ML19242A204
| ML19242A204 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 06/21/1979 |
| From: | Lainas G Office of Nuclear Reactor Regulation |
| To: | Ziemann D Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7907310597 | |
| Download: ML19242A204 (13) | |
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[9, UNITED STATES ygg3 j, NUCLEAR REGULATORY COMMISSION I
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W ASHINGTON. D. C. 20555 6
J' JUN 211979 MEMORANDUM FOR:
D. Ziemann, Chief, Operating Reactors Branch #2, Division of Operating Reacters FROM:
G. Lainas, Chief, Plant Systems Branch, Division of Operating Reactors
SUBJECT:
FIRE PROTECTION, ROBERT E. GINNA - LICENSEE'S CG:'".ENTS ON SER Facility: Robert E. Ginna Nuclear Station, Unit i Licensee: Rochester Gas and Electric Corporation Docket No.: 50-244 Rasponsible Branch: ORB #2 Project Manager:
J. Shea Reviewing Branch: Plant Systems Branch Status: SER issued; Evaluation is On-going I
We have reviewed the subject coments provided in the licensee's letter l
of March 13, 1979.
Staff's responsas are detailed in Enclosure 1.
The project manager is requested to take appropriate actions identified therein.
The licensee states that he did not make comaitments for modifications identified by his Comment Nos. (7), (12) and (21). These were originally listed in DSER as staff requirements. We cannot determine from our i
records whether the licensee had made such ccmitme'1t subsequent to the issuance of the DSER. However, if the licensee disagrees to these staff positions, several statements in the License Amendment No. 24 are no longer valid.
O G. Lainas, Chief P ont Systems Branch Division of Operating Reactors
Contact:
T. Lee, X27173 590028 7 g 9731 oW
Enclosure:
As stated cc w/ enclosure:
D. Eisenhut R. Vollmer B. Grimes R. Ferguson G. Lainas T. Lee J. Shea T. Wambach J. Klevan E. MacDougall e
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ENCLOSURE 1 FIRE PROTECTION - ROBERT E. GINNA, DOCKET N0. 50-244 STAFF RESPONS5 TO THE LICENSEE'S COMMENTS (DATED MARCH 13) ON SER Technical Specifications:
(1) Licensee's Comment Basis for Section 3.14,P 3.14-4.
The yard hydrants on the southeast corner of the yard loop provides back-up fire suppression capability not primary capability for the trans-formers and standby auxiliary feeewater building.
Staff's Response We accept the licensee's contention that this yard hydrant provides back-uo, instead of primary fire suppression capability for the above described areas.
(2) Licensee's Comment Specification 4.15.2.e.
For clarification, the method of obtaining the sample from the day tank has been discussed with members of the NRC staff.
It was agreed that a sample would be withdrawn from the fuel line running from the day tank to the diesel engine.
Staff's Resporne We accept tne proposed method of sampling.
Fire Protection Safety Evaluation Reoort (1)
Licensee's Comment P.3-2 item 3.1.4, P.4-9, item 4.4.5 and P.5-2 item 5.1.6.
A curb will be installed around the reactor coolant pump only if an automatic suppression system is installed (see item 3.1.39).
In this case it would be installed by 6/81.
If an oil collection system is installed, curbs will not be installed.
Staff's Response We agree.
co ~' "< 0 va-y (2) Licensee's Comment P.3-2 item 3.1.8 calls for the intermediate building cable tunnel opening to be sealed.
This is inaccurate since an entrance is necessary.
Item 3.1.5 calls for a three hour rated "A" labelled door for this opening.
Staff's Response In P.1:2-4 and P 4.3-7 of the licensee's " Fire Protection Evaluation", dated March 1977 and also in the licensee's response to the staff's request for additional information No. 57, the licensee stated the opening will be sealed.
(3) Licensee's Comment P.3-2 item 3.1.8.
In order to resolve concerns about a fire barrier between the nitrogen storage building, which is used to store hydrogen as well, and the auxiliary building and about the hy.drogen piping within the auxiliary building (see item 3.1.48) an alternative is being considered. This alternative would involve moving the hydrogen storage to a separate location removed from the auxiliary building and relocating the hydrogen piping in the auxiliary building.
Staf f's Response The staff will evaluate the proposal when the licensee decided on, and provided details of, the modification.
(4)
Licensee's Comment P.3-4 item 3.1.20 has the "A" and "B" label designations switched for the diesels.
Staff's Resconse We agree the SER is in error.
