ML19259D342
| ML19259D342 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 09/06/1979 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19259D338 | List: |
| References | |
| TAC-11094, TAC-11095, NUDOCS 7910180168 | |
| Download: ML19259D342 (83) | |
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FIRE PROTECTION SAFETY EVALUATION REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION U.S. NUCLEAR REGULATORY COMMISSION IN THE MATTER OF NORTHERN STATES POWER COMPANY PRAIRIE ISLAND NUCLEAR GENERATING PLANT - UNITS 1 & 2 DOCKET NOS. 50-282 AND -306 September 6,1979
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TABLE OF CONTENTS Page 1.0 INTRUCUCTION.................
1-1 2.0 FIRE PROTECTION GUIDELINES 2.1 General Design Criterion 3
" Fire Protection"...............
2-1 2-1 2.2 Supplementary Guidance....
3.0
SUMMARY
OF MODIFICATIONS AND INCOMPLETE ITEMS 3.1 Mod.fications..............................................
3-1 3.2 Incomplete Items.................................................
3-5 4.0 EVALUATION OF PLANT FEATURES 4-1 4.1 Safe Shutdown Systems........
4.2 Fire Detection and Signaling Systems......................
4-3 4-3 4.3 Fire Control Systems....
4.3.1 Water Systems...........................................
4-3 1.
Water Supply........
4-3 4-4 2.
Fire Pumps..
3.
Fire Water Piping System.............................
4-4 4.
Interior Fire Hose Stations...........................
4-6 5.
Sprinkler Systems.....................................
4-8 6.
Foam Extinguishing Systems.....................
4-9 7.
Effects of Flooding and Water Spray..............
4-9 4.3.2 Gas Fire Suppression Systems..............................
4-9 4.3.3 Portable Fire Extinguishers................
4-10 4.4 Ventilation Systems and Breathing Equipment...................
4-10 4-10
- 4. ".1 Smoke Removal....................................
4.4.2 Filters.................
4-10 4-11 4.4.3 Breathing Equipment..................................
4.5 Floor Drains.
4-11 4.6 Lighting Systems......
4-12 4.7 Communications Systems...
4-12 4-13 4.8 Electrical Cables..............................................
4.9 Fire Barrier Penetrations........................................
4-13 4.9.1 Electrical Cable and Conduit Penetrations......
4-13 4.9.2 Fire Doors..............
4-14 4.9.3 Ventilation Duct and Pipe Penetrations...................
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TABLE OF CONTENTS (Continued)
_Pajl_e 4-16 4.10 Separation Criteria..............................................
4-16 4.11 Fire Bcrriers.........
4-17 4.12 Access and Egress................................................
4-17 4.13 Toxic and Corrosive Combustion Products..................
4-17 4.14 Nonsafety-Related Areas..........................................
4-17 4.15 Instrument Air......
5.0 EVALUATION OF SPECIFIC PLANT AREAS 5-1 5.1 Control Room Complex...................................
5-3 5.2 Cable Spreading and Relay Room.......................
5-4 5.3 Computer Room....
5.4 Units 1 & 2 4160-Volt Safeguards Switchgear Rooms................
5-5
- -7 5.5 Units 1 & 2 480-Volt Safeguards Switchgear Rooms..........
5 ts 5.6 Units 1 & 2 4160-Volt Normal Switchgear Rooms....................
5-9 5.7 Units 1 & 2 480-Volt Normal Switchgear Rooms.....................
5.8 Units 1 & 2 Rod Drive Control and Switchgear Rooms...............
5-10 5-11 5.9 Battery Room Complex.............................................
5.10 Auxiliary Feedwater Pump, Instrument Air ar.d Hot Shutdown 5-12 Panel Rooms.............
5-14 5.11 Auxiliary Building - Elevation 695 Feet..........................
5-18 5.12 Auxiliary Building - Elevation 715 Feet..........................
5-20 5.13 Auxiliary Buildi ng - Elevation 735 Feet..........................
5-23 5.14 Auxiliary Building - Elevation 755 Feet....................
5-24 5.15 Reactor Containment Buildings....................................
5.16 Radwaste Guilding and Resin Disposal Building....................
5-26 5.17 Diesel Generator Rooms - Fire Zones 25 and 26 and Water Treatment Area - Fire Zone 27..................................
5-27 5-29 5.18 Yard Area........................................................
5-30 5.19 Screen House.....................................................
5.20 Turbine Building - Fire Zones 8 and 9 and Administrative 5-33 Building - Fire Zone 7.
5.21 Administrative Building - Fire Zone 24...........................
5-35 5.22 Working Materiai and Lunch Room - Fire Zcne 14 and Utility and Locke. Rooms - Fire Zone 15....................................
5-36 5.23 Turbine Building - Fire Zones 69 and 70 and Hydrogen House -
5-37 Fire Zone 57........
6-1 6.0 ADMINISTRATIVE CONTROLS.............
7-1 7.0 TECHNICAL SPECIFICATIONS..............................................
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8.0 CONCLUSION
S......................
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TABLE OF CONTENTS (Continued)
P.agg 9.0 CONSULTANTS' REPORT............
9-1 APPENDIX A - Chronology............
A-1 APPENDIX B - Discussion of Consultants' Report................
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1.0 INTRODUCTION
Following a fire at the Brown's 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 power plants.
As part of this continuing 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 for a comprehensive review of all new licensee applications.
The NRC issued new guidelines for fire protection programs in nuclear power plants which reflect the recommendations in NUREG-0GLO.
These guidelines are contained in the following documents:
" Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," NUREG-75/087, Section 9.5.1, " Fire Protection,"
May 1976, which includes " Guidelines for Fire Protection for Nuclear Power Plants" (BTP APCSB 9.5-1), May 1, 1976.
" Guidelines for Fire Protection for Nuclear Power Plants" (Appendix A to BTP APCSB 9.5-1), August 23, 1976.
" Supplementary Guidance on Information Needed for Fire Protection Program Evaluation," September 30, 1976.
" Sample Technical Specifications," May 12, 1977.
" Nuclear Plant Fire Protaction Functional Responsibilities, Admin-istrative Controls and Quality Assurance," June 14, 1977.
" Manpower Requirements for Operating Reactors," June 1978.
All licensees were requested to:
(1) compare their fire protection programs with the new guidelines; and (2) ?nalyze 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 struc-tures with both combustibles anc the associated fire detection and suppression systems.
Our review has been limited to the aspects of fire protection related to the protection of the public within the NRC's juris-
- diction, i.e., those aspects related to health and safety.
We have not considered aspects of the fire piotection 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.
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The report summarizes the results of our evaluation of the fire protection program at Northern States Power Company's Prairie Island Nuclear Generating Plant.
The chronology of our evaluation is summarized in Appendix A of this report.
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2.0 FIRE PROTECTION GUIDELINES 2.1 General Design Criterion 3
" Fire Protection" The Commission's basic criterion for fire protection is set forth in General Design Criterion 3, Appendix A to 10 CFR Part 50, which states:
" Structures, systems and components important to safety shall be designed and located to minimize, consistent with other safety require-ments, the probability and effect of fires and explosions.
" Noncombustible and heat resistaat materials shall be used wherever practical throughout the unit, particularly in locations such as the containment and control room.
" Fire detection and fighting systems of appropriate capacity and capability shall be provided and designed to minimize the adverse effects of fires on structures, systems and components important to safety.
" Fire fighting systems shall be designed to assure that their rupture or inadvertent operation does not significantly impair the safety capability of these structures, systems and components."
2.2 Supplementary Guidance Guidance on the implementation of GDC-3 for existing nuclear power plants has been provided by the NRC staff in " Appendix A" of Branch Technical Position 9.5-1, " Guidance for Fire Protection for Nuclear Power Plants."
Appendix A provides guidance on the preferred and, where applicable, acceptable alternatives to fire protection design for those nuclear power plants for whic: applications for construction permits were docketed prior to July 1, 197, Although this
>pendix provides specific guidance, alternatives may be proposed by li.ensees.
These alternatives are evaluated by the NRC staff on a case-by-case basis.
Additional 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," C tober 21, 1976.
" Sample Technical Specifications, Mr.y 12, 1977.
" Nuclear Plant Fire Protection Functic ul Responsibilities, Admin-istrative Controls and Quality Assura..ce," June 14, 1977.
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" Manpower Requirements for Operating Reactors," May 11, 1978.
When the actual configuration of combustibles, safety-related structures, systems or components, and tne fire protection features are not as assumed in the development of Appendix A or when the licensee has proposed alterna-tives 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 cafely 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 individ-ual objectives; increased strength, redundancy, performance, or reliability of one of these methods can compensate in some measures for deficiencies in the others.
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3.0
SUMMARY
OF MODIFICATIONS AND INCOMPLETE ITEMS 3.1 Modifications The licensee plans to make certain plant modifications to improve the fire protection programs as a result of both his and staff's evaluations.
The proposed modifications are summarized below.
The implementation schedule for these modifications is in Table 3.1.
The licensee has agreed to this schedule.
The sectio.1s of this report which discuss the modifications are noted in parentheses.
Certain items listed below are marked with an asterisk (*) to indicate that the NRC staff will require additional information in the form of design details, test results, or acceptance criteria to assure that the design is acceptable prior ta actual implementation of these modifications.
The licensee has agreed to provide this information.
The balance of the other modifications has been describcd in an acceptable level of detail.
3.1.1 Fire Barriers and Penetrations (1) A concrete barrier will be placed in the pump trench that passes through the auxiliary feedwater pump rooms at the boundary between the two rooms (5.10).
(2) Penetrations or selected fire barriers will be sealed and existing seals reexamined and, as necessary, upgraded in various plant areas (4.9, 5.11, 5.12, 5.13, 5.14, 5.20, 5.23).
(3) All electrical and mechanical seals installed in the future, or used as replacements will be qualified seal designs (4.9).
(4) Existing seals which contain polyurethane foam will be raplaced or suitably modf *ied anc L: e design tested to verify their effectiveness as a barrier (4.9).
3.1.2 Hose Stations (1) Additional fire hose accessories will be provided for exterior hydrant hose houses numbered 19 through 26 (4.3).
(2) All interior unlined linen fire hose will be replaced with 100%
synthetic material fire hose (300 psi test pressure), F.M. or U.L.
labelled, suitable for pin rack storace (4.3).
(3) All interior hose will ne nydrostatically tested every three years at a pressure of 50 psi aaove the maximum service pressure (4.3).
(4) One inch booster hose equipped with a variable gallonage nozzle and a shut off control will be provided for selected fire hose stations as specified herein (4.3, 5.1, 5.2, 5.5, 5.8).
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3.1.3 Yard Loco (1) Barricade posts at post indicator valves numbered FP35-2 and FP35-3 will be modified as specified (4.3).
(2) All other post indicator valve barricade posts will be evaluated and modified as necessary to assure that they are not vulnerable to vehicular traffic damage (4.3).
(3) A periodic inspection schedule for eac1 hydrant barrel will be estab-lished as specified herein (4.3).
(4) Hoses in fire houses 19 through 26 will be hydrostatically tested annually at a pressure of 50 psi above the maximum service pressure.4.3).
3.1.4 Control of Combustibles (1) The floor trench around the hydrogen seal oil units wil' be extended to improve drainage of any oil leakage (4.5).
(2) A two-inch ramp will be installed in the emergency diesel generator rooms (0-1) to prevent the flow of liquids from passing under the door to the adjacent diesel generator room (5.17).
(3) A 4" angle iron curb sealed with a gasket impervious to diesel oil will be provided in the screen house at the ooen doorways of the diesel engine driven cooling water pump rooms at the 695-foot eleva-tion (5.19).
(4) Gaskets that seal angle iron curbing will be water tested to assure seal tightness after each reinstallation of the curbing.
(5) The wooden battery covers in the area of diesel engine driven fire pump will be removed or replaced with noncombustible covers (5.19).
(6) All combustibles stored in safety-related areas of the auxiliary building except that stored in approved fire rated cabinets will be removed (5.11).
(7) Trash containers in all safety-related areas of the plant will be replaced with metal containers with metal swing top lids (5.11).
(8) All lumber and wooden items in all safety-related areas will be replaced with a pressure treated fire retardant lumber or coated with a penetrating fire retardcnt coating that has good abrasion resistance (5.11).
(9) Storage of combustibles in tne auxiliary building, 715-foot elevation, along the north wall of the Unit 2 wing will be discontinued except for a small amount of supplies for the not chemical laboratory which will be stored in approved fire rated lockers (5.12).
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(10) A ceiling has been installed at the 755-foot elevatien of the auxiliary building over part of the hatch area for storage of combustibles.
A sprinkler system will be installed under the new ceiling (5.13).
(11) A curb will be provided at the diesel fire pump day tank (5.19).
3.1.5 Fire Retardant Coatings (1) Building structural members in the vicinity of the lube oil reservoirs will be coated with a suitable fire retardant coating (5.23).
(2) All polyurethane foam piping insulation used in all safety-related areas of the plant will be coated with a fire retardant intumescent coating (5.12).
(3) The wooden equipment boxes stored in the halen arca on the platform above the entrance to containment will be coated with an acceptable fire retardant coating or they will be reaoved e Om the plant (5.13).
3.1.6 Combustible Fluid Cylinders (1) The 210 pound water capacity propane cylinder located in the cold laboratory and the 239 pound water capacity diamethylamine cylinder located in the counting room will be relocated to an arer separated from safety-related areas by a three hour fire-rated barrier. The new installations will be equipped with pressure regulators and the piping and cylinder installation will be in accordance with NFPA No. 58 (5.12).
3.1.7 Portable Fire Extinguisher (1) Additional portable extinguishers will be provided for various plant areas (4.3).
(2) A five pound dry chemical extinguisher will be provided in the record storage room adjacent to the cooking range (4.3).
3.1.8 Emergency Lighting (1) The fire brigade will be provided with two battery powered portable handlights (4.6).
3.1.9 Containment Fire Suporession Water (1) More timely fire suppression water will be provided for the contain-ment (4.3, 5.15).
3.1.10 Foam Aoplication Equipment (1) Manual foam aprlication ec,21;ter.t will be provided for use with 1 -inch hose lines at centrali;ec fire equipment locations as spec'-
fied (4.3, 5.23).
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3.1.11 Water Damage Protection (1) Waterproof tarpaulins will be stored for use in centralized storage location in the fire brigcde equipment locker (4.3, 5.1, 5.2, 5.5, 5.6).
3.1.12 Alternate Shutdown Capability (1) An alternate shutdown capability will be provided independent of the cable spreading and relay rooms (5.2).
3.1.13 Filters (1) A grease filter will be provided for the hood and ducts above the electric cooking range in the control room complex.
A periodic cleaning program will be instituted for this filter (5.1).
3.1.14 Administrative Controls (1) Pre-fire plan strategies will be developed for all diesel fuel day tank areas to provide for tripping the diesel fuel transfer pumps and/or isolating the fuel supply lines to the day tanks in the event of a fire or a pipe break (5.19).
3.1.15 Emergency Breathing Apparatus (1) Emergency breathing capability will be upgraded to meet the needs of 10 people Tor six naurs at a usage rate of three 30 minute air bottles per person per hour (4.4).
3.1.16 Detector Location Markings (1) Detector locations will be marked by floor markings or by remote wall mounted indicator lights (4.2).
3.1.17 Fire Dampers (1) Fire-rated dampers will be installed in various ventilation ducts as specified nerei- (5.1, 5.2, 5.4, 5.9, 5.10, 5.12, 5.13, 5.20, 5.23).
3.1.18 Reactor Coolant Pump (1) The lube oil resulting from a leak in the reactor coolant pumps will be drained through piping to cortainment sump "A".
3.1.19 Fire Doors (1) Fire doors will be inspected per the established frequencies and c.riteria (4.9).
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3.1.20 Hydrant Hose Valves (1) The practice of connecting 1 -inch hydrant hosu valves and 1 -inch hose to the 2 -inch hydrant outlets will be discontinued.
A 2 -inch hydrant hose valve will be installed at each hydrant and a length of 2 -inch hose ' sill be connected to this valve when needed (4.3).
3.1.21 Wc..iing Signs (1) Signs reading " Danger Flammable Gas" will be posted near each flammable gas tank (5.12).
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 incomplete items.
The sections of this report which discuss these incomplete items are nated 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 by October 1980.
3.2.1 Safe Shutdown Systems (1) The safe shutdown capab ity requirements will be reevaluated as discussea in subsection 4.1 of this report for equipment and cables and for the fire protection afforded these items.
Verification will also be provided that the fire protection system, as modified, will provide assurance that postulated fires in these areas will not affect hot or cold shutdown capability (4.1, 4.10, 4.15, 5.2, 5.4, 5.6, 5.7, 5.11, 5.12, 5.13, 5.14, 5.15, 5.23).
(2) Documentation will be providea of the actual separation that exists between redundant shutdown systems in ;ones where redundant shutdown systems are located (4.1, 4.10).
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(3) Verification will be provided that a fire in the cable spreading room and relay room will not cause spurious movement of components thac would adversely affect the ability to shat down the plant (5.2).
3.2.2 Per.,..ri tf (1) The licensee will demonstrate that the electrical and mechanical penetratica seals installed in the plant have a rating equivalent to the fir', se erity present on either side of the seal.
These seals will ue qual,fied by test by an independent testing laboratory in accordance with ASTM E-119 under criteria acceptable to the staff (4.9).
(2) The licensee will reevaluate the penetration seals between the diesel generator rooms and the auxiliary building to verify that these seals have a minimum three hour fire rating.
Existing seals with less than a three hour rating will be upgraG2d (5.17).
3.2.3 Hydrogen Seal Oil Units (1) The licensee will verify that a fire involving seal oil leakage into the propcsca trench will not be a hazard to redundant se'e shutdown systems.
In addition, the proposed trench will be described and the potential impact of an oil fire on safety-related systems will be stated (4.5).
3.2.4 Spent Fuel Pool Cooling (1) The licensee will verify that alternative means of spent fuel pool cooling can be made available, if both spent fuel cooling pumps are damaged, using equipment located outside the spent fuel pool cooling pump area (5.13).
3.2.5 Fire Dampers (1) As a part of the ongoing revision to the fire hazard analysis, the licensee will verify that all fire zones that contain safety-related systems and equipment co not convain unprotected boundary ventilation paths.
If unprotected ventilation paths are found to exist, the licensee will provide fire dampers of a rating commensurate with tha fire load on either side of the bouncary.,
At the boundaries between the turbine building and safety-related areas, the licensee will install three-hour fire rated dempers cr the equivalent thereof (4.9).
