ML19224D659

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Safety Evaluation Supporting Amend 18 to License DPR-66
ML19224D659
Person / Time
Site: Beaver Valley
Issue date: 06/06/1979
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML19224D657 List:
References
NUDOCS 7907130323
Download: ML19224D659 (79)


Text

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v SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 18 TO FACILITY OPERATING LICENSE id. DPR-66 DUQUESNE LIGHT COMPANY OHIO EDISON COMPANY PENN$YLVANIA POWER COMPANY BEAVER VALLLY POWER STATION UNIT NO. 1 DOCKET NO. 50-334 Introduction By letter dated June 17, 1976, Duquesne Light Company replied to the Conmission's May 24, 1976 request to comparc the existing fire pro-tection provisions at its facility with the NRC guidelines as set forth in Standard Review Plan 9.5.1, " Fire 'rotection", dated May 1, 1976.

The Duquesne Light Company response was detailed in its October 27, 1976 letter and Technical Specificiations w.ere proposed by the licensee in its February 11, 1977 letter.

By letter dated September 24, 1978 and supplemented by letter dated December 11, 1978, Duquesne Light Company responded to t~..a Commission's request for additionc! information letter dated July 18, 1978.

By letter dated January 11, 1979 and supplemented by letter dated Fet.,ary 21, 1979, Duquesne Light Company submitted its schedule for fire protection modifications.

Amendment No.11 to Facility Operating License No. DPR-66 for BVPS, Unit No.1, was issued on November 30, 1977. The amendmer' incorporated Fire P, otection Technical Specifications on existirg equip cut and administrative controls.

In order to correct a licensing oversight and to eliminate a conflict in intent, Specification 4.0.4 should be revised.

Our evaluation of this item is included herein.

By letter dated April 19, 1979, the licensee submitted a proposed change to Appendix A Technical Specification Table 3.7-4 to include all Category I hydraulic snubbers.

By letter dated December 'i, 1978, the licensee submitted a request for change to Appendix B of the Technical Specifications, Section 3.1.2 Chemical Releases.

$[g Evaluation

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Fire Protection Our evaluation and conclusions regarding the Fire Protection progri.m for the Beaver Valley Power Station, Unit No.1 are included in the attached

" Fire Protection Safety Eva'uation Report" dated May 3,1970.

The conclusions of this report apply in full to the apper.ded Safety Evaluation Report.

7 907130 MC [

. Implementation of Fire Protection Surveillance A potential conflict exists between the intended implementaticn of surveillance activities associated with Fire Protection Technical Specifications issued with Amendment No.11 for BVPS and the provisions of Specification 4.0.4.

It was and is necessary to insure an effective level of fire protection not become effective immediately upon the effective date of the license amendment but rather within the time period allowed for completion of the surveillance activitiy.

In order to eliminate the potential conflict in intent, Specification 4.0.4 should be modified by adding the following:

"The provisions of Specification 4.0.4 are not applicable to the performance of surveillance actions associated with fire protection Technical Specifications 4.7.14 and 4.7.15 until the completion of the initial surveillance interval associated with each specification."

The licensee has agreed to this wording.

Hydraulic Snubbers The NRC requires Technical Specifications governing the operability of all snubbers required to ensure the safe operability of the reactor ccolant system and all other safety-related systems. This requirement and the inspection frequency is further detailed in the Bases section of the Technical Specifications. During the original preparation of the hydraulic snubber Technical Specification, the licensee misunderstood these NRC requirements and listed only ASME Class I hydraulic snubbers.

However, the reactor coolant and other safety related systems are also protected by ASME Class 2 and 3 snubbers.

Therefore, in order to fully comply with the Commission's requirements, the licensee has expanded Table 3.7.4 to list all safety related system snubbers (which include those whose failure might affect a safety related system).

The licensee's proposed additions to Table 3.7.4 are acceptable.

Chemical Releases The licensee proposes to delete the test of the present Environmental Technical Specification 3.1.2 Chemical Releases, and replace it with an updated version of the specification for chemical releases that is presently being used in the Standard Environmental Technical Specifications.

This action would remove the uncertainty associated with interpretation of the monitorino and reporting required by the existing specification.

We find this to be a minor modification which does not change the limits or the intent of the existing Technical Specifications.

Therefore, the proposed change in ETS 3.1.2 is acceptable.

414 1is

. Environmental Consideration 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 determinatiorr, we have further concluded that the amendment involves an action which is insignificant from the standpoint of environmental impact and pursuant to 10 CFR 50.5(d)(4) that an environ-mental impact statement or negative declaration and environmental impact appraisal need not be prepared in connection with the issuance of thi s amendment.

Conclusion 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 does not involve a significant hazards consideration, (2) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (3) such activities will be conducted in compliance with the Commission's regulations and the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.

Date: June 6,1979 Appendix: May 3,1979 SER, " Fire Protection Safety Evaluation Report" f

414 113

FIRE PROTECTION SAFETY EVALUATION REPORT BY THE_

0FFICE OF NUCLEAR REACTOR REGULATION U.S. NUCLEAR REGULATORY COMMISSION IN THE MATTER OF DUQUESNE LIGHT COMPANY BEAVER VALLEY PO'JER STATION - UNIT 1 DOCKET NO. 50-334 MAY 3, 1979 414 1if

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TABLE OF CONTENTS PAGE 1-1

1.0 INTRODUCTION

2-1 2.0 FIRE PROTECTION GUIDELINES......................................

2.1 General Design Criterion 3

" Fire Protection".............

2-1 2-1 2.2 Supplementary Guidance.....................................

3-1 3.0

SUMMARY

OF MODIFICATIONS........................................

3-1 3.1 Fire Brigade...............................................

3-1 3.1.2 Equipment..............................................

3-1 3.1.1 Training...............................................

3-1 3.1.2 Procedures.............................................

3-2 3.2 Instrument Air Supply......................................

3.3 Reactor Containment (Fire Suppression).....................

3-2 3-2 3.3.1 Cable penetration Area.......e.........................

3-2 3.3.2 Auxiliary Feedwater System.............................

3-2 3.3.3 Component Cooling Water Pumps..........................

3-2 3.3.4 RHR Pump........................................

3-2 3.3.5 Cable Spreading Area...................................

3-2 3.3.6 Cable Vault............................................

3-2 3.3.7 Hose Stations..........................................

i g/1 #4

3.4 Exterior Ho3e Houses......................................

3-2 3.5 Hydrant and Post Indicator Valve Guard Posts..............

3-3 3.6 Fire System Value Supervision.............................

3-3 3.7 Exterior Fire Hydrant Inspection..........................

3-3 3.8 Welding, Cutting, Grinding and Open Flame Work Procedures.

3-3 3.9 Maintenance of Fire Equipmer.t Inventories.................

2-3 3.10 Turbine Lube Oil Reservoir................................

3-3 3.11 Diesel Generator Room.....................................

3-3 3-3

3. ll. l Drain System.........................................

3.11.2 011 Line Break.......................................

3-4 3.11.3 Curbing..............................................

3-4 3.11.4 Three Hour Fire Door.................................

3-4 3.11.5 Fire Rating Penetration..............................

3-4 3.11.6 Sump 011 Level Detection.............................

3-4 3.11.7 Manual Actuating Station.............................

3-4 3.12 Control of Unnecessary Combustibles.......................

3-4

  • 4 3.12.1 Fla=mable Liquids....................................

5 3.12.2 Fire Retardant Wooc..

3.12.3 Trash Containe s.....................................

3-5 3.12.4 Waste Storage........................................

3-5 3.12.5 Stairwells...........................................

3-5 3.12.6 Procedures...........................................

3-5 414 Iles 11

4.3.1 Water Systems.........................................

4-3 4.3.1.1 Water Supply.....................................

4-3 4.3.1.2 Fire Pumps.......................................

4-3 4.3.1.3 Fire Water Piping System.........................

4-4 4.3.1.4 Interior Fire Hose Stations......................

4-7 4.3.1.5 Water Suppression Systems........................

4-8 4.3.1.6 Effects of Water Suppression Systems.............

4-9 4.3.1.7 Foam Extinguishing Systems.......................

4-9 4.3.2 Gas Fire Suppression Systems..........................

4-10 4.3.3 Portable Fire Extinguishers...........................

4-11 4.4 Ventilation Systems and Breathing Equipment...............

4-11 4.4.1 Smoke Removal.........................................

4-11 4.4.2 Filters...............................................

4-12 4.4.3 Breathing Equipment...................................

4-13 4.5 Floor Drains..............................................

4-13 4.6 Lighting Systems..........................................

4-14 4.7 Communication Systems.....................................

4-14 4.8 Electrical Cable..........................................

4-16 4.9 Fire Barrier Penetrations.................................

4-14 4.9.1 Fire 9aors............................................

4-14 4.9.2 Ventilation Duct Penetrations.........................

4-15 4.9.3 Electrical Cable Duct Penetrations....................

4-15 4.9.4 Piping Penetrations...................................

4-16 414 f j.

iv

3.13 Fire Rating Penetrations..................................

3-5 3.13.1 Cable Fire Stops-Auxiliary Building..................

3-5 3-5 3.13.2 Ceiling-Cable Spreading Room.........................

3-5 3.14 Charging Pump Cubicle.....................................

3-6 3.15 Fire Hoses................................................

3-6 3.15.1 Booster Hoses........................................

3-6 3.15.2 Testing..............................................

3-6 3.16 Gas Cylinder Storage......................................

3.17 Floor Panel Lifter-Process Control Room...................

3-6 3.18 Cable Spreading Room-Fire Suppression.....................

3-6 3.19 Cont rol Room-Fire Supp res sion.............................

3-6 3.19.1 Detection in Vertical Panels.........................

3-6 3-6 3.19.2 Separation of Kitchen Area...........................

3.19.3 Portable Extinguisher................................

3-6 3-7 3.20 Hydrogen L1nes............................................

3-7 3.21 Ba t t ery Ro om Ven t ila t ion..................................

3-7 3.22 Smo k e Ej e c t o r s............................................

3.23 Main Station Intake Structure.............................

3-7 3-7 3.24 QA Program................................................

Table 3.1 Implementation Dates for Proposed Modifications......

3-8 4.0 EVALU ATI ON OF P LANT FEATURF.S...................................

4-1 4-1 4.1 Safe Shutdown Systems.....................................

4-1 4.2 Fire Detection and Signaling A

em.......................

4-3 4.3 Fire Control Systems......................................

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4.10 Separation Criteria..,.................................

4-16 4.11 Fire Barriers.............................................

4-17 4.12 Access and Egress.........................................

4-18 4.13 Toxic and Corrosive Products................

4-18 4.14 Nonsafety-Related Areas...................................

4-18

5. 5 EVALUATION OF SPECIFIC PLANT AREAS 5-1 5.1 Co n t r o l Ro o m C R-1.........................................

5-3 5.2 Control Room CR-2.........................................

5-4 5.3 Co n t r o l Ro o m C R-3.........................................

5-5 5.4 Control Room CR-4.........................................

5-6 5.5 Reactor Containment RC-1..................................

5-7 5.6 Cabling Spreading Room CS-1...............................

5-8 5.7 Emergency Switchgear Rooms ES-1 and ES-2..................

5-9 5.8 No rmal Switchgear Ro om NS-1...............................

5-10 5.9 Battery Rooms.............................................

5-11 5.10 Diesel Generator Rooms DG-1 and DG-2......................

5-13 5.11 Radwaste Building PA-1....................................

5-15 5.12 Fuel Oil Storage Areas....................................

5-16 5.13 Intake Structure..........................................

5-17 5.14 Yard Area.................................................

5-19 5.15 Mo to r G en e ra t o r Ro om MG-1.................................

5-21 5.16 Turbine Building..........................................

5-22 5.17 Miscellaneous Areas.......................................

5-24 5.18 Cable Tunnel CV-3.........................................

5-25 AI4 ll9 V

6.0 ADMINISTRATIVE CONTR0LS........................................

6-1 7.0 TECHNICAL SPECIFICATIONS.......................................

7-1 8-1 8.0 CONSULTANTS ' REPORT...

9-1

9.0 CONCLUSION

S.................................................

A-1 APPENDIX A, CHRON0 LOGY..............................................

