and boric acid system heaters and heat tracers are also routed through the area.
5.3.2 Combustibles Combustibles in this area consist of electrical cable insulation and a small quantity of lube oil.
5.3.3 Consequences if No Fire Suppression Steel tanks and piping containing liquid wastes or boric acid solution are unlikely to be damaged by a fire in the area.
However, damage to redundant cables in the area could cause the loss of auxiliary feedwater pump room fans and/or heating of the boric acid system.
The licensee has not provided the results of his analysis for such loss.
1084 162 5-3
5.3.4 Fire Protection Systems A manual hose and portable extinguishers are available for fire fighting.
5.3.5 Adequacy of Fire Protection A fire in Fire protection for the waste processing area is inadeqcate.
this area is not likely to be detected because of the lack of fire detectors.
The licensee has not analyzed the radiological consequences of a fire in the ar.a, nor the effects on safe shutdown of the loss of auxiliary feed-water pump room fans and/or heating of the boric acid system.
5.3.6 Modifications The licensee will:
(1) Analyze the radiological consequences of fire damage to the waste processing system cables, (2) Analyze the effects on safe shutdown of the loss of auxi~.iary feedwater pump room fans and/or heating of the boric acid system, and Install fire detectors in coolant receiver tank rooms (areas 107 (3) and 114), the corridor (area 104), and othcr areas containing safety-related cables / components.
Additional modifications will be provided as necessary following the above described studies to preserve the safe shutdown capability and to prevent excessive release of radioactive materials.
We will address the adequacy of fire protection for this area in a supplement to this report.
5.4 Component Cooling Pump Rooms (200, 201, 228) 5.4.1 Safety-Related Equipment Safety-related equipment in this area includes component cooling pumps and associated cabling and piping.
In addition, redundant cables for the following systems are routed through the pump rooms and adjacent corridor:
charging pumps ECCS pump room cooler fans auxiliary feedwater pump room fans boric acid tank heaters 5.4.2 Combustibles Combustibles in this area consist of electrical cable insulation, lube oil and rubber penetration seals.
Since the area is open and readily accessible, the possibility of transient combustibles being brought into the area cannot be discounted.
A hydrogen piping to the chemical and volume control tank is also routed through this area.
1084 163 5-4
5.4.3 Consequences if No Fire Suppression There are two component cooling pump rooms in the plant, each containing all three component cooling pumps for one unit.
Two rooms face each other across a narrow corridor which connects to hot machine shop and decontamina-tion areas.
Since both rooms and the corridor are essentially one fire area, a fire could affect all component cooling pumps in both units at the same time.
Fire damage to redundant cables routed in the area could cause the loss of the charging pumps and other systems identified in Section 5.4.1, above, that are needed for safe shutdown.
5.4.4 Fire Protection Systems Fire protection for the area consists of a manual hose station and portable extinguishers for manual fire fighting.
5.4.5 Adequacy of Fire Protection Fire protection for the component cooling pump rooms is inadequate. The rooms are not separated from each other and from other plant areas.
Separation of redundant pumps, cables and other components may not be adequate to assure the availability of at least one division of component cooling system and other systems identified in Section 5.4.1.
The hazard due to a possible leakage of hydrogen was not analyzed.
A fire in this area is not likely to be detected because of the lack of fire detection.
5.4.6 Modifications The licensee will:
(1) Separate each pump room from other plant areas by upgrading the fire resistance of doorway openings, and electrical cable, ventilation duct and piping penetrations in the barriers to a rating commensurate with fire hazards on both sides of the barrier, or provide an acceptable alternate.
(2)
Demonstrate, or provide appropriate modifications to assure, the com-ponent cooling capability can be preserved in the event of a fire in the area.
(3)
Install fire detectors in each room and in the corridor.
(4)
Install an excess flow stop valve in the hydrogen line to auto-matically secure hydrogen in the event of a piping system rupture.
(5)
Separate at least one division of cables associated with systems identified in Section 5.4.1 from their redundant counterparts and the hazards in the area by fire rated barrier enclosures, or demon-strate the adequacy of cable separation in preserving safe shutdown.
An administrative procedure will be implemented to keep any transient combustible out of this area.
We will address the adequacy of fire protection for this area in a supple-ment to this report.
1084 164 5-5
5.5 Service Water Pump Rooms (205, 226) 5.5.1 Safety-Related Equipment Safety-related equipment in this area includes service water pumps and associated piping and cabling.
Piping associated with auxiliary feedwater systems is also routed through Area 226.
5.5.2 Combustibles Combustibles in this area consist of electrical cable insulation, lube oil and anti sweat pipe insulation.
- 5. 5. 3 Consequences if No Fire Suppression Auxiliary feedwater piping is not likely to be damaged by a fire in this area.
The licensee has not demonstrated that at least one division of service water cooiing can be preserved in the event of a fire in the area.
Service water is required to cool the onsite emergency diesel generators.
The licensee also has not identified the function (s) of cables routed in the area and the consequence of fire damage to these cables.
5.5.4 Fire Protection Systems Manual hose stations and portable extinguishers are available for fire fighting.
5.5.5 Adequacy of Fire Protec'. ion Fire protection for this area is inadequate.
A fire in the area is not likely to be detected because of the absence of fire detectors.
Separation of the rooms from other plant areas is inadequate, and separation of redundant pumps and associated cabling has not been demonstrated to be adequcte to preserve at least one division of service water system in the event of a fire in the area.
5.5.6 Modifications The licensee will:
(1) Install fire detectors in this area, (2) Demonstrate the adequacy of the fire resistance rating of steel doors separating the pump rooms from the turbine building and replace other doors by UL or FM listed fire doors of an appropriate fire resistance
- rating, (3) Verify the adequacy of fire resistance of electrical, piping and ventila-tion duct penetrations or upgrade them to a rating commensurate with the fire hazards on both sides of the barrier.
1084 165 s_,
(4) Demonstrate, by tests or analyses, that separation between redundant service water pumps, including the associated cables and other com-ponents, is adequate to preserve at least one division of the service water system in the event of a fire in this area or provide alternate means of service water cooling, and (5) Identify otner safety-related cables or components which may be located in this area and analyze the safety consequences of fire damage to such cables / components.
We will address the adequacy of fire protection for this area in a supple-ment to this report.
5.6 Mechanical Piping Area (203, 206, 211, 221, 224, 227, 309, 310, 315, 316, 321, 326) 5.6.1 Safety-Related Equipment This area contains piping associated with the main steam system, the main and the auxiliary feedwater systems,the component cooling system, the shutdown cooling system, the low pressure safety injection system, the charging system, the steam generator blowdown system, the refueling water system, and the primary coolant letdown line.
Other safety-related equipment contained 'n the area includes atmospheric steam dump valves.
In addition, the area contains the power cables for charging pumps, a low pressure safety injection pump, an ECCS pump room cooler fan and an auxiliary feedwater pump room fan.
5.6.2 fombustibles Combustibles in this area consist of pipe insulation, electrical cable insulation, lube oil and hydraulic fluid.
5.6.3 Consequences if No Fire Suppression The licensee has not analyzed the consequences of possible fire damage to valves, especially remote controlled valves, in the area.
A fire in any room is not likely to damage steel tanks or pipes except in the piping areas (areas 203 and 224).
Piping areas contain a large amount of hydraulic fluid (250 gallons per room).
The licensee did not address the fire hazards involving a substan-tial portion of this fluid.
Although cables in these rooms are mainly from channel 8, because the area is not separated from adjacent machine shop and decontamination areas that contain cables redundant to those contained in the piping areas, a fire in these rooms could damage redundant safety-related cables which may compromise the plant's safe shutdown capability.
1084 166 5-7
5.6.4 Fire Protection Systems Manual hose stations and portable extinguishers are provided for manual fire suppression.
5.6.5 Adequacy of Fire Protection Fire protection for this area is inadequate.
A fire in the area will not be detected because of the lack of fire detectors.
Separation of the piping areas, which contain a substantial fire hazard, from other plant areas is not adequate.
Hose stations in the area may not be able to reach all points in this drea effectively.
5.6.6 Modifications The licensee will:
(1) Separate piping areas (areas 203 and 224) from other plant areas by fire barriers, complete with fire doo;., fire dampers and sealed penetrations, of anpropriate fire rating, or demonstrate the adequacy of cable / component separation in preserving safe shutdown.
(2)
Install fire detectors in piping areas (areas 203 and 224),
(3)
Identify any other safety-related cables / components in the area and analyze the consequences of fire damage to these cables / components, and (4) Verify the manual hose coverage, and install additional hose stations as necessary, to assure that all points in various rooms of this area can be reached effectively by at least one hose stream.
We will address the adequacy of fire protection for this area in a supple-ment to this report.
5.7 Radiation Exhaust Vent Equipment Rooms (204, 225) 5.7.1 Safety-Related Ecuipment Safety-related equipment in this area includes radiation exhaust vent equipment, which has charcoal filters; piping associated with the main steam system, and the main and auxiliary feedwater systems; and redundant power cables for cr.arping pumis, low pressure saft+y injection pumps, component cooling pumps, llc 5 pump room cooler fans and auxiliary feedwater pump room fans.
5.7.2 Combustibles Combustibles in this area consist of electrical cable insulation, fan belts and charcoal in the filters.
Transient combustibles could be introduced into the area.
1084 167 5-8
- 7. 3 Consequences if No Fire Suppression A fire in t5is area could damage redundant cables and cause the loss of functions of the systems listed in Section 5.7.1; most of them are required for safe shutdown.
A fire in the charcoal filters could cause the release of abnormal amounts of radioactive material.
5.7.4 Fire Protection Systems Manual hose stations and portable extinguishers are available for manual fire suppression.
5.7.5 Adequacy of Fire Protection Fire protection for this area is inadequate.
A fire in this area is not likely to be detected because of the lack of fire detectors.