3.2.6 Fire Pump The feasibility of providing a three-hour fire rated barrier around the electric motc. oriven fire pump in the screen house will be evaluated.
This evaluation will consider the exclusion of diesel fuel transfer piping from the area bounded by the fire barrier, and the routing of electric cables for the fire pump to assure that a diesel fuel fire will not damage the controls or power source for the fire pump.
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If the evaluation shows that it is not feasible to install such a fire barrier, the licensee will propose additional fire protection to assure that a diesel fuel fire would not incapacitate both fire pumps or alterna-tively upgrade the screen wash pump to function automatically as a fire pump if its use would not otherwise be required in a fire emergency (5.19).
3.2.7 Hydrogen Hazard - Auxiliary Building The licenree will verify that the excess flow valve on the auxiliary building h3 rogen line will limit hydrogen leakage sufficiently in the 1
event of a line break to preclude damage from a hydrogen fire to safety-related equip.3ent and cables (5.11).
3.2.8 Fire Detectors The licensee will verify that the existing installed detectors will respond promptly to the various types of materials found in the plant when these materials are involved in the incipient stages of a fire (4.2).
TABLE 3.1 IMPLEMENTATION DATES FOR PROPOSED MODIFICATIONS ITEM 0AiE 3.1.1 Fire Barriers and Penetrations 10/31/80 3.1.2 Hose Stations 12/31/79 3.1.3 Yard Loop 10/31/79 3.1.4 Control of Combustibles 12/31/79 3.1.5 Fire Retardant Coatings 10/31/79 3.1.6 Combustible Fluid Cylinders 10/31/79 3.1.7 Portable Fire Extinguishers Completed 3.1.8 Emergency Lighting Completed 3.1.9 Containment Fire Suppression Water 10/31/80 3.1.10 Foam Application Equipment 10/31/79 3.1.11 Water Damage Protection 9/30/79 3.1.12 Alternate Shutdown Capability 10/31/80 3.1.13 Filters Completed 3.1.14 Administrative Controls 12/31/79 3.1.15 Emergency Breathing Apparatus Completed 3.1.16 Detector Location Markings 12/31/79 3.1.17 Fire Dampers 10/31/80 3.1.18 Reactor Coolant Pump 10/31/80 3.1.19 Fire Doors 9/30/79 3.1.20 Hydrant Hose Valves 9/30/79 3.1.21 Warning Signs Completed o
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TABLE 3.2 LICENSEE SUBMITTAL DATES FOR INCOMPLETE ITEMS ITEM DATE 3.2.1 Safe Shutdown Systems 11/30/79 3.2.2 Penetrations 11/30/79 3.2.3 Hydrogen Seal Oil Units 12/31/79 3.2.4 Spent Fuel Pool Cooling 10/30/79 3.2.5 Fire Dampers 12/31/79 3.2.6 Fire Pump 12/31/79 3.2.7 Hydrogen Hazard - Auxiliary Building 12/31/79 3.2.8 Fire Detectors 11/30/79
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4.0 EVALUATION OF PLANT FEATUkES 4.1 Safe Shutdown Systems There are several combinations of safe shutdown systems which are capable of shutting down the reactor and cooling the core during and subsequent to a fire.
The combinations available in a fire situation will depend upon the effects of the fire on such systems, their power supplies, and their control stations.
To assure the safe shutdown of the reactor plant, those syste.ns and components which:
(a) insert negative reactivity into the reactor core; (b) control cooldown of the primary reactor coolant system; and (c) maintain reactor coolant inventory, should be protected in the event of a fire, and the measures should be taken to insure their availability.
Their general functional requirements for safe shutdown and the system auxiliaries and major components required to fulfill thes-requirements are as follows:
(1) Reactivity Controls The rod control system is of fail-safe design.
Faulting in the system circuits trips the reactor.
Following the reactor trip, soluble poisons are added to the primary system to assure subcriti-cality.
This is accomplished by using the charging pumps to inject borated water from the boric acid system into the reactor coolant system.
Alternative?y, the high pressure safety injection pumps, taking suction from the refueling water storage tank, can be used for tne injection of the poison.
(2) Reactor Coolant System Inventory Control Following a reactor shutdown or trip, reactor coolant system water inve7 tory is maintained by operation of the chemical and volume control system and charging pumps.
Primary coolant letdown may be isolated and charging pumps are cycled to maintain pressurizer level which otherwise would decrease due to coolant contraction during cooldown.
Alternatively, the high pressure safety injection pumps may be used to maintain the ccolant inventory.
(3) Decay Heat Removal Following a normal plant snu.s sn, the condenser steam dump system bypasses steam to the condenser to provide cooldown., If the condenser steam dump system is not available, locally or remotely controlled atmospheric steam dump valves on the main steam lines will provide cooldevn by relieving main steam to the atmosphere.
These atmospheric valves are backed up by the code safety valves on each steam line which can be manually opeated locally.
For decay heat removal imme-diately following the reactor trip, it is necessary only to maintain the control on one steam generator.
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For the continued use of the steam generators for decay heat removal, it is necessary to pecvide a source of water, a means of delivering that water, and instrumentation for pressure and level indication.
Feedwater may be supplied by a steam turbine driven, or motor-driven, auxiliary feedwater pump.
For ccoldown of the reactor coolant to a temperature of less than 200'F, the residual heat removal system is used. The system utilizes the residual heat removal pumps to circulate the reactor coolant through the residual heat removal heat exchangers where the decay heat is transferred to the component cooling water system and eventually rejected to the river via the coolirg water system.
(4) Auxiliaries Auxiliaries required for safe shutdown include the component cooling water system, cooling water system, instrument air system, and appro-priate instrumentation and power supply.
Multiple outside sources of power are available to the plant for both normal operatio.1 and shutdown functions.
Normal operations may utilize either outside or unit-generated power.
The power supplies to redundant safety-related equipment are electrically separated.
Emergency diesel generators will supply power for shutdown operations when offsite power or unit generated power is not available.
Station batteries will provide onsite d-c power for instrumentation and control.
(5)
Instrumentation Instrumentation required for safe shutdown include steam generator level indication, reactor coolant pressure and temperature indication and pressurizer level indication.
A number of the above described safety-related systems required for safe shutdown hara their redundant cables and components located in the same fire zone with minimum spatial separaticn.
The licensee has not adequately documented the actual separation between these redundant divisions.
Nor has he demonstrated that the separation is sufficient to permit safe plant shutdown in the evert of a major fire in these fire zones.
The licensee has committed to provide documentation of the actual separa-tion of redundant shutdown systems in zones where these systems are located.
The licensee is continuing his analysis to determine whether safe shutdown can be achieved in each plant area where tne fire is postulated.
If the results of such analysis indicates that safe shutdown could not be achieved with a postulated fire in any plant area, the licensee will propose modifi-cations which will e7able the plant to be taken to cold shutdown following any design basis fire; allowing minimal credit for automatic fire suppression measures.
We will address the adequacy of the safe shutdown capability of the plant in a supplement to this report after completion of the above described licensee documentation and evaluation.
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4.2 Fire Detection and Signaling System _s_
A fire detection and signaling system is provided throughout many areas of the plant which transmits alarm and supervisory signals to the control room where they are annunciated at the fire panel.
In addition to handling fire detector signals, the system transmits indications of water flow from the sprinkler and deluge extinguishing systems.
The system also indicates the operation of the carbon dioxide (CO ) extinguishing systems.
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cases, the zone from which the alarm or supervisory signal is initiated is indicated.
The fire detection system consists of approximately 828 ionization type detectors, 37 thermal type detectors, 18 flame detectors and 10 photoelectric type detectors.
The fire detection is independent of the fire protection systems and pecforms no actuation function.
The fire protection system has separate actuation devices to perform actuation functions.
The plant is divided into fire detection zones whch are not related to the fire areas discussed in the fire hazards analysis.
Each detection zone has fire detectors which feed into the fire zone panel located in the control room.
The fire zone panel visually indicates the alarm initiating zone.
The fire zone panel also alarms on the control room annunciator panel.
No audible alarming is provided locally although the public address system can be used to annm-e the location of a fire.
The six fire detection panels are provio. with 104 zones.
Seventy of these zones are used for detection, 17 for extinguishing system actuation indication and 19 are spares.
Some detectors are located in areas that are blocked from view by equipment or other obstructions.
The licensee will provide detector locations markings on the floor or install remote wall mounted indicator lights to show the approximate location of the hidden detectors.
The licensee will also provide verification that the existing installed detectors will respond promptly to the various types of materials found in the plant, including cabling, when these materials are involved in the incipient stages of a fire.
Manufacturer's test reports describing the detector response from burning of specific type materials will be considered acceptable.
The licensee has verified that the fire alarm system is backed up by an emergency source of power and has stated that all circuits are electrically supervised.
We find that, subject to implementation of the above described modifications, the fire detection and signaling systems satisfy tb7 objectives identified in Section 2.2 of this report and are, therefore, acceptable.
4.3 Fire Control Systems 4.3.1 Water Systems 4.3.1.1 Water Supply Water for fire protection is from the Mississippi River through the intake canal.
The water is drawn by fire pumps located in the screen house.
A
.f 4-3 bb OA3
secondary water supply is available through the cooling water system emergency intake pipe via crossovers to the fire mains.
We find the water supoly meets the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
4.3.1.2 Fire Pumps Two horizontal shaft centrifugal fire pumps each with a design capacity of 2,000 gallons per minute (gpm) at a pressure of 120 pounds per square inch (psi), are provided.
One of the fire pumps is diesel-engine driven and the other is electric motor-driven with power supplied from the emergency power bus.
A third pump, electric motor-driven, also having a capacity of 2,000 gpm at a pressure of 108 psi is normally assigned to the screen wash function but can be aligned to pump into the fire water system.
Pressurization of the fire water syctem is maintained by an electric motor-driven jockey pump.
The fire pumps can be started manually at the control room or at the pumps.
The fire cumps are also arranged to start automatically upon a drop in system pressure by means of Underwriters Laboratory listed fire pump controllers.
The electric motor-driven fire pump and the diesel engine-driven fire pump are located at the east side of the screen house separated by a distance of approv.imately 20 feet.
The screen wash pump, used as a backup fire pump, is located at the west side of the screen house, well separated from the regular fire pumps.
The licensee has committed to evaluate the adequacy of fire protection of the fire pumps in the screen house and to propose modifications to improve the fire protection of the fire ramps (5.19).
We will address the adequacy of the fire pumps in a supplement to this report after review of the licensee's evaluation and his proposal to improve the fire protection cf the fire pumps in the water screen house.
- 4. 3.1. 3 Fire Water Pipina System Separate 10-inch supply lines to the 10-inch underground yard main encircling the plant are provided from the fire pump header in the screen house.
Valving is provided so a single break in the discharge piping will not remove both fire pumps from service.
A backup supply of water to the yard fire main loop is provided by eight crossovers between the cooling water system and the fire water system.
Sectionalizing valves with post indicators subdivide the loop into a number of sections enabling a single section to be isolated without impair-ing the entire loop.
The post indicator valves are not provided with electrical supervision or approved locks to assure that all sections of the underground fire loop are fully open.
Some post indicator valves were found to be inadequately protected from vehicular traffic because the guard post was not tall enough.
){fy 4
4-4
Eight hydrants are provided in the yard spaced from 180 to 300 feet apart.
The hydrants are supplied from the underground fire loop although the laterals 'eeding the hydrant are not provided with isolation valves.
The plant is provided with a 10-inch fire header encircling the inside of the turbine building and the auxiliary building.
These internal headers are supplied from the yard er'n system at three different sides of the plant, with the piping running mder the ceilings.
All interior hose stations and fixed suppression s,r ams tap off the ir.terior headers.
The isolation valves in the interior fire header in the turbine building and auxiliary building are of the butterfly valve type with chain operators.
Because of this arrangement, the necessity of isolating a portion of the underground yard loop to repair a hydrant or leaking main will not result in shutting off the supply of water to systems protecting safety-related equipment or areas.
Valves controlling the flow of fire protection water throughout tre fire water piping system are not adequately supervised to insure against the possibility that an improperly closed valve may deprive water to fire protection systems when needed.
The hydrants are provided with hand wheels affixed to the stem nut for quick and easy operation of the hydrant.
The hydrants have two outlet ;
one has a 2 -inch gate valve with 100 feet of 2\\-inch hose attached.
The other is reduced to l\\ inch with a 1 -inch gate valve and 100 feet of 1 -inch hose attached.
The practice of connecting I\\-inch hose to the hydrants is not considered acceptable.
This arrangement may cause a reduction in fire water pressure when two hose streams are needed to fight a fire.
Threads on hydrant outlets and hose couplings are compatible with those of fi - departments which serve the plant.
Each of the hydrants is provided with a well maintained corrugated metal hose house containing:
100 feet of 1 -inch and 200 feet of 2 -inch single jacket lined hose, one 2 -inch and one 1 -inch fog nozzle and various other items of fire fighting equipment.
The inventory of equipment in the hose houses requires upgrading to include additional 1 -inch hose, hose gaskets and a gated wye to allow connecting two l\\-inch hose lines to a 2\\-inch hose line.
Existing procedures do not include provisions for servicing and pressure testing of hyd* ants at the beginning and end of the freezing season.
The licensee procedure of pressure testing exterior hose every three years is considered unacceptable.
The licensee will provide the following modifications to improve the fire water piping system.
(1) The barricade posts at post indicator salves FP 35-2 and FP 35-3 will be extended in height so that the height of the post is approximately 6 inches above the height of the valve operating assembly.
All other post indicator valve barricace pcsts will be evaluated and modified as needed to assure that tney are not vulnerable to damage from vehicular traffic.
.g I166 045 4-5
(2) A periodic inspection schedule will be established to:
(a) verify that each hydrant barrel i drained preceding the winter freezing season; (b) conduct a hydrostatic test of each hydrant barrel to verify its pressure integrity followirg the winter freezing season.
i (3) The folloting equipment will be provided in each of the e ght hyarant hose houses that are in the vicinity of the turbine bi'iiding, auxiliary building and containment building complex (hydrant hose houses 19, 20, 21, 22, 23, 24, 25, 26).
1.
Two hose gaskets for each hose size used; 2.
One 2 " x 1 " x 1 gated wye; and 3.
One additional 100-ft. length of 1 " hose.
(4) Valves controlling the flow of fire water will be provided with electrical supervision or chains and locks or tamper proof seals.
The licensee will revise the Technical Specifications to require that the fire suppression water systems, for safety-related areas and areas posing a fire hazard to safety-related areas, be demonstrated operable at least onct monthly by verifying that each valve (manual, power operated, or automatic) in the flow path is in its correct position and the method (electrical supervision, backup, or tamper-proof seals) of securing each valve in its correct position is functioning.
(5) All exterior fire hose will be hydrostatically tested at a pressure 50 psi above maximum service pressure annually.
(6) The practice of connecting 1 -inch hydrant hose valve and 1 -inch hose to the 2 -inch hydrant outlets will be discontinued.
- Instead, 2\\-inch hose valves will be connected to each hydrant outlet and a length of 2 -inch hydrant hose will be connected to this valve when neaded.
When only small hose streams are required, the proposed 2i-inch x 1 -inch x 1 -inch gated wyes be connected to the 2 -inch rose which can supply two 1 -inch hose lines connected to the discharge outlets of the gated wye.
We find that, subject to implementation of the above listed modifications, fire water piping systems satisfy the objectives identified in Section 2.2 of this report and are, therefore, acceptable.
4.3.1.4 Interior Fire Hose Stations Interior hose stations are provided throughout most areas of the plant connected to tha fire water header.
Most hose stat ons consist of a pin lug type hose rack, 300 psi hose valve with drip vent and 50 to 100 feet of 1 -inch unlined linen hose coupled to an all fog type nozzle with a ball shut off feature.
The provision of unlined linen hose is considered unsatisfactory in an industrial application since it cannot he practically 1i66 U46 4-6
tested, deteriorates readily when subjected to moisture, and is more subject to failure from abrasion and cuts than hose with synthetic lining and jacketing.
The standpipe and hose stations within the containment structure are dry during normal operating periods.
This is accomplished by removing spool pieces in the fire water supply line and sealing the open pipe ends with blind flanges.
This arrangement of the standpipes in containment will result in a six-to eight-hour period of time to elapse before the stand-pipes can be pressurized and mariual application of water started.
A more timely method for providing fire water to containment hose stations is needed to assure prompt extinguishment of a fire within containment.
Several areas af the plant contain electrical cabinets and panels which are susceptil to water damage.
Using a 1 -inch hose station would apply unnecessarily darge quantities of water in these areas which could affect safety-related equipment in the area or in adjacent areas.
H9se stations with low capacity adjustible nozzles in these areas would provide adequate fire fighting capability with reduced risk of damaging water sensitive electrical equipment.
Areas especially sensitive to water damage such as the cable spreading and relay rooms should be protected during fire fighting operations with waterproof tarpaulins.
The licensee has agreed to improve the interior fire hose stations by providing the following modifications:
(1) All interior unlined linen fire hose will be replaced with 100%
synthetic material fire hose (300 psi test pressure) F.M. or U.L.
labelled, that is suitable for pin rack storage.
(2) All interior fire hose will be hydrostatically tested every three years, at a pressure 50 ?si above the maximum service pressure.
(3) A one-inch booster hose with variable gallonage nozzle with shut off will be provided adjacent to the existing hose stations numbers 21, 23, 24, 64, 69 and 70.
Waterproof tarpaulins will be stored with other fire fighting equipment at the central storage location.
The licensee has agreed to provide a more timely method for providing fire water to the containment and will provide details for accomplishing this modification.
Possible methods under study include a solidly piped supply header, use of available plant makeup water, and use of available cooling water in containment.
We find that, subject to implementation of the above described modifications, interior fire hose stations satisfy the objectives identified in Section 2.2 of this report and are, therefore, acceptable.
66 047 4-7
4.3.1.5 Sprinkler Systems Various types of automatic and manually actuated sprinkler systems have been provided at some high hazard areas of the plant.
These systems include wet pipe automatic sprinkler systems, pre-action dry pipe sprinkler The systems and both r:anual and thermal detector-actuated deluge systems.
Jesign and installation of the sprinkler systems conform to the provisions of the National Fire Protection Association Standards 13 and 15.
In general, sprinkler systems have been provided where hazardous concentra' tions of combustibles exist such as at cil storage and equipment areas.