44 I2G c

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1.0 INTRODUCTION

Following a fire at the Browns Ferry Nuclear Station in March 1975, the Nuclear Regulatory Commission initiated an evaluation of the need for improving the fire protection programa at all licensed nuclear power plants. As part of this continuing evaluation the NRC, in February 1976, published a report by a special review group entitled, "Recommenda-tions Rela'.ed to Browns Ferry Fire," NJREG-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 vithstand fires without the loss of important functions.

To implement the report's recommendations, the NRC initiated a program for re-evaluation of the fire protection programs at all licensed nuclear power stations and for a comprehensive review of all new license applications.

The NRC issued new guidelines for fire protection programs in nuclear power plants which reflect the recommendations in NUREG-0050.

These guidelines are contained in the following d<euments:

a)

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

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

b)

" Guidelines for Fire Protection for Nuclear Power Plants" (Appendix A to BTP APCSB 9.5-1), August 23, 1976.

c)

" Supplementary Guidance on Information Needed for Fire Protection Program Evaluation," October 21, 1976.

d)

" Sample Techneial "pecifientions," May 12, 1977.

e)

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

f)

" Manpower Requirements for Operating Reactors," memo from E. G.

Case to R.

Boyd, V. Stello, and R. Mattson dated Ma7 11, 1978.

All licensees were requested to:

(1) compare their fire proter. tion programs with the new guidelines; and (2) analyze the consequeaces of a post ulated fire in eac:, plant area.

1-1 h

I c' d n

We have reviewed the licensee's analyses and have visited the plant to examine the relationship of safety-related r.omponents, systems and 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 public health and safety. We have not considered aspects of fire protection associated with life safety of onsite personnel and with property protection unless they impact the health and safety of the public due to potential release of radioactive material.

This report summarizes the status of our evaluation of the fire protection program at Duquesne Light Company's Beaver Valley Power Station Unit No.

1.

1-2 414 12:q.

2.0 FIRE PROTECTION GUIDELINES 2.1 General Design Criterion 3

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

" Structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions.

"Noncombus~ible and heat resistant materials shall be used wherever practical throughout the unit, particularly in locations such as the containment and the control room.

" Fire detection and 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 tmpair the safety capability of these structures, systems, and components."

2.2 Supplementary Guidance Guidance on the implementation of GDC-3 for existing nuclear power plants has been provided by the NRC staff in " Appendix A" of Branch Technical Position 9.5-1, " Guidelines for Fire Protection for Nuclear Power Plants".

A,uendix A provides for a comprehensive program assuring a substential level of fire protection, beyond minimums that might be deemed to satisfy GDC-3.

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

2-1 f

(1) reduce the 11xelihood of occurrence of fires; (2) promptly detect and extinguish fires if they occur; (3) maintain the capability to safely shut down the plant if fires occur; and (4) prevent the release of a significant amount of radioactive material if fires occur.

We have used the guidance of Appendix A as appropriate in our review.

We have evaluated alternatives proposed by the licensee to various specific aspect s of Appendix A using the overall objectives outlined above to assure that these objectives are met for the actual relationship of combuctibles, safety related equipment and fire protection features of the facility.

2-2 h?

3.0

SUMMARY

OF MODIFICATIONS The licensee plans to make certain plant modifications to improve the fire protection eogram as a result of both his and the staff's evaluations.

r The proposed modifications are summarized below. The implementation schedule for these modifications is in Table 3.1.

The licensee has agreed to this schedule.

The sections of this report which discuss the modifications are noted in parentheses.

Certain itemn listed below are marked with an asterisk to indicate that the NRC staff will require additional information in the form of design details, test results, or acceptance criteria to assure that the design is acceptable prior to actual implementation of these modifications.

The balance of other modifications has been dee ribed in an acceptable level of detail.

3.1 Fire Brigade A fire brigade of at least five (5) members will be maintained onsite at all times.

3.1-1 Training The licensee will comply with the requirements of attachment No. 2 of the NRC guidelines " Nuclear Plant Fire Protection Functional Responsibilities".

(v.l.2) 3.1-2 Equipment A suitable area will be provided for the etorage of fire brigade equipment.

(4.3.1.3) 3.1-3 Procedurqs Procedures will be developed to establish fire fighting strategies for specific safety-related areas.

(6.1.5) 3.2 Instrument Air Supply Air supply lines to valves necessary for r4Ee shutdown will be provided with adapters for use with bottled gas as the emergency power source.

(4.1) 3-1 IA l 2<f'~

3.3 Fire Suppression

  • 3.3-1 Reactor Containment Cable Penetration Area A remotely operated, mans,11y activated open head water spray system will be proviord for each redundant cable penetration area.

(4.2)

(4.2)

  • 3.3-3 Component Cooling Water Pumps PA-1F Fire detection and automatic suppression will be added for the Component Cooling Water Pumps.

(4.2)

  • 3.3-4 Residual Heat Renoval Pump Fire detection and automatic suppression will be added for the Residual Heat Removal Pu=p.

(4.2)

  • 3.3-5 Cable Spreading Area CS-1, CV-1, CV-2 Fire detection coverage conforming to NFPA-72 recommen-dations will be verified.

(4.2)

  • 3.3-6 Cable Tunnel CV-3 Fire detection, and rapid access hatchway will be added to the cable tunnel.

(5.18)

  • 3.3-7 Hose Stations Additional hose and/or hose stations will be provided to ensure coverage of electrical circuits and equipment necessary for safe shutdown.

(4.3.1.4) 3.4 Exterior Hose Houses Additional equipment will be added to existing equipment in the exterior hose houses as necessary.

Inoperative door latches on the hose houses will be repaired or replaced.

(4.3.1.3) 3-2 IA 12Li

3.5 Hydrant and Post Indicator Value Guard Posts A survey of all Hydrants and Valve Posts will be performed and guard posts installed in areas where they are subject to vehicular traffic damage.

(4. 3.1. 3) 3.6 Fire Suppression System Valves Supervision Valves in the fire water suppression system will be either electrically supervised or provided with tamper-proof seals and administratively controlled.

(4.3.1.3) 3.7 Exterior Fire Hydrant Inspection A semi-annual inspection (Spring and Fall) will be conducted of exterior hydrants to ensure that hydrant barrels are dry and the threads are lubricated. An annual operational hydrostatic test of hydrants will be perf>rmed to verify barrel integrity following the winter freeze.

(4. 3.1. 3) 3.8 Welding, Cutting, Grinding and Open Flame Work Procedures Administrative Procedures and Controls will be developed and imple-mented to meet the intent of NFPA-51B for surveying work areas prior to starting work, establish fire watches, issue proper equipment and safety certification.

(6.1.4) 3.9 Maintenance of Fire Protection Equipment Inventories Tamper indicating seals will be inst (.11ed on all fire protection equipment storage enclosures.

(4.3.1.3) 3.10 Turbine Lube Oil Reservoir The curbed area beneath the turbine lube oil reservoir will be increased in height to centain the entire volume of the tank plus a margin for fire suppression water.

(5.16) 3.11 Diesel Generator Rooms (5.10) 3.11-1 Drain Systems The drains in the diesel generator rooms will be plugged.

(5.10.6.5) 3-3 f hhf

3.11-2 011 Line Break A method will be provided to disable the diesel oil transfer pumps to the emergency diesc1 generator day tanks.

(5.10 6.4) 3.11-3 Curbing The curbing will be of sufficient height to prevent an oil spill in one room from entering the adjacent room.

(5.10.6.1) 3.11-4 Three-hour Rated Fire Door An additional three-hour rated fire door will be added opposite the existing door between the two diesel generator rooms.

(5.10.6.2; 4.9.1) 3.11-5 Fire Rating of Penetrations Cable, Conduit and pipe penetrations through the wall separating the two diesel generator rooms will have a minimum three-hour fire rating.

(5.10.7) 3.11-6 Sump Oil Level Detection A level detection device, which will annunciate in the control room, will be installed in the sump close to the day tank to detect oil accumulation due to a leak.

(5.10.6.6) 3.11-7.

Manual Actuating Station The manual actuation pull station for the C0, a.c.

y extinguishing system will be relocated outside the diesel generator room it in protecting.

(4.3.2; 5.10.o.3) 3.12 control of Unnecessary combustibles 3.12-1 Flac=able Liquids - Auxiliary Bldg - Elevation 768'-6" Fire proof cabinets will be provided for flammable liquids.

(6.1.3) 3-4 A1

't, '4 13 iL

3.12-2 Fire Retardant Wood All untreated lumber and wood items in safety-related areas will be removed. All lumber and wood required for use in safety-related areas will be treated, fire retardant lumber. Large wooden timbers may be coated with a fire retardant compound.

(6.1.3) 3.12-3 Containers Approved trash containers made of sheet metal and equipped with self closing covers in safety-related areas.

(6.1.3) 3.12-4 Contaminated Waste Storage The contaminated waste storage area will be relocated in a new building having sprinkler protection.

(5.11) 3.12-5 Stairwells Fla=mable materials stored in stairwells will be removed.

(Completed)

(6.1.3) 3.12-6 Procedures Administrative Controls will be established and implemented to control combustibles in safety related areas.

(6.1.3) 3.13 Fire Rated Penetrations 3.13-1 Cable Fire Stops - Fire Wall Penetrations All fire barrier penetrations in safety-related areas will be ;roperly sealed and all flammable materials used for damming vill be removed.

(4.9.3; 4.9.4) 3.13-2 Ceiling - Cable Spreading Room Penetrations between the cable spreading room and the control room benchboards will be upgraded to three-hour rated fire barriers.

(5.1.6) 3.14 Charging Pump Cubicle Smoke detectors will be installed in each charging pump cubicle with alarm annunciation in the control room.

(4.2) 3-3 I4 129

3.15 Fire Hose 3.15-1 Booster Hose - Water Sensitive Areas Hose coverage for the switchgear and Instrument area will be provided by installations of 1 1/2 inch cotton, rubber lined hose and a 12-30 gpm variable gallonage and adjustable spray nozzle with ball valve shutoff.

A 1 1/2 to 1 inch reducing adapter will also be provided.

(4. 3.1. 4 )

3.15-2 Testing All hoses stored outdoors or in unheated buildiag areas will be hydrostatically tested every 18 months.

Hoses stored in heated areas will be tested every three (3) years.

(4. 3.1. 3) 3.16 Gas Cylinder Storage Gas cylinders will be stored in racks designated for this purpose.

(6.1.3) 3.17 Floor Panel Lifter - Process Control Room A dedicated floor panel lifter will be provided in a wall mounted break glass front box in the process control room.

(5.4.6) 3.18 Cable Spreading Room - Fire Suppression Cables required for safe shutdown will be rerouted or provided with isolation capability from the cable spreading room.

(5.6) 3.19 Control Room - Fire Suppression

  • 3.19-1 Detectors in Vertical Panels Early warning detectors will be provided in the walk through section of the vertical control board panels.

(4. 2; 5.1)

  • 3.19-2 Separation in Kitchen Arca A one-hour rated fire barrier will be installed between the kitchen area and the control room operations area.

(5.1.5) 3.19-3 Portable Extinguishers A dry chemical extinguisher will be installed on the wall adjacent to the cooking range and a 2 1/2 gallon pressurized water extinguisher will be provided at each entrance to the control room.

(5.1.6) 3-6

3.20 Hydrogen Lines All hydrogen lines in safety-related areas will be identified by color coding or lettered markers affixed to the pipe.

(5.1.6) 3.21 Battery Room Ventilation A flow switch will be installed in the exhaust flow ducts to monitor the air flow with an alarm in the control room upon absence of air flow.

(5.9.6) 3.22 Smoke Ejectors Three (3) 5000 CFM, portable, explosion-proof fire service scoke ejectors with suitable ducting will be provided.

(4.4.1) 3.23 Main Station Intake Structure - Elevation 713'-6" An automatic fire detection system will be installed in the intake structures IS-1, 2 and 3.

(4.1) (5.13. 6) 3.24 QA Program The fire protection QA program is under developement.

The program will incorporate the requirements of section 2.2.

