ML19254E708
| ML19254E708 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 10/22/1979 |
| From: | Baer R Office of Nuclear Reactor Regulation |
| To: | Crews E SOUTH CAROLINA ELECTRIC & GAS CO. |
| References | |
| NUDOCS 7911020192 | |
| Download: ML19254E708 (24) | |
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NUCLEAR REGULATORY COMMISSION 5.'
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OCT 2 E 1979 Docket No.53-395 Mr. E. H. Crews, Jr.
Vice President and Group Executive Engineering and Construction South Carolina Electric and Gas Company P. O. Box 764 Columbia, South Carolina 29218
Dear Mr. Crews:
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION ON THE FINAL SAFETY ANALYSIS REPORT FOR THE VIRGIL C. SUMMER NUCLEAR STATION As a result of our review of recent amendments to the Final Safety Analysis Report (FSAR) for the Virgil C. Sunner Nuclear Station, we find that we need additional information to complete our review. contains requests for information and positions which cover the areas of (1) fire protection, (2) loose parts monitoring, (3) materials engineering and (4) containment systems. As discussed during the site visit for fire protection (August 27-29, 1979), we would prefer that we met to discuss your responses to the fire protection items prior to your responses. We request that you respond to all of the items in Enclosure 1 by December 1,1979.
If you can not meet this schedule, please provide us with your schedule within seven days of the receipt of this letter.
Sincerely, W / bdJ '7 Robert L. Baer, Chief Light Water Reactors Branch No. 2 Division of Project Management
Enclosures:
1.
Requests For Additional Infomation 2.
Staff Requirements For Alternate Shutdown Systems ccs w/ enclosures:
See next pages 1262 103 l92 7900 20 g' g U
Mr. E. H. Crews, Jr., Vice President and Group Executive - Engineering and Construction South Carolina Electric & Gas Company P. O. Box 764 Columbia, South Carolina 29218 cc:
Mr. H. T. Babb General Manager - Nuclear Operations South Carolina Electric & Gas Company P. O. Box 764 Columbia, South Carolina 29218 G. H. Fischer, Esq.
Vice President & General Counsel South Carolina Electric & Gas Company P. O. Box 764 Columbia, South Carolina 29218 Mr. William C. Mescher President & Chief Executive Officer South Carolina Public Service Authority 223 North Live Oak Drive Moncks Corner, South Carolina 29461 Mr. William A. Williams, Jr.
Vice President South Carolina Public Service Authority 223 North Live Oak Drive Moncks Corner, South Carolina 29461 Wallace S. Murphy, Esq.
General Counsel South Carolina Public Service Authority 223 North Live Oak Drive Moncks Corner, South Carolina 29461 Troy B. Conner, Jr., Esq.
Conner, Moore & Corber 1747 Pennsylvania Avenue, N. W.
Washington, D. C.
20006 Mr. Mark B. Whitaker, Jr.
Licensing and Staff Engineer South Carolina Electric & Gas Canpany P. O. Box 764 Columbia, South Carolina 29218 Mr. O. W. Dixon Group Manager, Production Engineering South Carolina Electric & Gas Company P. O. Box 764 Columbia, South Carolina 29218 1262 104
e Mr. E. H. Crews, Jr.
cc:
P.r. Brett Allen Bursey Route 1 Box 93C Little Mountain, South Carolina 29076 Mr. J. Skolds United States fiuclear Reguli tory Comission P. O. Box 1047 Irmo, South Carolina 29063 S
126^
11
OGT 2 L IS/S ENCLOSURE 1 REQUEST FOR ADDITIONAL INFORMATION Ott THE FINAL SAFETY ANALYSIS REPORT FOR THE VIRGIL C. SUMMER NUCLEAR STATION 1262 106
OCT 2 i 1979 022.00 C0tiTAltiMEtiT SYSTEMS 022.53 Your answer to Question 022.51 is unacceptable. The minimum con-tainment pressure used for the ECCS performance evaluation does not meet the provisions of Branch Technical Position (BTP) CSB 6-1,
" Minimum Containment Pressure Model for PWR ECCS Performance Evaluation."