More specifically, these sprinkler systems include:
TYPE OF SYSTEM AREA Wet Pipe Automatic Sprinkler Turbine Building - Turbine Lube Systems Oil and Control Oil Piping Areas Air Compressor and Auxiliary Feedwater Pump Rooms Exit Stairwells Records Storage Area Decontamination Area Water Treatment Area Warehouse Hot Lab Arca Deluge Systems Main Auxiliary and Startup Transformers Turbine Generator Bearings Turbine Seal Oil Unit Turbine Lube Oil Reservoir Oil Storage Room Charcoal Filters - Auxiliary Building Special Exhaust Filter and the Shield Building Exhaust Filters Pre-action Dry Pipe Sprinkler Containment Cable Penetration Areas Systems Diesel Generator Rooms Screeri House Pump Area (Both Levels) Including the Diesel Cooling Water Pumps and the Diesel Driven Fire Pump.
We find that the automatic sprinkler systems satisfy the objectives identi-fied in Section 2.2 of this report and are, therefore, acceptable.
4-8
4.3.1.6 Foam Extinguishing Systems There are presently no foam extinguishing systems nor equipment for manual application of toam at the plant.
There are a number of areas in the plant where there is a heavy concentration of combustible liquids which may prove difficult to extinguish with plain water.
The licensee has agreed to provide manual foam application equipment consisting of foam concentrate and foam applicator nozzles with pick-up tubes for use with l\\-inch hose lines.
We find that upon implementation of this modification, the foam manual application equipment is adequate for the hazard.
4.3.1.7 Effects of Flooding and Water Spray We have reviewed the effects of (1) breaks in fire protection piping that may result in water flooding damage to safety-related equipment; (2) cracks in fire protection piping that may result in water spray damage to safety-related equipment or that may impair suppression capability of both primary and backup means of suppression; and (3) inadvertent fire protec-tion system actuation that may result in damage to safety-related equipment.
With three exceptions, automatic sprinkler systems are not used in areas of the plant containing safety-relatd equipment.
The three safety-related areas that are protected by automatic sprinklers are the diesel generators, Water the diesel cooling water pumps, and the auxiliary feedwater pumps.
flows from automatic suppression systems are annunciated on the fire panel in the control room.
Flows from manual hose stations are not annunciated, but they will case the fire pump to start, thereby transmitting a " fire pump running" signal to the control room.
A flow from the fire protection water system can thus be inferred.
In most areas, curbs, drains and the mounting of equipment above the floor level minimizes the potential for flooding damage.
In other areas, water will drain out doors or via stairways or through grating to lower elevations, such that the standing water would not affect safety-related equipment.
In addition, valves have been provided to isolate sections of fire protec-tion system piping inside buildings to preclude the buildup of water and thus prevent equipment from being incapacitated due to flooding.
We find that the protection from inaavertent or required operation of a suppression system satisfies the objectives identified in Section 2.2 and is, therefore, acceptable.
4.3.2 Gas Fire Suopression Systems A carbon dioxide (CO ) type gas fire suppression system is provided in the 2
cable spreading and relay rocr The compJter room is located within this roon, and is also protected by the 002 system.
The system is designed for total flooding application witn a 50 percent concentration for 15 minutes.
Storage tank capacity is adequate for two shots.
The system is actuated 4-9 bh h4h
by thermal detectors with provisions for manual actuation.
The area is also provided with early warning detectors which indicate an alarm but does not actuate the CO suppression system.
2 We find that the gas fire suppression system satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
4.3.3 Portable Fire Extinguishers Portable and wheeled fire extinguishers are provided throughout +.he plant.
Most of the extinguishers are of the carbon dioxide (CO ) or dry chemical 2
type.
The licensee has proposed to provide additional extinguishers in various areas of the plant as identified by his comparison with the guide-lines contained in Appendix A to Branch Technical Position 9.5-1.
The licensee will also provide a five pound dry chemical extinguisher in the records storage room adjacent to the cooking range.
We find that subject to the provision of this additional unit, the quantity, type and distribution of portable extinguishers conform to the provision of Appendix A to BTP 9.5-1. and are, therefore, acceptable.
4.4 Ventilation Systems and Breathing Equipment 4.4.1
$moke Removal The turbine building has roof exhaust fans as well as smoke hatches that are fitted with automatic releases.
No other smoke exhausting systems are provided for the other plant buildings.
In the buildings without smoke exhausting systems, the normal ventilation systems could be used for smoke removal for some types of fires although not specifically designed for this purpose.
The fans ano other equipment in the normal air handling systems are not designed to withstand high temperatures, and could be incapacitated by the heat from a significant fire.
However, in plant areas other than the turbine building the fire loading is not high, and the installed and proposed fire protection features will limit the amount of smoke and hot gases ger.erated.
When normal air handling systems cannot be used for smoke removal, the plant personnel will use the portable and semi portable fans available at the plant.
We find that the smoke removal capability at the plant satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
4.4.2 Filters Charcoal filters are housed in metal cabinets on the top floor elevations of the auxiliary building and ir. the reactor containment buildings.
The charcoal filters in the auxiliary bt,lding are for the auxiliary building special ventilacion exhaust system; the shield building exhaust system; the spent fuel special and in-service purge exnaust system; and the control rocm ventilation system.
The auxiliary beilding special ventilation exhaust filters and the shield building exhaust filters have the greatest 4-10 66 050
potential for iodine decay heating and have been provided with a wet pipe sprinkler system.
Some of the other filter cabinets are provided with sprinkler heads but a water supply to the internal sprinkler piping has not been provided.
The containment internal air cleanup system charcoal filters, located on the 755 feet elevation of the reactor buildings are not used to filter the containment atmosphere under accident conditions and are not expected to experience significant heatup from iodine decay.
As discussed in Sections 5.14 and 5.15 of this report, we will require tM licensee to evaluate the fire hazard posed by charcoal filters on safe shutdown cables and equipment.
We will address the adequacy of fire protection for charcoal filters and nearby safe shutdown equipment ana cables in a supplement to this report after complet'on of the above-described licensee evaluations.
4.4.3 Breathing Equipment There are eight Scott " Air Paks" and eight " Bio-45" rebreathing units available for emergency breathing requirements at the plant.
Each of these units has one spare bottle.
The Scott anits are refilled from a four bottle cascado system which is supplied with large bottles of approved breathing air by a local vendor.
The " Bio-45" units are refilled from the plant oxygen bottle supply.
At present the emergency breathing supplies are not adequate for a severe long term fire.
The licenser. will provide additional emergency breathing capability so that the ccmplemeat of air breathing apparatus, spare bottles and recharge capability will meet the needs of 10 people for a period of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> at a usage rate of three 30-minute air bottles per person per hour.
We find that, subject to implementation of the above mod:fication, emergency breathing capability is adequate for plant cont 6 and manual fire fighting activities.
4.5 Floor Drains The turbine lube oil reservoirs and lube oil storage room are provided with curbs which drain to an uncerground concrete sump.
The combination of curb and sump capacities are adequate to prevent the spread of oil to other areas.
The present configuration of curos and drains in the screen house and diesel generator rooms is not adequate to prevent propagation of an oil fire involving fuel oil for the diesel-drivers cooling pumps, diesel-driven fire pump or diesel generators.
The licensee will provide additional curbs for the screen house and diesel generator rooms as discussed in Sections 5.19 and 5.17, resoectively.
These modifications will result in an adequate containment system for fuel oil leakage in the diesel generator rooms but we will require further modifications for the screenhouse as discussed in Section 5.19.6.
4-11
The hydrogen seal oil units are not presently curbed.
The licensee has proposed to extend the floor trench around the seal oil units to carry off any leakage.
The licensee has not adequately described the flow path in the proposed trench nor the potential impact of an oil fire on safety-related systems.
The licensee has committed to verify that a fire involving seal oil leakage into the proposed trench will not pose a hazard to redundant safe shutdown systems.
Details will be provided describing the flow path of the oil and potential impact on safety systems in other fire areas.
The adequacy of the drains to remove fire suppression water is addressed in Section 4.3.1(7) of this report.
We will address the adequacy of the curbs and drains to contain combustible liquid spills in a supplement to this report after review of the above-described licensee's verification.
4.6 Lighting Systems In addition to normal plant lighting, an emergency lighting system is provided throughout the plant except for the control unit.
This emergency lighting system is supplied from the units 120/208-volt minimum interruptible bus with the automatic trcnsfer to one of the 125 vol. batteries upon failure of the a-c supply.
Normal lighting in the control room consists of two independent lighting systems; each feed from a 480 volt safeguard bus.
Hallways, the control room, and other areas important to operation are also provided with wet cell fixed sealed beam units.
Sealed beam battery lanterns are also provided in the emergency locker, shift supervisor's office and the maintenance shop office.
To further facilitate access to remote areas of the plant by the fire brigade, the licensee will provide two battery powered portable handlights in the centralized fire equipment storage locker.
We find that the existing lighting system, when augmented by the portable handlights to b.
provided in the centralized fire equipment storage locker, satisfies the objectives identified in Section 2.2 of this report, and is, therefore, acceptable.
4.7 Communications Systems The licensee relies primarily on the fixed public addressed system, powered by the uninterrupted a-c system, and a separate branch exchange (PABX) telephone system, powered by a separate battery, for normal communication.
These systems may also be used for emergency communications.
In addition.
a sound powered telephone system is installed with telephone jacks throughout the plant.
Head sets are stored in the control room, the auxiliary building, and at the hot shutdown panels, located in the turbine building.
Due to 4-12 b hb2
loud background noise, and the potential for fire damage, such fixed systems 6 e not always effective for fire fighting operations.
To overome these problems, the licensee has provided two a-c powered receiver /
transmitters, one of each is located in the control room and the guard house.
Five handsets are stored in the control room shift supervisor's office and are available for use by the fire brigade.
We find that the communications provided to coordinate fire tighting and safe shutdown activities satisfy the objectives identified in Section 2.2 of this report, and are, therefore, acceptable.
4.8 Electrical Cables The cable insulation used for nower, control and instrumentation circuits consist primarily of ethylene propylene rubber, polyethy!er'e or cross-linked polyethylene insulation with neoprene, polyvinyl chloride ar asbestos brcid jacket.
All power cables are metallic armor enclosed.
The flame test standard for cables, Institute of Electrical and Electronics Engineers (IEEE) Standard 383-1974 was not in effect at the time these cables were purchased and installed.
However, the cables were tested using an oil soaked rag flame test.
The licensee has stated that the majority of the cable used in the plant have subsequently been qualified to IEEE 383-1974 by che manufacturer.
Control cables also meet IPLEA test requirements.
Based upon a review of the electrical cable insulation presented by ;he licensee, we find that all cable insulation material made of organi; material must be considered combustible in the configuration and quantity in which it is installed in the Prairie Island plant.
Therefore, in reviewing the adequacy of the fire protection system for the various plant areas discussed in Section 5.0, we have assumed that a fire could propagate between cables that were not adequately separated and/or coated with flame retardant matarials.
Appropriate automatic and/or manual fire suppression systems will be provided as discussed in Section 5.0 for all areas where large concentrations of cables exist.
4.9 Fire Barrier Penetrations Fire barriers such as wells, floors and ceilings are penetrated by ventila-tion ducts, electrical raceways, mechanical piping systems and doors.
A discussion of the adequacy of plant design features which are intended to prevent fires from propagating across barriers via these types of penetra-tions is provided below.
4.9.1 Electrical Cable and Conduit 3enetrations Seals have been installed in all electrical cable tray and conduit penetra-tions of areas containing safety-related equipment and systems.
These seals consist of a one-inch thick silicnne covering on cables and thermal insulction wool packing with an outer covering of a flame retardant coating.
The seals, however, have not been tested by the licensee to verify their effectiveness as a fire barrier.
The licensee has investigated seal designs that have been adequately qualified in accordance with ASTM E-119 4-13 f}bh 053
as a 3-hour barrier, and has committed to use such qualified seals for any new penetration seals which are Installed in the future or for seals which must be replaced.
The licensee will demonstrate by test that the electrical penetration seals presently installed in the plant have a rating equivalent to the fire severity present on either side of the seal.
The seals will be qualified by test by an indeperdent testing laboratory in accordance with ASTM E-119 under conditions and to criteria acceptable to the staff.
We will address the adequacy of the electric penetration seals in a supple-ment to this report after review of the licensee's demonstration of the adequacy of existing electrical penetration seals.
4.9.2 Fire Doors Doorways leading to safety-related areas are equipped with fire doors.
Generally, these doors are rated as 3-hour doors.
In a few cases, fire-rated doors have a lesser rating than 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> but one that is still commen-surate with the fire loading in the area.
The licensee does not have a controlled procedure for a semi-annual inspec-tion of fire doors to assure proper working order of these doors.
Fire doors between battery rooms and between diesel rooms are of the self-closing type and are electrically supervised with alarms in the control room.
The fire doors that separate the auxiliary feed pump rooms are of the swing shut type which are actuated by smoke detectors.
There are also a number of locked fire doors leading to safeguards areas in the turbine building.
These locked fire doors are not inspected weekly to verify that tt.e doors are in the closed position.
Rather, the licensee relies on checks by plant operators while on their normal rounds of inspections.
The cable spreading and relay rooms is protected by an automatic carbon dioxide suppression system.
The room has self-closing /'.ocking fire-rated doors with an automatic release feature that is energized during actuation of the suppression system.
The doors are fitted with electrical release mechanisms that open upon actuation of the suppression system.
The present system of fire door insoections does not provide adequate assurance that fire doors will te in the proper working order or will be positioned properly.
The licensee has committed to implement the following inspection frequency:
(1) Fire doors will be inspected semi-annually to verify that self-closing methanisms and latches are in good working order.
(2) Fire doors that are locked closed will be inspected weekly to verify that the doors are in the closed position.
(3) Fire doors with automatic release mechanisms will be inspected monthly to verify that doorways are free of obstructions.
4-14 l } h y y' tj j
(4) Fire doors with self-closing mechanisms will be inspected daily to verify that they are in the closed position.
The placement and location of fire doors in barriers comply with the provisions of Appendix A to BTP 9.5-1.
We find that, subject to implemen-tation of the above described fire door inspections, fire doors satisfy the objectives identified in Section 2.2 of this report and are, therefore, acceptable.
4.9.3
- entilation Doct and Pipe Penetrations Fire barriers for areas containing safety-related equ oment contain both i
sealed and unsealed pipe and ventilation duct penetrations and some venti-lation ducts without fire-rated dampers.
The licensee's commitments to provide fire-rated dampers at certain ventilation duct locations are included in the separate discussions for each area in Section 5.0 of tnis report.
However, in a number of areas the licensee has not adequately addressed the location of unprotected ventilation paths for fire zones that contain safety-related systems and equipment.
As a part of the ongoing revision to the fire hazard analysis, the licensee will verify that all fire zones that contain safety-related systems and equipment do not contain unprotected ventilation paths.
If unprotected ventilation paths are found to exist, the licensee will provide fire dampers of a rating commensurate with the fire load on either side of the boundary, At the boundaries between the turbine building and safety-related areas, the licensee will install 3-hour fire-rated dampers.
The penetration seals in piping and ventilation duct penetrations of fire barriers were sealed using materials and methods which have not been tested by the licensee to verify their effectiveness as a fire barrier.
The licensee has submitted descriptive material giving some details of these penetration seal-, and has stated that a number of seals contain polyurethane foam whicn is used to seal the voids in the seals.
All seals containing this polyurethane foam have been sealed with a minimum thickness coating of 1/4-inch thermal insulating mastic.
The present-day method of installing penetration seals utilizes other thermal insulation in place of polyurethane foam to fill voids.
The licensee's commitment to seal the open penetrations or to upgrade the existing penetration seals in areas of high combustible loading are included in a separate discussion for each area in Section 5.0 of this report.
The licensee has investigated seal designs that have been adequately qualified and states that they will be used for new penetration seals which are installed in the future or for seals which must be replaced.
Experience has shown that some types of urethane foam are combustible and even fire retardant types will burn when exposed to a high enough tempera-ture.
Existing penetration seals incorporating polyurethane foam will be replaced with a type of seal that does not contain this material or the seals will be suitably modified and the seal design tested to verify its effectiveness as a fire barrier in spite of the foam material.
The licensee will demonstrate by test that mechanical penetration seals presently 4-15 i165 055
installed in the plant have a rating equivalent to the fire severity present on either side of the seal.
In these cases, and in those cases where the licensee will install new seals, the seals will be qualified by test by an independent testing laboratory in accordance with ASTM E-119 under conditions and to criteria acceptable to the staff.
We will address the adequacy of mechanical penetration seals and ventila-tion duct dampers in a supplement to this report after review of the licensee's verifications of the adequacy of existing mechanical penetra-tien seals and ventilation duct dampers.
4.10 Separation Criteria The current NRC staff guidan provided in Regulatory Guide 1.75, " Physical Independence of Electric Syst,'s," was not available at the time the Prairie Island plant was designed and constructed.
Nevertheless, the licensee was cognizant of the need to provi's electrical sepa ation for redundant divisions of electrical equipment.
In most cases, redundant safety-related system components (e.g., pump, diesel generators) are separated by distance or barriers.
In general, cable trays, each containing an opposite redundant division of safety-related syrtems and reactor protection channels, are separated by at least three feet horizontally and by at least three feet vertically.
The spacing between any reactor protection system channel and cables of other safety-related systems is a minimum of three feet hori-zontally and 15 inches vt tically.
The licensee has proposed certain modifications to improve physical separation of redundant safety systems.
These proposed modifications are discussed in Section 5.0 of this report.
However, Lnere are a number of fire zones in the plant where redundant divisions of systems required for safe shutdown are located in close proximity.
The actual separation between these redundant divisions has not been adequately documented OV the licensee.
Nor has the licensee demonstrated that the separation provided is sufficient, in itself, to protect against a single fire.
The licensee has committed to provide documentation of thr actual separation that exists between shutdown systems in those zones where redundant shut-down systems are located.
The licensee will also reevaluate all fire zones in the plant in which these redundant shutdown systems are located with regard to safe shutdown requirements of equipment and cables as discussed in Section 4.1 cf this report.
We will address the adequacy of separation between redundant safe shutdown systems in a supplement to this report after completion of tr.9 above described licensee documentation and reevaluation.
4.11 Fire Barriers Most of the barriers in the plant are concrete with 3-hour fire resistance.
However, not all fire areas are completely enclosed within 3-hour ba riers.
In these cases, the overall fire resistance of the ba ier is degraded by open or inadequate penetration seals, inadequate door-open doorways or open hatches.
In some locations the licensee will upt ide the penetration 4-16 bb Obb
seal or door to contain the effects of a potential fire.
In other fire areas where the barrier cannot be upgraded, modifications to tne fire protection system will be made to prevent spread of fire to adjacent fire areas.