(6.1.6) 414

!)f 3-7

TABLE 3.1 Implementation Dates for Proposed Modifications Schedule Position In effect 3.1 Fire Brigide In effect 3.1-1 Trainirg December 31, 1979 3.1-2 Equipment 3.1-3 Procedures (Pre-fire Plans)

December 31, 1979 June 39, 1980 3.2 Instrument Air Supply 3.3 Fire Suppression 3.3-1 Reactor Containment Cable Penetration 1981 Refueling Outage Area October 31, 1980 3.3-2 At xiliary Feedwater System October 31, 1980 3.3-2 Component Cooling Water Pumps 1981 Refueling Outage 3.3-4 RHR Pump October 31, 1980 3.3-5 Cable Spreading Area 3.3-6 Cable Tunnel October 31, 1980 3.3-7 Reactor Containment Hose 1981 Refueling Outage Stations December 31, 1979 3.4 Exterior Hose Houses 3.5 Hydrant and Post Indicator Valve October 31, 1980 Guard Posts June 30, 1979 3.6 Fire System Valve Supervision 3.7 Exterior Fire Hydrant Inspection June 2.,

1979 3.8 Welding, Cutting, Grinding and Open July 31, 1979 Flame Work Procedures 3.9 Maintenance of Fire Equipment Inventories Jur.e 30,1979 October, 1980 3.10 Turbine Lube 011 Reservoir fj 3-8

s 3.11 Diesel Generator Rooms July 31, 1980 3.11.1 Drainage System 3.11.2 011 Line Break 3.11.3 Curbing 3.11.4 Three-hour Fire Door 3.11.5 Fire Rating of Penetration 3.11.6 Sump Oil Level Detection 3.11.7 Manual Actuating Stations 3.12 Control of Unnecessary Combustibles 3.21.1 Flammable Liquids June 30, 1979 3.12.2 Fire Retardant Wood December 31, 1979 3.12.3 Trash Containers June 30, 1979 3.12.4 Combustible Waste Storage October 31, 1980 3.12.5 Stairwells Completed 3.12.6 Procedures December 31, 1979 3.13 Fire Rating of Penetrations and Barriers 3.13.1 Cable Fire Stops - Auxiliary Bldg December 31, 1979 3.13.2 Ceiling - Cable Spreading Room Complete 3.13.3 Fire Wall Penetration - Switchgear December 31, 1979 Rooms 3.l'+ Charging Pump Cubicle December 31, 1979 3.15 Fire Hoses 3.15.1 Booster Hoses July 31, 1980 3.15.2 Testing June 30,1979 3.16 Gas Cylinder Storage January 31, 1979 3.17 Floor Panel lifter - Process Control Room June 30,1979 3.18 Cable Spreading Room - Fire Suppression October 31, 1980 3-9 414 133

~

3.19 Control Eoom - Fire Suppression 3.19.1 Detection in Vertical Panels June 30, 1979 3.19.2 Separation of Kitchen Area December 31, 1979 3.19.3 Portable Extinguishers March 31, 1979 3.20 Hydrogen Lines June 30, 1980 3.21 Battery Room Ventilation December 31, 1979 3.22 Smoke Ejectors December 31, 1979 3.23 Service Building - Intake Structures Octcber 31, 1980 3.24 QA Program September 30, 1980 fUf 3-10

4.0 EVALUATION OF PLANT FEATURES 4.1 Safe Shutdown Systems There are several arrangements of safe shutdown systems which are capable of achieving safe shutdown subsequent to a fire.

The exact arrangement available in a fire situation will depend upon the ef-fects of the fire on such systems, their power supplies and control stations.

To preclude a single event from affecting redundant systems, these systems are separated into two safety divisions, either of which would be capable of achieving safe shutdown.

The four primary functions to be maintained for a safe shutdown are:

1.

Negative reactivity insertion 2.

Reactor coolant system volume control 3.

Reactor coolant pressure control 4.

Decay heat removal To implement the above primary functions, the following secondary functions must be available:

1.

Motive power 2.

Auxiliary cooling Negative reactivity insertion is provided by the control rods for hot shutdown and by the boron injection system for additional negative reactivity needed for cold shutdown.

The reactor coolant system volume control function is required for safe shutdown.

The auxiliary feedwater system is available for emergency shutdown of the facility. The auxiliary feedwater system delivers water to the steam generators to remove both sensible and decay heat for hot shutdown.

The licensee has proposed to install air supply lines to pneumatic valves necessary for safe shutdown with adapters such that bottled gas can be used as a backup emergency power source for these valves for manual operation. We find that this modification satisfies the objectives identified in Section 2.2 and is, therefore, satisfactory.

4.2 Fire Detection and Signaling Systems The plant is provided with a fire detection and alarm system con-sisting of manual pull stations throughout the plant and fire de-tectors located in various safety-related and high hazard areas.

Ionization type detectors are utilized in most of the detection 4-1 f h,h'

systems with heat type detectors used to actuate fixed CO, and water deluge systems. Detector spacing in the plant was found to be generally more conservative than the spacing guidance outlined in NFPA 72E and should result in reasonable detector response times.

Fire detectors are located in the following safety-related areas:

Ionization Fire No. of Detectora Zone Plant Identification 5

ES-1 Emergency SWCR Room A 1

Battery Room 1 1

Battery Room 3 5

ES-2 Emergency SWGR Room B 1

Battery Room 2 1

Battery Room 4 4

MG-1 MG Rod Control Room CR-4 Process Inst. & Rod Position 12 2

CR-2 Air Cond. Equip Room 2

Puup Room 2

CR-3 Co=munication Equip. Room 13 NS-1 480 & 4160 SWGR Room 7

CR-1 Control Room 1

Office 2

Computer Room 3

DG-1 Diesel Generator Room 3

DG-2 Diesel Generator Room 31 CS-1 Cable Tray Mezzanine 3

CV-1 West Cable Vault 2

West Cable Tunnel 3

CV-2 Eest Cable Vault 2

East Cable Tunnel The detector and pull station circuits are connected to a central processor unit in the control room.

An alarm or trouble signal will immediately sound an audible signal and will display the location, status and type of alarm.

Actuation of a detector or pull station will ale; sound all the station fire alarm horns.

kfk 3

4-2

The licensee has stated that the installed system is in conformance with NFPA 72D and all circuits are supervised to indicate loss of power, undervoltage, short circuits, open circuits or ground faults.

Actuation of fixed C0 and water extinguishing systems are arranged 9

to alarm and annunciate at the fire alarm panel in the control room.

The plant does not have complete fire detection coverage and some areas containir.g or esposing safety-related systems do not have fire detection systems.

The licensee has proposed to install additional fire detectors in the following locations:

1.

Containment - cable penetration areas 2.

RHR Pump Area 3.

Charging Pump Cubicles 4.

Auxiliary Feedwater Pumps 5.

Control Roca - Vertical Control Board Panels 6.

Intake Structure - Zones 1S-1, 1S-2 and IS-3 We find that, subject to implementation of the above described modifications, the fire detection systems satisfy the objective identified in Section 2.2 of this report and are, therefore, acceptable.

4.3 Fire Control Systems 4.3.1 Water Systems 4.3.1.1 Water Supply Water for firefighting is obtained from the Ohio River through two separate pumps and pipe lines leading to the underground fire water loop.

We find the supply adequate to meet the anticipated fire protection demands of the plant.

4.3.1.2 Fire Pumps The water supply for fire protection is previded by two 2,500 gpm @ 135 psi vertical fire pumps. One of the pumps is diesel engine driven and the other is electric motor driven.

The 4-3 414 130

fire water system is pressurized by an electric motor driven jockey pump and a hydro pneumatic surge tank.

The fire pumps are arranged for automatic sequential starting upon a pressura drop in the piping system. The pumps can also be etarted remotely from the control room or from local control panels.

Shutdown of fire pumps is by manual actuation at the local control panels.

The fire pumps are located in the intake structure in separate seismic Class I cubicles with 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated separation.

Valves controlling the flow of water at the suction and discharge lines of the pumps are provided with wire seals affixed to the handwheels for tamper indication.

Alarued displays are provided in the control room for the following fire pump functions:

1.

Motor driven fire pump running 2.

Motor driven fire pump loss of control power 3.

Motor driven fire pump controller trip 4.

Engine driven fire pump running 5.

Engine driven fire pump non-auto control 6.

Engine driven fire pump trouble.

This common trouble alarm monitcts lov oil pressure, high engine jacket water temperature, failure of engine to start automatically due to excessive cranking, shutdown from overspeed, or low battery potential.

7.

Low level in fire protection fuel oil tank The fire pumps are considered adequate to supply the fire protection water requirements of the plant and are, therefore, acceptable.

4.3.1.3 Fire Water Piping System Separate 12 inch discharge lines from the diesel engine driven and electric motor driven fire pumps supplies the 12 inch underground loop which encircles the plant.

Post indicator type valves are strategically located along the fire loop which provides sectionalized control and isolation of portions of the fire main loop.

The licensee will implement supervision of the post indicator sectionalizing valves to assure they are 414 1s,ja 4-4

in the open position by means of electrical switches and alarme or chains, locks or tamper proof seals with administrative procedures conforming to NF"A 26.

Ihe arrangement of the sectionalizing valves insure that a single break in the system will not deprive water supply to both primary and secondary protection systems in the fire zone.

Yard hydrants with isolation curb box valves are installed along the yard loop at intervals of approximately 250 feet.

Each hydrant has two 2-1/2 inch hose valves with National Standard fire hose thread which is compatible with the responding offsite fire departments.

Fire hose reel cabine:s (hose houses) and fire hose cart houses are located around the perimeter of the plant at approximately 300 foot intervala.

Each fire hose reel cabinet contains:

Quentity Item Description Ea. Cabinet 1

Hose with couplings, 1-1/2 inch in reel 3 x 50 ft.

cabinet 2

Adjustable nozzles 3

3 Hose reducers 2-1/2 female to 1-1/2 male 3

4 1-1/2 inch hose washers 3

2 5

Coupling spanners 2

6 Spanner brackets 7

Double female coupling 1

gIh 4-5 1

/'#

Each hose cart house is equipped with:

Quantity Item Description Each House 1

Hose with couplings, 1-1/2 inch in cart 3 x 50 feet house with storage racks 2

1-1/2 inch adjustable nozzles 2

3 Nozzle brackets 2

4 Fixed axe 1

5 Fire axe brackets 1 pr.

6 Crowbar 1

7 Crowbar brackets 1 pr.

4 8

Coupling spanners 4

9 Spanner brackets 10 Hose and ladder straps 2

it Hose reducers 2-1/2 female 2

to 1-1/2 female 12 1-1/2 inch hose washers 2

2-1/2 inch hose washers 2

13 Double female coupling 1

14 Hose cart 1

15 Hose w/ couplings, 2-1/2 inch on cart 100 feet 16 2-1/2 inch x 1-1/2 inch x l-1/2 inch 1

valved "Y" 2

17 Hydrant wrench 18 Emergency light 1

19 Hydrant wrench bracket 2

All fire hose in 100% polyester jacket with neoprene lining.

The licensee will upgrade the hose houses by adding 2 hose gaskets for each of the hose sizes used, a 2-1/2 inch by 1-1/2 inch by 1-1/2 inch valved "Y" and a forcible entry tool in each fire hose reel cabinet.

The licensee will also maintain the hose reel and cart houses in a clean and orderly condition and will provide tamper proof seals on the doors to insure that the inventory of firefighting equipment is maintained.

4-6 414 190

The licensee vill provide barrier guard posts to protect the indicator valves and hose houses from vehicular hydrants, post traffic along the east, north and west sides of the plant.

The liceasee will also conduct a semiannuel inspection (Fall and Spring) of the hydrants to ensure the barrels are dry and that the threads are properly lubricated.

Operational pressure tests will be performed to verify barrel integrity following the winter freeze season.

In addition to these modifications, we will require that the licensee hydrostatically test all exterior fire hose at a test pressure of 50 psi above working pressure at a maximum time schedule of once every 18 months.

We find that, subject to the implementation of the above describ(d modifications, the fire water piping systems satisfy the ob-jectives ioentified in Section 2.2 of this report and are, therefore, acceptable.

4.3.1.4 Interior Hose Stations Interior 1ose stations are provided throughout the turbine building, service building, primary auxiliary building and the Hose stations are not provided in the intake structure.

safeguards area, diesel generator cubicles, and safety-related portions of the scctor cubicles, and safety-related portions of the service building. Hose stations are equipped with 50 feet of 1-1/2 inch cotton rubber lined hose with adjustable spray nozzles. During the site visit, it was observ2d that several hose station valves were not tightly shut or were leaking past the seat, resulting in water accumulation in the racked hose.

The licensee will administratively control the condition of the hose valves and replace seat rings where necessary to stop water from seeping into the hose.

Tae licensee has performed a location analysis and hose stretch to determine which areas of the plant do not presently test have hose station coverage.

