ML19261F389
| ML19261F389 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 09/28/1979 |
| From: | Sylvester E Office of Nuclear Reactor Regulation |
| To: | Benaroya V, Lainas G Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7910260061 | |
| Download: ML19261F389 (4) | |
Text
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7TRD gp 2 81979 NRC PDR l
DSB Reading i
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j MEMORANDUM FOR:
G. Lainas, Chief, Plant Systens Branch, DOR V. Benaroya, Chief, Auxiliary Systems Branch, DSS FROM:
E. Sylvester, Plant Systems Branch, 00R l
SUBJECT:
NRR FIRE PROTECTI0il REVIEW GROUP - CALVERT CLIFFS ISSUES AND RULEf1AKING L
A neeting of the Fire Protection Review Group was held on September 21, 1979 l
to clarify the intent / basis for certain requirements in Appendix A to BTP 9.5-1 that are unresolved issues in the Calvert Cliffs fire review and to discuss the current fire protection rulemaking effort. Attendees 3
at this meeting are listed in Enclosure 1.
Background infomation on the Appendix A items of interest was transmitted to the Review Group by letter dated Septenber 20, 1979.
The Review Group comnents on the i
Appendix A itens and the rulenaking effort are provided in Enclosure 2.
l I
E. Sylvester
{
PPlant Syttens Cranch i
Division of Operatino Reactors i
Enclosures:
As stated
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cc w/ enclosures:
D. Eisenhut
- 3. Grimes V..'toore T. Lee P. Tan, ACRS G. Cunninghan, OELD 4
R. Ferguson f^
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R. Voegeli I. E L,_ J.
S. Burns T. Wambach D. Notley 4q1/
31'4 S. Hudson u.
Harrison eme= 4...Syl.vester..
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ENCLOSURE 1 ATTENDEES FIRE PROTECTION REVIEW GROUP MEETING SEPTEMBER 21, 1979 R. Voegeli - OELD S. Burns - 0 ELD R. Ferguson - NRR/D0R T. Wambach - NRR/ DOR
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D. Notley - OSD/ DES S. Hudson - NRR/ DSS G. Harrison - NRR/ DSS E. Sylvester - NRR/ DOR l9'7 3}b
ENCLOSURE 2 g
NRR FIRE PROTECTION REVIEW GROUP MINUTES OF MEETING SEPTEMBER 21,.,19 The Review Group met to discuss the basis / intent of certain requirements of Appendix A to BTP 9.5-1.
These requirements were used to derive staff positions in th. Calvert Cliffs review which are being contested by the licensee.
The Review Group also discussed the status of the current fire protection rulemaking effort. The Review Group comments are provided below.
1.
Halon System Backup Power Sect.on E.1.(d) of Appendix A requires that fire suppression actuation systems be connected to the plant emergency power supply.
- Further, Section E.4 requires that l51on systems comply with NFPA 12 which requires capability for emergency manral operation.
The Halon systems in certain equipment cabinets at Calvert C'iffs are powered from the normal AC system, and are not backed up by aergency AC power.
The Calvert Cliffs Halon systems require electrics 1 power for manual opcration.
The NRC staff position for Calvert Cliffs requires that these Halon systems be provided with backup cnsite power.
The Review Group after discussion of the intent of the Appendix A requirements for automatic Halon suppression systems, concluded that the requirements for backup power depends on the application, i.e.:
(a)
If the Halon suppression system is used to pr3tect single divisions of safe shutdown equipinent, backup power is not necessary provided a backup suppression method is available on loss of offsite power; and (b)
If the Halon suppression system protects a space containing redundant divisions of safe hot shutdown equipment, backup power supplies for Halon suppression systems are needed.
The power supply and controls for the Halon system should be outside the area to be protected.
(Note: Total reliance should not be placed on the Halon system to preserve safe shutdown capability.)
2.
Emergency Lighting Section D.5.(a) of Appendix A requires fixed emergency lighting units having individual 8-hour battery power supplies.
The Calvert Cliffs licensee proposes the use of fixed 1-1/2 hour capacity lights backed up by portable lights of greater capacity.
The Review Group concluded 1H 7 316
. that the staff should continue to require fixed units with 8-hour individual battery capacity ur.til it is demonstrated that a lesser capability will conservatively assure adequate lighting for access, egress, fire fighting activities and plant operations for all postulated fires.
3.
Fire Pump Separation Section E.2.(c) of Appendix A requires that fire pumps be separated from the " remaining pumps" by three ocur barriers.
Corresponding Section 5.b.(3) of Regulatory Guide 1.120 requites that fire pumps be separated from the " remaining fire pumos" by 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> barriers. A staff position requires that the redundant Calvert Cliffs fire pumps be separated from each other oy 3-hour fire barriers.
Three Review Group members, Messrs. Notley, Harrison and Sylvester agreed that the intent of the Appendix A guidelines is to separate redundant fire pumps from each other.
The basis for this conclusion is the requirement in Appendix A that a single failure of a fire suppression system should not incapacitate both the primary and backup fire suppression capability in a safety-related area.
If the single failure is assumed to be a leak in the diesel fire pump fuel system, a diesel fuel fire could then damage redundant pumps
-1 these pumps are not separated from each other by an adequate barrier.
This single failure could occur when fire pumps are needed to supply fire suppression water to a fire in a safety related area.
Mr. Wambach dissented from the above finding on the basis that: (1)
Appendix A guidelines do not require postulation of more than one fire at a time, and (2) a fire at the diesel fire pump would require multiple failures to get leakage from the fuel system 2nd ignition of the fuel.
4.
Rulemaking A preliminary draft of the proposed rule was distributed to the meeting attendees by Mr. Notley prior to the meeting, along with suggested modifications to the draft prepared by Mr. Ferguson.
Some of the requirements in the preliminary draft were written in general terms so as to be applicable to both operating plants and new plants.
Mr. Voegeli suggested that consideration be given to writing the requirements in two sections, with separate applicability for old and new plants, to provide for more specific requirements.
It was generally concluded that the proposed rule be redraf ted to include the mocifica-tions requested by Mr. Ferguson and that the proposed requirements be limited to those items being contested by licensees. Mr. Notley will redraft the proposed rule and distribute it for internal NRC review by September 25, 1979.
A meeting will be held on September 28, 1979 to discuss the revised draft of the rule.
1'"7 31/
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