ML19270H292
| ML19270H292 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 05/23/1979 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19270H286 | List: |
| References | |
| NUDOCS 7906260141 | |
| Download: ML19270H292 (53) | |
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UNITED STATES f,,
,k NUCLEAR REGULATORY COMMISSION
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WASHINGTON, D. C. 20555 ew-4.....
FIRE PROTECTION SAFETY EVALUATION REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION IN THE MATTER OF NEBRASKA PUBLIC POWER DISTRICT COOPER fiUCLEAR STATION - UNIT 1 DOCKET fl0. 50-298 2314 228 f
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TABLE OF CONTENTS PAGE
1.0 INTRODUCTION
1 -1 2.0 F IRE PROTECTION GU IDEL INES.......................................
2-1 2.1 General Design Criterion 3
" Fire Protection"..............
2-1 2.2 S u p pl eme n t a ry Gu i da nc e......................................
2-1 3.0
SUMMARY
OF MODIFICATIONS.........................................
3-1 3.1 Sel f Contained Breathi ng Apparatus..........................
3-1 3.2 Emergency Radio-Communication...............................
3-1 3.3 D i e s el F i re P um p............................................
3-1 3.4 House Boiler Room...........................................
3-1 3.5 Diesel Generator Room.......................................
3-2 3.6 Cable Chase - Turbine Building North Wa11...................
3-2 3.7 MG S et O il C oo 1 er s..........................................
3-2 3.8 Reactor Building Cable Trays -
Northeast Corner - EL 903'..................................
3-2 3.9 Battery Rooms...............................................
3-2 3.10 Turbi ne Building 011 Isolation..............................
3-3 3.11 Reactor and Control Building Automatic Suppression Water Feed......................................
3-3 3.12 C abl e Ex pa ns i o n Ro om........................................
3-3 3.13 Ma nual Foam Su ppre s si o n.....................................
3-3 3.14 MG S et C u r b i n g..............................................
3-3 3.1 5 C o n t ro l R o c m................................................
3-3 3.16 P en etra tio n Barri e rs........................................
3-4 3.17 F i re A l a rm Sy s t em...........................................
3-4 3.18 Control Building Corridor - EL 903 '.........................
3-4 3.19 L au nd ry R oom A rea...........................................
3-4 3.20 Air Compressor Room - Curbi ng...............................
3-4
- 3. 21 I nstrument S to rag e Room.....................................
3-4 3. 2 2 F i r e B ri g a d e................................................
3-4 3. 2 3 Smo k e Ej e c t o r s..............................................
3-5 3.24 Hydrant Fittings............................................
3-5 3.25 Hose House Equipment........................................
3-5 3.26 Orip Protection for Certain Vital Switch Gear...............
3-5 3.27 Fire Pump Discharge Header..................................
3-5 3.28 R eac tor Buil ding - EL 9 76 '..................................
3-5 3.29 Fire-Rated-Docrs............................................
3-6 3.30 Fire Hose Stations..........................................
3-6 2314 229 PAGE 3.31 Fire Hoses and Racks........................................
3-6 3.32 Administrative Procedures for Fire Doors....................
3-6 3.33 HVAC Ducting................................................
3-6
- 3. 34 Control Val ves for HEPA Fil ters.............................
3-6 3.35 Sectional Control Va1ves....................................
3-6 3.36 Fire Hose Nozzles...........................................
3-6 3.37 Radwaste Building...........................................
3-6 Table 3.1 Implementation Dates for Proposed modifications........
3-7.
4.0 EVALUATION OF PLANT FEATURES.....................................
4-1 4.1 Safe Shutdown Systems.......................................
4-1 4.2 Fire' Detection and Signaling System.........................
4-1 4.3 Fire Control Systems........................................
4-2 4.3.1 Water Systems........................................
4-2 4.3.1.1 Water Supp1y................................
4-2 4.3.1.2 Fire Pumps..................................
4-2 4.3.1.3 Fire Water Piping System....................
4-3 4.3.1.4 Interior Fire Hose Stations.................
4-4 4.3.1.5 Automatic Water Suppression Systems.........
4-4 4.3.1.6 Foan Suppression System.....................
4-5 4.3.1.7 Effects of Suppression System on Safety Systems...........................
4-5 4.3.2 Gas Fire Suppression Systems.........................
4-5 4.3.3 Portabl e Fire Extingui shers..........................