Additional hose will be added to existing stations (not to exceed a total of 100 feet), and additional hose stations will be installed to provide manual hose coverage throughout the plant as delineated in Table E.3-2 of the licensee's letter dated December 11, 1978.

Excess equipment will be documented and removed.

d,- j g 7

4-7

/9

The licensee will provide manual hose stations throughout the containment. The licensee vill also provide a hose station to serve the control room, switchgear room and instrument relay rooms equipped with a 12 to 30 gpm variable gallonage and adjustable spray angle nozzle with a ball valve shutoff.

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

4.3.1.5 Automatic Water Suppression Systems A total of eleven separate fire areas throughout the plant have been provided with automatic water suppreseion syetems.

These areas include:

Fire Zone Plant Identification Type System MF-1; 2 lbin Exhaust Filter Banks Water Spray TR-1 to IR-5 Main and Station Transformers Water Spray TB-1 Turbine Building Generator Area Wet Pipe Sprinkler TB-3 Hydrogen Seal Oil Unic Water Spray TO-1 Turbine Oil Storage Room Wet Pipe Sprinkler AB-1 Auxiliary Boiler Room Wet Pipe Sprinkler RS-1 Records Storage Room Wet Pipe Sprinkler WH-1; 2 Warehouse Wet Pipe Sprinkler SB-1 PCA Shop Wet Pipe Sprinkler CL-1 Chemical Lab Wet Pipe Sprinkler SH-1 Clean Shop Wet Pipe Sprinkler h

4-8

/d

The licensee has stated that the design of the sprinkler systems conform to NFPA-13 and the design of water spray deluge systems conform to NFPA-15.

Water spray deluge systems are automatically actuated by heat detectors and all water suppression systems are arranged to sound an alarm locally and at the control room upon actuation of the system.

The licensee will provide a preaction sprinkler system to protect the auxiliary feedwater pumps.

We f ind thc., subject to implementation of the above described modi fication, the automatic water suppression systems satisfy the objectives identified in Section 2.2 of this report and are, therefore, acceptable.

4. 3.1. 6 Effects of Water Suppression Systems Existing water suppression systems are not located in areas that would be highly sensitive to the ef fects of water impinge-The water spray systems protecting the outside transformers ment.

will not have a detrimental effect on these units ac this type of equipment is designed for outside environments.

The suppression systema protecting the lube oil areac in the turbine building will not discharge in the area of safety-related equipment such as switchgear which is sensitive to water.

Pumps and equipment are mounted on pedestals which will prevent the water accumulations on the floors from affecting them.

The sprinkler systems protecting the Auxiliary Boiler Room, Record Storage Room, Warehouses, Chemical Lab and shops will have no effect on safety-related equipment because of distance.

4.3.1.7 Foam A fixed foam extinguishing system is provided for protection of the auxiliary boiler fuel tank which is located in the yard.

This is a non-safety-related tank and it does not expose safety-related structures and equipment.

The controls for this system are located in a foam house situated outside the dike surrounding the fuel tank.

$fg 4-9

/{?

Two portable foam educators suitable for applying foam through hose streams and ten 5 gallon containers of 3% foam concentrate are stored in the foam house.

We find that the existing foam firefighting equipment and supplies are adequate for the typn of fire hazards encountered at the site and is, therefore, acceptable.

4.3.2 Gas Fire Suppression Systems A total flooding Halon 1301 extinguishing system is provided in the controlled environment storage room which is a non-safety-related area.

The licensee has proposed to install a Halon 1301 total flooding extinguishing system in the underfloor cable area of the Process Instrument and Rod Position Room, Fire Zone CR-4.

Carbon dioxide suppression systems are provided at the following locations:

Fire Zone Plant Identification Type System Actuation CS-1 Cable Tray Mezzanine Total Flood-Auto / Heat ing Fbnual DG-1 and Diesel Generator Cubi-DG-2 cles CV-1 West Cable Vault CV-2 East Cable Vault TG-1 Turbine Generator Local Appli-Bearing cation The carbon dioxide extinguishing agent is stored in two low pressure refrigerated tanks with manifolding and piping to the individual systems.

The capacity of the stored agent is adequate for two applications at 52% concentration.

Discharge of the first application is automatic upon actuation of the heat detection system or manual initiation of the pull station in the area. Application of the second discharge is by manual initiation.

4l4 14 4-10

The licensee will relocate the carbon dioxide suppression syc.sa pull stations from inside the diesel generator cubicles autside the protected cubicles.

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

4.3.3 Portabl_e Fire Extinguishers Both handheld and wheeled dry chemical extinguishers are pro-vided in strategic areas of the plant.

These are supplemented with carbon (ioxide and pressurized water portable extinguishers.

The licensee will provide additional wheeled ABC dry chemical extinguishers with 50 foot hoses for use at the following locations:

Fire Zone Plant Identification Process Instrument and Rod CR-4 a.

Position Room ES-1 & 2 b.

Emergency Switchgear Rooms NS-1 c.

Normal Switchgear Rooms ME-1 d.

Motor Generator Room Communication Equipment and C R-3 e.

Relay Panel Room The licensee will provide additional portable extinguishers at specific plant locations as discussed in Section 5.0 of this report.

We conclude that, subject to provision of these additional units, adequate portable fire extinguishers will be available throughout the plant for manual firefighting.

4.4 Ventilation Systems and Breathing Equipment 4.4.1 Smoke Removal Manual smoke removal capability to facilitate manual fire fighting efforts is available in all plant areas where 4-11 4l4 1er

safety-related equipment required for safe reactor shut-down may be exposed to a fire:

the existing plant venti-lation system cen be manually aligned to remove smoke from vital fire areas such as the a) Cable Spreading Room, CS-1; b) Normal Switchgear Room, NS-1; c) Emergency Switchgear Rooms, ES-1 and ES-2; and d) Motor Generator Room, MG-1.

The removal of smoke from other vital plant areas requires the use of portable exhaust fans and attached flexible ducting.

With the exception of areas where a potential for radio-active contamination of the smoke exists, smoke will be discharged directly outside. Potentially contaminated smoke will be discharged through monitored ventilation paths such as the a) ventilation vent; b) elevated release process vent on the top of the cooling tower; and c) decontamination building rcof vents.

In order to provide adequate ventil-ion capability for the above areas, the licensee has proposed the addition of portable smoke removal fans and ducting strategically locsted in the plant.

Subject to the implementation of this modification; the smoke removal capability satisfies the objective identified in Section 2.2 of this report and is, therefore, acceptable.

4.4.2 Filters There are seven charcoal filter installations at this facility as follows:

the main exhaust filter banks, the process vent filters, the control room emergency supply filter, the fuel building emergency exhaust filter, the containment recirculation filters and the containment atmospheric purge filter. All of these filter systems are provided with heat detectors that activate an alarm in the control rocm.

In addition, water suppression is provided for the main exhaust filter banks which contain approximately 2,700 pounds of charcoal per filter bank.

Except for the main exhaust filter and the process vent filter, the remaining systems are not operational and any increase in temperature would most likely be due to decay 4-12 4/4 1 4f?

heat which can be removed by the respective ventilation system to lower the charcoal temperature.

Portable CO 2 extinguishers and hose stations are available to put out a fire in the area.

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

4.4.3 Breathing Equipment There are twenty complete self-contained breathing apparatus and twenty six spare bottles.

A recharging cascade system is also available as backup to approved breathing air compressor on site.

In addition, the control room personnel have access.co approved self-contained breathing apparatus.

There are six units located in the control room with six hour supply bottles and 50 foot hose for mobility.

We find that the breathing apparatus available on site is adequate and satisfies the objectives identified in Section 2.2 of this report and is therefore acceptable.

4.5 Floor Drains The main exhaust filter banks housing is provided with a water drainage system that directs the water discharged from the fixed water suppression system to the liquid radwaste system.

Safety-related areas protected by existing standpipe systems have adequate floor drainage to remove fire fighting water from the area.

The reactor containment ficor drainage system is routed to the containment The floor drainage system for the control room air conditioning sump.

equipment room is routed into the main drainage system for the turoine building.

The primary auxiliary building floor drainage system is routed to the auxiliary building sumps.

The floor and equipment drainage system in the safeguards area is routed to the pipe tunnel sump. The floor drain system for the diesel generator roo;as will be plugged to prevent the spreading of spilled diesel fuel frcm one diesel generator room to the other.

All floor drain systems that could possibly contain radioactive wastes are directed to the liquid radwaste system.

We find that, subject to the implementation of the modifications acted above, the protection to prevent the spread of fire through floor drain systems satisfies the objectives of Section 2.2 of this report and is, therefore, acceptable.

4-13 f/g 14g

4.6 Lighting Systems Emergency lighting consists of 125 V DC incandescent units supplied from station batteries.

Remote areas have local self-contained battery powered units.

The control room has incandescent and 120 V fluorescent lighting powered from station batteries. Additional fluorescent units in the control room are powered from the diesel generators.

Sealed beam portable lights will be provided by the licensee for the fire brigade.

We find that, subject to the implementation of these modifications, the. emergency lighting satisfies the objectives of Section 2.2 of this report and is, therefore, acceptable.

4.7 Communication Systems Communication systems include an in-plant PAX switchboard telephone system, a calibration jack system routed throughout the plant and a page-party system.

Portable VHF radios are also used and available to the emergency squad.

We find that the communication systre meets the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

4.8 Electrical Cables All safety-related cables installed in crays were constructed co pass the vertical cable tray flame test with oil / burlap flame source which was in effect at that time.

The flame tests indicated that extensive propagation of fire does not occur.

We find that retest of cables to IEEE-383 Standard would not provide information that would change our recommendation or conclusions.

Accordingly, we find the safety-related electrical cables used at Beaver Valley Power Station, Unit 1, acceptable.

4.9 Fire Barrier Penetraticas 4.9.1 Fire Doors The licensee will provide a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> fire rated fire barrier and door between the control room and the adjacent kitchen eating areas, provide additional 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire doors and frames on the doorway between the diesel generator rooms, replace the existing 4-14

'l/ y l<lf

doors in the emergency switchgear rooms between zones ES-1 and ES-2 with 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire doors.

The doors in the normal switchgear room between areas NS-1 and the Control Room CR-4 will be replaced with 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire doors. The non-labeled door at the 768 foot level of the radwaste building leading to the pipe tunnel PT-1 will also be replaced.

We find that, subject to the implementation of the above described modifications, protection for door penetrations of fire bar-riers satisfies the objectives of Section 2.2 of this report and is, therefore, acceptable.

4.9.2 Ventilation Duct Penetrations Generally, where a duct passes through a fire rated wall, a 1-1/2 hour rated fire damper is provided.

The duct penetratio:d were sealed with cellular cement during the initial construction of ';he plant.

The control room perimeter areas, however, were found lacking fire dampers in some ducts penetrating fire barriers.

The licensee has conducted a survey of penetrations in safety-related areas and will upgrade them where necessary to the fire rating of the wall, ceiling or floor they pass through.

We find that, subject to the implementation of the above de-scribed modifications, protection of ventilation duct pene-trations satisfies the objectives of Section 2.2 of this report and is, therefore, acceptable.

4.9.3 Ele:trical Cable Penetrations Electrical penetrations in most safety-related areas of the plant are sealed with cellular concrete.

The licensee has provided documentation of fire tests by the Portland Cement Association attesting to the adequacy of this method and future penetration seals will be made with an approved silicone rubber compound.

The licensee has conducted a survey of penetrations in safety-related areas and will upgrade them shere necessary to the fire rating of the wall, ceiling or floor they pass through.

4-15

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/N

We find that, subject to tha implementation of the above described modifications, protection of electrical penetrations satisfies the objectives of Section 2.2 of this report and is, therefore, acceptable.

4.9.4 Piping Penetrations Piping penetrations of fire barriers are either poured in place or sealed by cellular concrete or silicone rubber.

Plastic foam fill used ao an air seal in some places has been removed and the opening sealed with silicone rubber.

The licensee has conducted a survey of penetrations in safety-related areas and will upgrade them where necessary to the tire rating of the wall, ce114.ng or floor they pas s through.

We find that, subject to implementation of the above described modifications, protection of pipe penetrations satisfies the objective of Section 2.2 of this report and is, therefore, ac-ceutable.

4.10 Separation Criteria The licensee has stated that the cable separation of safety-related systems is accomplished by spatial separation in accordance with the following criteria:

1.

