ML19248D156
| ML19248D156 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 07/27/1979 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19248D154 | List: |
| References | |
| NUDOCS 7908100168 | |
| Download: ML19248D156 (62) | |
Text
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FIRE PROTECTION SAFETY EVALUATION REFORT BY THE OFFICE OF NUCLEAR REACTOR 'EGULATION U.S. NUCLEAR REGULATORY CC'OtISSION IN THE MATTER OF DAIRYLAND POWER COOPERATIVE LACROSSE BOILING WATER REACTOR DOCKET N0. 50-409 Date: July 27, 1979 908100teg ;
TABLE OF CONTENTS Pace 1.0 INTRCCUCTION...
1-1 2.0 FIRE PROTECTION GUIDELINES.............
2-1 2.1 General Design Criterion 3
" Fire Protection" 2-1 2.2 Supplementary Guidance...
2-1 3.0
SUMMARY
OF MCDIFICATIONS, INCCMPLETE ITEMS AND REQUIREMENTS.
3-1 3.1 Modi fications.......
3-1 3.1.1 Exterior Hose Houses.
3-1 3.1. 2 Fire Fighting Eauipment..
3-2 3.1.3 Interior Hose Stations.
3-2 3.1.J Fixed Suppression Systems.....
3-3 3.1.5 Heat Detector Circuit Supervision...
3-3 3.1.6 Breathing Air.....
3-3 3.1.7 Diesel Oil Shutoff..
3-3 3.1.3 Flame Retardant Coating..
3-4 3.1.9 Piping Penetration Seal.
3-4 3.1.10 Emergency Lighting...
3-4 3.1.11 Hydrogen Detectors...
3.1.12 Exposed Steel Protection..
3-4 3.1.13 Protection of Service Water Piping...
3-4 3-4 3.1.14 Neutron Shields..
3-4 3.1.15 Diesel Tank Filler Cap..
3-4 3.1.16 Relocation of Cascade System.
3-4 3.1.17 Fire Door Replacement.
3-5 3.1.18 Fire Door Supervision.
3-5 3.1.19 Fire Dampers.
3-5 3.1.20 Unrated Barrier..
3-5 3.1.21 Relocation of Chemicals..
3-5 3.1.22 Protection for the Electrical Equipment and the Control Rooms.
3-5 3.1.23 Interior Hoses.......
3-5 3.1.24 Fire Hazards in the Waste Handling Suilding..
3-6 3.1.25 Gas Suppression System Actuation.
3-6 3.1.26 Drains and Curbs..
3-6 3.1.27 Combined Water Demand..
3-6 3.1.28 Cable Penetration Seal.
3-6 3.1.29 Signaling System.
3-6 3.2 Incomplete Items..
3-7 3.2.1 Safe Shutdown Analysis.
3.2.2 Fire Water System.
3-7 3-5 562233
TABLE OF CONTENTS (Continued)
Page 3.2.3 Fire Pump Performance....
3-8 3.2.4 Exposed Structural Steel in Turbine Building...
3-8 3.2.5 Security Modification on Fire Doors...
3-8 3.2.6 In-Situ Detector Testing.
3-9 3.2.7 Circuit Interaction Study..
3-9 3.2.8 Fire Water Supply Reliability.
3-9 4.0 EVALUATION OF PLANT FEATURES......
4-1 4.1 Safe Shutdown Systems.......
4-1
- 4. 2 Fire Detection and Signaling Systems.
4-4 4.3 Fire Control Systems....
4-5 4.3.1 Water Systems..
4-5 4.3.1.1 Water Supply.
4-5 4.3.1.2 Fire Pumps.
4-S 4.3.1.3 Fire Water Piping System....
4-8 4.3.1.4 Interior Hose Stations...
4-10 4.3.1.5 Water Suppression Systems..
4-10 4.3.2 Gas Fire Suppression Systems.
4-11 4.3.3 Portable Fire Extinguishers........
4-12 4.4 Ventilation Systems and Breathing Equipment..
4-12 4.4.1 Smoke Removal..
4-12 4.4.2 Filters...
4-13 4.4.3 Breathing Equipment.....
4-13 4.4.4 Battery Room Ventilation.
4-13 4.5 Floor Drains and-Curbs..
4-14
- 4. 6 Lighting System.
4-14 4.7 Communication...
4-15 4.8 Electrical Cables.
4-15
- 4. 9 Fire Barrier Penetrations......
4-15 4.9.1 D o o rway s...................
4-15 4.9.2 Ventilation Duct Penetrations..
4-16 4.9.3 Electrical Cable Penetrations...
4-17 4.9.4 Piping Penetrations.
4-17 bE32[dSd
4 TABLE OF CONTENTS (Continued)
Page 4.10 Cable Separatior..
4-17 4.11 Fire Barriers.........
4-18 4.12 Access and Egress..
4-19 4.13 Toxic and Corrosive Combusticn Products..
4-19 4.14 Nonsafety-Related Areas...........
4-20 4.15 Instrument Air...
4-20 5.0 EVALUATION OF SPECIFIC PLANT AREAS.
5-1 5.1 Turbine Building...
- 5. 2 Oil Storage Room.
5-1
- 5. 3 Machine Shop Area and "A" Diesei Generator Rocm.
5-3 5-4
- 5. 4 Penetration Room.
- 5. 5 "B" Diesel Generator Building.
5-5 5-5 5.6 Cor..ai nme nt..
5-8 5.7 Electrical Equipment Room and Control Room.
5-9
- 5. 8 Waste Handling Building.
5-10
- 5. 9 Crib House..
5-11 5.10 Yard Area and Transformers.
5-12 6.0 ADMINISTRATIVE CONTROLS..
6-1
- 7. 0 TECHNICAL SPECIFICATIONS.
7-1
8.0 CONCLUSION
S..
8-1 9.0 CONSULTANTS' REPORT..
9-1 APPENDIX A CHRONOLOGY.
A-1 APPENDIX S DISCUSSION OF CONSULTANTS' REPORT.
B-1 562235
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 programs at all licensed nuclear pcwer plants. As part of this contir.uing evaluation, the NRC, in February 1976, published the report by a special review group entitled, " Recommendations Related to Browns Ferry Fire," NUREG-0050.
This report recommended that improvements in the areas of fire prevention and fire control be made in most existing facilities and that consideration be given to design features that would increase the ability of nuclear facilities to withstand fires without the loss of important functions.
To implement the report's recom-mendations, the NRC initiated a program for reevaluation of the fire protection programs at all licensed nuclear power stations and a com-prehensive review of all new licensee appli.ations.
The NRC issued new guidelines for fire protection programs in nuclear power plants which reflect the recommendations in NUREG-0050.
These guidelines are contained in the following documents:
" Standard Review Plan for the Review of Safety Analysis Report 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.
" Guidelines for Fire Protection for Nuclear Power Plants" (Apcendix A to BTP APCSS 9.5-1), August 23, 1976.
" Supplementary Guidance on Information Neeced for Fire Protection Program Evaluation," Septemoer 30, 1976.
"Samole Technical Specifications," May 12, 1977.
" Nuclear Plant Fire Protection Functional Responsibilities Acministrative Controls and Quality Assurance," June la,1977.
" Manpower Requirements for Operating Reactors," May 11, 1973.
All licensees were recuested to:
(1) compare their fire protection programs with the new guidelines; and (2) analyze the consequences of a postulated fire in each plant area.
We have reviewed the licensee's analyses and have visited the plant to examine the relationship of safety-related components, systems and structures with both combustibles and the associated fire detection and sucoression systems.
Our review was based on the fire protection review team's site visit of October 31-November 2, 1978 and the licensee's proposed program for fire protection as described in tne following docketed information:
1_1 SG2236
(1) Application for Operating License, LACBWR.
(2) " Fire Hazards Analysis of the Lacrosse Boiling Water Reactor,"
docketed February 14, 1977.
(3) Licensee responses to requests for additional information and staff position, by letters of October 18, 1978 and November 15, 1978.
Our review has been limited to the aspects of fire protection with the NRC's jurisdiction, i.e., those aspects related to the protection of public health and safety.
We have not considered aspects of fire protec-tion associated with life safety of onsite personnel and with property protection, unless they impact the health and safety of the public due to the release of radioactive material.
This report summarizes the results of our evaluation of the fire protection program at Dairyland Power Cooperative's Lacrosse Boiling Water Reactor.
The chronology of our evaluation is summarized in Appendix A of this report.
^"
5G22S7
2.0 FIRE PROTECTION GUIDELINES 2.1 General Desicn Criterion 3
" Fire Protection" The Commission's basic criterion for fire protection is set forth in Generai 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 require-ments, the probability and effect of fires and explosions.
" Noncombustible 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 fighting systems of appropriate cacacity and capability shall be provided and designed to minimize the adverse effects of fires on structures, systems and components important to safety.
" Fire fighting systems shall be designed to assure that their rupture or inadvertent operation does not significantly impair the safety capability of these structures, systems and components."
2.2 Sucolementary Guidance Guidance on the implementation of GDC-3 for existing nuclear power piants hac been provided oy the NRC staff in " Appendix A" of Branch Technical Position 9.5-1, " Guidelines for Fire Protection for Nuclear Power Plants."
Appendix A provides guicance on the preferred and, where applicable, acceptable alternatives to fire protection design for those nuclear pcwer plants for which applications for construction permits were docketed prior to July 1, 1976.
Although this appendix provides specific guidance, alternatives may be proposed by licensees.
These alternatives are evaluated by the NRC staff an a case-by-case basis.
Acditional guidance which provides clarification of fire protection matters has been provided by the NRC staff in the following documents:
" Supplementary Guidance on Information Needed for Fire Protection Program Evaluation," October 21, 1976.
" Sample Technical Scecificaticns,".tiay 12, 1977.
" Nuclear Plant Fire Protection Functional Responsibilities, Acministrative Controls and Quality Assurance," June 14, 1977.
2-1 SGuss
" Manpower Requirements for Operating Reactors," May 11, 1978.
When the actual configuration of combustibles, safety-related structures, systems or components, and the fire protection features are not as assumed in the development of Appendix A or when the licensee has proposed alternatives to the specific recommendations of Appendix A, we have evaluated such unique configurations and alternatives using the defense-in-depth objectives outlined below:
(1) reduce the likelihood 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 materials if fires occur.
In our evaluation, we assure that these objectives are met for the actual relationship of combustibles, safety related equipment and fire protection features of the facility.
Our goal is a suitable balance of the many methods to achieve these individual objectives; increased strength, redundancy, performance, or reliability of one of these methods can ccmcensate in some measures for deficiencies in the others.
562233 2-2
=
3.0
SUMMARY
OF MODIFICATIONS. INCCMPLETE ITEMS AND REQUIREMENTS 3.1 Modifications The licensee plans to make certain plant modifications to improve the fire protection program as a result of the licensee's and the staff's evaluation.
The proposed modifications are summarized belcw.
Further detail is provided in the licensee's submittals.
The section of this report which discusses the modifications are noted in parentheses.
The schedule for completion of all modifications is listed in Table 3.1.
Certain items listed below are marked with an asterisk (*) to indicate that the NRC staff requires additional information, in the form of design details to assure that the design is acceptable, prior to actual imole-mentation of these modifications.
The other modifications have been described in an acceptable level of detail.
3.1.1 Exterior Hose Houses (4.3.1.3)
(1) Two additional exterior hose houses will be provided on the yard fire loop, one accessible to the "S" diesei generator area and one accessible to the northwest entrance to the turbine building.
Each exterior hose house will incluce the following equipment:
(a) sufficient lengths of 2 " hose to reach from the hydrant location to the building entrance, (h) 200' - 1 " hose, (c) 2 - 1 " fcg nozzies with ball type shutof f valves, (d) 2 - 2 " gate valves, (e) 1 - 2 " x 1 " x 1 gated wye, (f) 1 universal type hydrant wrench, (g) 2 - 2h" hose spanners, universal type, (h) 2 - lh" hose spanners, universal type, (i) 2 - Th" coupling gaskets, and (j) 2 - 2h" coupling gaskets.
In addition:
(2) Acministrative control procedures will be estaoiishec to orovice for the clearing and removal of sncw in the area of the exterior hose houses to ensure accessibility.
3-1 56'4300
(3) Administrative control orocedures will be established to provide a semiannual inspection (Fall and Spring) of exterior hydrants tc ensure the barrel is dry and tnat the threads are properly lubricated.
(4) Administrative control procedures will be established to provide a monthly inspection of each hose house to ensure that the fire fighting equipment is in gccd working condition and properly stored.
(5) Administrative control procedures will be established to provide annual hydrostatic testing of hose stored in exterior hydrant hose houses.
3.1.2 Fire Fichtina Ecuitment (4.4.3, 4.3.1.4, 4.3.1.5)
The equipment listed below will be added to the existing inventory of manual fire fighting equipment.