':.paration of redundant cables and of the area from adjacent plant areas may not be adequate to preserve the pl.at's shutdown capability in the event of a fire.
A charcoal fire may release an excessive amount of radioactive materials.
5.7.6 Modifications The licensee will:
(1) Install fire detectors in this area, (2) Replace the existing unrated docrs by VL or FM listed, 3-hour rated fire doors, or acceptable alternate protection, (3) Separate one division of safety-related cables from their redundant counterparts by rated fire barriers, or reroute one division of cables out of the area, or demonstrate tne adequacy of cable separation in preserving safe shutdown, and (4) Provide the results of an analysis for the radiolcgical consequences of a charcoal fire.
We will address the adequacy of fire protection for this area in a supple-ment to thB report.
5.8 Chemical and Volume Control Area (212, 213, 214, 215, 216, 216A, 217, 218, 219, 220) 5.8.1 Safety-Related Eqt ipment Safety-related equipment in this area includes volume control tanks, boric acid pumps and tanks, and degasifier pumps.
The area also contains piping associated with the charging system and the boric acid system.
Safety-related cables routed in the area include redundant power cables for auxiliary feedwater pump room fans, boric acid tank heaters and boric acid piping heat tracers.
1084 168 5-9
5.8.2 Combustibles Combustibles in this area consist of electrical cable insulation and pipe insulation.
Some transient combustibles were observed in the corridor area during the site visit.
Hydrogen lines supplying the volume control tanks are routed in the area.
5.8.3 Consequences if No Fire Suppression The area is subdivided into several rooms, a corridor and the elevator vestibule; however, all rooms are joined to the corridor via open doorways or doorways with unrated doors.
The corridor is, in turn, open to other plant areas on the same floor.
The effects of a fire in the area, especially in the corridor area, therefore, may not be confined in the room where the fire originates.
The licensee has not analyzed the effects of fire damage to redundant cables / components in this area.
5.8.4 Fire Protection Systems Manual hose stations ar.L purtable extinguishers are available for manual fire fighting in this area.
5.8.5 Adequacy of Fire Protection Fire protection for this area is inadequate.
A fire in the area is not likely to be detected because of the lack of fire detectors.
The licensee has not demonstrated that redundant cables will not be damaged by a fire in the area.
No protection is provided against a possible leakage of the hydrogen piping.
5.8.6 Modifications The licensee will:
(1) Install fire detectors in the corridor (including passage) and boric acid and tank rooms, (2) Demonstrate the adequacy of separation of redundant cables, from each other and from possible exposure fire hazards, in preserving safe shutdown, or provide appropriate codifications to preserve such, and (3)
Install an excess flow stop valve in the hydrogen line to secure hydrogen automatically in the event of a piping N stam rupture.
5 We will address the adequacy of fire protection fe ' is brea in a supple-ment to this report.
1084 169 5-10
5.9 Balance of Auxili6cf Building at Elevation 5'-0" (207, 208, 209, 210, 222, 223) 5.9.1 Safety-Related Equipment Safety-related equipment in this area includes waste gas equipment and cables associated with charging pumps, auxiliary feedwater pump room fans, ECCS room cooler fans, and boric acid system heaters and heat tracing.
- 5. 9. 2 Combustibles The area conteins large quantities of oil / solvent, plastics, wood, acetylene gas in bottles, and electrical cable insulation.
Most of these combustibles are concentrated in the hot machine shop / instrument shop areas.
Large quantities of transient combustibles, such as waste oil and waste plastics / woods, were observed in the corridor.
Hydrogen piping supplying volume control tanks is routed through the area.
5.9.3 Consequences if No Fire Suppression The licensee contends that safety-related cables redundant to those contained in the hot machine shop and the hot instrument shop exist outside of these shops.
However, adjacent areas which contain such redundant cables are joined to these shops by unprotected open doorways.
A fire in this area could, therefore, damage not only all cables in the area but also those redundant cables in the adjacent areas, compromising the plant's safe shutdown capability.
The licensee has not analyzed the radiological con-sequences of a fire in the waste gas area.
5.9.4 Fire Protection Systems Manual hose stations and portable extinguishers are provided to combat a fire in this area.
5.9.5 Adequacy of Fire Protection Fire protection for this area is inadequate.
A fire in the area is not likely to be detected because of the lack of fire detectors.
Separation of cables in the area from their redundant counterparts in the adjacrat areas may not be adequate to prescrve the shutdown capability of the plant.
5.9.6 Modifications The licensee will:
(1)
Install fire detectors in the hot machine shop and instrument shop, (2) Provide apprnpriately rated fire doors; fire damper; and piping, electrical cable and ventilation duct penetration seals to separate the hot machine shop and the hot instrument shop from the adjacent plant areas.
I084 170 5-11
(3) Provide curbs at the doorways to the hot machine shcp and the hot instrument shop, or other ccceptable means to contain a possible oil / solvent spillage, (4)
Install an excess flow stop valve in the hydrogen line to secure hydrogen automatically in the event of a piping system rupture.
(5) Analyze the radiological consequences of a fire in the waste gas area.
The licensee will also remove all combustibles that are not required for the routine operation and maintenance of the plant from the area and prohibit open storage of combustible materials near or under the safety-related cables / equipment.
Storage of combustible materials necessary for the routine operation or maintenance of the plant will be limited to approximately one week's supply.
Appropriate storage facilities will be provided.
We will address the adequacy of fire protection for this area in a supple-ment to this report.
5.10 Cable Spreading Rooms (302, 306, lc and 2c) 5.10.1 Safety-Related Equipment The safety-related equipment in these areas consists of 480 volt battery chargers, 125 volt DC buses, safety-related panels, and a large quantity of cabling feeding redundant divisions of safety-related equipment.
5.10.2 Combustibles The combustibles in this area consist of electrical cable insulation, duct insulation and small amounts of combustible electrical components in the panels.
5.10.3 Consequences if No Fire Suppression Safety-related circuits from redundant divisions are allowed to be wired to within six inches of each other inside panels.
An unmitigated fire in these panels could endanger safe shutdcwn.
The rooms are congested with a large quantity of electrical cables, including 480-volt power cables, serving both redundant divisions of safety-related equipment.
An unmitigated fire in the rooms is likely to damage redundant cables for many safety-related systems endangering safe shutdown.
Heat generated by a large cable fire in the roomscould also damage the safety-related panels.
5.10.4 Fire Protection Systems Electrical panels in the rooms are protected by individual Halon 1301 systems which are actuated automatically by heat detectors located in the panels.
The general area of the rooms is provided with smoke detectors and a manual hose station, and portable extinguishers are available for fire fighting.
1084 171 5-12
5.10.5 Adequacy of Fire Protection Fire protection for this area is inadequate.
Separation of redundant cabling / wiring has not been demonstrated to be adequate to preserve at least one division of safety-related cabling / equipment for safe shutdown in the event of a fire in the area.
Manual fire fighting will allow a fire in this critical area to burn for an additional period of time increasing the extent of damage.
Access to the cable chases and the recessed areas above the battery rooms is poor.
5.10.6 Modifications The licensee will install an automatic fire suppression system in each cable spreading room, and demonstrate the adequacy of cable / equipment separation in preserving safe shutdown during and following a fire emergency.
Dedicated ladders of fiberglass construction have been provided in each room to provide access to the areas above the battery rooms and the overhead cable chases.
We will address the adequacy of fire protection for cable spreading rooms in a supplement to this report.
5.11 Battery Rooms (301, 304, 305, 307) 5.11.1 Safety-Related Equipment The safety-related equipment in these areas consists of the station batteries.
In addition, there are electrical cables feeding safety-related equipment.
5.11.2 Combustibles The combustibles in these area; consist of battery cases and electrical cable insulation.
5.11.3 Consequences if No Fire Protection Since there are no air flow monitors in these areas, loss of ventilation air flow, and possible accumulation of hydrogen, could occur without the timely knowledge of the control room operators.
Otherwise the fire loading is low and it is not likely that an entire battery bank could be lost by a fire.
However, if this did occer, the redundant battery room would serve to insure safe shutdown.
1084 172 5-13
t 5.11.4 Fire Protection System A manual hose station and portable extingushers are available for manual fire fighting.
5.11.5 Adequacy of Fire Protection Fire protection in these areas is tradequate because of the lack of pro-tection against a possible hydrogen accumulation.
5.11.6 Modification The licensee will install telltales at the exhaust and supply air grills in each battery room and verify the ventilation air flow twice each shift.
We will address the adequacy of fire protection for this area in a supplement to this report.
5.12 Switchgear Rooms (311, 317, 407, 430) 5.12.1 Safety-Related Equipment The safety-related equipment in these areas consists of 4,000 volt switchgear, 480 volt load centers, service transformers and cabling that feeds safety-related equipment.
5.12.2 Combustibles The combustibles in these areas consist mainly of electrical cable insulation.
There are also small amounts of combustible electrical components.
5.12.3 Consequences if No Fire Suppression An unmitigated fire in either switchgear room could disable one redundant division and the "C"
(swing) division.
The alternate switchgear room would be available for safe shutdown.
However, there are a few conduits containing cables from the "A" division located above the 4KV "B" switchgear.
The licensee has not analyzed the consequences of the loss of these "A" cables concurrent with the loss of "B" division.
5.12.4 Fire Protection System Smoke detectors are installed in each room.
Manual hose stations and portable extinguishers are available for fire fighting.
5.12.5 Adequacy of Fire Protection The licensee has not analyzed the consequences of the loss of "A" cables in conduits above the "B" switchgear concurrent with the loss of "B"
division.
The licensee also has not demonstrated that all points in 1084 1/3 5-14
switchgear rooms can be reached effectively by at least one manual hose stream.
5.12.6 Modification The licensee will:
(1) Analyze the consequences of losing "A" cables in conduits above "B" switchgear concurrent with the loss of "B" division, and (2) Demonstrate by hose reach tests that every point in switchgear rooms can be reached effectively by at least one manual hose stream.
