ML19210C686

Responds to NRC Re Actions Taken on Concerns Stated in Fire Protection Safety Evaluation.Addl Fire Fighting Equipment Will Be Procured.Fire Water Sys Overpressurization Will Be Identified

ML19210C686
Person / Time
Site:	Calvert Cliffs
Issue date:	11/13/1979
From:	Lundvall A BALTIMORE GAS & ELECTRIC CO.
To:	Reid R Office of Nuclear Reactor Regulation
References
NUDOCS 7911190428
Download: ML19210C686 (36)

Text

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BALTIMORE GAS AN D ELECTRIC COMPANY GAS AN D ELECTRIC BUILDING BALTlMORE, MARYLAN D 21203 November 13, 1979 ARTHUR C. LUNOVA66,dR.

v.ct Passiot=T sumv Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C.

20555 Attention:

Mr. Robert W. Reid, Chief Operating Reactors Branch #4 Division of Operating Reactors

Subject:

Calvert Cliffs Nuclear Power Plant Units No. 1 & 2, Docket No. 50-317 & 50-318 Fire Protection Safety Evaluation Report and Amendments to Facility Operating License File:

013-261-0, L-037-F

Reference:

NRC letter dated September 14, 1979 from Reid to Lundvall, same subject Gentlemen:

The enclosures attached are submitted in response to the referenced letter which forwarded the NRC Fire Protection Safety Evaluation (SE) that identifies the modifications and concerns of the NRC staff. Enclosure 1 addresses modifications identified in Paragraphs 3.1.1 through 3.1.21. provides additional information as to " Incomplete Items" identi-fied in Paragraphs 3.2.1 through 3.2.11. provides additional responses and updates the status of " Unresolved Issues" identified in Para-graphs 3.3.1 through 3.3.7.

Additional information will follow later under separate cover rela-tive to Paragraphs 3.1.19, 3.1.20, 3.2.1, 3.2.2, 3.2.8, and 3.2.9.

Drawings and other data are now being prepared for NRC staff review.

Very trulyg ours,

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J. A. Biddison, Esquire G. F. Trowbridge, Esquire i

l} Messrs. E. L. Conner, Jr. - NRC f J. W. Brothers - Bechtel

1. 7911190 P

3.1.1 ENCLOSURE 1 3.1.1 Curb in Diesel Room (4.5, 5.18) The licensee has provided information showing that the curb will pre-vent a possible communication of spilled oil between two adjacent diesel rooms in Unit 1 area. The staff will address its evaluation in a supplement to this report.

Response

The curb identified as required to prevent possible communication of oil between the two adjacent diesel rooms in the Unit 1 area has been provided. Calculations have been provided previously to demonstrate that this curb is adequate. This item is complete subject to staff review. 3.1.2 Additional Fire Fighting Equipment (4.3.1.3, 4.3.1.4) The licensee will provide the following additional hose and equipment: (1) For each exterior hose cabinet (a) 200' of 2i" fire hose (single jacket, lined, synthetic) (b) One 2%" x 1%" x 1%" gated wye (c) One 2%" combination fog / straight stream nozzle rated at least 250 gallons pc: minute (d) One 1%" fog / straight stream nozzle rated at 60-90 GPM (e) Two each of 2%" and 1%" gaskets (2) For each portable equipment cabinet (a) 50' of 2%" fire hose (b) One Halligan type forcible entry tool (c) 100' of 1%" fire hose (3) For each interior hose station (a) One universal type hose spanne-that can be used as a hose valve wrench and as a hose coupling spanner 'for both 2%" and 1%" hoses. (4) At a suitable central location (a) One heat sensing device (b) 10 sets of fire fighting protective clothing; each set includes one turnout coat with removable liner, one helmet, one pair of boots and one pair of gloves. l I353 002

3.1.2

Response

The equipment identified above has been purchased and is available at the site. This item is completed. 3.1.3 Fire Water System Overpressurization (4.3.1.3) The licensee will identify and correct the cause of the fire water system overpressurization.

Response

As indicated in previous BG&E submittals dated April 19 and August 6, 1979, the cause of "overpressurization" has been identified with the on-off operation of the electric motor driven fire pump and its check valves. One half inch pressure relief valves are to be installed on all thirteen alarm check valves which trap pressure surges. These relief valves will be set to open at 175 psi. These pressure relief valves will be installed by October, 1980. 3.1.4 Marking of Fire Water Valves (4.3.1.3) The licensee will provide identification tags clearly marking post-indicator valves and control valves for fire protection water systems so that reference to written descriptions or reference number is not necessary to identify the systems or areas each valve controls.

Response

By December 1, 1979, each valve in the fire suppression water system, excluding instrument stops, are being provided with an identification tag. These are stainless steel tags which will identify the valve by number and provide sufficient description to facilitate the identity of the valves function by a qualified operator. 3.1.5 Breathing Apparatus Recharging System (4.4.3) The licensee will: (1) relocate the recharging system from the present location in ware-house No. I to a suitable central location within the Unit 1-Unit 2 operating area, (2) provide cooling water tank for each cascade system for air cylinders being recharged. 1355 003

3.1.5

Response

The recharging system has been relocated from Warehouse No. I to a central location inside the fenced yard within the Service Building. The cooling water tanks are on site and the installation will be completed before January 1, 1980. 3.1.6 Automatic Fire Suppression in Cable Spreading Rooms The licensee will install an automatic fire suppression system in each cable spreading room.

Response

A fixed automatic Halon 1301 fire suppression system is being designed and will be installed for each of the Cable Spreading Rooms. Its scheduled in service date is October, 1980. 3.1.7 Fire Water System Valves (4.3.1.1, 4.3.1.3) The fire water tank discharge valves are locked open. The fire water tank interconnection valve has been locked closed. All locked valves in the fire protection system will be checked monthly to verify their position.