This equipment will be stored in a central location and be readily accessible to the brigade at all times.
(1) One fire fighting type, explosion proof, smoko ejector rated for 5000 CFM.
(2) Protective clothing (coats, boots, gloves and fire fighters helmet) for a minimum of eight men.
(3) Two double female adaptcrs - 2 "
(4) Six automatic sprinkler stopper wedges.
(5) Six spare sprinkler heads.
(6) One sprinkler head wrench.
(7) Spare hose gaskets.
(3) One spare hose nozzle i "
3.1.3 Interior Hose Stations (4.3.1.4)^
(1) Hose reach tests will be performed and additional hose stations provided as necessary to assure that all points in safety-related areas (including those areas protected by autcmatic suppression systems) and other plant areas wnich contain major fire hazards, can be effectively reached by at least one hose stream.
(2) Tests and/or calculations will be performed that will confirm that the (ficwing) pressure at each fire hose station outlet is greater than or equal to 55 psig at 100 gpm flow rate.
(3) Acministrative controis wil' be estaDlished to prevent access to manual fire fignting ecuipment from being restricted by temporary storage of materials sithin the plant.
~~
SG2301
(4) 1 -inch diameter 100% polyester, single jacketed, lined, FM or UL listed fire hose factory test rated at not less than 300 psig, will be provided for those hose stations which protect safety-related systems and components.
3.1.4 Fixed Suppression Systems (4.3.1.5, 5.2.6, 5.3.6, 5.4.6, 5.6.6)*
(1) The automatic sprinkler system protecting the turbine oil reservoir will be extended to also protect the associated piping.
(2) An automatic water fire suppression system, or an oil shield and collection system, will be provided to protect or prevent an oil fire at the reactor coolant recirculation pumps.
(3) An automatic fire suppression system will be provided to protect the "A" diesel generator room.
(4) A fixed dry pipe sprinkler system capable of quick connection to a manual hose will be provided at the exterior side of the cable pene-tration of containment.
(5) An automatic water fire suppression system will be provided to protect against a fire at outside transformers.
3.1.5 Heat Detector Circuit Supervision (4.3.2)*
The circuits of heat detectors which actuate the carbon dioxide suppres-sion system protecting the "B" diesel generator room will be electrically supervised for power failure, ground faults or circuit breaks to alarm and annunciate in the control room these abnormal conditions.
3.1.6 Breathing Air (4.4.3)*
A 6-hour onsite breathing air reserve will be provided for each of the existing eight breathing units based on 20 minutes of air per bottles.
Two spare bottles will be provided for each unit.
3.1.7 Diesel Oil Shutoff (5.3.6)
Capability to shut off oil transfer to "A" diesel day tank from outside the room will be provided.
- As a result of our evaluation, we identified these additional modifications that we deem necessary to improve the fire protection program.
They were discussed with the licensee during the meeting at the site on June 7, 1979.
At this meeting and the subsequent telephone conversations the licensee agreed to provide these modifications.
562302 3-3
3.1.8 Flame Retardant Coating (4.8)
The licensee will spot check the thickness of the flame retardant coating on the cables in each safety-related area, where such coating is applied, and repair as necessary, to ensure that the coating thickness is in accordance with the manufacturer's specification.
3.1.9**
Piping Penetration Seal (4.9.4)
The licensee will close all unsealed pipe penetrations with a noncombustible material to provide fire resistance required of the barriers.
3.1.10 Emergency Lichting (4.6)
Fixed, sealed beam, 8-hour rated battery powered emergency lights will be provided in all safety-related areas, and their access and egress, to facilitate emergency shutdown operation and fire fighting.
3.1.11 Hydrogen Detectors (4.4.4)
A hydrogen detector ha s been installed in the electrical equipment room and in the "B" diesel room, which contain the station batteries, to alarm in the control room an excessive hydrogen concentration.
3.1.12 Exposed Steel Protection (5.3.6)
Three-hour protection will be provided for the exposed steel structure supporting the ceiling of the machine shop.
3.1.13 Protection of Service Water Piping (5.2.6)
The licensee has provided protection for the service water pipes and their supports in the oil storage room against a fire in the room.
3.1.14 N_eutron Shields (5.6.6)*
Polyethylene neutron shield blocks around the control rod drive system below the reactor will be replaced with those of noncombustible material.
3.1.15 Diesel Tank Filler Cao (4.3.1.2, 5.9.6)
A locking filler cap has been provided for each of the diesel-driven high pressure service water pump fuel oil storage tanks.
3.1.16**
Relocation of Cascade System (4.4.3)
The licensee will relocate the cascade system, which is currently hcated in the southeast corner of the turbine building basement, to an area where a fire in the area will not require its use.
3-4 562303
3.1.17**
Fire Door Replacement (4.9.1)
The licensee will replace the 1-1/2-hour rated fire doors from the "A"
diesel room to the machine shop and from the machine shop to the penetra-tion room with 3-hour rated fire doors.
3.1.18**
Fire Door Supervision (4.9.1)
All fire doors in the plant, except the two doors discussed in Section 4.9.1 of this report, will either be locked closed or electrically supervised to provide a time delayed alarm in a constantly occupied area.
3.1.19**
Fire Damoers (4.9.3)
The ventilation duct penetrations of fire barriers between the instrument repair shop and the electrical equipment room will be protected by fusible link actuated fire dampers with appropriate fire resistance rating.
3.1.20**
Unrated Barrier (4.11, 5.3.6)*
The licensee will upgrade the unrated barrier between the "A" diesei room and the machine shop to provide the fire resistance commensurate with hazards on both sides of the barrier.
3.1.21**
Relocation of Chemicals (5.2.6)
Miscellaneous chemicals stored in the flammable liquid storage cabinets in the oil storage room will be relocated.
3.1.22**
Protection for the Electrical Eauipment and the Control Rooms (5.7.6)*
The licensee will (1) relocate record file cabinets stored in the electrical equipment room out of safety-related areas, (2) provide an automatic suppression for the electrical equipment room, and (3) provide additional protection, such as enclosure, coating, or automatic suppression for cables in the concealed space above the control room.
3.1.23**
Interior Hoses (4.3.1.4)
The length of the hose at all interior hose stations will be limited to 75 feet maximum.
The 3/4-inch hoses and nozzles inside the containment have been replaced by 1 -inch, UL or FM listed fire hoses and nozzles.
5G2304 3-5
3.1.24**
Fire hazard in the Waste Handlina Building (5.8.6)*
The licensee will provide the results of an analysis which demonstrate that a fire in the waste handling building, including the off gas system, will not cause the release of a significant amount of radioactive materials.
3.1.25**
Gas Sucoression System Actuation (4.3.2)*
The licensee will (1) provide the actuation power for the carbon dioxide system that protects the "B" diesel room from the essential service bus which derives the onsite backup power from the "A" diesel generater, and (2) modify the emergency manual release of the carbon dioxide system to conform to the provisions of NFPA 12-1977, Section 1-S.3.5.
3.1.26**
Orains and Curbs (4.5, 5.1.6, 5.2.6, 5.3.6, 5.5.6)
Curbs will be added or upgraded in the following areas to contain the entire content of oil in each area plus additional 10% capacity for fire water:
(1) The turbine oil reservoir (2)
"A" diesel room (3)
"B" diesel room The licensee will also provide an opening at the floor level of the oil storage room which will drain a possible oil accumulation in the room toward the yard area.
3.1.27**
Combined Water Demand (4.3.1.3)*
The liransee will provide the results of an analysis to demonstrate that the combined water demand for fire fignting and for safety-related functions can be setisfied under any fire emergency or accident.
3.1.23**
Cable Penetration Seal (4.9.3)
The licensee will modify the existing electrical cable penetration seal to a design with established adequate fire resistance.
3.1.29**
Sicnalinq System (4.2)*
The licensee will:
(1) Test the sorinkler system water flow alarm at 2-month intervals.
(2) Perform sprinkler system drain tests follcwing operation of system control valves.
(3) Install a timer for each cetector zone to provide sarning wr.en a detector :cne nas been bypassed for a certain period cf time.
3-6 562305
4 3.2 Incomplete Items In addition to the licensee's proposed modifications, several incomplete items remain, as discussed below.
The licensee will complete the evalua-tions necessary to resolve these incomp'7te items.
The sections of this report which discuss these incomplete items are noted in parentheses.
We will address the resolution of incomplete items in a supplement to this report.
The schedule for the completion of the licensee action on these incomplete items is given in Table 3.2.
This schedule will permit any additional modifications, such as may be required, to be implemented on a schedule which is consistent with that noted in Section 3.1 of this raport.
3.2.1 Safe Shutdown Analysis (4.1)
The licensee will provide an analysis to demonstrate that the safe shutdown capability exists independent of cabling and equipment in any one fire area or to verify the effectiveness of the barriers, spatial separation, tray covers and/or fire stops in preventing simultaneous damage to redundant safety systems required for safe shutdown from a possible exposure fire involving the fixed combustibles in the area and m reasonable amount of transient combustible materials, which may be in the area for routine plant operations and maintenace.
In addition to damage resulting from elevated temperatures, the analysis will consider the effects of:
(1) Smoke and heat propagation via open stairways anc hatches, and unrated penetrations in barriers.
(2) Water spray damage from fire hose streams.
(3) Simultaneous fire and loss of offsite power.
The licensee will proposa, at the completion of the safe shutdown analysis, modifications to assure that the plant's shutdown capability will meet the following criteria:
(1) Following any fire, the plant can be brought to hot shutdown conditions using equipment and systems that are free of fire damage.
(2) The plant should be capable of maintaining hot shutdown conditions for an extended time period significantly longer than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
(3) Fire damage to systems necessary to achieve and maintain cold shutdown conditions should be limited so that repairs can be made and cold shutdown conditions achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
(4) Repair procedures for cold shutdown systems should be prepared now and material needed for such repairs should be on the site.
(5) The bot shutdown condition must be achievable with power from the offsite power system, and upon its loss, with power from the onsite 3-7
power system.
A dedicated power supply may be substituted for the onsite power systems.
(6) The power needed to achieve the cold shutdown condition may be obtained from any one of the offsite power, onsite power, and dedicated power systems.
(7) When these minimum systems are provided, their adequacy shall be verified by a thorough evaluation of:
(a) Systems required for hot shutdown; (b) Systems required for cold shutdown; (c) Fire damage to power distributien systems; and (d)
Interactions caused by fire damage to power and water supply systems and to supporting systems, i.e., component cooling water supply.
3.2.2 Fire Water System (4.3.1.2, 4.3.1.3)
The licensee will provide the results of a study af the arrangement of fire pumps and the yard main piping which will assure that a sufficient number of pumps are available to meet the fire water demand at all times taking into account the poss'bility of a fire involving both diesel driven fire pumps, failure of a fire pump, or failure of a section of the fire water piping system.
The study will include the consideration for (1) separate pump feeds to the yard main, (2) additional sectional valies, and (3) interconnection with the fire water system at adjacent fossil units.
3.2.3 Fire Pump Performance The licensee will provide the results of a full-range fire pump flow test for the electric water driven fire (HPSW) pump and each diesel engine driven fire (HPSW) pump.
Each test report will cover the range of pump discharge from shut off to 150% of rated capacity, with the associated discharge pressure.
3.2.4 ExDosed Structural Steel in Turbine Building (4.11)
The licensee will provide the results of an analysis of a fire in the turbine building damaging exposed structural steel and the safety consequences of such damage.
3.2.5 Security Modification on Fire Doors (4.9.1)
The licensee has provided further documentation to demonstrate that the fire resistance ratig of those fire door assemblies provided with physical security modification are not reduced by the modifica+. ion.
We are presently reviewing this information.
3-8
e 3.2.6 In-Situ Detector Testing (4.2)
The licensee has provided a description and acceptance criteria for the in-situ tests of the fire detectors.
This information is currently being reviewed.
3.2.7**
Circuit Interaction Study (4.1)
The licensee will identify cables which, if exposed to a fire, have a potential of being damaged to produce an adverse effect on safe shutdown.
Additional protection will be proposed for these cables to preserve the safe shutdown capability of the plant.
3.2.8**
Fire Water Supoly Reliability (4.3.1.2, 5.9.6)
The licensee is studying the feasibility of interconnecting the fire water system with that of Unit 3 to improve the reliability of the fire water supply.
The diesel-driven fire pump and relevant portion of the fire water piping in Unit 3 will be included in the surveillance nrogram of Lacrosse Boiling Water Reactor.
GGL'308 3-9
TABLE 3.1 IMPLEMENTATION DATE FOR MODIFICATIONS ITEM DATE 3.1.1 Exterior Hose Houses.
8-1-80 3.1.2 Fire Fighting Equipment..
7-31-79 3.1.3*
Interior Hose Stations..