We will address the adequacy of fire protection for this area in a supple-ment to this report.
5.13 Cable Chases (lA, 18, 2A, 2B, Ul and U2) 5.13.1 Safety-Related Equipment A large quantity of electrical cables serving many safety-related systems is located in cable chases.
There is no other equipment.
5.13.2 Combustibles The combustibles in this area consist of electrical cable insulation.
5.13.3 Consequences if No Fire Suppression An unmitigated fire in any one cable chase could damage cables from redundant divisions in that chase.
Each cable chase contains cables mostly from one The division mixed with some cables from the other redundant division.
licensee indicated that any of the cables in the cable chases can be disabled without affecting safe shutdown, but did not address the possible consequences of losing redundant cables in each chase.
5.13.4 Fire Protection System Smoke detectors are installed in all cable chases.
Manual hoses and portable extinguishers can be brought in from adjacent areas.
5.13.5 Adequacy of Fire Protection The fire protection in the cable chases is not adequate because of the following problem:
Poor accessiblity for fire fighting "A" chases have access at (1) elevations 45'-0" and 69'-0, "B" chases have only one access at the elevation 45'-0".
These vertical cable chases extend downward to the elevation 27'-0" and a steel platform with approximate floor area of 4' x 6' is provided inside each chase at the access on the elevation 45'-0".
It is highly unlikely that a fire in any vertical cable chase can be 5-15
effectively fought from this small platform.
Each horizontal cable chase has one access which can be reached only by climbing up a vertical ladder'and then weaving through piping and steel structure.
It is difficult, if not impossible, to bring up portable extinguishers or manual hose lines into the horizontal cable chases.
(?) In "B" chase, smoke venting may not be possible because the only opening to the chase is the doorway near the lower end of the chase.
(3) No fire water drainage is provided for any vertical cable chase.
There is a possibility of fire water accummulation submerging cables near the bottom of the cable chases.
(4) Separation of cables has not been demonstrated to be adequate to limit the fire damage to a single redundant division.
5.13.6 Modification The licensee is analyzing fire hazards in these cable chases and will propose, at the completion of such analysis, modifications to preserve safe shutdown, and to provide a capability to suppress a fire in these chases.
We wil; address the adequacy of fire protection for the cable chase in a supplement to this report.
5.14 Purge Air Supply Rooms (312, 318) 5.14.1 Safety-Related Equipment The rooms contain service transformers in addition to cables and buses serving many safety-related equipment.
5.14.2 Combustibles Combustibles in these rooms consist of electrical cable insulation and fan belts.
5.14.3 Consequences if No Fire Protection An unmitigated fire in either room could damage redundant cables required for shutdown in the room.
5.14.4 Fire Protection System Manual hoses and portable extinguishers are available to combat a fire in these rooms.
5-16
5.14.5 Adequacy of Fire Protectioh A fire in these rooms is not likely to be detected because of the lack of fire detectors.
Separation of redundant cables in the rooms may not be adequate to preserve the plant's capability for safe shutdown in the event of a fire in the area.
5.14.6 Modification The licensee will:
(1) Install fire detectors in each of these -
3, and (2) Separate redundant cables in each room by a rated fire barrier, reroute one division of redundant cables out of the room, or demonstrate the adequacy of cable separation in preserving safe shutdown.
We will address the adequacy of fire protection for this area in a supple-ment to this report.
5.15 Area West of Spent Fuel Pool at Elevation 27'-0" (319, 320, 322, 323, 324, 325, 327, 328) 5.15.1 Safety-Related Equipment Safety-related equipment in this area i" -ludes letdown heat exchangers and the spent fuel cooling system.
5.15.2 Combustibles Combustibles in this area consist of lube oil, electrical cable insulation and resin inside the demineralizer.
5.15.3 Consequence if No Fire Suppression The licensee has not analyzed the fire hazards in this area.
5.15.4 Fire Protection System A manual hose station and portable extinguishers are available to combat a fire in this area.
5.15.5 Adequacy of Fire Protection The licensee has not analyzed fire hazards in this area.
5.15.6 Modification The licensee will analyze the effect on the spent fuel cooling, and other possible safety effects, of a fire in this area.
We will address the adequacy of fire protection for this area in a supple-ment to tnis report.
1084 1~6
/
5-17
5.16 Control Room Complex (400, 401, 402, 403, 404, 405, 406, 415, 431, 432, 434, 435, 436) 5.16.1 Safety-Related Equipment The safety-related equipment in this area consists of the main control board and safety-related panels.
There is also a considerable amount of instrumentation and control cable that serves safety-related equipment.
5.16.2 Combustibles The combustibles in this area consist of electrical cable insulation; electrical components; class A material such as computer printouts, logs, cardboard, and drawings; HVAC duct insulation, and solvents and cleaning used in the log and test instrument room.
There are wooden table tops, wooden shelves, and wooden bench tops in the complex.
5.16.3 Consequence if No Fire Suppression Without fire suppression, a fire in a safety-related panel could damage cables of redundant divisions endangering safe shutdown. A fire in any one of the control room fringe areas is likely to be contained within the area.
5.16.4 Fire Protection System Smoke detectors are installed in (1) HVAC ducts, (2) control room ceiling, (3) the log and instrument room, (4) supervisor's office, and (5) computer rooms.
The computer rooms have, in addition, heat detectors located within cabinets and under the floor which actuate Halon 1301 systems protecting these cabinets and subfloor area.
A manual hose and portable extinguishers are available for manual fire suppression.
5.16.5 Adequacy of Fire Protection The present detection system is adequate to properly protect all areas vf the control complex.
The nozzle of the manual hose covering this area is not designed to suppress a fire within electrical equipment.
The wooden furniture and shelves present an unnecessary fire hazard for this critical area.
The unprotected computer printout terminal in the middle of the main control board presentsan even larger fire hazard.
Separation of redundant wiring inside the panels has not been demonstrated to be adequate to preserve safe shutdown against any fire within the area.
Fire resistance of bullet proof doors in the area has not been established.
5.16.6 Modification The licensee has provided a fog nozzle for the manual hose protecting this area.
He will also:
(1)
Replace wooden furniture and shelves with those of metal except for work benches in the Log and Test Instrument Room (Room 435).
5-18
(2)
Provide metal partitions to separate the adjoining panels from the computer terminal in the middle of the main panel.
(3) Demonstrate that the safe shutdown capability can be preserved in the event of a fire in this area.
(4) Replace the existing bullet-proof doors with VL listed 3-hour rated, bullet-proof fire doors, or demonstrate the adequacy of fire resistance of the existing doors.
We will address the adequacy of fire protection for this area in a supplement to this report.
5.17 Electrical Penetration Rooms (409, 414, 423, 429) 5.17.1 Safety-Related Equipment Motor Control Centers (MCCs) 104 and 204 serving safety-related equipment are located in these rooms.
cables serving safety functions are routed in these rooms.In addition, man 5.17.2 Combustibles The combustibles in this area consist of electrical cable insulation.
5.17.3 Consequences if No Fire Suppression Each room contains redundant cables required for safe shutdown.
An unmitigated fire in any room could damage redundant cables within the room, endangering safe shutdown.
MCCs 104 and 204 are redundant to each other and contained in separate rooms.
5.17.4 Fire Protection System Smoke detectors are installed in each room.
Manual hose stations and portable extinguishers are provided.
5.17.5 Adequacy of Fire Protection Fire protection for these rooms is inadequate.
Separation of redundant cables may not be adequate to preserve one division of cLbles for safe shutdown in the event of a fire in these rooms.
The manual hose stations designated to prote:t these rooms may not be able to reach all points in these rooms effectisely.
5.17.6 Modification The licensee will:
(1) Perform hose reach tests and provide additional interior hose stations as necessary to assure the effective manual hose coverage for ali points in these rooms, and 1084 1/8 5-19
(2) Separate redundant cables in each room by complete enclosure in rated fire barriers, reroute redundant cables out of each room, or demon-strate the adequacy of cable separation in preserving saft shutdown.
We will address the adequacy of fire protection for this area in a supplement to this report.
5.18 Diesel Generator Rooms (416, 421, 422) 5.18.1 Safety-Related Equipment Each diesel generator room contains an emergency diesel generator and associated equipment and cables.
5.18.2 Combustibles The major combustible materials in each diesel generator room include electrical cable insulation, lubricating oil, fuel oil, and thermal and acoustical insulation.
5.18.3 Consequences if No Fire Suppression There are three diesel generators housed in three separ ate rooms separated from each other and from other plant areas by 3-hour rated fire barriers except unrated doors facing the yard area.
Two of the three diesel genera-tors each feeds one redundant safety division in both units, while the third diesel generator is capable of feeding both divisions in both units.
A fire in one of these rooms could disable one diesel generator.
Other diesel generators should be able to provide emergency onsite power for safe shutdown.
Howevar, oil leakage under the door separating diesel rooms 421 and 422 could involve both diesels in a single fire.
5.18.4 Fire Protection Systems A preaction sprinkler <.fstem and portable dry chemical and carbon dioxide fire extinguishers are in each room.
Hose lines from yard hydrants are also available.
5.18.5 Adequacy of Fire Protection The installed sprinkler system should be able to suppress a fire starting in one of these rooms.
Howr.ve, leakage of oil out of the room could result in fire involvement of an adjoining area.
A failure in, or isolation of, the fire service water system underground piping in this area could cause the loss of both the primary and backup fire suppression capability for these rooms.
5.18.6 Modificat'ons The licensee will install a curb at the doorway between two adjacent diesel generator rooms to prevent a possible communication of spilled oil via the doorway.