Cable separation design includes separation of trains, channels and non-class 1 E circuits into different raceways.

Several non-class 1 E circuits have been routed through raceways associated with one train, however, they are never routed from one train to another.

There is complete separations thrcughout the plant with either barriers or space between trains and channels of redundant circuits.

2.

Separate exposed conduit or concealed metal conduit carrying nuclear instrumentation system cable for neutron detection have redundant channels separated by a minimum of 2 feet where channels run parallel to each other except where they converge at termination points.

3.

Separate adjacent cable trays with a minimum horizontal sepa-ration of 3 inches between side rails.

ff/I 4-16 trq

4.

Separate cable trays with a minimum vertical separation of 8 inches center to cen*er with solid metal covers on all tastru-ment and control cable trays and rnised, vented cover on all power cable trays except on the top tray which is directly under the concrete ceiling.

5.

Where exposed cables of redundant circuits leave trays to enter sleeves, they are grouped by each train and each group has at least 6 inches minimum between outer periphery of the groups of exposed cables.

6.

Relay and instrument racks for control of redundant safety-related equipment are in separate panels.

In control panels for control of safety-related redundant equipment such as the main control board, safety-related trains are separated by either a full metal barrier between redundant safety-related control groups or a partial barrier between redundant control devices.

Where internal panel cable wiring between redundant devicet are not separated by a minimum of 6 inches the redundant cables are installed in flexible conduit.

We find that the existing meagures and proposed modifications noted herein adequately address the physical separation of redundant systems. This satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

4.11 Fire Barriers The licensee fire hazards analysis concludes that the basic wall, floor and ceiling structures bounding each fire area have adequate resistance to prevent the spread of an unsuppressed fire through the barrier.

The analysis further indicates that sufficient separa-tion is provided by space, low combustible loading and other con-struction features to preclude a fire epread between zones.

In some cases, however, fire dampers are not provided in duct penetrating fire barriers.

With the excepticn of the fire barrier components that are being replaced, the three hour fire rated fire barrier provided between fire areas is considere/..lequate.

We find tha subject to implenentation of the modifications noted herein, the fire barriers provided satisfy the requirements of Section 2.2 of this report and is, therefore, acceptable, ff?/gf 4-17

/c3D

4.12 Access and Egress All safety-related areas and areas containing safe shutdown equip-ment that rely on manual fire fighting capability are reasonably accessible in a fire situation with many areas having two or more entrances.

We find that the provisions for access and egress are adequate for manual fire fighting and evacuation of safety-related areas.

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

4.13 Toxic and Corrosive Combustion Products The products of combustion for many plastic materials, most common being cable insulation and jacket materials, are toxic to humans and corrosive to metals.

Prompt firt detection and extinguishment are relied upon to minimize the quantities of such products.

Ad-ditional means of smoke removal will be provided as an aid in fire-fighting access as noted in Section 4.4.

The fire brigade is provided with and trained in the use of emergency breathing apparatus for fighting fires involving such materials.

We find that adequate precautions have been taken to minimize the effects of toxic and corrosive combustion products.

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

4.14 Nonsafety-Related Areas We have evaluated the separation by distance or by fire barriers of nonsafety-related areas to determine that, subject to implementation of codifications described elsewhere in this report, fires in such areas will not adversely effect the ability to safely shutdown the plant.

Nonsafety-related areas which potentially pose a fire hazard to safe shutdown equipment are addressed in Section 5.0 of this report.

We have also evaluated the ef fects of fires in radwaste areas in terms of radioactive releates, and have determined that fires in such areas will not result in unacceptable consequences.

4/4 4-18 h

5.0 EVALUATION L7 SPECIFIC PLANJ AREAS _

The licensee has performed a fire hazards analysis of the facility to determine the fire loading of various plant areas, to identify the consequences of fires in safety-related and adjoining nonsafety-related areas, and to evaluate the adequacy of existing and proposed fire protection systems. We have evaluated tl'e assumptions, methodolgy, and conclusions of the fire hazards analysis in detail, as well as supplemental drawings showing cable routing and saparation.

The results of the fire hazards analysis, other docketed information and site visit observations were used in the staff's evaluation of specific plant areas to assure that the objectives stated in Section 2.2 were met.

The staff's evaluation of specific areas is discussed in the following subsections.

5.1 Control Room CR-1 5.1.1 Safety Related Equipme_nt All controls, instrumentation, displays and alarms required for the safe operations and safe shutdown of the station are located in this area.

5.1.2 Combustible Futerials The combustibles in this area include electrical cable and wire insulation, a quantity of class A combustibles such as log books, operating procedures, recorder chart paper, combustible file storage boxes and a limited quantity of class A combustibles associated with the adjoining kitchen area.

5.1.3 Consequences if No Fire Suppression An unmitigated fire in the CR-1 area would not prevent the safe-shutdown of the facility.

A remote emergency auxiliary shutdown panel located in the process instrument and rod position room (CR-4) is provided for control of essential equipment required for attaining a cold shutdown.

These two rooms are physically separated by an interposing room with three hour fire barriers.

The remote control panel circuits can be isolated from the control room circuits by transfer switches.

f/g 5-1 153

5.1.4 Fire Protectio _n System Portable CO extinguishers and a portable water extioquisher 2

are provided for manual fire suppression capability.

Detection consist of ionization coverage with control ros and local alarm.

5.1.5 Adequacy of Fire Protection The kitchen area located adjacent to the supervisor's office in the control room contains an electric range and various combustibles, thus creating an exposure hazard to the control room.

The duct penetrating the gypsum wall board and passing through the construction area for BVPS II control room does not have a fire damper.

Ccntrol room air conditioning ductwork penetrations servicing area CR-1, CR-2, CR-3 and CR-4 are not provided with fire dampers. Walk-in type vertical control board panels are not provided with early warning fire detection devices -

a fire in this section may go undetected until observed by an operator.

Lack of detectica could allow fire to propagate unnecessarily in redundant cables in control panels.

5.1.S Modifications The licensee has proposed the following modifications. A fire rated barrier for the control room bench board access panels.

A temporary 3-hour fire rated insulated enclosure around the ductwork penetrating the gypsum wall board penetrations to BVPS II.

The Kitchen area will be enclosed with a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> fire-rated wall barrier and door.

A portable dry chemical extinquisher will be placed adjacent to the electric cooking range and 2 1/2 gallon pressurized water extinguishers will be placed at the entrances to the standup control board.

Fire detectior.

will be installed in vertical control board panels.

We find that, suj ec t to the implementation of the above described modifications, the fire protection for control room CR-1 satisfies the objectives identified in Saction 2.2 of this report and is, therefore, acceptable.

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5.2 Control Rocm CR-2 5.2.1 Safety Related Equipment This area contains the HVAC equipment and controls for control room areas CR-1, CR-2, CR-3 and CR-4.

Isolation valves for isolating control room from outside atmosphere and the charcoal filter banks are also located in this area.

5.2.2 Combustible Materials The combustibles in control room CR-2 area include electrical cable and wire insulation and lubrication oil for the HVAC and charcoal associated with the emergency charceal filter bank.

5.2.3 Consequences if No Fire Suppression An oil fire associated with the refrigerant condensing units could result in the loss of both units; however, this would have no effect on plant shutdown capability, since redundant river water coils are available as back up for cooling the control room area.

A charcoal fire could develop in the filter bank resulting in its loss.

Early warning detection devices and proposed fire suppression precludes the loss of the filter bank due to fire.

5.2.4 Fire Protection System A portable dry chemical extinguisher exists within the area, with additional CO, extinguishers available directly outside the area.

Detection consists of ionization coverage with control room and local alarms.

Heat de-tection is provided for the charcoal filter banks with control room alarm.

5.2.5 Adequacy of Fire Protection The double doors to CR-4 are non-labeled doors.

Available fire suppression equipment is inadequate for fighting a fire in this area.

4/

5-3 ISr

5.2.6 Fbdification The non-labeled doors will be replaced with 3-hour fire rated doors.

Fire suppression in this area will be upgraded by the installation of large wheeled, dry chemical extinguishers throughout the 713 ft. 6 inch elevation of the service building.

The extinguishers will have a UL rating for class A, B and C fires and equipped with 50 ft. hoses and nozzles to produce an effective stream of 25 ft.

We find that, subject to the implementation of the above described modifications, the fire protection for the control room CR-2 area satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

5.3 Control 1oom CR-3 5.3.L Safety Related Equipment The equipment located in this room consists of relay and communication panels, most of which are nonclass lE.

The only essential panels for safe shutdown are the diesel generator protection panels.

5.3.2 Combustible FSterials Combustibles in Control Room CR-4 area consists of electrical cable and wire insulation.

5.3.3 Consequences if No Fire Suppression An unmitigated fire in one panel could spread to the adjacent panel, resulting in the loss of the diesel generator protection panel.

5.3.4 Fire Protection Systems Portable CO, extinguishers exist within the area, with additional C03 extinguishere. and a dry chemical portable extinguisher in the adjacent area.

Detection consist of area ionization coverage with control room alarms.

5-4

$I IS$

5.3.5 Adequacy of Fire Protection Existing fire suppression equipment is inadequate for fighting a fire in this area.

5.3.6 Modifications Fire suppression capability for this area vill be upgraded by the addition of wheeled dry chemical extinguishers discussed in 5.2.6.

We find that, subject to implementation of the above described modification, the fire protection for the control room CR-3 satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

5.4 Control 1.com CR-4 5.4.1 Safecy Related Equipment Both class IE and non-class IE equipment and electrical cable and wire exist within this area.

The essential safe shutdown system consist of primary and secondary process racks, reactor protection racks and the emergency shutdown panel.

5.4.2 Combustible Staterials Combustibles in control room CR-4 include electrical cable and wire insulation.

5.4.3 Consequences if No Fire Suppressi;gn An unmitigated fire in control room CR-4 area could result in an electrical cable insulation f:ce resulting in propagation of fire from panel to panel and the loss of the emergency shutdown panel.

5.4.4.

Fire Protection System Portable CO, extinguishero exist within the area with additional CO., extinguishers and a portable dry chemica]

extinguisher Available in adjacent areas.

Detection consist of area ionization coverage with control room and local alarm.

Y /gf 5-5

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5.4.5 Actquacy of Fire Protection Control room air conditioning ductwork penetrations into the area do not have fire dampers.

The doors to MG-1 and NS-1 are nonrated fire doors.

5.4.6 M fications The nonrated doors to MG-1 and NS-1 will be replaced with 3-hc ur rated fire doors.

Fire suppression for area CR-4 wil] be upgraded with the addition of the wheeled dry chemical extinguishers discussed in 5.2.6.

In addition, an automatic total flooding Halon cystem will be installed for the cable trench below the false floor of control room CR-4.

A floor lifter will also be available to facilitate the removal of floor panel sections.

All ducts penetrating fire barriers surrounding the control room perimeter, (CR-1 through CR-4), will be provided with fire dampers rated comparable to the fire ru ing of the fire barrier it penetrates.

We find that, subject to implementation of the above described modifications, the fire protection for control room CR-4 satisfies the objectives identified in Section 2-2 af this report and is, therefore, acceptabic.

5.5 Reactor Containment RC-l_

5.5.1 Safety Related Equipment Safety related equipment in the containment includes:

Fegenerative Heat Exchanger, Excess Letdown Heat Exchanger, Steam Generators, Reactor Coolant Pumps, Residual Heat Renoval Pumps, Recirculation Spray Coolers, Inside Recircu-lation Spray Pumps, Safety Injection Accumulator tanks, Pressurizer and associated cabling.

5.5.2 Combustible !bterials Significant combustibles in the containment include large quantities of electrical cable and wire insulation most of which is concentrated at the penetration areas to tie containment, lubricating oil assoicated with each of the reactor coolant pumps, and charcoal filter banks.

f/g 5-6

/SA

5.5.3 Consequences if No Fire Suppression An unmitigated fire in the reactor coolant pump lubricating oil system would result in the spread of fire to adjacent areas.

5.5.4 Fire Protection Systems The only firefighting equipment in the containment consists of portable extinguishers.

The only existing detection within the containment are heat detectors located inside the housings of two containment iodine recirculacion filter units.

5.5.5 Adequacy of Fire Protection Portable extinguishers would not be adequate to suppress cable insulations fires or residual oil fires on the reactor coolant pumps.

