ML19242D208

Forwards Response to NRC Draft Safety Evaluation Rept Section 3.3 Re Fire Protection Program

ML19242D208
Person / Time
Site:	Calvert Cliffs
Issue date:	08/06/1979
From:	Lundvall A BALTIMORE GAS & ELECTRIC CO.
To:	Reid R Office of Nuclear Reactor Regulation
References
013-261-0-L-037, 13-261--L-37, NUDOCS 7908140688
Download: ML19242D208 (58)

Text

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BALTIMORE GAS AN D ELECTRIC COM PANY GAS AN D CLECTRIC SUILDING B ALTI M O R lt. M A RYLA N D 212 03 Ant ua c.Lu=ovau.,sm.

August 6, 1979 v,.........-

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Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C.

20555 Attention:

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

Subject:

Calvert Cliffs Nuclear Power Plant Unic No. 1 & 2, Docket No. 50-317 & 50-318 Fire Protection Program, NRC Review File: 013-261 0, L-037-F

Reference:

Draft Safety Evaluation Report by the Office of Nuclear Reactor Regulation, Staff / Licensee Discussions held July 11, 24 & 31, 1979 Centlemen:

The enclosures attached are submitted in response to a request to furnish information and data, and to furnish commitments relative to staff positions identified in Section 3.3 of the Draft Safety Evaluation Report (DSER). Enclosure 1, entitled " Responses", addresses Section 3.3 that con-tains 47 positions. Some positions were mutually resolved during discus-sions held in July and are indicated as completed in the enclosure attached.

Entlosure 2 provides, in tabular fctm, commitment dates for implementation of the various positions.

Very tr y yours,

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J. A. 31ddison, Esquire G. F. Trowbridge, Esquire Messrs. E. L. Conner, Jr. - NRC/

J. W. Brothers, Sechtel 7908144 A

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Calvert Cliffs Nuclear Power Plant Fire Protection Review RESPONSES TO STAFF POSITIONS IDENTIFIED IN SECTION 3.3 0F THE DRAFT SAFETY EVALUATION REPORT f hh

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3.3.1 Fire Hazards Analysis (b.1, 5.3, 5.5, 5.6, 5 12, 5.15, 5 23, 5.2L, 5.26, 5.30)

We vill require the licensee to provide the results of an analysis to:

(1) identify the minimum separation between the redudnant cables (in trays or in conduits)/ equipment required for safe shutdovn in each fire area, (2) identify the largest fire than can be expected in each fire area based on the fixed co=bustibles in the area and transient combustibles which may be introduced into or moved through the area.

(3) identify the vorst damage that could rr. salt from such fire, and (L) demonstrate that such damage vill not have an adverse effect en safe shutdown or cause excessive radioactive release to the environment.

Pesvense In our April 19 letter, we co==itted to a fire hazards analysis in our responses to positions 8, 9 and 11.

This analysis is underway, and vill address the Staff's concerns expressed in 3.3.1, 3.3.32, 3.3.37, 3.3.38 and 3.3.h2.

The intent of the analysis is to verify safe shutdown /cooldown canahilities following any single maximum exposure fire. Where this carability is not verified by the analysis, modifications vill be provided as necessary. "hese modifications may take the fom of additional barriers or fire suppression systems, or even modifications to or additions of shutdovn/cooldown equirment. Where necessary to suuport the analysis, ve vill conduct tests of equipment, cable or barriers; for example, ve vill conduct a fire test on silicone rubber insulated asbestos jacketed cable in conduit to demonstrate that it will continue to perfor= its function following the maximum exposure fire (see response to 3.3.32).

Our approach was discussed with the Staff on July 31. Using equiement in the charging purp rooms as an example, we defined safe shutdown equipment and cable locations and routing and proposed modifications, which in this case consisted of curbs at doorways and automatic sprinkler protection at the ceiling; in this case, our analysis shows that these planned modifications preclude the need for additional barriers between equipment, fire doors for the room, or detection in addition to that built into the automatic sprinkler system. The corridors containing redundant cable for charging pu=ps vill be provided with early warning fire detection at the ceiling and sprinklers below the trays to eliminate the transient fire hazard. Criteria for cables vill be derived from our cable seearation verk (described in 3.3.32), which will prove adequacy of our existinc separation or provide adequate protection where needed.

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3.3.2 Alar = Power Surply (k.2) k*e vill require the licensee to verify that those fire protection alar =s annunciated on the separate panul in the Centrol Roc = are provided with back-up power from the en-site energency power syste=

and are designed and installed in accordance with Article 2h0 of NFPA 72D.

Fesponse The Alar: Pover Supply for the fire protection ala=s annunciated on the separate panel IC17B is fro = the 125V OC stationary battery.

Se batte:/ is backed up by Class IE primary chargers which are supplied fro = Class IE buses and therefore can be censidered as a plant emergency power supply.

Electrical cuperviaten, in accordance with NFPA 72D, Article 2h0, is provided cc panel IC2kB vhich is a Pyretronics U/L approved panel. Panel IClT3 a.lthough not U/L approved specifically for fire protection use, serves as a re=ote annunciator.

The signal indication provided en annunciator panel IClTB includes the folleving fire protecticn conditions:

(1) fire, (2) fire extinguish-ing syste= trouble, (3) electrical fire pump cperation, (k) diesel fire pu=p operatien, (5) fire punp trouble, and (6) pressurized fire protection syste= tank trouble. Signal indication of conditions identified by (1) through (h) above is provided with electrical super-visien by panel IC2kB vhich is in the Control Roo=.