1084 179 5-20
In addition, the licensee will implement an administrative procedure to prelay a 2 1/2" hose connected to Hydrant No. 5 to provide the manual hose coverage in case of a failure in, or isolation, of the section of fire water piping serving this area. The licensee will also replace nonrated doors facing the yard area by 1 1/2-hour rated UL or FM listed fire doors.
We find that, subject to implementation of the modifications described above, fire protection for the diesel generator rocms conforms to the provisions of Appendix A of Branch Technical Position 9.5-1 and is, therefore, acceotable.
5.19 Containment 5.19.1 Safety-Related Equipment Safety-related equipment inside containment includes the reactor, the primary coolant system, steam generators and associated piping, instrumenta-tion and cabling.
5.19.2 Cm.bustibles The significant combustibles in the containment include electrical cable insulation, lubricating oil for the reactor coolant pumps, and rubber material.
5.19.3 Consequences if No Fire Suppression A fire involving reactor coolant pump lubricating oil could produce high temperatures and release a large amount of heat in a short period of time.
The licensee has indicated that each of the reactor coolant pumps has been equipped with an oil collection system; however, the details submitted by the licensee revealed that the system is less than adeauate to contain the fire hazards associated with leakage of such oil.
Specifically, the licensee has not demonstrated that:
(a)
The existing system provides a complete containment for all potential leakage points which include lift pump and piping, external oil cooler, flanged connections, drain plugs, fill points, upper and lower reservoirs, sight glasses and overflow lines.
(b) The copper drain tubing does have adequate capacity to accommodate drainage of a large oil leak.
(c) Draining collected oil on the containment floor is safe.
(d)
The effects of a seismic event on this system will not adversely affect the plant safety.
The licensee has not demonstrated that separation between redundant cables /
equipment inside containment is adequate to preserve at least one division of these cables / equipment for safe shutdown.
~
'1084 180 5-21
P00R~0nlmi 5.19.4 Fire Protection Systems fh2re are a total of six hose stations in each containment.
Each hose station is located at a stairway and contains 75 feet of lis inch fire hose.
These are connected to the fire protection water system by a normally shut motor-operated valve outside of the containment.
This valve may be operated from the control room, from any of the hose stations in containment, or mawally.
Portable carbon dioxide extinguishers are lceated outside the containment personnel access hatch and emergency personnel air lock.
Charcoal filters in containment are provided with high temperature monitors and manually actuated emergency cooling water suppression systems.
5.19.5 Adequacy of Fire Protection The existing reactor co'>lant pump lube oil collection system is inadequate to contain a possible oil leakage and drain the leaked oil to a safe place Fire fighters using the containment hose stations should be able to suppress fires involving other materials or those resulting from failure of the oil collection system, except tl.at the existing 75-foot lengths of, hose may not be able to reach all parts of every area in containment.
In addition, the lack of fire detection devices in containment will permit such fires to continue unneces-sarily before suppression activities begin.
The licensee has not demonstrated the adequacy of separation of redundant cables / equipment.
5.19.6 Modifications The licensee will:
(1) Demonstrate the adequacy of cable / equipment separation in preserving safe
- shutdown, (2)
Install fire detection devices in areas which contain safety-related cables and/or equipment, (3) Perform hose reach tests to ensure that all fire hazards can be reached by at least one effective hose stream, However, the licensee has not provided sufficient justification for not modifying the existing lube oil collection system.
This issue will be resolved in a separate action.
We will address the adequacy of fire protection in the containment in a supplement to this report.
5-22 1084 181 1
5.20 Area West of Spent Fuel Pool at Elevation 45'-0" (412, 413, 417, 418, 419, 420, 424, 425, 426, 441) 5.20.1 Safety-Related Equipment Safety-related equipment in this area includes the coolant waste evaporator and solid waste handling equipment including spent resin tank and pump.
5.20.2 Combustibles Combustibles in this area consist of electrical cable insulation, solid wastes (plastics, clothing, paper) and possible storage of spent resin in this area.
5.20.3 Consequences if No Fire Suppression It was observed during the site visit that several safety-related cable trays are routed in the cask and equipment loading area.
The licensee has not analyzed the consequences of the fire damage to these cables. The
'icensee also has not analyzed the radiological consequences of a fire involving solid waste, especially spent resin.
5.20.4 Fire Prr+ f+40. System The waste handling room is provided with an automatic sprinkler system.
Manual hoses and portable extinguishers are available for suppression of a fire in the area.
5.20.5 Adequacy of Fire Protection Fire protection for this area may not be adequate.
Possible fire damage to safety-related cables other than those in the waste handling room have not been analyzed.
The radiological consequences of a fire involving 31id waste in this area have not been addressed.
5.20.6 Modification The licensee will:
(1) Identify other safety-related cables in the area and analyze the possible consequences of fire damage to these cables, and (2) provide the results of an analysis of the radiological consequences of a fire involving solid waste, in particular the spent resin, stored in this area.
We will address the adequacy of fire protection for this area in a supple-ment to this report.
1084 182 5-23
5.21 Intake Structure 5.21.1 Safety-Related Equipment The intake structure contains the six salt water pumps and associated motors, cabling and piping, for Units 1 and 2.
5.21.2 Combustibles The significant combustible material includes lubricating oil for the circulating water pumps and salt water pumps, and electrical cable insulation.
5.21.3 Consequences if No Fire Suppression Floor area around each circulating water pump slopes down toward the pump forming a pit around the pump which is capable of containing a possible lube oil leakage from the pump.
A fire involving more than one pump is therefore unlikely.
A major fire involving one of the salt water pumps or circulating water pumps would be unlikely to affect redundant safety-related equipment.
The licensee has not demonstrated that separation of redunaant cables in this area is adequate to preserve the safe shutdown capability of the plant.
5.21.4 Fire Protection Systems Portable carbon dioxide extinguishers are located at 120-foot intervals along the west wall of the pump room.
5.21.5 Adequacy of Fire Protection Portable extinguishers are not adequate for suppressing a major lubricating oil fire in this area.
In addition, the lack of fire detection devices would increase the likelihood of significant fire damage.
5.21.6 Modifications The licensee will:
(1) Install a fire detection system in this area, (2) Demonstrate, or install additional hose stations to ensure, that all points in the intake structure can be reached by at least one effective hose stream.
(3) Demonstrate by the results of additional testing or analyses that separation of redundant cables is adequate to preserve the safe shutdown capability of the plant against a fire in this area.
We will address the adequacy of fire protection for this area in a supplement to this report.
.1084 183 5-24
5.22 Refueling Water Pump and Heat Exchanger Rooms (439, 440T 5.22.1 Safety-Related Equipment Safety-related equipment in this area includes refueling water storage tanks, pumps, heat exchangers, and associated piping.
5.22.2 Combustibles There is a small amount of lubricant and electrical cable insulation in these rooms.
5.22.3 Consequences if No Fire Suppression The licensee has not analyzed the hazards of fire in the yard area or a possible fire involving transient combustibles.
5.22.4 Fire Protection System Yard fire hydrants and portable extinguishers are available to combat a fire in and outside of these rooms.
5.22.5 Adequacy of Fire Protection Separation of these rooms from a possible fire hazard in the yard area is inadequate.
i084 i84 5-25
5.22.6 Modification The licensee will replace the non-rated doors leading to the yard area by by 1 1/2-hour rated UL or FM listed fire doors or provide acceptable alternate protection unlen it can be demonstrated that the loss of all equipment includiag pumps and valves in either room will not prevent safe shutdown.
We will address the adequacy of fire protection for this area in a supplement to this report.
5.23 Health Physics Area (502, 503, 504, 505, 506, 507, 508, 509, 511, 513, 514, 515, 516, 518, 519, 521, 522, 523, 525, 527, 534, 535) 5.23.1 Safety-R lated Equipment Except for the component cooling head tank and associated valves and piping in the personnel access, this area does not contain any safety-related equipment.
5.23.2 Combustibles Large quantities of fabric, paper and plastics are present in this area.
Transient combustibles are possible.
5.23.2 Consequences if No Fire Suppression The component cooling haad tank and piping are not likely to be damaged by a fire in or around the personnel access areas.
However, the licensee has not addressed the possibility of fire damage to valves in these access areas.
Combustibles in other rooms of thir area are well separated from safety-related equipment in the adjoining areas by rated fire barriers or a large distance.
A fire in these rooms ~is unlikely to have any adverse effect on the plant safety.
5.23.4 Fire Protection System Manual hoses and portable extinguishers are available to combat a fire in this area.
5.23.5 Adequacy of Fire Protection Manual hoses and portable extinguishers should be adequate to suppress a fire in this area.
5.23.6 Modification The licensee will verify that possible fire damage to valves in the personnel access areis would not have an adverse impact on the plant safety.
We find that, subject to implementation of the above described modification, fire protection for this area satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
1084 185 5-26
t 5.24 Ventilation Equipment Rooms (512, 520, 524, 526, 531) 5.24.1 Safety-Related Equipment Safety-related equipment in these rooms includes ventilation equipment for the control room, for the spent fuel pool area and for the waste processing area.
5.24.2 Combustibles Combustibles in these rooms consist of charcoal, ventilation duct insulation, lubricant and electrical cable and motor winding insulation.
Approximately 5 gallons of lubrication oil and other transient combustibles were observed dering the site visit.
5.24.3 Consequences if No Fire Suppression The licensee has not analyzed the impact on' plant safety of a fire in these rooms.
5.24.4 Fire Protection System Manual hoses from adjoining areas and portable extinguishers provide the manual fire suppression capability for these rooms.
5.24.5 Adequacy of Fire Protection Manual hoses may not reach all points in these room s effectively.
Existing equipment may r.ot be adequate to suppress a charcoal fire incide filters.
5.24 6 Modification The licensee will:
(1) Perform hose reach tests, and pre"ide additional hose stations as necessary, to assure effective manual hose coverage for all points in these rooms, and (2) Analyze the possible safety impacts of fire damage to ventilation equipment which will include, but not be limited to, control room habit-ability, possible effects on instruments in the control room and in other areas served by the damaged equipment, and the potential for a release of radioactive materials.