These modifications are discussed in Section 5.0 of this report.
We find that, subject to implementation of the modifications described in Section 5.0 of this report, fire barriers in the plant will be adequate to contain fires and are, therefore, acceptable.
4.12 Access and Egress All safety-related areas except the reactor containment buildings are reasonably accessible for manual fire fighting.
During normal operation, the containment is sealed; access is provided through a personnel airlock.
Special procedures must be followed te gain access, increasing the response time of the fire brigade.
The acceptability of the fire protection program inside containment will be addressed in a supplement to this report.
4.13 Toxic and Corrosive Combustion Products The products of combustion of many polymers are toxic to humans and corro-sive to metals.
Prompt five detection and extinguishment are relied on to minimize the quantity of such products.
Additionally, means for smoke removal are provided as discussed in Section 4.4 of this report.
The fire brigade will also be provided with and trained in the use of emergency breathing apparatus or manually fighting fires involving such materials.
We find that, subject to implementation of the modifications described in this report, the measures taken to minimize the development of toxic and corrosive combustion products satisfy the objectives identified in Section 2.2 of this report and are, therefore, acceptaole.
4.14 Nonsafety-Related Areas We have evaluated the separation, by distance and/or barriers, between safety-related and nonsafety-related areas.
Upon impleinentation cf the modifications described in Section 3.0 of this report, a fire in a nonsafety-related area will not adversely affect the ability to safely shut down the plant.
4.15 Instrument Air Five air compressors are available for safe shutdown operations.
Instru-ment air is required for residual heat removal system flow control for safe cold shutaown.
The other requirements for instrument air for safe hot and cold shutdown have not been adequately described by the licensee.
Two instrument air compressors are located in one of the auxiliary feed-water pump rooms (fire area 32), and one instrument air compressoi is located in the other auxiliary feedwater pump room (fire area 31).
The other two air compressors are associated with the condensate polishing system but are interconnected with the instrument air system.
The two condensate polishing air compressors are located in the Unit 2 side of the turbine building at elevation 695 feei 4-17 1165 057
The licensee will evaluate all the requirements for instrument air for hot and cold shutdown and will verify that an adequate air supply will be available for safe shutdown in the event of a postulated fire in all plant areas.
The analysis will consider damage to compressors as well as the routing of instrument air lines, compressor cables and the location of air operated valves.
We will address the adequacy of the fire protection for the instrument air system in a supplement to this report after completion of the above described licensee evaluation.
I166 058 4-18
5.0 EVALUATION OF SPECIFIC PLANT AREAS 5.1 Control Room Complex 5.1.1 Safety-Related Equipment The control room complex which contains control and systems for both units is located at an elevation of 735 feet adjacent to the turbine building between the turbine building and the auxiliary building.
The complex consists of the control room, the records room, and the instrument labora-tory.
A small supervisor's office is located in the center of the control room.
The walls, floor and ceiling of the control room are of fire resistant construction and rated at three hours.
The two doors leading to the control room from the turbine building are 3-hour fire-rated doors and the separate entrances to the control room from the records room and the instrument lab have 1 -hour fire rated doors.
The wall and ceiling covering in the control room has a flame spread rating of 25, classified by UL Number R5583U8.15 and meets NFPA Code 90A.
The records room and the instrument laboratory are enclosed in concrete and concrete block walls, ceilings and floors varying in thickness between 8 and 24 inches.
The entrances to the records room and the instrument laboratory contain doors having a fire rating of 1 -hours.
The control room ceiling is penetrated by return and supply air ducts which do not contain fire dampers.
The contral room contains safety-related cables.
Certain of these cables would be required for safe shutdown.
However, the records room and the instrument laboratory contain no cables required for safe shutdown.
Safety-related equipment in the control room consists of the main control board and console and various cabinets, panels and racks for control and instrumentation.
5.1.2 Combustibles The combustibles in the area consist of electrical cable insulation and electrical components in panels and consoles and moderate amounts of paper such as log books, drawings and operating manuals.
All wooden furniture previously located in the main control room has been removed.
The records room contains paper in cabinets and an electric range for cooking.
This stove contains a vent hood which does not contain a grease filter.
5.1.3 Consequences if No Fire Suppression Any unsuppressed fire in a control room cabinet has the potential for damaging significant amounts of safety-related equipment including systems required for safe shutdown.
However, the cabinets and consoles are compart-mentalized to provide protection of redundant divisions.
Remote shutdown panels located in the auxiliary feedwater pump rooms may be used to shut down the plant in the event of damage to redundant shutdown systems in the control room or evacuation of the control room because of fire.
5-1166 059
5.1.4 Fire Protection Systems There are no automatic fire suppression systems in the control room or the instrument laboratory.
A wet pipe sprinkler system is provided in the fire extinguishers are located in the records room.
Four portable CO2 control room.
Fire extinguishers are located in the records room.
Hose stations are located near the control room complex in the turbine building.
Ionization detectors are mounted in the ceiling and in the false floor of the control room and in the records room and the instrument laboratory.
An emergency locker in the records room contains self-contained breathing units for control room personnel.
5.1.5 Adequacy of Fire Protection Redundant shutdown systems enter different panels which are separated by steel barriers.
There are seals in electrical penetrations which enter the control room.
The procedures for manually extinguishing small fires that might occur in the false floors of the control room is adequate.
The light combustible loading under the false floor makes a large fire unlikely.
The ceiling and floor of the control room contain ducts without fire dampers which could allow smoke and hot gases to enter the control room due to a fire in adjacent areas.
The room contains a large number of electrical panels and cabinets that are susceptible to water damage.
In the event of a fire in the room, the use of a 1 -inch hose and nozzle may damage nearby safety-related equipment and circuits in cabinets not involved in the fire.
The fire doors leading to the records room and the instrument laboratory were found to be out of adjustment and did not close properly.
These doors have since been adjusted to remain closed when not in use.
The electric range hood does not contain a grease filter.
A fire in this hood could have hindered adequate control room operation.
Because combustible loading is light and the separation provided between redundant circuits is adequate, the prompt detection and manual suppression provided are considered satisfactory to control and suppress fires in this area.
5.1.6 Modifications The licensee has committed to the following modifications:
(1) The hood and ducts above the electric range will be provided with a grease filter.
A periodic cleaning program will be instituted for this filter.
(2) One-inch booster hoses with variable gallonage nozzles with shutoff will be provided at existing nearby hose stations to permit localized application of water for fire fighting.
The licensee has also committed to provide waterproof tarpaulins to be used to protect the relay cabinets from water damage at a centralized location.
5-2 l166 060
(3) Fire-rated dampers will be installed in the ventilation ducts which penetrate the main control room boundaries.
These dampers will have a rating equivalent to the combustible load in each adjacent area but will not have a rating less than 1-1/2 hours.
We find that, subject to the modifications described above, the fire protec-tion for the control room complex satisfias the objectives in Section 2.2 of this report and is, therefore, acceptable.
5.2 Cable Spreading and Relay Room 5.2.1 Safety-Related Equipment The cable spreading and relay room is located directly below the control room at an elevation of 715 feet.
Cables of redundant safety-related divisions for Unit 1 and Unit 2 are routed through the room.in open cable trays.
The room contains instrument racks, distribution panels and control and relay cabinets.
A large amount of cable congestion exists in the overhead space of the room.
The computer room is located in the center of the cable spreading and relay room and is enclosed in concrete and concrete block walls, floor and ceiling varying in thickness between 5.5 inches and 16 inches.
Two doors leading to the computer room are 3-hour rated fire doors.
Two doors that provide entrance to the cable spreading and relay room from the turbine building are also 3-hour rated fire doors.
Ventila-tion ducts that service the room contain automatically actuated fire dampers; however, at the boundary of the control room these ducts are not provided with dampers.
5.2.2
_Combustiblas The significant combustibles in this room consist of a large amount of cable insulation.
5.2.3 Consequences if No Fire Suppression Redundant divisions of safety related equipment and safe shutdown equipment served by cables in this room would be incapacitated by a major fire in this room.
5.2.4 Fire Protection Systems The cable spreading room is provided with an ionization smoke detection system with remote alarms in the control room.
An automatically actuated double shot total flooding carbon dioxide system is provided.
Portable fire extinguishers are also located in the room.
Hose stations are pro-vided near the entrances to the room.
5.2.5 Adequacy of Fire Protection Fire protection for the cable spreading and relay room is inadequate.
The cable spreading and relay room contains, in close proximity, cables of redundant systems of both Units 1 and 2 that are required for safe shutdown.
There is a heavy concentration of combustible cables, especially in the 5-3 l}bh Oh}
ceiling area of the room and access to this area is limited to the extent that manual suppression of the fire would be difficult.
The CO2 system may not be effective in suppressing a deep-seated fire and the spatial separation between redundant divisions of safe shutdown systems may not be sufficient to prevent an exposure fire from damaging both divisions.
With regard to tire protection for equipment and cables required for safe shutdown, the information provided by the licensee is not sufficient for us to determine the adequacy of fire protection.
The specific information required is discussed in Section 4.1 of this report.
The room contains a large number of electrical panels and cabinets that are susceptible to water damage.
In the event of a fire in the room the use of a 1 -inch hose and nozzle may damage nearby safety-related equipment and circuits in cabinets not involved in the fire.
5.2.6 Modifications The licensee has committed to:
(1) Provide one-inch booster hoses with variable gallonage nozzles with shutoff, at existing nearby hose stations to permit localized applica-tion of water for fire fighting.
The licensee has also committed to provide waterproof tarpaulins to be used to protect the relay cabinets from water damage at a centralized location.
(2) Install 3-hour fire-rated dampers or equivalent in ducts at the boundary of the room where the ducts enter from the control room.
The licensee has committed to provide an alternate shutdown capability that is independent of the cable spreading and relay room.
In conjunction with this commitmen'., the licensee will reevaluate the cable spreading and relay room with regard to safe shutdown requirements of equipment and cables located here as discussed in Section 4.1 of this report.
Verifi-cation will be provided that the fire protection system, as modified, provide adequate assurance that a fire in any room will not prevent safe hot and cold shutdown of both units.
The licensee will also verify that a fire in the cable spreading and relay room will not cause the types of spurious movement of components that would adversely affect the ability to shut down the plant.
We will address the adequacy of fire protection for the cable spreading and relay room in a supplement to this report after completion of the above described licensee evaluation.
5.3 Computer Room 5.3.1 Safety-Related Equipment The computer room is located in the center of the cable spreading and relay room and is separated from this room by concrete block valls and a concrete ceiling.
Two doors leading to the computer room are 3-hour fire-rated doors.
Safety-related cables and the cables for the 5-4 1iM 062
nonsafety-related cooling water pumps of one division of each unit are located in the room.
5.3.2 Combustibles The computer room contains combustible cable insulation and computer paper.
- 5. 3. 3 Consequences if No Fire Suppression An unsuppressed fire in this room would damage safety-related cables and would incapacitate one division of nonsafety-related cooling water pumps of each unit.
However, plant shutdown could be accomolished using the safety related cooling water pumps.
5.3.4 Fire Suppression Systems The computer room is provided with an ionization smoke detection system with remote alarms in the control room.
An automatically actuated total flooding carbon dioxide system is provided that is actuated by thermal detectors.
A pressurized water extinguisher is located within the computer room.
Dry chemical and C0 extinguishers and a hose station are located 2
nearby.
5.3.5 Adequacy of Fire Protection The existing detection and suppression equipment would be adequate to control a fire in this room.
5.3.6 Modifications We find that fire protection for the computer room satisfies the objec-tives identified in Section 2.2 of this report and is, therefore, acceptable.
- 5. 4 Units 1 & 2 4160-Volt Safeguards Switchgear Rooms 5.4.1 Safety-Related Equipment Four 4160-volt safeguards switchgear rooms, two for each unit, are located in the midsection of the turbine building at an elevation of 715 feet.
Each room contains one redundant division of 4160-volt safety-related switchgear and associated cables.
Each room is enclosed in concrete walls, ceilings and floors which vary in thickness between 10 and 18 inches.
Doors leading to the rooms and between Unit 1 and Unit 2 rooms are 3-hour fire rated.
The ventilation paths to these rooms do not have fire rated dampers.
5.4.2 Combustibles The switchgear rooms contain combustible electrical insulation in trays, conduit and inside electrical cabinets.
5.4.3 Consequences if No Fire Suppression An unsuppressed fire in any 4160-volt switchgear room would result in a loss of single division of 4160-volt switchgear which supplies emergency power for safety related and safe shutdown equipment.
An unsuppressed fire in the adjacent areas of the turbine building could cause loss of redundant safety-related and shutdown systems because of the paths provided in unprotected ventilation ducts.
5.4.4 Fire Protection Systems There are no automatic fire suppression systems provided for the 4160-volt safeguards switchgear rooms.
Ionizatica detectors are installed in each room with remote alarms in the control room.
A hose station is located near the entrance to each room.
In addition, C02 fire extinguishers are provided in each room.
5.4.5 Adequacy of Fire Protection The unprotected ventilation ducts provide pathways by which redundant 4160-volt switchgear may be damaged by a single fire.
Because of the light combustible loading in the rooms, the present detection and manual suppres-sion provided is adequate to contain and extinguish a fire within any single room.
With regard to fire protection for equipment and cables required for safe shutdown, the information provided by the licensee is not sufficient for us to determine the adequacy of fire protection.
The specific information required is discussed in Section 4.1 of this report.
5.4.6 Modifications The licensee has committed to provide 3-hour fire dampers in the ventila-tion ducts leading to the 4160-volt safeguards switchgear rooms.
We find that the above modification represents an improvement to the fire protection of the 4160-volt safeguards switchgear rooms.
We, therefore, conclude that the licensee should proceed with implementing the modification.
The licensee will reevaluate the 4160-volt safeguards switchgear rooms with regard to safe shutdown requirements of equipment and cables located here as discussed in Section 4.1 of this report.
Verification will be provided that the fire protection system, as modified, provides adeauate assurance that a fire in any room will not prevent hot or cold shutdown of either unit.
We will address the adequacy of fire protection for the 4160-volt safeguards switchgear rooms in a supplement to this report after completion of the above described licensee evaluation.
1166 064 5-6
5.5 Uqits 1 & 2 480-Volt Safeguards Switchgear Rooms 5.5.1 3afety-Related Equipment The 480-volt safeguards switchgear rooms are located at the 735-foot eleva-tion adjacent to either side of the control room complex.
Two rooms for Unit 1 are located at the eastern end of the control room complex.
The Unit 2 rooms are located at the western end of the control room complex.
These rooms each contain redundant 480-volt switchgear for their respective units.
The boundaries that surround each room consist of concrete or concrete block varying in thickness between 8 and 18 inches.
Three-hour fire-rated doors provide entry into each room.
5.5.2 Combustibles The switchgear rooms contain electrical cable insulation in trays and inside electrical cabinets.
5.5.3 Consequences if No Fire Suppression An unsuppressed fire in any 480-volt switchgear room would result in a loss of a single division of 480-volt switchgear which supplied emergency power for safety-related equipment.
5.5.4 Fire Protection Systems There are no automatic fire suppression systems provided for the 480-volt safeguard switchgear rooms.
Ionization detectors are installed in each room with remote alarms in the control rocm.
A hose station is located in the turbine building in the near vicinity of the 480-volt switchgear rooms fire extinguishers are provided in each for each unit.
In addition, C02 room.
5.5.5 Adequacy of Fire Protection Because of the light combustible loading in each room, the present detection and manual suppression provided is adequate to contain and extinguish a fire within any of these rooms.
The rooms contain electrical panels and cabinets that are susceptible to water damage.
In the event of a fire in the room, the use of a 1 -inch hose and nozzle may damage nearby safety-related equipment and circuits in cabinets not involved in the fire.
With regard to fire protection for equipment and cables required for safe shutdown, the information provided by the licensee is not sufficient for us to determine the adequacy of fire protection.
The specific information required is discussed in Section 4.1 of this report.
5.5.6 Modifications The licensee has committed to p* ovide one-inch booster hoses with variable gallonage nozzles, with shutoff, at existing nearby hose stations to permit localized application of water for fire fighting.
The licensee has also committed to provide waterproof tarpaulins to be used to protect the relay cabinets from water damage et a centralized location.
5-7 1166 fl65
We find that the above modification represents an Sprovement to the fire protection of the 480-volt safeguards switchge.'r rooms.
We, therefore, conclude that the licensee should proceed with implementing the modifications.
Implementation of tne above listed modifications does not provide assurance that redundant safe shutdown cables, and electrical equipment will not be damaged by fires.
The licensee will reevaluate the 480-volt safeguards switchgear rooms with regard to safe shutdown requirements of equipment and cables located here as discussed in Section 4.1 of this report.
Verification will be provided that a postulated fire will not prevent safe hot and cold shutdown of both units.
We will address the adequacy of fire protection for the 480-volt safeguards switchgear rooms in a supplement to this report after completion of the above described licensee evaluation.
5.6 Units 1 & 2 4160-Volt Normal Switchgear Rooms 5.6.1 Safety-Related Equipment Two 4160-volt normal switchgear rooms, one for each unit, are located in the midsection of the turbine building at an elevation of 715 feet.
Each room contains a small number of electrical cables for safety-related equipment.
Each room is enclosed in concrete walls, ceilings and floor which vary in thickness from 5.5 inches to 18 inches.
Doors leading to the rooms are 3-hour fire-rated.
5.6.2 Combustibles The switchgear rooms contain combustible electrical cable insulation in trays, conduit and electrical cabinets.
5.6.3 Consequences if No Fire Suppression An unsuppressed fire in either room would damage safety-related cables located in the room and would also damage cables which serve the motor driven cooling water pumps of both units.
5.6.4 Fire Protection Systems There are no automatic fire suppression systems provided for the 4160-volt normal switchgear rooms.
Ionization detectors are installed in each room with remote alarms in the control room.
A hose station is located near the entrance to each room.
Portable C0 fire extinguishers are located in 2
each room.
5.6.5 Adequacy of Fire Protection With regara to fire protectio 1 for cables required for safe shutdown, the information provided by the 'icensee is not sufficient for us to determine the adequacy of fire protection.
The specific information required is discussed in Section 4.1 of this report.
5-8 l } 66 ()66
Because of the light combustible loading in the rooms, the present fire detection and manuel suppression are adequate to contain and extinguish a fire within any sii. ie room.
5.6.6 Modifications The licensee has not proposed modifications to the 4160-volt normal switch-gear rooms.
The licensee will reevaluate the 4160-volt normal switchgear rooms with regard to safe shutdown requirements as discussed in Section 4.1 of this report.