Audible and visnal alar = and supervisien indication is provided for conditiens (1) and (2).

Visual alar = and supervisien indication is provided for the running alam for the electrical and diesel fire pt.ps, conditions (3) and (L) identified above. Conditiens (5) and (6) identified above are trouble signal circuits which do net require electrical supervision as detailed in Section 2h3 cf Article 2k0 of NFPA, Standard 72D.

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3.3.3 Fire Detection in Safety-Related Areas We will require the licensee to install appropriate fire detection devices in all safety-related areas which contain fire hazard.

Response

Many of the safety-related areas containing redundant divisions of safety-related cables and components are currently provided with automatic fire detection. The fire hazard analysis described in Section 3.3.1 will identify those additional areas which contain necessary cables and components for shutdown / cool down and radio-activity release controls. We will provide additional automatic fire detection in those rooms identified by the analysis. For example, we will provide automatic fire detection systems in the Charging Pump Rooms and adjacent corridors and similar areas con-taining redundant divisions of safety-related cables and components.

Automatic fire detection systems may consist of automatic sprinkler protection, fixed temperature, rate of rise, products of combustion or flame type detection as may be required by the Fire Hazards Analysis.

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3.3.4 Adequacy of Detector Installations (4.2)

We will require the. licensee to provide the results of a study or tests to verify that proper consideration has been given to such factors as ceiling height and configuration, ventilation air flow rate and pattern, location and arrangement of plant equipment and combustibles, etc., in determining the type, number and location of the existing and the pro-posed fire detector installations.

RESPONSE

BC&E will provide results of the study or test to verify that proper consideration has been given to such factors as ceiling height and configuration, ventilation air flow rate and pattern, location and arrangement of plant equipment and combustibles, etc., in determining the type, number and location of existing fire detector installations.

For detection systems installed to meet requirements of other sections, the job specification will require the successful bidder to provide this verification.

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3.3.5 Fire water storage (4.3.1.1)

We will require the licensee to increase the amount of water that is reserved for fire protection in the storage tank to provide the amount of water required for 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> operation of the combination of the largest cprinkler system with an additional 1,000 gallons per minute for the manual hose application.

RESPONSE

The largest sprinkler system protecting a safety related area is in the

" Solid Waste Handling Room" (Rs. 418). Thi.s system is desir.ied as

" ordinary hazard" as defined in the National Fire Protection Association'a

" EPA 13, Standard fer the Installation of sprinkler Systems". Table 2-2.1(B) of that Standard requires a mini =ue water supply of 750 gpm for ordinary hazard - Group 3 BTP 9.5 1 req u es an additional 1,000 gpm for hose streams for a total requirements of 1,750 gpm. A one hundred and twenty minute duration corresponds to a total de=and of 210,000 gallons.

As described in previous ::u"ittals, fire water is supplied from either of two independent 500,000 gallon capacity storage tanks. Each tank has 300,000 gallons reserved for fire protection.

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3.3.6 Fire Water System Valves (4.3.1.1, 4.3.1.3 )

We will require the licensee to electrically supervise the fire water tank discharge valves and to check the positions of all locked valves at least monthly. We will also require the licensee to keep the. valve in the fire water tank interconnection locked closed except when the incurconnection is necessary in case of fire.

RESPONSE

The fire water discharge valves are locked open. The fire water tank interconnection valve will be locked closed. All locked valver in the fire protection system are checked monthly to verify their position.

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3.3.7 Fire Water Freeze Protection (4.3.1.1)

We will require the licensee to verify that adequate measures are provided to prevent freezing in the fire water tanks.

RESPONGE Tsble 6 in NFPA 22 shows a loss of 1,093,000 Btus per hour from a 500,000 g llon capacity water storage tank when an atmospheric temperature is 0 F and the water temperature is 42 F.

Specification No. 6750-M24, Specifica-tion for Pretreated Water Storage Tank Heat Exchangers and Miscellaneous Waste Procassing System Heat Exchanger Calvert Cliffs Nuclear Power Plant Units Nos. 1 & 2" calls for a heat exchanger " capable of maintaining the tank contents at a minimum temperature of 45 F with a minimum ambient temperature of +5 F when supplied with 75 gpm of 200 F plant heating water".

The specification suggests that this requires 1,500,000 Btu per hour which is well in excess of the actual huat loss. This figure is conservative as it allous no reduction due to expected plant water usage which world be made up by well water which weuld be introduced at 55 F.

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3.3.8 MISCELLANEOUS USAGE OF FIRE WATER (4.3.1.1)

We will require the licensee to discontinue usage of fire water for purposes other than fire pmtection or to provide the results of a detailed analysis to demonstrate that such uses will have no adverse effects on the availability of adequate fire water supply.

RESPONSE

In addition to those measures previously described in Reference 1, (P-20), BG&E will implement administrative controls to ensure that fire system usage for purposes other than fire fighting will be limited to a single (li") hose stream at any time. These s

administrative contmls were discussed with and found acceptable by the staff at the July 24 meeting.

Reference 1, Letter from Lundvall to Reid dated April 19, 1979 bhN l

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3.3.9 Fire Pumo Flow Test (4.3.1.2)

We will require the licensee to submit recent fire pump flow test reports which include the full range of pump output from shut-off to 150% of rated capacity.

RESPONSE

The most recent full-scale fire pump tests were made on 11/22/77. See er.cicsed esst results. Locp tests wars parformad satisfactorily on 5/30/78 to verify the condition of underground piping as well as pump capacity. Full scale pump tests are scheduled to be performed in August of 19/9. Results of these tests will be furnished.