Additional modification may be provided following the analysis.
(3) Remove from the area all combustibles that are not needed for routine operation or maintenance of the plant.
We will address the adequacy of fire protection for these rooms in a supplement to this report.
1084 186 5-27
5.25 Spent Fuel Pool and Fuel Handling Area (313, 314, 411, 427, 528, 530, 533, 536, 537) 5.25.1 Safety-Related Equipment Safety-related equipment in this area includes spent fuel pool, waste evaporator and evaporator control panel.
5.25.2 Combustibles During the normal operation, this area has only an insignificant amount of combustibles.
5.25.3 Consequences if No Fire Suppression Spent fuel rods submerged in water. are not likely. to be a#fccted.bv a_ fire in this area.
The licensee has not analyzed the possible safety impact of fire damage to the waste evaporator control panel.
5.25.4 Fire Protection System Fire protection equipment consists of manual hoses and portable extinguishers.
5.25.5 Adequacy of Fire Protection Portable extinguishers should be adequate to suppress a fire in this area during the normal operation of the plant.
However, during the refueling period, a large quantity of combustibles will be introduced into this area.
A fire involving such combustibles may not be suppressed by portable extinguishers.
Existing interior hose stations may not reach all points in this area effectively.
5.25.6 Modification The licensee will:
(1) Perform hose reach tests and provide additional modification, as necessary, to assure effective manual hose coverage for all points in this area, and (2) Analyze the radiological consequences of possible fire damage to the waste evaporator control panel.
We will address the adequacy of fire protection for this area in a supple-ment to this report.
5.26 Electrical Rooms (529, 532) 5.26.1 Safety-Related Equipment The safety-related equipment in these rooms consists of motor control center 114 in room 529 and motor contral center 214 in room 532.
There is also electrical cabling that feeds safety-related equipment.
5-28
)Q84 ]8[
5.26.2 Combustibles 4
The combustibles in these rooms consist of electrical cable insulation, cardboard, sheeting, hoses, bags and other miscellaneous combtstible materials.
5.26.3 Consequences if No Fire Suppression If an unmitigated fire destroyed all the cable and the motor control center, safe shutdown would still be assured by redundant equipment and cables.
5.26.4 Fire Protection System The fire protection system consists of smoke detectors, a manual hose station, and portable carbon dioxide extinguishers located outside the rooms.
5.26.5 Adequacy of Fire Protection Existing equipment should be adequate to detect and suppress a fire in these rooms.
However, these rooms contain iarge amounts of unnecessary combustible materials.
5.26.6 Modification The licensee will remove from these rooms all combustible materials which are not needed for routine operation and maintenance of the plant.
Storage of combustible materials required for operation or maintenance of the plant will be limited to approximately one week's supply.
The licensee will also verify the manual hose cover. age.
We will address the adequacy of fire protection for this area in a supple-ment to this report.
5.27 Auxiliary Feed Pump Rooms (603, 605)
There are two auxiliary feed pump rooms in the plant, one for each unit.
5.27.1 Safety-Related Equipment Each room contains both auxiliary feed pumps; associated piping, valves and cabling; and the remote hot shutdown control panel.
Cables routed in each room include instrument cables for reactor coolant temperature (2 channels), pressurizer pressure and level (2 channels each), and steam generator level; and power and control cables for all three channels of salt water pumps.
1084 188 5-29
5.27.2 Combustibles Combustibles in chese rooms consist of electrical cable insulation, lube oil and snubber oil.
5.27.3 Consequences if No Fire Suppression The licensee has not demonstrated that at least one turbine-driven pump for each unit can be preserved during and following a major fire in these Auxiliary feedwater is required for safe shutdown when offsite rooms.
power is not available.
Redundant cables for salt water systems could be damaged by a fire involving leaking lube oil or transient combustibles.
5.27.4 Fire Protection System Manual hoses and portable extinguishers are available for manual fire suppression.
5.27.5 Adequacy of Fire Suppression Fire protection for these rooms is inadequate.
8 fire in these rooms is not likely to be detected because of the lack of fire detection systems in these rooms.
Separation of redundant cables is inadequate to preserve at least one division of redundant cables required for shutdown.
Separation of redundant auxiliary feed pumps and associated valves and cables has not been demonstrated to be adequate to preserve the function of at least one pump against a fire in the rooms.
5.27.6 Modification The licensee will: -'
(1)
Install a fire detection system in each of these rooms, (2) Demonstrate by tests or analyses that separation between redundant auxiliary feed pumps and associated piping, valves and cables is adequate to preserve the function of at least one pump against a fire in the room, or provide additional modification to preserve such function.
(3) Enclose at least one division of other safety-related cables in a rated barrier unless the function of such cables can be duplicated by other cables routed outside of the rooms, or demonstrate the adequacy of cable separation in preserving safe shutdown.
We will address the adequacy of fire protection in a supplement to this report.
5.28 Turbine Building (601, 606, 800, 801, 802, 803) 5.28.1 Safety-Related Equipment The licensee's fire hazard analysis stated that there is no safety-related cable or equipment in the turbine building.
1084 189 5-30
5.28.2 Combustibles Principle combustibles in the turbine building include lubricating oil, seal oil, hydraulic fluid, electrical cable insulation, hydrogen in the generators, and HVAC duct insulation.
5.28.3 Consequences if No Fire Suppression An unmitigated fire in the turbine building would cause serious damage to the cont;nts; however, the licensee has indicated that there is no safety-related cable or equipment in the turbine building so that safe shutdown will not be compromised by such damage.
5.28.4 Fire Protection Systems Deluge sprinkler systems automatically actuated by heat detectors are installed to protect the steam generator feed pumps, and hydrogen seal oil units on elevation 12 feet of the turbine building.
Automatic sprinkler systems are installed to protect the auxiliary boiler room on elevation 27 feet of the turbine building, and to provide general area protection on elevations 12 feet and 27 feet of the turbine building.
Manually actuated preaction sprinkler systems are installed to protect the turbine generator bearings on elevation 45 feet of the turbine building.
Interior hose stations and portable extinguishers are provided throughout the open areas of the turbine building.
5.28.5 Adequacy of Fire Protection The installed fixed suppression systems are capable of controlling or suppressing fires in their areas of coverage, and the installed base lines should likewise be effective in other areas, except that some areas may be beyond the reach of presently provided hose lengths.
5.28.6 Modifications The licensee will perform hose stretch tests and install additional interior hose stations as necessary to insure that all points in the turbine building can be reached by at least one effective hose stream.
We find, subject to implementation of the above described modification, fire protection for this area meets the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
5-31 1084 190
5.29 Fire Pump House 5.29.1 Safety-Related Equipment There is no safety-related equipment in the fire pump house.
5.29.2 Combustibles Major combustible materials include 550 gallons of fuel oil in the diesel engine driven fire pump fuel tank, and electrical cable insulation.
The fuel tank is in a drained, curbed area of sufficient size to contain the entire volume of the tank.
5.29.3 Consequences if No Fire Suppression An unmitigated fire would have no effect on safe shutdown of the plant, although it could affect the availability of fire water because both the electric and the diesel driven fire pumps as well as the fuel tank are in the same room.
5.29.4
_ Fire Protection Systems A wet pipe automatic sprinkler system is installed in this building.
Portable extinguishers and hose lines from outside hydrants are also available for fire suppression.
5.29.5 Adequacy of Fire Protection The installed automatic sprinkler system may not be capable of controlling or suppressing a fire in this building because fire pumps may not be available in the event of a fire in this area.
5.29.6 Modifications The licensee has not demonstrated that the sprinkler system installed in barrier in limiting the effect of a fire at the t!esel fire cu fuel tank, on the electric tire pump.
This issue will be r,olved in a separate action.
s We wil1 address the adequacy of fire protection for this area in a suppleme to this report.
5.30 Yard Area 5.30.1 Safety Related Equipment The two refueling water storage tanks and the three condensate storage tanks are the only safety-related equipment in the yard.
5.30.2 Combustibles Significant combustible materials in the yard include No. 2 fuel oil in the two 125,000 gallon capacity diesel generator fuel oil storage tanks 5-32 lN4 }h!
propane in two 124 gallon (water capacity) storage tanks, and anhydrous ammonia in a storage tank, hydrogen gas in storage tanks, turbine oil in a 20,000 gallon storage tank, and large quantities of transformer oil associated with each transformer.
5.30.3 Consequences if No Fire Suppression An unmitigated fire involving the turbine lubricating oil or fuel oil storage tanks would not affect the safe shutdown of the plant.
The licensee has not demonstrated that a fire or explosion involving the various com-pressed gas storage cylinders would not affect safety-related equipment in any of the main plant buildings, or damage the condensate storage tank housed in the concrete structure.
safe shutdown provided onsite emergency power is available.A fire involving tran 5.30.4 Fire Protection Systems A manually actuated fixed foam system is installed to protect each diesel generator fuel oil storage tank.
A water spray system, automatically actuated by heat detectors, is provided for each transformer.
Hose lines from yard hydrants, and wheeled or portable fire extinguishers, are also available for fire suppression.
5.30.5 Adequacy of Fire Protection The installed fire suppression systems and available hose lines and extin-guishers should be capable of controlling or suppressing a fire in the yard area.
However, a single failure in the fire service water system piping west of the auxiliary building could cause the loss of primary and backup fire suppression capability for the station service transformers in that area.
5.30.6 Modifications The licensee will verify that at least one condensate storage tank would be available for safe shutdown following the explosion of a propane-air mixture in the area north of the turbine building.