Provide the following:
(a) Specify the initiating times for the containment sprays and fan coolers assuming loss of offsite power and startup of the diesel generators. Specify the effective times for actating these systems assuming offsite power is available, ano provide justi-fication for the specific times utilized.
(b) FSAR Table 6.2-1 states that there are four an cooling units.
Provide justification for assuming only two fan cooling units are operational for the backpressure calculation.
022.54 You were asked to thermally analyze safety related equipment whose qualification test temperatures were lower than the containment peak temperature in order to determine if the equipment would sur-vive the environment resulting from a main steam line break.
In July 1978 you submitted a report on this subject.
In your request you chose three sample pieces of equipment for the thermal analysis and concluded the remainder of the equipment was similar to these three samples and did not need analyzing. Provide the basis for concluding that the three sample pieces of equipment are representative of all equipment that was not qua?ified to the environment resulting from the main steam line break.
1262 107
Oct g.1979 121.0 MATERIALS ENGINEERING BRANCH - MATERIALS INTEGRITY SECTION 121.12 The inspection program requirements, as detailed in 0121.6, have recently been revised to reflect information gained from recent inspection program reviews.
Therefore, Q121.6 is now superseded by the information required by this question, including staff guidance for preparing relief requests.
We require that your inspection program for Class 1, 2 and 3 components be in accordance with the revised rules in 10 CFR Part 50, Section 50.55a, paragraph (g). Accordingly, submit the following information:
(1) A preservice inspection plan which is consistent'with the required edition of the ASME Code. This inspection plan should include any exceptions you propose to the Code requirements.
(2) An inservice inspection plan submitted within six months of the anticipated date for cormercial operation.
This preservice inspection plan will be required to support the safety evaluation report finding regarding your compliance with preservice and inservice inspection requirements. Our detennination of your compliance will be based on:
(1) That edition of Section XI of the ASME Code referenced in your FSAR or later editions of Section XI referenced in the CEDERAL REGISTER that you may elect to apply.
(2) All augmented examinations established by the Commission when added assurance of structural reliability was deemed necessary.
Examples of augmented examination requirements can be found in the NRC positions on:
(1) high energy fluid systems in Section 3.6 of the Standard Review Plan (SRP), NUREG-75/087; (2) turbine disk integrity in Section 10.2.3 of the SRP.
Your response to this item should define the applicable edition (s) and subsections of Section XI of the ASME Code.
If any of the examination requirements of the particular edition of Section XI you referenced in the FSAR cannot be met, a request for relief must be submitted, including complete technical justification to support your request.
Detailed guidelines for the preparation and content of the inspection programs to be submitted for staff review and for relief requests are attached as Appendix A to Section 121.0 of our review questions.
121.13 The response to Question 121.8 is not adequate.
It has been indicated in Table 5.2-8 of the V. C. Sumer FSAR that steels having a minimum specified yield strength greater than 50 ksi will be used in the reactor coolant pressure boundary. Appendix G of 10 CFR Part 50 states that the adequacy of these high strength steels shall be demonstrated to the Ccmmission on an individual case basis.
1262 108
121-2 Oct 221979 As a partial fulfillment of this requirement Westinghouse submitted Topical Report WCAP-9292, " Dynamic Fracture Toughness of ASME SA-508 Class 2a ASME SA-533 Grade A Class 2 Ba:e and Heat Affected Zone Material and Applicable Weld Metals," to the staff for review. The purpose of this topical report is to demonstrate the adequacy of the subject materials to be described by the K curve of Appendix G,Section III of the ASME Code. Wehaveconbetedaninitialreview of this topical report and have found the technical content of the report to be generally acceptable. However, we have identified several areas where the infomation presented in the report is not adequate and have requested Westinghouse to supply additional information. We are currently waiting for this information so that we may complete our review.
However, acceptance of this topical report will only allow the generic use of these materials; and the remaining fracture toughness requirements of Appendix G, 10 CFR Part 50 must be met for each specific heat of material used in each plant. Therefore, we require that the results of the fracture toughness tests (Cherpy V-notch, drop weight and tensile) required by Appendix G be submitted so that an evaluatation of the degree of compliance with this regulation tan be made.