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3.3.10 Fire Water Demand (4.3.1.2)

We will require that the licensee provide the results of an analysis which demonstrates that a single fire pump is capable of meeting the combined demand (flow and pressure) for any fixed water fire suppres-sion system plus 1,000 gpm for hose streams, taking into account the pressure drop between pump discharge and the suppression system, and minimum pressures required for effective sprinkler discharge and manual hose application.

RESPONSE

The largest sprinkler system protecting a safety related area is in the " Solid Waste Handling Room" (Room 418). This system is designed as an ordinary hazard as defined by NFPA Standard 13, Table 2-2.1 (B).

This standard requires a minimum water supply of 750 gpm for " Ordinary Hazard - Group 3".

BTP 9.5.1 requires an additional 1,000 gpm for hose streams. Therefore, the total requirements are 1,750 gpm at 65 psi at PIV #11.

As described in previous submittals, fire water is supplied from either of two independent 500,000 gallon capacity storage tanks by two 100 per-cent capacity fire pumps rated at 2,500 gpm at 125 psi.

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3.3.11 LOW WATER TANK LEVEL INTERLOCK (4.3.1.2)

Fire cumps are interlocked to shut off when the water level in both fire water tanks is 12 inches above the bottom. This is in violation of the provision of NFPA 20. We will require the licensee to replace the interlock with alarms which sound in the control room and in the fire pump house.

RESPONSE

BG&E will rewire each fire pump controller in such a manner as to effectively remove the pretreated water storage tank level interlock from the control logic.

In addition, BG&E will provide pretreated water tank low level alarrs which will annunciate in both the control room and the fire pump house.

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3.3.12 Single Isolation in Fire Water Pioing System (4.3.1.3, 5.18, 5.30)

We will require the licensee to provide modifications necessary to preclude a single isolation in the fire water piping system from causing the loss of fire water supply to both fixed water suppression system and the backup hose stations in any single safety-related area.

RESPONSE

The ordinary hazard automatic sprinklers in the Diesel Generator Room No. 21 could be valved out of service simultaneously with hydrants No. 6 and 7 in the event of a break in the underground piping in the west loop.

BG&E plans to modify Calvert Cliffs Instruction (CCI) No. 113 which will require a 2h" hose be preconnected to hydrant No. 5 and run to the exterior door of Diesel Generator Room No. 21 in the event of an impairment as described above. This prelaid hose will be available for manual fire fighting through the duration of the impairment.

In addition, interior standpipe hose systems are designed for Class III service and are provided with both 2 " and li" connections. Hose Station 45-10 is located imme-diately adjacent to the overhead roll up door in the west wall of Room 419 and can be isolated from the west loop to be available for backup hose stream protection west of the structures.

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3.3.13 Hose Reach Tests (4.3.1.4, 5.6, 5.12, 5.17, 5.19, 5.21, 5.24, 5.25, 5.26, 5.28)

We will require the licensee to perform hose reach tests, and provide additional hose stations as necessary to assure that all points in safety-related areas and other plant areas which contain major fire hazards can be effectively reached by at least one hose stream.

RESPONSE

As indicated in our previous submittal on Staff Position 13, hose stretch tests have been performed. Additional lh" fire hose has been added to existing hose stations at Elevation 45'-0" and 27'-0" so as not to exceed 100 feet at each station. Eight additional hose statious are proposed for the Auxiliary Building, Elevation 69'-0",

45'-O" and 27'-O".

Two additional stations are proposed for the Intake Structure, Elevation 12'-0".

Hose station design and installa-tion will be as shown on Figure E-1 of t!.e Fire Protection Program Evaluation (see the detail of Type "C" Hose Station).

Preliminary engineering and design is being performed now to provide hose stream protection in those areas containing safety-related equipment and areas containing large fire hazards.

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4 3.3.14 Halon System Backup Power (4.3.2)

We will require the licensee to verify that the Halon suppression systems are provided with backup power from the onsite emergency power system.

RESPONSE

Halon 1301 Fire Suppression Systems are supplied with power from dedicated breakers on 120 VAC distribution panels at 480 V MCC (#103 WP).

These systems are electrically supervised by the fire protection control panel IC24B located in the constantly attended Control Room. Loss of power to the Halon 1301 control panels would be immediately alarmed visually and audibly as required by NFPA Standard 12A Section 1-8.

Backup power is not provided as it is not required by NFPA Standard 12A.

3.3.15 SMOKE REMOVAL CAPACITY (4.4.1)

We will require the licensee to demor. strate that the capacity of the smoke removal systems complies with the provision of Apper. dix A to BTP 9.5-1, which specifies at least 300 CFM for every 200 square feet of floor area, or is adeauate for the service in the area they are provided; especially in the cable spreading rooms.

3.3.16 VENTILATION SYSTEM POWER AND CONTROL (4.4.1)

We will require the licensee to verify that power supply and controls for those ventilation systems providing smoke removal capability are nJn outside the fire areas served by the system.

We will require the licensee to justify, or modify, the place-ment of any ventilation system power supply or controls in the fire area which they serve.

3.3.18 PORTABLE SM0KE EJECTORS (4.4.1)

We will require the licensee to provide three portable smoke ejectors and associated portable ducting to aid in manual smoke removal. The ejectors should be of the explosion-proof type that are used for fire fighting and have a minimum combined capacity of 17,500 CFM.