Verification will be provided that a fire in either room will not prevent safe hot or cold shutdown of both units.
We will address the adequacy of fire protection for che 4160-volt normal switchgear rooms in a supplement to this report after completion of the above described licensee evaluation.
5.7 Units 1 & 2 480-Volt Normal Switchgear Rooms 5.7.1 Safety-Related Equipment Two 480-volt normal switchgear rooms, one for each unit, are located in the midsection of the turbine building at an elevation of 695 feet.
Each room contains a small number of electrical cables for safety-related equipment.
Each room is enclosed in concrete walls, ceilings and floors which vary in thickness from 8 inches to 24 inches.
Doors leading to the rooms are 3-hour fire-rated.
5.7.2 Combustibles The switchgear rooms contain combustible electrical cable insulation in trays, conduit and electrical cabinetc.
5.7.3 Consequences if No Fire Suppressicn An unsuppressed fire in either room would damage safety-related cables located in the room and would also damage cables which servic? the motor-driven cooling water pumps of both units.
5.7.4 Fire Protection Systems There are no automatic fire suppression systems provided in the 480-volt normal switchgear rooms.
Ionization detectors are installed in each room with remote alarms in the control room.
A hose station is located near the entrance to each room.
Portable CO fire extinguishers are located in 2
each room.
5.7.5 Adequacy of fire Protection With regard to fire protection for cables required for safe shutdown, the information provided by the licensee is not sufficient for us to determine the adequacy of fire protection.
The specific information required is discussed in Section 4.1 of this report.
5-9 llbh Ob[
Because of the light combustible loading in the rooms, the present fire detection and manual suppression are adequate to contain and extinguish a fire within any single room.
5.7.6 Modifications The licensee has not proposed modifications to the 480-volt normal switch-gear rooms.
The licensee will reevaluate the 480-volt normal switchgear rooms with regard to safe shutdown requirements as discussed in Section 4.1 of this report.
Verification will be provided that a fire in either room will not prevent safe hot and cold shutdown of both units.
'4c will address the adequacy of fire protection for the 480-volt normal switchgear rooms in a supplement to this report after completion of the above described licensee evaluation.
5.8 Units 1 & 2 Rod Drive Control and Switchgear Rooms 5.8.1 Safety-Related Equipment The rod arive control and switchgear rooms are located at the 735-foot elevation adjacent to each respective unit's 480-volt safeguards switchgear Each room contains nonsafety-related switchgear and safety-related room.
equipment and cables including pressurizer heater switchgear, and motor cnrtrol centers, rod drive motor generator sets and reactor trip breakers.
The rooms are enclosed in concrete and concrete block that vary in thick-ness between 8 and 12 inches.
Each room contains two entrances protected by 3-hour firc-rated doors.
5.8.2 Combustibles The rooms contain electrical cable insulation in trays and inside electrical cabinets.
5.1. 3 Consequences if No Fire Suopression An unsuppressed fire in either room would result in the loss of some safety-related equipment such as the pressurizer heaters and the rod drive niotor generator sets.
5.8.4 Fire Protection Systems There are no automatic fire suppression systems provided for the rod drive control and switchgear rooms.
Ionization detectors are installed in each room with local alarms and remote alarms in the control raom.
A hose station is located in the turbine tuilding in the near vicinity of each fire extinghishers are provided in each room.
In addition, portable CO2 room.
lIh 5-10
5.8.5 Adequacy of Fire Protectior!
Because of the light combustible loading in each room the present detection and manual suppression provided is adequate to contain and extinguish a fire within the room.
The room contains a large rumber of electrical panels and cabinets that are susceptible to water damage.
In the event of a fire in the rooms the use of a 1 -inch hose and nozzle may damage nearby safety-related equipment and circuits in cabinets not involved in the fire.
With regard to the fire protection for equipment and cables required for safe shutdown, the information provided by the licensee is not sufficient for us to determine the adequacy of fire protection.
The specific informa-tion required is discussed in Section 4.1 of this report.
5.8.6 Modifications The licensee has committed to provide one-inch booster hoses with variable gallonage nozzles with shutoff at existing nearby hose stations to permit localized application of water for fire fighting.
The licensee has also committed to provide waterproof tarpaulins to be used to protect the relay cabinets from water damage at a centralized location.
We find that the above modification represents an improvement to the fire protection of the rod drive control and switchgear rooms.
We, therefore, conclude that the licensee should proceed with implementing the modifications.
Impler..entation of the above listed modification does not provide assurance that redundant safe shutdown cables and electrical equipment will not be damaged by fires.
We will require the licensee to demonstrate that safe hot and cold shutdown can be achieved for any postulated fire in these rooms as discussed in Section 4.1 of this report.
5.9 Battery Room Complex 5.9.1 Safety-Related Equipment The battery room complex is located in the midsection of the turbine building at an elevation of 695 feet.
The complex consists of four battery rooms, two for each unit.
Battery rooms 11 and 12 each contain one 125-volt battery and battery charger which serve Unit 1 requirements.
Battery rooms 21 and 22 serve Unit 2 requirements and each also contains a 125-volt battery and charger.
Each room is enclosed in walls, floors and ceiling having a fire resistance of three hours.
Entry doors to each room and between rooms have a 3-hour fire resistance rating.
The doors between battery rooms are counterweighted gravity sliding Class "A" fire doors provided with dual fusible links.
Fire dampers are not provided in the ventilation ducts serving battery rooms 21 and 22.
I166 069 5-11
5.9.2 Combustibles Combustible material in each room consists of battery cases and a small amour.t of electrical cable insulation, much of it in conduit.
Hydrogen buildup is precluded by operation of two separate exhaust systems. The fans of one system are powered from the safeguards bus and continue opera-tion following a power failure.
Fan operation is verified twice per shift.
5.9.3 Consecuences if No Fire Suppression An unsuppresed fire in any battery room would cause a loss of one of the 125-volt batteries, but would not affect the redundant battery or the batteries of the other unit.
5.9.4 Fire Suppression Systems Automatic detection with alarms in the control room is provided.
Portable fire extinguishers are available and 1 -inch fire hose stations are access-ible to the room.
5.9.5 Aaequacy of Fire Protection The unprotected ventilation ducts leading to the Unit 2 battery rooms provide a path by which redundant systems could be af'iected by a single fire.
In view of the limited quantity of combustibles in these rooms, we conclude that the detection and suppression provided are adequate to detect ana extinguish fires in these rooms and provided the integrity of the boundary is sustained, to prevent involvement of redundant safe shutdown equipment.
5.9.6 Modifications The licensee has committed to provide 3-hour rated dampers at the boundaries of these rooms.
We find that, subject to the above described modification, the fire protec-tion for the battery room complex satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
5.10 Auxiliary Feedwater Pump, Instrument Air and Hot Shutdown Panel Rooms 5.10.1 Safety-Related Equipment Two auxiliary feed pump, instrument air and hot shutdown panel rooms are located in the midsection of the turbine building at an elevation of 695 feet.
Each room contains one train of auxiliary feed pump for both units, a hot shutdown panel and an instrument air compressor.
A significant amount of safety-related cables for redundant shutdown systems of both units are located in each room.
The walls, floor and ceiling of each room have a fire resistance of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.
Two 3-hour rated swing fire doors separate the rooms from the east and west ends of the turbine building.
A rolling steel 3-hour rated fire door actuated by a fusible link is provided 5-12 1166 070
between the two rooms.
However, an unprotected pipe trench passes under this door.
Ventilation supply ducts to these rooms are provided with fire dampers; return ducts do not contain fire dampers.
Cable penetrations are sealed.
All electrical circuits required for s,fe shutdown are contained a
in waterproof cabinets.
5.10.2 Combustibles The combustibles in the rooms consist of a small amount of lube oil (43 gallons) enclosed within the auxiliary feed pump housing and gear box and air compressors.
Additional combustible material in the form of electrical cable insulation is present.
5.10.3 Consequences if No Fire Suppression An unsuppressed fire in either room would damage safety-related equipment and cables for redundant systems for both units required for safe shutdown.
In addition, an unsuppressed fire has the potential of spreading via the unprotected pipe trench to the o*,her auxiliary feed pump room.
The open trench that runs from the turbine building through each room provides a pathway by which a fire in the turbine building could spread to either or both auxiliary feedwater pump rooms.
However, the slope of the trench will direct the flow of combustible liquids accumulating in the turbine building away from the auxiliary feedwater pump rooms.
5.10.4 Fire Protection Systems An automatic fire detection system with remote alarms in the control room is provided in each room.
A thermally actuated wet pipe sprinkler is installed in each room.
Portable fire extinguishers are available and 1 -inch fire hose stations are accessible to the rooms from the turbine building.
5.10.5 Adequacy of Fire Protection The detection system should provide early warning of a fire in these rooms.
The automatic suppression system should limit the damage but because of the configuration of the room this fire protection is not adequate.
A fire in either of these rooms could damage redundant shutdown systems of both units.
The unprotected pipe trench which passes through these rooms from the turbine building provides a pathway by which both rooms could be affected by a single fire.
With regard to fire protection for equipment and cables required for safe shutdown, the information provided by the licensee is not sufficient for us to determine the adequacy of fire protection.
The specific information required is discussed in Section 4.1 of this report.
llbd O[l 5-13
5.10.6 Modifications The licensee has committed to the following modifications:
(1) A concrete fire barrier will be placed in the pipe trench that passes through the auxiliary feedwater pump rooms at the boundary between the two rooms.
The existing grating will be notched and a 1/4-inch thick checkered floor plate will be tack welded in pla.e to provide resistance to buckling.
(2) Fire-rated dampers (3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> or equivalent) will be installed in all return ventilation ducts that penetrate the boundaries of the rooms.
We find that tha above moc'ifications represent an improvement to the fire protection of the auxiliary feedwater pump, instrument air and hot shutdowr, panel room. We, therefore, conclude that the licensee should proceed with implementing the modifications.
The licensee will reevaluate these rooms with regard to safe shutdown requirements of equipment and cables located here as discussed in Section 4.1 of this report.
Verification will be provided that the fire orotection system, as modified, provides adequate assurance that a fire in any room will not prevent safe bot and cold shutdown of both units.
We will address the adequacy of fire protection for the auxiliary feedwater pump, instrument air and hot shutdown panel rooms in a supplement to this report after review of the above described licensee's evaluation.
5.11 Auxiliary Building - Elevation 695 Feet 5.11.1 Safety-Related Equipment The central section cf the auxiliary building is located between the two containment buildings; two wings extend out from the central area and are bounded on two sides by the turbine building and on the otner by the containment.
Generally, support equipment for both units is located in the central section and equipment for a single unit is located in the wing adjacent to the unit's reactor containment.
The central section on this elevation of the auxiliary building is composed of two low level waste decay tank compartments, a decontamination area, holdup tank enclosures and an open area between the auxiliary buildings wings.
None of these areas, except the open area, contains safety-related equipment.
The open area contains the component cooling heat exchangers and redundant component cooling pumps for each unit.
One component cooling pump per unit is required for safe cold shutdown of the plant.
Cables for a Mundant safe shutdown systems of both units are located in the central corridor.
The wings of the auxiliary building at this elevation contain cables and equipment for redundant divisions of safe shutdown and safeguards equipment.
Redundant charging pumps, safety injection pumps, containment spray pumps l}bh O/2
and residual heat removal pumps for each unit are located in the wing adjacent to the unit that they serve.
However, cables for some of these systems are located in both wings.
A charging pump or a safety injection pump per unit is required for safe shutdown of the plant.
One residual heat removal pump per unit is required to bring the plant to safe cold shutdown.
The containment spray system is only required for loss-of-coolant accidents.
In addition to the above-named systems, there are pumps, valves, cables and electrical equipment for other safe shutdown systems in the side wings and connecting corridor at this elevation.
Not all of the cables for this equipment are confined to the wing for the unit that they serve.
Cables and equipment for the auxiliary feedwater system, pressurizer heaters, reactor coolant system instrumentation and the chemical and volume control system are located in the wings ar.d the connecting corridor.
5.11.2 Combustibles The side sections of the auxiliary building contain combustible cable insulation, some wood, and lube oil in the pumps.
A hydrogen pipeline and an oxygen pipeline enter the auxiliary building on the Unit I side, traverse the central corridor and part of the Unit 2 wing.
The corridor also contains cable insulation, solvents in cabinets in the workshop and miscellaneous transient combustibles and combustible storage.
A room in the Unit 2 wing is used for storage of some combustible clothing.
The decontamination area contains miscellaneous transient combustibles including used filter units.
The other compartments contain small amounts of cable insulation or miscellaneous combustibles.
5.11.3 Consequences if No Fire Suppression An unmitigated fire originating in either of the auxiliary building wings on this elevation or in the connecting corridor could propagate throughout these areas via the combustible cable pathways.
The resulting damage to cables and equipment associated with the charging system, safety injection system, auxiliary feedwater systen and component cooling water system could prevent safe hot shutdown of both units.
An unmitigated fire in these areas could damage the hydrogen and oxygen piping in the overhead, which would result in an increased fire load.
Not all of the pipe penetrations to the turbine building are adequately sealed; a fire in the turbine building could, therefore, endanger safe shutdown systems on this elevation of the auxiliary building.
A fire on this elevation of the auxiliary building would spread smoke and hot gases via unsealed pipe penetrations to the upper elevation of the building.
Open pipe penetrations between charging pump cubicles could permit damage to more than one pump.
A fire in either of the low level waste decay tank compartment or in the waste holdup tank enclosures would have no effect on safety-related equip-ment.
There are no safety-related cables or equipment in these compartments 5-15 32 l}b0 IJ [ 3
and the barriers are adequate to contain a fire involving the relatively minor amounts of combustibles.
The decontamination area is separated by barriers and distance from the safety-related portions of the auxiliary building.
A fire in this area would have no effect on safe shutdown capability of the plant.
Smoke and hot gases could propagate to the remainder of the auxiliary building via the large open hatchway in the ceiling of this area.
5.11.4 Fire Protection Systems Ionization smoke detectors are provided on all areas of this elevation except for one of the low level waste decay tank areas.
Thermal detectors are provided in addition to the smoke detectors in the holdup tank area.
A smoke detector is provided for each of the residual heat removal pumps which are located in separate pits below this elevation.
Hose stations and portable extinguishers are located throughout this elevation for manual fire fighting.
Fixed automatic sprinkler systems are provided under the stairs in the side sections.
The storage compartment in the Unit 2 wing is protected by a wet pipe sprinkler system.
5.11.5 Adequacy of Fire Protection The location of detectors and fire hose stations is adequate for early warning of fires and to support manual fire fighting activities on this elevation of the auxiliary building.
The lack of fire detectors in one of the low level waste tank compartments is not a concern due to the lack of combustible materials in this area and the protection afforded safety-related equipment by the barriers enclosing the area.
It is expected that manual suppression activities would be adequate to prevent damage to redundant safety injection, residual heat removal, containment spray and component cooling pumps.
A fire i1 a charging pump cubicle could spread to the other charging pumps for a single reactor unit via unsealed pipe penetrations in the barriers between pumps.
- However, damage to all charging pumps would not prevent safe shutdown since one of the safety injection pumps could perform the makeup and boration functions of the charging pumps for safe shutcown.
The licensee has not adequately described the separation between redundant divisions of safe shutdown cables, electrical equipment and valves to permit an evaluation of the adequacy of the fire protection afforded these components.
Safe shutdown may be prevented by damage to redundant divisions of the systems whose cables are located on this elevation.
The licensee has provided an analysis to show that the flow rates from the hydrogen pipe would not result in an explosive mixture because of the dilution from ventilation on this elevation.
The hydrogen flow is auto-matically isolated on high flow from a pipe leak.
The analysis did not address the possibility for local buildup of hydrogen above the explosive concentration limit, nor did it address the possibility for damage to 5-16 1166 074
safety related cables from a fire at the leakage site on the hydrogen pipe.
The separation between the pipe and safety-related cables was not described.
5.11.6 Modifications The licensee has proposed the following modifications to improve the fire protection for elevation 695 feet of the auxiliary building.
(1) Unsealed or inadequately sealed penetrations in the auxiliary building walls shared with the turbine building and the storage area (fire area 66) will be sealed, or existing seals upgraded as necessary to provide seals with a 3-hour fire rating.
(2) Pipe penetrations in the walls between charging pump cubicles will be provided with seals with a fire rating equivalent to the fire loading on both sides of the barrier.
(3) All combustible storage in safety-related areas will be removed except for that in approved fire rated storage cabinets.
(4) Trash centainers in all safety-related areas of the plant will be replaced with metal containers with metal swing top lids.
(5) All lumber and wooden items in all safety-related areas of the plant will be replaced with pressure treated fire retardant lumber or coated with a penetrating fire retardant, that has good abrasion resistance.
We find that the above listed modifications represent a significant improve-ment to the fire protection for this elevation of the auxiliary building.
We, therefore, conclude that the licensee should proceed with implementing the modifications.
Implementation of the above listed modifications does not provide assurance that redundant safe shutdown cables, electrical equipment and mechanical components (other than large pumps discussed in Section 5.11.5) will not be damaged by fires on this elevation.
The licensee will verify that safe hot and cold shutdown can be achieved for any postulated fire on this elevation of the auxiliary building as discussed in Section 4.1 of this report.
Postulated fires on this elevation should include fires involving installed combustibles, transient combustibles, combustible liquid spills and hydrogen fires.
The licensee will verify that the excess flow valve on the hydrogen line will limit hydrogen leakage sufficiently to preclude damage from a hydrogen fire to safety related equipment and cables.
We will address the adequacy of fire protection for the safety-related areas of elevation 695 feet of the auxiliary building in a supplement to this report after completion of the above described licensee evaluation.
b 5-17
5.12 Auxiliary Building - Elevation 715 Feet 5.12.1 Safety-Related Equipment Most of the safety related and safe shutdown equipment on this elevation is located in the building wings adjacent to the reactor buildings.
The Unit 1 wing contains safety related motor control centers and cables for redundant divisions of the chemical and volume control system, including charging pumps and boric acid pumps; auxiliary feedwater system; residual heat removal system; and component cooling system.
Most of the cables are for Unit 1 but there are also Unit 2 cables in this wing.
The Unit 2 wing contains motor control centers and cables for redundant divisions of safe shutdown systems as listed above for the Unit 1 side.
Unit 1 cables are also located in the Unit 2 side.
The cable penetrations into the contain-ment annulus are located in the wings.
The counting room and hot chemistry laboratory are located off the central corridor of the auxiliary building joining the building wings.
