ML19210A352
| ML19210A352 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/14/1978 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19210A334 | List: |
| References | |
| NUDOCS 7910290583 | |
| Download: ML19210A352 (62) | |
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FIRE PROTECTION SAFETY EVALUATION REPORT 1
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i BY THE 1
0FFICE OF NUCLEAR REACTOR REGULATION I
l U.S. NUCLEAR REGULATORY C0f4 MISSION l
IN THE MATTER OF f
METROPOLITAN EDISON COMPANY, j
JERSEY CENTRAL PCWER AND LIGHT COMPANY.
I AND PENNSYLVANIA ELECTRIC CCMPANY THRE5 MILE ISLAND NUCLEAR STATION, UNIT NO.1 DOCKET NO. 50-289 1-488.221
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291029 0D 583
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TABLE OF CONTENTS
,.PAGE 1.0 INTR 000CTION.....................................................
1-1
- 2. 0 FIRF PROTECTION GUIDELINES.......................................
2-1 2.1 General Design Criterion 3
" Fire Protection"..............
2-1 2.2 Supplementary Guidance......................................
.f-l 3.0
SUMMARY
OF MODIFICATIONS AND INCOMPLETE ITEMS....................
3-1 3.1 Modifications...........................................,...
3-1 3.1.1 Fire 0etect' ors....................................
3-1 3.1.2 Manual Hose Stations..............................
3-1 3.1.3 Automatic Water Spray System......................
3-1 3.1.4 Automatic Sprinkler Systems or Coating of Electrical Cables................................
3-1 3.1.5 Halon Extinguishing System in Computer Room.......
3-2 3.1.6 Curbs in Reactor Building.........................
3-2 3.1.7 Fire Dampers......................................
3-2 3.1.8
' Fire Doors........................................
3-2 3.1.9 Fire-Barrier Penetrations.'........................
3-2 3.1.10
. Thermal Insulation on Valves............
3-2 3.1.11
- Fire Barriers at Reactor Building Emergency Cooling Valves........................
3-2 3.1.12 Fire Wa'ur Valve Sea 1s............................
.3-2 3.1.13 Reactor Coolant Pump Lube Oil Collection System...............................
3-2 3.1.14 Separation of Control Roem........................
3-3 3.1.15 Electrical Cable Penetration Seals................
3-3 3.1.16 Battery Room Ventilation Air Flow Monitor.........
3-3 3.1.17 Fire Fighting Plans...............................
3-3 3.1.18 Smoking...........................................
3-3 3.1.19 Control of Combustibles...........................
3-3 3.1.20 Backup Manual Hose Coverage.......................
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3.1.21 Alternate Shutdown Capability.....................
-3 3.1.22 Brigade Training..................................
.-4 3.1.23 Communication Cable Penetrations..................
3-4 3.2 Incomplete Items......
3-4 3.2.1 ;
Protection of Emergency Feedwater Pumps...........
3-4 3.2.2 Cable Separation..................................
3-4
- 3. 2. 7 E f fects o f Wa te r S p ray............................
3-4 3.2.4 Adequacy of the Cetector System Design............
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.i TABLE OF CONTENTS (Continued)
PAGE 4
i 3.2.5 Fire Protection Inside the Reactor Buf1 ding.......
3-5 J
3.2.6 Unlabeled Fire Doors..............................
3-5 1
3.2.7 Alarm Circuit Supervision.........................
3-5 3.2.8 Remote Shutdown Stations..........................
3-5 3.2.9 Transient Comoustibles Study......................
3-5 3.2.10 Control Building HVAC Loss........................
3-5 f
3.2.11 Interior Hose Station Standpipes Less Than Four Inch Diameter...................................
3-5 3.2.12 Emerges.cy Lighting................................
3-6 3.2.13 Protection of Relay Room (Cable Spreading Room)...
3-6 3.2.14 Fire Door Supervision.............................
3-6 3.2.15 Engineered Safeguards Cabinets....................
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1 4.0 EVA LUATION O F P LANT F EATURES.....................................
4-1 l
1 4.1 Safe Shutdown Systems.......................................
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4.2 Fire Detection and Signaling Systems........................
4-2 3,. 3 Fire Control Systems........................................
4-3 4.3.1 Wa t e r Sy s t e m s......................................
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4.3.1.1 Water Supply............................
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4.3.1.2 Fire Pumps..............................
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4.3.1.3 Fire Water Piping System................
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4.3.1.4 Interior Hose Stations..................
4-5 4.3.1.5 Automatic Water Suppression Systems.....
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'4.3.1.6 Effects of Wcter Spray..................
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4.3.2 Gas Fire Suppression Systems......................
4-7 4.3.3 Portable Fire Extinguishers.......................
4-7 4.4 Ventilation Systems and Breathing Equipment.................
4-7 4.4.1 Smoke Removal.....................................
4-7 4.4.2 Filters...........................................
4-8 4.4.3 Breathing Equipment.................
4-8 4
4.4.4 Battery Room Ventilation..........................
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- 4. 5 Floor 0 rains................................................
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4.6 Lighting System.............................................
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4.7 Communications..............................................
4-9 4.8 El e ctri ca l Cab 1 e s...........................................
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4.9 Fi re Barri e r Penetrations...................................
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TABLE OF CONTENTS (Continued)
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PAGE 4-10 4.9.1 Doorways.........................................
4.9.2 Ventilation Duct Penetrations.....................
4-11 4.9.3 Electrical Cable Penetrations.....................
4-11 4-11 4.9.4 Piping Penetrations...............................
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4-12 4.10 Separati on Cri te ri a.........................................
4-12 4.11 Fire Barriers...............................................
4-13 4.12 Access and Egress...........................................
4-13 4.13 Toxic and Corrosive Combustion Products.....................
4-13 4.14 Nonsafety-Related Areas.....................................
4-13 4.15 Instrument Air..............................................
5-1 5.0 EVALUATION OF SPECIFIC PLANT AREAS...............................
4 5-1 5.1 Reactor Building.....'....................-
5.2 Decay Heat Removal Pits - Auxiliary Building, 5-3 Elevation 261 Feet........................................
5.3 Fuel and Auxiliary Building Basement -
Elevations 271 Feet and 281 Feet..........................
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- 5. 4 Fuel and Auxiliary Building, Ground Floor -
5-6 Elevation 305 Feet........................................
5.5 Intermediate Building, Basement Floor -
5-7 Elevation 295 Feet........................................
5.6 Remainder of Intermediate Building -
Elevations 305 Feet, 322 feet and 355 Feet................
5-8 5.7 Control Building Basement - Elevation 306 Feet..............
5-9 5.8 480 Volt Switchgear Room - Control Building, 5-10 Elevation 322 Feet........................................
5.9 Station Batteries and Accessories -
Control Building, Elevation 322 Feet......................
5-11 5.10 4160 Volt Switchgear - Control Building, Elevation 338 Feet, 6 Inches..............................
5-12 5.11 Cable Spreading Room - Control Building, Elevati on 338 Feet, 6 Inches.............................
5-13 5.12 Control Room - Control Building, Elevation 355 Feet.........
5-14 5.13 Control Building Heating, Ventilation and Air Conditioning Equipment Area -
Control Euil di ng, El evati on 380 Feet......................
5-15 5-16 5.14 Intake Screen and Pump House...............
5-17 5.15 Diesel Generator Rooms......................................
5.16 Fuel Storage Areas - Fuel Handling Building, Elevations 329 Feet, 331 Feet and 348 Feet................
5-18 5.17 Zone Between Fuel Pool and Control Building, Elevations 322 Feet and 380 Feet..........................
5-19 5-19 5.18 Turbine Sui 1 ding............................................
5-20 5.19 Air Intake Tunne1...........................................
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TABLE OF CONTENTS (Continued)
PAGE 5.20 Yard Area...................................................
5-2) 5.21 Air Conditioning Equipment Roca - Fuel Handling Building, Elevation 285 Feet..............................
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i 6.0 ADMINISTRATIVE CONTR0LS..........................................
6-1 7.0 TECHNICAL SPECIFICATIONS,.........................................
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8.0 CONCLUSION
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9.0 CONSULTANTS' REP 0RT..............................................
9-1 APPENDIX A CHRON0 LOGY.............................................
A-1 4
APPENDIX 8 DISCUSSION OF CONSULTANTS' REP 0RT......................
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1.0 INTR 000CTION Following a fire at the Brown's Ferry Nuclear Station in March 1975, the Nuclear Regulatory Commission initiated an evaluation of the r.eed for improving the fire protection programs at all licensed nuclear power 1
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 functions. To implement the report's recommendations, the NRC initiated a program for reevaluation of the fire protection programs at all licensed nuclear power stations and for a comprehensive 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,"
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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," May 12, 1977.
" Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance," June 14, 1977.
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 "As used nere and in subsequent portions of this evaluation, the term " licensee" refers specifically to Metropolitan Edison Company which acts as operating and management agent. for the group of licensees consisting of Metropolitan Edison Company, Jersey Central Power and Light Company and the Pennsylvania Electric Company.
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structures with both combustibles and the associated fire detection and suppression systems.
Our review has been limited to the aspects of fire protection within the NRC's jurisdiction, i.e., those aspects related to the protection of the public health and safety.
We have not considered aspects of the fire protection associated with life safety of onsite personnel and with property protection, unless they impact the health and safety of the public due to the release of radioactive material.
This report summarizes the result of our evaluation of the fire protection program at Metropolitan Edison Ccmpany's Three Mile Island Nuclear Station, Unit 1.
The chronology of our evaluation is summarized in Appencix A of this, report.
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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:
1" Structures,' systems, and components important to safety shall be designed and located to minimize, consistent with other safety require-ments, the probability and effect of fires and explosions.
" Noncombustible and heat resistant materials shall be used wherever i
practical throughout the unit, particularly in locations such as the containment and the control room.
" Fire detection and protection systems of appropriate capacity and capability shall be provided and designed to minimize the adverse effects of fires on structures, systems, and components important to safety.
Fire fighting systems shall be designed to assure that their rupture or inadvertent operation does not significantly impair the safety capability of these structures, systems, and components."
2.2 Suculementary Guida: _e Guidance on the implementation of General Design Criterion 3 for existing nuclear power plants nas been provided by the NRC staff in " Appendix A" of Branch Technical Position 9.5-1, " Guidelines for Fire Protection for Nuclear Power Plants" (BTP 9.5-1).
' Appendix A to STP 9.5-1 provides for a comprehensive program assuring a substantial level of fire protection, deemed to satisfy General' Design Criterion 3.
. The overall objectives of the fire protection program embodied in BTP 9.5-1, Appendix A are to:
(1) Reduce the likelihood of occurrence of firos; i
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(2) Promptly detect and extinguish fires if they occur; (3) Maintain the capability to safely shut down the plant if fires occur; agd i
(4) Prevent the release of a significant amount of radioactive material if fires occur.
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l We have used the guidance of Appendix A, as appropriate in our review.
We have evaluated alternatives proposed by the ifcensee to various specific aspects of Appendix A using the overall objectives outlined above to assure that these objectives are met for the actual relationship of combus-j tibles, safety-related equipment and fire protection features of the facility.
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3.0
SUMMARY
OF. MODIFICATIONS AND INCCMPLETE ITEMS 3.1 Modifications The licensee plans to make certain plant modifications to improve the fire i
protection program as a result of both his and the staff's evaluatier.s.
Such proposed modifications are summarized below.
The implementation 1
I schedule for these modifications is in Table 3.1.
The licensee has agreed to this schedule.
The sections of this report which discuss the modifica-
"2 tions are noted in parentheses.
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.
The balance of other modifications has been described in an acceptable level of detail.
3.1.1 Fire Detectors * (4.2)
Fire detectors will be installed on all levels of the reactor building, in several areas of the auxiliary building, in several areas of the interme-diate building, in certain areas in the fuel handling building, and in safety-related control cabinets in the control room.
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3.1.2 Manual Hose Stations (4.3.1.4)
Manual hose stations will be installed in the heat exchanger vault of the auxiliary building and on all levels of the zone in the fuel handling building between the fuel pool and the control building.
In addition, a hose stretch test will be performed and additional modification proposed as necessary to ensure that all points in safety-related areas, and other areas which contain major fire hazards, can be reached by at least one effective hose stream.
3.1.3 Automatic Water Soray Svstem*(4.3.1.5)
An automatic water spray system will be installed in the pipe penetration area of the auxiliary building.
i 3.1.4 Autcmatic Snrinkler Systems or Coatinc of Electrical Cables * (4.3.1.5)
I Automat'e sprinkler systems or applicaticn of a flame retardant coating j
will te provided for protection of electrical cables cons'tituting a I
significant fire hazard on elevation 281 feet of the fuel handling building.
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j 3.1.5 Halon Extincuishinc Svstem in Ccmouter Room (4.3.2)
An automatic Halon 1301 extinguishing system will be installed in the 1
subfloor of the computer room on elevaticn 355 feet of the control build-ing, adjacent to the control. room.
P 3.1.6 Curbs in Reactor Buildina (5.1) i 1
Curbs will be installed inside the secondary shield at elevation 281 feet of the reactor building to reduce the possible spread of oil frcm the 1
j reactor coolant pu_mp motor lubrication systems.
i 3.1.7 Fire Damoers (4.9.2)
,,1 Fire dampers will be installed in heating, ventilating and air condition-ing ducts penetrating fire barriers in several areas throughout the plant.
3.1.8 Fire Doors (4.9.1)
Class A labelled fire doors will be installed, and existing unlabeled doors in various areas of the plant will be verified to have the correct i
rating or will be replaced with labeled doors.
3.1.9 Fire Barrier Penetrations * (4.9.3, 4.9.4)
Various types of fire barrier penetrations, including cable and pipe 1
penetrations and building construction joints, will be sealed in various 1
areas of the plant to provide appropriate fire resistance.
j 3.1.10 Thermal Insulation on Valves *(5.1) k Thermal insulation will be installed on decay heat valves in the reactor building.