4-6 4.4 Ventilation Systems and Breathing Equipment.................
4-6 4.4.1 S mo k e R em o v a l........................................
4-6 4.4.2 Filters..............................................
4-6 4.4.3 Breathing Equipment..................................
4-6 4.5 Floor Drains................................................
4-7 4.6 Lighting Systems............................................
4-7 4.7 Communications Systems......................................
4-7 4.8 El ectrical Cabl e Combu sti bil ity.............................
4-8 4.9 F i re Ba rri e r Penetra ti o n s...................................
4-8 4.9.1 Electrical Cabl e and Conduit Penetrations............
4-8 4.9.2 Fire Doors...........................................
4-8 4.9.3 Ventilation Duct Penetrations........................
4-9 4.10 S epa ra ti o n C ri te ri a.........................................
4-9 4.1 1 F i r e B a r r i e r s...............................................
4-9 4.12 Non sa fety-Rel a ted A rea s.....................................
4-9 4.1 3 I n s t r um e n t A i r..............................................
4-10 4.14 A cc e s s a n d Eg re s s...........................................
4-10 4.15 Toxic and Corro sive Ccmbustion Products.....................
4-10 2314 230
_ii.
PAGE 5.0 EVALUATION OF SPECIFIC PLANT AREAS...............................
5-1 5.1 Cable Spreading Room........................................
5-1 5.2 D ie sel G enera to r R oom s......................................
5-2 5.3 Battery Rooms...............................................
5-3 5.4 Laundry Room Area - Controll ed Access Corridor..............
5-5 5.5 Air Compressors - Control Building Basement.................
5-6 5.6 Control Room................................................
5-7 5.7 C a bl e Ex pa n s i o n R oom........................................
5-8 5.8 Intake Structure............................................
5-9 5.9 Turbine Building............................................
5-10 5.10 Reactor Building Elevation 859'-9" (Quads)..................
5-12 5.11 Reactor Building El evation 903 '-6"..........,...............
5-12 5.12 Reactor Building Elevation 931 '-6"..........................
5-13 5.13 Reactor Building Elevation 958'-3"..........................
5-15 5.14 Reactor Building El evation 976'-0"..........................
5-16 5.15 Reactor Building El evation 1001 '-0".........................
5-17 5.16 Radwaste and Augmented Radwaste Buildings...................
5-17 5.17 Yard Area...................................................
5-18 6.0 ADMINISTRATIVE CONTR0LS..........................................
6-1 7.0 TECHNICAL SPECIFICATIONS.........................................
7-1
8.0 CONCLUSION
S......................................................
8-1 9.0 CONSULTANTS REP 0RT...............................................
9-1 Appendix A Chronology..................................................
A-1 2314 231
-iii-
1.0 If1TRODUCTI0f1 Following a fire at the Browns Ferry fluclear Station in March 1975, the fluclear 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 f4RC, in Feburary 1976, published a report by a special review group entitled, " Recommendations Related to Browns Ferry Fire," fiUREG-0050.
This report recommended that improvements in the areas of fire prevention and fire control be made in nost existing facilities and that consideration be given to design fea-tures that would increase the ability of nuclear facilities to withstand fires without the loss of important functions.
To implement the report's recommendations, the f;RC initiated a program for reevaluation of the fire protection programs at all licensed nuclear power stations and for a com-prehensive review of all new license applications.
The f4RC issued new guidelines for fire protection programs in nuclear power plants which reflect the recommendations in f;UREG-0050. These guidelines are contained in the following documents:
a.
" Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plant," NUREG-75/087, Section 9.5.1, " Fire Protection,"
May 1976, which includes " Guidelines for Fire Protection for fluclear Power Plants" (BTP APCSB 9.5-1), May 1, 1976.
b.
" Guidelines for Fire Protection for fluclear Power Plants" (Appendix A to BTP APCB 9.5-1), August 23, 1976.
c.
" Supplementary Guidance on Information Needed for Fire Protection Program Evaluation," October 21, 1976.
d.
" Sample Technical Specifications," May 12, 1977.
e.
"fluclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance," June 14, 1977.
f.
" Manpower Requirements for Operating Reactors," memo from E. G. Case to R. Boyd, V. Stello, and R. Mattson dated May 11, 1978.
All licensees were requested to:
(1) compare their fire protection programs with the new guidelines; and (2) analyze the consequences of a postulated fire in each plant area.