RESPONSE

BG&E will provide three (3) explosion-proof portable smoke ejectors with a minimum combined capacity of 17,500 CFM and will provide associated oortable ducting to aid in manual smoke removal. BG&E will not demorntrate that the capacity of the smoke removal systems complies with the provisions of Appandix A to BTP 9.5-1, as referenced in 3.3.15.

BG&E will not verify that power supply and controls for those ventilation systems providing smoke removal capability are run outside fire areas as referenced in 3.3.16.

The preceeding two items (3.3.15, 3.3.16) were deleted from consideration during the July 24 meeting between staff and BG&E, since staff agreed that portable smoke removal equipment would provide a suitable equipment sub-stitute to installed ventilation hardware for the purposes of fire protection.

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3.3.17 Ventilation Duct Penetrations (4.4.1, 4.9.2, 5.4, 5.5, 5.6, 5.9)

We will require the licensee to verify -hat all ventilation duct pene-trations of fire barriers are protected with 3-hour rated (or lower rating if justified by the amount of combustioles) UL or FM listed fire door dampers which will close automatically in event of a fire, and the gaps between the ducts and the barriers are sealed. Additional modifi-cations will be required as necessary.

RESPONSE

Ventilation duct penetrations through rated fire barriers are equipped with U/L or FM listed fire dampers which close automatically in the event of fire and the gaps between the ducts and barriers are sealed.

Fire ratings of fire dampers will be evaluated and appropriate modifi-cations made as a result of the Fire Hazards Analysis (3.3.1).

3.3.19 Separation of Ventilation Air Intake from Exhaust (4.4.1)

We will require the licensee to provide additional information which will enable the staff to evaluate the adequacy of separation between the intake and exhaust of ventilation air.

RFSPONSE:

The Staff Review Team requested and under separate cover will receive BG&E Drawings 60-319-E, Sheets 1 and 2 which clearly identifies the relative locations of the smoke removal system intake and exhaust relative to the normal outside air intake for the Control and Cable Spreading Rooms H.V.A.C. system. Attention is directed to " Responses" for items 3.3.15, 3.3.16 and 3.3.18 relative to smoke removal capa-bility.

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3.3.20 Fire Water Piping Overoressurization (4.3.1.3)

We will require the licensee to demonstrate that the fire water system overpressurization has not inflicted any permanent damage to the fire water piping.

RESPONSE

As indicated in the April 19 response, the cause of the overpressuriza-tion has been identified. This is to be corrected by installation of h" pressure relief valves on the 13 automatic sprinkler systems which trap pressure surges. As identified in Position No. 22, pressures trapped on the system side of the alarm check valve are now observed to be up to 275 psi. Any test to verify that no damage has been done would require hydrostatic tests to 50 psi in excess of normal oper4 ting pressure, as specified in Section 1-11.3 of NFPA Standard 13. The fact that no leakage has been observed at the 275 ps' pressurization in fact proves that the system has not been damaged. During the July 31 meeting this discussion satisfied the Staff Review Team's concern and no further action is contemplated.

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3.3.21 Bettery Room Ventilation Air Flow Monitor (4.4.4, 5.11)

We will require the licensee to install a ventilation flow monitor in each battery room to alarm and annunciate in the control room the loss of ventilation air flow in any battery room.

RESPONSE

Information previously submitted April 19 in response to Position P-7 and additional clarification furnished during July discussions has satisfied the Staff Review Team's concern.

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3.3.22 Fire Water Drainaae (4.5)

We will require the licensee to periorm an additional study, following the completion of hose reach tests and addition of interior hose sta-tions, to verify that fire water drainage in all safety-related areas is adequate and possible fire water accumulation in any safety-related area will be acceptable.

RESPONSE

BG&E will perform an additional study to verify that fire water drainage in all safety-related areas is adequate or that any accumulation in a safety-related area is acceptable as a result of modifications requiring installation of additional standpipe or suppression systems.

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e 3.3.23 Backflow Protection (4.5, 5.2)

We will require the licensee to provide the results of an analysis, including drawings or sketches of the drain systems as necessary, to demonstrate that the design of existing drain systems can prevent the backflow of cotsbustible liquids to other safety-related a*.eas, or to provide additional modifications to prevent such possibilities.

RESPONSE

BG&E will perform an analysis and furnish drawings and sketches, if necessary, to demorstrate that backflow of combustible liquids is prevented from communicating fire from one safety-related *rea to another.

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3.3.24 ECCS ROOM SUMPS (4.5, 5.1)

We will require the licensee to derrenstrate that oil drainage from a failed reactor coolant ptrnp could only affect one ECCS room and that concurrent fires at the reactor coolant pump area and at the affected ECCS room will not prevent safe shut-down.

RESPONSE

Two motor operated valves (normally shut) exist in line between the containment and ECCS Pump Room sump piping ard therefore preclude the possibility of a fire spreading to the ECCS Pump Room. In addition, containment sump draias are piped such that oil drains from a failed Reactor Coolant Pump may only drain into one ECCS Pump Room (Room 12 for Unit I and Room 22 for Unit 2).

In the unlikely event that a fire were to scread to an ECCS Pump Room, safety equipment redundancy between each ECCS Pump Room precludes the possibility of preventing safe shutdown.

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;7

3.3.25 EMERGENCY LIGHTING (4.6)

We will require that each fixed, sealed beam emergency lighting unit be provided with battery power rated at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, and that they be provided in all safety-related areas and their access to facilitate fire fighting and emergency operation of equipment.