Valves and piping assaciated with the chemical and volume control system charging, letdown, and excess letdown lines for both Unit 1 and Unit 2 are located in the corridor. 'None of this equipment is required for safe shutdown.
The boric acid pumps which can be used for safe shutdown are located outside the counting room.
The holdup tank compartments, Unit 1 and Unit 2 main steam areas and spent fuel pool heat exchanger areas are located in the central section of the building on this elevation.
None of these areas contain safety-related equipment.
5.12.2 Combustibles The major combustible material in the side areas of the auxiliary building on this elevation is cable insulation.
These areas are also used fo/
storage and contain fiber drums of protective clothing, plastic, and cardboard boxes.
The hydrogen line discussed in Section 5.0 enters the Unit 1 and Unit 2 volume control tanks on this elevation.
Combustible urethane-based insulation is used to cover pipes associated with the chil_ led water systems.
A 210 pound water capacity prcpane cylinder is located in the cold labora-tory and a 239 pound water capacity dimethylamine cylinder is located in the counting room.
These cylinders and the attached piping are not rigidly supported.
The tanks are not provided with excess flow valves.
5.12.3 Consequences if No Fire Suppression A fire originating in either of the auxiliary building wings or the connect-ing corridor could spread throughout tnese zones, if unmitigated, due to the continuous cable pathways.
A fire in these zones would be enhanced by the large quantities of stored combustibles and combustible gases in cylinders and piping.
An unmitigatea fire in these zones could prevent safe shutdown of the plant.
1166 076 5-18
A fire could spread from the turbine building into the auxiliary building wings via unsealed or inadequately sealed penetrations or through ventila-tion ducts without fire dampers.
An unmitigated fire in any of the other areas on this elevation would not affect safe shutdown systems because of the separation by distance and barrier from safety-related equipment and the lack of significant amounts of combustibles in these areas.
5.12.4 Fire Protectic' 3ystems Ionization detectors are located throughout the safety-related areas on this elevation of the auxiliary building.
Hose stations and portable extinguishers are located throughout the elevation for manual fire fighting.
Wet pipe sprinkler systems are p*ovided under the stairways in both wings of the building.
Preaction sprinklers are located above the concentrations of cable trays at the containment annulus penetrations in both Unit 1 and Unit 2 sides of the auxiliary building.
A wet pipe sprinkler is provided in the hot chemical laboratory, laundry and access control area.
5.12.5 Adequacy of Fire Protection The location of detectors and fire hose stations is adequate for early warning of fires and to support manual fire fighting activities on this elevation of the auxiliary building.
The preaction sprinklers are expected to prevent significant damage to cables at the containinent annulus cable penetratic,n areas.
There are two penetration areas per unit; each penetra-tion area contains cables of a single safety division.
A fire confined to a single penetration area would not prevent safe shutdown.
- However, failure of the sprinklers could result in considerable loss of cables at the penetration areas and spread of the cable fire to other cable areas.
The licensee has not adequately described the separation between redundant divisions of safe shutdown cables, electrical equipment and valves to permit an evaluation of the adequacy of the fire protection afforded these components.
Safe shutdown could be prevented by damage to redundant divisions of systems whose cables are located on this elevation.
The staff concerns relative to the hydrogen hazard to safe shutdown systems is discussed in section 5.11.5 of this report.
5.12.6 Modifications The licensee has proposed the following mocifications to improve the fire protection for elevation 765 feet of the auxiliary building.
(1) Storage of combustible materials along the north wall of the Unit 2 wing will be discontinued.
A small amount of supplies for the hot chemical laboratory will be stored in approved fire-rated lockers.
5-19
(2)
The propane cylinder and the dimethylamine cylinder on this elevation will be relocated to an area separated from safety-related areas by a three hour rated fire barrier.
The new installations will be equipped with pressure regulators and the piping and cylinder installation will be in accordance with NFPA No. 58.
(3) A sign reading " Danger, Flammable Gas" will be posted near each flammable gas tank.
(4) Unsealed or inadequately sealed penetrations in the walls between the auxiliary building and turbine building fire areas 69 and 70 will be sealed, or existing seals upgraded as necessary to provide seals with a 3-hour fire rating.
Seals in the wall between the auxiliary building and fire area 14 will be upgraded to a rating commensurate with the fire loading on both sides of the wall.
(5) Ventilation duct penetrations between the auxiliary building and the turbine building will be fitted with approved 3-hour fire-rated dampers or equivalent.
(6) Seals between the auxiliary building and the access control room will be inspected and upgraded as necessary to provide a fire resistance equivalent to the fire loading in each area.
(7) Approved fire dampers will be installed in the ventilation ducts penetrating the barriers between the auxiliary building and the access control room.
(8) All polyurethane foam piping insulation used in all safety related areas of the plant will be painted with a fire-retardant intumescent coating.
We find that the above listed modifications represent a significant improve-ment to the fire protection for this elevation of the auxiliary building.
We, therefore, conclude that the licensee should proceed with implementing the modifications.
Implementation of the above listed modifications does not provide assurance that redundant safe shutdown cables, electrical equipment and mechanical components, will not be damaged by fires on this elevation.
The licensee will verify that safe hot and cold shutdown can be achieved for any postu-lated fire on this elevation of the auxiliary building as discussed in Section 4.1 of this report.
Postulated fires on this elevation should include fires involving installed combustibies, transient combustibles, combustible liquid spills and hydrogen fires.
The licensee will verify that the excess flow valve on the hydrogen line will limit hydrogen leakage sufficiently to preclude damage from a hydrogen fire to safety-related equipment and cables.
We will address the adequacy of fire protection for the safety-related areas of elevation 715 feet of the auxiliary building in a supplement to this report after completion of the above described licensee evaluations.
5-20 1166 078
5.13 Auxiliary Bulding - Elevation 735 Feet 5.13.1 Safety-Related Equipment The Unit I wing of the auxiliary building contains both divisions of the Unit 1 steam generator power operated relief valves and safety valves, as well as the main steam valve for the turbine-driven auxiliary feedwater pump.
There are also cables for the auxiliary feedwater system and the residual heat removal system and motor control centers for safeguards equipment.
The Unit 2 wing of the auxiliary building contains one division of Unit 2 steam generator power operated relief valves and safety valves, and the main steam valve for the turbine-driven auxiliary feedwater pump.
There are also cables for the auxiliary feedwater system, residual heat removal system, chemical and volume control system and safety injection system, and safety-related motor control centers.
In the center part of this elevation there is a demineralizer hatch area which extends to the roof of the building with a gallery at elevation 755 feet.
The boric acid tanks are located in a separate enclosure within the hatch area.
Cables for one Unit 1 reactor coolant pump and one Unit 2 reactor coolant pump are routed through the hatch area.
The spent fuel pool cooling pumps and spent fuel pool skimmer pump are in an area separated from the main part of the auxiliary building by the spent fuel pool walls.
5.13.2 Combustibles The combustibles in the wings of tne auxiliary building at this elevation consist almost entirely of a small amount of cables.
Except for the hatch area, the combustibles in other areas are minimal.
The hatch area contains storage of resins and significant amounts of protective clothing.
5.13.3 Consequences if No Fire Suppression The side areas of the auxiliary building contain redundant divisions of safe shutdown cables and equipment.
The consequences of fire damage in these areas relative to safe shutdown capability have not been adequately addressed by the licensee.
However, fire propagation in these areas would be restricted by the lack of combustible pathways.
Much of the cable in the side areas is in conduit.
A fire confined to the hatch area would have no effect on the safe shutdown capability of the plant.
However, a significant fire in the hatch area or turbine building could spread to the safety-related areas of the auxiliary building via open or inadequately sealed penetrations and, in the case of the hatch area, through undampered ventilation dects.
A fire in the fuel handling area could damage both spent fuel pool cooling pumps and cables for these pumps as well as for the spent fuel pool skimmer pumps.
The capability for alternative spent fuel cooling using equipment independent of this fire area has not been described by the licensee.
5-21 f
bb O[9
5.13.4 Fire Protection Systems Ionization detectors are located throughout the safety-related areas on this elevation and above the spent fuel pool cooling pumps.
Hose stations and portable extinguishers are located throughout the elevation for manual fire fighting.
Wet pipe sprinklers are provided under the stairways in both wings of the building.
5.13.5 Adequacy of Fire Protection The location of detectors and fire hose stations is adequate for early warning of fires and to support manual fire fighting activities on this elevation of the auxiliary building.
However, manual suppression may not be adequate to prevent damage to redundant safe shutdown equipment and cables, or to fuel pool cooling pumps and cables.
The licensee has not adequately described the separation between redundant divisions of safe shutdown cables, electrical equipment and valves to permit an evaluation of the adequacy of the fire protection afforded these components.
Safe shutdown could be prevented by damage to redundant divisions of systems whose cables are located on this elevation.
5.13.6 Modifications The licensee has proposed the following modifications to improve the fire protection for elevation 735 feet of the auxiliary building:
(1) A ceiling will be constructed at elevation 755 feet over part of the hatch area and a sprinkler system will be installed under the ceiling.
All combustible storage will be located under this sprinklered area.
(2) The wooden equipment boxes stored in the hatch area on the platform above the entrance to contair. ment will be coated with an acceptable fire retardant coating or they will be removed from the plant.
(3) Penetrations in the barriers between the turbine building and auxiliary building will be sealed, and existing seals upgraded, to provide 3-hour fire-rated seals.
(4) Penetration seals between the hatch area (fire area 61) 7.nd the other areas of the auxiliary building will be inspected and u nraded as necessary to provide 3-hour fire resistance.
(5) Penetrations in barriers between the auxiliary building and other plant areas will be inspected and upgraded as necessary to provide a fire resistance equal to the fire loading on both sides of the barrier.
We find that the above listed modifications represent a significant improve-ment to the fire protection for this elevation of the auxiliary building.
5-22 1166 080
We, therefore, conclude that the licensee should proceed with implementing the modifications.
Implementation of the above listed modifications does not provide assurance that redundant safe shutdown cables, electrical equipment and mechanical components will not be damaged by fires on this elevation.
The licensee will verify that safe hot and cold shutdown can be achieved for any postu-lated fire on this elevation of the auxiliary building as discussed in Section 4.1 of this report.
Postulated fires on this elevation should include fires involving installed combustibles, transient combustibles, and combustible liquid spills.
The licensee will verify that no ventilation ducts penetrate the barriers between the hatch area and other areas of the auxiliary building.
Any ventilation duct penetrations in these barriers should have 3-hour fire rated dampers.
The licensee will also verify that alternative means of spent fuel poo!
cooling can be made available if both spent fuel cooling pumps are rendered inoperable by fire damage.
The alternative fuel pool cooling equipment should be located outside of the spent fuel pool cooling pump area.
We will address the adequacy of fire protection for the safety-related areas of elevation 735 feet of the auxiliary building in a supplement to this report after completion of the above described licensee verifications.
5.14 Auxiliary Building - Elevation 755 Feet 5.14.1 Safety-Related Equipment The central section of the auxiliary building at this elevation contains the fuel handling area, the top of the spent fuel pool, the mezzanine of the hatch area and the water chiller compartments.
Only the water chiller equipment is safety-related.
The side wings on this elevation contain the Unit 1 and Unit 2 ventilation fan rooms.
Redundant safety related cables and motor control centers for ventilation equipment are located in both fan rooms.
5.14.2 Combustibles The fan rooms and water chiller compartments contain some combustible cable insulation.
The major combustible material in these areas are the charcoal filters in ventilation system filter cabinets.
The other areas on this elevation contain only minor quantities of combustibles.
5.14.3 Consequences if No Fire Suppression An unmitigated cable tray fire or heat buildup from an unmitigated charcoal filter fire could damage redundant divisions of safety-related cables and electrical equipment in the fan rooms or chiller compartments.
The effect of such damage on safe shutdown has not been adequately addressed by the licensee.
A fire in other areas on this elevation would have no effect on safety-related systems.
5-23 f f bh (@ }
5.14.4 Fire Protection Systems Ionization smoke detectors are provided throughout this elevation of the auxiliary building.
Portable fire extinguishers and fire hose stations are available for manual fire fighting.
In addition, the auxiliary building special ventilation exhaust charcoal filter for each unit is protected by a wet pipe sprinkler system.
The spent fuel special charcoal filters and the in-service purge charcoal filters are provided with a dry sprinkler system inside the filter cabinets, but the sprinkler system is not connected to a water supply.
5.14.5 Adequacy of Fire Protection The location of detectors and fire hose stations is adequate for early warning of fires and to support manual fire fighting activities on this elevation of the auxiliary building.
However, manual suppression may not be adequate to prevent damage to redundant safety-related cables and electrical components in the fan rooms or chiller compartments.
The licensee has not adequately described the separation between redundant divisions or the consequences of their loss to permit an evaluation of the fire protection afforded these components.
5.14.6 Modifications The licensee will upgrade the barrier penetration seals between the hatch area and other auxiliary building areas as discussed in Section 5.13.6 of this report.
We find that the above modifications represent a significent improvement to the fire protectica for this elevation of the auxiliary building.
W, therefore, conclude that the licensee should proceed with implementing the modification.
Assurance has not been provided that redundant safe shutdown cables and electrical equipment will not be damaged by fires on tnis elevation.
The licensee will verify that safe hot and cold shutdown can be achieved for any postulated fire on this elevation of the auxiliary building as discussed in Section 4.1 of this report.
Postulated fires on this elevation should includt fires involving installed combustibles, transient comb.stibles, and combustible liquid spills.
We will address the adequacy of fire protection for the safety-related areas of elevation 755 feet of the auxiliary building in a supplement to this report after completion of the above described licensee evaluation.
5.15 Reactor Containment Buildings 5.15.1 Safety-Related Equipment The reactor containment buildings for Unit 1 and Unit 2 are essentially identical structures.
A steel wall divides the containment into an outside annulus area and the main central equipment spaces.
The central section has four floor levels.
f f bh ()82 5-24
Pipes and cables for safe shutdown systems pass through the annulus and are then dispersed through the central area.
There are two cable penetra-tion areas in the annulus; each penetration area generally contains a single division of safety-related cable.
Safety-related systems serviced by these cables include the chemical and volume control system, residual heat removal system, safety injection system, pressurizer heaters and process indications.
There are valves in containment for the chemical and volume control system, residual heat removal system and safety injection system.
5.15.2 Combustibles The significant combustibles in the central containment area are cable insulation, reactor coolant pump lube oil and charcoal filters.
Some lumber is stored on the 755-foot elevation.
The only significant combustible in the annulus is cap e insulatin.
5.15.3 Consequences if No Fire Suppression An unmitigated cable fire or reactor coolant pump lube oil fire could damage cables necessary for the safe shutdown of the plant.
Loss of redundant process indication cables could prevent safe hot shutdown.
The consequences of fire damage to other cables relative to safe shutdown capabilit.y has not been adequately addressed by the licensee.
5.15.4 Fire Protection Systems Each of the four levels in the central sections of the containments is provided with ionization type fire detectors which alarm in the control room.
Detectors are also provided in the annulus sections at the cable penetration areas.
The cable penetration areas are protected by pre-action sprinkler systems.
Portable extinguishers are proviaed in the central sections of the contain-ment buildings.
There are also two hose stations on each floor level in the central sections.
These hose stations are supplie-by a dry standpipe system which is pressurized during refueling and maintenance activities.
An oil co'iectio'1 w tem is provided for potential reactor coolant pump lube oil leakage.
This system includes oil collection pans on the pumps with drain piping to the containment ground floor.
5.15.5 3dequacy of Fire Protection During normal reactor operation, the containment hose stations are dry.
Following detection of a fire in containment it is necessary to reb.ove containment fire hose standpipe system flanges attached at the inner and outer containment boundaries and to install spool pieces in the fire water system.
The licensee's description of the procedure to reestablish fire water to containment indicates that fire suppression water would not be available for a period of 6 to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> following detection of a fire in containment because of contair. ment integrity considerations prior to l } bh lIh3
a cooldown to 200 F.
A more timely method for providing fire water to containment hose stations is needed to assure prompt extinguishment of a fire within containment.
The separation between redundant divisions of safe shutdown cables in the containment annulus and central section has not been adequately described to permit an evaluation of the fire protection afforded these cables.
Redundant divisions of cables could be damaged in the annulus if the cable penetration sprinkler system failed to operate.
5.15.6 Modifications The licensee has proposed the following modifications to the containment fire protection systems:
A more timely method for p'oviding fire water to containment fire hose stations will be implemented.
Possible methods under investigatie include a solidly piped supply header, use of available plant makeup water, end use of available cooling water in containment.
Piping will be provided to drain reactor coolant pump lube oil leakage to the covered containment sump "A".
We find that the above modifications represent a rignificant improvement to the fire protection for the containment buildings.
We, therefore, conclude that the licensee should proceed with implementing the modifications.
Implementation of the above listed modifications does not provide assurance that redundant safe shutdown cables, electrical equipment and mechanical components will not be damaged by fires in containmcat.
The licensee will verify that safe hot and cold shutdown can be achieved for any postulated fire in the containment buildings as discussed in Section 4.1 of this report.
Postulated fires in containment should include fires involving installed combustibles, transient combustibles and combustible liquid spills.
We will address the adequacy of the fire protection for the reactor contain-ment buildings in a supplement to this report after completion of the above described licensee evaluations.
5.16 Radwaste Building a.;J Resin Disposal Buildina 5.16.1 Safety-Related Equipment The radwaste building is a two-story building adjacent to and sharing cne wall with the auxiliary building.
The resin disposal building is adjacent to the southwest corner of the ra2.mste building on the side away from the auxiliary building.
The radwaste building houses the radwaste baling and drumming equipment and the resir. disposal builc;ing contains wet resin handling equipment.
None of this equipment is safety-related or required for shutdown.
b O' 4 5-26
5.16.2 Combustibles The combustibles in the radwaste building include cable insulation, resin and contaminated trash.
All the resin in the resin disposal building is wet or drummed and not available for combustion.
There is a small amount of cable insulation in this building.
5.16.3 Consequences if No Fire Suppression The wall between the radwaste building and the auxiliary building in concrete for the bottom 10 feet and insulated metal siding above the concrete wall.
Although an unsuppressed fire in the radwaste building may be able to breach the insulated metal wall, there is no safety-related equipment in the auxiliary building fire a*eas immediately adjacent to the wall.
5.16.4 Fire Protection Systems Ionization type fire detectors are provided on both elevations of the radwaste building.
Fire hose stations and portable extinguishers are available in the radwaste building and resin disposal building.
5.15.5 Adequacy of Fire Protection The manual fire fighting equipment provided for these areas is adequate to prevent the spread of fire from these buildings to safety-related areas of the plant.