10-1-79 3.1.4 Fixed Suppression Systems.
6-1-80 3.1. 5
- Heat Detector Circuit Supervision......
9-1-79 3.1.6*
Breathing Air.
9-1-79 3.1.7 Diesel Oil Shut 0ff...
10-1-79 3.1.8 Flame Retardant Coating....
9-1-79 3.1.9 Piping Penetration Seal.....
10-1-79 3.1.10 Emergency Lighting..
1-1-80 3.1.11 Hydrogen Detectors.
Completed 3.1.12 Exposed Steel Protection.
9-1-79 3.1.13" Protection of Service Water Piping...
Completed 3.1.14*
Neutron Shields.....
3-1-80 3.1.15 Diesel Tank Filler Cap.
Completed 3.1.16 Relocation of Cascade System.
9-1-79 3.1.17 Fire Door Replacement..
12-1-79 3.1.18 Fire Door Supervision.
12-1-79 3.1.19 Fire Dampers.
12-1-79 3.1.20*
Unrated Barrier..
12-1-79 3.1.21 Relocation of Chemicals..
10-1-79 3.1.22*
Protection for the Electrical Equipment and the Control Rooms.
12-1-79 3.1.23 Interior Hoses.....
10-1-79 3.1.24*
Fire Hazards in the Waste Handling Building.
9-1-79 3.1.25*
Gas Suppression System Actuation.
10-1-79 3.1.26 Drains and Curbs.
10-1-79 3.1.27" Combined Water Demand.
10-1-79 3.1.28 Cable Penetration Seal.
1-30-80 3.1.29*
Signaling System..
3-1-80 562309 3-10
TABLE 3.2 COMPLETI0_N SCHEDULE FOR IMCOMPLETE ITEMS ITEM DATE 3.2.1 Safe Shutdown Analysis.........
Deferred to SEP 3.2.2 Fire Water System............
9-1-79 3.2.3 Fire Pump Performance............
9-1-79 3.2.4 Exposed Structural Steel in Turbine Building.....
10-1-79 3.2.5 Security Modification on Fire Doors..
Completed 3.2.6 In-Situ Detector Testing..
Completed 3.2.7 Circuit Interaction Study.
9-1-79 3.2.8 Diesel Fire Pump Reliability....
6-30-80 SGL'310 3-11
e 4.0 EVALUATICN OF PLANT FEATURES 4.1 Safe Shutdown Systems There are several arrangements of safety-related systems which can be used to shut down the reactor and cool the core during and suosequent to a fire.
The exact arrangement available in a fire situation will depend upon the effects of the fire on such systems, their power supplies, and control stations.
The general functional requirements for safe shutdown and systems / components required to fulfill these requirements are as follows:
(1) Reactivity Control Shutdown of the reactor is normally accomplished by inserting control rods.
Tha reactor can be scrammed automatically on abnormal operating conditions by the reactor protecting system or by the action of the operator in the control room.
The control rod drive utilizes both the electric and the hydraulic drive systems.
The hydraulic drive provides the high speed insertion required for the reactor scram while the electric drive provides backup to insert the control rods.
Each control rod drive contains its own hydraulic accumulator whicn is constantly pressurized so that the reactor can be scrammed even if the electric power is not available.
In the event -that one or more control rods failed to insert, the boron injection system provides an alternate means of reactivity control.
The system is manually controlled from the control rcom to pump a baron solution into the reactor using high pressure core spray pumps.
(2) Reactor Cooiing In a normal plant shutdown, the main condenser is used to dissipate the decay neat generated in the reactor and tne reactor coolant inventory is maintained by the feedwater system.
During the initial stage of the normal shutcown, the decay heat is also dissipated through steaming to air ejectors and gland seals, and the seal injection and the purification flows also add coolant to tne reactor.
Other means of cooling the reactor are available using safety-related systems.
The shutdown condenser system and the high pressure core sprav system have the capability to provide cooling following reactor shutdown at all decay heat levels, reactor water temcerature and pressure wnile the decay heat cooling system and the alternate core spray system provide cooling at a recuced reactor pressure and temperature.
562311 a-;
P The shutdown condenser automatically functions when the reactor is isolated from the main condenser or if the reactor pressure exceeds 1,325 psig.
It is a fail-safe system in that the loss of instrument air or electric power will cause the steam inlet valves, the condensate return valves and the shell side water supply valves to open.
Cooling is provided oy boiling off water in the shell side of the condenser.
Water is supplied by the demineraliced water system or, alternatively, by the high pressure service water system which also serves as the fire water system.
The shutdown condenser can cool the reactor down to about 300 F.
To cool the reacter to a lower temperature, the decay heat cooling system is used.
The decay heat is carried away frcm the reactor by the decay heat system and transferred to the component cooling water system which, in turn, rejects the heat to the service water system to be dissipated eventually to Mississippi River.
If the decay heat cooling system were unavailable, cooldown can be accomplished alternatively by using the aiternate core spray system.
Decay heat blowdown valves will be used to maintain the reactor water level in this application.
The high pressure core spray system provides backup to tne shutdown condenser for cooling the reactor when tne pressure is above 150 psig.
Alternatively, tre reactor can be decressuriced and cocidown accomplished by using either the decay heat system or the alternate core spray system. When using the core spray systems for reactor cooling, it is necessary to control the reactor water inventory oy periccically blowing down to the main condenser.
(3)
Instrumentation In addi' ion to those instruments associated with the systems discussed
- above, he following instrumentation is needed for the safe shutcown:
Neutron monitor Reactor level and pressure indication (4) Plant auxiliary power sources are the two service transformers which are fed by either the offsite or the unit generated power.
They provide 2,400-volt power to large plant loads as well as 480-volt buses A and B.
Each 480 volt bus supplies one 480-volt essential service (ES) bus in addition to various motor control centers (PCC).
Each E5 bus has a diesel generator for a cackup cower sucply.
The two ES buses can be tied to eacn other by a common feed.
125 volt buses fed from station batteries provice the DC cower source for various CC loacs and to inverters wnich in turn sucoly power to 120-volt AC noninterruptible buses.
4-2 562312 e
e The original design and construction of Lacrosse Boiling Water Reactor did not include divisional redundancy for systems important to safety.
Many systems required for shutdown and cocidown of the reactor, however, were provided with alternate means of fulfilling the safety-related function in the event that the system is unavailable.
In subsequent backfits, the licensee has provided redundancy in certain functions.
The Fire Hazard Analysis of the Lacrosse Boiling Water Reactor, dated February 14, 1977 discussed how the reactor can be brougnt to a hot shut-down condition postulating a fire in any one plant area.
The analysis, however, did not provide assurance that the plant can be brought to and maintained at a cold shutdown condition during and following a major fire in each fire area. Moreover, the analysis postulates a mechanistic loss of cables which could be damaged by the fire but did not address the possibility that cables could be damaged to produce undesirable actions which could have adverse effects on safe snutdown operations.
The licensee will provide an analysis to demonstrate that the safe shutdown capability exists independent of cabling and equipment in any one fire area or to verify the effectiveness of the barriers, spatial separation, tray covers and/or fire stops in preventing simultaneous damage to redundant safety systems required for safe shutdown from a possible exposure fire involving the fixed combustibles in the area and a reasonable amount of transient combustible materials, which may be in the arec :or routine plant ocerations and maintenance.
In addition to damage resulting from elevated temperatures, the analysis will consider the effects of:
(1) Smoke and heat propagation via open stairways and hatches, and unrated penetrations in barriers.
(2) Water spray damage from fire water application.
(3) Simultaneous fire and loss of offsite power.
The licensee will propose, at the completion of the sautdown analysis, modifications to assure that the plant's shutdown capability will meet the following criteria:
(1) Following any fire, the plant can be brought to hot shutdown conditions using equipment and systems that are free of fira damage.
(2) The plant should be capable of maintaining hot shutdown conditions for an extended time period significantly longer than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
(3) Fire damage to systems necessary to achieve and maintain cold shutdown conditions should be limited so that repairs can be made and cold shutdown conditions achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
(4) Repair procedures for cold snutdown systems should be preoared now and material needed for such repairs should be on the site.
4-3 562313
(5) The hot,hutdown condition must be achievable with pcwer from the offsite power system, and upon its loss, with power from the onsite pcwer system.
A dedicated power supply may be substituted for the onsite power systems.
(6) The power needed to achieve the cald shutdown condit on may be obtained i
from any one of the offsite power, onsite power, and dedicated power systems.
(7) When these minimum systems are provided, their adequacy shall be verified by a thorough evaluation of:
(a) Systems required for hot shutcown; (b) Systems required for cold shutdown; (c) Fire damage to power distribution systems; and (d)
Interactions caused ' y fire damage to power and water supply a
systems and to supporting systems, e.g., component cooling water supply.
The licensea will also :onduct a study to identify critical cables whicn have a potential of producing adverse effects on safe shutdown if camaged.
Additional protection for these cables vill be proposed.
We will address the safe shutdown capability of the plant, during and following a fire, in a supplement to this report.
4.2 Fire Detection and Sicnalinc Systems The plant has a protective signaling system which transmits various fire alarm and supervisory signals to the control rocm.
In acdition to signals from smoke detectors located in selected areas in the plant, the system also transmits alarm and supervisory signals concerning diesel fire pump operation or impairment, fire main pressure, caroon dioxide system actuation or trouble, and water flow in the automatic sprinkler syste.-'s.
The signalir.g system is provided with backuo power in the event of a loss of offsite power by a connection to the noninterruptible bus supplied by the 18 emergency diesel generator.
ine signaling system does not comply with NFPA 720 in that tests of sprinkler waterflow alarm dev'ces are performed at intervals greater than that permitted by NFPA 720, sprinxier system drain tasts are not mace folicwing system control valve operations, ano the zone indicating units of the signaling system nave been modified by tne licensee in a manner tha! woulc permit loss of detection in part of t9e system without knowlecge of the operators.
A cyoass switch has been installed into tne circuit of each detector zone. wita a necn lignt to indicate wnen the cne nas oeen
.1-4
% 2314
bypassed.
This arrangement could permit a zone to be bypassed indefinitely because the bypass indicating lights are not visible from the part of the control room which are normally occupied.
The licensee agreed to test sprinkler system waterflow alarm at 2-month intervals and perform sprinkler system drain tests following operation of system control valves.
The licensee will also install a timer for each detector zone to provide a warning when a detector zone has been bypassed for a certain period of time.
Smoke detectcrs have been provided in selected areas of the plant.
Heat detectors have also been provided for actuation of a carbon dioxide extin-guishing system.
The licensee indicated that in-situ tests were conducted, using canned smoke, to verify the adequacy of the type, numbe, and dis-tributicn of detectors in each plant area.
The procedure and acceptance criteria of the tests have been provided and are currently being reviewed.
Alarm, supervisory, and trouble signals are annunciated in the control room visually, and audibly by a common alarm bell waich is distinctive from other plant system alarms.
A local predischarge alarm is provided at the area where the carbon dioxide system is installed.
Smoke detectors at the air intakes to the turbine building are arranged to close the air intake dampers upon activation.
We find that, subject to implementat' ion of the above described modifications, the fire detection and signaling systems satisfies the objectives identified in Appendix A to Branch Technical Position 9.5-1 and is, therefore, acceptable.
4.3 Fire Control Systems 4.3.1 Water systems The fire protection water system is also the high pressure service water system (HPSW).
In addition to supplying water for fire protection, the HPSW system supplies water for safety related and nonsafety-related services as identified in Section 4.3.1.3.
The schematic of the fire water piping system is shown in Figure 4.3.1.
4.3.1.1 Water Supply The fire protection water supply for the plant is provided by the Mississippi River, which also serves as the ultimate heat sink.
Water is channelled to the fire pumps in the crib house by a reinforced concrete flume.
We ':nd that the water supply satisfies the objectives identified in Appendix A of BTP 9.5-1 and is, therefore, acceptable.
4.3.1.2 Fire Pumps The water supply is developed by two diesel driven vertical shaft centrifugal fire pumps, each with a rated output of 750 gpm at 125 psig, and a motor SG'd315 4-5
f 4
- ~.. ATIP. ::::.' 3 3:h!"'.TI:
"C ::
1.
Fire pumps are also high pressure service water pumps; and CRIB 2.
Water supplies to interior hose stations, i
HOUSE the automatic water sprinkler system, and I
safety-related services are all connected DIESEL FIRE to the distribution header in the turbine i
PUMP 1A I
building.
l DIESEL FIPI PUMP IB i
i H M NT #3 HYDRANT Fl HYDRANT #2 i
i i
PUMP IB d
TURBINE ELECTRIC MOTOR BLDG.
DRIVEN FIRE PUMP DISTRIBUTION
-?