Response

As indicated above in the SER, this item has been completed. 3.1.8 Miscellaneous Usage of Fire Water (4.3.1.1) An additional centrifugal pump, taking suction from the fire water tank standpipe and discharging to the fire protection system header, will be installed with adequate capacity to meet the intermittent use of fire water for purposes other than fire protection. Administrative procedures will be implemented to limit such usage of fire water to a single 1-1/2" hose stream at any time. In the event of a fire, non-fire fighting water usage will be terminated immediately.

Response

An additional electric driven centrifugal fire pump is to be installed by October, 1980, in the Turbine Building. This pump will have ade-quate capacity to meet intermittent use of fire water for purposes other than fire protection. The pump will take suction from the fire water tank standpipe and will discharge into the fire protection system header. This pump will be arranged to start and stop automatically. Administrative procedures have been established to insure that the fire system usage for purposes other than the fire fighting will be limited to a single 1-1/2" hose stream at any one time. 1355 004

3.1.9 3.1.9* Low Water Tank Level Interlock (4.3.1.2) The fire pump controller will be modified to remove the fire water storage tank low level interlock from the control logic. Alarms will be provided to annunciate, in both the control room and the fire pump house, low level in fire water storage tanks.

Response

BG&E will rewire each fire pump controller so as to defeat the present pretreated water storage tank low level interlock from the fire pumps control logic. This will be accomplished by removing control relay functions (initiated by low pretreated water storage low tank level) from each fire pump controller. This modification will prevent the fire pump from stopping on a low pretreated water storage tank level. Presently installed level sw'tches on the pretreated water storage tank now being used for fire pump control function will be modified to provide pretreated water tank low level alarms which will annunciate in both the control room and the fire pump house. These modifications will be accomplished by January 1, 1980 suoject to timely review and approval by the NRC staff. 3.1.10 Single Isolation in Fire Water Piping System (4.3.1.3, 5.18, 5.30) A 2-1/2" hose connected to Hydrant No. 5 will be prelaid to provide hose coverage for Diesel Generator Room No. 21, when the fire water supply to the automatic sprinkler system and manual hoses stations protecting these areas are valved out simultaneously.

Response

As indicated in the SER, this item has been completed. Technical Specification No. 3.7.11.2, Unit 2 covers this condition and CCI 133 specifically addresses the temporary corrective action required. 3.1.11 Portable Smoke Ejectors (4.4.1) Three portable smoke ejectors and associated portable ducting will be provided to aid in manual smoke removal. The ejectors will be of the explosion-proof type that are used for fire fighting and have a minimum combined capacity of 17,500 CFM.

Response

Three portable smoke ejectors and associated portable ducting have been provided to aid in manual smoke removal. The ejectors, two explosion-proof electric motor driven and one water-motor driven, provide a com-bined capacity of 17,500 cfm. This item has been completed. r

3.1.12 3.1.12 Battery Room Ventilation (4.4.4, 5.11) Te11 tales have been installed at the exhaust and supply air grills in each battery room and the air flow is being verified twice each shift.

Response

As indicate.2 ebove in the SER, this item has been completed and is considered acceptable to the NRC staff as indicated in Section 4.4.4. 3.1.13* Emergency Communication (4.7) Communication equipment will be provided which is capable of maintain-ing communication between the control room and all areas of the plant, including the interior of containment, considering possible damage due to a single fire.

Response

Existing plant communications systems include a page system and sound powered phone system which are capable of maintaining communications between the control room and all areas of the plant including the interior of the containment. An additional communications system will be provided which will also be capable of maintaining communica-tions between the control room and all areas of the plant including the containments. Adequate separation between this system and the existing communication systems including their respective power sup-plies will be provided to ensure that a single fire at any location cannot disable both systems. BG&E will furnish documentation to the NRC staff for review prior to implementing modifications. 3.1.14* Hydrogen Piping (5.4, 5.8, 5.9) An excess flow stop valve will be installed in the line to the hydro-gen supply to euxiliary building to automatically secure hydrogen to the building in the event of a piping system rupture.

Response

Design drawings and details will be furnished for NRC staff review prior to implementing the modifications described above in the SER. 1355 006

3.1.15 3.1.15* Addition of Curbs (5.9) The licensee will provide means to curb or contain a possible oil / solvent spillage in the hot machine shop and in the hot instrument shop.

Response

Both the hot machine shop and hot instrument shops have been provided with two inch curbs at their respective entrances to contain possible oil / solvent spillage to the rooms. These curbs are sufficient to con-tain 1640 gallons in the hot machine shop and 425 gallons in the hot instrument shop. Calculations are shown below. These modifications will be accomplished by June 1, 1980 subject to timely review and acceptance by the NRC staff. Q. ' l. I t3 Project - ((k Y@-/Od Est. No. 500M $AlLL 0AfhC/r/E3 f 6th Fc/E 19 ,) 3 p /br Mptamt Jace Voluine

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3.1.16 3.1.16 Control of Combustibles (5.9, 5.24, 5.26) All combustibles that are not required for the routine operation and maintenance of the plant will be removed from all safety-related plant areas. Storage of combustible materials necessary for the routine operation or maintenance of the plant will be limited to approximately one week's supply. Metal cabinets, removed from the vicinity of any safety-related cables / equipment will be provided for such storage.