RESPONSE

BG&E will provide in sufficient quantity, enough portable light-ing of a battery power rating not less than eight hours to facilitate fire fighting and emergency operation of ecuipment for all safety-related areas. Further, as a result of the July 24 meeting, it 4 understood that the presently installed fixed emergency lighting is acceptable for the purposes of access to and egress from all safety-related areas during fire fighting and emergency operating conditions. The portable equipment will be of such a type that the operator is unencumbered in perfoming his fire fighting or emergency operating duties.

The number of portable emergency lighting units available shall match the total number of ernergency) breathing units stored on site.

(See accompanying literature.

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=130 H AND LIGHT - 25.000 beam candiepower,1/4 mile beam with 2 amp bulb, adjustable g

focus. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> light per charge,3000 hours0.0347 days <br />0.833 hours <br />0.00496 weeks <br />0.00114 months <br /> battery use life. Recharge 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for each hour of i

use. Polished Stainless Steel construction, waterproof toggle switch and battery top, shockproof I

leather handle, Carry hands free on a shoulder strap. Use 120 voit chargers #125, #126, or 12 volt vehicle mounted chargers w5500 and a5520.

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• =175 SAFETY H AND LIGHT-Similar to *130. Approved by U.S. Bureau of Mines for methane atmosonere: U.S. Coast Guard Listing *CG293 for Class 1, Group D use,15,000 beam candle-s po* er, one amp bulb,hurs n_ grit per ena]rge. 6000 hours0.0694 days <br />1.667 hours <br />0.00992 weeks <br />0.00228 months <br /> battery use life. Recharge 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> frr each hour of use. Use 120 voit chargers #12o, #126.

175 Light jg cam candiepowerhours light oer cham 6000 hours0.0694 days <br />1.667 hours <br />0.00992 weeks <br />0.00228 months <br />

• 5100 or 5200 CAP LIGHT-15, O battery use life. Recharge 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for eacn hour of use. Powerhead weighs only 5% ounces, is

,e made of high impact resistant polycarbonate. Has a single Krypton filled bulb with two filaments, l l e

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N 550 hours0.00637 days <br />0.153 hours <br />9.093915e-4 weeks <br />2.09275e-4 months <br /> useful bulb life,15% more light than competitive products, and greater safety. A

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charpe, 6000 hours0.0694 days <br />1.667 hours <br />0.00992 weeks <br />0.00228 months <br /> battery use luc. Charge 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for eich hour of use. Use au voit enargers e

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wS301 Single Light for #5200 Cap Light.

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3.3.26 PORTABLE RADIO COMMUNICATION (4.7)

We will require the licensee to provide signal repeaters as necessary to ensure that all plant areas, including the contain-ment, can be reached by the portable radio comunication. We will also reouire that a sufficient number of portable radios be provided tc coordinate fire fighting, a worst emergency operation, and a physical security emergency, if the radios are also shared by the security force.

RESPONSE

BG&E will provide comunications equipment to facilitate ccmuni-cations between the Control Room and all areas of the plant including the interior of cantainment.

3.3.27 UnerotecteA Doorways (4.9.1, 5.1, 5.2, 5.4, 5.5, 5.7, 5.18, 5.22)

We vill require the licensee to install UL or ni listed fire doors of appropriate ratings at the unprotected doorways in fire barriers separating various safety-related areas of the plant.

EESPGGE:

A ce=sitnent for insts17 ation of fire doors or other appropriate protection for the above racms has been incorporated in the response to 3 31.

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3.3.28 Bullet-Proof Doors (4.9 1, 5.16)

We vill require the licensee to replace five bullet -proof doors without fire resistance ratings that have been installed in the coc:puter roo=s, control room and stair tower in the control room area with UL listed 3-hour rated bullet-proof fire doors.

RESPONSE

As part of the Fire Hazards Analysis as required by 3.3.1, the adequacy of the bullet-proof doors to withstand fire exposure is being evaluated.

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3.3.29 Fire Door Supervision (4.9.1)

We will require the licensee to identify those fire doors which are not presently locked or electrically supervised. We will require the licensee to keep these doors locked closed or electrically supervised, or to justify the lack of locks or electric supervision.

RESPONSE

Information previously submitted April 19 in response to Position P-1 and additional clarification furnished during July discussions is being evaluated by the Staff Review Team.

3.3.30 Electrical Penetration Fire Resistance (4.9.3, 5.4, 5.5, 5.6, 5.9)

We will require the licensee to provide the results of those tests con-ducted to demonstrate the adequacy of fire resistance of the Calvert Cliffs electrical penetrations. Additional tests, or upgrading of the penetrations, will be required if these test results fail to establish the adequacy of the penetrations.

RESPONSE

BC&E will perform a standard ASTM E119 Fire Test to demonstrate the adequacy of the fire resistance of cable tray and conduit penetrations fire stops in rated fire barriers as defined by the Fire Hazards Analysis (3.3.1).

We propose to include in this test representative piping pene-tration fire stops consisting of pipe in sleeves with the annular space closed by rope packing as requested in item 3.3.31.

Test specifications will be developed to provide the necessary documentation for the NRC staff review.

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3.3.31 Pioins; Penetration Fire Resistance (4.9.4, 5.4, 5.5, 5.6, 5.9)

We will require the licensee to provide test results or other evidence to demonstrate that piping penetrations have fire resistance ratings commensurate with fire hazards on both sides of the barriers. If the adequacy of fire resistance for such penetrations cannot be established, upgrading of these penetrations will be required.