(5) Licensee's Comment P.3-4 item 3.1.22 (3) and P.4-5, item 4.3.1.3 require snow removal procedures during snow storms. We believe the words "to the extent practical" should be added to this.
The length and intensity of a storm has a tremendous bearing on what is necessary during a storm.
This was discussed during our deliberations of this particular item.
Staff's Response We request the licensee to prescribe the condition under which snew removal operation will be initiated.
590031
I (6)
Licensee's Coment P.3-6 item 3.1.29 and P.4-5 item 4.3.1.2.
These paragraphs require the diesel fire pump engine to be operated for a minimum of 1/2 hour each month. Tne Technical Specifications require a 15 minute test, not a 1/2 hour test.
Therefore, these paragraphs should be corrected to reflect u 15 minute tast. As discussed with the hRC Staff, the 15 minute test is adequate to determine operability.
Staff's Response The licensee is requested to justify his request for deviation from this requirement which is explicitly provided in NFPA 20, 1976, Section 8-6.1.
(7)
Licensee's Coment P.3-7 item 3.1.38 and p.4-14 i tem 4.11.
This requirement has never been discussed with us by the NRC Staff.
The wall separating the north and south sections of the intermediate building has never been considered a fire barrier. The fire hazards analysis used the wall as a zone border but pointed out that the wall was there for radiological considerations and the drawings do not indicate that it qualifies as a fire barrier. We see no justification for upgrading this wall.
Staff's Response The licensee's " Fire Protection Evaluation", dated March 1977, treats this wall as a fire barrier. The BTU loadings in the intermediate building are calculated as though each floor in the building is divided into two fire areas by the wall and the fire hazards in the building are discussed accordingly. Our evaluation has considered this wall as a fire barrier.
If the licensee does not want to consider the subject wall as a fire barrier, their analyses should be revised.
(8)
Licensee's Comment P.3-ll item 3.1.15.
In the schedule for completion of modifications, Table 3.1, this item is incorrectly listed as being complete.
Al though flame retardant coating has been applied in the east cable vault, the modifications in the relay room will not be completed until 6/81.
Staff's Response We request that the licensee justify extending the implementation date until June 1981 which is significantly beyond our target date of October 1980.
5 9 2 i
l (9) Licensee's Comment P.3-ll i tem 3.1.29.
To be consistent with Technical Specification 4.15.2.e it should tse clarified that testing of the diesel fire pump fuel oil is required after June 1,1979. The deferred effective date is allowing time for a sample tap in the fuel oil I
line to be installed.
Staff's Resconse We accept that the diesel fire pump fuel oil test will be started on June 1,1979.
(10) Licensee's Comment P.4-2 item (4) states that source range r.eutron detectors are required during shutdown. This is not true and should be deleted.
j Shutc',wn condition can be ensured thrcugh addition of sufficient borated water to the primary syetem.
l Staff's Response We do not consider shutdown without means of monitoring the reactor reactivity " safe".
If the concentration of boron instead i
of neutron is to be monitor: I such provision should be listed as required for safe shutdot n'.
(11) Licensee's Commeg P.4-4 item 4.3.1.1 states there are two locations for wall hydrants on the plant.
Actually, there are four.
Staff's Response We have re-checked the licensee's fire water piping diagram and verified that there are four wall hydrangs.
(12) Licensee's Comment P.4-5 item 4.3.1.3 discusses modifications to the fire service water piping to reduce the number of interior hose stations that might be isolated if one section of the piping were taken out of service.
Actually, planned modifications are for the purpose of preventing isc.ation of both fixed protection and hoselines that protect ;.he same area.
590C33 Staff's Response The plant's fire water piping arrangement is such that a break in pipe sections 10-FS-125-10 or 10-FS-125-ll, or isolation of these sections for the purpose of repair or maintenance would disable all interior hosa stations in the auxiliary and the intermediate buildings. We do not believe such possibility should be neglected.
Pacause it does not appear possible to provide bacP-up manual hose capability within one hour (Tech Spec requirement) to so many interior hose stations without appropriate modifications to the piping system, certain limitation to the operating condition has to be imposed if the licer.see does not agree to this modification.
(13) Licensee's Comment P.4-6 item 4.3.1.4 refers to elevation 293 of the auxiliary building.
We believe this should be elevation 293 the controlled (south) side of the intermediate building.
Staff's Response We agree.
(14) Licensee's Coment P.4-9 item 4.4.4 discusses the battery room ventilation system.
The system described is the proposed modification, not the existing sys tem. The existing system has nearly 1007, makeup air.