Response

Storage of combustible material within safety related areas will be restricted to a one week supply of those materials required for routine operation and maintenance of the plant. Storage of combus-tible materials in excess of a one week supply inside or adjacent to safety related buildings or systems is prohibited except where such combustibles are stored in covered metal containers (i.e., drums or cabinets). No combustible material will be stored directly under safety related cabling or components. Combustible material which is removed from systems in the course of normal maintenance activities, such as charcoal filter material, will be properly packaged and removed from the vicinity of safety related equipment as soon as practicable. Transient Fire Loading.nside or adjacent to safety related buildings or systems during maintenance or modification will be minimized con-sistent with the requirements of the job. When transient combustibles are introduced into these areas, the responsible supervisor shall specify the additional fire protection, if any, required. He may be assisted by the Fire Protection Inspector as necessary in making this determination. Debris, scrap, rags, oil spills or other waste com-bustibles resulting from the work activity will be removed either after the completion of the activity or et the end of the.hift, whichever Comes sooner. At least weekly during normal plant operation, the Fire Protection Inspector will make a tour of all accessible safety related areas of the plant. During this tour, he will inspect for hazards as noted above. Should items presenting unacceptable risk be noted, the cog-nizant supervisor will immediately be notified to correct the hazard. Results of these inspections will be documented on a Fire Protection Inspector Report, which shall be retained for one year. During outages involving major work, in addition to the tours required above, the Fire Protection Inspector will make frequent inspections of the safety related work areas for fire hazards. Additienally, he will note equip-ment and materials used on the job which may change the combustible loading of the area and requite fire protection measures over and above the installed equipment. 1353 008

3.1.17 3.1.17 Dedicated Ladders (5.10) The licensee has provided a dedicated ladder of fiberglass construction in each cable spreading room to provide access to the areas above the battery rooms and the overhead cable chases.

Response

As indicated in the SER, this item has been completed. 3.1.18 Miscellaneous Protection for Control Room (5.16) (1) The licensee has provided a fog nozzle for the manual hose pro-tecting the room. (2) All wooden furniture and shelves will be removed from the control room complex except for work benches in the Log and Test Instru-ment Room. (3) Metal partitions will be provided to separate the adjoining panels from the computer terminal in the middle of the main panel.

Response

As indicated above in the SER: (1) The fog nozzle has been provided, (2) Wooden furniture and shelves will be removed except for work benches, and (3) We will relocate the printer from the bench board or provide a metal enclosure for printout paper. 3.1.19* Fire Detection in Safety-Related Areas (4.2, 5.1, 5.2, 5.3, 5.4, 5.5, 5.6, 5.7, 5.8, 5.9, 5.14, 5.19, 5.21, 5.27) The licensee has proposed to install appropriate fire detection devices in some additional safety-related areas. We will further evaluate this modification when the design details become available.

Response

To follow under separate cover. 1355 009

3.1.20 3.1.20* Unprotected Doorways (4.9.1, 5.1, 5.2, 5.4, 5.5, 5.7, 5.16, 5.18, 5.22) UL or FM listed fire doors of appropriate ratings will be installed, or acceptable alternate provided to protect the unprotected doorways in fire barriers separating various safety-related plant areas, including five doorways in the computer rooms currently provided with nonfire rated bullet-proof doors.

Response

To follow ender separate cover. 3.1.21* Manual Hose Coverage (4.3.1.4, 5.6, 5.12, 5.17, 5.19, 5.21, 5.24, 5.25, 5.26, 5.28) The licensee has performed hose reach tests and proposed to provide several additional hose stations. We will further evaluate this modification when the design details become available.

Response

The results of the hose stretch test are attached herewith. Additional hose stations are to be added as shown on the attached drawings. Cross-hatched areas identify areas beyond reach of preconnected fire hose. Next to the crosshatched areas, we have identified the fire loading characterized by less than one pound of combustibles per square foot. These low fire loads do not justify extension of the standpipe and hose stations. The new hose station design and installation is shown on Figure E-1 of the Fire Protection Program Evaluation, Type C hose sta-tion detail. Fire brigade response is assured as the crosshatched areas are within rooms equipped with automatic fire detection. The fire brigade is trained in hose laying evolutions and additional hose, both 1-1/2 and 2-1/2 inch, are available in strategically located por-table equipment cabinets. 1355 010

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?.2.1 ENCLOSURE 2 3.2.1 Fire Hazards Analysis (4.1, 5.1, 5.2, 5.3, 5.4, 5.5, 5.6, 5.7, 5.8, 5.9, 5.10, 5.12, 5.13, 5.14, 5.15, 5.16, 5.17, 5.19, 5.20, 5.21, 5.23, 5.24, 5.27, 5.28, 5.30) The licensee will provide the results of an analysis to: (1) demonstrare the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance, (2) identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area, (3) identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combustibles which may be introduced into or moved through the

area, (4) identify the worst damage that could result from such fire, and (5) demonstrate that such damage will not have a.. adver a effect on safe shutdown or cause excessive radioactive release to the environment.

The analysis will, as a minimum, include the following considerations: (il The possibility that redundant cables (in trays or in conduits)/ equipment may be involved in an exposure fire due to fixed or transient combustibles. (2) Effects of the fire and possible explosion, and fire fighting activities. (3) Shutdown capability without offsite power. (4) Safe shutdown consequences of possible system transients result-ing from a fire induced faulting of electrical cables. Where assumptions are made, such as operability of damaged cabling / equipment, or effectiveness of protection, etc., they will be sub-stantiated by the results of tests and/or analyses. In those plant areas where it cannot be demonstrated that safe shut-down capability can be preserved during and following the postulated fire, appropriate modification (s) will be provided to assure that the plant's shutdown capability will meet the following criteria as the minimum: 1355 017

3.2.1 (1) Following any fire, the plaat can be brought to hot shutdown conditions using equipment and systems that are free of fire damage. (2) The plant shall be capable of maintaining hot shutdown condi-tions for an extended time period significantly longer than 72 hours. (3) Fire damage to systems necessary to achieve and maintain cold shutdown conditions shall be limited so that repairs can be made and cold shutdown conditiona achieved within 72 hours. (4) Repair procedures for cold shutdown systems shall be prepared now and material needed for such repairs shall be on the site. (5) The hot shutdown condition shall be achieved with power from the offsite power system, and upon its it ss, with power from the onsite power system. A dedicated power supply may be sub-stituted for the onsite power systems. (6) The power needed to achieve the cold shutdown condition may be obtained from any one of the offsite power, onsite power, and dedicated power systems. (7) When these minimum systems are provided, their adequacy shall be verified by a thorough evaluation of: (a) Systems required for hot shutdown; (b) Systems required for cold shutdown; (c) Fire damage to power distribution s, stems; and (d) Interactions caused by f(re damage to power and water supply systems and to supporting systems, i.e., com-ponent cooling water supply.