If these materials were tested to an edition and addenda of the ASME Code in effect before the 1972 Summer Addenda, specify the edition and addenda employed, the tests required, the minimum acceptable results, and a technical analysis to demonstrate that these levels of fracture toughness are equal to that currently required in the regulation.
121.14 To demonstrate compliance with Appendix H to 10 CFR Part 50, 'rclude in the V. C. Summer FSAR and Technical Specifications a tabb that provides the following information for each surveillance specimen capsule:
(1) The actual surveillance traterials in each capsule.
(2) The beltline material from which each surveillance material was
- obtained, (3) The test specimen type (s), and their orientation, for each
- urveillance material, (4) The actual location of each capsule in the reactor vessel, (5) The lead factor for eacn capsule calculated with respect to the 1/4 wall thickness location.
(6) The proposed loading schedule of the capsules into the V. C.
Summer reactor vessel, and (7) The proposed time of capsule withdrawal (calender years and effective full power years).
1262 109
121-3 379 121.15 5 3.4.9.2 of the Technical Spec'fications for V. C. Summer Nuclear Station specifies a maximum heatuo rate for the pressurizer of 200 F in any one hour period. Westinghouse has notified the NRC that the design heatup rate for their pressurizers is 100'F/ hour and that the heatup rate in the Technical Specifications should not exceed this value. Therefore, revise 5 3.4.9.2 to incorporate this change.
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OCT 2 y ggyg APPENDIX A GUIDANCE FOR PREPARING PRESERVICE AND INSERVICE INSPECT BN PROGRAMS AND REi.IEF REQUEST PURSUANT TO 10 CFR 50.55a(g)
A.
O_escription of the Preservice/ Inservice Inscecticn Procram This program should cover the requirements set forth in Section 50.55a(g) of 10 CFR Part 50 and the ASME Boiler and Pressure Vessel Code,Section XI, Subsections IWA, IWB, IWC and IWD. The guidance provided in this encicsure is intended to illustrate the type and extent of information that should be provided for NRC review.
It also describes the information necessary for " request for relief" of items that cannot be fully inspected to the requirements of Section XI of the ASME Code.
By utilizing these guidelines, licensees can significantly reduce the need for requests for additional in4mation from the NRC staff.
B.
Contents of the Submittal The infomation listed below should be included in the submittal:
1.
For each facility, include the applicable date of the ASME Code and the appropriate addendum date.
2.
The period and interval for which this program is applicable.
3.
Provide the proposed codes and addenda to be used for repairs, modifications, additions or alternations to the facility which might be implemented during this inspection period.
4.
Indicate the examinations that you have exempted under the rules of Section XI of the ASME Code. A reference to the applicable paragraph of the code that grants the exemption is satisfactory.
The inspection requirements for exempt components should be stated (e.g., visual inspection during a pressure test).
5.
Identify the inspection and pressure testing requirements of the applicable portion of Section XI that are deemed impractical because of the limitation of design, geometry or materials of construction of the components.
Provide the irformation requested in the following section of this appendix for the inspections and pressure tests identified in Item 4 above.
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001 x. ;g73
, C.
Reguest for Relief from Certain Inspection and Testino Recuirements It has been the staff's experience that many requests.or relief from testing requirements submitted by licensees have not been supported by adequate descriptive and detailed technical infomation. This detailed information is necessary to:
(1) document the impracticality ei the ASME Code requirements within the limitations of design, geumetry and materials of construction of components; and (2) detemine whether the use of alternatives will provide an acceptab'.e level of quality and safety.
Relief request submitted with a justification such as " impractical,"
" inaccessible," or any other categorical basis, require additional infomation to permit the staff to make an evaluation of that relief request. The objective of the guidance provided in this section is ti illustrate the extent of the information t;:st is required by the NRC staff to make a proper evaluation and to adequately document the basis for granting the relief in the staff's Safety Evaluation Report. The NRC staff believes subsequent requests for additional information and delays in completing the review can be considerably reduced if this information is provided initially in the licensee's submittal.
For each relief request submitted..the following information should be included:.