5.16.6 Modifications No modifications have been proposed for the fire protection of these buildings.
We fint
.e fire protection for the radwaste building and resin disposal huilding satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
5.17 Diesel Generator Rooms - Fire Zones 25 and 26 and Water Treatment Area Fire Zone 27 5.17.1 Safety-Related Equipment The two emergency diesel generator rooms are located at the Unit 1 side of the auxiliary building at the 6SS-foot elevation.
Each room is approxi-mately 50 feet long by 25 feet wide and is located adjacent to each other end to end.
Each room contains the ciasel engine driven generator, fuel day tank, motor control pare' anc ancillary equipment.
The water treat-ment area, fire zone 27, is u. tea acjacent to the diesel generator rooms.
This area contains no afety-related equipment.
l}bh 00b 5-27
5.17.2 Combustibles The combustibles in each diesel generator room consists of approximately 700 gallons of diesel fuel and lube oil and some cable insulation.
The combustibles in the water treatment area consist of minor amounts of cabling and some resin storage.
5.17.3 Consequences if No Fire Suppression An unsuppressed fire in one of the emergency diesel generator rooms could cause a loss of one division of safety-related equipment for one unit if normal and backup offsite power were not available.
An unmitigated fire in the water treatment area would probably pose no threat to the diesel generator rooms or other safety-related area.
6.17.4 Fire Protection Systems The diesel generator rooms are enclosed with concrete walls, floors, and ceilings having a minimum fire ratir.g of 3-hours.
The doorway communicating betweea the two rooms is provided with a 3-hour rated fire door, but the doorway is not curbed to prevent seepage of fuel or lube oil from a rupture or pipe break.
The licensee has indicated that the penetra-tions in the walls surrounding the diesel generator rooms are sealed although the fire rating of these penetration seals was not stated.
Each emergency diesel generator room is monitored by a fire detection system utilizing both ionization type and flame detectors.
The rooms are also protected by a preaction type automatic sprinkler system.
Backup fire protection is provided by manual hose stations and portable extinguishers.
The water treatment area, fire zone 27, is monitored by early warning detectors and protected by a wet pipe automatic sprinkler system.
Hose stations and portable extinguishers are also provided within the area.
5.17.5 Adequacy of Fire Protection The fire rated door between adjacent diesel generators does not have curbs to prevent the seepage of combustible fluids under the door.
Penetrations in the walls of the diesel generator rooms may not have a 3-hour fire rating, thereby permitting a fire in one of the diesel generator rooms from spreading to adjacent areas.
The fire protection provisions for the water treatment area, fire zone 27, is considered adequate for the hazard.
5.17.6 Modifications The licensee has proposed the following modification to improve the fire protection for the emergency diesel generator rooms:
A ramp of 2 inches will be installed in the D-1 diesel generator room to prevent the flow of liquids from passing under the door to the adjacent diesel generator room.
5-28 l l b b I)r36
The licensee will also reevaluate penetration seals between the diesel generator rooms and the auxiliary building to verify that these seals have a minimum fire rating of 3-hours.
Where penetration seals having less 5han a 3-hour fire rating are found to exist, they will be upgraded to a P hour fire rating.
We will address the adequacy of fire protection for the emergecy diesel generator rooms in a supplement to this report after completion of the above described licensee's evaluation.
5.18 Yard Area 5.18.1 Safety-Related Equipment The safety-related equipment in the yard area includes underground cabling piping running between the screen house and turbine building which serve the cooling water pumps Other safety-related components in the yard area are the six diesel fuel underground storage tanks each with a capacity of 19,500 gallons (fire zone 48).
Other fire zones located in the yard area, but which are not safety-related include:
FIRE ZONE DESCRIPTION 28 Transformers 43 Unit 2 transformer oil sump 44 Unit 1 transformer oil sump 45 Fuel oil and transfer house 49 Heating boiler fuel oil storage tanks 56 Drum storage area 5.18.2 Combustibles The combustibles in the yard area include:
oil filled transformers, underground fuel oil storage tanks, and associated fuel oil transfer equipment.
In addition, the potential exists for the introduction of significant combustibles such as construction materials and fuel oil trucks.
5.18.3 Consequences if No Fire Suppression In general, an unsuppressed fire in the yard area would not present a significant fire exposure to safety-related systems because of intervening distance or barriers.
5.18.4 Fire Protection Systcms The transformers are provided with rate-of-rise thermal detectors which alarm in the control room.
The transformers are also protected with deluge water spray systems which can be actuated from the control room or at the system control valves near the transformers.
The transformers are set in concrete basins which drain to two oil sump collection areas well separated from the units.
5-29 l } My []@ /
Manual fire fighting capability is provided by hydrants and hose houses containing firefighting equipment spaced throughout the yard area.
Tanks for storage of diesel fuel and fuel oil are buried.
5.18.5 Adequacy of Fire Protection The fire protection previsions for the yard area are considered acceptable with the exception of those items identified as requiring upgrading in Section 4.3.1.3 of this report.
5.18.6 Modifications The need for modifications to fire protection systems which are located in the yard area is outlined in Section 4.3.1.3 of this report.
These modifications include improvements to barrier posts protecting hydrants and post-indicator valves, maintenance and testing of hydrants and hose, supervision of valves controlling fire protection water and upgrading of fire protection equipment.
With the implementation of the modifications listed in Section 4.3.1.3 of this report, we find that the fire protection for the yard area satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
5.19 Screen House 5.19.1 Safety-Related Eauipment The screen house is a concrete structure approximately 75 feet wide by 120 feet long.
Water from the Mississippi River enters the base of the building via the intake canal through a system of trash grids and traveling screens.
The building is divided into two levels housing water pumps and associated equipment.
The upper level, elevation 695'-0", contains traveling screen units, strainers, electric motor-driven cooling water pump, and two diesel engine-driven cooling water pumps with ancillary equipment including air compressors, control panels, and diesel fuel day tanks.
The lower level, elevation 670'-0", contains the large circulating water pumps, two electric-driven cooling water pumps, the electric-driven screenwash pump, the electric motor-driven fire pump, jockey pump, sump pumps and the diesel engine-driven fire pump including the diesel fuel day tank, controllers and batteries / charger system.
5.19.2 Combustibles The significant combustibles in this building consist of diesel fuel contained in the piping and cay tanks, lube oil, and electric cable insulation.
At the time of the site visit, small quantities of untreated lumber was also noted.
Covers on the diesel engine-driven fire pump batteries are of wood.
1166 088 5-30
5.19.3 Consequences if No Fire Suppression An unmitigated fire on the upper level of the structure involving the diesel fuel associated with one of the diesel engine-driven cooling water pumps would affect redundant safe shutdown equipment because of the separation of equipment bot spatially and by fire barriers.
The licensee's proposal to install 4-inch angle iron curt's sealed with gasket material at the open doorways to the diesel driven cooling water pumps will prevent burning liquid to migrate to other areas.
The existing detection and fire suppression systems also minimize the concern of an unmitigated fire occurring at this elevation.
An unmitigated fire at the lower level of the screenhouse could damage both fire pumps and one electric motor driven cooling water pump and possibly the other electric motor driven cooling water pump and screenwash/ backup fire pump.
5.19.4 Fire Protection System The two cooling water pumps located on the lower level of the screenhouse are separated from the three redundant cooling water pumps on the upper level by distance and concrete barriers.
Two of the cooling water pumps on the upper level are diesel engine driven and are locateri in separate compartments.
The two diesel engine driven pumps are the safety-related cooling water pumps while the motor driven pumps are considered by the licensee to be nonsafety-related.
The entire screenhouse is provided with a fire detection system utilizing ionization detectors which alarm in the control room.
The building is also protected by a preaction type automatic sprinkler system.
Backup fire protection is provided by hose stations and portable extinguishers.
5.19.5 Adequacy of Fire Protection The separation of redundant safety-related pumps, eoc,y warning detection system, automatic pre-action, sprinkler system, and backup fire protection equipment for manual fire fighting are significant fire protection provisions and greatly reduce the likelihood of a serious fire.
The arrangement of the equipment on the lower level could result, however, in a fire that could damage both fire pumps and one cooling water pump.
A break in a diesel fuel line or a rupture of the diesel fuel day tank supplying the diesel driven fire pump could result in fuel spreading along the floor at this level and the entire area could be affected by a fire.
A fire in this area could also be supplied by diesel fuel continuing to be delivered by the transfer pumps from the underground diesel fuel storage tanks.
Three diesel fuel transfer pipes enter the east wall of the building and run along the ceiling across the area in which the electric driven fire pump is located.
In the vicinity of the diesel driven fire pump, two of the lines enter the upper level and are piped to the two diesel engine driven cooling pumps day tanks.
The remaining line is piped to the diesel 5-31
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engine driven fire pump day tank.
A fire fed by the day tank fuel supply could produce a serious fire if provisions are not adequate to automatically or manually stop the transfer of fuel.
The physical arrangement in various portions of the building will also allow migrating fuel oil from a day tank or pipe leak to spread and potentially have a greater effect if a fire should occur.
The most likely area to be affected by a diesel fuel leak would be the diesel engine driven fire pump and the electric motor driven fire pump which are located in the same area and separated by approximately 18 feet.
The covers protecting the batteries for the diesel engine driven fire pump are composed of wood which unnecessarily adds to the combustible loading in this area.
The power cables to the electric motor driven fire pump is contained in 4-inch conduit and is run along the ceiling above the diesel fuel area serving the other fire pump.
A fire involving the diesel fuel could affect the cabling within the conduit resulting in the' loss of function of both fire pumps.
5.19.6 Modifications The licensee has proposed the following modifications to improve the fire protection for the screen house:
(1) A 4-inch angle iron curb, sealed with a gasket impervious to diesel oil will be provided at the open doorways of the diesel engine driven cooling water pump rooms at the 695-foot elevation.
(2) Gaskets that seal angle iron curbing will be water tested to assure seal tightness after each reinstallation of the curbing.
(3) The wooden battery covers in the area of the diesel engine driven fire pump will be removed or replaced with noncombustible covers.
(4) Pre-fire strategies will be developed for all diesel fuel day tank areas to provide for tripping the diesel fuel transfer pumps and/or isolating the fuel supply lines to the day tanks in the event of a fire or a piping break.
(5) A curb will be provided at the diesel fire pump day tank of suf-ficient height to contain the entire contents of the tank plus a margin for fire protection water.
We find that the above listed modifications represent a significant improvement to the fire protection for the screenhouse. We therefore conclude that the licensee should proceed '.sith implementing these modifications.
Not all the potential fire protection problems, however, have been addressed by the above modifications.
Specifically, a fire due to a leak or rupture of a diesel fuel transfer line could incapacitate both the diesel engine driven fire pump and the electric motor driven fire pump l166 090
because of the location of these pumps and their associated support equipment with respect to the routing of diesel fuel oil transfer piping.
The licensee has committed to evaluate the feasibility of providing a 3-hour fire-rated barrier around the electric motor driven fire pump.
This evaluation will consider the exclusion of diesel fuel transfer piping from the area bounded by the fire barrier and the routing of electric cables for the fire pump to assure that a diesel fuel fire will not damage the controls or power source for the fire pump.
If the evaluation shows that it is not feasible to install such a fire barrier, the licensee will propose additional fire protection to assure that a diesel fuel fire would not incapacitate both fire pumps, or alterna-tively upgrade the screenwash pump to function automatically as a fire pump if its use would not otherwise be required in a fire emergency.
We will address the adequacy of the fire protection for the screenhouse in a supplement to this report after completion of the above-described evaluation.
5.20 Turbine Building - Fire Zones 8 and 9 Adminis d ative Building - Fire Zone 7 5.20.1 Safety-Related Equipment These areas include the turbine deck of the turbine building (fire zone 8) and contiguous areas which include the maintenance shops (fire zone 9) and the administration building office area (fire zone 7).
The turbine deck (fire zone 8) is a large higii bay area located at the 735'-0" elevation measuring approximately 125 feet wide by 500 feet long and houses the steam driven turbines and generators for Units 1 and 2.
Fire zone 9 is located adjacent to the turbine deck at the southeast corner and covers an area approximately 50 feet wide by 125 feet long.
This zone houses the machine shop, welaing shop, electrical shop parts storage, and shop office.
Fire zone 7 is composed of engineering and administrative offices which are located in the administrative building which is partially within the turbine building at the 735'-9" elevation.
Fire zone 6 contains the heating, ventilation, and air conditioning equipment.
It is located on top of the offices (fire zone 7) and forms a mezzanine within the turbine deck area.
There is no safety-related equipment in these fire zones.
5.20.2 Combustibles The combustibles in fire zone 6 include small quantities of lube oil and cables associated with the air handling equipment.
The combustibles in fire zone 7 consist mainly of paper used in the offices.
The significant combustibles in fire zone 8, the turbine deck, include cabling, lube oil at the bearngs, and hydrogen in the generator units.
Other combustibles include maintenance materials and wood laydown blocks.
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5.20.3 Consequences if No Fire Sgpression An unmitigated fire in fire zones 6, 7, or 9 would not have an effect on safe shutdown because they do not contain safety-related equipment and these areas are separated by distance and barriers from areas that do have safety-related systems.
A fire in fire zone 8 involving the lube oil for the turbine bearingsA fire o could result in a significant fire.the turbine building roof support!. with th Because of the self supporting construction of the auxiliary building located adjacent to the turbine building, safety-related equipment would not be jeopardized.
5.20.4 Fire Protection Systems The turbine generator bearings in fire zone 8 are protected by thermal The detectors and a manually actuated deluge extinguishing system.
turbine deck is also provided with portable and wheeled unit extinguishers Seven hose stations are also provided on the turbine and hose stations.
building roof to fight a roof fire.
Fire zone 7, the office area, is provided with pressurized water extinguishers.
Fire zones 6 and 7 are provided with porttble extinguishers and hose stations.
5.20.5 Adequacy of Fire Protection The plant, including those used at the top elevation of the turbine building, will perform adequately with the pressures available at this level.
The fixed fire suppression systems protecting the turbine bearings and the secondary fire protection provisions throughout all the fire zones being considered are adequate for the hazar.i.
A number of mechanical penetrations, piping, conduit, and ventilation ducts between the turbine building and adjacent areas have been identified by the licensee.
5.20.6 Modifications Each penetration between the turbine building and adjacent safety-related Penetrations found deficient will be up5;raded areas will be reexamined.
to a 3-hour fire rating.
e find that With the implementation of the above described modification, the fire protection for fire areas 7, 8, and 9 satisfies tL objectives identified in Section 2.2 of this report and is, therefore, acceptable, f ! b b I.!92 5-34
5.21 Administration Building - Fire Zone 24 5.21.1 Safety-Rela +.ett Equipment Fire zone 24 includes the two lower elevations of the administration building located adjacent to the north wall of the turbine building.
Each level covers an area approximately 40 feet wide by 55 feet long.
The lower level, at grade, houses the lube oil storage tank and transfer The upper level at the 715'-0" elevation contains the office staff pumps.
lunch room, locker room, and meeting room.
There is no safety-related equipment in this fire zone.
5.21.3 Combustibles The turbine oil storage tank has a capacity of approximately 18,000 gallons.
The combustibles in the lunch room and locker room consists of moderate quantities of paper and clothing.
5.21.2 Consequences if No Fire Suppression An unmitigated fire involving the turbine oil storage tank could produce a severe fire that might jeopardize the adjacent normal switchgear rooms which are separated from the oil storage room by a 3-hour fire barrier.
An unmitigated fire at the upper level containing the locker and lunch rooms would probably have no effect on adjacent areas containing safety-related equipment.
5.21.4 Fire Protection Systems The turbine oil storage room is provided with infrared fire detectors and a deluge system actuated by thermal detectors.
The remainder of the area is provided with hose stations and portable extinguishers.
5.21.5 Adequacy of Fire Protection The lube oil storage tank is adequately separated from the adjacent areas by 3-hour fire barriers.
The licensee has verified that the drainage system serving the lube oil storage tank room cannot back up into safety-related areas of the plant or areas that pose a hazard to safety-related areas.
The licensee has also verified that the design density of the deluge system protecting the oil storage tank is 0.30 gallons per minute per square foot which is adequate.
The provision of ionization detectors, hose stations, and portable extinguishers throughout the remaining areas of this fire zone is con-sidered ad;quate.
5.21.6 Modifications None.
We find that the fire protection for the Administration Building, fire zone 24, satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
5-35 llbb 093
5.22 Working Material and Lunch Room - Fire Zone 34; Utility and Locker Rooms - Fire Zone 15 5.22.1 Safety-Related Equipment The working material and lunch room, fire zone 14, is located at the 115'-0" elevation at the Unit 1 side of the turbine building.
The area contains no safety-related equipment.
The utility and locker rooms are also located at the 715'-0" elevation in the auxiliary building.
There is no safety-related equipment in this area.
5.22.2 Combustibles The combustibles in fire zone 14 consist primarily of moderate quantities of Class A materials including paper.
The combustibles in fire zone 15 consist of miscellaneous type Class A combustibles including clothing.
5.22.3 Consequences if No Fire Suppression An unmitigated fire in either of these areas would probably have no effect on safe shutdown capability.
5.22.4 Fire Protection Systems The working material and lunch room area, fire zone 14, is monitored by ionization type fire detectors and protected by wet pipe automatic sprinklers.
Secondary fire protection is provided by hose stations and portable extinguishers.
The utility and locker area is monitored by ionization type fire detectors.
Secondary fire protection is provided by portable extinguisher with hose stations available from adjacent areas.
5.22.5 Adequacy of Fire Protection The provisions for fire protection in fire zones 14 and 15 are considered adequate for the hazard.
5.22.6 Modifications None.
We find that the fire protection for the working material and lunchroom, fire zone 14, and the utility and locker area, fire zone 15 satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
5.23 Turaine Building - Fire Zones 69 and 70 and Hydrogen House - Fi, Zone 57 5.23.1 S_a_foty-Related Equipment
^
Fire zone 69 is the basement and mezzanine levels of the turbine building serving Unit 1.
Fire zone 70 is the basement and mezzanine levels of the turbine building serving Unit 2.
The two fire zones are separated from each other by a block of rooms containing switchgear, batteries, and shutdown panels which are described in other portions of this section of the report.
5-36 l f bd l}94
The equipment loc.ated on the mezzanine level of both fire zones 69 and 70 include:
condenser piping, heat exchangers, motor control centers, the iso phase ducts running outside to the transformers.
The equipment located on the basement level of both fire zones 69 and 70 include:
turbine condensers, piping, cabling, hydrogen seal oil unit, turbine oil reservoir, and storage of chemicals.