HEADER l
l O
l 4 DRANT #4 HYDRANT #5 i
l l
I i
I I
I A
POSSIBLE CONNECTIONS TO UNIT 3 (Fossil Plant)
FIG. 4.3.1 SG2316
i driven horizontal shaft centrifugal booster pump with a rated output of 500 gpm at 65 psig.
The diesel pumps, which take suction through suction lines from a common sump, are adjacent to each other in the crib house.
The motor driven pump is on the grade floor of the turbine building and takes suction from the 16-inch low pressure service water main.
The low pressure service water system is supplied by two redundant 3000 gpm at 145-foot head motor driven pumps in the crib house.
A UL listed automatic fire pump controller is located in the same area with each diesel fire pump.
Each of these pumps can be manually started or stopped from the control room or at the individual controller.
Pump running, driver nonavailability, and pump driver trouble signals are annunciated in the control room.
Additional annunciation is provided at each fire pump controller.
One diesel pump will start at a fire main pressure of 70 psig.
The second diesel pump will start when the pressure drops to about 60 psig.
The electric motor driven pump operates automatically to keep fire main pressure between 80 and 120 psig.
There is no automatic or manual fire pump controller for this pump, because it also supplies water for other purposes.
See Section 4.3.1.3 of this report for discussion of these other purposes.
It is controlled from a switch in the control room, and can be stopped at a breaker in the turbine building.
All fire pump con-trols in the control room are located together on a single panel board, along with the controls for the low pressure service water pumps.
Adminis-trative controls require at least one diesel driven fire pump control to be in the " automatic" position at all times.
Power for the electric motor driven pump is supplied from the normal AC system.
Each diesel engine driven fire pump is provided with a fuel tank containing enough fuel to operate the engine for at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
The licensee has provided a locking filler cap to each tank to prevent a possible tampering.
The fuel tanks are buried so that the bottom of the tank is approximately 6 feet below the fuel pump on the associated diesel engine.
This arrangement is not permitted by the current edition of NFPA 20, although it was allowed by the code when the plant was built.
In addition, fuel lines are not interconnected so that all engines may con-tinue to operate even though one fuel tank may be out of service or empty.
Interconnection of fuel supplies is now required by NFPA 20, although it was not required by the code when the plant was built.
To improve the reliability and availability of fire water, the licensee is studying the feasibility of interconnecting the fire water system with that of Unit 3 (fossil fuel generating unit) of the plant and include the diesel fire pump and the relevant portion of fire water piping in the Unit 3 fire water system in the surveillance program.
The diesel fire pumps discharge into 6-inch diameter overhead lines in the crib house which parallel one another before joining together into a single 6-inch diameter line which supplies the 6-inch yard main.
56231*?
4_7
The 6-inch overhead line inside the crib nouse also supplies the two 3-inch diameter lines for the traveling screen wash.
Lccked open valves are installed to isolate either pump discharge line, but there are several piping sections in which a break could not be isolated without causing the nonavailability of both diesel driven pumps.
See Section 4.3.1.3 of this report for more details.
The motor driven fire pump discharges into the 6-inch fire main in the turbine building.
Calculations indicate that the fire suppression water requirements for the largest sprinkler system plus 500 gpm for hose streams, will exceed the capacity of any one of the three existing fire pumps.
The licensee is studying the situation to find an arrangement which will assure that a sufficient number of pumps are available at all times to meet the fire suppression system requirements for water.
Arrangements suggested to the licensee include providing one of the diese# engine driven fire pumps with a separate connection to yard fire main loop incependent of the existing 6-inch pipe from the crib house and providing an appropriate fire barrier to separate the diesel engine driven fire pumps from each other, or providing a per;:anent connection between LAC 5WR yard fire main loop anc the adjacent fossil plant yard fire main loop and assuring that a reliable autcmatic fire pump with a rated capacity with at least 750 gpm at 125 psig is available at all times from the adjacent plant.
Recent fire pump test data did not cover the entire range of pump dis-charge from 0 to 150% of rated capacity. Without this information, the staff cannot comolete its evaluation of the adequacy of fire pumps at the plart.
The licensee will provide the results of a full range fire pump flow test for each fire pump, covering the range of pump discharge from shut off to 150% of rated capacity, with the associated discharge pressure and pump speec. We will address the acceptability of the fire pumps in a supplement to this report.
4.3.1.3 Fire Water Picino System The 6-inch discharge line from the crib house supplies the 6-inch under-ground leap main wnich encircles the plant on tnree sides and casses through the turoine building to complete the locp.
All yard fire hydrants, autcmatic water suopression systems, and interior hose stations are supplied by this 1000 main. Only two key operated (curo) valves are provided as sectional valves on the exterior portion of this loop.
These valves are in locked curb boxes which are checked weekly.
The valves themselves are cycled twice yearly.
No sectional valves are provided on the interior porticn of the system.
This arrangement is unsatisfactory because a single failure in certain locations could cause the loss of both primary and backup sucpression systems in the plant.
The licensee is consicering provicing additional visually indicating sectional valver to assare availability of at least two sources of supoly to the fire protection water system and precluce the loss of primary (automatic) and backup (mar.Jal) water suceressien cacacility to areas so protected.
Valves controlling water flow into sorinkler systems are sealed anc checked weekly.
562318 4-3
Yard fire hydrants have been provided at intervals of 200 to 250 feet around the exterior of the plant, except that hydrant #5 is on the outside of the chain link security fence around the plant.
However, other hydrants are within reasonable distances of building openings and yard areas, so the present arrangement is acceptable.
The lateral to each hydrant is controlled by a key-operatad (curb) valve.
Two hose houses are in the
- r "d.
Each hose house contains several lengths of 1 -inch hose, hydrant wrenches, hose no::les, and other equipment.
The licensee will provide additional manual fire fighting equipment as itemized in Section 3.1.l(1) of this report, and two additional hose houses.
The new hose houses will be located near the northwest entrance to the turbine building and in the vicinity of the "B" diesel generator area.
Admitistrative procedures as identified in Section 3.1.l(2) through (5) of this report will be estao-lished to assure the availacility of the yard hydrants.
Threads on hydrant outlets and hose connections throughout the plant are National Standard Fire Hose Connection Screw Thread, and are compatible sith those of fire departments which serve the plant.
The plant fire protection water system is also the high pressure service water system (HPSW).
In addition to supplying water for fire protection, the HPSW supplies water for the alternate core spray system, the high pressure core spray system (back up water supply only), the air comoressor cooling system (back uo only), the shutdown ccndenser supply (back up for demineralized water system), the eductor on the turbine condenser monitor (back up only), and the crib house traveling screen wash.
Except during an emergency accident condition, the last two systems are the only ones which normally place a demand on the HPSW.
The required ficw is about 75 gpm, most of which is for the screen wash at the crib house.
The licensee contends that although the fire water system comoines the function of the service water, emergency shutdown and cooldown of the reactor can be accomplished without using the HPSW system.
In this operation, reactor cooling is provided by the shutdown condenser using the demineralized water system so that during the period of fire fighting there is a separation between the fire water system and the system providing tne function of the service water.
The licensee will provida the results of an analysis wnich demonstrate that the combined water demand for fire fighting and for safety-related functions can be satisfied under any fire emergency or accident.
Postulated fires need not be tonsidered concurrent with other plant accidents.
However, accident induced failure or malfunction of the fire suppression system, such as a steam line break opening the sprinkler heads, or a broken pipe whipped to break fire water piping, will be considered.
We will address the adequacy of the fire water ciping system in a supolement to this report.
4-9 562313
4.3.1.4 Interior Hose Stations Five interior hose stations equipped with 75 feet of 1 -inch diameter unlined linen fire nose are provided in the turbine building, and a simi-lar hose station is provided in the waste disposal building.
A hose reel with 50 feet of 1 -inch diameter lined and jacketed fire hose is provided in the "B" diesel generator electrical equipment room.
A fog nozzle is provided on each of the above hoses.
Four hose cabinets, each witn 75 feet of 3/4-inch unlined linen hose and an adjustable garden type nozzle are provided in the containment building.
Present hose station locations may not provide sufficient hose reach in all plant areas for effective application of water for suppressing a fire.
System pressure losses may result in inadequate flows or pressures at hose nozzles.
Access to some interior hose stations in the plant is presently blocked by storage areas.
Interior hose stations provided for protection of safety-related areas of the plant are presently equipped with linen hose, which is not suitable for industrial fire fighting.
Three quarter inch hoses and nozzles provided inside containment will produce excessive pressure drop and are, therefore, inadequate for fire fighting.
The licensee will perform hose reach tests and provide additional hose stations as necessary to assure that all coints in safety-related areas, including those areas protected by automatic suppression systems, and other plant areas which contain major fire hazards can be reached effectively by at least one hose stream.
The licensee will further perform tests and/or calculations to confirm that the flowing pressure at each hose station outlet is greater than or equal to 65 psig at 100 gpm flow rate.
Administrative controls will be established to prevent access to manual fire fighting equipment from being restricted by temporary storage of materials within the plant.
The existing linen hoses will be replaced by 1 -inch 100% polyester, single jacketed. lined, FM or UL listed fire hoses, factory test rated at not less than 300 psig, for those hose stations which are provided to protect safety-related systems and components.
Additional equipment as listed in Section 3.1.2(1), (2), (3),
(7) and (8) of this report will be provided to facilitate manual fire fighting.
The length of the hose at all interior hose stations will be limited to 75 feet maximum and the 3/4-inch hoses and nozzles inside the containment have been replaced with 1 -inch UL or FM listed fire hoses and nozzles.
We find that, subject to implementation of the above described modifica-tions, the interior fire hose stations satisfy the objectives identified in Appendix A of BTP 9.5-1 and are, therefore, acceptable 4.3.1.5 Water Suporession Systems Wet pipe automatic sprinkler systems have been provided in the turbine building to protect the turbine oil reservoir, and in the office building to protect the oil storage room.
4-10 562320
The main control valve for each sprinkler system is locked open and checked weekly. Water flow in these systems is alarmed and annunciated in the control room.
The licensee has proposed to extend coverage of the sprinkler system protecting the turbine oil reservoir to include the associated piping in the same area.
In addition, the licensee will:
(1) Provide an automatic water suppression system, or an oil shield and collection system at the reactor coolant recirculation pumps.
(2) Provide an automatic fire suppression system (water or other suitable agent) to protect the "A" ciesel generator room.
(3) Provide a fixed cry pipe sprinkler system capable of quick connection to a manual hose at the exterior cable penetration of the containment building.
(4) Provide additional equipment as listed in Section 3.1.2(4) through (6) of this report.
(5) Provide an automatic water fire suppression system to protect against a fire at outside transformers.
We find that, subject to implementation of the above described modifications, the automatic sprinkler systems satisfy the objectives identified in Appendix A of BTP 9.5-1 and are, therefore, acceptable.
J. 3. 2 Gas Fire Sucoression Systems A total floodirg carbon dioxide suppression system is proviaed for the "B"
diesel generator room.
The system is automatically actuated by 160 F rate comoensation type heat detectors at the ceiling of the room, or manually actuated either at the fire alarm panel in the control room or at the switchgear room adjacent to the diesel generator room.
An alarm bell and a 30-second release delay are incorporatec for personnel evacuation.
Actuation of this system is annunciated on the control room fire alarm canel.
Pressure switches actuated by carbon cioxice discharge close room vent 'lation dampers and shutoff the room exhaust fan.
The heat detector circuit is not supervised, and a failure in this detection system would preclude automatic operation of the suppression system.
Tne licensee will supervise the heat detection system for power failure, ground faults, and ciruit creaks a'd to annunciate the supervisory signals in the control room.
The extinguisning system requires electrical power for automatic actuation of agent discharge.
The actuation power is proviced from Breaker 711 wnicn is connected to tne 120-volt AC essential aus tnat derives onsite backuo power from the diesel generator tne system is cesigned to orotect.
562321 2-11
It is possible, therefore, that in the event of a fire at "B" diesel rocm, the extinguishing system will be without onsite pcwer backup.
- Moreover, it was verified that the emergency manual control of the carbon dioxide system does not conform to the provisions in Section 1-8.3.5 of NFPA 12-1977.
The licensee will provide the actuation power for the carbon dioxide system from the essential bus which derives backup onsite power from the other diesel generator.
He will also modify the emergency manual release of the system to conform with the provisions of NFPA 12-1977.
The primary agent supply is from four 100 pound high pressure cylinders with a connected reserve supply of four more 100 pound cylinders.
All of these cylinders are in the rocm they protect, although NFOA 12-1977 indicates that they should not be locat.ed where they will be exposed to a fire.
Hcwever, because the detector circuit will be supervised, emergency power will be provided, and there will be an emergency manual release for the system, we find the arrangement of storage cylinders acceptable.
We find that the design of the carbon dioxide extinguishing system satifies the objectives identified in Section 2.2 of this report and is, therefora, acceptable.