Staff's Response We agree.
(15) Licensee's Ccmment P. 4-10 item 4.4.6 discussed emergency lighting.
Cla rifica tion would help here as the implication is that emergency lighting is not now generally available.
Battery operated emergency lighting units are being added throughou.t the plant.
- However, in addition to the nomal lighting system, emergency lights are presently installed throughout the plant and are run off the emergency busses.
Staff's Response We agrec.
59cr94 (16) Lice.see's Comment
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P. 4-11 item 4.9.1 calls for the door between the relay room and the computer room to be upgraded to a three hour labelled door.
Since the walls are rated at two hours and the modified ceiling at one' hour, the door requirement should be 1 1/2 hour, "B" label.
Staff's Re:ponse Combustibles in the computer room correspond to nerly 3-hour's
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fiie severity. The 3-hour fire rating is required for the wall, the ceiling, the door and penetration seals Ps contain such fire.
(17) Licensee's Comment P. 4-14 item 4.12 discusses the cable tunnel accesses. There seems i
to be some confusion as to the accessibility of the tunnel.
There
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are three tunnel endings. The ending at the control building is
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sealed with no access.
The er ding at tha intermediate building is open but a modification is planned to close this opening with an access incorporated in the barrier. All three barrier closings will be rated at three hours.
Staff's Response We accept the licensee's revised description.
(18) Licensee's Comment P. 5-1 item 5.1.3 states that "some" valves required for safe shutdown and primary coolant temperature instrumentation could be damaged in a reactor coolant pump lubricating-oil fire. One valve in each reactor coolant pump area could be damaged.
Further-more, other flow paths are available should the valve in either reactor coolant pump area be inoperable.
These flow paths would permit the plant to be maintained in a safe-shutdown condition.
In addition, loss of the primary coolant temperature indication for a loop would not preclude the plant from being maintained in a safe shutdown cor.dition.
l Staff's Rescanse The licensee's submittals does not include a description of the separation between these redundant valves and the separation between the redunc, ins trumentation.
The staff is still unable to determine if more than one valve or one temperature indication could be damaged by a fire. The licensee is requested to provide a detailed description of such separaticq.
5eC P5 (19) Licensee's Comment P. 5-2 item 5.1.6 (2) states that a hose station will be provided k
for all hazards and safety-related equipment.
Certain safety-related equipment is not combustible and does not require protection.
Protection will be provided by means of suppression for any hazards which could affect safety related equipment.
Staff's Resconse We request the licensee to provide a description of his conceptual design of the proposed suppression systems.
(20) Licensee's Cormtent P.5-4 item 5.3.3 and P.5-5 item 5.3.6(6) have the "A" and "B" diesels reversed.
Staff's Response We agree.
(21) Licensee's Coment_
P. 5-5 item 5.3.6 (7) was not discussed or committed to.
Safe shutdown capabilities should a fire occur in this area will be addressed in the Shutdown Analysis which is item 3.2.1 s It should be noted that flame retardant cable coating has been appT1ed to the cables in this vault and detection will be installed, There is no external heat source in this vault and hence a fire has low credibility.
Staff's Response Based on the present fire hazards analysis, we cannot agree with the licensee's implication above that cable coating and fire detection provide adequate protection for this cable vault.
(22) Licensee's Comment F.5-6 item 5.4.2 states that certain transient combustibles were not included in the licensee's Fire Portection Evaluation and that there were "large" quantities of paper, clothes, and paints on the operating floor. All these transients were included in the report in a lump figure rather than being spelled out individually.
Much of the paper in the listed nine cabinets has been removed and the clothes are actually rags for cleaning ourooses.
The contents of these cabinets were however included in the Fire Prctection Evaluation.
59CCM Staff's Response Our SER states that such transient combustibles as wood scraps, oil in drums, gas bottles, etc., which we found in this area during the site visit were not included in the licensee's analysis.
(23) Licensee's Comment P.5-7 item 5.4.6(6) talks about doors and entrances. There is only one entrance at this level and it will be upgraded with a 3-hour rated door.
Staff's Response We agree (24) Licensee's Comment P.5-7 item 5.4.6 suggets storage of paper, cloth, etc. should be limited to approximately one weeks' supply at the most. To be consistent, this time period should be two weeks as shown in i tem 3.l.47.
Staff's Response We agree.
(25) Licensee's Comment P.5-8 item 5.5.3 lists containment cooling as a safety-related system required for shutdown.
In fact, it is not required for shutdown.