We find that, subject to sacisfactory resolution of the concern describ d above, fire protection for the yara area conforms to the provisions of e
Appendix A to Branch Technical Position 9.1-1 and is, therefore, acceptable 5-33 1084 192
6.0 ADMINISTRATIVE CONTROL 5 The administrative controls for fire protection consist of the fire protection organization, the qualifications and training for fire protection personnel, the controls to be exercised over combustibles and ignition sources, plans and procedures for fighting fires in the varicus plant areas, and the quality assurance provisions for fire protection.
The licensee has provided a detailed description of pro-posed administrative controls, except for the quality assurance pro-visions for fire protection.
He is developing and implementing plans and procedures stipulating the management and staff organization and its qualifications, the fire brigade training program, controls over combustibles and ignition sources, and the prefire plans for fighting fires.
The licensee has taken two exceptions to our guidelines that require further justification.
6.1 Fire Fighting Strategies Contrary to scragraph d of Guidelines Attachment 5, the licensee states:
" Fire fighting strategies will not be established for fighting fires in all safety related areas.
Strategies will be established to combat fires within the following areas as recommended by the team of personnel from your office during the site visit regarding fire protection during the last week of November 1978:
1.
Horizontal Cable Chases 2.
Hot Machine Shop 3.
Cable Spreading Rooms 4.
Diesel Generator Rooms 5.
Electrical Penetration Rooms 6.
Main Turbine Lube Oil Reservoir Rooms 7.
SGFP Turbine Lube Oil Reservoirs A coninensurate level of protection will be maintained in other areas as fire brigade members are trained and knowledgeable in fire fighting techniques and are familiar with the operating equipment in each plant area.
In addition, drills simulating fires in other plant areas will be conducted periodically.
These drills will encompass most of the items in this guideline."
6.2 Quality Assurance Contrary to Guidelines Attachment 6, the licensec states:
"The Quality Assurance Procedure (QAP) addressing design, procurement, installation, testing, and administrative controls for the Fire Protection Program is currently being developed.
A comparison of the QAP and the guidelines of this section will be submitted at a later date."
1084 193 6-1
Our review of the minimum shift fire brigade size of five persons as specified in Technical Specifications 6.2.2.f shows conformance with ths staff position on this matter as stated in, " Evaluation of Minimum Fire Brigade Snift Size" June 8, 1979.
We find that, subject to implementation of quality assurance provisions for fire protection and the development of adequate fire fighting strategies, the fire protection program satisfies the objectives identifiea in Section 2.2 of this report and is, therefore, acceptable.
6-1084 194
1 7.0 TECHNICAL SPECIFICATIONS The interim technical specifications for fire protection were issued earlier to include limiting conditions for operation and surveillance requirements for the existing fire protection systems and administrative controls.
Following the implementation of the modifications to the fire protection systems and administrative controls resulti;ig from this review, the tect.nical specifications will ae modified to adequately address all of the existing fire protection systems, and to incorporate limiting conditions for operation and surveillance requirements for these modifications.
1084 195 7-1
8.0 CONCLUSION
S The licensee has performed a fire hazards analysis and has proposed certain modifications to improve the fire protection program.
Additional modifications 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.
These are summarized in Sections 3.2 and 3.3.
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 follcwing potential fire situations.
Additional evaluation of incomplete items, oiscussed in the preceding sections, will be necessary before we can conclude that the overall fire protection at the Calvert Cliffs Units Nos.1 and 2 will satisfy the provisions of Branch Technical Position 9.5-1 and Appendix A thereto, which the staff has established for satisfactor 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, while the remaining items are completed.
In the report of the Special Review Group on the Browns Ferry Fire (NUREG-0050) dated February 1976, consideration of the safety of operation of all operating nuclear power plants pending the completion of our detailed fire protection evaluation was presented.
The following quotations from the report summarize the basis for the Special Review Group's conclusion that the operation of the facility need not be restricted for public safety:
" Fires c.ccur rather frequently; however, fires involving equipment unavailability comparable to the Browns Ferry fire are quite infrequent (see Sectior. 3.3 of [NUREG-0050]).
The Review Group believes that steps already taken since March 1975 (see Section 3.3.2) have reduced this frequency significantly."
" Based on its review of the events transpiring before, during and af ter the Browns Ferry fire, the Review Group concludes that the probability of disruptive fires of the magnitude bf the Browns Ferry event is small, and that there is no need to restrict operation of nuclear power plants for public safety.
However, it is clear that much can and should oa done to reduce even further the likelihood of disabling fires and to improve assurance of rapid extinguishment of fires that occt-Consideration should oe given also to features that would increase further the ability of nuclear facilities ta withstand large fires without loss of inportant functions should such fires occur."
1084 196 31
We recognize that the " Risk Assessment Review Group Report to the U.S.
Nuclear Regulatory Commission," NUREG/CR-0400 (The Lewis Committee Report),
states that this Review Group is unconvinced of the correctness of the WAMi-1400 conclusion that fires contribute negligibly to the overall risk et nuclear plant operation.
In the Commission's Policv Statement dated January 18, 19/9, "NRC Statement on Risk-Assessment and the 4eactor Safety
'atody Report (WASH-1400) in Light of the Risk-Assessment Review Group Report", the Commission indicated on page 3 that it " accepts, the Review Group Report's conclusion that absoluta 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 af the Review Group coe lusions on accident probabilities, the Commission does not regard as refiable the Reactor Safety Study's numerical estimate of the overall risk of reactor accident."
In summary, it is our conclusion that the operation of the facilif,y, 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 concurrence with the Browns Ferry Special Review Group's conclusions identified abov(,giving due consideration to the Commission Policy Statement, as well as the significant imprevements in fire protection already made at the facility since the Browns Ferg fire.
These include establishment of administrative controlf over com-bustible materials and use of ignition sources, training and staf'ing of a fire brigade, and issuance of technical specifications to provide limiting conditions for operation and surveillance requirements for fire protection systems.
We have determined that the license amendments do 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 amendments involve an action with is insignificant from the standpoint of environmental impact and pursuant to 10 CFR 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 these amendments.
We have concluded, based on the considerations discussed above, that:
(1) because the amendments do not involve a significant increase in the probability 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 cf the public will not be endangered by operation in the proposed nanner, 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.
1084 197 8-2
9.0 CONSULTANTS' REPORT Brookhaven National 1.aboratory, 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 prepara-tion and review of this safety evaluation report.
Their report, " Fire Protection in Operating Nuclear Power Stations, Calvert Cliffs Units 1 and 2 Safety Evaluation Report Review", dated June 5, 1979 is attached herein.
The consultants' recommendations which we have not totally adopted are discussed in Appendix "B".
Our basis for not adopting these recommendations is given therein.
9-1
APPENDIX A CHRONOLOGY In February 1976, the report by the NRC Special Review Group was issued as NUREG-0050, " Recommendations 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 NUREC-0050.
By letter dated May 11, 1976, Baltimore Gas and Electric Company (BG&E) 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 therefore.
By letter of September 30, 1976, Baltimore Gas and Electric Company was requested to provide the results of a fire hazards analysis and proposed Technical Specifications pertaining to fire protection.
BG&E was also provided a copy of Appendix A which includes acceptable alternatives to the guidelines of SRP 9.5.1.
On March 15, 1977, Baltimore Gas and Electric Company provided a submittal responding to our requests of May 11 and September 30, 1976.
A report entitled " Fire Protection Program Evaluation" was included.
By letter of June 24, 1977, Baltimore Gas and Electric Company was requested to propose the Inte'im Technical Specifications for fire protection.
On August 5, 1977, Baltimore Gas and Electric Company submitted its Interim Technical Specifications pertaining to fire protection at the Calvert Cliffs Nuclear Power Plant, Units 1 and 2 facilities.
By letter of August 12, 1977, Baltimore Gas and Electric Company was provided with the document entitled, " Nuclear Plant Fire Protection Functional Respoi.sibilities, Administrative Controls and Quality Assurance,"
as a supplemental guidance in defining BG&E's position on the subjects for Calvert Cliffs, Units 1 and 2.
On December 2, 1977, NRC issued License Amendment Numbers 11 and 26 for Calvert Cliffs facility operating licenses incorporating interim technical specifications for fire protection.
By letter of December 20, 1977, Baltimore Gas and Electric Company presented its reservation to certain modifications to the technical specifications included in the License Amendment Numbers 11 and 26.
1084 199 A-1
By letter of February 6, 1978, Baltimore Gas and Electric Company was provided a copy of the revised document, " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance,"
with the request to compare the fire protection program at the Calvert Cliffs facilitiet for conformance with the guidelines of the document.
On July 11, 1978, Baltimore Gas and Electric Company provided a submittal responding to our request of February 6,1978.
By Letter of August 30,,1978, Baltimore Gas and Electric Company was provided our requests for additional information and staff positions pertaining to fire protection at Calvert Cliffs, Units 1 and 2 facilities.
On September 13, 1978, Baltimore Ges and Electric Company requested the staff's site visit for fire protection which was scheduled for September 18-22, 1978 be postponed because it coincided with the Unit 2 refueling outage.
The visit was subsequently rescheduled for the week of November 27, 1978.
On October 4, 1978, the staff made a 1-day visit to observe the fire protection features inside Calvert Cliffs, Unit 2 containment.
On October 20, 1978, Baltimore Gas and Electric Company provided a sub-mittal responding to the staff's requests for additional information and positions identified in NRC's letter of August 30, 1978.
On November 14, 1978, Baltimore Gas and Electric Company indicated that it will review again NRC guidelines contained in the document provided by NRC's letter of February 6, 1978 and resubmit its responses by December 29, 1978 revising those provided in BG&E's letter of July 11, 1978.
On November 27 - December 1, 1978, the 00R fire protection review team visited the Calvert Cliffs, Units 1 and 2 facilities.
On December 1, 1978, a meeting was held at the Calvert Cliffs facility at which the review team identified the position it is taking as a result of the site observation.
On December 21, 1978, a meeting was held in Bethesda, Maryland to discuss control and instrumentation cables used in the Calvert Cliffs facility.