I 3.1.11 Fire Barriers at Reactor Buildinc Emercency Coolina Valves *(5.5)
Additional fire barriers will be installed 'to reduce the possibility of f
loss of function of the reactor building emergency cooling valves in the
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event of a fire in the valve gallery anc penetration room in the interme-diate building.
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3.1.12 Fire Water Valve Seals (4.3.1.3) i The existing plastic seals on the fire water valves will be replaced with
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tamper proof seals.
j 3.1.13 Reactor Coolant Pumo Lube Oil Collection System * (5.1)
The exfsting lube oil splash guard on the reactor coolant pumo will be i
codified to enclose the pumo motor and to drain the collected oil in a drain tank located inside the secondary shield.
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.O 3.1.14 Seoaration of Control Room (5.12)
Penetrations through fire barriers enclosing the control r em will be protected to provide an adequate separation for the control room from the remainder of i
the plant. All paper, tapes and other combustible materials in the computer 1
office area will be removed.
3.1.15 Electrical Cable Penetration Seals (4.9) 1 I
Existing electricai cable penetration seals will be upgraded to' conform f
with a design having a demonstrated three-hour fire resistance rating.
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certain areas, additional seals will be provided which conform to this same design.
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.3.1.16 Battery Room Ventilation Air Flow Monitor (5.9)
A ventilation air flow monitor will be installed in each battery room to
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alarm and annunciate in the control room the loss of air flow to either battery room.
3.1.17 Fire Fichtino Plans (6.5)
Fire fighting plans identifying strategies for fighting fire in all safety-related areas will be developed and implemented.
3.1.18 Smoking (6.4)
Administrative controls to prohibit ' smoking in safety-related areas and in ot:1er plant areas containing major fire hazards will be implemented.
3.1.19 Control of Combustibles (6.3) l Unnecessary combustibles in six plant areas will be removed.
Administrative measures will be implemented to control introduction and storage of transient combustibles in various plant areas.
1 3.1.20 Backuo Manual Hose Coverace (4.3.1.3) l Necessary modifications will be provided to secure a backup manual hose coverage for those locations where the isolation of a single section of fire water piping could impair the availability of both automatic water suppression and the manual hose station (s) protecting the same area con-taining or exposing safety-related equipment.
,1 3.1.21 Alternate Shutdown Cacability* (5.11)
An alternate shutdown capability independent of cables and equipment in the cable spreading room (relay room) will be provided.
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3.1.22 Bricade Training (6.2)
The licensee will modify the fire brigade training program to provide classroom instruction quarterly and to repeat the entire program within each two year period. The scope of the classroom train ng instruction will be expanded to include a detailed review of the plant's fire fighting procedures, prefire strategies, procedure changes, and plant modification relating to manual fire fighting.
3.1.23 Communication Cable Penetrations (4.7)
An asbestos board barrier will be installed to protect redundant communi-cation cables at the containment penetration from fire hazards in the "2
nonsafety-related cable tray below.
3.2 Incomolete Items The licensee has committed to take action on incomplete items as noted below.
The staff's review of the licensees response to these items and any further proposed changes to the fire protection program will be addressed in a supplement to this report.
The schedule for the completion of the licensee action on these incomplete items is given in Table 3.2.
The sections of this report which discuss these items are noted in parentheses.
3.2.1 Protection of Emercency Feedwater Pumos (5.5)
The licensee will. analyze the fire hazards in the emergency feedwater pump area and propose additional modification as necessary to preserve the safe shutdown capability.
3.2.2 Cable Separation (4.10)
The licensee will perform a study and/or testing to verify the effective-ness of the asbestos board barrier design in preventing (1) the spread of a tray fire to a nearby tray (s) with or without the presence of the interposing nonsafety-related cables, and (2) the damage to redundant cables from a possible exposure fire. Where the stucy indicates that the present design is inadequate, corrective modification will be proposed.
3.2.3 Effects of Water Soray (4.3.1.6)
The licensae will analyze the effect of water spray to ensure that both divisions of safety-related equipment will not be incapacitated by rupture or inadvertent operation of the fire water system, or the application of fire hoses. Additional mooif' cation (s) will be provided as necessary.
3.2.4
_Adecuacy of the Detector System Desian (4.2)
Thelicebseewillperformastudyand/ortestingtoverifytheadequacyof the existing and the proposed detector placement and distribution.
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3.2.5 Fire Protection Inside the Reactor Building (5.1.5)
The licensee will submit for our review, a study of the feasibility of providing manual hose stations inside the reactor building and proposed modifications.
3.2.6 Unlabeled Fire Doors (4.9.1)
The licensee is studying the feasibility of establishing the adequacy of the fire resistance of unlabeled fire door and frame assemblies.
If the adequacy of the fire resistance of such assemblies cannot be established, they will be replaced by properly rated fire door assemblies.
t 3.2.7 Alarm Circuit Suoervision (4.2)
The licensee will perform a study to ensure that the signal initiating and alarm circuits for all fire detection and suppression systens are super-vised to detect circu;it breaks, ground faults, and power supply failure, and to annunciate in the control room.
Additional nodification(s) will be proposed if the study determines the need for such.
3,2.8 Remote Shutdown Stations (4.1)
The licensee will perform an analysis to determine whether a single fire at any location could cause loss of both'iocal control and control from the control room of any safe shutdown systems.
If the analysis indicates such loss could occur, appropriate corrective modifications will be provided.
3.2.9 Transient Combustibles Study (4.10)
The licensee will conduct a study to determine the effects of transporting transient combustibles through zones that were not analyzed for their presence.
Corrective modifications will be provided as needed.
3.2.10 Control Buildino HVAC Loss (5.13)
The licensee will provide a study cf the possible effects of a fire on the operability of the normal and emergency heating, ventilating and air conditioning system used in the Centrol Building and the effects of such loss of operability on the capaoility to safely shutdewn the reactor.
If it is determined that a fire could adversely affect the capability for safe shutdown, the licensee will propose corrective measures.
3.2.11 Interior Hose Station Standoices Less Than Four Inch Diameter The licensee has committed to demonstrate by July 1, 1979, using tests or calculations, that all interior hose stations served by standpipes that are less than four inches in diameter (nominal pipe size) are capaole of delivering a minimum water flow of 100 gpm at a residual pressure of at least 65 psig at the outlet of the hose station.
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n, 3.2.12 Emeroency Lichting The licensee has committed to evaluate the safety-related areas of the facility to assure that adequate emergency lighting has been provided to safely shutdown the plant and to fight fires in safety-related areas, and to submit the results of the evaluation for staff review.
3.2.13 Protection of Relay Room (Cable Screadina Room) (5.1)
The licensee will identify for the staff those areas in the Relay Room where he proposes.to provide a manually operated fixed water suppression system or will coat the electrical cables with an appropriate flame retardant coating.
We will address the acceptability of the licensee's proposal upon completion of our review of his submittal.
3.2.14 Fire Door Sucervision (4.9.1)
The licensee will provide to the staff his preposal with regard to (1) fire doors which are electrically locked and alarmed, (2) fire doors which are mechanically locked closed when not in use, and (3) fire doors which are neither locked nor alarmed but which are kept closed when not in use.
We will address the acceptability of the licensee's proposal upon completion of our review of his submittal.
3.2.15 Engineered Safecuards Cabinets (5.10)
-~ The licensee will perform an evaluation to determine if safe shutdown of the reactor can be accomplished assuming loss of both Engineered Safeguards Actuation cabinets in Fire Zone CS-3C.
If the evaluation indicates that the capability for safe shutdown could be adversely affected, the licensee will propose additional fire protection measures.
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TABLE 3.1 IMPLEMEllTATI0ff DATE FOR MODIFIC",TIONS ITEMS DATE 3.1.1 Fire Detectors EOR-80*
3.1.2 Manual Hose Stations
' g EOR-80
< 3.1.3 Automatic Water Spray System E0R-80 3.1.4 Automatic Sprinkler Systems or Coating of Electrical Cables Chen**
3.1.5 Halon Extinguishing System in Computer Room EOR-80 3.1.6 Curbs in Reactor Building EOR-80 E0R-80 3.1.7 Fire Dampers 3.1.8 Fire Doors Open**
3.1.9 Fire Barrier Penetrations E0R-79*
3.1.10 Thermal Insulation on Valves E0R-80 3.1.11 Fire Barriers at Reactor Building Emergency Cooling Valves Ocen**
3.1.12 Fire Water Valve Seals EOR-79 3.1.13 Reactor Coolant Pump Lube 0il Collection System E0R-79 3.1.14 Separation of Computer Room from Contro.1 Room EOR-79 3.1.15 Elec.trical Cable Penetration Seals
_E0R-79 3.1.16 Battery Room Ventilation Air Flow Monitor 5-31-79 3.1.17 Fira Fighting Plans 7-01-79 3.1.18 Smoking 10-30-78 3.1.19 Control of. Combustibles 9-30-78 3.i.20 Backup Manual Hose Coverage EOR-80 3.1.21 Alternate Shutdown Capability Open**
3.1.22 Brigade Training 7.-01-79 3.1.23 Communication Cable Penetrations E0R-80
- EOR-80: By end of refueling cutage in 1980 EOR-79: By end of refueling outage in 1979
- The licensee has committed to provide the implementation date for this modification by September 29, 1978. We will review the acceptability of the date upcn receipt from the licensee and specify an acceptable date in a supplement to this report.
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TABLE 3.2 COMPLETION DATE FOR INCOMPLETE ITEMS ITEMS
. DATE 3.2.1 Protection of Emergency Feedwater Pumps 12-31-78 3.2.2 Cable Separation 7-15-79 3.2.3 Effects of Water Spray 12r31-78 3.2.4 Adequacy of the Detector System Design 7-15-79 3.2.5 Fire Protection Inside the Reactor Building 12-31-78 3.2.6 Unlabeled Fire Doors 9-15-78 3.2.7 Alarr #3ircuit Supervision 12 78 3.2.8 Remote Shutdown Stations 12-31-78 3.2.9 Transient Combustible Study 10-31-78 3.2.10 Control Building HVAC Loss 12-31-78 3.2.11 Interior Hose Station Standpipes Less Than Four Inch Diameter 7-01-79 3.2.12 Emergency Lighting 12-31-78 3.2.13 Protection of Relay Room (Cable Spreading Room) 10-31-78 3.2.14 Fire Door Supervision 10-31-78 3.2.15 Engineered Safeguards Cabinets 9-30-78 1/88 23.7 3-8
s 4.0 EVALUATI0fl 0F 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 system auxiliaries and major components required to fulfill these require-ments are as follows:
i (1) Reactor Coolant System Inventory Control Following a reactor shutdown or trip, reactor coolant system water inventory is maintained by operation of makeup and purification 1
pumps.
Primary coolant letdown is isolated and the makeur pumps are cycled to maintain pressurizer level which otherwise would decrease due to coolant contraction during cooldown.
(2).<0ecay Heat Removal Following a normal plant shutdown, a steam bypass control system bypasses steam to the condenser to provide cooldown.
If the steam bypass control system is not available, remotely controlled relief i
valves on a main steam line will provide cooldown by relieving main steam to the atmosphere. This relief valve is backed up by the code i
safety valves on eacn steam generator which can be manually operated.
The steam relief facility has adecuate redundancy.
For decay heat removal immediately following the reactor trip, it is necessary only to maintain the cor.brol on one steam generator.
For the continued use of the steam generators for decay heat removal, it is necessary to pravide a source of water, a means of delivering that water and instrumentatiun for pressure and level indication.
Feedwater may ee supplied by a motor-driven or a steam turbine-driven auxiliary feedwater pump.
0 For a cooldown of the reactor coolant below 250 F, the decay heat removal system is used.
The system utilizes tne decay heat removal pumps to circulate the reactor coolant througn the cecay heat removai coolers where the decay hece is transferred to the decay heat closed cycle cooling water system and eventually rejected to Susquenanna River via the decay heat river water system.
1488 2l28 1 W
(3) Reactivity Control The rod control system is of fail-safe design.
Faulting in the system circuits trip the reactor.
Following the reactor trip, soluole poison may be added to the primary system to assure subcriticality.
This is accomplished by using makeup and purification pumps.to inject borated water frcm the borated water storage tank into the reactor coolant system.
(4) Monitor Reactor Neutron Levci 1 ource range neutron detectors are required to monitor core' reactivity S
during the shutdown condition.
3 (5) Airxiliaries Auxiliaries required for safe shutdown include the nuclear services closed cycle cooling water system, the nuclear services river water system, the reactor building emergency cooling system, and appropriate instrumentation and power L : ply.
Multiple cutside sources of pcwer are available to the plant for both normal operation and shutdcwn functions.
Normal operations may utilize either outside or unit generatac power. The oower supplies to redundant safety-related equipment are electrically separated.
Emergency. diesel generators will supply
-power for shutdcwn operation wnen offsite power or unit generated power. is not available.
A substantial. degree of capability for safe shutdown from outside the control room now exists.
Mcwever, it has not been demonstrated that the capability of acnieving safe shutdown exists in the event of fire in critical areas such as the relay room.
The licensee is continuing to analyze the fire hazard in such areas.
The licensee has agreed to provide necessary modifications so that safe shutdcwn capability can be assured.
We have determined that, subject to completion of the above analysis 7.aa implementation of the necessary modifications, a sufficient number af systems and components will be available to perform the shutdcwn function following a fire.
4.2 Fire Detection and Sicnalino Systems The plant has a protective signaling system which transmits various fire alarm and supervisory signals to the control roca.
In addition to fire alarm and supervisory signals frca heat or smoke detectors locatec in selected areas or ventilation systems in the plant, the system also trans-mits signals concerning fire pumo operation or imcairment, carbon dicxide system actuation or trouble, rialon system actuation or trouble, altitude tank level and temperature, operation of fire damcers in the air intake tunnel, operatien of or wate, ficw in automatic sprinkler systems, and closing of selected valves in the fire protection water system.