Staff's Response Table 3-1 of the licensee's "Fim Protection Evaluation", dated March 1977, lists containment cooling units as safe shutdown related equipment.
(26) Licensee's Comment P.5-8 item 5.5.4 states that the turbine driven auxiliary feedwater pump oil tank is curbed.
It is not curbed but has drainage around it.
Staff's Resoonse P.4.3-6 item of the licensee's " Fire Protection Evaluation" explicitly stated that the tank is located in a curbed area.
59F07 (2' dcensee's Comment
..5-9 item 5.5.5 aists the 253' - 6" elevation of the intermediate building as the intermediate floor.
Staff's Response We agree.
(28) Licensee's Coment P.5-9 item 5.5.6(2) calls for water spray systens to be provided for a portion of the intermediate floor. The elevation is the basement floor.
Staff's Response We agree.
(29) Licensee's Comment P.5-9 ' item 5.5.6(4) calls for the cable tunnel to be sealed.
In fact, a barrier will be provided with a rated door.
Staff's Resoonse We agree.
(30) Licensee's Comment P.5-9 item 5.5.6 states that we comitted to provide corrective modifications, "pending" the safe shutdown analysis. This is incorrect. We will perform modifications which are necessary following the analysis.
Staff's Resocnsa We agree.
(31) Licensee's Comment P.5-il item 5.7.5 describes a modification that was being planned at the time of the NRC site visit in June 1978.
In fact, the pr*sent system has nearly 100% makeup air.
Staff's Resoonse We agree.
59CC38 (32) Licensee's Comment P.5-12 item 5.8.3 is incorrect.
The control room ventilation system is not required for safe shutdown.
The safe shutdown analysis will determine if the cables from the cable tunnel are required for safe shutdown and hence it should not be stated at this time that fire will leave the plant without the capability to safely shutdown.
Staff's Response Table 3-1 of the licensee's " Fire Protection Evaluation", dated March 1977 listed the control room air handling unit, the return air fan and the ventilation damper as safe shutdown related equip-ment.
We agree with the licensee's statement on the cable tunnel.
(33) Licensee's Comment P.5-13 f tem 5.8.6 states that "pending" the safe shutdown analysis, necessary modifications have been committed to.
We will perform any modifications which are necessary following the analysis.
Staff's Response We agree.
(34) Licensee's Comment P.5-13 item 5.9.3 states that a fire in this room will deprive the plant of the capability to safely shutdown.
This has not been established.
Staff's Response We agree; however, the licensee, to this date, has not established to the contrary.
(35) Licensee's Coment P. 5-13 f tem 5.9.5 states that the existing fire protection is inadequate to prevent a fire from damaging redundant cables in the room which serve safety-related systems required for safe shutdown.
This has not been established.
Staff's Response The staff made the conclusion from our observation that the cable separation is inadequate, that both divisions of cables are present, and that the arranger.ent of control boards in the control room and relay cabinets in tha rocm will necessitate cables serving safe shutdown system to be routed through this cable spreading room.
59CC9
, (36) Licensee's Comment I
P. 5-15 item 5.10.4 does not include all of the fire protection i
provided for the area.
In addition to the CO2 extinguishers, ionization detection is installed in the return air duct, one pressurized water extinguishers is installed in the room, and a hose line is available outside the room in the turbine buildina.
Staf f's Response The above information is not in either Section 4.4.6, or Drawing No.
D-024-014 Of the licensee's " Fire Protection Evaluation" dated March 1977 which describes fire protection for this area. The licensee is requested to revise these documents to provide such information.
(37) Licnesee's Comment P. 5-15 item 5.10.6 states that a smoke detector will be installed l'
in each safety-related cabinet, etc. The comitment was thatWe early warning detection would be provided for each cabinet.
have not agreed specifically to install smoke detec+. ors and
- have not comitted to putting the detection inside the cabinets.
Staff's Response We agree.
(38) Licensee's Coment P. B-2 staff response indicates a delayed decision on manual versus automatic operation of water spray system (s) pending further fire hazards analysic. There aces not appear to be any reason to defer a decision on this item and it may adversely affect design and hence installation of any fixed systems in this area.
Therefore we request that the Staff promptly reach a decision so that our installation schedules are not adversely affected.
Staff's Response Based on the present fire hazards analysis, the staff requires an automatic spray sys tem.
However, protection in addition to the automatic suppression capability may be required to assure safe shutdown, if the shutdown analysis could not assure preservation of the safe shutdown capabili ty.
59C040