The lack of fire detection in critical areas could allow the fire to propagate un-necessarily.

5.5.6

_Mcdifications The licensee proposes to upgrade the containment fire protection with the installation of an oil collection system for the

. tor coolant pumps, additional detectors, hose stations, anu additional portable fire extinguishing equipment.

We find that, subject to impletectation of the above described modifications, the fire protection provided for the reactor building statisfies the objective of Sectien 2.2 of this report and is, therefore, acceptable.

5.6 Cable Spreading Rooms CS-1, CV-1 and CV_2 5.6.1 Safety Relat_ed Equipment The cable spreading roons consists of the cable tray mezzanine and the east / west cable vaults containing safety-related redundant instrurent, control and power required for attaining a safe-shutdown.

cables that are In addition, these areas house the emergency powered redundant supply and exhaust fans for the emergency switchgear and battery rooms.

/hf 5-7

5.6.2 Combustible Fbterials The ni2nificant combustibles on the cable Spreading Roons constst of large amounts of electrical cable, wire insulation, and an exposed p.2 molded bituminas expansion joint.

5.6.3 Consequences of No Fire Suppression An unmitigated fire in this room could affect cables from redundant divisions.

The loss of the cable spreading room would cause the loss of control of redundant safe-shutdown equipment from the control room and remote ahutdown panel.

5.6.4 Fire Protection Syste3 The primary fire suppression system is the double discharge, total flooding CO, system for the cable tray mezzanine area and east / west cable vaults.

Detection consists of area ionization coverage with control room and local alarm.

Additional detection is provided by electric rate-compensated heat-actuated devices associated with automatic acutation of the CO system.

Portable CO fi#*

2 2

extinguishers are provided in the east / west cable vaults.

Interior hose stations are available..

5.6.5.

Adequacy of Fire Protection The ionization type smoke detector provides rapid response to incipient fires in cable trays.

The initial shot for CO fl ding is actuated by temperature detection with 2

manual actuation capability.

The second shot is manual actuation.

However, a backup water suppression system is desirable to assure that cables required for safe shutdown would not te damaged should the C0 system fail to extinguish 7

the fire.

Lockout switches as well as CO2 predischarge alarms and odorizers are provided for perconnel protection.

The cable tray mezzanine does not have portable extinguishers, however, water coverage could be provided for the cable tray mezzanine and cable vaults from hose racks in the PCA and clean shops by adding additional lengths of fire hose. The ventilation duct penetration of the cable tray mezzanine slab has no fire damper.

This penetration is

/gg 5-8

the main exhaust duct for the emergency powered ventilation system servicing the two emergency switchgear araes and the emergency battery cubicles.

The cable spreading area perimeter also has an exposed premolded bituminas expansion joint which is combustible.

5.6.6 Modifications Portable 150 lb. dry chemical extinguishers with 50 f t.

hoses will be added for overall site use.

Tha non-fire rated entrance door from the auxiliary feed pump room will be replaced with a 3-hour fire ratad door and hardware.

The tain ventilation duct penetrating the cabic tray mezzanine Letween fire area CS-1 and ES-1 will be provided with a fire damper rated comparable to the fire rating o:

the fire barrier it penetrates.

The exposed expansion joint will be covered with fire retardant material.

In lieu of a backup water suppression system for the cable spreading room, the licensee proposes rerouting cables o safe shutdown systems from shutdown panels A and B outside the cable spreading room to ensure safe shut down capability ir.

fire results in the loss of the cabic spreading room.

the event a We find that, subject to implementation of the above described modifications the fire protaction for the cab 12 spreading area satisfies the objectives identified in Section 2.2 of this report and is, therefore acceptable.

5.7 Emergency Switchgear Room ES-1 and 2 5.7.1 Safety Related Equipment Redundant Safety Related Kv switchgear and 480 v substations are located in each of these separate areas.

The equipeent supplies power to class IE circuits required for safe shutdown.

5.7.2 Combustible Materials Combustible material in the switchgear rooms consists of electrical cable insulation in trays and electrical cabinets.

5-9 gf/r 4

/Of

5.7.3 Consequences if No Fire Suppression An unsuppressed fire in either switchgear room could result in severe damage to the electrical cable insulation in trays and inside electrical cabinets.

5.7.4 Fire Protection System Portable 20 lb. CO extinguishers are provided in all 2

Area ionization coverage is provided with control areas.

room and local alarm.

Water coverage could be provided by adding additional hose length to the hose racks in the clean shop.

Smoke venting could be accomplished through the use of area xhaust fan located in the service building equipment room.

5.7.5 Adequacy of Fire Protection The existing construction, with the exception of non-fire rated doors, between compartments ES-1 and ES-2, would contain the fire within the individual areas.

A total loss of on2 emergency switchgear room would not affect the ability to shutdown due to total redundancy and separation of these areas.

Lack of a hose station could inhibit firefighting operations and allow the fire to propagate unnecessarily.

5.7.6 Modifications The non-labeled doors between compartment ES-1 and ES-2 will be replaced with 3-hour fire rated doors.

Additional hose will be added to existing stations to provide area coverage.

We find that, subject to implementation of the above described modifications, the fire protection for the emergency switchgear rooms ES-1 and ES-2 satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

5.8 Normal Switchgear Room NS-1 5.8.1 Safety Related Equipment This area contains non-safety related 4160 v switchgear and 480 v substation.

f[f 5-10

,r -

5.8.2 Combustible futerf als Combustible uaterial in the normal switchgear room consists of electrical cable insulation in trays and inside electrical cabinets.

5.8.3 Consequences if No Fire Suppression An unsuppressed fire in this area could spread to the adjacent safety-related control room CR-4 through the non-rated fi: e door.

Loss of the normal switchgear area NS-1 would not affect the ability to achieve safe shutdown.

5.8.4 Fire Protection System Portable CO extinguishers are located within the area 2

with additional portable extinguishers available in adjacent areas.

Water coverage is available from the interior hose station in the clean shop.

Detection consists of area ionization coverage with control room and local alarms.

5.8.5 Adequacy of Fire Protection The existing construction with the non-rated fire door between NS-1 and CR-4 is inadequate to contain a fire within the area.

5.8.6 Modifications The non-labeled door between NS-1 and CR-4 will be replaced with a 3-hour fire rated door.

We find that, subject to implementation of the above described modification, the fire protection for the normal switchgear room NS-1 satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

5.9 Battery Rooms 5.9.1 Saf ety Related Equipment Two station battery rooms are located within the fire area of their respective emergency switchgear rooms.

5-11 414 i6J3

5.9.2 Lal.4M ble Materials Combustible materials consists of potential build up of hydrogen gas that exists during battery charging operations arid minimal quantity of cabic insulation.

5.9.3 Consequences if No Fire Suppression An unsuppressed fire in a battery room could cause the loss of one of the redundant batteries, however, it vc Id not affect redundant equipment nor ability to achieve safe shutdown.

5.9.4 Fire Protection System The battery room exhaust duct penetrations are fitted with 1 1/2 hour rated fire darpers.

Each battery room is constructed of 12 inch concrete ble

'c walls with 5 inch concrete ceiling slab on a steel d a constituting a 3-hour and a 2 1/2 hour rated fire 3a-

.er, respectively.

The emergency powered, redundant exnaust fans have alarmed control room indication for fan trip as well as indicating lights for fan run condition.

Automatic smoke detector with control room and local alarm are installed.

Portable CO, fire extinguishers are readily available directly ouEside the battery rooms. Water coverage is available from a hose station located in the service building clean shop.

5.9.5 Adequacy of Fire Protection The emergency powered, redundant ventilation system servicing this area is designed to maintain concentrations of hydrogen at less than 1 percent with ten times the calculated hydrogen generation during battery recharging.

The fans are direct drive to eliminate possibility of fan belt failure.

Fire damper closure in the exhaust duct could go undetected, resulting in hydrogen buildup when batteries are being charged.

5.9.6 Modifications Air flow sensor will be installed in the exhaust duct to monitor the flow of air.

414 Ib5' 5-12

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

5.10 Diesel Generator Rooms 5.10.1 Safety-Related Equipment Each of tha two redundant diesel generator rooms contains a diesel engine driven air compressor, local control panels, cabling, and fuel day tank.

At least one division of this equipment is necessary for safe shutdown upon loss of offsite power.

5.10.2 Combustible Materials Combustibles in the diesel generator room area include diesel engine lubricating oil, diesel fuel in fuel lines, day tants, and electrical cable insulation.

5.10.3 Consequences if No Fire Suppression An unmitigated fire in one of the two diesel generator rooms could result in the loss of function of one unit with possible damage to the redundant diesel generato:.

located in the adjacent fire area, by means of fuel passing under the communicating door or by breaching the fire door.

5.10.4 Fire Protection Systems Early warning fire detection is provided by ionization type smoke detectors arrranged to alarm in the ontrol room. A total flooding CO, extinguishing system automatically actuated by thermal detectors is provided in the diesel generator rooms.

The C0 system has reserve capacity for asecondmanuallfactua*bddischarge.

Back up fire suppression capability consists af portable CG, and dry chemical extinguishers located la each room.

Additiona l manual firefighting capability is provided by yard hydrants.

The two diesel generator rooms are enclosed by 3-hou/

fire rated reinforced concrete walls and ceilings.

Tae doorway between the two rooms is provided with a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated fire door.

{ 0 % p g' 5-13 414 16g

5.10.5 Adequacy of Fire Protection The existing ionization fire detection system, portable extinguishers and back up firefighting capability from the yard hydrant is considered acceptable.

The fixed CO fire cytinguishing system is adequate as 2

the primary automati. suppression system.

The location of the manual pull stations inside the protected rooms is not acceptable.

The intensit; of a potential diesel fuel fire in one of the rooms could make it impossible to enter and reach the pull box.

Provisions are not ndequate to insure a fire in one diesel generator room does not affect the redundant diesel generator room via oil seepage under the doorway.

The manual control for stopping the diesel fuel transfer pump is located within the diesel generator rooms and coulc be inaccessible during a fire.

A leak in the diesei nel supply system could go undetected for a consideraoie period of time and accumulate on the floor.

If significant quantities of fuel entered the floor drains, the posriblity exists that fuel could communicate via the drainage system to the adjacent diesel generator room.

The fire door between the two redundant diesel generator rooms may not be capable of withstanding a potential high intensity diesel fuel fire.

5.10.6 Modifications In order to mitigate the possibilities of a fire affecting both redundant diesel generator rooms, the licensee will make the following modifications:

1.

Curbing of sufficient height to prevent on oil leak in one room from entering the adjacent room will be provided at the doorvsy between the rooms.

2.

An additional three (3) hour fire rated door aad frame with self-closing hardware will be provided at the doorway between rooms.

(also discussed under 4.9.1) 3.

The manual actuation pull box for the CO extinguishing 2

systems will be relocated outside the room it is designed to protect.

(also discussed under 4.3.2) 5-14 bh

4.

A control for shutting off the diesel fuel transfer pump outside of the diesel generator rooms will be provided.

5.

Floor drains in the diesel generator roome will be plugged.

6.

A fail safe level detecting device will be installed in a sump close to the day tank to detect an oil ac c umula t io-due to a leak.

High sump level will be annuciated in the control rcom.

7.

Fire barrier wall penetration between Die <ml Generator rooms will be evaluated and up graded to a 3 hr L;rrier.

We find that, upon implementation of the above described modifications, the Diesel Generator Room's fire protection satisfies the objectives identified in Section 2.2 of this report and is, therefore. ceptable.

5.11 Raduaste Building PA-1 5.11.1 Safety Related Equipment Ice radwaste building is designated as the primary auxiliary ouslding.

Safety-Related equipnent required for safe shut down is not located in the radwaste building.

However it is adjacent to the service building, cable vault building and fuel building.

5.11.2 Combustible Materials The only significant source of combustibles in this buliding are the charcoal filters in the main exhaust filter banks, electrical cable insulation in trays and unlabeled waste.

5.11.3 Consequences if No Fire Suppression An unsuppressed fire in this area could result in a release of ra..J.oactive contaminated materials to the environment.

5-15

5.11.4 Fire Protection System All exterior doors to adjacent buildings have 3-hour fire rating.

All interior doors to stair towers in the PA building have 1 1/2 hour fire rating.

The charcoal filter banks are provided with a water deluge spray system that is actuated automatically by heat detectors.

Manual actuation capability is also provided.