1488.2,39 4-2
The signaling i ;.m is provided with backuo po' n event of a loss of 1
offsite power by a connection to the emergency power supply system.
Alarm and trouble signals are annunciated in the control room with visual and audible signals.
Soa:e detectors in ventilation system ducts in various parts of the plant will also deenergize fans or clase dampers upon actuation.
i The licensee has committed to provide an analysis to determine if the signal initiating and alarm signal sounding circuits for all fire detection i
and suppression systems are supervised to detect and annunciate circuit i
breaks, ground faults, and power supply failures.
Based on our review of r
this analysis, we will present our conclusions as to the acceptability of the circuit supervision in a supplement to this safety evaluation.
Smoke or heat detectors have been provided in selected areas of'the plant, i
generally in ventilation system ducts.
Additional detectors are proposed in many unprotected areas.
However, there are still a number of safety-related areas without means to detect a fire after the proposed modification.
i These have been discussed with the licensee and he has agreed to provide 1
detectors for some of these additional areas. These plant areas are identified and discussed in Section 5 of this report. We have reviewed the safety-related areas where fire detectors are not provided and conclude that this condition is acceptable because the occurrence of
- g a significant fire in these areas is not credible.
i To ensure that proper consideration has been given to such factors as ceiling height and configuration, ventilation air flow pattern, location and arrangement of plant equipment and combustibles, etc. in determining the type, number and location of fire detectors, the licensee will perform a study and/or testing to verify the adequacy of the existing and proposed detector system design. We will review the licensee's submittal and address the acceptability of the detector design in a supplement to this
~
safety evaluation.
i We find th'at, except for the incomplete item noted above and subject to implementation of the above described modifications, the fire detection i
i and signaling system satisfies the objectives identified in Section 2.2 of this report and are, therefore, acceptable.
i 4.3 Fire Control Systems
~
4.3.1 Water Systems 4.3.1.1 Water sucoly The fire protection water supply for the plant is provide.d by the Susquehanna River.
The circulating water flume located betwean the TMI-1 cooling towers serves as an additional source of fire protection water for the natural draft cooling towers, and can be made available as another source of water for the other areas of the pla.c by manually opening a bypass valve in the connection to the fire protection water piping system.
A 100,000 ga11on alto de tank can be made available by opening a normally u
closed gate valve at the base of the tank.
We find that the water supply conforms to the guidance presented in Appendix A to BTP 9.5-1 and is, therefore, acceptable.
4-3 1488 240
4.3.1.2 Fire Pumos The water supply is delivered by a combination of three centrifugal fire pumps, each with a rated output of 2500 gpm at 125 psig.
One pump, located in the intake screen and pump heuse, is an electric motor-driven vertical shaft centrifugal pump, taking suction from one of the intake bay',- beneath I
the intake screen and pump house.
Each of the other pumps is diesel engine driven. One of these, a vertical shaft pump taking suction from a separate bay beneath the intake screen and pump house, is located in a
^
fire pump house adjoining the intake screen and pump house, but separated from it by a 3-hour fire barrier.
The other pump, a horizontal shaft centrifugal pump, is located in the circulating water pump house between the natural draft cooling towers, and takes suction from the circulating
"~
water fiume.
An additional 2500 gpm at 125 psig diesel engine driven centrifugal fire pump taking suction from the Susquehanna River is located at the TMI-2 intake screen and pump house, and is available at all times without additional valve alignment operations.
A 25 gpm automatic electric driven centrifugal jockey pump located at elevation 305 feet on the east side of the turbine building takes suction from the altitude tank to maintain about 120 psig in the fire water system yard loop.
One or more of the fire pumps, depending on the size of the pressure drop, will start automatically if system pressure drops due to a water demand which the jockey pump is unable to satisfy.
A UL listed automatic controller is located 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 availability and various trouble condition signals are annunciated in the control room as well as at the individual pump con-troller.
Supervision of low fuel tank level is provided for the diesel engine driven pumps, and the main discharge valve from each pump is electri-cally supervised and annunciated in the control roca.
Each of the pumps has sufficient capacity to supply the maximum sprinkler system demand plus 1000 gpm for manual hose streams in any safety-related area.
We conclude that the fire pumps conform to the guidance presented in Appendix 5 to BTP.9.5-1.
Accordingly, we find the fire pumps acceptable.
4.3.1.3 Fire Water Picina System A separate 12-inch discharge line from each fire pump supplies the 12-inch underground loop main which encircles the plant.
Sectional valves permit isolation of this loop from a similar loop around Unit 2.
All yard fire 1488.241 4-4
d hydrants, automatic and manual water suppression systems, and interior i
hose stations are supplied by this loop main.
Post indicator valves subdivide the loop into a number of sections so that a single sect:on 0
could be isolated without impairing the entire system.
However, there are locations where the isolation of a single section between two valves could impair the availability of both automatic sprinklers and the manual hose stations in areas containing or exposing safety-related equipment.
The licensee has committed to provide necessary modification (s) to secure a backup manual hose coverage for these locations in the event of such isolation.
Existing seals on post indicator valves in the loop main will be replaced by tamper proof seals.
Electrical supervision is provided for other sectional valves in the system, for valves controlling water flow.to stand pipe headers, and for some of the valves controlling water flow into sprinkler or deluge systems, as noted in Section 4.2.
The position of all a
valves is checked monthly.
Yard fire hydrants have been provided at approximately 250-foot intervals i
around the exterior of the plant. Tae lateral to each hydrant is controlled by a key operated (curb) valve.
Each fire hydrant is provided with a hose house containing 250 feet of 2h-inch hose, combination fog nozzle, and auxiliary equipment.
Threads on hydrant outlets and hose couplings are compatible with those of two of three fire departments which serve the plant.
Adapters to fit the hoses of the third fire department are kept at i
i the north and south gates to the plant.
This fire department is gradually changing over to American National Fire Hose Connection Screw Thread, t
which is used by the plant and the o'ther two fire departments.
We find that, subject to implementation of the above described modifica-tions, the fire water system conforms to the guidance presented in Appendix A to BTP 9.5-1 and is, therefore, acceptable.
4.3.1.4 Interior Hose Stations A total of 42 interior hose stations, 37 of which are equipped with 75 feet of 1 -inch diameter synthetic braided rayon cord pile hose, and five of which are equipped with 150 feet of similar hose, sra provided in all areas of the plant except containment, control building, diesel generator building, intake screen and pump house, and circulating water pump house.
The licensee has proposed to provide additional hose stations in all areas of the centrol building, except the 306-foot elevation. The licensee has further committed to perform a hose stretch test, and provide additional modification as necessary, to assure that all points in safety-related areas, and other plant areas which contain major fire hazards, can be reached effectively by at least one hose stream.
The licensee will also provide a backup manual hose coverage for those areas containing or ex os-ing safety related equipment where isolation of a single section of fire water. piping could impair the availability of both automatic water suppression and the manual hose station (s) protecting the same a ea.
The licensee nas 4-5 1488'242
also committed to perform a study to determine the possibility of installing hose stations inside containment.
The diameter of standpipes supplying interior hose stations does not comply with the requirements of Section E.3(d) of Appendix A to BTP 9.5-1 in that all individual standpipes are not at least four inches in diameter for multiple hose connections.
The licensee has agreed to perform calculations or flow tests to verify that a 7inimum supply of 100 gallons per minute at a residual oressure of 65 osio at the outlet is available at every hose station with standpipe diameter of less than four inches.
We find that, subject to implementation of the above described modifica-tions and verification of interior hose statica delivery capabilitp as noted above, the interior fire hose stations satisfy the objectives identified in Section 2.2 of this recort and are, therefore, acceptable.
4.3.1.5 Automatic Water Sucoression Systems
~
Automatic wet pipe sprinkler and delt.ge systems have been provided in the turbine buiding to protect the lube oil systems, the hydrogen seal oil system, the basement and me::anine areas, and feedwater pump turbine bearings.
Automatic sprinkler systems are also provided on the 306-foot elevation of the control building and part of the adjacent fuel handling building, in each of the two diesel generator rooms, the diesel fire pump house, the intake screen and pump house, the circulating water pump house, the rifachine shop, and the. service building.
Automatic water spray systems protect the oil filled transformers located outside the turbine building.
Manual deluge systems protect many of the charcoal filters in the plant.
Autcmatic deluge systems protect the air intake tunnel, and the combustion and cooling air intakes for the diesel generators.
The licensee has proposed to install an automatic deluge system in the penetraticn area at the 281-foot elevation of the auxiliary building.
These suppression systems are designed and maintained in compliance with the provisions of NFPA 13 and NFPA 15.
We find that, subject to imolementation of the above described modifica-tion, the autcmatic and manual sprinkler systems conform to the guidance presented in Appendix A to STP 9.5-1 and are, therefore, acceptable.
4.3.1.6 Effects of Water Scray The licensee will analyze the effect of water spray to ensure that both divisions of safety-related equipment will not be incapacitated by rupture or inadvertent operation of the fire water system, or the application of fire hoses.
Additional modification (s) will be provided as necessary.
We will. address the adequacy of protection against the fire water spray damage *in a supplement to this report.
4-5 1488'243
4.s.2 Gas Fire Suoeression Svstems A total flooding low pressure storage automatic carbon dioxide extinguish-ing system, actuated by rate anticipation type heat detectors, protect the relay room (cable spreading room). Upon actuation, the system is designed to discharge 4200 pounds of carbon dioxide in 177 seconds, achieving and maintaining a nominal 50% concentration for about 18 minutes.
A~ reserve supply of carbon dioxide is available from the five ton storage unit.
Dampers in the ventilation ducts to the relay room close automatically on discharge of the system.
Doors to the relay room are maintained closed.
A total flooding Ralon 1301 extinguishing system, actuated by pressure and ultraviolet detectors, protect the air intake tunnel.
Upon actuation, the system is designed to achieve a 9.9% concentration in the tunnel. tFire door dampers at the discharge end of the tunnel close automatically upon system discharge.
A total flooding automatic Halon 1301 extinguishing system, actuated by an icnization type smoke detector, protects the chemical supervisors office at the 322-foot elevation of the control building.
The acceptability of the designs of the various gas suppression systems is addressed in the discussion of the areas where such systems are utilized (see Section 5).
4.3.3 Portable Fire Extincuishers Pressurized water, dry chemical and Aalon 1211 portable fire extinguishers have been distributed throughout the plant in accordance with the p'avisions of NFPA 10~.
We find that the type and distribution of portable fire extinguishers conform to the guidance presented in Appendix A to BTP 9.5-1 and are, therefore, acceptable.
4.4 Ventilation Systems and Breathino Ecuicment 4.4.1 Smoke Removal Ventilation systems are provided for all indoor plant areas.
The plant does not have exhaust systems designed specifically for smoke removal, but the installed air handling systems are capable of exhausting limited volumes of smoke direct to the outside.
Ventilation system discharge from controlled areas is monitored for radio-active contamination.
In case high radiation levels are detected in t%se areas, system air intake and exhaust are terminated, and the contaminated air is recirculatad through filters.
Smoke exnaust operations, if in progress, will be terminated.
1488 244 4-7 er
.e a
Pertable smoke removal equipment, consisting of two smoke exhaust fan units with a combined capacity of 15,000 cfm, have been ordered and will be available for smoke removal in case of fire.
Two more units are avail-able as backup from Unit 2 of the plant.
We find that, subject to implemintation of the above described modifica-tions, the smoke removal capability is adequate and, therefore, satisfies the objectives identified in Section 2.2 of this report and is acceptable.
4.4.2 Filters
~
HEPA filters used throughout the plant are of noncombustible construction.
Charcoal filters are installed in containment as well as in the auxiliary and control buildings.
A,ll charcoal filters are, however, normal!y bypassed.
No ignition sources are located near these filters nor can the buildup of radioactive products generate sufficient heat to cause ignition.
The r
amount of combustibles in the area of these filters, other than the filters themselves, is also low.
All charcoal filters are protected by deluge systems.
The water supply for the kidney filter in containment is pro-vided by a water storage tank and two redundant fire pur.ps also located in containment.
We find that the fire prntection for the charcoal filters satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
- 4. 4. 3 -
Breathino Ecuiement
~
At least ten self-contained _ breathing units, dedicated to emergency use, will be provided.
In addition, the plant has the capability to supply breathing air to 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 ( hour) bottles per man per hour.
A compressor and cascade system are provided onsite to supply this breathing air.
We find that breathing equipment conforms to the guidance presented in Appendix A to BTP 9.5-1 and is, therefore, acceptable.
4.4.4 Battery Room Ventilation Maintenance of ventilation air to station battery rooms is vital in prevention of hydrogen buildup in these rooms.
Currently, fans in the ventilation systems are provided with air flow monitors.
However, thes monitors are not sufficiently sensitive to detect the loss of air flow in a single battery room.
The licensee will install ventilation air flow monitors to alarm on loss of air flow to either battery recrr We find that, subject to implementation of the above described modifica-tion, protection against hyrogen accumulation in battery rooms satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
F488,245 4-8
l s
j
- 4. 5 '
Floor Drains I
Floor drains have been provided in areas protected by automatic water suppression systems and in areas where manual hoses are likely to be used, 2
with the exception of the control room, the relay room, the switchgear i
rooms, the battery rooms, and the diesel generator rooms.
In these areas equipment are mounted on pedestals and fire water will be drained out 1
1 through door openings.
l.
~
i Curbs and drains in various plant areas were reviewed and it was concluded that safety-related equipment in each area will not.be flooded with stand-j ing water.
n j
There are three safety-rekted areas inside the plant which contaili a i
large quantity of stored combustible liquids.
These are the diesel genera-I tor rooms, the makeup and purification pump rooms, and the reactor coolant 1
pump areas inside containment.