1.
An identification of the component (s) and/or the examination requir~ement for which relief is requested.
2.
The number of items associated with the requested relief.
3.
The ASME Code class.
4.
An identification of the specific ASME Code requirement that has been determined to be impractical.
5.
The infomation to support the determination that the requirement is impractical; 1.e., state and explain the basis for requesting relief.
6.
An identification of the alternative examinations that are preposed:
(a) in lieu of the requirements of Section XI; or (b) to supplement examinations performed partially in ecmpliance with the requirements of Section XI.
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'1 2 % 1979 7.
A description and justification of any changes expected in the overall level of plant safety by performing the preposed alternative examinations in lieu of the examination required by Section XI.
If it is not possible to perform alternate examinations, discuss the impact on the overall level of plant quality and safety.
For inservice inspection, provide the following additional infomation regarding the inspection frequency:
8.
State when the request for relief would apply during the inspection period or interval (i.e., whether the request is to defer an examination).
i State when the proposed alternative examinations will be implemented and performed.
- 10. State the time period for which the requested rei.ef is needed.
Technical justification or data must be submitted to support the relief request. Opinions without substantiation that a change will not affect the quality level are unsatisfactory.
If the relief is requested for inaccessibility, a detailed description or drawingA which depicts the inaccessibility must accompany the request.
relief request is not required for ' tests prescribed in Section XI that do not apply to your facility. A statement of "N/A" (not applicable) or "None" will suffice.
D.
Request for Relief for Radiation Considerations Exposures of test personnel to radiation to accomplish the examina-tions prescribed in Section XI of the ASME Code can be an important factor in detemining whether, or under what conditions, an examina-tion must be pe. formed. A request for relief must te submitted by the licensee in the manner described above for inaccessibility and must be subscquently approved by the NRC staff.
We recognize that some of the radiation considerations will only be kncwn at the time of the test.
However, the licensee generally is aware, from experience at operating facilities, of those areas where relief will be necessary and should submit as a minimun, the following information with the request for relief:
1.
The total estimated man-rem exposure involved in the examination.
2.
The radiation levels at the test area.
1262 113
. OCT g g ggyg 3.
Flushing or shielding capabilities which might reduce radiation levels.
4.
A proposal for alternate inspection techniques.
5.
A discussion of the considerations involved in remote inspections.
6.
Similar welds in redundant systems or similar welds in the same systems which can be inspected.
7.
The results of preservice inspection and any inservice results for the welds for which the relief is being requested.
8.
A discussion of the consequences if the weld which was not examined, did fail.
1262 F14
- SD 221.0 REACTOR AflALYSIS 221.13 For the Summer facility, we do not require special seismic considera-tions in the procurement of components for the loose parts monitoring system. However, we do require that appropriate consideration be given to the installation of the equipment (e.g., mounting of sensors and other system components within containment) to provide reasonable capability to withstand seismic events. We request that information be provided to give assurance that feasible steps to enhance the seismic capability of the system have been employed in the installation of the system. The loose parts monitoring system cannot be found acceptable until this information is provided.
221.14 With regard to your response to Item 221.7, we request that you provide the following information:
1.
The sensitivity of the monitors in terms of the weight, kinetic energy of the loose part, and detectable distance from the monitor.
2.
The number of sensors at each location and method of mounting.
We require at least two sensors at each natural collection region.
3.
Discussion of anticipated sources of internal and external noise and your plans to minimize this noise.
1262 115
P00RORIS!NA_
421.0 QUALITY ASSURANCE BRANCH 421. 77 The response in Section C of your August 19,19'7 subri :al coes not indicate whether :ne OA progran for fire prote::icn is under the management control of the QA organizaticn. This control consists of (1) formulating and/or verifying that the fire protection CA program incorporates suitable recuireaents a.no is acceptable to the managenent responsible for fire protectior, and (2) <erifyir.g the effectiveness of the QA program ^or fire prote::icn througn review, surveillance, and audits.
Performance of c:her QA program functions for meeting the fire protection program re: uirements may be performed by personnel outside of the QA organization.