The licensee has also agreed to install automatic fire sucpression systems to protect the "A" diesel generator rocm and the electrical equipment room.
Preliminary information received indicates that they will be gas systems.
We will evaluate these systems when design data are receivec.
- a. 3. 3 Portaole Fire Extincuishers Portable fire extinguishers have been provided throughout the pl 7t in accordance with the provisions of NFPA 10.
We find that the type and distribution of portable fire extinguishers ccmolies with the provision of Appendix A to Branch Technical Position 9.5-1 and is, therefore, acceptable.
4.4 Ventilation Systems and Breathing Ecuioment 4.4.1 Socke Removal Ventilation systems are provided for all indoor plant areas, but these systems are not designed specifically for smoke removal.
Nr'erthelets, installed air handling systems are capable of exhausting limited volumes of smcke, generally directed to the outside. Major exceptions include the turbine building, containment building, and waste treatment building, which discharge into the plant stack.
Ventilati0n system discnarge frem the reactor building, turoine building, and waste treatment building is monitored for radioactive contamination.
In case hign radiation levels are detectec in these areas, system air intake and exhaust are terminated autcmatically.
If smoke exhaust opera-tions are in Orogress, these will also De terminated.
The licensee has on a-12 562322
hand three portable smoke removal fans, each rated at about 1,000 cucic feet per minute, and several 15-foot lengths of 12-inch diameter flexible duct.
The licensee will provide one additional fire fighting type explosion proof smoke ejector, rated at 5,000 cubic feet per minute.
We find that, subject to implementation of the above described modifica-tion, the provisions for smoke removal comply with the requirements of Appendix A to Branch Technical Position 9.5-1 and is, therefore, acceptable.
4.4.2 Filters A charcoal filter is installed in the of f gas line from the air ejector, located in the 4,500 gallon waste tank room in the turoine building tunnel.
HEPA filter elements are located in the same housing as the charcoal filters.
The filters are contained in steel casings and there are no ignition sources located near the filters, nor can the buildup of radio-active products generate sufficient heat to cause ignition.
The amornt of combustibles in the area of these filters, other than the filters themselves, is also low.
We find that the fire protection for the charcoal filters complies with the requirements of Section 2.2 of this report and is, tnerefore, acceptable.
4.4.3 Breathina Eovicment The plant currently has on hand eight air masks, each with one h-hour rated air bottle, and a total of six spare bottles of the same rating.
A cascade system is currently 1ccated in the southwest corner of the turbine building basament.
The licensee will relocate the cascade system to a plant area wnere a fire in the area will not require its use.
This system currently does not provide.:_icient onsite reserve air supply.
The licensee will provide a 6-Ecc-onsite breathing air reserve for each of the existing eight breathing units, based on 20 minutes of air per bottle.
Two spare bottles will be provided for each unit.
We find that breathing equipment cceplies witn the provisions of Appendix A to BTP 9.5-1 and is, therefore, acceptacle.
4.a.4 Batterv Rocm Ventilation There are two battery rooms. One is the electrical equipment room and one is a separate room in the "B" diesel generator building.
The batteries in the electrical equipment room supply the turbine building static inverter and the reactor building motor generator set.
Ventilation air here is supplied from the control rocm HVAC system and is exnausted into tne turoine building.
The other batteries supply the diesel generator building standby 125 voit D.C. distribution bus.
Ventilation is oy a unit-tyce air concitioner anc seoarate exnaust f an in outsice wclls of the cattery rocm.
Hycrogen a-13 562323
monitors which alarm and annunciate in the control room have been installed in each battery roon We find that protection against hydrogen accumulation in battery roors complies with the provisions of Appendix A of Branch Technical Position 9.5-1 and is, therefore, acceptable.
4.5 Floor Drains and Curbs In general, safety-related equipment is mounted on pedestals. Where there are floor drains, they are adequate to remove fire fighting water prior to the equipment being flooded.
In safety-related areas where no drains are supplied, fire water will be satisfactorily drained through door openings.
The diked area around the outdoor fuel oil storage tank is adequate to contain the entire content of fuel oil in a full tank plus an additional capacity for fire fighting agent.
The curbed areas around the oil storage room, the turbine lube oil reservoir and the "B" diesel generator day tank are not sufficient to contain the content of oil in each area.
There are no curbs to contain an oil leakage in the "A" diesel room.
Since a clogged drain is not uncommon, in the event of a major oil leakage, there is a possibility oil fire may spread.
The licensee will add or upgrade curbs in the following areas to contain the entire content of oil in each area plus additional 10% capacity for fire water:
(1) the turbir,e oil reservoir, (2) "A" diesel room and (3) "B" diesel room.
An opening will be provided at the floor level of the oil storage room which will drain a possible oil accumulation in the room toward the yard area.
The plant's drainage systems are separated so that no areas containing flammable liquids have drains that are common to drains from safety-related There' ore, a fire could not spread from an area containing flammable areas.
liquids to a afety-related area by way of the drainage system.
We find that the floor drains and curbs satisfy the objectives identified in Section 2.2 of this report and are, therefore, acceptable.
4.6 Lighting 5 3 tem The emergency lighting consists of DC lighting units powered from the station batteries and AC units that have diesel backup power source.
In addition there are a few fixed sealed beam lighting units.
The arrange-ment of the lighting systems in the plant is such that both AC and DC emergency lighting systems as well as the normal lighting system are subject to loss due to a single fire.
The licensee will provide fixed, sealed beam, 8-hour rated battery powered emergency lights in all safety-related areas and their access and egress to facilitate emergency shutdown operation and fire fighting.
562324 4-14
We conclude that subject to implementation of the above described modifica-tions, the lignting system will provide ataquate lighting under the fire emergency and is, therefore, acceptable.
4.7 Communication The internal communication systems througnout the plant consists of:
sound powered phones, private paging and conference telephone system, FM and HF radio.
There are no repeater stations; hcwever, communications into the containment is achieved through the 5-watt radio system.
There is a possibility that both the sound pcwered phone system and the private paging and conference telephone system could be lost to a single fire, but the radio systems provide adequate backup.
We find that the plant's communication system meets the provisions of Appendix A to 3 ranch Technical Position 9.5-1 and is, therefore, acceptable.
4.8 Electrical Cables The majority of the electrical cables for this plant were ourchased and installed prior to the publication of IEEE 383 Standard for Flame Testing of Electrical Cables and do not meet this standard.
The original cables installed in the plant are mostly cross-linked polyethylene and polyvinyl cnloride.
The cross-linked polyethylene cable was testad under IPCEA 5-19-31 and the polyvinyl chloride cables were tested under IPCEA S-51-402.
These tests are not as demanding as the IEEE 383 Standard test, but these original caoles have been provided with the fire retardant coating.
The more recently installed cables are made of newer compoimcs of cross-linked polyethylene that have passed the IEEE 333 Standard.
The flame retardant coating, where it is provided, appeared to be apolied in an uneven manner and, in some cases, aere not applied to all caoles in an individual tray.
The licensee agreed to spot check the coating thickness in each safety-related area and repair, as necessary, to provide a thick-ness which conforms to the manufacturer's reccmmendation.
We find that, subject to implementation of the aoove described modification, electrical cables comoly with the provisiens of Appendix A to STP 9.5-1 and is, therefore acceptable.
4.9 Fire Barrier Penetrations Fire barriers in most plant areas are penetrated by doorways, ventilation ducts, electrical cables, and pipes.
4.9.1 Doorways ire barriers separating various fire areas or zones are peretratec by numerous coorways, most of wnicn are protected oy 3-nour rated accrs.
The remaiaing acorways are provided witn ib-hour rated coces, except inat tne 3-15 56Z3'25
air lock doors
'.o the containment building are not rated.
The licensee will replace toe 1 -hour rated doors from the
'A" diesel generator room to the machine shop, and from the machine shop to the penetration room with 3-hour rated fire doors.
The air lock doors are acceptable because of their heavy steel construction and secure latching mechanisms.
Other 1 -hour rated doors are considered acceptable because the estimated fire severity on either side of the doorway is less than 1 -hours.
Various doors have been modified for security purposes.
The licensee has provided further documentation to demonstrate that the fire resistance ratings of these door assemblies have not been reduced b, such modifications. We are presently reviewing this information.
Most fire doors in the plant are either normally closed and locked, or will be electrically supervised.
Two exceptions identified by the licensee are the door betweer the control room and the office area ha lway and the door between the change room and the hallway.
The former is in a constantly watched area and the latter separating two nonsafety-related areas.
We conclude that these exceptions are acceptable.
The information submitted by the licensee, however, did not indicate if all fire doors in the plant were included in his review of the door super-vision.
The submittal also failed to specify hcw and where the alarm will be provided.
In the subsequent discussion the licensee agreed to verify that, except for the two doors discussed above, all fire doors in the plant will either be locked closed or electrically supervised with a time delayed alarm in a constantly occupied area.
We find that, subject to implementation of the abcve described modifica-tions, protection for doorways complies with the requirements of Section 2.2 of this report and is, therefore, acceptable as described above.
4.9.2 Ventilation Duct Penetrations Fire barriers are penetrated by ventilation duct penetrations in two areas of the plant.
One area is the ventilation opening between the change room in the office building and the mezzanine floor of the turbine building.
The opening is protected by a 1 -hour rated fire damper operated by fusible link.
The other area is between the electrical equipment room and the instrument repair room on the mezzanine floor of the office building.
The ventilation duct supplying air from the control room air conditioning system in the electrical equipment room penetrates the wall to the instru-ment repair room without fire dampers at these penetrations.
An additional duct penetration for the instrument repair room to the electrical equipment room is also not provideo with a fire damper.
The licensee will protect these ventilation duct penetrations by installing fusible link actuated, 1 -hour rated fire dampers.
4-6 56232G
We find that, subject to implementation of the above described modifications, the protection of ventilation duct penet-ations is adequate to prevent the spread of a fire via the ventilation ducts.
4.9.3 Electrical Cable Penetrations Cable tray and conduit penetrations of fire barriers were not sealed in the original design of the plant.
Following the fire hazard analysis conducted to compare the fire protection program at Lacrosse with the guidelines of BTP 9.5-1 and Appendix A, the licensee sealed all cable penetrations outside containment by filling the opening with mineral wool and covered by a flame retardant coating.
This sealing arrangement has not been tested in accordance with ASTM E-119 and the fire resistance of this arrangement cannot be established by the information currently available.
The licansee has agreed with the staff's recommendation to modify the existing electrical cable penetration seals to a design with established adequate fire resistance.
We find, subject to implementation of the above described modification, fire protection of the cable penetrations comply sith the provision of Appendix A to BTP 9.5-1 and is, therefore, acceptable.
4.9.4 Picina Penetrations Piping penetrations through fire barriers, except for those into the reactor building, are not sealed.
The licensee has proposed to close all such unsealed pipe penetrations with a noncombustible material, except where limited by seismic consideration.
Because resilient materials are available to provide fire resistant penetration seals that will not affect the seismic characteristics of piping systems and because the penetration seals are not required to withstand the safe shutdown earthquake, we recommended that all piping penetrations should be sealed.
The licensee agreed to seal all piping penetrations and provide information concerni.1g the material and construction which will establish the fire resistance of tne seal.
We find that, subject to implementation of the above described modifications, protection for piping penetrations of fire barriers complies with the requirements of Appendix A to Branch Technical Position 9.5-1 and is, therefore, acceptable.
4.10 Cable Separation The design and construction of the Lacrosse plant predate IEEE Standard 33a on criteria for separation of Class lE equipment and circuits.
Althougn many plant systems imcortant to safety are proviced with alternate means to achieve the safety functions, the original plant design did net incluce divisional redundancy, and consequently divisional separation, for safety-related caoles and equipment.
E-17 kb(h
/!
Subsequent to the issuance of the provisional operating license, another train of diesel generator and station batteries were added to provide redundant AC and DC power sources for certain systems imocrtant to safety.
However, no criteria were established to physically separate redundant cables or cables serving alternate systems.
Redundant cables or cables serving alternate systems were observed to be routed in the close proximity of each other without barrier interposition; in many cases redundant cables are routed in a common tray.
Safety-related cables are not marked as required by industry standards and difficult to identify.
The licensee will conduct an analysis to determine if safe shutdown caca-bility exists independent of cabling and equipment in any single fire area, or to demonstrate the effectiveness of barriers, sDatial separation, tray covers and/or fire stoos in preserving tne safe shutdown capability against the effects of a major fire in any one fire area.
If the results of such analysis could not provide reasonable assurance that the cacability to safely shut down and cool down the reactor can be maintained curing anc following a fire, additional modifications will be required to preserve such capacity.
We will address the adequacy of cable separation in a supplement to this report.