Floor drain systems in the diesel rooms j
are physically closed, and drain systems in all three makeup and purifica-1 tion pump rooms are equipped with backflow valves to prevent the spread of i
liquid fires via the drain system.
The existing oil splash guards on the i
reactor coolant pumps will be modified to enclose the pump motor so that possible oil leakage can be contained.
Leaked oil will be drained and stored in lube oil drain tanks inside the secondary snield wall.
i We find that, subject to implementation of the above described modification, I
the drain systems conform to the provisions of Appendix A to BTP 9.5-1 ano
{
are, therefore, acceptable.
4.6 Lichting System The genera'l plant lighting is provided by a system fed by normal AC buses and another system fed from emergency AC buses.
The emergency AC units i
are made up of fluorescent fixtures and are marked with red stripes for more frequent lamo maintenance.
In addition DC emergency lights, powered by the station batteries, are also proviced throughout the control room.
l These lights come on during loss of AC power.
Battery operated hand lights are also provided.
I The licensee has committed to conduct a survey to determine if adequate emergency lighting is provided for shutdown operation and fire fignting in safety-related areas, and to submit the results of the survey for our review.
The acceotability of the emergency lighting provisions, therefore, will be addressed in a supplement to this report.
4.7 Communications There fire three hard wired communication systems located throughout the plant.' The standard party /page system contains three party intercoms and cover's the general plant area including the containment.
A similar system with separate wiring covers safe-shutdown areas but not the containment.
4-*
1488'246 mme
g A third system is used for maintenance; this system has three channels i
with Jacks located in the control room, relay room, the containment and most other safe shutdown areas.
Portable radio communication is also available.
Separationbetweenthetwocomm7nicationsystamswhichservethecontainment is about 4-!s feet at the containment penetration; however, there is a nonsafety-related cable tray located below which could provide a path for fire propagation between these two systems. The terminal boxes at these penetrations are left open.
The licensee will'close off the open terminal boxes and provide a fire barrier to separate these communication cables from the fire hazards in the nonsafety-related cable tray below.
1 We find that, subject to the implementation of the above described modifi-cations, adequate redundancy of communications can be maintained during and following the fire emergency.
4.8 Electrical Cables Power cables in the plant are insulated by hypalon.
Instrumentation and control cables are insulated by either hypalon, cross-linked polyethylene, f
or Teflon.
IEEE~ Standard 383-1974 for flame testing electrical cables was not in existence at the time Three Mile Island, Unit 1 cables were purchased and installed. The licensee has performed flame tests in accordance with procedures and criteria similar to the provisions of IEEE Standard 383-1974 on cables representative of a major portion of cables used in the plant.
Other cables are also tested but in accordance with different procedures and criteria.
Flame retardancy for the latter cables is difficult to determine.
The licensee is contemplating applying a flame retardant coating to cables in certain areas where cable separation may not be adecuate.
Tne exact number of areas and locations where additional protection will be needed will be determined by the licensee's pending stucy on cable separation (see Section 4.10). We will address the acceptability of the cable insula-tion flame resistance in a supplement to this report.
4.9 Fire Barrier Penetrations 4.9.1 Doorway _s Fire barriers are penetrated by doorways, ventilation ducts, electrical raceways, piping and conduit.
Many doorway penetrations are not provided with 3-hour rated fire doors and/or labeled frames.
The licensee will establish fire resistance ratings of the door assemblies through testing certain representative configurations, or by the study and certification of an independent registered fire protection engineer.
Additional modifi-cation will be proviced to remedy those door assemolies that are found to have inadequate fire resistance.
1488 247 4-
/
With respect to supervision of fire doors, the licensee has committed to submit his proposal with regard to: (1) fire doors which will be electrically locked and alarmed, (2) fire doors which are mechanically locked when net in use, and (3) fire doors which are neither locked nor alarmed but whicn are kept cloe.ed when not in use.
We find that, suuject to implementation of the above described modifica-tions, protection for door penetrations of fire barriers satisfies the objectives identified in Section 2.2 of this report and are, therefore, acceptable.
We will address the acceptability of fire door supervision measures in a supplement to this report.
g 4.9.2 Ventilation Duct Penetrations Fire dampers are installed at the discharge end of the air intake tunnel and in selected ventialation duct penetrations of the fire barriers in various parts of the plant.
The licensee has proposed to install rated fire dampers in numerous other ventilation duct penetrations of fire barriers.
We find that, subject to implementation of the above described modifica-tions, protection of ventilation duct penetrations satisfies the objec-tives identified in Section 2.2 of this report and is, therefore, acceptable.
4.9.3 Electrical Cable Penetrations Many of the cable penetrations in the plant have previously been sealed using a mineral wool-asbestos board seal with an undefined fire resistance rating.
In the course of cur review, the licensee presented test data on an alternative seal design using silicone foam.
Based on our review of the licensee's submittal, we conclude that the seal design employing silicone foam as described by the licensee provides adequate fire resistance for cable penetration seals.
In addition, the licensee has committed to replace the mineral wool seals with silicone foam seals of the approved design, and to use the silicone foam seal in all additional cable penetra-tions they have committed to seal as a part of this fire protection review.
We find that, subject to completion of installation of the silicone foam seal of approved design, as noted above, the cable penetration seals conform to the guidance presented in Appendix A to BTP 9.5-1 and are, therefore, acceptable.
4.9.4 Pioing Penetrations The licensee has proposed to replace the existing piping penetration seals with a 3-hour rated silicone RTV foam penetration seal.
4 1488 248 4-11
We find that, subject to implementation of the above described modification, protection of piping penetrations of' fire barriers conforms to the guidance presented in Appendix A to BTP 9.5-1 and is, therefore, acceptable.
4.lc Seoaration Criteria All reactor protection system cables are routed either in conduits or in completely enclosed trays. Other safety-related cables are routed in conduits or open trays.
The separation criteria of the plant between redundant conduits is 6 inches minimum.
The minimun conduit to tray separation is 6 inch'es if the conduit is below a tray and 3 feet other-wise.
The separation between redundant trays is 3 feet both horizontally and vertically.
Six-inch spacing is maintained where possible for rgdundant wiring within cabinets.
Where the minimum separation between trays and conduits cannot be main-tainad fire barriers have been provided.
The horizontal barriers consist of two 3/8-inch asbestos cement boards placed together back to back which extend one tray width to either side of the tray.
In all vertical barriers inspected, two 3/8-inch asbestos cement boards were extended from aDout a foot below the trays to the ceiling. Where 6-inch spacing cannot be maintained between redundant wiring within cabinets, double fire retardant tapings were applied.
The design and construction of fire barriers in Three Mile Island, Unit i facility has many unique positive features.
However, there has been no analysis / test performed to verify the effectiveness of such barriers in preventing the spread of fire.
In particular, possible damage from expo-sure fires involving transient combustibles and nonsafety-related cables providing a possible path of combustion were not taken into account in the original design of the barrier. The licensee will conduct a study to determine the effect of transporting transient combustibles through zones which were not analyzed for their presence.
The licensee will also per-form an analysis / test to verify the effectiveness of the barrier design in preventing (1) the spread of a tray fire to a nearby redundant tray with or without the interposing nonsafety-related cables, and (2) damage to redundant cables from a possible exoosure fire. Where the results of such study indicate that the present des gn is inadequate corrective modifica-tion or additional protection will be provided.
We will address the adequacy of cable separation in a supplement to this report.
4.11 Fire Barriers Fire areas, with few exceptions, are enclosed by floors, walls and ceilings which have adequate fire resistance ratings for the contained combustibles.
Where exceptions have been identified (primarily the absence of fire doors or the use of unlabeled doors), the licensee has agreed to make the necessary modifications.
1488 249 4-12
s i.i We find that, subject to implementation of the above modifications, the 1
design of fire barriers satisfies the objectives identified in Section 2.2 2
of this report and is, therefore, acceptable.
i j
4.12 Access and Egress 5
All safety-related areas are rea.ionably accessible for manual fire fighting except the containment.
During a normal operation, containment is sealed; 1
access is provided through an interlocked double-door air-lock.
Special procedures must be followed to gain access, increasing the response time of the fire brigade.
The diesel generators are accessible by way of a common control cen;ar i
corridor, and also frcm outside by way of large overhead doors.
i The five levels of the ontrol building are accessible either frors a common stairway that runs from elevation 306 feet to elevation 3S0 feet or
~
from the fuel handligg building.
We find that reasonable access and egress are available to e.ach fire area in the plant.
4.*13 Tovic and Corrosive Combustion Products i
The products of combustion of many polymers are toxic to humans and corro-sive to metals.
Prompt fire detection and extinguishment are relied upon to reduce the quantity of such products produced during a fire. Means of smoke removal, as discussed in Section 4.4.1, are provided as an aid in fire fighting. 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, subject to implementation of the modifications described elsewhere in this report, the precautions taken to reduce the effects of toxic and corrosive products satisfy the objectives identified in Section 2.2 of this report and are, therefore, acceptable.
4.14 Nonsafetv-Related Areas We have evaluated the separation by distance or by fire barriers of nonsafety-related areas and have determined that fires in such areas will not adversely affect the ability to safely shut down the plant.
4.15 Instrument Air Systems in the plant which have pneumatic instruments and controls may be required for safe shutdown depending on the location of a postulated fire.
It was verified that air operated valves will fail in safe positions so that a fire induced loss of the instrument air syste.n would not prevent safe shutdown.
1488 250 4-13
i 1
/
w 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 identify I
the consequences of fires in safety-related areas and to evaluate.the adequacy of fire protection systems.
I The results of this analysis, other docketed information, and site visit 1
observations were used in the staff's evaluation of specific plant areas
~"
which is discussed in the following sections.
5.1 Reactor Buildina 5.1.1 Safety-Relatec Ecuicment Outside the secondary shield:
Safety-related equipment in this area includes reactor building emergency cooling units, the steam generator level and the pressurizer level instru-4 mentation, and the decay heat removal valve at elevation 281 feet; steam i
generator pressure instrumentation at elevation 308 feet; and primary coolant pressure instrumentation at elevation 346 feet.
l
- Inside the secondarv shield:
1 i
Safety-related' equipment includes the reactor and associated auxiliaries, i
reactor coolant pumps, steam generators, and coolant temperature instrumenta-
- tion, i
The electrical cabling is concentrated in the containment penetration area.
Safety-related cables inside the containment are all routed in I
conduits.
5.1.2 Combustibles The combustibles in this area consist of approximately 138 gallons of lube oil in each of two reactor coolant pumps, charcoal in the kidney filter plenum and electrical cable insulation.
Transient comoustibles are minimal due to strict access control into the building.
I 5.1.3 Consecuences if No Fire Suceression I
An unmitigated fire involving reactor coolant pump lube oil could damage 1
the affected pump and associated electrical caoles.
The reactor and i
associated instrumentation are shielded by a massive concreta wall.
Should i
the containment temperature and pressure increase significantly as a result i
1488 251 5-1 l
_..=-./ -
of the fire containment spray will be actuated.
Charcoal fire in the kidney filters is likely to be cont,ained within the filter casing.
Cables at the containment penetration area are well separated.
All safety-related cables are routed in metal conduits and located at least 30 feet above the floor.
However, there are some nonsafety-related cable trays forming paths of combustibles between separated conduits / penetrations.
The licensee has not analy::ed if redundant cables could be damaged by a fire in such trays.
The power-operated decay heat removal valves are accessible for manual
__ operation in,the event the power operatcrs were disabled by a fire.
7.-
5.1.4 Fire Protection Systems Each reactor coolant pump is equipped"with an oil splash guard to direct leaked oil away from hat metal surfaces.
An automatic self-contained deluge system protects charcoal in the kidney filter clenum.
Portable water, dry chemical, and Halen 1211 fire extinguishers are distributed
' throughout the building and are also located outside the reactor building at the personnel air lock.
5.1.5 Adecuacy of Fire Protection Existing fire orotection in this area is inadequate.
No fire detector has been providea to detect a fire in the area.
Portable extinguishers orovided are not adequate to suppress a large fire such as the lube oil fire in the reactor coolant pump areas.
Portable extinguishers may not be able to reach some cable fires because many cable trays are located hign above the floor.
Effectiveness of the existing oil splash guards in preventing the reactor coolant pump lube oil fire from starting is not proven.
The self contained deluge system should be adequate to protect against a charcoal fire in the kidney filters.
5.1.6 Modifications The licensee will provide the following modifications:
(1) Early warning fire detection systems will be installed throughout the reactor building.
(2) Thermal protection will be provided for the decay heat removal valves.
(3) Oil splash guards on the reactor coc,lant pumas will be modified so tiat any possible oil leak can be contained and drained to a tank l
located away from safety-related cables / equipment.
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-(4) Curbs will ue installed inside the ' econdary wield at elevation s
281 feet to reduce the possible spread of lube oil frem the reacter coolant pumps.
Tne licensee will also analyze the adecuacy of the cable separati:n 4;sinst the hazards in the area and provide additional protection as nacessary to protect redundant caoles frca being damagea by a single fire.
1 In addition, the licensee will perform a study to determine the feasibility of installing aanual hose stations within tne building and will install such stations if feasible.
We will address the acceptability of the fire protection measures inside the reactor building in a supplement to this report.
4 5.2 Decay Heat Removal Pits - Auxiliary Buildinc. Elevation 261 Feet
~
- 5. f.1 Safety-Related systems 1
' Each pit contains one division of decay heat removal pump, decay ti~ eat cooler, and asscciated valves and cabling. The pit area has reinforced concrete walls and flecr and is covered with a reinforced concrete slab i
fitted with concrete ecuipment access hatch covers. The ceiling is penetrated by air handling supply and return ducts, cable trays, piping and steel personnel access hatches.