The QA program for fire protection should be part of the overall plant QA program. These QA criteria apply to those items within the scope of the fire protection program, such as fire protection systems, emergency lighting, communication anc emergency creathing apparatus as well as the fire protection requirements of applicable safety-related equipment.
421. 78 Although you have addressed the ten specific cuality assurance criteria in Branch Technical Position APCSS 9.5-1, we find that your response does not describe sufficient detail for these criteria.
In order for the QA3 to fully evalua:e these criteria, additional detailed description is necessary.
Examples of the detail we would expect South Carolina Electric and Gas Corgany to consider are provided in Attachment 6 of Mr. D. 3. Vassallo's letter of August 29, 1977.
If, however, you cnoose not to provice this det' ail, you may apply the same controls to eacn criterien that are commensurate with the controls described in ycur operational QA program (af ter acceptance by NRC). These controls would apply to the remaining construction activities and for the operations phase of Unit No. 1.
If you select this method, a statement to this effect would be adequate for our review of the fire protection QA ' program.
1262 116
GCT 2 2 1979 -
422.~
COMDUCT OF OPERATIONS Describe viho will te assigned as heaa or'icacer :# j:.e 422.3 fire fighting teams.
If he is not your Snif-Su:erviscr describe his authority relative to your Shif-Su;arvisor for actions tht might af fect safety-related systems or eccip. ment.
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1262 117
OCT g z 1973 FIRE PROTECTION POST SITE REVIEW REQUEST FOR IrlFORMATION AND STAFF POSITIONS 1.
You state in your Fire Hazards Analysis how various safety-related cable trays, onduit and equipment are separated by distance from its redun-dant counterpart, and the criteria that were used to establish barriers between these redundant trains.
In order to provide a defense-in-depth design, so that a fire will not prevent the perfomance of necessary safe plant shutdown functions, a detailed fire hazards analysis should be conducted for each plant area.
It is essential that the analysis include the effects of postulated fire involving pemanent and/or transient combustibles (exposure fires) on systems, circuit cable trays or equipment required for safe plant cold shutdown. The fire hazards analysis should identify all the redundant mechanical and electrical systems and components necessary for safe cold shutdown which are separated only by distance (no fire barriers and with redun-dant trains 20 ft. or less from each other). Redundant trains within 20 ft. of each other, as a minimum, will be required to be protected by a half hour fire rated barrier as well as are' outomatic sprinklers.
This does not mean that in some instances, suoh as the auxiliary feedwater system, redundant trains separated by more than 20 ft. will not require additional protection. The fire hazards analysis need to demonstrate that, assuming failure of the primary suppression system, a fire on installed or transient combustibles will not result in the loss of 1262 118
. OCT 2 21979 capability to achieve safe cold shutdown. Where this cannot be demonstrated, an alternate means of assuming safe plant shutdown (cold shutdren) should be provided.
We request that you demonstrate:
(1) Safe shutdown from the main control room where a fire disables any safe shutdown equipment including conduit / cable trays controlled from remote locations.
(2) Safe shutdown from remote locations when the main control room is unin-habitable due to a fire or when fire disables safe shutdown equipment of the relay room, cable chase areas, or the cable spreading areas.
Remote location need only be provided for the essential instrumentation, controls and equipment necessary to bring the plant to a hot standby condition. Fire damage to systems necessary to achieve and maintain cold shutdown should be limited so that repairs can be made and cold shutdown condition achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Enclosure No. 2 presents our require-runts for alternate shutdown systems.
2.
It is our position that you, comply with Section 0.1.j of BTP 9.5-1, Appendix A, in that the enclosure (walls, ceilings, and penetration seals) separating safety related equipment areas be 3-hou,r fire rated bar-riers. Many fire zones barriers enclosing redundant equipment were not identified as being fire rated.
Indir-'e how you will comply i i
- 19 { 'J-
}
L with our position. Revise your list to include all areas in which redundant safety-related systems (cable, conduit, equipment, e+c.) are located.
Identify the location and function of all such systems on pur drawings.