Response

To follow us. der separate cover. 3.2.2 Adequacy of Detector Installations (4.2) The licensee will provide the results of a study or tests to verify that proper consideration has been given to such factors as ceiling height and configuration, ventilation air flow rate and pattern, location and arrangement of plant equipment and combustibles, etc. in determining the type, number and location of the existing and the proposed fire detector installations. , Response To follow under separate cover. 1355 018

3.2.3 3.2.3 Fire Pumo Flow Test (4.3.1.2) The licensee will perform full scale pump tests and furnish the results of such tests.

Response

Full-scale fire pump tests were performed August 29, 1979. These tests were witnessed by representatives of the American Nuclear Insurers (IRI personnel). The results of the tests are attached. 3.2.4 Ventilation Duct Penetrations (4.4.1, 4.9.2, 5.4, 5.5, 5.6, 5.9) The licensee has verified that all ventilation duct penetrations of fire barriers are protected with UL or FM listed fire dampers which will close automatically in the event of a fire, and the gap; between the ducts and the barriers are sealed. Fire rating of the dampers will be evaluated and appropriate modifications provided as necessary.

Response

The fire dampers provided in ventilation duct penetrations are fusible link dampers which have a 1-1/2 hour UL rating. This rating was eval-uated relative to inventoried fire loads across associated fire barriers, and this rating was found adequate. The fire hazards analysis has identified those areas where additional fire dampers are required to maintain fire separation. These addi-tional dampers will carry a 3 hour rating. The method by which the fire damper is installed in its associated wall or ceiling penetra-tion assures that all gaps between the dampers and the barriers are completely closed. This method was used for the original installa-tion of fire dampers and will be used for the additional ones as well. See the attached drawing detail. 3.2.5 Backflow Protection (4.5, 5.2) The licensee will provide the results of an analysis, including draw-ings or sketches of the drain systems as necessary, to demonstrate that the design of existing drain systems can prevent ti, backflow of combustible liquids to other safety-related areas, or to provide additional modifications to prevent such possibilities.

Response

Drains in safety related areas of the auxiliary building are con-nected to a common drainage system which empties into the miscella-neous waste receiver tank. The drain system consists of stainless steel floor drain fittings and connecting piping embedded in the floor concrete. Four inch lines are used as connecting headers for these drains in the upper elevations. The headers are tied to a six inch gravity drain which leads to the receiver tank at Elevation -10'-O". The piping from any given floor drain is embedded at least 12" below the floor. 1355 019

~ @"7 RECEIVED 3 13 surers sgp 17 1979 ANNUAL FIRE PUMP TEST SHEET ELEC. ENGR. DEPT. sC. ID. p _ G) RISK 3. 6,. -t[. DATE ? ?$ 19 'IT A m m.- kce Model or type sazets: Serial No.e zrge:rq 7s 2_ MAKE Rated capacity 2.cc>c:, gpm. at rated head r2.5 est., c: at rated speed /77o rpm. Net pressure at shuto:f_/jf3 psi. Net pressure at 150% rated capacity 72.3 pst. Brake horsepower at rated conditions 7_(.g.7 Max. brske H. P. at rated speed atTdy capacity /W.3 Horizontal, vertical, turbine / stages impeller dia. /B'/s inches. FUMP OPERATES: 'anual, Automatic Cut in Fs" psi Cut out/[Auu. psi. DRIVEN BY: Elec':ic motor; steam turbine; gasoline, diesel, engine; water wheel; no clutch. SUCTION FROM:.% lw Capacity geowe, Gals. Lift it. Vertical Turbine Discharge head to Water Level Ft. Head c3, e::, 6 Vertical Turbine Lowest Impeller to Water Level Ft. d-f um. Y? ?3 e JOCKEY OR MAKE-UP FUMP: m ke /6e.sr Typeggsated Capacity so gpm. Rated Head /GC usi., sr. Cut -in ffr psi., Cut-out /zr-psi. ~ Centrifucal or Positive Displacement Type. Relief Valve Setting _ No _pst. SPECIAL COMMENTS OAe.:er _P#&Lrw 4.ru/itu,E C6_FM" M P Q.ru y. '7I/5/ J22 ClllSed 1GML1, Lett -Oc Steam Pump Pressures