RESPONSE

BC&E will perform tests as identified in Item 3.3.30.

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3.3.32 Cable Senarstion (L.10, 5 1, 5.,

5.h, 5 5, 5 7, 5.8, 5.lk, 5.17, 5.21. 5.28)

We vill requim the licensee to trovide the results of additional tests or analyses which demonstrate that seperation of electrical cables in the Calvert Cliffs facilities is adequate to preserve the plant's safe shutdovn capability, postulating a fire in any one plant area.

Tne size of the pcstulated fire in each area should be the largest possible fire as discussed in Section h.1 of this report. These tests / analyses should also establish the effectiveness of the fire barrier desien or the steel conduit /virevay in preventing the stread of fire damage if a credit vere taken for such.

If it cannot be demonstrated that the plant's safe shutdown catability can be treserved under fire emergency situations, additional modification (s) vill be required.

Resvonse

• he criteria for cable separation o-the amplication of protective materials to conduit and cable trays vill be established based on the results of the fire hazards analysis (3 3.1) and the results of our test and evaluation program, described as follows:

(1) We vill provide the results of tests to demonstrate that silicone rubber cables which are installed in steel conduit are idequate to preserve the plant's safe shutdown capability.

(2) Cables other than silicone rubber which are installed in conduit vill be protected where shown to be necessary by the fire hazards analysis by materials which have been proven by test to provide adequate trotection to preserve the plant's safe shutdown capability.

(3) Where shown to be necessary by the fire hazards analysis, cables which are installed in cable trays vill be protected by materials which have been troven by test to provide adequate protection to preserve the plant's safe shutdown capability.

l

3.3.33 U:mrotected structural steel (14.11, 5.28)

We will require the licensee to identify those areas in which barriers are supported by unprotected structural steel, and provide appropriate ' protection for this steel unless it can be verified that postulated fires in these areas would not adversely affect these supports, or that failure of these supports could not i::: pair the safe shutdown or cause excessive release of radioactive materials.

Pl.5Fundt;:

There are no fire walls supported by unprotected structural steel at Calvert Cliffs nuclear Power Plant.

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3.3.3h Safety -Relar,ed Areas (k lb, 5 5, 5.6, 5.20)

We vill require the licensee to provide a list identifying those plant areas which contain systems, cc=ponents and structures i=portant to ssfety and major safety-related syste=/ce=ponents contained therein.

Resnonse The attachment lists roc =s/ areas which centain safety-related equip =ent, and the major equip =ent in each room. Equip =ent such as piping, valves, instrunents and cable are not listed. Roc = and equip =ent nu=bers in parentheses refer to Unit 2.

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Major Safety-Related Ecuipment 100 103 10h 115(105)

Charging Pu=ps 11, 12, 13 (21, 22, 23) 117 118(102)

CS Pu=p 12 (22)

HPSI Pu=p 13 (23)

LPSI Pu=p 12 (22)

West ECCS Pu=p Em. Fans & Cover SDC HX 12 (22) 119(101)

CS Pu=p 11 (21)

HPSI Pu ps 11, 12 (21, 22)

LPSI Pu=p 11 (21)

East ECCS Pu=p R=. Fans & Cover SDC EX 11 (21) 122 200 202 207 Waste Gas Decay Tanks 208 209 210 212 216(216A)

Heat Tracing Equip.

217(215)

Boric Acid Tanks 11, 12 (21, 22)

Scric Acid Pu=ps 11, 12 (21, 22) 218(21L) 220(213) 221(211) 222 223

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Room Maior Safety-Related Eculpment (cent.)

22h(203)

MSIV Eydraulics 11 (21) 225(204)

Aux. Feed R=. Vent Fans 11, 12 (21, 22)

Ct=t. Purge Exh. Fan 11 (21)

ECCS Pu=p R=.

Fans 11, 12 (21, 22) & Filters Penetration Ps. Fans 11, 12 (21, 22)

Associated Filters 226(205)

Service Water Pps. 11, 12, 13 (21, 22, 23)

Salt Water Air Co=p. 11, 12 (21, 22)

Service Water HX 11, 12 (21, 22) 227(206) 228(201)

CCW Pp. 11, 12, 13 ( 21, 22, 23 )

CCW EX 11, 12 (21, 22) 301(305)

Batter /-

30h(307)

Battery 306(302)

Various Centrol & Equip. Cabinets Battery Chargers 11,12 (13, lb)

Inverters DC Centrol Panels 31h(313)

Spent Fuel Racks 315(309)

MSIV's 316(310) 317(311)

Breakers, Switchgear 218(312) 319 320 SFP Cooling Pp. 11, 12 SFP Cooling HX 11, 12 223 32h(322) 326(321) 327 328 Cable Chase 1A, 13 (2A, 23)

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Roon Ma.jor Safety-Related Equipment (cont.)

h05 Control Roem Equipment kl0 bl6 DG 21, Air C0=p., Vent Fan, FO Xfr. Pp.

h19 h21 DG 12, Air Co=p., Vent Fan, FO Xfr. Pp.

h22 DG ll, Air Cc=p., Vent Fan, FO Xfr. Pp.

h23(hlk)

MCC's Recombiner 12 (22) Panel h2T(h11) h28(h08)

MSIV Hydraulics 12 (22)

Atmos Du7s h29(h09)

Recombiner n (21) Panel h30(h07)

Breakers, Switchgear h39(kho)

Refueling Wtr. Recire. Pp. n (21)

Refueling Wtr. EX 11 (21)

Cable Chase 1C (2C) 512 Control R=. & CSR HVAC Equip.