4.11 Fire Barriers Most fire areas are secarated from each other by walls, floors, and ceil-ings which have at least 3-nour fire resistance ratings.
Safety-related areas separated from each other or from nonsafety-related areas by barriers rated less than 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> were evalcated and it was concluced that the barriers around these areas are adequate to prevent the spread of fire or protect the safet" related areas against hazards from nonsafety-related areas.
There are other safety-related areas separated from each other or from nonsafety-related areas by barriers for wnich a rating has not been deter-mined, including:
The oil storage room and me::anine level of the office area.
Although the depth of cover of the reinforcing steel in the 6-incn concrete floor between the two areas is unknown, this arrangement is consicerad acceptaLle because of the limited hazara presented to the oil storage room by the office area.
The "A" diesel generator room and the machine shop.
The turoine building and the main and auxiliary transformers.
The licensee will upgrade the barrier between the "A" diesel room ana tne macnine shop to orovice fire resistanca acecuate to :antain fire hazarcs 4-13 562328
in the diesel rocm.
An automatic water fire suppression system will be installed to protect the turbine building frca a fire at outside trans formers.
There are also several plant areas in which the failure of exposed structural steel supporting fire barriers could imoair the safe shutdown capability of the plant.
These areas include the machine shcp and turbine building.
The licensee has proposed to protect the exposed steel supporting the machine snop ceiling with a 3-hour rated fire barrier.
The licensee is also analyzing the possibility of a fire in the turbine building damaging exposed structural steel and the safety consequences of such damage.
Additional modifications will be proposed if the results of such analysis reveal the need for protection of exposed structural steel.
We find that, subject to implementation of the above describea modifica-tions, the design of fire barriers meets the cbjectives identified in Section 2.2 of this report and is, therefore, acceptable.
4.12 Access and Ecress Most safety-related areas are reasonably accessible for manual fire fight-ing.
Frcm an entrance on the grade ficor, an enclosed stairway joins all tnree levels of the main building grade level, mezzanine level, and main level.
In addition, access to various plant areas in the 7.ain building is also possible frcm the machine shop and from the turoine building via cpen stairways.
During normal operation, the containment is sealed.
Access and agress is available through an interlocked double-door air lock at elevation 642'-9" Special procedures must be follcwed to gain access.
The crib house has two doors for access and egress, but the building is somewnat congested with equipment which could slow up manual fire fignting.
In those safety-relatea areas wnere access for manual fire fighting is limited, additional protection in tha form of automatic water suopression, nazard containment, and/or alternate shutdown capability will be proviced or required to compensate for such shortcoming.
Such areas are discussed in Section 5 of tnis report.
It is therefore concluded that, subject to the aoove described modifica-tion, access and egress to various plant areas are adequate for fire fighting.
This satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
J.13 Toxic and Corrosive Combustion Products The products of comccstien of many polymers are toxic to humans and : rro-sive to metals.
Promot fire detection and extinguisnment are reliec upon to recuce the quantity of such products procuced during a fire.
' deans of 562329
- _3
smoke removal, as discussed in Section 4.4.1, are proviced as an aid in fire fighting access. Members of the fire brigade will be provided with, and trained in the use of, emergency breathing apparatus for fighting fires involving such materials.
We find that, subject to implementation of the mcdifications described elsewhere in this report, the precautions taken to reduce the effects of toxic and corrosive products comply with the objectives identified in Section 2.2 of this report and are, therefore, acceptable.
4.14 Nonsafetv-Related Areas We have evaluated the separation by distance or by fire barriers between safety-related and nonsafety-related areas to determine that fires in nonsafety-related areas will not adversely affect the ability to safely shut down the plant.
Nonsafety-related areas which potentially pose a fire hazard to safe shutdown equipment are addressed in Section 5.0 of this report.
4.15 Instrument Air It was verified that air-cperated valves required for safe shutdcwn will fail in safe positions in tne event of a fire-induced loss of the instrument air system.
Therefore, safe shutdcwn will not be prevented if instrument air is lost.
562330 4-20
5.0 EVALUATION OF SPECIFIC PLANT AREAS The licensee has performed a fire hazard analysis of the facility to determine the combustibles present in various plant areas, to identify the consequences of fires in safety-related areas and to evaluate the adequacy of fire protection systems.
The results of this analysis, other dccketed information, and site visit observations were used in the staff's evaluation of specific plant areas which is discussed in the folicwing sections.
The licensee has committed to perform additional studies on issues listed in Section 3.2 of this report to identify problematic areas and propose, if necessary, additional modifications.
Exactly whicn plant area (s) will be affected by these studies are nnt known a priori.
The conclusions made in the following sections for various plant areas are based on the assumption that additional modification (s), consistent with the objectives of Section 2.2 of tnis report, will be provided should any one of these plant areas be identified by such studies to have a problem not identified previously.
5.1 Turbine Building 5.1.1 Sarety-Relatec Ecuicment High pressure service and demineralized water supplies, component cooling water for the decay heat removal system, main steam valves, and associated switchgear and motor control centers are in the turbine building.
5.1.2 Combustibles The major ccmbustible materials include 4,000 gallons of turbine oil in the turbine oil reservoir and piping, 40 gallons of hydraulic cil for the main steam bypass valve, 1,500 pounds of cable insulation, and a00 pounas of miscellaneous combustibles.
5.1.3 Consecuences if No Fire Sucaression The turbine oil reservoir is on the grade ficar of the turoine building.
The area over the reservoir is open to the unders. A of the main ficor.
A fire involving the contents of this reservoir or associated piping would, therefore, expose the unprotected structural steel supoorts of cotn floors above.
Collapse of these supports could degrade the safe shutdown ability of the plant.
It has not been demonstrated that a fire or exolosion involving the trans-formers outside the west end of the turoine building will not affect the safe snutccwn capability of the plant.
The extorior wall at the main ficar level is insulated metal of undetermined fire resistance, and tnere are large non-rated air intake louvers in tnis wall.
5-1 UG2331
The licensee's fire hazard analysis has not demonstrated that safe shut-down can be achieved and maintained given a fire at any location in the turbine building.
5.1.4 Fire Protection Svstems An autcmatic sprinkler system is installed over the turbine oil reservoir.
Five interior hose stations, each provided with 75 feet of Ib-inch diameter unlined linen hose, are in the turbine building.
Portacle extinguishers are also provided.
Ionization-type smoke detectors are located in most areas, including the downstream side of the turbine building air intake louvers.
Detectors in this latter area are arranged to close the louvers upon detection of smoka from a fire outside the turbine building.
5.1.5 Adecuacy of Fire Protection The automatic sprinkler system is not adequate to control or sucpress a fire involving the turbine oil piping on the grade floor away frem the turbine oil reservoir.
Curbed area around the reservoir is not adequate to contain the content of oil in the reservoir.
Portable extinguishers would not be adequate for control of a large turbine oil fire.
Interior nose might also be inadequate to control such a fire.
In addition, the existing unlined linen hose is not suitable for fire fighting in industrial buildings.
Unprotected structural steel may not be capable of supporting a load when exposed to a fire involving combustible liquids.
Tne protection of the turbine building frcm fire or explosion in one of the outside oil-filled transformers has not been shown to be adequate.
5.1.5 Modifications The licensee will:
(1) Extend the automatic sprinkler system to protect the turnine oil piping west of the turoine oil service tank.
(2) Conduct a study to determine the need for protection of exposed structural steel.
(3)
Install an automatic water fire suppression system to protect the turbine cuilding from a fire at transformers.
(4) Upgrade the curbs around the reservoir to a capacity sufficient to contain tne entire content of oil plus 10% acditional capacity for fire water.
5-2 fig 2332
a We will address the adequacy of fire protection in the turbine building in a supplement to this report.
5.2 011 Storace Room 5.2.1 Safety-Relaten Ecuioment A 6-inch high pressure service water line and a low pressure service water line run through this room.
5.2.2 Ccmoustibles The major combustible materials include the contents of the 4,000 gallon clean turbine oil tank, 4,000 gallon dirty turbine oil tanx, 1,000 gallon auxiliary boiler fuel oil tank, six 55 gallon drums of lubricating oil, various containers of flammable and ccmoustible liquids stored in three flammable liquids storage cabinets, and a large compressed gas cylincer containing 10 percent methane and 30 percent argon for use in the labora-tory.
The 4,000 gallon clean oil tank is normally empty.
Containers for acids and other chenicals are also stored in the UL listed flammacle liquids storage cabinets in this rocm.
5.2.3 Consecuences if No Sucoression The licensee has not provided an evaluation of consequences of an unmiti-gated fire in this room.
However, it is likely that a severe fire could result, exposing the service water lines and its nangers to high tempera-tures for a considerable length of time.
5.2.4 Fire Protection Svstems An automatic sprinkler system is installed to protect the room contents.
The sprinklers are located 2b feet below the ceiling, somewnat in excess of the maximum allowed by NFPA 13.
Ionization-type smoke detectors are installed here.
Portable fire extin-guishers and interior hose lines are available from adjacent areas.
5.2.5 Adecuacy of Fire Droteccion Fire protection in this room is not adequate, because of the possibility of damage to the service water lines or their hangers, and because the curb is not high enough to contain the entire content of oil in the event of a major break to the tanks or associated piping.
Ionization-type smoke detectors should provide promet detection of fires in this area.
The installed automatic sorinkler system srould be cacable of controlling fires in this room, although sprinkler 5.uation time will probably oe greater than if the sprinklers haa been istalled closer to the ceiling in accordance witn NFPA 13.
5-3 662333
e Acids and other chemicals should not be stored in the flammable liquid storage cabinets becatse of the possibility that the flammable liquid container or cabinet may be damaged by these acids and chemicals and that the chemical reaction may provide an ignition source.
5.2.6 Modifications The licensee has provided protection for the service water piping and its supports.
The miscellaneous acids and chemicals will be removed from this room and stored elsewhere in a suitable cabinet, and an opening will be provided at the floor level to drain away a possible oil accumulation in the room toward the yard area.
We find that, subject to implementation of the above described modifica-tions, fire protection for the oil storage room complies with the require-ments of Appendix A to Branch Technical Position 9.5-1 and is, therefore, acceptable.
5.3 Machine Shop Area and "A" Diesel Generator Room 5.3.1 Safety-Related Equipment The "A" diesel generator and certain cable tray runs between the penetra-tion room (5.6) and the electrical equipment room (5.9) are in this area.
The diesel generator is in a separate room, separated from the rest of the area by a 6-inch masonry wall.
The doorway to this room from the machine shop is protected by a pair of Class B labelled fire doors.
5.3.2 Combustibles The combustible materials in this area include 100 gallons of diesel fuel oil in the diesel generator day tank located in the diesel generator room cable insulation, and several hundred pounds of ordinary combustibles in the machine shop area.
5.3.3 Consequences If No Fire Suopression An unmitigated fire here could damage the "A" diesel generator and electrical cables between the penetration room and the electrical equipment room.
However, the licensee's fire hazards analysis has not provided sufficient information to permit the staff to conclude that an unmitigated fire in this area would have no effect on the safe shutdown capability of the plant.
A major fire in this area could also damage exposed steel at the ceiling which supports the electrical equipment room floor.
5.3.4 Fire Protection Systems An ionization-type smoke detector which alarms and annunciates in the control room is installed in the emergency diesel generator room.
Portable extinguishers and interior hose are available from adjacent areas.
Ionization-type smoke detectors are also installed in the electrical shop portion of the machine shop.
5-4 tiG2334 6
4 4
- 5. 3. 5 Adecuacy of Fire Protection The installed smoke detectors should provide early warning of fire in the protected areas.
Portable extinguishers and interior hose lines should be adequate to limit fire damage to the machine shop area.
Fires in the diesel generator rocm will likely damage cables and equipment in tne machine shop area before they are extinguished.
The exposed steel supports for the ceiling of the machine shop are subject to failure resulting from exposure to a severe fire.
There is no curb around the day tank area to prevent the spread of a possible liquid fire in the event of a major oil leakage.
No oil shutoff is available frcm outside of the room to cut off the oil ficw if the day tank or makeup piping leaks.
5.3.6 Modifications The licensee will:
(1) Provide 3-hour protection for the exposed structural steel sucporting the ceiling of the machine shop.
(2) Provide automatic fire suppression to the diesel generator roca and the capability to shut off oil transfer to the diesel generator day tank from outside tne room.
(3) Provide caoability to shutoff oil transfer to "A" diesel day tank from outside the rocm.
(4) Provide curbs around the day tank of "A" diesel to contain the entire content of the tank, plus 10% additional capacity for fire water, in the event of a major leakage in the oil system.
(5) Upgrade the barrier between the "A" diesel room and the macnine shoo to provice an adequate fire resistance and replace the existing door with a 3-hour rated fire door.
We will address the adequacy of fire protection in this area in a supple-ment to this report.