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I RECEIVED I 3.23 ++w SEP 171979 bEI 6 fe,3 ANNUAL I[ igg,PgfMtyEPTJiEET C.ID. K)_rs1 RISK 3. (3.+d. DATE E-Bt 19'T9 MAKE AwaAnts. -Nc:2fg Model or type SBE45 Serial No, h29)tts'(~f BE Rated capac2ty '2.5::o gpm.at rated head 1 Ls ps, 2::. at rated speed /74 c rpm. Net pressure at shutoff j p/.rpsi. het pressure at 1507; rated capacity _ 90 psi. Brake horsepower at rated conditionsde/z.c-Max. brake H.P. at rated speed at any capacity'2. f7 Horizontal, vertical, turbine / stages impeller dia. fg7e-inches. RJMP OPERATES: Manual, Automatic Cut in /co psi Cut out /74~ psi. DRIVEN BY: Electric motor; steam turbine; gasoline, diesel, engine; water wheel; no clutch. SUCTION FROM: S:c_b b Capacity Tcqoro Gals. Lift it. Vertical Turbine Discharge Head to Water Level Ft. Head tg 6, psi,. Vertical Turbine Lowest Impeller to Water Level Ft. t zr3 JOCKEY OR MAKE-UP PUMP: Makekey.o-s.Mes Type t.$3EqRated Capacity ~5 o gpm. Rated Head 15o p1 h. Cut-in i ts psi., Cut-out f z.s-psi. Centrifugal or Fositive Displacement Type. Relief Vaive Setting /o psi. SPECIAL COMMENTS T I?_sec:n. t tMER. Pump Pressures Steam Vertical Turbine Discharge at Gage to Water Level Inlet Jets Number and or slip Size of Suedon Stroke at 100 Streams Discharge Net Date Ft. of Hose Loca tion Pitot GPM PSI, Ft. PSI,Ft. PSI.Ft. R.P.M. Volts AMPS Insp- ' z%74 Cum b&_ l c) i I L-,5-13 1 15z ms i Po, 4-tce-I N' I M7474 f v1 E4oG>t t44 0;

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3.2.5 Spillage on Elevation -10'-0" and -15'-0" is drained to individual room sumps and then pumped to the waste receiver tank. Check valves prevent backflow to other rooms. At Elevation 5'-0" and above, spillage of combustible liquids in any given room will drain by gravity co the receiver tank. Connecting piping is sufficiently below the floor level to preclude transfer of combustibles to other safety related rooms. 3.2.6 Electrical Penetration Fire Resistance (4.9.3, 5.4, 5.5, 5.6, 5.9) The licensee will provide the results of a standard ASTM E-119 test to demonstrate the adequacy of fire resistance of the Calvert Cliffs elec-trical penetrations.

Response

The staff requested BG&E furnish a procedure for testing cable tray, pip-ing and conduit penetrations through walls and floors. This was done by our letter dated September 14, 1979 from Lundvall to Reid. NRC staff com-ments were received November 5, 1979 by telecopy and are now being evaluated. 3.2.7 Piping Penetration Fire Resistance (4.9.4, 5.4, 5.5, 5.6, 5.9) The licensee will provide the results of a standard ASTM E-119 test to de-monstrate that piping penetrations have fire resistance ratings commensu-rate with fire hazards on both sides of the barriers.

Response

Refer to Item 3.2.6 " Response". 3.2.8 Radiological Consequences of Fire (4.14, 5.3, 5.7, 5.9, 5.20, 5.24, 5.25) The licensee will provide the results of a study of radiological consequen-ces of a fire in areas containing radioactive materials (including a fire in a charcoal or a HEPA filter), or other areas where a fire could cause the release of radioactive materials. Additional modifications will be provided in areas where a fire could cause the release of radioactive materials that could oreclude the normal usage or occupancy of areas sur-rounding the plant.

Response

To follow under separate cover. 3.2.9 Effects of Fire on Radiation Monitors The licensee will provide the results of a study to demonstrate that the radiation monitor will remain operational when exposed to smoke and/or heat of a potential fire.

Response

1355 023 To follow under separate cover.

'.2.10 3.2.10 Fire Water Drainage (4.5) The licensee will perform an additional study, following the comple-tion of hose reach tests and addition of interior hose stations and other automatic water systems, to verify that fire water drainage in all safety-related areas is adequate and possible fire water accumu-lation in any safety-related area will be acceptable.

Response

Thelargestgostulatedfireisonethatactuatesasprinklercoverage A sprinkler actuation of this magnitude could occur in of 3,000 ft. one of the following three areas: No. 419 (Cask and Equipment Loading Area), Nos. 228 and 201 (Component Cooling Water Pump Rooms, Units 1 arealessthan3,000ft.gledareasintheauxiliarybuildinghavean and 2). All other sprin , so the largest flow rate of fire water will come from one of these three areas. Also, there are three hose stations which could serve each of the areas. If a fire were to actuate 3,000 ft.2 of sprinkler coverage and 3 hoses were used in any one of the three rooms, the drain capacity of the room would be exceeded. In addition, if we assume that the miscellaneous waste receiving tank is full at the start of the fire (all drains will flow into this tank), the drainage will overflow from the tank to a sump, fill and overflow the sump, and begin to flood elevation -15'-0". The area being sprinkled will accumulate up to two inches of water but no more, as the water will flow down the staircases and eventually reach elevation -15'-0". Some fire water may backflow from the drains to other areas, but this will eventually drain down to the bottom elevation without significant accumulations. At elevation -15'-0" only the corridor, Area 100, will flood as the other areas at this elevation are provided with watertight doors. Ele-vation -10'-0" will begin to flood, and this is acceptable up to the top of the equipment pedestals. For fire water to reach this point, the sprinklers and hose stations would all have to operate continuously for at least 60 minutes. It will actually take longer for all the water to reach the bottom elevation, as the water will not instantaneously flow down. Considering all fixed and transient combustibles andtheoperationof3hosesandacoverageof3,000ft.gnthearea, of sprinklers, 60 minutes would be adequate to extinguish a fire in these areas. The effects of fire water drainage in all of the other areas in the auxiliary building would be less severe with the exception of the ECCS pump rooms, Areas Nos. 118, 119, 102, and 101. For fire fighter admis-sion to these rooms, a watertight door must be opened. Fire water could accumulate up to the top of the equipment pedestals in this room. Two hose stations can serve any of the rooms. With a fire in one of the smaller ECCS pump rooms, the miscellaneous waste receiving tank full, and two hoses used, it would take 48 minutes to flood the room but this would not prevent safe shutdown as the redundant room would be sealed from flooding by watertight doors. These time periods would be suffi-cient to extinguish a fire within the room. 13L3 024

3.2.11 3.2.11 Control Air (4.15) Loss of control air to the salt water system valves causes the service water heat exchanger and the component cooling water heat exchanger inlet and outlet valves to fail open. The licensee will provide the results of his study to verify that possible over-cooling of service water and/or component cooling water will not have adverse effects on the plant safety.