5.2.2 Combustibles The ccmbustibles in this area consist of two quarts of lube oil in the pumps and cable insulation.
5.2.3 Consecuences if No Fire Suoeression m
A fire in either pit may disable the division of the decay heat removal system associated with the pit. Because of unsealed or inadequately sealed penetratiens, the barrier around each pit may not be adecuate to contain a fire within one pit.
5.2.4 Fire Protection Systems i
Fire protection for this area consists of dry chemical fire extinguishers and manual hose stations on the basement floor of the auxiliary building.
5.2.5 Adecuacy of Fire protection Manual suppression would be adequate to control a fire in this area.
iiowever, a fire in this area is likely to burn itself out undetected because of the lack of autcmatic fire detection in tne area.
Undetected damage, even if limited to one division, could deprive the plant of required redundancy for this vital shutdcwn system in a subsequent snut-down operation.
5.2.6 Modifications The lidensee will install a fire damcer in HVAC supply and return ducts and seal the piping and electrical cable ::enetraticas to crovide adequate fire resistance for tre :enetrati:ns.
The licensee has also ::mmi tic to provide a fire detecter in eacn of '.re pin a prev ce an m / n e warning.
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Ve find that, subject to implementation of the above described modifica-i tions, fire protection for the area conforms to the guidance presented in Appendix A to BTP 9.5-1 and is, therefore,-acceptable.
5.3 Fuel and Auxiliarv Buildinc Basement - Elevations 271 Feet and 281 Feet 5.3.1 Safety-Relatec Ecuicment Safety-related equipment in the area includes makeup and purification pumps and associated valves; nuclear service cooling water heat exchangers; decay heat removal heat exchangers; and miscellaneous waste storage and treatment facilities.
The electrical cables are mostly concentrated in the fuel handling building area to the east of the makeup and purification pumps, and near tr.e penetra-tion area.
5.3.2 Combustibles The combustibles in this area consist of 20 gallons of lube oil and hydraulic fluid in each of 3 makeup and purification pumps, a small amount of lube oil % other pumps, and electrical cable insulation.
Radioactive spent resin is stored in a steel tank in the form of a watery sludge and, there-fore, is excluded from the combustibles.
5.3.3 Consecuences if No Fire Sucoression Floor drains in the makeup pump cubicles are equipped with back flow protection valves so that an oil fire in these cubicles will act spread via tre drain system.
However, barriers enclosing each pumo, although capable of three hour fire resistance, are penetrated by an unsealed duct, piping, and cable penetrations.
A large oil fire may involve all three makeup and purification pumps. At least one of these pumps is needed for shutdown.
s I
Cable trays routed in the fuel handling building to the east of the makeup pump area are provided with asbestos cement board barriers to protect redundant cables frota being damaged by a single fire.
The design of the barriers has not taken into consideration possible effects of exposure fires and/or interposing nonsafety-related cable trays capable of provid-ing paths for fire propagation.
Reduncant cables, therefore, could be damaged in a single fire.
An unmitigated fire in the pipe penetration area could disable certain instrumentation, and both divisions of the decay heat removal valves and the makeup and purification valves.
A fire in the remainder of the area is not likely to affect safe plant shutdown because very few camoustibles are located in this area during tne normal
- operation and because most of the equipment which could ::e involved consists'of tanks, piping, and heat exchangers all containing water.
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5.3.4 Fire Protection Systems Portable extinguishers and manual hose stations are provided for fire suppression in this area.
Fire stops consisting of two 3/8 inch asbesto cement boards, placed back to back, are provided to prevent the spread of fire between cable trays.
5.3.5 Adeouacy of Fire Protection Existing fire protection in this area is inadequate.
Because no ' ire f
detector has been provided in the area, fire could develop to an advanced stage before being discovered.
In the pipe penetration area, a fire could involve both divisions of valves controlling the decay heat removal. system and the makeup and purification system.
A cable or exposure fire fh the fuel handling building could damage both divisions of cables.
The barriers enclosing the makeup and purification pump cubicles may not be able to contain a;1arge fire because the HVAC duct, the piping, and the cable penetrations of the barriers are not protected.
Manual hoses may not be able to reach all points in the area effectively and the effective-ness of asbestos board fire stops in preventing redundant cables from being damaged by an exposure fire, or a fire in interposing cable tray (s),
has not been demonstrated.
5.3.6 Modifications The licensee will provide the following modifications:
(1) A deluge system actuated by fonization type smoke detectors will be installed in the pipe penetration area.
(2) A fire damper will be installed in eaca HVAC duct penetrating the barriers enclosing the "A" makeup and purification pump cubicle.
All the piping and cable penetrations of these barriers will be sealed to provide a fire resistance rating ccamensurate with the fire hazard in the area.
(3) Conduct a hcse stretch test, and provide additional hose stations as necessary, to ensure that all points in the area can be reached effe<;tively by at least one hose stream.
The licensee will also perform an analysis or a test to demonstrate the effectiveness of the fire stops in preventing fire damage to redundant cables, considering the effect of exposure fires due to transient combus-tibles and the effect of interposing nonsafety-related cable trays.
Additional protection will be proposed to prevent redundant cables from being damaged by a single fire. '
In addit. ion, the licensee has agreed to provide fire detectors in each of the makeup and purification pump cubicles, the valve gallery and the area east of the pump cubicles.
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We find that, subject to implementation of the above described modifications, fire protection in this area satisfies the objectives identified in Section 2.2 of tais report and is, therefore, acceptable.
5.4 Fuel and Auxiliary Building. Ground Floor - Elevation 305 Feet 3.4.1 Safety-Relatec Eouiement Safety-related equipment in this area includes makeup and purification decineralizers, engineered safeguard motor control centers (MCC), decay heat removal cooling pumps, nuclear service cooling pumps, air han'dling units for the pump area, waste gas decay tanks and exhaust filters for the auxiliary building. The electrical cabling in this area is mainly of one division except in the closed cooling water pump area where there are both
- 2 divisions of cabling.
5.4.2 Combustibles The combustibles in this area consist of approximately 1 gallon of lube oil in each of the decay heat removal and the nuclear service water pumps, charcoal in filters and electrical cable insulation. There is also a plastic tank and polyvinyl chloride piping in an area away from safety-related cables / equipment required for shutdown.
Ion exchange resin in the domineralizers is excluded from the combustibles tecause it is always a.aintained in water.
5.4.3 Conseabences if No Fire Sucoression Considering only fixed combustibles, there is not a credible fire hazard in this area which could disable both divisions of safety-related Systems except possibly a fire in nonsafety-related cable trays interposing redundant cables.
A fire involving lube oil uf the ccoling water pump will be prevented frca affecting the redundant pump (s) by the concrete walls interposing the pump cubicles.
A fire in either of the engineered safeguard MCCs is not likely to involve sufficient combus*.ibles to camage the redundant MCC.
A charcoal fire in the filters most likely will be contained within the steel casing of the filter.
However, the area is largely open and the possibility for an ex::osure fire from transient combustibles cannot be ruled out. A pool fire caused by a combustible liquid spillage at certain critical locations in the' area could damage redundant components of the engineered safeguard MCCs, the decay heat removal cooling water system, or the nuclear cervice closed cooling water system.
5.4.4 Fire Protection Systems An automatic deluge water sucpression system is provided to protect against charcoal fires in the exhaust filters.
Dry chemical and carbon dioxice extinguishers, and manual hoses are available for manual fire suporession in this area. The area between the east wail of the fuel pool and the control building is protected by a sprinkler rystem.
5-s 1488 2.56
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s 5.4.5 Adecuacy of Fire Protection The fire protection in this area is inadequate.
There is no detector to provide early warning for a fire in this area.
Adequacy of the cable separation, with the asbestos board fire stops, in preventing damage to redundant cables is not established.
The fire hazards analysis for this area did not consider the possibility of exposure fires.
5.4.6 Modifications As stated in Section 4.10, the licensee will provide the results of an analysis or tests to demonstrate the adequacy of the cable separction and effectiveness of the asbestos board fire stops, taking into account. the effect of interposing cable trays between redundant cables and the effect of. exposure fires. The licensee will also prov'ide the results of a study to identify the type and the maximum quantity of transient ccmbustibles likely to be brought into or through each area for rcutine operational or maintenance activities and will evalu' ate the fire hazards from such cc= bus-tibles to ensure redundant equipment required for shutdown will not be damaged. Corrective modifications or additional protection will be proposed if the results of these studies show that the present protection is inadequate.
In addition, the licensee has Greed to provide automatic fire detection in the decay heat removal and the nuclear service closed cooling water pump. area; and tne engineered safeguard MCC area.
We will address __the adequacy of fire protection for this area in a supple-ment to this recort.
5.5 Intermediate Buildino. Basement Ficar - Elevation 295 Feet 5.5.1 safety-Relatec Eculoment Safety-related equipment in this area includes the steam turbine driven emergency feedwater pump, two electric motor driven emergency feecwater pumps, reactor building emergency cooling valves, and electrical contain-ment penetrations.
5.5.2
. Combustibles The combustibles in this area consist of 5 gallons of lube oil in the turbine driven emergency'feedwater pump, 2 gallons in the motor driven emergency feedwater pumps, 5 gallons in air compressors, and electrical cable insulation.
5.5.3 Consecuences if No Fire Suceression An unmi.tigated fire involving the lube oil from either the turbine driven pump or air compressors could disaole all emergency feedwater pumps and damage all reactor building emergency cooling valves.
5-7 1488 257
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5.5.4 Fire Protection Systems Water and carbon dioxide extinguishers and manual hoses are available for manual fire suppression.
i 5.5.5 Adecuacy of Fire Protection The steam driven and the motor driven emergency feedwater pumps are separated from each other and other equipment in the area by concrete walls.
- However, the walls are penetrated by a door opening and piping penetrations and are inadequate to contain a fire.
Since the turbine driven pump and air compressors contain a significant amount of lube oil, the possibility of an oil fire involving several gallons cf lube oil must be considered. The licensee, however, has not demonstrated that redundant cabling or equipment required for safe shutdown will not ce disabled by such fire in the area 5.5.6 Modifications An automatic fire detection system will be installed in the area to provide an early fire warning.
The licensee will analy::e the effects of a !ube oil fire or other possible exposure fires in the area. Additional protec-tion will be proposed if the results of the analysis cannot demonstrate that the function of safe shutdown systems in the area will be preserved under such fire.
We wil1 address the adequacy of fire protection for this area in a supple-ment to this report.
~
5.6 Remainder of Intermediate Buildino - Elevations 305 Feet. 322 Feet. and 355 Feet 5.6.1 Safety-Related Ecuioment The only safety-related equipment in the area are main steam safety valves, main steam isolation stop check valves and atmospheric dump valves located at elevation 322 feet, and associated electrical cables.
5.6.2 combustibles The combustibles in this area consist of a small amount of electrical cable insulation.
5.6.3 Consecuences if No Fire Sucoression It is not credible that main steam piping and valves, which are'of heavy steel construction, could be damaged by a fire in this area.
Damage to cables controlling atmospheric dump valves will not affect the safe shut-down because backup is available by manually operating spring loaded safety valves.
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5.6.4 Fire Protection Systems Water and carbon dioxide portable extinguishers are provided for manual suppression in this area. Manual hoses are available at elevation 305 feet.
5.6.5 Adecuacy of Fire Protection Manual suppression is adequate for the fire hazard in this area.
5.6.6 Modifications -
The licensee will insta71 a class A door in the door openino at elevation 305 feet to provide a three hour barrier between the intermediate building
~2 and the turbine building.
We find that fire protection for this arer satisfies the objectives i
identified in Section 2.2 of this report and is acceptabl.e.
5.7 Control Buildino Basement - Elevation 306 Feet 5.7.1 safety-Relatec Eculement i
The area contains both divisions of safety-related cables.
There is no other safety-releated equipment in this area.
- 5. 7. 2 Combustibles
- Combustibles in this area consist of. electrical cable insulation and miscellaneous ccabustibles consisting of protective clothing, bacts, gloves, etc.
5.7.3 Consecuences if No Fire Sucoression An unmitigated fire could damage both divisions of cables routed in the area which are required for safe shutdown.
5.7.4 Fire Protection Systems An automatic sprinkler system is installed te protect the area.
Water and dry chemical fire extinguishers are also available.
This area is separated from other parts of the plant by concrete walls and ceiling capable of 3-hour fire resistance.
However, the door opening and piping and caele pent:trations of the barrier separating this area from the fuel handling building are not protected. Asbestos board fire stops are provided to prevent a fire in a cable tray from spreading to redundant trays.
5.7.5 Adecuacy of Fire Protection Fire stops and the automatic sprinkler system should be able to prevent redundant cables frem being dacaged by a single fire.
The barrier is inadequate to prevent the cables in this area from being exposed to the fire hazard in the neighboring areas.
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N 5.7.6 Modifications The door opening to the fuel handling building will be protected by a class A fire door.
Cable and piping penetrations will be sealed to provide an adequate fire resistance.
Manual hose (s) will be made available to protect the area.
In addition, the licensee has agreed to limit the miscellaneous combustibles kept in the area to the mini.a m needed for normal operations.
We find that, subject to implementation of the above described modificaticas, fire protection for this area satisfies the objectives identified in
.Section 2.2 of this report and is, therefore, acceptable.
,,1
- 5. 8 480 Voit Switchcear Room - Control Buildina, Elevation 322 Feet 5.8.1 safety-Reiatec icuic:ent The safety-related equipment in this area consists of engineered safeguards 480 volt switchgear IP and 15, motor control center lA and 18, switchgear, area boostee fans A at;d B, AC transfer switch 1C, and DC transfer switch IM.
5.8.2 Combustibles The combustibles in this area consist of electrical cable insulation, electrical com::enents, and miscellaneous combustibles kept in the chemical superviser's office.
5.8.3 Consecuences if No Fire Sucoression Redundant switchgear and MCCs are located in separate rooms separated by 3-hour barriers.