Post-LOCI Filters 520 Fuel Fool Vent Equip.

52h(526)

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525(527)

CCW Head Tank 11 (21) 529(532)

MCC's 533 New Fuel Racks Ecrizontal Chase El 82'9" 603(605)

Aux. Feed Pp. E, 12 '21, 22)

Intake Structure Salt Water Pps.

Centainments NSSS & Support Syste=3 f) h Ob

3.3.35 Radiolorical Consecuences of Fire (4.1h, 5 3, 5.7, 5 9, 5.20, 5.2h, 5.25)

We vill require the licensee to sunplement his fire hazards analysis with a study of radiological consequences of a fire in areas containing radio-active materials (including a fire in a charcoal or a HEPA filter), or other areas where a fire could cause the release of radioactive raterials.

Additional modifications vill be required in areas wherr a fire could cause the release of radicactive materials that could preclude the normal usage or occupancy of area surrounding the plant.

Bestonse An analysis of the radiological consequence of fire vill be trovided as required by the staff. Modifications vill be provided if necessary to prevent fire-caused releases that exceed our safety related criteria.

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3.3.36 Control Air (4.15)

We will require the licensee to.:

(1) provide a detailed information which supports the statement that the operation of the charging system valves are required only following a LOCA, and (2) provide the results of an analysis which demonstrate that the transient caused by the loss of control air to the saltwater valves would not have a detrimental effect on the salt water pumps, or any adverse effect on the plant safety. The analysis should take into account a possiole delay in the operator's action.

RESPONSE

BG&E is currently evaluating and will provide information relative to the independent control air systems identified in this item by August 17, 1979.

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3.3.37 Senaration of Redundant Ecuitnent (b.1, 5.2, 5.h, 5 5, 5 27)

We vill require the licensee to separate, by fire barriers of appropriate fire resistance, one division of equipment (pump, valve, control, instru-mentation, etc. ) recuired for safe shutdovn from its redundant counterpart (s) to treserve the functions of such systems during and following fire emergency situations, or provide alternate means of performing such functions.

Systems to be so protected include but not be limited to:

(1) the component cooling vater system, (2) the charging system, (3) the service vater system, and (h) the auxiliary feedvater system.

Resnonse

".efer to the response to 3.3.1.

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3.3.38 Senaration of Plant Areas (5.h, 5.6, L.o)

'Je vi'1 require the li::ensee to seuarate each of the following areas from 2

adjoining plant areas by installing fire doors and upgradine cenetrations of barriers to fire resistance ratings required of the barriers:

(1) Each of the cocoonent ecoling tump rooms (2) Each of the piting areas Nos. 203 and 22h (3)

"'he hot ::achine shop and the het instment shop.

Restonse Refer to the response to 3.3.1.

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3.3.39 Rerouting Hydronen Piping (5.4, 5.8, 5.9)

We will require the hydrogen piping in the referenced plant areas out of the areas and other safety-related plant areas, or provide other additional protection.

RESPONSE

BG&E is currently evaluating and will provide information relative to the hydrogen piping by August 17, 1979.

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3.3.40 Addition of Curbs (5.9)

We will require the licensee to provide curbs at the doorways ti the hot machine shop and the hot instrument shop to contain a possible oil / solvent spillage.

RESPONSE

B. G. & E. will provide means to curb or contain passible oil / solvent spillage to the Hot Machine Shop and the Hot Instrument Shop.

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3.3.41 CONTROL OF COMBUSTIBLES (5.9, 5.24, 5.26)

We will require the licensee to remove all combustibles that are not required for the routine operation and maintenance of the plant from all safety-related plant areas and prohibit open storage of combustible materials near or under the safety-related cables /ecuipment. Storage of combustible materials necessary for the routine operation or maintenance of the plant should be limited to approximately one week's supply. Appropriate facilities should be provided for such storage.

RESPONSE

BG&E will remove and prohibit storage of all corrbustibles not required for routine plant operation and maintenatice from all safety-related areas.

In addition, BG&E will provide metal storage cabinets removed from the vicinity of any safety-related cables / equipment for the storage of a one week's supply of combustible materials necessary for the routine operation and maintenance of the plant.

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3.3.h2 Alternate Shutdown carabilf tv (510, 5.13, 5.16)

We vill reauire the licensee to verify the existence of, or provide if it cannot be verified, the capability to safely shutdown both units indecendent of cables and equipment in any one of the following rooms or chases:

(1) The control room (2) Two cable spreading rooms (3) Six cable chases (1A,13, 2A, 2B, U1 and U2)

Resnonse Pefer to the response to 3.3.1.

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3.3.43 DEDICATED LADDERS (5.10)

We will require the licensee to provide a dedicated ladder of noncombustible construction in each cable spreading room to provide access to the areas above the battery rooms and the over-head cable chases.

RESPONSE

BG&E has provided fiberglass construction dedicated ladders for each cable spreading room. Fiberglass was selected so as to meet OSHA standards for electrical shock hazards in these areas.

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3.3.44 Fire Suppression System f.n Cable Chases (5.13)

We will require the licensee to provide an automatic water suppression system in each of the six cable chases (IA, IB, 2A, 2B, U1 and U2).

RESPONSE

BC&E will perform a fire hazards analysis (3.3.1) for the six cable chases identified and modifications will be provided as necessary.