Response

Loss of control air to the salt water system valves causes the service water heat exchanger and component cooling water heat exchanger inlet and outlet valves to fail open with a resultant decrease in service water and component cooling water temperatures. This failure mode is consistent with the positions to which the valves would automatically be positioned in the event of an Engineering Safety Features Actuation. Therefore, all equipments serviced by component cooling or service water are designed to accept this reduced temperature water with no adverse impact on plant safety. This includes the diesel generators which utilize service water to cool integral jacket cooling, air cool-ing, and lube oil cooling heat exchangers. Overcooling of these systems is prevented by thermostatically actuated valves which bypass service water around the heat exchangers to maintain jacket cooling water 170-185 F, scavenging air 100-1150F, and lube oil 190-2050F. 135a 0,2u-r r

3.3.1 ENCLOSURE 3 3.3.1 Halon System Backup Power (4.3.2) The licensee has nct provided sufficient justification for not pro-viding backup power for the Halon suppression systems.

Response

The staff accepted the existing Halon systems power supplies without further modification during a meeting held on October 2, 1979. 3.3.2 Emergency Lighting (4.6) The licensee has not provided sufficient justification for not replac-ing the existing 1-1/2. hour rated batteries of the emergency lighting units with those of 8-hour rating. The distribution of existing emer-gency lighting units has not been demonstrated to provide adequate lighting for shutdown operation and fire emergency responses.

Response

The normal lighting throughout the plant is fed from the station aux-iliary transformers. The normal / emergency lighting in the Control Room consists of normal AC/ emergency AC and emergency DC. Upon loss of AC power, the emerger.cy DC lighting in the Control Room is provided from the 125 volt station batteries. (DC Control Panel Bus 24). Also, the emergency AC is provided by the auxiliary busses which are fed by emergency diesel generators upon loss of offsite AC power. The normal AC/ emergency AC lighting is provided for Cable Spreading Room (elevation 27'-O") and Switchgear Rooms (elevation 27'-0" and 45'-0"). The eme~gency AC is provided by the auxiliary busses which are fed by the emergency diesel generators upon loss of AC power. For personnel safety and safe egress during the period of time it takes the diesel generator to pick up the lighting load, less than 5 minutes, battery-operated emergency lights have been provided. These battery-operated emergency lights actuate immediately upon loss of normal AC power. All safety related areas of the plant contain fixed emergency lighting units, which have individual batteries and are presently rated for 1-1/2 hours. These units are automatically actuated upon loss of nor-mal AC pcwer. We will replace the existing 1-1/2 hour units with new 8 hour battery-operated units in the areas listed below. The new units will be Exide Model B-200, or equal. (See attached literature.) 1355 026

s.1. 2 @) Exibi EXIDE EMERGENCY LIGHTING An Economical 12 Volt SYSTEMS Unit or System O 7 Totally Maintenance Free with o o 0 O New Model H Lamps q { a u g g Model B-200_12-volt Universal 120/277 V AC input l Model B-200 with Model H Halogen ACCESSORIES lamps provides high efficiency emergency lighting protection economically. A unit D ADDITIONAL D WIREGUARD mounts up to three Model H lamps. MODEL H 1 AMPS PROTECTORS As a system, all 13 lamps can be remotely mounted. Two maintenance-free LEC-36 O WALL MOUNTING D EXPLOSION batteries are used. They need no watering BRACKET PROOF FIXTURES and operate unattended for their 10 year or longer lives. There are no moving O REMOTE FIXTURES O ADJUSTABLE parts-the internal components are all l TIME DELAY solid-state. The pulse-type charger keeps D ILLUMINATED. the battery up to charge; the switch EXIT SIGNS See Accessories circuit insures instantaneous load transfer Section on AC failure; the protector circuit prevents excessive discharging. S. .f}gg s. x r.. a _a it - = llllll!llll!!,! ~~ ~ j, ;m... _. _..'. , - -e- ~7 - Z.;:-;g:, _ t L ./ w 4 7 xn- -M r .lyadjiliiiilIliIllI D < E 5b ggw -J @s- @ @ 1355 027 .5 + 39.A,

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3 3. b 1 Sp'ecifications D0 ']l n d 4 LIGHTGUARDE EMERGENCY LIGHTING MODEL B-200 OPERATION ' DIMENSIONS gI Model B-200 provides emergency light automatically Approx. S and instantaneously on failure of normal AC power. Assembled wt. \\ QM h HlulHHliUI HHIUHE 77 lbs. RATING 35 kg ,u- - u i..o ACINPUT l DC OUTPUT ] .Q, j.,j * * * " VOLTS l WATTS NN.I b MODEL VOLTS HERTZ PHASE WATTS l 12 l 200 s-200 120/277 60 1 60 g"7'8HIHHHI INSTALLATION N -aim =- N Unit is easily field connected for a 120 or 277 voE \\

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60 Hz,tmswitched power source. It should comply PROTECTOR AND SWITCH CIRCUITS with the National Electric Code and all other Solid-state circuits continually monitor both AC and applicable codes. DC current. The switch circuit.mstantly connects CASE lamps to battery on AC failure, and disconnects The 18 gage steel container and 20 gage steel door are them when normal power is restc, red. The protector coated with an acid-resistant gray finish. The battery, circuit automatically monitors battery output and and the charger and controls are in separate switches off the lamps when rated illumination time compartments. Internal access is through the front is reached, preventing excessive discharging. panel, piano hinged on the left, and held closed by All components operate at 50% of their rating to two screws on the right. insure reliability and long life. N l D' N PS i Rated t!!uminationTime-Hoursof Light j To s7.5% Of initial voltage (12 Volts) Front mounted are a " PRESS-TO-TEST" switch for Case can mount ~ quick testing of lamps and battery; an amber ready-three horizontally l No.of12 Watt Lamps Hours of Light light; a red light indicating fast charge rate; and a and vertically adjustable Model H 4 3 vo'tmeter indicating battery voltage. Within the unit high efficiency 7 4 is a ready /off switch. 13 5 r-3 028 12 watt 13 1.s ORDERING INFORMATION halogen lamps. EXAMPLE: B-200 - 2H Lamps can be remotely mounted also. 5ee accessory sheet 5-0 for detail specifications and light Model No. of distribution curves. Lamps CHARGER