However, piping, duct, cable penetrations, and door openings of the barriers either are not protected or have unrated barriers, so that redundant equipment required for safe shutdown could be exposed to a single fire.
Damage to AC and/or DC transfer switches wil not affect safe shatdown.
5.8.4 Fire Protection Systems The fire protection for this area consists of smoke detectors in HVAC.
ducts which alarm and annunciate in the control room, and dry chemical and carbon dioxide fire extinguishers.
5.8.5 Adecuacy of Fire Protection The existing fire protection is not adequate to assure safe shutdown.
Separation between tne reduncant acuipment is inacequate and tne effectiveness of fire stops is not established.
N f
i 5.8.6 Modifications The licensee will pr: vide a damper in eac.5 "/C duct per m atic-m mal the piping and the caole penetrations to provice acequate fira res:s;2c:e.
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Adeq c.y of fire resistance will be established for the existing unlabelled door assemblies, or the existing doors and frames will be replaced with those with appropriate ratings.
The ifcensee will also conduct a study to ensure the adequacy of cable separation, including the. design of fire stops.
Additional protection will be provided, if necessary, to preserve one division of cables / equipment to assure safe shutdown.
Manual hoses will be maca available to cover the area effectively. The licensee will limit the miscellaneous ccmbustibles kept in this area to the minimum required for normal operations.
We find that, subject to imolementation of the abcve described nodifica-tions', fire protection for this area satisfies the objectives icentified
.in Section 2.2 of this report and is, therefore, acceptable.
g 5.9 Station Batteries and Accessories - Control Buildina, Elevation 322 Feet 5.9.1 Safety-Relatea Eculement
~
The safety-related equipment in this area consists of station batteries, battery chargers, inverters, and AC and DC distribution panels.
5.9.2 Combustibles i
The combustibles in this area are cable insulation.and battery cases.
5.9.3 Consecuences if No Fire Sucoression
)
- Redundant divisions of station batteries are located in r ms separated from each other and from other parts of the plant by concrete walls, ficor and ceiling capable of 3-hour fire resistance.
Except for unprotected ducts, piping, and cable penetrations, a fire in either of thes9 rooms is not likely to affect the redundant equipment.
Redundantbatterychargers, inverters,andACandDCdistributionpanel are also separated from each other ar.d from other parts of the plant by barriers capable of 3-hour fire resistance except for the unsealed penetrations.
The rooms also contain both divisions of cables seoarated by more than 10 feet of space but interposed by a nonsafety-related cable tray.
A fire in either rocm could expose both divisions of cables / equipment to damage.
5.9.4 Fire Protection Systems The fire protection systems for this area consist of smoke detectors installed in HVAC ducts, serving the area, which alarm and annunciate in the control room, anc cry chemical anc caroon dioxide portable extinguishers.
5.9.5 Adecuacy of Fire Protection o
The five protection in this area is inadequate due to the lack of manual hoses, of proper seais for the barrier penetrations, and of a means for positive surveillance of the ventilation air ficw in the batterv roc ts.
Adequacy of cable se;iration with rmec-o t.a fi o h--
1; / - ; >
interposing cables anc from tne transien;. ca.T.bustiRs i2
.x u nai ; 3ne::.
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1488 26i
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5.9.6 Modifications The licensee will install a fire damper in each HVAC duct penetration and seal piping and cable cenetrations to provide an adequate fire resistance.
Manual hose stations will be installed in adjacent areas to provide coverage for this area.
The licensee will review the adequacy of cable separation against fire hazards from the interposing cables and from the transient combustibles.
Additional protection will be provided if the study reveals deficiency.
A ventilation air flow monitor will be installed for each battery room to alarm and annunciate the loss of the ventilation air flow to either of the battery rooms.
We find that, subject to implementation of the above described modifi;ca-tions, fire protection for this area conforms to.the guidance presedted in Appendix A to BTP 9.5-1 and is, therefore, acceptable.
5.10 4160 Volt Switchcear - Control Buildino, Elevatirn 338 Feet. 6 Inches 5.10.'
safety-Relatea Eculement The safety-related equipment in this area includes 4160 volt engineered safeguard switchgear, and engineered safeguard actuation cabinets and relay cabinets.
5.10.2 Combustibles The combustibles in this area are electrical cable insulation and electrical
--components inside cabinets.
5.10.3 Consecuences if No Fire Sucaression Redundant switchgear is located in separate rooms; all the actuation and relay cabinets are located together in the third room.
Barriers enclosing each room, however, have unprotected ventilation ducts, and cable penetra-tions. The effects of a fire would not be limited to one division of safety-related cables / equipment.
5.10.4 Fire Protection Svstems The fire protection in this area consists of smoke detectors in the HVAC ducts, and dry chemical and carbon dioxide portable extinguishers.
5.10.5 Adecuacy of Fire Protection
. Existing fire protection in this area is inacequate.
Unlabeled doors and unsealed penetracions could permit the spread of heat and smoke from one room to another.
Redundant cabinets in the same room could both be involved in a fire.
i 1488 262 5-12
5.10.6 Modifications The licensee will provide manual 'h'ose stations to serve the area; will upgrade cable penetration seals and install fire dampers in the HVAC duct penetrations to provide aopropriate fire resistance.
Adequacy of fire resistance of unlabelled fire door and frame assemblies will be demonstrated by a test / analysis, or the coor assemblies replaced if the result of the study fails to establish the adequacy of such assemblies.
In addition, the licensee will perform an evaluation to determine whether safe shutdown can be accomplished assuming the loss of both divisions of engineered safeguards relay and actuation cabinets.
If the evaluztion indicates that the capability to achieve safe shutoown is adversely affected, the licensee has committed to provide additional. protection.
Theacceptabi'ityofthefireprotecf.ionmeasuresinthisareawillbe addressed in a supplement to this report.
5.11 Cable Screadina Room - Control Buildina. Elevation 338 Feet, 6 Inches 5.11.1 Safetv-Relatec Eculoment The safety-related equipment in this area includes redundant relay cabinets in addition to both divisions of cables.
5.11.2 Combustibles The combustibles in this area consist of electrical cable insulation and elegtrical components in relay cabinets.
5.11.3 Consecuences if No Fire Sucoression An unmitigated fire in this area could disable the safe shutdown capability of the plant.
5.11.4 Fire Protection Systems Fire protection for this area consists of an automatic, total flooding, low pressure carton dioxide system actuated by heat detectors; portable dry chemical, Halon 1211, and carbon dioxide extinguishers located outsica of the cable spreading room.
Asbestos board fire stops are provided to prevent a cable fire from spreading to' redundant tray (s).
5.11.5 Adecuacy of Fire Protection Existing fire protection is inadequate.,The cable secaration is inadequate to prevent fire damage to botn divisions of cables.
The effectiveness of the total flooding, automatic gas system has against a deep-seated cable fires is questionable.
Heat detectors, actuating the automatic gas system, 1488 263 5.u ese
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8 will not detect a escie fire as cuickly as smoke detectors so that a cable i
fire in the roca is more likely to become deep-seeted before the gas system is actuated.
1 5.11.6 Modifications The licensee will replace unlabeled doors and upgrade barrier peiletration seals to provide a 3-hour barrier encloiing the rocm. Manual hose (s) will be provided to reach all points in the area effectively.
The licensee 1
will also provide a shutdown capability independent of cabling and equip-ment in this area., Additional smoke detectors will be installed in this l
room.,-
f In addition, the licensee will identify the areas in this roca whe e he proposes to provide a manually cperated fixed water suppression system or apply an appropriate flame retardant coating to the electrical cables.
We will address the acceptability of the fire protection measures in this area in a supplement to this report.
1.
5.12 Control Room - Control Buildino, Elevation 355 Feet j
5.12.1 Safety-Relatec Eculement r
The safety-related equipment in the control rcom consists of instrumenta-tion.and control panels and consoles.
There is no safety-related equip-ment or cables in the neighboring rooms.
5.12.2 Combustibles 6
The combust.ibles in the control recm consist of electrical cable insula-tion, electrical components in panels and consoles and some class A combustibles h
such as log books, drawings, operating manuals, and computer printouts.
L 5.12.3 Consecuences if No Fire Suceression Considering the small quantity of ccmbu:tibles in the area, and the fact that the area is constantly manned, an unsucpres?ed fire involving the whole control recm is incredible.
Mcwever, a fire in a cabinet or a console could cause consicerable damage before being extinguished.
A fire in a neighboring reca, sucn as the cceputer rocm, could also expose ecufpment in the control recm.
The plant, however, can be shutdcwn independent of i
i tb 9 room.
i j
5.12.4 Fire protection Systems a
Fire protection for this area consists of smoke detectors in HVAC ducts and in the control recm, and portacle dry, chemical and carben dioxide extingu,ishers.
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5.12.5 Adecuacy of Fire Protection The existing fire protection is ir. adequate.
Many doorway openings either 4
.4 do not have a coor or are provided with unlabeled doors.
Duct, cable and pipf.J penetrations of the barr,iers are unprotected. Detection and suppression capabilities are inadequate.
5.12.6 Modifications The licensee will provide Class A fire doors for the open doorways in the fire barriers enclosing the control rocm.
Unlabeled doors will be replaced or the adequacy of fire resistance established.
Fire dampers will be installed in the HVAC duct penetrations, and piping and cable penetrations i
will be sealed to provide an adequate fire resistance. A manual, hose will i
be provided in the adjacent stairway area. An ionization type smoke detector will be installed in each safety-relatd cabinet and console in the control room.
The licensee will also relocata a'l unnecessary combustibles from the computer office to nonsafety-related areas.
We find that, suoject to implementation of the above described modifica-tions, fire protection for this area conforms to the guidance presented t
in Appendix A to STP 9.5 ' and is, therefore, acceptable.
5.13 Control Buildino HVAC Ecuicment Area - Control Buildino, Elevation 380 Feet i
5.13.1 Safety-Relateo eculement The safety-related equipment in this area includes the normal and emergency control building supply air charcoal filters, exhaust fans, and associated ducts, dampers ~, and cables.
5.13.2 Combustibles The combustibles in this area consist of cable insulation and charcoal in the filters.
5.13.3 Consecuences if No Fire Sucoression Redundant components of the normal and the emergency control building ventilation systems are located in separate rooms, except for the exhaust fans.
Both exhaust fans are located in "A" rocm. Barriers enclosing each room, however, have unprotected door openings, ducts, piping, and cable penetrations. The effect of a fire will not be contained within one division.
At least one division of either the normal or the emergency control bu. lding ventilation system may be needed to maintain control rocm habitability.
5.13.4 Fire Protection Svstems Fire protection for tnis area consists of smoke detectors in the HVAC ducts, and portable water and dry chemical extinguishers for manual suppres-si on.'
Charcoa' filters are protected by heat sensors and a deluge water system.
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5.13.5 Adecuacy of Fire Protection i
The existing fire barriers, with unprotected openings and penetrations, are inadaquate to prevent a fire in the area from involving both divisions e
of the ventilation system.
Manual suppression capability is inadequate without manual hose coverage.
The licensee has not analyzed the safe i
shutdown consequences of losing control building ventilation.
l 5.13.6 Modifications 1
The existing donr openirigs will be modified and Class A doors installed to provide 3-hour fire resistance.
Fire dampers will be installed in the HVAC duct penetrations, and cable and piping penetrations sealed );o provide an adequate fire resistance rating.
A manual hose station will be provided in the adjacent stairway.
i The licensee has committed to analyze the safe shutdown consequences of losing control bu ' ding ventilation and to propose corrective measures if needed.
j i
We will address the adequacy of fire protection in this area in a supple-ment to this report.
j 5.14 Intake Screen and Pumchouse j
0.14.1 Safetv-Relatec Ecuicment Safety related equipment in this area consists of screen house air han-dling units A and B, screen house 480 volt switchgear and motor control centers, decay heat river water pumps A and B, nuclear service river water pumps A, B and C, reactor building emergency cooling pumps A and B, and associated valves.
t 5.14.2 Combust nes l
The combustibles in this area consist of a total of about six gal'ans of lubricatng oil, electrical cable insulation, and transient materials. The adjacent diesel fire pump rocm contains 350 gallons of diesei fuel oil in the fire pump day tank.
5.14.3 consecuences if No Fire Suceression Postulated fires would be limited to the area of origin.
A fire in the diesel fire pump room would not affect safety-related equipment in the adjacent intake screen and pump house because these areas are separated by 4
a 3-hour rated fire barrier.
The east section of the intake screen and pumphouse, where nearly all of the safety-related equicment is located, is divided into two rooms by a concrete wall.
Reduncant items of equipment i
are located in these separate rocms. Althougn there is an open coorway in this wall, the location and arrangement of safety-related equipment and
- .ombustible materials makes it unlikely that recundant counterparts would be affected by a single fire.
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1 5.14.4 Fire Protection Systems An automatic sprinkler system equipped with a flow alarm has been installed in this building, including the diesel fire pump room.
Portable dry chemical and water type fire extinguishers are also provided.
Fire hoses
]
are available from the yard fire hydrants.
j 5.14.5 Adecuacy of Fire Protection
~
The fire protection measures for this area are adequate.
j 5.14.6 Modifications eA We find the fire protection for this area conferms to the cuidanc( presented
.in Accendix A to BTP 9.5-1 and is, therefore, acceptable.
5.15 Diesel Generator Rooms 5.io.I safety-Relatec Ecuiement The safety-related equipment in each of the two diesel generator recms includes an emergency diesel generator, diesel fuel day tank, fuel trans-
[
fer pumps, diesel generator starting air compressors and receivers, the o
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control panel, and the room air handling unit.
f 5.15.2 Combustibles I
-~ The combustibles in each room consist of lubricating oil in the engine, l
fuel oil in the-day tank, fuel oil and lubricating oil in the diesel-driven
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air compressors, and possible transient materials.