On December 29, 1978, Baltimore Gas and Electric Company indicated that resubmittal of responses to NRC's letter of February 6, 1978 will be delayed until March 1, 1979.
By interoffice memorandum of January 18, 1979, staff positions on Calvert Cliffs' fire protection, which were provided to the licensee at the meeting on December 1, 1978, were forwarded to ORPM/ DOR with the request for official transmittal to Baltimore Gas and Electric Company.
1084 200 A-2
By interoffice memorandum of February 28, 1979, staff positions P-8 and P-14 were revised per ORPM's request to include detailed discussion of the staff's evaluation of pertinent information submitted to date.
By letter of March 19, 1979, Baltimore Gas and Electric Company was provided the preliminary staff position en Calvert Cliffs fire protection program.
On April 19, 1979, Baltimore Gas and Electric Company provided a submittal responding to NRC letter of March 19, 1979. On March 22, 1979, Baltimore Gas g3gnFiectric Company provided administrative controls and auality assurance infor-On May 15, 1979, the staff issued the draft safety evaluation report which included numerous staff reconmendations concerning the fire protection program at the Calvert Cliffs facilities. A copy of this report was forwarded to Baltimore Gas and Electric Company.
By letters dated August 6,17 and 29,1979, Baltimore Gas and Electric Company provided submittals which included many committments to the staff's recommendations identified in the draft safety evaluation report.
1084 201 A-3
APPENDIX B DISCUSSION OF CONSULTANTS' REPORT Under contract to the Nuclear Regulatory Commission, Brookhaven National Laboratory has provided *he services of fire protection consultants who participated in the eva~uation of the licensee's fire protection program and the preparation of the Safety Evaluation Report (SER).
Their report
" Fire Protection in Operating Nuclear Power Stations - Calvert Cliffs Units 1 and 2 Safety Evaluation Report Review," presents certain recommend-ations and comments.
The consultants' recommendations and comments which are not included in the SER, and our resolution of these matters, is given below.
Valve Supervision It is recommended that the electrical supervision (of certain fire protection system valves) be extended to (include) all sectional valves and valves controlling the supply of water for fire protection.
Staff Respons;e The NRC guidelines on fire water system control valve supervision are given in Appendix A to 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 position.
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 systems, and provide adequate assurance that valves are maintained in the appropriate position.
The licensee's program for valve supervision is consistent with NRC guidelines.
In addition, the plant's Technical Specifications require a monthly check of all valves in the flow path to fire suppression systems, to ensure that each valve is in the correct position.
1084 202
j];j; 3
BROOKHAVEN NATIONAL LABORATORY
[u' 'U ;
ASSOCIATED UNIVERSITIES. INC.
Upton, New York 11973 Department of Nuclear Energy (516) 345-2362 June 5, 1979 Division of Operating Reactors U.S. Nuclear Regulatory Comission Washington, D.C.
20555 Attention: Mr. Robert L. Ferguson Plant Systems Branch
Dear Bob:
Subject:
Fire Protection in Operating Nuclear Power Stations Calvert Cliffs Units 1 and 2 Safety Evaluation Report Review The Safety Evaluation Report, as developed jointly by the NRC staff and Brookhaven National Laboratory, (BNL), adequately reflects the concerns and recommendations of the consultants. Throughout the reevaluation of Calvert Cliffs there has been general agreement between the NRC staff and the BNL consultants.
Based on present data, the proposed fire protection, as set forth in the SER, will give reasonable assurance that the health and safety of the public is not endangered.
The following exception rep-resents a differing engineering point of view that should be evaluated by the NRC staff.
Valve Supervision SER item 4.3.1.3 indicates that, subject to implementation of several modifications, post indicator valves on the underground loop main and sec-tional valves inside the plant will be locked open and checked monthly.
The success of valve position control programs depends en ongoing admin-istrative controls that are subject to human failure. Analysis of data from a Factory Mutual System study indicates that valves which are not electrically supervised are 5 or 6 times more likely to be found closed (when they should be open) than those valves which are electrically super-vised.
It is recommended that electrical supervision be extended to all sectional valves and post indicator valves in the fire protection water system.
The preceding statement is based on a detailed reevaluation of the fire protection program as impicmented by the Baltimore Gas and Electric Company (BG&E) at the Calvert Cliffs Nuclear Power Station.
The analysis covered a review of the fire prevention, detection and suppression capabilities of the plant as interfaced with the nuclear systems requirements.
This was d '2 o
\\
1084 203 7906220.3Jf.
R.L. Ferguson June 5, 1979 accomplished by utilizing a review team concept with members from Brookhaven National Laboratory and the Nuclear Regulatory Commission Division of Opera-ting Reactors staff.
Tne fire protection evaluation for this plant is based on an analysis of documents submitted by BG&E to the NRC and a site visit. The site visit was conducted by Mr. T. Lee and Mr. M. Virgillio, of the NRC, Mr. E. MacDougall of BNL, Mr. J. Klevan of Rolf Jensen and Associates under contract to BNL, and Mr. J. Townley, consultant to BNL.
Mr. Tomley was under contract to Brookhaven National Laboratory to review the manual fire fighting capabilities of the station along with administrative controls.
Milestone Dates 1.
On March 15, 1977, Baltimore Gas & Electric Company provided their
" Fire Protection Program Evaluation" in response to NRC requests of May 11 and September 30, 1976.
2.
By letter of August 30, 1978, Baltimore Gas and Electric Company was provided NRC requests for additional infonnation and staff positions pertaining to fire protection at Calvert Cliffs, Units 1 and 2 facilities.
3.
On September 13, 1978, BG&E requested the Review Team's site visit for fire protection which was scheduled for September 18-22, 1978 be postponed because it coincided with the Unit 2 refueling outage. The visit was subsequently rescheduled for the week of November 27, 1978.
4.
On October 4, 1978, the Review Team made a one-day visit to observe the fire protect'on features inside Calvert Cliffs, Unit 2 containment. The consultant m ober of the Review Team had not previously completed an eight-hour radiation protection course and was unable to enter the con-tainment.
5.
On October 20, 1978, BG&E provided a submittal responding to NRC requests for additional information and positions identified in NRC's letter of August 30, 1978.
6.
On November 27 - December 1, 1978 the Review Team visited the Calvert Cliffs, Units 1 and 2 facilities. On December 1, 1978 a meeting was held at the Calvert Cliffs facility at which the Revie c Team identified the positions it was taking as a result of the site coservation.
7.
On December 21, 1978 a meeting was held in Bethesda, Maryland to discuss control and instrumentation cables used in the Calvert Cliffs facility.
8.
By NRC interoffice memorandum of January 18, 1979, staff positions on Calvert Cliffs' fire prctection, which were provided to the licensee at the meeting on December 1, 1978, were forwarded to ORPM/ DOR with the request for official transmittal to Baltimore Gas and Electric Company.
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R.L. Ferguson June 5, 1979 9.
By NRC interoffice memorandum of February 28' 1979, staff positions P-8 and P-14 were revised per ORPM's request to include detailed discussion of the Review Team's evaluation of pertinent information submitted to date.
- 10. By NRC letter of March 9,1979 BG&E was provided with staff positions which had been discussed on December 1, 1978 during the site visit exit meeting and was requested to respond within 30 days.
- 11. On April 19, 1978 BG&E provided a submittal in response to the NRC letter of Mr.rch 19, 1979.
- 12. On May 15, 1979 the draft Safety Evaluation Report was transmitted from the Chief, Plant Systems Branch to the Chief, Operating Reactors Branch #4.
Review Documents 1.
NRC Branch Technical Position APCSB 9.5-1, Appendix A, dated August 23, 1976.
2.
Calvert Cliffs Nuclear Power Plant Units 1 and 2 Fire Protection Program Evaluation dated March 15, 1977.
3.
Baltimore Gas and Electric Company responses of October 20, 1978 and April 19, 1979 to NRC positions and requests for additional information.
4.
Various engineering drawings and other documents provided infonnally by Baltimore Gas and Electric Company.
5.
May 15, 1979 draft Safety Evaluation Report.
The Calvert Cliffs review has been conducted under the direction of Mr. E. A. MacDougall and myself of Reactor Engineering Analysis Group at BNL.
We have reviewed the analyses submitted by the licensee and have visited the facility to examine the relationship of safety-related components, systems and structures with both combustibles and the associated fire detection and suppression systems. Our review has been limited to the aspects of fire pro-tection related to the protection of the public from the standpoint of radio-logical health and safet". We have not considered aspects of fire protection associated with life saf 5 of onsite personnel and with property protection, unless they impact the hs Ith and safety of the public due to the release of radioactive material. The proposed modifications represent a significant in-crease in the level of protection against serious fire associated hazards.
Sincerely yours,
?fk
- 9' % 7.
Robert E. Hall, Group Leader Reactor Engineering Analysis EAM:sd 1084 205
q 01 mt Un u nil STAFFPOSITION l
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SAFE SHUTDOWN CAPABILITY Staff Concern During the staff's evaluation of fire protection progrars at operating plants, one or more specific plant areas may be identified in which the staff does not have adequate assurance that a postulated fire will not damage both redundant divisions of shutdown systems.
This lack of assurance in safe shutdown capability has resulted from one or both of the following situatiens:
Case A: The licensee has not adequately identified the systems and components required for safe shutdown and their location in specific fire areas.
Case B: The licensee has not demonstrated that the fire protection for specific plant areas wi!1 prevent danage to both redundant divisions of safe shutdown components identified in these areas.
For~ tase' A,'the staff hE req ~uirediat Tn' i'dequate safe Ttrurdown analysis be performed.
This evaluation includes the identification of the systers required for safe shutdown and the location of the system componente
'n the plant.
Where it is determined by this evaluation.that mts shutdown components of both redundant divisions are located in the same fire area, the licensee is required to demonstrate that a postulated fire will not damage both divisions or provide alternate shutdown capability as in Case B.