2314 232 1-1
We have reviewed,the licensee's analyses and have visited the plant to examine the relationship of safety-related components, systems and structures with both combustibles and the associated fire detection and suppression systems.
Our review has been limited to the aspects of fir?
protection within the NRC's jurisdiction, i.e., those aspects related to the protection of public health and safety.
Ve have not considered aspects of fire protection associated with life safety of onsite per-sonnel and with property protection unless they impact the health and safety of the public due to potential release of radioactive material.
This report summarizes the status of our evaluation of the fire protection program at Nebraska Public Power District's Cooper.'4uclear Station.
9 O
2314 233 1-2
2.0 FIRE PROTECTION GUIDELINES 2.1 General Desion 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 reauirements, the probability and effect of fires and explosions.
" Noncombustibles and heat resistant raterials shall be used wherever practical throughout the unit, particularly in locations such as the containment and the control room.
" Fire detection and protection 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 signifi-cantly impair the safety capability of these structures, systems, and components. "
2.2 Sucolementary Guidance Guidance on the implementation of GDC-3 for existing nuclear power plants has been provided by the NRC staff in "Apoendix A" of Branch Technical Position 9.5-1, " Guidelines for Fire Protection for Nuclear Power Plants. "
Appendix A provides for a comprehensive program assuring a substantial level of fire protection, beyond nininums that might be deemed to satisfy GDC-3.
The overall objectives of the fire protection program embodied in BTP 9.5-1 and Appendix A, are to:
(1) reduce the likelihood of occurrence of fires; (2) promptly detect and extinguish fires if they occur; (3) maintain the capability to safely shut down the plant if fires occur; and 2314 234 2-1
(4) prevent the release of a significant amount of radioactive material if fires occur.
We have used the guidance of Appendix A as approoriate in our review.
We have evaluated ' alternatives proposed by the licensee to various specific aspects of Appendix A using the overall objectives outlined above to assure that these objectives are met for the actual relation-ship of combustibles, safety related equipment and fire protection features of the facility.
2314 2L35 e
2-2
3.0 SU"FARY OF MODIFICATIONS The licensee plans to make certain plant modifications to improve the fire protection program as a result of both his and the 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 sections 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 to the actual implementation of these modifications. The balance of the other modifications has been described in an acceptable level of detail.
3.1 Self Contained Breathing Apparatus (4.4.3)
An on-site six hour supply of reserve air will be provided for ten men.
3.2 Emeroency Radio-Communication (4.7)
Three portable radios will be provided for fire emergency situations.
3.3 Diesel Fire Pump (4.3.1) (5.8)
- 3. 3.1 Foam Suppression & Automatic Sprinkler Systems Automatic sprinkler and foam suppression systems will be supplied for the diesel fire pump.
Feed to the foam suppression system will be independent of the feed to the sprinkler system (4.3.1.2).
3.3.2 Fuel Oil Line The fuel oil lines for the diesel fire pump engine will be relocated so as not to pose an oil spill fire hazard to the service water pumps and the two electric fire pumps.
3.4 House Boiler Room (5.2)
A dike or scme method of drainage will be provided between the diesel generator room, 1B, and the house boiler room.
2314 236 3-1
3.5 Diesel Generator Room (5.2) 3.5.1 Floor Dike The existing double Class A fire door between diesel generato.r rooms lA and 1B will be modified and the dike will be extended underneath these doors.
3.5.2 Fire Door Suoervision Electrical Supervision with communication to the control room will be provided for the double fire doors separating the two diesel generator rooms.
3.5.3 Abort Switch Annunciation Annunciation will be provided in the control rocm for the abort switches for the high pressure carbon dioxide extinguishing systems in thc diesel generator rooms.
- 3.6 Cable Chase - Turbine Building North Wall (5.9)
A sprinkler system will be provided for coverage of cable chase and penetrations in the north wall of the turbine building.
- 3.7 MG Set 011 Coolers An automatic suppression system will be provided over the oil system heat exchangers for the MG sets on elevation 932' in the northwest corner of the reactor building.
- 3.8 Reactor Building Cable Trays - Northeast Corner - El. 903' (5.12)
An automatic suppression system will be installed in the northeast corner of the reactor building at elevation 903' to preclude the possibility of a fire affecting redundant sets of cable trays.