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5.15.3 Consecuences if No Fire Succression, Except for a door in the " lobby" area which is unlabeled, the two diesel generator rooms and their control centers are separated by a three-hour
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rated fire barrier.
An unmitigated fire in one diesel generator rocm could cause the loss of the diesel generator in that room.
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5.15.4 Fire Protection Systems Automatic sp inkler systems are installed in each diesel generator roca and lobby.
An automatic deluge system is installed in the air intake area for each diesel generator.
Portable cry chemical fire extinguishers are provided. Manual hose backup is available frcm yard fire hydrants.
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,i 5.15.5 Adecuacy of Fire Protection i
The autcmatic sprinkler and deluge systems will be adequate to control and suppress fires in this area of the plant.
i 1488 267 5-17 I
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5.15.6 Modifications The licensee proposes to rep 1&c9 the non-rated door between the diesel generator building and the serv M building with a Class A labeled fire door and to upgrade or verify the rating of the unlaceled lobby door.
We find that. subiect to implementation of the above described modifi-cations, the fire protection for this area conforms to the guidunce presentec in Appendix A to BTP 9.5-1 and is, therefore acceptable.
5.16 1 Storace Areas - Fuel Handlina Buildina. Elevations 329 Feet, 331 Feet.
348 Feet 5.16.1 TaYety-Related Ecuicment The safety-related equipment in this area includes the spent fuel pool and the nuclear service closed cooling water surge tank at elevation 348 feet i
and the decay heat closed surge tanks at elevation 329 feet.
4 5.16.2 Combustibles The combustibles in this area consist ef lube oil in the fuel handling bridge and crane, and electrical cable in3ulation.
During refueling, significant quantities of transient combustibles could be present.
5.16.3 Consecuences if No Fire Sucaression Spent fuel is stored under water and.the safety-related cooling water surge tanks are_of heavy steel construction and filled with water.
Even an unmitigated fire is not likely to cause damage to these components and equipment.
5.16.4 Fire Protection Svstems Manual hoses and portable dry chemical, water, and carbon dioxide extin-guishers are available for fire :appression.
5.16.5 Adecuacy of Fire Protection Manual suppression is adequate to control a fire in this area.
5.16.6 Modifications The licensee will seal joints where the fuel handling building walle abut the reactor building and replace unlaceled doors with Class A doors.
We find that, subject to implementation of the above described modifica-tions, fire protection for this area satisfies the oojectives identified in Section 2.2 of this report and is, therefore, acceptable.
1488 268 5-18
5.17 Zone detween Fuel Pcci and Control Buildino. Elevations 322 Feet and 380 Feet 5.17.1 Safetv-Related Ecuioment Some safety-related cables are in the area.
There is no other safety related equipment in this area.
5.17.2 Combustibles Combustibles in this area consist of cable insulation and possible transient combustibles.
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5.17.3 Consecuences if No Fire Sucaression J.
The licensee's Fire Hasard Analysis did not identify which system (s) is served by the cables routed through tnis area.
The licensee has agreed to submit a list of the systems served by these cables and an analysis of the effect of a fire in this area on the ability to safely shutdown the reactor.
5.17.4 Fire Protection Svstems Dry chemical and carbon dioxide fire extinguishers are availabie for manual fire suppression.
5.17.5 Adecuacy of Fire Protection
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-- We will address the adequacy of fire protection for this area in a supple-ment to this report.
5.17.6 Modifications We will identify any needed modifications in a supplement to this report.
5.18 Turbine Buildino 5.18.1 Safety-Relatea deuicment Safety-related equipment in the turbine building consists of one channel of safety-related cables which traverse the area.
5.18.2 Combustibles The combustibles in the turbine building consist of large quantit.ies of oil, hydrogen and electrical cable insulation.
5.18.3 Consecuences if No Fire Suceression The walls between the turbine building anf the control building and inter-mediate building have a fire resistance rating of at least 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, but they contain unrated caole and pipe penetrations and unlabeled doors.
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A detailed evaluation of unmitigated fires in the turbine building has not been completed, but a fire could spread to other parts of the plant through the penetrations mentioned above.
The severity of a fire here may exceed the fire resistance of the walls themselves.
The turbine building is a separate structure from adjacent buildings, however, and collapse of the turbine building should not affect them.
5.18.4 Fire Protection Systems Automatic sprinkler systems protect the ground floor and mezzanine' level.
Specific oil hazards on elevation 305 feet, including the hydrogen seal oil unit and the turbine lubricating oil reservoir, are protected by automatic deluge systems.
The turbine bearings are protected by a pqe-action system. Manual hose stations and portable extinguishers are*also provided.
5.18.5 Adecuacy of Fire Protecticn r
The licensee did not provide a detailed analysis of the safe shutdown consequences of possik.e damage due to a fire in this area in his original submittal, but has at. eed to provide such an analysis. We will address the adequacy of fire protection in this area in a supplement to this report.
5.18.G Modifications The licensee proposed to make the following improvements in the turbine building:
(1) Unlabeled doors in
- ..s between the turbine building and other buildings will be replaced with Class A labeled fire doors.
(2) Cable and piping penetrations in the turbine building walls and structural joints between the reactor building buttresses and the turbine wall will be sealed.
The staff's evaluation of the adequacy of proposed modifications, and any additional requirements, will be contained in a supplement to this report.
5.19 Air Intake Tunnel 5.19.1 safety-Relateo Ecuicment There is no safety-related equipment located in this area except some electric cables routid in the conduits.
5.19.2 Combustibles There are no combustibles located in the tunnel.during normal operation.
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5.19.3 Consecuences if No Fire Sucoression The tunnel is designed to maintain the selected plant areas safe for occupancy following a hypothetical aircraft crash on site.
Even without suppression, a fire in this area will be isolated automatically by redun-dant fire dampers.
Safe shutdown of the plant will not be affected.
5.19.4 Fire Prutection Systems In addition to redundant fire dampers described above, the tunnel ~is provided with smoke. detectors and flame detectors to actuate a deluge i
1 system and a total flooding Halon 1301 system.
Curbs and a sump are also provided to prevent the spread of a fire involving spilled aircraft fuel.
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5.19.5 Adecuacy of Fire protection The existing fire protection is adequate to contain and control a fire in this area.
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5.19.6 Modifications No modifications are needed in this area.
We find that fire protection for this area satisfies the obiectives identi-fied in Section 2.2 of this report and is', therefore, acceptable.
i 5.20 Yard Area i
5.20.1 Safety-Related EoSiement The safety-related equipment in the yard area includes two condensate storage tanks and a borated water storage tank.
5.20.2 Combustibles The combustibles in this area consist of fuel oil in an oil storage tank and transformer oil in the transformers.
5.20.3 Consecuences if No Fire Sucoression An unsuppressed fire involving one transformer would result in the probable loss of that transformer.
Fire barriers between transformers and drainage facilities would restrict the damage to one unit.
A fire in the fuel oil storage tank might affect condensate storage tank "A"; however, the redundant condensate storage tank "B" and the borated water storage tank are located on the other side of the plant and would not be affected.
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5.20.4 Fire Protection Systems Automatic water spray systems, actuated by heat detectors, are installed to protect each transformer in this area.
Hose lines from nearby hydrants are available for manual fire suppression.
5.20.5 Adecuacy of Fire Protection The existing fire protection is adequate to control and suppress a fire in this area.
5.20.6 Modifications No mcdifications are needed in this area.
l We find that the fire protection for this arca satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
5 5.21 Air Conditioninc Ecaicment Room - Fuel Handlina Buildina. Elevation 235 Feet 5.21.1 Safety-Related Eculon.9nt Safety-related equipment in this area includes both divisions of air cooling units serving the control building.
5.21.2 Combustibles Combustibles in this area consist of small quantities of lube oil and cable insulation.,
5.21.3 Consecuences if No Fire Sucaression The licensee did not evaluate in his initial submittal the effects of loss of control building air cooling on the habitability and instrumentation in the control building.
He has, however, agreed to provide such an analysis.
5.21.4 Fire Protection Systems A dry chemical portable extinguisher is available for manual suppression.
5.21.5 Adecuacy of Fire Protection We will address the adequacy of fire protection for this area in a supple-ment to this report.
5.21.6 Modifications We will identify any modifications necessary in this area in a supplement to this report.
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I 6.0 ADMINISTRATIVE CONTROLS The administrative controls for fire protection consist of the fire protec-tion organization, fire brigade training, the controls over combustibles and ignition sources, the prefire plans and procedures for fighting fires, and the quality assurance provisions for fire protection.
The licensee has provided a description of the elements of his administrative controls for fire protection, as detailed in the following sections.
6.1 Organization The licensee's' fire protection organization defines.the orgariizational responsibilities and lines of communication between the various positions involved in the fire protection program, the qualification requirements of 1
key positions in the fire protection program, and the composition of the i
fire brigade.
The fire protection organization encomcasses positions extending from the Vice President-Generation to the Station Shift 1
Supervisor.
These management and staff positions are responsible for i
formulation, implementation, and assessment of the fire protection program.
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The licensee has described the organizational responsibilities for inspec-cion, training, review of design changes, review of proposed work activi-ties and the station documents that define these and other responsibilities i
j as related to plant fire protection.
The licensee has described the cualification requirements that have been 2
established for the positions responsible for formulating and implementing the fire protection program, training instructions, and for service in the
- fire brigade.
In addition to the training requirements, the licensee will establish minimum physical qualification requirements for service in the fire brigade, and provide an annual physical examination for each fire i
brigade member.
The licensee has proposed a fire brigade of at least five members to be i
maintained on site at all times. The fire brigade will not include the operating shift. crew shown in Section 6.2.2 of the Technical Scecifica-tions or any other personnel required for other essential functions during 2
a fire emergency.
Based on the above, we find that the fire protection organization conforms to the staff document " Nuclear Plant Fire Protection Functional Respnsibili-ties, Administrative Controls and Quality Assurance" (" Administrative Controls")
transmitted to the licensee by letter dated August 4, 1977, and is, therefore, acceptable.
6.2 Fire Brigade Training The fire brigade training program consists of classroom instruction, The classroom instruc-practice in fire fighting and fire brigade drills.
tion is provided annually and includes instruction in the types of fires that could occur in the plant and their particular nazards; reporting 1488 273 em
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s fires; maintenance and use of the plant's fire fighting equipment; fire i
chemistry; nd fire fighting strategies and techniques.
Annually brigade members participate in training sessions in actual fire extinguishment.
Quartarly brigade memcers participate in preplanned fire brigade drills.
Thelicenseehasproposedtomadlytheformatofthebrigadetraining 1
program such that classroom instruction will be provided quarterly and the 3
entire program repeated within each two year period.
In addition, the scope of the classroom training instruction will be expanded to include:
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a detailed rev.iew of the plant's fire fighting procedures, prefire strate-gies, procedure changes, and plant modifications relating to manual fire fighting.
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We find that, sub.iect to implementation of the above described program-d 1
i matic changes, the fire brigade training ;rogram conforms to the guidance presented in the staff document " Administrative Controls" and is, therefore, acceptable.
6.3 Control of Combustibles Administrative controls have been established to limit the amount of 1
combustibles that a safety-related area may be exposed to.
These controls include:
housekeeping procedures; periodic inspections to determine the effectiveness of housekeeping practices; procedures and guidelines for use and storage of flammable, and/or volatile materials; and a review of l
maintenance requests and modifications 'for special fire protection require-ments.
Station procedures have been established for the use of combustible materials in the controlled areas of the plant, and to ensure that non-fire retardant treated waad is not used iriside buildir.gs containing safety-related i
I systems.
The licensee has proposed to revise the existing acministrative b
control procedures to further limit the amount of transient comoustibles i
that can be brought into safety-related areas of the plant.
I i
We find that, subject to implementation of the above described changes, i
the program established to control comoustible matarials in the plant conforms to the guidance presented in the staff document "Administrativ'e Controls" and is, therefore, acceptable.
- 6. 4 Control of Ionition Sources i
Administrative controls have been established to protect safety-related
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equipment from fire damage or loss resulting from work involving ignition i
sources. These controls include station procedures which require a work 1
permit to perform welding or flame cutting ocerations.
Issuing a hot work 1
permit requires review and signed approval by a responsible supervisor, an 1
inspection of the work area and the posting of a fire watch.
Plant proce-4 dures prohibit the use of open flames or combustion generated smoke for 1
leak testing.
Administrative controls to prohibit smoking i'1 safety-
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i related areas and in other plant areas containing major fire hazards will be impTemented.
1488 274 6-2 i
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We find that the procedures established to control ignition sources in the plant conform to the guidance presented in the staff document " Administrative
.i Controls" and are, therefore, acceptable.
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6.5 Fire Fichtina Procedures
}
The ifcensee has described the fire fighting procedures that have been
-i established to prescribe the actions to be taken by the individual discovering the fire, the control room operators and the memcers of the ~
fire brigade..
New plans covering fire fighting strategies for safety-related fire areas will be developed and documented.
Such plans will include a discussion of the combustibles, appropriate extinguishing agents, location of nearby i
fire fighting equipment, likely approach routes, location and prot'ection of safety-related and vital equipment, fire fighting hazards, location and handling of radiological and toxic ha:ards, and methods to ventilate the fire area.
Written agreements with local fire companies are maintained to assure adequate support for any fire emergency.
Officers and members of these
- fire companies have been given training and orientation at the station.
We find that, subject to implementation of the above described changes, i
the fire fighting plans and procedures conform to the guidance presented in the staff document " Administrative Controls" and are, therefore, acceptacle.
I
- 6. 6 Quality Assurance The design, procurement, installation, testing and administrative control i
activities for fire protection will be controlled in accordance with the i
approved Operational Quality Assurance plan, implementing the quality assurance program criteria of Appendix A to BTP 9.5-1.
Necessary changes i
will be made to.the procedures implementing the OQA plan to prescribe tne controls for fire protection.