For Case B, the staff may have required that an alternate shutdown capability be provided with is independent of the area of concern or the licensee may have proposed such a capability in lieu of certain additional fire protection modifications in the area.
The specific modifications associated with the area of concern along with other systems and equipment already independent of the area form the a ! ternate shutdown capability.
For each plant, the modifications needed and the combinations of systens which provide the shutdown functions may be unique for each critical area; however, the sh0tdown functions provided should maintain plant parameters within the bounds of the limiting safety consequences deemed acceptable for the design basis event.
Staff Position Safe shutdown capability should be demonstrattd (Case A) or alternate shutdown capability provided (Case B) in accordance with the guidelines provided below:
- 1. Desien Basis Event The design basis event for considering the need for alternate shutdcwn is a postulated fire in a specific fire area containing redundant safe shutdown cables /ecuipment in close proximity where it has been determined that fire protection means cannot assure that safe shutcown capability will be preserved.
Two cases should be censidered:
(1) offsite power is available; and (2) offsite power is not available.
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e
. 2. Limitinc Safety Consecuences and Recuired Shutdown Functions 2.1 No fission product boundary integrity shall be affected:
~
a.
No fuel clad damage; b.
No rupture of any primary coolant boundary; c.
No rupture of the contrinment boundary.
2.2 The re. actor coolant system process variables shall be within those pred1cted for a loss of normal ac power.
2.3 The alternate shutdown capability shall be able to achieve and maintain subcritical conditions in the reactor, maintain reactor coolant inventory, achieve and mair.tain hot standby
- conditions (hot shutdown
- for a EWR) for an extended period of time, achieve cold shutdown
- conditions within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and maintain cold shutdown conditions thereafter.
As defined in the Standard Technical Specifications.
- 3. performance Goals 3.1 The reactivity control function shall be capable of achieving and maintaining cold shutdown reactivity conditions.
3.2 The reactor coolant makeup function shall be capable of maintaining the reactor coplant level above the top of the core for BWR's and in the pressurizer for PWR's.
3.3 The reactor heat removal function shall be capable of achieving and maintaining decay heat removal.
3.4 The process monitoring function shall be capable of providing direct readings of the process variables necessary to perform and control the above functions.
3.5 The supporting function shall be capable of providing th'e process cooling, lubrication, etc. necessary to permit the operation of the equipment used for safe shutdown by the systems identified in 3.1 - 3.4.
3.6 The equipment and systens used to achieve and maintain hot standby conditions (hot shutdown for a BWR) should be (1) free of fire damage; (2) capable of maintaining such conditions for an extended tire period longer than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> if the equipment required to achieve and maintain cold shutdown is not available due to fire damage; and (3) capable of being powered by an onsite emergency power system.
3.7 The equipment and systers used to achieve and maintain cold shutdown conditions should be either free of fire damage or 1nQA 9n7 the fire damage to such systems should be limited such iUU7 4UI that recairs can be made and cold shutdown conditions achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Equipment and systems used prior to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after the fire should be capable of being powered by an onsite emergency power system; those used after 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> may be powered by
P00lfDENAL
. offsite power.
3.8 These systems need not be designed to (1) seismic category I criteria; (2) single failure criteria; or (3) cope with other plant accidents such as pipe breaks or stuck valvas
( Appendix A BTP 9.5-1), except those portions of these systems which interface with or impact existing safe.ty systems.
- 4. PWR Eouipment Generally Necessary For Hot Standby (1) Reactivity Control Reactor trip capability (scram).
Boration capabili ty e.g.,
charging pump, makeup pump or high pressura injection pump taking suction from concentrated borated water supplies.
and letdown system if required.
(2) Reactor Coolant Makeuo Reactor coolant makeup capability, e.g., charging pumps or the high pressure injection pumps.
Power operated relief valves may be required to reduce pressure to allow use of the high pressure injection pumps.
(3) Reactor Coolant System Pressure Control Reactor pressure centrol capability, e.g., charging pumps or pressurizer heaters and use of the letdown systems if required.
(4)
Deca ~y Heat Removal Decay heat removal capability, e.g., power operated relief valves.(steam generator) or safety relief valves for heat removal with a water supply and emergency or auxiliary feedwater pumps for makeup to the steam generator.
Service water or other pumps may be required to provide water for auxiliary feed pump suction if the condensate storage tank capacity is not adequate for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
(5) Process horitorina Instrumentation Process monitcring capability e.g., pressurizer pressure and level, steam generator level.
(6) Succort.
The equipment required to support operation vi the above described shutdown equipment e.g., compcnent cooling warte service water, etc. and onsite power scurces ( AC, DC) with their associated electrical distribution system.
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3dOROnly
-4
- 5. PWR Ecuipment Generally Necessary For Cold Shutdown *
(1) Reactor Coolant System Pressure Reduction to Residual Heat Removal System RHR Ca caol li ty Reactor coolant system pressure reduction by cooldown using steam generator power operated relief valves or atmospheric dump valves.
(2)
Decry Heat Removal Decay heat' reraoval capability e.g., residual heat removal system, component cooling water system and service water
~
system to removal heat and maintain cold shutdown.
(3) Sueoort Support capability e.g., onsite power sources ( AC & DC) er offsite after 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and the associated electrical distribution system to supply the above equipment.
Equipment necessary in addition to that already provided to maintain hot standby.
- 6. BWR Ecuipmnt Gt;nafal,1y Necessary For Hot Shutdown (1)
Reacti, h reatrol Reactor trip capability (scram).
(2) Reactor Coolant Makeuo Reactor coolant inventory makeup capability e.g., reactor core isolaticn cooling system (RCIC) or the high pressure coolant injection system (HPCI).
(3) Reactor Pressure Control and Decay Heat Removal Depressurization system valves or safety relief valves for dump to the suppressicn pool. The residual heat removal system in steam condensing mode, and service water system may also be used for heat removal to the ultimate heat sink.
(4) Suoeression Pool Coolino Residual heat removal system (in suppression pool cooling mode) service water system to maintain het shutdow;..
(5)
Process Monitorino Process monitoring capability e.g., reactor vessel level and pressure and suppression pool temperature.
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P00RDH EL (6) Succort Support capability e.g., onsite power source (AC & DC) and their associated distribution systems to provide for the shutdown equipment.
- 7. BWR Ecuiement Generally Necessary For Cold Shutdown
- At this point the equipment necessary for hot shutdown has reduced the primary system pressure and temperature to where the RHR system may be placed in service in RHR cooling mode.
(1) Decay Heat Removal Residual heat removal system in the RHR c:oling node, service water system.
(2) Succort Onsite sources (AC & DC) or offsite af ter 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and their associated distribution systers to provide for shutdown equipment.
Equipment provided in addition to that for achieving hot shutdown.
- 8. Information Recuired For Staff Review Descriotion of the systems' or portions thereof*used to (a) provide the shutdown capability and modifications required
' to achieve the alternate shutdown capability if required.
Syst'em design by drawings which show nomal and alt (b) that viring which is in the area and the wiring which is out of the area that required the alternate system.
Demonstrate that changes to safety systems will not (c)
(e.g., new isolation switches (legrade safety systems.and control switches should meet design criteria standards in FSAR for electrical equipment in the system that the switch is to be installed; cabinets that the switches are to be mounted in should also meet the same criteria (FSAR) as other safety related cabinets and panels; to avoid inadvertent isolation from the cen in the control room if in the " local" or " isolated" position; periodic checks should be made to verify switch is switch or other new device should not be a source for a single failure to cause loss of reduncar.t safety systems).
that wiring, including cower scurces for the Demonstrate c;ntrol circuit and equi: ment Operation for the alternate (c) shutdown metnod, is incepenJent of equipr. ant wiring in the area to be avoided.
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100R ORGINAL 6-(e)
Demonstrate that alternate shutdown power sources, including all breakers, have isolation devices on control circuits that are routed through the arca to be avoided, even if the breake r is to be operated manually.
(f)
Demonstrate that licensee procedure (s) have been developed which describe the tasks to be performed to effect the shutdown me thod.
A sumary of these procedures should be reviewed by the staff.
(9)
Demonstrate that spare fuses are available'for control circuits shere these fuses,may be required in supplying power to control circuits used for the shutdown method and may be blown by the effects of a :able spreading room fire. The spare fuses should be locat.d convenient to the existing fuses.
The shutdown proce'.ure should inform the operator to check these fuses.
(h)
Demoastrate that the manpower required to perform the shutdown functions using the procedures of (f) as well as to provide fire brigade members to fight the fire is available as required by the fire brigade technical specifications.
(i) Demonstrate that adequate acceptance tests kre perfortned.
These should verify that: equipment operates from the local control station when the transfer or isolation switch is placed in the " local" Rosition and that the equipment cannot be operated from the control room; and that equip-ment operates from the control room but cannot be operated at the local control station when the transfer or isolation switch is in the " remote" position.
(j) Technical Specifications of the surveillance requirements and limiting conditions for operation for that equipment not a'1 ready covered by existing Tech. Specs.
For example, if new isolation and control switches are added to a service water system, the existing Tech. Spec. surveillance require-ments on the service water system should add a statement similar to the following:
"Every third pump test should also verify that the pump starts from the alternate shutdown station after moving all service water system isolation switches to the local control position."
(k) Demonstrate that the systems available are adequate to perform the necessary shutdown functions.
The functions required shculd be based on previous analyses, if possible (e.g.,
in the FSAR), such as a loss of normal a.c. power or shutdown on a Group I isolation (BWR). The equipment recuired for the alternate capability should be the same or equivalent to tnat relied on in the above analysis.
1084 211
P00ROHGlMa
~
7-(1)
Demonstrate that repair procedures for cold shutdown systems are developed and material for repairs is maintained en site.
o O
e e
1084 212