Portable CO fire extinguishers and hose racks are provided throughout 2

the PA building.

5.11.5 Adequacy of Fire Protection Lack of detection could allow fire to propagate unnecessarily.

5.11.6 Modifications Appropriate general area fire detection and suppression for the PA building with common control room alarm will be provided if this area is to be used as a storage area.

A new building is to be constructed in the near future with appropriate fire protection to contain contaminated waste.

We find that, subject to the construction of the new building and implementation of the area fire detection in the PA building if used for storage, fire protection for this area satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

5.12 Fuel Oil Storage Areas 5.12.1 Safety Falated Equipment Liesel generator fuel oil tanks are located underground, covered with sand and concrete slab and located 50 ft.

from diesel generator cubicles.

5.12.2 Combustible Materials Each of the f':

sii storage tanks contain 20,000 gallons of fuel of'-

5-16 f4 fh

5.12.3 Consequences if No Fire Suppression An unsuppressed fire in areas adjacent to the fuel tanks would not involve the fuel tanks since the buried tanks are considered as meeting the 3-hour fire separation requirement.

5.12.4 Fire Protection System None is provided 5.12.5 Adequacy of Fire Protection Buried fuel tanks are considered as meeting the 3-hour fire rating.

5.12.6 Modifications No modifications are proposed or recommended for this area.

We find that the fire protection for the fuel oil storage facility satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

5.13 Intake Structure 5.13.1 Safety-Related Equipment The safety-related equipment in the intake structure consists of three river water pumps, motor control center, A-C power panels, ventilation fans and associated cabling and piping.

5.13.2 Combustible ;taterials The major combustibles include the diesel fire pump lube oil, fuel supply day tank, pump lubricating oil and insulation on wiring and inside electrical equipment.

During the site visit, considerable quantities of transient combustibles were evident including untreated lumber, rags and plastic drop cloths.

5-17

5.13.3 Consequences if No Fire Suppression An unmitigated fire in the intake structure would not result in compromising safe shutdown capability because of the separation and barriers between redundant safety-related equipment. The river water pumps are located in separate compartments and cabling is in conduit. A separate alternate water intake structure with redundant river water pumps is provided 1800 feet away.

Because of the curbing at the diesel day tank and the trench to the diesel engine, a leak from the tank or supply lines would not spread to other areas.

5.13.4 Fire Protection System Manual hose stations and portable extinguishers are provided within the building for manual firefighting.

Thermal type fire detectors which alarm in the control room are provided in the compartments housing the river water pumps and the compartment housing the diesel fire pump.

Separation between pump compartments is provided by 18" thick reinforced concrete walls with 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated doors.

5.13.5 Adequacy of Fire Protection Because of the redundancy of the safety-related equipment and separation between cables and components, the provisions of manual firefighting equipment are adequate.

The significant quantities of unaecessary combustibles obscrved in this area, however, jeopardizes this capability.

A fire originating in one of the safety-related pump compartments, (IS-1 through IS-3), would go undetected for some time and result in the loss of one of these units.

5.13.6 Modifications The licensee will remove all unnecessary combustibles from the intake structure and will allow only fire retardant treated lumber to be used within the building.

The 5-18

()

licensee will also provide automatic fire detectors in the safety-related pump compartments IS-1, IS-2 and IS-3 arranged to alarm in the control room.

We find that, upon implementation of the above described modifications, the Intake Structure fire protection satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

5.14 Yard Area 5.14.1 Safety-Related Equipment The safety-related equipment in the yard area includes the buried diesel fuel tank and tne above ground tanks containing demineralized water storage and refueling water storago Other safety-related equipment in this area is underground cabling and piping between the main plant and the intake structure.

5.14.2 Combustible Materials The major combustibles in the yard are the fuel oil tank, hydrogen tank and cylinder storage, oil filled transformers, underground diesel fuel tank and oil drum stcrage.

Potential transient combustibles include fuel oil trucks and construction materials.

5.14.3 Consequences if No Fire Suppression An unsuppressed fire in the yard area would not present a hazard to safety-related systems because of intervening distances or barriers nor affect the capability to achieve safe shutdown.

5.14.4 Fire Protection Systems Hydrants and hose houses are available for manual fire-fighting as discussed in Section 4.3.

The oil tilled transformers are protected by automatic water spray systems.

The fuel oil tank is surrounded by an earthen dike and is protected by a manually actuated foam extin-guishing system.

The safety related demineralized water and refueling water tanks are surrounded by concrete missile shield enclosures and the diesel fuel tank is located underground.

4i4 f/f 5-19

5.14.5 Adequacy of Fire Protection The automatic water spray systems protecting the transformers and the manually actuated foam system protecting the fuel oil tank are considered adequate for the hazards protected.

The barriers and distances separating safety-related equipment from potential sources of fire e.xposures are also considered adequate.

Although the number and placement of the hydrants and hose houses are adequate, the equipment stored in the hose houses and the protection from vehicular damage to the hydrants and the hose houses were found to be deficient.

5.14.6 Modifications The licensee will provide the following modifications:

1.

Hose houses and the equipment stored therein will be maintained in good condition including reasonably free of sand and dirt.

The equipment inventory in each hose house will be upgraded to include two hose gaskets for each hose size used, one 2-1/2" x 1-1/2" x l-1/2" gated Wye, and one forcible entry tool.

2.

A survey of all hydrants, hose houses, and post indicator valves will be performed and guard posts installed in areas where they are subject to vehicular traffic damage.

3.

Post indicator valves will be provided with tamper-proof seals and administratively controlled to insure the valves are maintained in the proper mode.

4.

A semi-annual inspection (Fall and Spring), will be conducted of hydrants to insure the barrel is dry and the threads are properly labricated.

An operational hydrostatic test of each hydrant will be made to verify barrel integrity following the winter freeze seascn.

5.

Hose in exterior hose houses will be tested every 18 months at a pressure 50 psi above working pressure as recommended by the Staff.

414

7

'~

We find that, upon implementation of the above described modifications, the fire protection for the yard area satisfies the objectives identified in Section 2.2 of this report and is, therefare, acceptable.

5.15 Motor Generator Room MG-1 5.15.1 Safety Related Equipment Two 100 percent rod drive motor generator sets and switch-gear which supply power to the control rod drive mechanisms are located in this area.

5.15.2 Combustible Materials Combustibles in this area consists of electrical cable insulation.

5.15.3 Consequences if No Fire Suppression The reactor trip switchgear is fail safe.

An unsuppressed fire in this area would trip out the thermal protective device creating a reactor trip.

5.15.4 Fire Protection System Portable CO fire extinguishers exist within the area.

2 Additional portable CO extinguishers and portable dry chemical extinguishers are available in adjacent areas.

Detection consists of area ionization coverage with control room and local alarms.

5.15.5 Adequacy of Fire Protection The existing and proposed fire suppression equipment discussed for control room CR-2 and the existing detection systems provide the required fire protection for control and extinguishment of any fire in its incipient stages.

5.15.6 Modifications No modifications are proposed or recommended for this area.

5-21

/

We find tnat fire protection for the Motor Generator Room MG-1 satisfies the objective identified in Section 2.2 of this report and is, therefore, acceptable.

5.16 Turbine Building 5.16.1 Safety-Related Equipment Various equipment located within the Turbine Building is utilized in attaining safe shutdown, however, safe shutdown can be attained without the use of any equipment located in this building.

5.16.2 Combustibles Materials The combustibles in thr tarbine building consist generally of oil, hydrogen, and electrical cable insulation.

During the site visit, sigr#:icant quantities of transient combustibles such as plastic sheeting, cardboard, rags, solvents and untreated lumber were identified.

5.16.3 Consequences if No Fire Suppression An unsuppressed fire in any portion of the turbine building would generate heat, smoke and corrosive combustion products which could affect safety-related syster; in other areas. A fire involving large quantities c f turbine lube oil or hydrogen could result in substantial damage to equipment within the building and possibly result in severe structural damage to the building.

5.16.4 Fire Protection Systems An automatic sprinkler system is installed under all turbine building floors.

Back up firefighting capability consists of portable extinguishers and hose stations.

The high hazard turbine oil areas consisting of:

turbine oil reservoir, coolers and oil conditioner, and the hydrogen seal oil unit are all protected by automatically actuated deluge water suppression systems.

The turbine lube oil room and the auxiliary boiler room are protected by automatic sprinkler systems.

5-22 414 l/

An automatic local application CO suppression system is provided at the turbine bearings.2 The system is provided with dual thermal detectors with provision for manual actuation.

A CO hose reel is also provided at each side 2

of the turbine generator unit.

The turbine building is separated from adjacent structures by an 18-inch reinforced concrete wall.

Penetrations through the walls have a fire rating equivalant to that of the wall.

5.16.5 Adequacy of Fire Protection The sprinkler systems and water spray system in the turbine building are adequate to suppress an oil fire until back up manual firefighting utilizing the hose stations can be initiated.

The C0 system protecting the 7

turbine bearings would help to minimize the affects of an overheated bearing.

The height of the present curbs surrounding the turbine lube oil reservoir is inadequate.

Hydrogen lines running through the area are not identified.

Lumber used for scaffolding and lay down pads is not treated with a fire retardant compound.

5.16.6 lbdifications The licensee will increase the height of curbing around the turbine lube oil reservoir sufficient to hold the entire contents of the tank plus a margin for fire suppression water.

The licensee should identify hydrogen lines by color coding or affixing signs to the lines.

The licensee will remove all unnecessary combustibles from the turbine building.

We find that, upon implementation of the above described modifications, fire protection for the turbine building satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

1 5-23 414 17 5

5.17 Miscellaneous Areas 5.17.1 Safety Related Equipment Ndscellaneous areas such as auxiliary boiler area, warehouse, machine shop, chem lab, records room, clean shop and record storage room contain no safety related equipment and are located such that they pose no threat to any safety related equipment or areas.

5.17.2 Combustible >bterials Combustibles in this area include cable insulation, fuel oil solvents, paints and paper.

5.17.3 Consequences if No Fire Suppression An unsuppressed fire in any of the above areas could result in damage to non safety related equipment, however safe shutdown capability will not be affected.

5.17.4 Fire Protection System The above areas are provided with automatic wet pipe sprinkler systems.

Backup suppression capability is provided by interior hose rack stations and portable dry chemical extinguishers.

5.17.5 Adequacy of Fire Protection The existing construction, fire suppression and alarms provide the capability for early detection and extinguish-ment of fires in these areas to preclude the propagation of fires to adjacent areas.

Some doors between various areas, however, are non-labeled doors.

5.17.6 Modifications The licensee proposes to replace unlabeled doors with UL approved 3-hour fire rated doors.

We find that, subject to implementation of the above described modification, the fire protection for the mis-cellaneous areas listed above satisfy the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

$ f tl

-24

//f;

5.18 Cable Tunnel CV-3 5.18.1 Safety Related Equipment The cable tunnel functions primarily as a transition area for cables routed from the service building to the electrical underground ductbanks in the north yard.

Class IE power and control cable associated with the river water pumps and essential support eculpment 1c sted in the intake structure IS-1 through IS-4 and thi alternate intake structure are routed within the tuncel area.

5.18.2 Combustible Materials The significant combustibles in this area consists of electrical cable insulation.

S.18.3 Concequences if No Fire Suppression An unsuppressed fire could result in a major cable fire in the cable tunnel area and subsequent loss of the river water pump function and associated essential support equipment.

5.18.4 Fire Protection System There is no extinguishing equipment or detection provided within the tunnel. Water coverage could be provided by utilization of a yard fire hydrant and equipment ctored in the hose cart houses.

5.18.5 Adequacy of Fire Protection Fire protection for this area is inadequate.

The aree lacks fire detection necessacy for prompt response and 1ccessibility to a fire in this area.

5.18.6 Modifications The licensee proposes the addition of a detection syste with control room alarm annunciation, the installation of a portable CO extinguisher and a modified access hatch 2

to provide rapid entry capability.

41<1 5-25 7,

We find that, subject to implementat. ion of the above described modifications, the fire protection for the cable tunnel satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

4/4 / '[

/

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6.0 ADMINISTRATIVE CONTROLS 6.1 General The administrative controls for fire protection consist of the fire protection organization, fire brigade training, the controls over combustibles and ignition sources, the prefire plans and procedures for fighting fires, and the quality assurance provisiens for fire protection.