5.4 Penetration Room 5.4.1 Safety-Relatea Eouicment The safety-related equipment in this area consists of essential cus switch-gear lA, a portion of tne core scray line, and safety-related caoles.
52335 5-5
5.4.2 Combustibles The comoustibles in this area consist of cable insulation and electrical components in the essential bus switchc3ar lA.
5.4.3 Consecuences if No Fire Sucoression An unmitigated fire could damage many cables entering containment through this area and cause the loss of essential bus lA.
The contrcl rod drive system will shut down the reactor on the loss of electric power.
Core cooling could be provided by the shutdown condenser using local manual control and visual nbservation of instrument inside containment.
The licensee, however, did not analyze the effects of a fire damage in this area on the long-term cooling capability of the plant, and the possibility of circuit interaction among damaged cables.
5.4.4 Fire Protection System Ionization-type smoke detecters are installed to provide early warning.
Manual suppression capability is provided by portable extinguishers and ih-inch interior hose lines.
5.4.5 Adecuacy of Fire Protection Manual fire fighting would be adequate to suppress a fire in this area except the access to the penetrations is obstructed by the fiber glass panels installed to protect the penetrations fecm ructure of water pipes.
The lh-N ur rated fire doors may not provide adequate protection against fire hazards from the outside.
5.J.6 Modifications The licensee will provide a fixed dry pipe sprinkler suppression system, capable of quick connection to a manual hose, to facilitate fire fighting at the penetration.
Th' licensee will also replace tne Class B, 1 -nour dcors with Class A, three hour decrs.
We wiil address the adequacy of fire protection for this area in a supple-ment to this report.
5.5 "B" Diesel Generator Buildinc 5.5.1 Safety-Reiated Eculement The safety-related equipmerit in this area consists of the "B" diesel generator, essential bus 1B switchgear; the station stancby battery bank, and cables that feed safety-related eouipment.
3-5 56233G 1
/
i 5.5.2 Combustibles The combustibles in this area consist of diesel oil, polystyrene battery cases, and cable insulation.
Hydrogen could be generated in the batteries.
5.5.3 Consecuences if No Fire Sucoression A fire in this area could disable the essential bus 18 and the station standby battery bank.
The plant would be deprived of onsite power to one emergency core spray pump, one seal injection pump and the reactor building motor control center lA.
The reactor, however, can be tripped manually from the control room, or automatically on loss of power to the control rod drive system. The capability to cool the reactor will not be affected.
5.5.4 Fire Protection System A total flooding carbon dioxide system is installed to protect this area.
The system is actuated automatically by fixed temperature heat detectors and can also be initiated manually.
Ionization-type smoke detectors are provided in addition to those heat detectors actuating the CO2 system.
Portable extinguishers and manual hoses, from both the interior hose station and the outside hydrant, are available for manual fire fighting.
5.5.5 Adecuacy of Fire Protection The automatic carbon dioxide system would be adequate to suppress a fire in this area.
The circuit of heat detectors that actuate the automatic carbon dioxide system is not supervised and, therefore, does not have desired reliability.
The actuation power of the carbon dioxide system is provided from the essential bus that derives onsite power from the very diesel the system is designed to protect.
It is possible, therefore, that in event of a fire at "B" diesel, the extinguishing system will be without onsite power backup.
The manual release of the ca-bon dioxide system does not conform to the isions of NFPA 12-1977 which tends to reduce the reliability of the aal release.
There is no provision to cetect a possible hydrogen olldup in the room.
Curbed area in tne rocm is inadequate to contain oil in the day tank.
5.5.6 Modifications Electrical supervision for power failure, grounds and circuit breaks will be provided to the circuit of heat detectors that actuate the C02 system.
The actuation power for the CO system will be provided from the essential 2
bus which derives the onsite backuo pcwer from the "A" diesel generator.
The emergency manual release of the CO system will be modified to conform 2
with the provisions of NFPA 12-1977.
The curbs will be upgraded to provide suf ficient capacity for the entire content of the day tanx plus 1C%
additional capacity for fire water.
A hydrogen monitor has been installed to alarm anc annunciate in the control rocm a nigh hydrogen concentration.
- _~
~
562337
w We find that, subject to implementation of the above described T.odifica-tion, fire protection for this area satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
5.6 Containment 5.6.1 Safetv-Related Eouicment The containment structure contains the reactor, associated piping and instrumentation, the decay heat pump, the shu;down condenser and the containment ventilation system.
5.6.2 Combustibles Combustible materials inside containment include lubrication oil and hydraulic fluid in the reactor coolant recirculation pumps, borated poly-ethylene neutron shield blocks cround the control rod drives, cables, and some miscellaneous cembustibles that include wood, paper and plastics.
- 5. 6. 3 Consecuences if No Fire Sucoression A major fire involving combustible liquid of the recirculation pumps and/or polyethylene blocks could damage the control drive mechanism, the decay heat removal system, main steam valves, as well as instrumentation in the area.
The reactor can be shutdown by injecting baron, using high pressure core spray pumps.
5.6.4 Fire Protection Systems Ionization-type smoke cetectors which alarm and annunciate in the control room have been installed throughout the containment.
Portacle extinguishers and four 75-foot lengths of 3/4-inch unlined linen hose are available in the containment for manual fire fighting.
5.6.5 Adecuacy of Fire Protection Fire protection in the containment is not adequate.
Existing fire suppressicn equipment is not capable of timely suppression of oil fires.
In addition, the existing unlined linen hose is not suitacle for industrial fire fighting.
5.6.6 Modifications The licensee will:
(1) Replace existing interior hose station standoipe 30 that a minimum of 100 gpm is available at each hose station outlet at a residual pressure of at least 65 psig.
The 3/4-inch hoses and no :les will be replaced with 1 -inch, UL or FM listed, fire hoses and no les.
(2) Provide an acceptacle modificaticn to prevent or suooress a fire
.1 the recirculation pump area.
5-s 562338
f e
(3) Replace polyethylene neutron shielding with noncombustible materials.
We will address the adequacy of fire protection in the containment in a supplement to this report.
5.7 Electrical Eouicment Room and Control Room 5.7.1 Safety-Related Eculement Safety-related equipment includes the main control console which extends from the control room to the electrical equipment room below; the reactor building and the general plant batteries and associated switchgear and inverters; AC and CC motor control centers; and cables.
5.7.2 Combustibles The combustibles in this area consist of electrical cable insulation, electrical components, polystyrene battery cases and a large quantity of paper - operational manuals, logs and drawings in the control room, and a number of file cabinets full of paper records stored in the electrical equipment room.
- 5. 7. 3 Consecuences if No Fire Sucaression The electrical equipment room is the caole spreading area for the control room consoles. The two rocms are not separated by a fire barrier so tnat a fire in the electrical equipment room is likely to also affect cabling and components in the control room consoles.
The reactor will be scrammed on loss of non-interruptive bus and the shutdown condenser will be avail-able for core cooling.
However, cacability of bringing the reactor down to a cold shutdown condition may not ce preserved because the decay heat system could oe disabled.
Furthermore, both onsite AC and DC power systems could be damaged by a fire in this area.
It has not been demonstrated conclusively that safe shutdown can be accomplished without onsite and offsite electric power.
There also is a possibility of circuit interaction among cables damaged by a fire producing effects unfavoracle to safe shutdown.
5.7.4 cire Protection System Ionization-type smoke detectors are located througnout the electrical equipment room, the ceiling of the control room and ventilation air return duct from the control room consoles.
One and one-half inch manual hoses with fog nozzles are available from the turbine building.
Portable extin-guisners are provided within and around the area.
Most cables are proviced with a flame retardant coating.
5.7.5 Adecuacy of Fire Protection Fire protection for this area is inadequate.
Storage of a large quantity of record file in this area exposes cacling and components in :nis critical 5-9 56' 339 2
area to an unnecessary hazard. Manual suppression may not be adequate to extinguish a fire before it inflicts a significant amcunt of damage.
It has not been demonstrated that safe shutdown capability can be preserved during and following a fire in this area.
There is no provision for detecting or preventing a possible accumulation of hydrogen generated in the batteries.
The cables above the ceiling in the control room present a fire hazard in an area where fire fighting is difficult.
- 5. 7. 6 Modifications A hydrogen detector has been installed in the battery area of the electrical equipment room to provide an alarm in the control room.
The licensee will:
(1 ) Relocate all file cabinets stored in the electrical equipment room out of the safety-related areas.
Storage of combustible materials not essential for the routine operation and mainteaance in this area will be prohibited.
(2) Provide automatic fire rappression to the electrical equipment rcom.
(3) Provide additional pr~tection, possibly enclosure in conduits, for cables in the concealed space above the control rocm ceiling.
We will address the adequacy of fire protection for this area in a supple-ment to tnis repcrt.
5.8 Waste Handling Building 5.8.1 Safetv-Relatec Ecuicment Radwaste systems are located in his area.
5.8.2 Combustibles Combustibles in this area include solid wastes such as pacer, plastic, and filter elements; ion exchange resin; and charcoal in the off gas system.
5.S.3 Consecuences if No Fire Sucoression No cable or equipm?nt in this area is required for safe shutdown.
An unmitigated fire in this area could release radioactive materials.
The licensee has not analyzed the radiological consequences of a fire in this area.
5.8.4 Fire Protecticn Svstems Ionization-type smoke cetectors are installed to provide alarm in the control rocm.
An interior hose station, an outsice fire hydrant and portaole extinguishers are available for manual fire fighting.
SG2340
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5.8.5 Adecuacy of Fire Protection Adequacy of fire protection in preventing excessive release of radicactive materials from a fire in this area has not been analyzed by the licensee.
5.8.6 Modifications The licensee will provide the results of an analysis which demonstrate that a fire in the waste handling building will not cause the release of significant amount of radioactive materials.
Such analysis will include, but not be limited to, a charcoal fire in the off gas system and the fire hazards associated with the storage of spent resin.
We will address the adequacy of fire protection for this area in a supplement to this report.
- 5. 9 Crib House
- 5. 9.1 Safety-Related Ecuioment The two reduncant low pressure service water electric pumps which supply water to the high pressure service water system, and the two alternate core spray diesel-driven pumps which also supply water to the high pressure service water system (HPSW) are in this area.
The HPSW system is also the fire water system.
5.9.2 Cemeustibles Diesel fuel oil in tne pipes to the diesel pumps, and electric cable insulation are the majcr combustibles in this area.
The diesel fuel suoply tanks are buried outside, and the small gravity tank for each diesel is on the outside wall of the crib house.
5.9.3 Consecuences if No Fire Suceression The licensee's fire hazard analysis has not provided sufficient informa-tion to sucpcrt a staff conclusion that safe shutdown capability would not be impaired by a fire in the crib house.
5.9.4 Fire Protection Systems Two ionization-type smoke detectors are installed in the crib house. One is over the area of the two diesel pumps, and the other is over a cable tray near the other side of the crib house.
Portable extinguishers are available from both inside and outside the crio house, and exterior lh-inch fire hose lines are also available.
- 5. 9. 5 Adecuacy of : ire Protection The licensee's fire hazards analysis does not provice sufficient informa-tion to support a staff conclusion that safe shutdown cacaDil'ty would not SG' 341 2
5-n
a be impaired by a fire in the crib houses.
The fuel tanks for diesels are located below the fuel pump and fuel lines to the two diesels that are not interconnected; both in deviation from the provision of NFPA 20-1975.
- 5. 9. 6 Modifications The licensee will provide the results of an analysis which demonstrates that safe shutdown capability will not be impaired by a fire in the crib house.
A locking filler cap has been provided for the diesel fucl oil storage tank filler pipe.
To improve the reliability of fire water supply, the licensee is studying the feasibility of interconnecting the fire water system with that of Lacrosse, Unit 3 (fossil plant) and include the diesel fire pump and relevant portion of fire water piping in Unit 3 in his surveillance program.
We will address the adequacy of fire protecticn for the crib house in a supplement to this report.
5.10 Yard Area and Transformers 5.10.1 Safety-Related Equipment No safety-related equipment is in the yard area.
5.10.2 Combustibles Major combustible materials in the yard area include 20,000 gallons of fuel oil in an aboveground tank, transformer oil in the main power trans-former and reserve auxiliary transformer, and various quantities of ordi-nary combustibles in several warehouses and at the records storage building.
The fuel oil storage tank is about 90 feet from the crib house and about 105 feet from the turbine building in a dikea area capable of containing the tank contents.
The two transformers are in a stone-filled yard about 8 feet west of the turbine building.
The warehouses and records storage building are separated from other buildings at the plant.
5.10.3 Consequences if No Fire Suppression An unmitigated fire involving the contents of the fuel oil storage tank will not impair the safe shutdown ;apability of the plant.
The conse-quences of an unmitigated fire in one or both transformers is discussed in Section 5.1 of this report.