Verify that dampers installed in vertical or horizontal positions a.
are listed for their respective installation (i.e. dampers listed for horizontal installation or listed for vertical installation). During our site visit we observed two 1-1/2-hour rated fire dampers installed in vertical penetration of floor / ceiling construction. Ducts or openings in fire rated barriers should be provided with appropriate fire dampers.
Modify your design accordingly, b.
During our site visit we observed many fire door or door frame labels were not in place where credit for rated fire door has been utilized in your analysis and on-the diagrams. Verify that these doors are either labeled door / frames or that they qualify to be the equivalent.
3.
Portable smoke ejectors, capable of operating with loss of offsite power, are required for fire brigade use.
Indicate how you will satisfy this requirement.
4.
It is our position you comply with Section D.5. a of BTP 9.5-1 Appendix A,
by providing 8-hour battery pack emergency lighting in all areas required to be manned for safe shutdown operations and for access and egress routes to and from all fire areas.
5.
Fire pumps must be able to supply the largest firewater flow demand in addition to any other demand, e.g., diesel generator cooling system, and be in conformance to the applicable requirements of NFPA Standard No. 20.
Indicate how you will comply with these requirements including 1269..
120 i
-4 OCT 2 2 tg79 how you will test the automatic start feature on the pumps. Also, provide a system description of '.he filtered water pumps supplying water to the firewater system.
6.
During our site visit we were infomed that some circuit changes have been made in the fire pump controller for the electric driven fire pump.
The fire pump controller should be UL listed or FM approved, and any changes made to the unit or delivered voids the UL or FM approval.
Provide electrical diagrams to indicate what changes have been made.
7.
Page 5.0-41; Item 7 It is our position that you comply with Section D.7 of BTP 9.5-1, Appendix A by providing air flow monitors that alam in the control room, for the ventilation air in the battery rooms.
8.
Page 5.0 -46; Item G1 You have net indicated that work involving ignition sources such as welding and flame cutting is coordinated by a pemit system.
It is our position that all work involving ignition sources require a permit to comply with Section B.3.a of BTP9.5-1, Appendix A.
9.
Page 5.0-25; Item h It is our position that you comply with Section-0.4.h of BTP 9.5-1, Appendix A, by providing a 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> onsite reserve air supply for the self-contained breathing apparatus air bottles.
- 10. Page5.0-26a; Item (c)
It is our position that you comply with Section 0.5.(b) of BTP 9.5-1 Appendix A by providing voice-powered head sets for emergency connunications at pre-selected stations.
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. OCT 2 z 1979
- 11. Page 5.0-30; Item g It is our position that hose houses be equiped with 1 -inch and 2h-inch hoses and that equipment comply with Chapter 5 of NFPA Standard No. 24.
- 12. Page 5.0-31; Item 3(s)
It is our position, as stated in Section C.3.b of BTP 9.54, Appendix A, that you provide valves in the fire protection system that are electrically supervised, alamed, and annunciated in the control room. Post indication valves on the fire main system can be kept under lock and key with adminis-trative controls.
- 13. Page 5.0-37; Item F.2, page 5.0-41; Item 6, and page 5.0-43; Item 11.
It is our position, as stated in " Guidelines for Specific Plant Areas", of BTP 9.5-1, Appendix A, Sections D.2, D.12, and 0.13 that you provide smoke detection systems for the control room area, the control room ventilation. system, and the new and spent fuel pool areas.
- 14. Section 4.2; Auxiliary Building a) It is our position that you comply with " General Guidelines for Plant Protection" of BTP 9.5-1, Appendix A, Section 1.j, by providing 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated penetration seals for the floor and wall openings.
b) During our site visit you indicated that automatic sprinklers would be installed in areas of the solid waste druming station. Verify that the sprinklers will provide total areas coverage.
c) If the collapse of the unprotected steel deck roof can affect safety related systems, then comply with Section 1.j of
" General Guidelines for Plant Protection", of BTP 9.5-1, Appendix 'A.
Indicate how you will accomplish this.
1262 122 007 2 2 1979
.15 Page 5.0-32; Item d According to Section C.3.d of the BIP 9.5-1, Appendix A, standpipes should be equipped with linen, woven-Jacket fire hose. Your standpipe stations consist of hose reels with unlisted rubber hose. Verify that your unlist2d rubber hose is equivalent to linen, woven-jacket fire hose.