The program and its bnplementing procedures as provided by letter from the licensee-dated October 27, 1976, as supplemented by letters dated February 11, 1977, May 1, 1978, September 29, 1978, December 11, 1978, and January 11, 1979, are found acceptable by the staff using items referenced in Sections 1.0(e) and 1.0(f).

The following sections provide a description of the elements of the administrative controls for fire protection.

6.1.1 Organization The licensee's fire protection organization contains the organizational responsibilities and lines of communication between the various positions involved in the fire protec-tion program, the qualification requirements of key positions in the fire protection program, and the composi-tion of the fire brigade.

The fire protection organization contains positions extending from the General Superintendent of Power Generation to the Station Shift Supervisor.

The.se management and staff positions are responsible for formulaticn, implementation, and assessment of the fire protection program.

The licensee has described the organizational responsibilities for inspection, training, review of design changes, review of proposed '.ork activities and the station documents that define these and other responsibilities as related to plant fire protection.

The licensee has described the qualification requirements that have been established for the positions responsible for formulating an? implementing the fire protection program, training instructions, and for service in the fire brigade.

In addition to the training requirements, the licensee has established minimum physical qualifi-cation requirements for service in the fire brigade, including periodic physical examinations with an annual evaluation by the Company's Medical Department for each brigade member.

The licensee has a fire brigade of at least five members on site at all t!mes.

The fire brigade will not include 6-1

the minimum operating shift crew shown in Section 6.2.2 of the Technical Specifications or any other personnel required for other essential functions during a fire emergency.

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

6.1.2 Fire Brigade Training The fire brigade training program consists of classroom instruction, practice in fire fighting and fire brigade drills.

Classroom type instruction is provided annually and includes instruction in the types of fires that could occur in the plant and their particular hazards; reporting fires; maintenance and use of the plant's fire fighting equipment; fire chemistry; and fire fighting strategies and techniques.

Annually, brigade members participate in training sessions in actual fire extinguishment.

Quarterly, each brigade participates in preplanned fire drills.

The licensee's program for classroom type instruction for the fire brigade requires the entire program to be repeated every two years.

In addition, the scope of the classroom training instruction will include:

a detailed review of the plant's fire fighting procedures, prefire strategies, procedure changes, and plant modi-fications relating to manual fire fighting.

We find that, subject to implementation of the above described programmatic changes, the fire brigade training program satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

6.1.3 Control of Combustibles Administrative controls have been established to limit the amount of combustibles that a safety related area may be exposed to.

These controls include: housekeeping procedures; periodic inspections to determine the effective-ness of housekeeping practices; procedures and guidelines for use and storage of flammable, and/or volatile materials; and a review of maintenance requests and modifications for special fire protection requirements.

Trash containers 6-2 gff i41

!86

will be replaced with approved containers.

Station pro-cedures have been established for the use of combustible materials in the controlled areas of the plant, and to ensure that non-fire retardant treated wood is not used inside buildings containing safety related systems.

The licensee has proposed to revise the existing administrative control procedures to further limit the amount f transienc combustibles that can be brought into safety related areas of the plant.

We find that, subject to implementation of the above described changes, the program established to control combustible materials in the plant satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

6.1.4 Control of Ignition sources Administrative controls have been established to protect safety related equipment from fire damage or loss resulting from work involving ignition sources.

These controls include station procedures which require a work permit to perfor velding or flame cutting operations.

Issuing a hot work permit requires review and signed approval by a responsible supervisor, an inspection of the work area and the establishing of a fire watch.

Plant procedures prohibit the use of open flames or combustion generated smoke for leak testing.

Administrative controls to prohibit smoking in plant arcas containing major fire hazards will be implemented.

We find that the procedures established to control ignition sources in the plant satisfy the objectives in Section 2.2 of this report and are, therefore, acceptable.

6.1.5 Fire Fighting Procedures The licensee has described the fire fighting procedures that have been established to prescribe the actions to be taica by the individual discovering the fire, the control room operators and the members 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,

'-3 414 iJfl

appropriate extinguishing agents, location of nearby fire fighting equipment, likely approach routes, location and protection of safety related and vital equipment, fire fighting hazards, location and handling of radiological and toxic hazards, 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 f ind t'ta t, subject to implementation of the above described changes, the fire fighting plans and procedures satisfy the objectives identified in Section 2.2 of the report and are, therefore, acceptable.

6.1.6 Quality Assurance The design, procurement, installation, testing and admin-istrative control activities for fire protection will be controlled in accordance with the approved Operational Quality Assurance plan, implementing the quality assurance progra criteria of Appendix A to BTP 9.5-1.

Necessary changes will be made to the procedures implementing the OQA plan to prescribe the controls for fire protection.

We find that, subject to implementation of the above described changes, the quality assurance provisions for fire protection satisfy the objectives identified in Section 2.2 of this report and are, therefore, acceptable.

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7.0 TECllNICAL SPECTFICATIONS The Technical Specifications have previously been modified to incorporate interim Technical Specifications which include limiting conditions for operation and surveillance requirements for existing fire protection systems and administrative controls.

The interim Technical Specifications now require that at least five individuals with fire protection training be on site at all times.

Following the implementation of the modifications of fire protection systems resulting from this review, the Technical Specifications will be similarly modified to incorporate the limiting conditions for operation and surveillance requirements for these modifications.

hl4 7-1 183

8. 0 CONSULTANT'S REPORT Under Contract r.o Nuclear Regulatory Con: mission, Brookhaven National Laboratory has,:rovided the services of fire protection consultants who participated in the evaluation of the licensee's fire,rotection program and in the preparation of the safety evaluation re:) ort (SER). Their report, " Fire Protection Evaluation - Beaver Valley Power Station Unit 1," dated February 2, 1979, discusses s.sveral matters which have been addressed in the SER.

The consult. tnt's report contains recommendations which have, for the most p.trt, been implemented during our evaluation.

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9. 0 CONCLUSIONS The licensee has performed a fire hazards analysis and has proposed certain modifications to improve the fire protection program.

Additional modifications have been proposed by the licensee during the course of our review, which are based upon the fire hazards analysis and our onsite evaluation of the fire protection program.

These proposed modifications are summarized in Section 3.

In addition, we have concluded that the licensee should implement certain evaluations or improvements related to the fire protection program. These are also summarized in Section 3 Significant steps are being taken to provide additional assurance that safe shutdown can be accomplished and the plant can be maintained in a safe condition during and following potential fire situations.

Upon implementation of the licensee's proposed modifications summarized in Section 3, we find that the objective of Section 2.0 will be satisfied.

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 operacion of the facility, while the remaining items are completed.

In the report of the Special Review Group on the Brown Ferry Fire (NUREG-0050) dated February 1976, consideration of the safety of operation of all operating nuclear power plants pending the completion of our detailed fire protection evaluation was presented.

The following quotations from the report summarize the basis for the Special Review Group's conclusion that the operation of the facility need not be restricted for public safety:

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" Fires occur rather frequently; however, fires involving equipment unavailability comparable to the Browns Ferry fire are quite infrequent (see Section 3.3 of (NUREG-0350)).

The Review Group believes that steps already taken since March 1975 (see section 3.3.2 of (NUREG-0050)) have reduced thic frequency significantly".

" Based on its review of the events transpiring before, during and after the Browns Ferry fire, the Review Group concludes that the probability of disruptive fires of the magnitude of the Browns Ferry event is small, and that there is no need to restrict operation of nuclear power plants for public safety.

Howevar, it is clear that much can and should be done to reduce event further the l'.kelihood of disabling fires and to improve assurance of rapi. 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 recognize that the " Risk Assessment Review Group Report to the U. S. Nuclear Regulatory Commission" NUREG/CR-0400 (The Lewis Committee Report), states that this Review Group is unconvinced of the correctness of the WASH-1400 conclusion that fires contribute negligibly to the overall risk of nuclear plant operation.

In the Commission's Policy Statement dated January 18, 197 "NRC Statement on Risk-Assessment and the Reactor Safety Report", the Commission indicated on page 3 that it " accepts the Review Group Report's con-clusion that absolute values of the risks presented by WASH-1400 should not be used uncritically either in the regulatory process or for public policy purposes and has taken and will continue to take steps to assure that any such use in the past will be corrected as appropriate.

In particular, in light of the Review Group conclusions on accident probabilities, the Commission does no; regard as reliable the daactor Safety Study's numerical estimate of the overall risk of reactor accident."

In summary, it is our conclusion that the operation of the facility, pending the implementation of all facility modifications, does not present an undue risk to the health and safety of the public based on our concurrence with the Browns Ferry Special Review Group's conclusions identified above (giving due consideration to the Commission's Policy Statement), as well as the significant improvements in fire protection already made at the facility since the Browns Ferry fire. These include establishment of administrative controls over combustible materials and use of ignition sources, training and staffing of a 0f) 9-2

fire brigade, and issuance of technical specifications to provide limiting conditions for operation and surveillance requirements for fire protection systems.

Dated: May 3, 1979 AIA 182 9-3

APPENDIX A CIIRONOLOGY In February 1976, the report by the NRC Special Review Group was issued as NUREG-0050, " Recommendations Related to the Browns Ferry Fire."

on Fby 1,1976, Standard Review Plan 9.5.1, "Fi' e Protection," was issued, incorporating the various recommendations contained in NUREG-0050.

By letter dated lby 24, 1976, Duquesne Light Company was requested to compare the existing fire protectinn provisions at their facilities with new NRC guidelines as set forth in Standard Review Plan 9.5.1, " Fire Protection," dated tiay 1,1976, and to describe (1) the implementation of the guideliner. met, (2) the modifications or changes underway to meet the guidelines tnat will be met in the near future, and (3) the guidelines that will not be met and the basis therefore.

By letter of September 30, 1976, Duque: e Light Company was requested to provide the results of a fire hazards aaalysis and propose Technical Specifications pertaining to fire protection.

Duquesne Light Company was also provided a copy of Appendix A to BTP 9.5-1 which includes acceptable alternatives to the guidelines of SRP 9.5-1.

On June 17, 1976, Duquesne Light Cocpany replied to the Commission's correspondence of bby 24, 1976, and indicated that a response to the Standard Review Plan 9.5.1 will be sumbitted by November 1, 1976.

By letter dated July 7, 1976 the Staff forwarded additional guidelinee regarding the comparison of the facilities existing fire protection provisions to the Standard Review Plan 9.5.1.

By letter dated October 27, 1976 Duquesne Light Company submitted their report entitled " Beaver Valley Power Station Unit No. 1 Fire Protecticn Program Review APCSB 9.5-1 Appendix A".

By letter dated February 11, 1977 Duquesne Light Company submitted the proposed Fire Protection System Limiting conditions for operations, to be incorporated in the Technical Specifications.

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a By letters dated August 4, 1977 and February 3, 1978 the staff requested that Duquesne Light Company review their fire prctection programs in conformance with NRC staff guideline document entitled, " Nuclear Plant Fire Protection Functional Responsibilities, Administrativ; Controls and Quality Assurance.

By letter dated November 30, 1977 Ammendment No. 11 to Facility Operating license No. DPR-66 for Beaver Valley Power Station Unit No. 4 was issued by the Commission to incorporate changes to the fire protection Technical Soccifications.

On May 1, 1978 the Duquesne Light Company replied to the staff's August 4, 1977 and February 3, 1978 letters outlining exceptions from the staff's guideline document entitled, " Nuclear Plant Fire Protection Functionel Responsibilities, Administrative Controls and Quality Assurance.

On July 18, 1978 the staff forwarded to Duquesne Light Company the results of the staff's initial review of the Fire Protection Program for Beaver Valley Power Station Unit No. 1, A request for additional information was also included along with several staff positions.

By letter dated September 29, 1978, Duquesne Light Company responded in part to the staffs request of July 18, 1978, for additional information.

The balance of the information to be transmitted to the staff by November 30, 1978.

On October 30, through November 3, 1978 the staff's fire protection review team visited the Duquesne Light Company Beaver Valley Unit 2 site.

By letter dated November 1978 the staff transmitted to Duquesne Light Company positions developed and discussed with the licensee during the site visit.

By letter dated December 11, 1978, Duquesne Light Company submitted the balance of information not included in the September 29, 1978 response to the staff's July 8, 1978 request.

By letter dated January 11. 1979 supplemented bv letter dated February 21, 1979, Duquesr.e Light Company submitted their schedule for fire protection modifications.

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