An unmitigated fire in the warehouses or records storage building will not affect the safe shutdown capability of the plant.
5.10.4 Fire I otection Systems Ionization-type smoke detector systems are provided in each warehouse and in the records storage building.
Portable extinguishers and outside hydrants and hose are available for manual fire fighting.
5
'I 5-12
o 5.10.5 Adecuacy of Fire Protection Fire protection for the transformer; adjacent to the turbine building has not been shcwn adequate to preserve the safe shutdown capability of the plant in case of a fire or explosion in this area.
Fire protecticn for other parts of the yard area, including the warehouses and records storage building, is considered adequate to preserve the safe shutdown capability of the plant in case of a fire in these areas.
5.10.6 Modifications The licensee will install an automatic water fire suppression system to protect the turbine building frcm transformer fires.
We find that, subject to irrplementation of the above described modifica-tions, the fire protection for the yard area and transformers complies with the requirements of Appendix A to Branch Tecnnical Position 9.5-1 and is, therefore, acceptable.
SG2343 5-13
a I
i 6.0 ADMINISTRATIVE CONTROLS The administrative controls for fire protection consist of the fire protec-tion organization, the fire brigade's training, the controls over combus-tibles and ignition sources, the prefire plans and procedures for fighting fires, and the quality assurance provisions for fire protection.
I The original licensee's description of the administrative controls is not adequate to permit a conclusion by the staff.
The licensee has reviewed his administrative controls using the guidelines set forth in " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance," and submitted a detailed fire plan describing how the administrative control guidelines will be met.
We are continuing to review this fire plan and will address our evaluation of the administrative controls for fire protection in a supplement to this report.
I, I
i SG2344 6-1
7.0 TECHNICAL SPECIFICATIONS The Technical Specifications have been modified (License Amendment No.10, dated February 28, 1978) to incorporate interim Technical Specifications which include limiting conditions for operation and surveillance requirements for existing fire protection systems and administrative controls. Following the implementation of the modifications of fire protection systems and administrative controls resulting from this review, the Technical Specifications will be similarly modified to incorporate the limiting conditions for operation and surveillance requirements for these modifications.
56 4345 7-1
6.0 CONCLUSION
S The licensee has performed a fire hazards analysis and has proposeo certain todifications to improve the fire protection program.
Additional modifica-tions have been proposed by the licensee during the course of our review, which are based upon the fire hazards analysis and our onsite evaluatson of the fire protection program.
These proposed modifications are summarized in Section 3.1.
In summary, 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 pe+ential fire situations.
Upon implementation of the modifications summarized in Section 3, we find that the provisions of Section 2.0 are satisfied and that:
(1) Combustibles in safety-related areas are limited to the extent practicable; (2) Fire detection and suppression systems will minimize, consistent with other safety requirements, the effects of fire on safety-related systems and will not in themselves significantly impair the capabil-ity of safety related systems;
( 3) A fire in any fire zone will not damage safety-related structures such that they cannot perform their safety function;
( 4) The fire protection organization has the professional qualifications to implement the fire protection program, and administrative controls are adequate to maintain control of combustibles, ignition sources, and the fire protection organization; and (5) A fire in any fire zone will not cause the release of amounts of radioactive material in excess of those considered in previous safety evaluations.
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 rescect to continued safe' operation of tne facility.
SC:34G 8-1
i f
In the ecort of the $pecial Review Group of the Browns Ferry Fire (T. MEG-CC50) cstec February 1975, censiceration cf Ine sEfety of operation of 5;l 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.
" Fires occur rather frequently; however, fires involving equipment unavailability comparable to the Browns Ferry fire are quite infre-quent (see Section 3.3 of [NUREG-0050]) The Review Group believes that steps already taken since March 1978 (see Section 3.3.2) have reduced this frequency significantly.
" Based on its review of the events transpiring before, during and af ter the Browns Ferry fire, the Review Group concludes that the probability of disruptive fires of the magnitude of the Browns Ferry event is small and that there is no need to restrict operation of nuclear power plants for public safety.
However, it is clear that much can and should be done to reduce even further the likelihood of disabling fires and tc improve assurance of rapid extinguishment of fires that occur.
Consideration should be given also to features that.wonid increase further the ability of nuclear facilities to l
withstand large fires without loss of important functions should such fires occur."
l We recognize that the " Risk Assessrent 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 negligioly to the overall risk of nuclear plant operation.
However, 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.
This is based on our concurrence with the Browns Ferry Special Review Group's conclusions identified above as well as the significant improvements in fire protec-tion 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 fire brigade, and issuance of technical specifications to provide limiting conditions for operation and surveillance requirements on fire protection systems.
We have determined that the license amenament does not authorize a change in effluent types or total amounts nor an increase in power level and will nct result in any significant environmental imoact.
Having made this deter-m' nation, we have further concluded that the amenc ent involves an action
,-icn is insignificant from the standpoint of ensi cnmental impact and pt suant to 10 CFR 5.15(d)(4) that an environmenta' impact statement, or negative ceclaration and environmental impact aparaisal, need not be pre-pared in connection with the issuance of this amencment.
$~347 5-2 J
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We have concluded, based on the censiderations discussed above. thet-(1) beca se.he amencment 00es not involve a significar.; in:rsa;a in :ne probability or consequences of accidents previously considered and does not involve a significant decrease in a safety margin, the anendment 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, ano (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.
3-3 56:3348
9.0 CONSULTANTS' REPORT Brookhaven Nation'l Laboratory under contract to the NRC has provided the services of fire protection consultants who participated in the evaluation of the fire protection program.
They have also participated in the prepara-tion and review of this safety evaluati, report.
Their report, " Fire Protection in Operating Nuclear Power scations, La Crosse Boiling Water Reactor Safety Evaluation Report Review," dated April 6,1979 discusses many items which have been addressed in this report.
The consultants' recommendations which we have not totally adopted are discussed in Appendix "8."
Our basis for not adopting these recommendations is given therein.
SG2349 9-1
e AcePC:X._A Chronoloaf In February 1976, the report by the NRC Special Review Group was issued as NUREG-0050, " Recommendations Related to the Browns Ferry Fire."
On May 1,.1976, Standard Review Plan 9.5.1, " Fire Protection," was issued, incorporating the various recammendations contained in NUREG-0050.
By letter dated May 11, 1976, Dairyland Power Cooperative was requested to compare the existing fire protection provisions at their facilities with new NRC guidelines as set forth in Standard Review Plan 9.5.1, " Fire Protection," dated May 1, 1976, and to describe (1) the implementation of the guidelines met, (2) the modifications or changes underway to meet the guidelines that will be met in the near future, and (3) the guidelines that will not be met and the basis therefor.
On May 27,1976, Dairyland Power Cooperative replied to the Commissioner's correspondence of May 11, 1976, and indicated that the evaluation of the fire protection program at Lacrosse Boiling Water Reactor will be completed by October 1, 1976.
On February 14, 1977, Dairyland Power Cooperative submitted the fire hazard analysis for LACBWR il response to the NRC request of May 11, 1976.
By letter of June 16, 1977, Jairyland Power Cooperative was requested to submit technical specifications on existing fire protection equipment and administrative controls.
On July 20, 1977, Dairyland Power Cooperative submitted proposed addition to technical specifications in response to our request of June 16, 1977.
By latter of August 4, 1977, Dairyland Power Cooperative was requested to review the fire protection program at LaCresse with NRC staff guidelines
" Nuclear Plant Fire Protection Functional Responsibilities."
By letter of November 28, 1977, Dairyland Power Cooperative was notified that a revision to technical specifications is necessary pertaining to e
protection.
On December 16, 1977, Dai,yland Power Cocperative requested a meeting in Bethesda, Maryland to discuss the revision to technical specification.
The meeting was held on December 19, 1977.
W2350 A '.
On January 11, 1977, Dairyland Power Cooperative submitted revised tec5mical
..eci'ica-ions in resccnse to NRC letter cf Nover.tsr 22, 197 and apc'.ic for an amencment to Provisional Operating License No. DPR-45.
By letter of February 3,1978, Dairyland oower Cooperative was provided the staff guideline document entitled, " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Control and Quality Assurance," and was requested to review the fire protection program at Lacrosse for conformance with the guideline.
By letter of April 13, 19/8, Dairyland Power Cooperative was provided our requests for additional information and staff positions pertaining to fire protection at Lacrosse Boiling Water Reactor.
On September 27, 1978, Dairyland Power Cooperative submitted an application for amendment to Provisional Operating License No. DPR-45 concerning fire detection.
The aoplication was approved and Amendment 14 to the licens:
was issued on October 11, 1978.
On October 18, 1978, Dairyland Power Cooperative provided responses to staff requests of February 3, 1978 and April 13, 1978.
On Octooer 31 - November 2, 1978 the NRC fire protection review team visited the Lacrosse Boiling Water Reactor f acility.
On November 2, 1978, a meeting was held in Dairyland Power Cooperative headquarters in Lacrosse at which the review team presented numerous staff positions.
Dairyland Power Cooperative adopted most of these staff positions.
By letter of November 15, 1978, Dairyland Power Cooperative was requested to provide (1) the schedule for implementing the staf f's positions which nc agreed at the November 2 meeting to adopt, and (2) responses to the remaining staff positions which were identified, but not agreed on, during the November 2 meeting.
On December 19, 1978, Dairyland Power Cooperative provided responses to the staff requests of November 15, 1978.
On June 7,1979, the NRC fire protection review team met the representatives of Dairyland Power Cooperative at the La Crosse Boiling Water Reactor facility to resolve the renaining open issues concerning the fire protection program at the plant.
b62351 A-2
e APPENDIX B DISCUSSION OF CONSULTANTS' REPORT Under contract to the Nuclear Regulatory Commission, Brookhaven National Laboratory has provided the services of fire protection consultants who participated in the evaluation of the licensee's fire protection program and the preparation of the Safety Evaluation Report (SER).
Their report,
" Fire Protection in Operating Nuclear Power Statlans - Lacrosse Boiling Water Reactors Safety Evaluation Report Review," dated April 6,1979, presents certain recommendations and comments. The consultant's recommendations and comments which are not included in the SER, and our resolution of these matters is given below.
Valve Supervision It is reccmmended that the electrical supervision (of certain fire protec-tion system valves) be extended to (include) all sectional valves and valves controlling the supply of water for fire protection.
Staff Response The NRC guidelines on fire water system control valve supervision are given in Appendix A to Branch Technical Position (BTP) 9.5-1 of the Standard Review Plan.
These guidelines permit, as an alternative to electrical supervision, an administrative pro; ram to assure that valves are maintained in the proper position. Such a program includes locking valves with strict key control or sealing valves with tamper proof seals.
Periodic inspections are to be performed to verify that the method of, securing the valve is intact.
These measures are consistent with the requirements imposed for supervising valves in safety-related systems, and provide adequate assurance that valves are maintained in the appropriate position.
The licensee's program for valve supervision is consistent with NRC guidelines.
In addi tion, the olant's Technical Specifications require a monthly check of all valves in the flow path to fire suppression systems, to ensure that each valve is in thc correct position.
Ventilation SER Item 4.4.1 indicates that portable smoke ejectors and flexible ducting will be provided to aid in manual smoke removal activities in the plant in addition to the installed ventilating systems which serve many plant areas, and that these measures consistute acceptable provisions for smoke remov-l during fires.
Reevaluation of this aspect of nuclear power plant fire protection has prnduced additional concerns on my part.
Effective smoke removal is essentially the transporting of smoke from the fire area at a rate which will limit its effects on property and personnel to tolerable levels.
Estimating the rate of generation of the smoke, and its character, are necessary first steps in evaluating the effectiveness of a smoke removal plan. The rate of generation of smoke depends on the D'352
, rate of burning, which has not been estimated by the licensee. The character of the smoke depends on the material being burned and the nature of the burning, neither of which have been adequately quantified by the licensee.
Installed systems may have to be significantly altered to provide effective smoke removal in all plant areas.
I would recommend that a complete evaluation of smoke generation potential and smoke removal metheds be made by the licensee so that conclusions drawn by the NRC staff will have a firm technical basis.
Staff Response Modification of the plants' ventilation system in those areas without adequate fixed smoke removal systems, is unwarranted because portable smoke removal equioment can be used and because self-contained breathing apparatus are available for the fire fighters and plant operators.
The portable smoke exhaust systems are recommended by the manual fire fighting consultant's based on their evaluation of the fire fighting capabilities at this plant.
Hose Testing SER Item 3.1.i calls for testing of exterior hoses, but no pressure for testing is stipulatzd.
Our consultant recommends that the exterior hoses be tested at 200 psi.
Staff Response The requirements of the hose test are included in the technical specifications for fire protection.
The test pressure of 200 psi will be specified therein.
562353
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