The licensea has indicated that a considerable number of safety-related systems including those required for safe shutdown are contained in these levels of the turbine building.
The location of these components and the separation between redundant trains, however, have not been adequately identified.
The hydrogen house, fire zone 57, is a small structure approximately 30 feet wide by 35 feet long situated against the east exterior wall of the turbine building at grade level.
A door and stairway fro.n this building lead to grade level east of the plant.
The building contains hydrogen and oxygen generators.
5.23.2 Combustibles Considerable quantities of oil are located in these a eas of the turbine building including the seal oil units and the turbine lube oil reservoirs.
The piping W the turbine lube oil and seal systems is also routed through these fire les.
Other significant combustibles in these levels of the turbine i ang include hydrogen piping and cabling.
5.23.3 Consequence if No Fire Suppression An unmitigated fire involving the turbine lube oil system or seal oil units could result in a fire of major proportions.
A fire involving these units could expose the auxiliary feedwater pumps and shutdown panels in the adjacent fire areas 31 and 32.
Oil escaping from the curbed area around the turbine lube oil tanks or escaping from the seal oil unit could travel to the auxiliary feedwater pumps, and shutdown panel rooms via the drainage trough.
This trough travels the length of both units at the basement level of the turbine building and passes under the doors and through the auxiliary feed pump / shutdown panel rooms.
Both the turbine lube oil reservoirs and seal oil units for both units are situated within 10 feet of the trough.
An unmitigated fire at the turbine lube oil reservoir could also expose the steel structural members supporting the building which are located adjacent to the reservoir.
Cabling throughout the area could also be affected by a fit s.
A fire and resulting fire in the hydrogen house would blow out the exterior wall of the hydrogen house.
The cencrete wall of the turbine building and 1 -hour fire-rated door would probably prevent the explosion in the hydrogen house from affecting the turbine building.
5-37 1166 095
5.23.4 Fire Protection Systems Most areas of fire zones 69 and 70 are monitored by early warning fire detectors and protected by wet pipe automatic rprinkler systems.
Fire zone 57, the hydrogen house, is monitored by thermal type fire detectors.
Portable extinguishers and hose sta.tions are provided throughout the areas, or are available from adjacent areas.
The turbine oil reserdrs are provided with a 2-foot high dike surrounding the units and protected by manually actuated deluge systems.
The seal oil units are also protected by manually actuated deluge systems.
5.23.5 Adequacy of Fire Protection The area detection systems and automatic sprinkler systems provided throughout the mezzanine and basement levels of the turbine building (fire zones 69 and 70) are considered ec' equate for general fire protection in these areas.
The number and locatiore of hose stations and portable extinguishers are also considered adequate.
The licensee has provided an analysis of the drainage system serving the 10,000 gallcn turbine oil reservoirs which has adequately demonstrated that in the event of a tank rupture, the oil would be contained within the 9,500 gallon capacity curbed area and in the 20,000 gallon enclosed sump to which the curbed area is drained by 4-inch and 6-inch drain lines.
The license has also stated that the deluge fire suppression systems protecting the turbine oil reservoirs and the seal oil units have a design discharge density of 0.30 gallons per minute per square foot, which is considered acceptable.
The seal oil units are not provided with curbs or surrounding drainage troughs to prevent a rupture or Ice from spreading along the floor of the turbine building basement.
Exposed steel structural building support members are located adjacent to the turbine lube oil reservoirs and could be weakened by the heat from a fire at this location.
The lack of manual foam application equipment could hinder fire fighting success in manually fighting a fire involving flammable liquids such as at the seal oil units or turbine lube oil reservoirs.
A fire or explosion in the hydrogen house vill probably have no effect on safety-related systems because of spatial and barrier separations and the provision of blowout and exterior walls.
A number of mechanical penetrations, piping, conduit, and ventilation ducts between the turbine building and adjacent areas have been identified by the licensee.
The penetrations include ventilation ducts to the auxiliary building which are not provided with fire dampers.
b 5-38
5.23.6 Modifications The licensee has proposed the following modifications to improve the fire protection at the mezzanine and basement levels of the turbine building, fire zones 69 and 70:
(1) A 6" x 6" drainage trough with a grating surface will extend to surround the seal oil units.
(2) A suitable fire retardant coating will be applied to the building structural members in the vicinity of the lube oil reservoirs.
(3) Foam applicator nozzles suitable for use with 1 -inch hose lines and a supply of foam concentrate will be provided and stored at the central fire equipment location.
(4) Each penetration between the turbine building and adjacent safety related areas will be reexamined and if found deficient upgraded to a 3-hour fire rating.
Ventilation duct penetrations will be provided with approved 3-hour fire dampers.
We find that the above modifications represent an improvement to the fire protection of the turbine building fire zones 69 and 70 and the hydrogen house fire zone 57. We, therefore, conclude that the licensee should proceed with implementing the modifications.
The licensee will evaluate fire zones 69 and 70 of the turbine building with regara to safe shutdown requirements of equipment and cables located here as discussed in Section 4.1 of this report.
Verification will be provided that the fire protection syC em, as modified, provide adequate assurance that a fire in any room w'.ll not prevent safe hot and cold shutdown of both units.
We will address the adequacy of fire protection for fire zones 69 and 70 of the turbine building in a supplement to this report after completion of the abo"e described licensee evaluation.
We find the fire protection for the hydrogen house, fire zone 57, satisfies the objectives identified in Section 2.2 of this report, and is, therefore, acceptable.
f f bU ljy[
5-39
6.0 ADMINISTRATIVE COUTROLS General The administrative controls for nuclear plant fire protection consist of the fire protection organization ard its qualifications, fire brigade training, the controls over combustibles and ignition sources, methods for assuring the availability of the fire protection systems and equipment; procedures for fighting fires, fire watch, and quality assurance provisions for the fire protection program.
The licensee has provided a description of proposed administrative controls for fire protection by submittals dated May 18, 1978; June 22, 1978; and May 2, 1979; and as modified by discussions with the NRC staff.
Based on our review of this information and our understanding that the licensee meets or will meet the specific guidance found in " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls, and Quality Assurance," we conclude that the licensee has provided an adequate program for fire protection administrative controls.
We find that the control of nuclear plant fire protection functional responsibilities, administrative controls, and quality assurance conforms to the provisions of Appendix A to BTP 9.5-1 and is, therefore, acceptable.
6.1 Fire Prctection Organization The licensee's fire protection organization contains the organizational responsibilities and lines of communication between the various positions through the use of organizational charts and functional descriptions of each position's responsibilities.
Upper level offsite management positions are designated which have management responsibility for the formulat Wn, implementation, and assessment of the effectiveness of the nuclear plant fire protection program.
The results of these assessments are reported to the upper level management position responsible for fire protection with recommendations for improvements or corrective actions as deemed necessary.
The organizational responsibilities are delineated through onsite management positions for design, installation, testing, maintenance, modification, and review of fire protection systems and for fire brigade training.
A fire brigade size has been agreed upon.
Qualification requirements have been established for fire brigade members, and the position responsible for formulating and implementing the fire protection program.
Satisfactory completion of a physical examination including periodic screening for performing strenuous activity is required for all fire brigade members.
We find that the fire protection organization conforms to the provisions of Appendix A to BTP 9.5-1 and is, therefore, acceptable.
} Ibd ll98 6-1
6.2 Fire Brigade Training The fire brigade training program consists of an initial classroom instruction program followed by periodic classroom instruction, practice in fire fighting and fire drills.
Practice sessions are held for fire brigade members on the proper method of fighting various types of fires that could occur in a nuclear plant considering such factors as the magnitude of the fire and the complexity and difficulty of fire fighting.
Records of training are provided and are available for review including drill critiques.
We find that the fire brigade training conforms to the provisions of Appendix A to BTP 9.5-1 and is, therefore, accetable.
6.3 Control of Combustibles Administrative controls have been established to minimize the amount of combustibles that a safety-related area may be exposed to, and to assure that these items are not stored in safety-related areas and an assessment of the need for additional suppression equipment for transient fire loads.
Station procedures have been established to ensure that fire-retardant lumber of good abrasion resistance is used inside Duildings containing safety-related systems.
We find that the control of cnmbustibles conforms to the provisions of Appendix A to BTP 9.5-1 and is, therefore, acceptable.
6.4 Control of Ignition Sources The control of ignition sources instituted are to protect safety-related equipment from fire damage or loss resulting from work invoiving ignition sources, such as welding, cutting, grinding, or open flame work.
Administrative controls established require review and approval by a responsible supervisor prior to performing cutting, weldirg, grindir,g, or open flame work; proper removal or covering of combust'ble material use of trained and equipped fire watches; signature concurre.'ce; acceptable methods of leak testing; and restrictions on smoking in safety-related areas.
We find that the control of ignition sources conforms to the provisions of Apoendix A to BTP 9.5-1 and is, therefore, acceptable.
6.5 Fire Fighting Procedures The licensee has provided an adequate description of its current fire fighting procedures, those under development and those planned to be developed in the near future.
Fire fighting procedures / plans a '
established to cover such items as notification of a fire, fire emergency procedures, coordination of fire fighting activities with offsite fire departments, strategies for fighting fires in all safety-related areas and areas presenting a hazard to safety-related equipment.
Provisions have been made for including offsite fire fighting organizations in fire brigade drills and training as required.
6-2 l}bb 099
We find that the control of fire fighting procedures conforms to the provisions of Appendix A to BTP 9.5-1 and is, therefore, acceptable.
6.6 Quality Assurance The method by which the design, procurement, installation, testing and administrative control activities for the fire protection Quality Assurance (QA) program criteria of Appendix A to BTP 9.5-1 or Regulatory Guide 1.120 will be controlled has been identified. The method used to meet the aforementioned criteria will be described. Audits will be performed annually to provide an overall assessment of conformance to fire protection requirements.
We find that, subject to implementation of the described changes, the Quality Assurance conforms to the provisions of Appendix A to BTP 9.5-1 and is, therefore, acceptable.
f f bh
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7.0 TECHNICAL SPECIFICATIONS The Technical Specifications have previously been modified to incorporate interim Technical Specifications which include limiting conditions for operation and surveillance requirements for existing fire protection systems and administrative controls.
The resolution of the open items as indicated in our letter dated February 14, 1978, which transmitted Amendment Nos. 20 and 26 and established the interim Technical Specifications, has been completed.
Following the implementation of the modifications of the fire protection systems resulting from this review, the Technical Specifications will be similarly modified to incorporate the limiting conditions for operation and surveillance requirements for these modifications.
1166 101 7-1
8.0 CONCLUSION
S The licensee has performed a fire hazards analysis and has proposed certain modifications to improve the fire protection program.
Additional modifications have been propcsed 'y the licensee during the course of our o
review, which are based upon the fire hazards analysis and our onsite evaluation of the fire protection program.
These proposed modifications are summarized in Section 3.1.
In addition, we have concluded that the licensee should implement certain evaluations or improvements related to the fire protection program.
These are summarized in Section 3.2.
Significant steps are being taken to provide additional assurance that safe shutdown can be accomplished and the plant can be maintained in a safe shutdown during and following potential fire situations.
Additional evaluation of incomplete items, discussed in the preceding sections, will be necessary before we can conclude that the overall fire protection at the Prairie Island Nuclear Generating Plant will satisfy tne provisions of BTP 9.5-1 and Appendix A thereto, which the staff has established for satisfactory long-term fire protection.
We find that the licensee's proposed modifications described herein are acceptable both with respect to the improvements in the fire protection program that they provide and with respect to continued safe operation of the facility, while the remaining items are completed.
In the report of the Special Review Group on the Browns Ferry Fire (NUREC-0050) dated February 1976, consideration of the safety of operation of all opcrating nuclear power plants pending the completion of our detailed fire protection evaluation was presented.
The following quo-tations from the report summarize the basis for the Special Review Group conclusions 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 infrequent (see Section 3.3 of [NUREG-0050]).
The Review Group believes that steps already taken since March 1975 (see Section 3.3.2) have reduced this frequency significantly.
" Based on its review of the events transpiring before, during, and after the Browns Ferry fire, the Review Group concludes that the probability of disruptive fires of the magnitude of the Browns Ferry event is small, and that there is no need to restrict operation of nuclear power plants for public safety.
- However, it is clear that much can and should be done to reduce even further the likelihood of disabling fires and to improve assurance of rapid extinguishment of fires that occur.
Consideration should be given also to features that would increase further the ability of nuclear facilities to withstand large fires without loss of important functions should such fires occur."
8-1
We recognize that the " Risk Assessment Review Group Report to the U. S.
Nuclear Regulatory Commission," NUREG/CR-0400 (The Lewis Committee Report),
states that this Review Group is unconvinced of the correctness of the WASH-1400 conclusion that fires contribute negligibly to the overall risk of nuclear plant operation.
In the Commission's Policy Statement dated January 18,1979, "NRC Statement on Risk-Assessment and the Reactor Safety Study Repcrt (WASH-1400) in Light of the Risk-Assessment Review Group Report", the Commission indicated on page 3 that it " accepts the Review Gr Report's conclusion that absolute values of the risks presented by WASH-14.oup 00 should not be used uncritically either in the regulatory process or for public policy purposes and has taken and will continue to take steps to assure that any such use in the past will be corrected as appropriate.
In particular, in light of the Review Group conclusions on accident probabil-ities, the Commission does not regard as reliable the Reactor Safety Study's numerical estimate of the overall risk of reactor accident."
Our conclusion that the operation of the facility, pending resoltuion of the incomplete items and the implementation of all facility modifications, does not present an undue risk to the health and safety of the public is based on our concurrence with the Special Review Group's conclusions identified above giving due consideration to the Commission policy state-ment as well as the significant improvements in fire protection already made at the facility since the 3rowns Ferry fire.
These include establish-ment 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 surveillanct reouirements on fire protection systems.
We have determined that the license amendment does not authorize a change in effluent types or total amounts nor an increase in power level and will not result in any significant environmental impact.
Having made this determination, we have further concluded that the amendments involve an action which is insignificant from the standpoint of environmental impact and pursuant to 20 CFR 51.5(d)(4) that an environmental impact statement or negative daclaration and environnental impact appraisal need not be prepared in connection with the issuance of this amendment.
We have concluded, based on the considerations discussed above, that:
(1) because the amendments do not involve a significant increase in the probability or consequences of accidents previously considered and do not involve a significant decrease in a safety margin, the amendments do not involve a significant hazards consideration, (2) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (3) such activities will be conducted in compliance with the Commission's regulations and the issuance of these amendments will not be inimical to the common defense and security or to the health and safety of the public.
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8-2
9.0 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 in the preparation of the Safety Evaluation Report (SER).
Their report, " Fire Protection in Operating Nuclear Power Stations, Prairie Island 1 and 2 Safety Evaluation Report Review," dated June 21, 1979, discusses several matters which have been addressed in the SER.
The consultants' report contains two recommendations one of which (portable gas cylinder) has, for the most part, been implemented during our evaluation.
The consultants' recommendation which we have not adopted, along with our basis therefore, is identified in Appendix "B."
f } bh
} I)4 9-1
APPENDIX A CHRON0 LOGY In February 1976, the report by the NRC Special Review Group was issued as NUREG-0050, "Racommendations Related to the Browns Ferry Fire."
On May 1, 1976, Standard Review Plan 9.5.1, " Fire Protection," was issued incorporating the various recommendations contained in NUREG-0050.
By letter dated May 11, 1976, licensee was required to compare the existing fire protection provisions at their facilities with new NRC guidelines as set forth in Standard Review Plan BTP 9.5.1 " Fire Protection," cated 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.
By letter dated September 30, 1976, licensee was requested to provide the results of a fire hazards analysis and propose Technical Specifications pertaining to the present fire protecticn systems.
Licensee was also provided a copy of Appendix A which includes acceptable alternatives to the guidelines of BTP 9.5.1.
By letter dated December 6, 1976, we provided model Technical Specifica-tions as guidance for the fire protection Technical Specifications requested in our September 30, 1976 letter.
By letter dated December 8, 1976 and supplemented by July 5, 1977 and July 26, 1978 letters, the licensee responded to staff's letter of May ?'
1976.
By letters dated March 11 and July 5,1977, the licensee submitted t' Fire Hazards Analysis.
By letter dated July 31, 1977, the licensee.
to the Technical Specifications requested in our December 6, 1976 le" By letter dated December 2, 1977, the licensee was sent proposed T-mu Specifications and requested to respond in 20 days with any object The licensee's response dated December 22, 1977 amended the applicuic a of January 31, 1977.
Technical Specifications for the present fire ~atecti systems were issued by Amendment Nos. 20 and 26 dated February.
197L.
On January 31, 1978, we provided the licensee with our initial revie
,f their Fire Hazards Analysis.
By letter dated February 6, 1978, we provided a copy of an NRC do ume;.
entitled, " Nuclear Plant Fire Protection Functional Respon3ibilit,c Administrative Controls, and Quality Assurance."
By letter dated April 18, 1978, the licensee responded to o.-
k ' e vf January 31, 1978.
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By letter dated May 2, 1978, the licensee provided a revised fire protection program outline which addressed certain NRC staff concerns related to their May 18, 1978 submittal.
By letter dated May 18, 1978, the licensee provided their response to our document antitled, " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls, and Quality Assurance," transmitted by our letter dated February 6, 1978.
By letter dated June 22, 1978, the licensee provided a response to the staf f's document, " Manpower Requirement for Operating Reactors," as requested by the staff's letters of May 22 and June 5,1978.
On September 13 and 19, 1978, we telecopied the licensee a request for additional fire protection program information.
On October 16 to 20, 1978, the fire protection team visited the site to review the fire protection system used at the plant.
By letter dated November 8, 1978, the licensee formally responded to our telecopied requests of September 13 and 19, 1978.
On November 21, 1978, we provided the licensee a list of additional staff concerns and positions.
By letters dated January 2 and March 9, 1979, the licensee submitted their completed review of the staff's positions contained in the November 21, 1978 letter.
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o 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 Stations - Prairie Island 1 and 2 Safety Evaluation Report Review," discusses a recommendation which we have not adopted.
The consultants' recommendation which we have not adopted, along with our basis therefor, is id*ntified herein.
Consultants' Comment:
Valve Supervision
" Electrical valve supervision should be provided on all valves controlling fire water systems and sectionalizing valves.
The present proposal of administrative controls or locks is unacceptable."
Staff Response The NRC guidelines on 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 program 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 addition, the plant technical specifications will require a monthly check of all valves in the flow path to fire suppression systems, to ensure that each valve is in the correct position.
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