16.
Portable Fire Extinguishers - General Your present design does not comply with NFPA 10 covering pcrtable extin-guishers for many areas, especially the Fire Areas 18-18 and 19, Control Building, cable vaults, service water pump house, East and West Pene-tration Areas and Battery Ventilation Equipment Rooms A&B.
It is our position that you provide portable fire extinguishers so that the require-ments of NFPA 10 (75 ft. maximum travel distance to any area from portable extinguisher) is complied with in each plant area.
17 Floor Drains - General It is our position, as stated in Section 0.1.i of the BTP 9.5-1, Appendix A, that you provide floor drains that will inhibit the transr.itting of a small flammable liquid spill fire.
The Battery Ventilation Equipment (Rooms A&B), Service Water Booster Pump Area (Rooms A&B), HVAC Water Chiller Equip-ment Areas, Fire Areas IB-7 through IB-9 and Fire Area SWPf:-),tre areas having floor drains that should meet this design objective. Verify that your installation meets this requirement.
18 Control Building - General vour analysis for several areas of the Control Building was changed in Revision 2 Revision 2 now describes the ceiling construction as a 1262 123
h OCTgaig7g
" steel from deck on protected steel framing." Your original submittal described these floor / ceiling slabs as "3 hr. protected steel form deck and framing." Verify that in your present design all ceiling / floor assemblies in the control building are 3 hr. fire-rated assemblies. Also, several areas of this building are identified as being reserved for a future Unit.
Provide a fire hazard analysis to show that a fire in this area will not affect safety related areas.
10.
?VAC Water Chiller Equipment Area - i' ire Areas IB-7 through IB-9 All three chilled water pumps are located in one room. We require that these pumps be separated by a fire rated barrier totally enclosing each pump.
Indicate how you will comply with this requirement.
20.
Service Water Pump fiouse Describe the barrier, including its fire rating, that will be installed to separate the ventilation ducts from the electrical equipment areas similar to the way you described other barriers in your fire hazards analysis Section 4.7.2.1.
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OCT 2 21979 ENCLOSURE 2 STAFF REQUIREMENTS FOR ALTERNATE SHUTCOWN SYSTEMS 1.0 Minicum safe shutdown systems when one division of all safety systems is not available.
1.1 Following any fire, the plant can be brought to hot shutdown conditions using equipment and systems thatare free of fire damage.
-1. 2 The plant should be capable of maintaining hot shut.down 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 />.
1.3 Fire damage to systems necessary to achieve and maintain cold shutdown conditions should be limited so that repairs car be made and cold shutdown conditions achieved within 72 acurs.
1.4 Repair procedures for cold shutdown systems should be prepared now and material needed for such repairs should be on the site.
1.5 The hot shutdown condition must be achievable with power from the offsite power system, and upon its loss, with power from the onsite power system. A dedicated power supply may be substituted for the onsite power system.
1.6 The power needed to achieve the cold shutdown condition may be obtained from any one of the offsite power, onsite power, and dedicated power system.
w 1.7 When these minimum systems are provided their adequacy shall be verified by a thorough evaluation of:
a.
Systems required for hot shutdown; b.
Systems required for cold shutdown:
c.
Fire damage to power distribution systems; and d.
Interactions caused by fire damage to power and water supply systems and to supporting systems, i.e., component cooling water supply.
- 2. 0 Minimum fire protection when dedicated or citernate shutdown systems are provided.
2.1 The fire protection systems in areas (such as cable spreading rooms) that contain~ cables for a large number of systems should consist of:
a.
Fire detection system;
) 2(32
\\
b.
Hose stations; and c.
Fixed manual suppression system (gas or water)
NOTE: Consideration to pra,'enting fire propagation via covered trays, fire retardant coating, barriers or blankets on a case-by-case basis.
. 107 a : SN 2.2 Where access is difficult or impossible automatic systems should be provided.
2.3 Where modifications will not be implemented for an extended '
period, interim protection masures should be required to compensate for the lack of protection.
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