• See accessories section to order accessories Solid-state pulse type charger restorestattery to full charge within 12 hours after a discharge not over s H H H H H i i!H Hi" Hi"! H" H H i n i H "'H " t u !" H H H "" T i H " H "" H " H """"s 1.5 hours, with a 200 watt load. Charger also monitors 5

5 ei.oe ucNicuano battery voltage, and charges on fast rate when 5 sn--ia veAa savremy cuanANice g necessary. Components operate at less than 50% of E re. ac.,... ..s. ..,use.co. + E rating to insure reliabili'y and long lif 2. E O "Tf/'#*J."4*A*' 'O.*IT' T '.*4J'O'/I"J'u'J' 5 g ;.pl,,,';f C,'?::. : 22;f2.. ';'?7:, **s'C,'*g' f,;,te,~.; E ?:?; %T E y BATTERY iwo LEC-36 batteries are used. E

l;'O,7*y,, ".;T,';',,'01;;'!ltl ;'*;/',:",,Jl.'?,'l.", ',*/. 5 The LEC-36 is a 3-cell,6-volt, sealed lead-aod calcium-E. #.'".T.'?.0,';. * 'J,l',!!,"!.'!J!,'?ll 'J.4'YO" TE alloy grid battery. It has a 36 ampere hour capacity at 5

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i the 8 hour rate, at 77'F., to 87.5% of initial voltage. E E'O'$!IN E*E"!7f='?/El,*U U ""l25$ 5 E "El#*I El=~IE E *A.4 fU*<SIla"5'I N #'~E/* T 5 (ARTICLE 700-7 NEC) E 'C 9 I g gy.Y.;4*.7,,',g" *;",'. '5y pg'4;.;? YTA"'.!,,#.;i".%',',.. <4,

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,yg.,g; i Positive plates have a s. ingle insulation of m.icroporous separators. The battery case is a high-impact, heat g pyygg,g'ggypj;;,.gy-lal,yll;74 ;;<,a,g";y. g i resistant, transparent plastic container with perma-g aa';;,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,...,,, nently sealed cover preventing electrolyte leakage. The E gi!'neMtsis '"'"' *a' *****" ] '"'"c""' battery operates entirely unattended and needs no E 5 s""'""'"""Hi""i"""""'"""""H"""""'"'""""""""""'"""'" watering or maintenance for 10 years or longer. EXIDE LIGHTGUARD i ESB WILT. SON CANADA LTD. ESB INCORPORATED ) et T Form 79412/77 racNTON ONTARIO RANQQL.PM, MASS 02368 -J 3-9A

3.3.2 Corridors 100, 103, 104, and 120 (elev. -10' and -15') Corridors 200, 202, 203, 212, and 224 (elev. 5' and 10') Corridors 300, 308, 309, 315, 319, and 327 (elev. 27') Corridors 410 and 426 (elev. 45') Corridors 506, 517, and 522 (elev. 69') Stairtowers AB-1, AB-2, AB-3, AB-4, AB-5, and T-3 Auxiliary Feed Water Pump Rooms 603 and 605 (including passageway in Heater Bay) Diesel Generator Rooms 416, 421, and 422, Room 419 Automatic Steam Dump Valve Rooms 408 and 428 Auxiliary Feed Water Valve Rooms 310 end 316 Fire Pump House 3.3.3 Fire Door Supervision (4.9.i) fhe licensee has not provided sufficient justification for not provid-ing electrical supervision or locking closed those fire doors which are presently not supervised or locked. Aesponse The staff has under study earlier responses and additional information developed during the October 2, 1979 meeting and will address its evaluation in a supplement to this report. 3.3.4 RC Pump Lube Oil Collection System (5.19) The licensee has not provided sufficient justification to demonstrate that: (a) The existing system provides a complete containment for all potential leakage points which include lift pump and piping, external oil cooler, flanged connections, drain plugs, fill points, upper and lower reservoirs, sight glasses and over-flow lines. (b) The copper drain tubing does have adequate capacity to accommo-date drainage of a large oil leak. (c) Draining collected oil on the containment floor is safe. (d) The effects of a seismic event on this system will not adversely affect the plant safety.

Response

An oil spillage protection system will be provided for each reactor coolant pump motor. The system will consist of encapsulating devices which will be installed around potential leakage points and will be sized to protect against a major oil leak. Typical motor components to be encapsulated are: lube oil lift pump, lube oil cooler, con-necting flanges and oil reservoir drainage points. Piping from the 1355 029

3.3.4 encapsulations will accommodate a major oil leak and will be inter-connected to a common drain leading to an oil spillage collection tank located at elevation 10'-0". Two collection tanks will be installed in each containment, sized to accommodate the largest potential oil leak. Each of the tanks will service two reactor coolant pump motors. The piping from the oil spillage protection systems to the tanks as well as the tanks themselves will be seismically supported. The tanks will be a UL approved standard design and will be vented to ensure proper system drainage. A drain valve will be provided on each tank to per-mit oil removal. Detailed design of the oil spillage protection system when complete will be furnished for staff review prior to implementation of these modifications. 3.3.5 Fire Pump Separation (4.3.1.2) The licensee has not demonstrated that the sprinkler system installed in the fire water pump house provides equivalent protection to the 3-hour fire barrier in limiting the effect of a fire at the diesel fire pump, or its fuel tank, on the electric fire pump.