3.3.45 Miscellaneous Protection for Control Room (5.16)

We will require the licensee to:

(1) provide a fog nozzle for the manual hose protecting the room, (2) replace wooden furniture and shelvea with those of metal, and (3) provide metal partitions to separate the adjoining panels from the computer terminal in the middle of the main panel.

RESPONSE

(1) A fog no?zle is provided for the standpipe hose station protect-ing the room.

(2) All wooden furniture will be removed from the control room complex except for work benches in the Log and Test Instrument Room (Room 435).

The metal work benches with wooden tops are required to reduce potential electric shocks from injuring technicians. This room is separated from the constantly attended Control Room by a metal bullet-proof door. The room is equipped with an early warning fire detection system.

(3) Metal partitions will be provided to separate the adjoining panels from the computer terminal in the middle of the main panel.

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3.3.46 RC Pumo Lube Oil Collection System (5.19)

We will require the licensee to provide a description of design bases of the lube oil coller. tion system for the reacto coolant pumps, and the drawings or sketches showing its arrangement.

RESPONSE

Ir. formation previously submitted April 19 in response to Position P-5, new information, photographs, and additional clarification furnished during the July discussiens is being evaluated by the Staff Review Team.

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3.3.47 Effects of Fire on Radiatien Monitors We will require the licensee to provide the results of a study to demonstrate that the radiation monitors will remain operational when exposed to smoke or heat of a potential fire.

RESPL 3:

We will provide the results of a study to demonstrate the capability to effectively monitor radiation levels in the plant.

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Calvert Cliffs Nuclear Power Plant Fire Protection Review IMPLEMENTATION DATES FOR ANALYSIS, ADDITIONAL DATA AND MODIFICATIONS h

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Iaplementation Table It m Analysis / Data Modification 3.3.1 Fire Hazards Analysis Nov 1979(

Oct 1980 3.3.2 Alarm System Aug 1979 N/A 3.3.3 Fire Detection Nrv 1979 Oct 1980 3.3.4 Adequacy of Detector Installation Nov 879 N/A 3.3.5 Fire Water Storage Aug 1979 N/A 3.3.6 Fire Water System Valves Aug 1979(

N/A 3.3.7 Fire Water Freeze Protection Aug 1979(

N/A 3.3.8 Miscellaneous Use of Fire Watar Aug 1979 N/A 3.3.9 Fire Pump Flow Test Aug 1979(

N/A Aug 1979(2h N/A 3.3.10 Fire Water Demand 3.3.11 Low Water Level Interlock Aug 1979 Nov 1979 3.3.12 Single Isolation in Fire Water Piping Aug 1979 Aug 1979 3.3.13 Hose Reach Tests Nov 1979 Oct 1980 3.3.14 Halon System Backup Power Aug 1979(

N/A 3.3.15 Smoke Removal Capacity Aug 1979(

N/A 3.3.16 Ventilation System Power Aug 1979 N/A 3.3.17 Ventilation Duct Penetrations Nov 1979 Oct 1980 I

3.3.18 Portable Smoke Ejectors Aug 1979 N/A 3.3.19 Separation of Ventilation Intake and Aug 1979(,

N/A s

Exhaust 3.3.20 Fire Water Overpressure Aug 1979( '

N/A 3.3.21 Battery Room Vent Air Flow Aug 1979(1)

N/A 3.3.22 Fire Water Drainage Nov 1979 Oct 1980 3.3.23 Back Flow Prevention Nov 1979 Oct 1980 3.3.24 ECCS Sumps Aug 1979( '

N/A 3.3.25 Emergency Lighting Aug 1979(

Oct 1979 3.3."

Fire Protection Communications Nov 1979(

June 1980 3.3.47 Unprotected Doorways Nov 1979 Oct 1980 3.3.28 Bullet-Proof Doors Nov 1979(

Oct 1980 3.3.29 Fire Door Supervision Aug 1979(1 N/A 3.3.30 Electrical Penetration Test Nov 1979 Feb 1980 3.3.31 Piping Penetration Test Nov 1979 Feb 1980 3.3.32 Cable Separation Nov 1979 Oct 1980 3.3.33 Unprotected Steel Aug 1979(

N/A 3.3.34 Safety Related Area Listing Aug 1979 N/A (s

I

2 Imolementation Table (Continued)

Item Analysis / Data Modification 3.3.35 Radiological Consequences Nov 1979 Oct 1980 Aug 1979( }

3.3.36 Control Air N/A

,.3.37 Separation of Redundant Equipment Nov 1979(

Oct 1980 Nov 1979(

3.3.38 Separation of Plant Areas Oct 1980 3.3.39 Hydrogen Piping Aug 1979(

N/A 3.3.40 Additional Curbs Nov 1979 June 1980 3.3.41 Control of Combustibles Aug 1979(

N/A 3.3.42 Alternate Shutdown Capability Nov 1979(

Oct 1980 3.3.43 Dedicated Ladders Aug 1979(

N/A 3.3.44 Fire Suppression in Cable Chases Nov 1979 Oct 1980 3.3.45 Miscellaneous Protection for Control Aug 1979(

Oct 1980 Room Aug 1979(

N/A 3.3.46 RCP Lube oil Collection 3.3.47 Effects of Fire on Radiation Monitors Nov 1979 N/A

(

Data furnished prior to this submittal.

(2) Data furnished with this submittal.

(

Additional data to be furnished by August 17, 1979.

(

Items common to fire hazards e.nalysis of safe shutdown systems, Item 3.3.1.

6/[0 n

.