2 We find that, subject to implementation of the above described changes, the quality assurance provisions for fire protection conform to the guidance presented in the staff document " Administrative Controls and are, therefore, acceptable.
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7.0 TECHNICAL SPECIFICATIONS The Technical Specifications were modified by Amendment No. 32, dated November 30, 1977, as corrected December 12, 1977, to include limiting q
conditions for operation and surveillance requirements for existing fire 1
protection systems and administrative controls.
Following the implemen-1 tation of the modifications of fire protection systems and administrative d
controls resulting from this review, the Technical Specifications will be i
similarly modified to incorporate the limiting conditions for operati,on
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and surveillance requirements for these modifications.
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1488 276 i
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CONCL'SIONS 8.0 U
3 The licensee has performed a fire hazards analysis and has proposed certain modifications to improve the fire protection program.
Additional modifica-i tions have been proposed by the licensee during the course of our review which are based upon the fire hazards analysis and our onsite evaluation i
of the fire protection program.
These proposed modifications are summarized in Section 3.1.
Significant steps are being taken to provide additional assurance that safe shutdown can be accomplished and the plant 1
can be maintained in a safe condition during and following potential. fire situations.
Additional evaluation of incomplete items, summarized im Section 3.2, will be necessary before we can conclude that the overall fire protection at Three Mile Island, Unit No. I will satisfy the provi-sions of STP 9.5-1 and Appendix A thereto, which the staff has established for satisfactory long-term fire protection.
We find that the licensee's proposed modifications described herein are acceptable both with respect to the improvements in the fire protection program that they provide and with respect to continued safe operation of the facility, while the remaining items are completed.
In the report of the Special Review Group' of the Browns Ferry Fire (NUREG-0050) dated February 1976, consideration of the safety of operation of all
~
operating nuclear power plants pending completion of our detailed fire protection evaluation was presented.
The following quotations from the report summarize the basis for our conclusion that the operation of the facility, pending resolution of the incomplete items and the implementa-tion of all facility modifications, does not present an undue risk to the health and safety of the public.
"A probability assessment of public safety or risk in quantitative terms is given in the Reactor Safety Study (WASH-1400).
As the result of the calculation based on the Browns Ferry fire, the study concludes that the potential for a significant release of radio-activity from such a fire is about 20 percent of that calculated from all other causes analyzed.
This indicates that predicted potential accident risks from all causes were not greatly affected by considera-tion of the Browns Ferry fire.
This is one of the reasons that urgent action in regard to reducing risks due to potential fires is not requi ed.
The study (WASH-1400) also points out that 'rather straightf rward measures, such as may already exist at other nuclear plants, can significantly reduce the likelihood of a potential core melt accident that mignt result from a large fire.'"
" Fires occur rather frequently; however, fires involving equipment unavailability comparable to the Browns Ferry fire are quite infre-quent (see Section 3.3 of NUREG-0050).
The Review Group believes that steps already taken since March 1975 (see Section 3.3.2) have
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reduced this frequency significantly."
8-1 1488 277
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" 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 of the Brcwns 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 euch can and should be done to reduce even further the likelihood of disabling fires and to improve assurance of rapid extinguishment of fires that occur.
Consideration should be given also to features that would increase further the ability of nuclear facilities to withstand large fires without loss of important functions should such fires occur.','
We have determined that the amendment does not authorize a change in effluent types or total amounts nor an increase in power level and'will not result in any significant environmental impact.
Having made this determinaLion, we have further concluded that the amendment involves an action which is insignificant frca the standpoint of environmental impact and, pursuant to 10 CFR 951.5(d)(4),'that an environmental impact statement, or negative declaration and environmental impact appraisal need not be prepared in connection with the issuance of this amendment.
We have concluded, based on the considerations discussed above, that:
(1)
.because the amendment does not involve a significant increase in the probability or consequences of accidents previously considered and does not involve a significant decrease in a' safety margin, the amendment coes not involve a significant hazards consideration, (2) there is reasonacie assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (3) such acticities will be conducted in compliance with the Commission's regulations and the issuance of this amendment will not be inimical to the cccmon defense and security or to the health and safety of the public.
Date:
O 8-2 W
y.
I I
9.0 CONSULTANT 5' REPORT f
Under contract to Nuclear Regula' tory Commission, Brookhaven National t.
Laboratory has provided the services of fire prctection consultants who 4
paticipated in the evaluation of the licensee's fire protection program a
i and in the preparation of this report.
Their report, " Fire Protection in Operating Nucl. ear Power Stations - Three Mile Island, Unit 1," dated September 1, 1973, and supplemented September 11, 1978, discusses several matters which have been addressed in this report. These elements of the consultants' recommendations which we have not adopted are identified in Appendix "B" along with our bases therefor.
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1488 279
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APPENDIX A CHRON0L'0GY NUREG-0500, " Recommendations Related to the Browns Ferry Fire."
In February 1976, the report by the NRC Special Review Group was
{
i On May 1, 1976, Standard Review Plan 9.5.1, " Fire Protection," was issued, incorporating the various recommendations contained in NUREG-0500.
By letter dated May 11, 1976, Metropolitan Edison Company was requested to compare the existing fire prctection provisions at their facilities,with new NRC guidelines as set forth in Standard Review Plan 9.5.1, " Fir'e i
Protection," dated May 1, 1976, and to describe (1) the implementation of the guidelines met, (2) the modifications or changes underway to meet the guidelines that will be met in the near future, and (3) the guidelines that will not be met and the basis therefor.
By letter dated September 30, 1976, Metropolitan Edison Company was requested to provide the results of a fire hazards analysis and propose i
Technical Specifications pertaining to fire protection.
Metropolitan Edison Company was also provided a copy of Appendix A which includes i
acceptable alternatives to the guidelines of SRP 9.5-1.
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By letter of December 2, 1976, we provided model Technical Specifications l
and requested submittal of fire protection Technical Specifications.
On February 10,'1977, Metropolitan Edison Company submitted proposed Technical Specifications for fire protection in response to car request of December 2, 1976.
On May 16, 1977, Metropolitan Edison Company provided a fire ha:ards analysis submittal responding to our requests of May 11 and September 30, 1976.
,0n August 12, 1977, Metropolitan Edison Comoany submitted a revised Fire Protection Technical Specification change, requesting amendment to the operating license.
By letter of April 17, 1978, Metropolitan Edison Comeany was provided with our requests for additional information and staff positions pertaining to fire protection at the Three Mile Island, Unit 1 facility.
On May 22-26, 1978, the DCR fire protection review team visited the Three Mile Island, Unit 1 facility.
On May,26, 1978, during the meeting at the plant, the review team identified additional staff positicns and ricuested Petro olite Edison Co muy to idicP..: their ce= itment to these positir.s.
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On June 12, 1978, Metropolitan Edison Company provided a submittal responding to our requests of April 17 and May 26, 1978.
By letter of June 28, 1978, Metropolitan Edison Company was requested to provide additional information and commitment to meet staff positions, pertaining to fire protection at the Three Mile Island, Unit 1 facility.
On July 14, 1978, Metropolitan Edison Company provided additional response to our request of April 17, 1978.
On July 20, 1978, Metropolitan Edison Company provided a submittal responding to our request of June 28, 1978.
On July 28, 1978, Metropolitan Edison Company provided information c'n the schedule for completion of their study of methods of fire door qualification.
By letter of August 4, 1978, Metropolitan Edison Company was requested to provide additional information and commitments to meet staff positions.
On August 15, 1978, Metropolitan Edison Company provided information on the fire hazards analysis that was performed for the Turbine Building.
By letter of August 17, 1978, Metropolitan Edison company was requested to providt additional information and commitments to meet staff positions.
On August 28, 1978, Metropolitan Edison Company responded to our requests of August 4 and 17, 1978.
By letter of August 31, 1978, Metrepolitan Edison Company was requested to provide commitments to staff positions.
On September 8, 1978, Metropolitan Edison Company responded to our request of August 31, 1978.
On September 18, 1973, Metropolitan Edison Company committed to provide completion dates for certain modifications by Septem:er 29, 1978.
1488 28;l A-2 O
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- x APPENDIX B 3.-
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DISCUSSION OF CONSULTANTS' REPORT Under contract to the Nuclear Regulatory Commission, Brookhaven National Laboratory has provided the services of fire protection consultants who participated in the evaluation of the licensee's fire protection program and the preparaticn of the Safety Evaluation Repcet (SER). Their report, " Fire Protection in Operating a
i Nuclear Power Stat' a - Three Mile Island Unit 1 (TMI-1) Safety Evaluation Report Review," and the supplement thereto present certain recommendations and t
comments. The consultant's recommendations and comments and our resolution of these matters is given below.
f_
Fire Water System Control Valve Supervision I
.1 It is recommended that electrical supervisica be required on all control valves in the fire protection systems protecting areas containing or exposing safety-relatad equipment.
i Staff Resconse:
The NRC guidelines on 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 tamcer proof seals. Periodic inspections are to be performed to verify that the method 1
of securing the valve is intact.
These measures are consistent with the requirements imposed for supervising valves in safety-re44ted 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 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 positicn.
Hydrotest of Fire Hoses Establish a program to hydro-test all fire hores at 220 psi and to maintain reccrds of such tests. The outside hoses to be tested annually and the inside hoses every three years.
Staff Response:
The facility technical specifications already contain a requirement that the hose at each hose station be hydrostatically tasted at least once per three years at a pressure at least 50 psi greater than the maximum pressure available at that hose station. Since the pump shutoff head is approximately 170 psig, this would make the maximum test pressure approximately 220 psig, which is in accordance with the consultant's recommendaticn.
1488 282 P
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- ..n The existing specification of a three year test pericd for outside hoses instead of cne year as recommendec, is based.cn the fact that hoses used at exterior stations are kept inside hcse houses where they are provided some protection from the deterioratina effects of sunlicht and weathe'.*,
We acree with the consultant, however, that this protecti6n is less than that received oy hoses stored within the facility. Accordingly, we shall request the licensee to increase the frequency of hydrostatic testing of hoses installed at outdoor stations to ence a year.
~
Use of Municical Fire Pumoer l
Create a site where a municipal fire pumper can take suction from the cooling tower basin and pump into the yard loop to supply a line for inside fire protection.
Staff Resocnse:
~
This is not required by Appendix A to STP 9.F-1 nor is it necessary for adequate fire protection. The number of fixed fire p mps (4) available to tne TMI-l fire water supply system exceeds the number and capacity requirements of Appendix A to BTP 9.5-1.
Further, cnly one of the four pumps is needed to supply the required fire fighting capability.
'n addition, one of the fixed diesel driven pumps is located in the circulating <.4ter pump house when it draws water frca the circulating water flume which is the same water source referred to by the consultant. Therefore, since the capability re:ccmendeo by the censultant already exists as a permanent installation, we do not agree that there is a need for an additional requirement.
Freeze Protection of Outdoor Hydrants Inspect all'outdcor fire hydrants for drainage of their dry-carrels immediately prior to freezing winter weather, and for prcper functioning immediately after the winter season.
Staff Resconse:
The licensee has made a ccmmitment to perform such inspections.
Use of Outdcor Hydrants for Fire Figh inc Inside Buildings Provide a 1-1/2" hose capability in the outside hydrant hose houses as folicws:
Cne 2-1/2" x l-1/2" gated wye with 150' of 1-1/2" hose and 2 adjustable 1-1/2" nozzles should be provided in each hose house where it may be necessary to extend yard hydrant service into the structure to back up other systems.
Staff Rescense:
The licens,ee has made a commitment to provide the above capability.
1488 283
I 7590-01 UNITED STATES NUCLEAR REGULATORY CCMMISSION DOCKET NO. 50-289 METROPOLITAN EDISON COMPANY JERSEY CENTRAL PCnER AND LIGHT CCMPANY AND PENNSYLVANIA ITECTRIC COMPANY NOTICE'0F ISSUANCE OF AMENDMENT TO FACILITY uPERATING LICEN5E
.1
' The U. 5. Nuclear Regulatory Commission (the Commission) has issued Amendment No. N to Facility Operating License No. DPR 50 issued to Metropolitan Edison Company, Jersey Central Power and Light Company and Pennsylvania Electric Company (the licensees), which revised the license for operation of the Three Mile Island Nuclear Station, Unit No. 1, located in Dauphin County, Pennsylvania. The amendment is effective
- - as of 11:s date of issuance.
This amendment adds a license condition relating to the ccmpletion of facility modifications for fire protection.
The Cornission has made appropriate findings as required by the Atomic Energy Act of 1954, as amended, and the Commission's rules and regulations in 10 CFR Chapter I, which are set forth in the license amendment. Prior public notice of this amendment was not required since the amendment does not involve a significant hazards consideration.
The Commission has determined that the issuance of this amendment will not result in any significant environmental impact and that pursuant to 10 CFR 551.5(d)(4) an environmental impact statement, or negative declkrationan:'environmentalimpactappraisalneednotbepreparedin 1488 284 connection with issuance of this emendment.
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7590-01 e
For further details with respect to this action, see (1) the licensee's submittals dated May 16, 1977, and June 12, July 14, July 20, ' July 28, August 15, August 28, and September 8 and 18,1978, (2) l Amendment No. 4/i to License No. DPR-50, and (3) the Comission's related Safety Evaluation. All of these items are available for public inspection at the Comission's Public Document Room,1717 H Street, N.W.,
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Washington, D. C. and at the Government Publications Section,. State Library of Pennsylvania, Box 1601 (Education Buildincj), Harrisburg, I
-A copy of nems (2) and (3) may be obtained upon request addressed to the U. S. Nuclear Regulatory Commission, Washington, D. C.
I 20555, Attention: Director, Division of Operating Reactors.
Dated at Bethesda, Maryland, this 19th day of September 1978.
i FOR THE NUCLEAR REGULAT Y COMMISSION
.f Robert W. Reid, Chief Operating Reactors Branch #4 Division of Ocerating Reactors l
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