Response

The fire pump house is protected by automatic sprinklers. A repro-duction of the sprinkler design drawing is attached. The sprinkler system water supplies consist of two - 2500 gpm at 125 psi U/L approved horizontal centrifugal pumps taking suction from two - 500,000 gallon pretreated water storage tanks and a 15,000 gallon pressure tank (10,000 gallon nominal capacity) located remote from the fire pump house. A make-up pump is to be installed which also will serve as an additional water supply. Automatic sprinklers will control temperatures and extinguish fires involving combustible liquids in the Fire Pump House. In NFPA Standard 30, the Flammable and Combustible Liquids Code, automatic sprinklers are recommended for protection of flammable and combus-tible liquid hazards. American Nuclear Insurers specifically recommended automatic sprinklers to protect against fires in the Calvert Cliffs Nuclear Power Plant Firs Pump House. It is anticipated that both the electric motor and engine driven fire pumps will properly function in the event that the sprinklers are actuated and discharging in the Fire Pump House. The fire pump controllers have NEMA 3 drip-tight weather resistant enclosures which are elevated on foundation pedestals. The electric pump foundation pedestal and base plate are 16 inches above the floor 1353 030

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3.3.5 so that air intaken are elevated more than 20 inches. The elec-tric motor is enclosed to NEMA Type MG1-1.25A Drip-Proof specifi-cations (i.e., motor ventilating openings are so constructed that successful operation is not interfered with when water particles strike or enter the enclosure at any angle from 0 to 15 degrees downward from the vertical). The diesel engine is also supported on a pedestal and steel base plate and the engine is qualified to operate when exposed to weather conditions subject to freeze pro-tection. The pump room floor is pitched to floor drains to pre-clude communication of water or fuels from one pump to another. The diesel fuel oil tank is provided with a dike to contain its contents. Attached is a hydraulic calculation of the in situ automatic sprinkler system for the pump house. The hydraulic calculation shows that at least 5 psi can be maintained at the most remote sprinkler head with all sprinklers in the Fire Pump House opera-ting when supplied by the 500,000 gallon pretreated water storage tanks which are 40 feet high. The Factory Mutual System has selected 5 psi because it is the approximate minimum required for effective sprinkler discharge. Further, it should be recognized that an additional centrifugal pump is to be installed as required in Item 3.1.8. This pump will be capable of supplying the sprinkler demand for the Fire Pump House and will have a power supply independent of the Fire Pump House. This pump will be located in the Turbine Building to take suction from the fire water tank standpipe and will dis-charge into the fire protection system header. 3.3.6 Fire Fighting Strategies (6.1) The licensee has not provided sufficient justification that the fire fighting strategies he has developed for seven areas in the plant are adequate for all plant areas.

Response

Fire fighting strategies are being developed for the following plant areas which either contain significant quantities of com-bustible material or which would pose unusual problems for the fire brigade combating a fire in that area. All strategies will be completed by August 1, 1980. I355 034

3.3.6 Room No. Description (-) 10' Aux. Bldg. 101 Safety Injection Pumps & Spray Unit 2 102 Unit 1 118 119 115 Charging Pump Rm. Unit 1 " Unit 2 105 111 Waste Processing Control Rm. 5' Aux. Bldg. 226 Service Water Pump Rm. Unit 1 225 Rad Exhaust Vent Equip. Rm. Unit 1 224 Piping Area Unit 1 202 Passage 228 Component Cooling Pump Rm. Unit 1 201 " Unit 2 203 Piping Area Unit 2 205 Service Water Pump Em. Unit 2 223 Hot Machine Shop 222 Hot Instrument Shop 204 Rad Exhaust Vent Equip. Ra. Unit 2 27' Aux. Bldg. 320 Spent Fuel Pool Cooling Rm. 315 Main Steam Piping Rm. Unit 1 309 Unit 2 317 Switchgear Rm. Unit 1 318 Purge Air Supply Unit 1 1355 035

3.3.6 Room No. Description 311 Switchgear Rm. Unit 2 312 Purge Air Supply Unit 2 301 Battery Rm. Unit 1 304 305 " Unit 2 307 45' Aux. Bldg. 405 Control Rm. 423 k'est Elect Pent Rm. Unit 1 414 " Unit 2 418 Solid Waste Handling Rm. 408 Piping Area Unit 2 409 East Elect Pent Rm. Unit 2 407 Elect Equip. Rm. Unit 2 (2A) Cable Chase Unit 2 (2B) 428 Piping Area Unit 1 429 East Elect Pent Rm. Unit 1 430 Elect Equip. Rm. Unit 1 (IA) Cable Chase Unit 1 (IB) 419 Equip. Loading Area 5Si 036

3.3.6 Room No. Description 69' Aux. Bldg. 512 Control Rm. HVAC Equip. Rm. 520 Spent Fuel Pool Area Vent Rm. 524 Main Plant Exhaust Rm. Unit 1 526 " Unit 2 522 Hot Laboratory Rad Chem. 529 Elect. Equip. Rm. Unit 1 " Unit 2 532 530 Cask Handling Area 12' Turbine Bldg. 603 Auxiliary Feed Pump Rm. Unit 1 " Unit 2 605 Intake Structure 1101 Warehouse Storage Area 602 Auxiliary Steam Gen. Rm. 3.3.7 Quality Assurance (6.2) The licensee has not provided the comparison of his quality assurance program and the guidelines.

Response

A Fire Protection Quality Assurance Procedure (QAP) will be completed and a comparison of the QAP and the guidelines will be provided by January 1, 1980. 1355 037}}