3.9 Battery Rocms (5.3) 3.9.1 Fire Detection An additional smoke detector will be installed in each battery room.
3.9.2 Air Flow Monitoring Air flow supervision will be provided in the exhaust ducts of each battery room.
2314 237 3-2
3.9.3 Conduit Risers - Room 18 A one hour fire barrier enclosure will be provided for the conduit risers in battery room 18.
3.10 Turbine Building Oil Isolation (5.9)
A drain system will be provided to prevent overflowing of the existing dike in the turbine oil reservoir room.
- 3.11 Reactor and Control Building Automatic Suppression Water Feed (4.3.1.3)
An independent feed for autcmatic suppression systems in the reactor building and the control building will be provided.
- 3.12 Cable Expansion Room (5.7)
An automatic suppression system will be provided to protect redundant cabling in the cable expansion room.
3.13 Manual Foam Suopression (4.3.1.6) (5.5) (5.17)
Manual foam suppression capability will be provided for the oil hazards in various areas of the plant.
3.14 MG Set Curbing (5.14)
Curbing will be provided between the MG sets on elevation 976'.
3.15 Control Room (4.3.3) (5.6) 3.15.1 Kitchenette A photoelectric cell will be provided for smoke Jetection in the kitchenette $n the control room.
- 3.15.2 Particle Board Wall Certification will be obtained or tests performed to show that the particle board used in the control room has acceptable flame spread and smoke spread ratings.
3.15.3 Portable Fire Extinauishers Two 24 gallon portable pressurized water fire extinguishers will be provided for the control room.
2314 238 3-3
3.la Penetration Barriers (4.9) (5.9)
Information relating to the adequacy of the penetration barriers will be provided.
3.17 Fire Alarm System (4.2)
Electrical supervision will be provided for the initiating circuits for the high pressure CO systems protecting the diesel generator 2
rooms.
3.18 Control Building Corridor - EL 903' (6.0)
Administrative procedure will be provided to control the combustibles in the corridor of the control building on elevation 903'.
In addition, signs will also be posted in this area.
- 3.19 Laundry Room Area (5.4)
An automatic sprinkler system will be provided throughout the laundry room area and in the adjacent control access corridor.
3.20 Air Compressor Room - Curbina (5.5)
Curbs will be provided around the conduit risers adjacent to the south wall and in front of the manways adjacent to the east wall.
3.21 Instrument Storage Room (5.3)
An automatic sprinkler system will be provided for the instrument storage room.
3.22 Fire Brigade (6.0) 3.22.1 Staff for Brigade A trained five man fire brigade will be available onsite during all shifts for fire situations.
3.22.2 Fire Brigade Chief An Administrative Procedure defining)the responsibilities of the Fire Brigade Chief (Shift Supervisor during a fire emergency situation will be provided.
2314 239 3-4
3.23 Smoke Ejectors (4.4.1)
Three 5,000 CFM portable explosion proof fire service smoke ejectors with suitable ducting will be provided.
3.24 Hydrant Fittinos (4.3.1.3)
A 2-1/2 inch gated fitting will be provided for each yard hydrant outl et.
3.25 Hose House Equipment (4.3.1.3) (5.17)
In addition to the equipment already provided in the hose houses, two hose carts with the following capability will also be provided onsite:
250 feet of 2-1/2 inch hose; 200 feet of 1-1/2 inch hose; one 2-1/2 inch by 1-1/2 inch by 1-1/2 inch gated Y; one 2-1/2 inch adjustable spray nozzle; two 1-1/2 inch adjustable spray nozzles; forceable entry tool; hose clamp; gaskets (two spare for each size hose); minimum, two universal spanner wrenches, two hydro wrenches, one each 2-1/2 inch male to male adapter, and 1-1/2 inch male to male adapter; one each 2-1/2 inch female to female adapter; and a 1-1/2 inch female to female adapter.
3.26 Drip Protection for Certain Vital Switch Gear (4.3.1.7)
Overhead drip protection will be provided for vital switch gear in areas where manual suppression is the prime means of extinguish-ment, or automatic suppression systems have been installed above the switch gear.
- 3.27 Fire Pumo Discharge Header (4.3.1.3)
An isolation valve will be installed to permit the isolation of redundant fire pumps.
3.28 Reactor Building - EL 976' (5.14) 3.28.1 Diking A minimum of 4-inch high di' King will be installed along column line 8.2 between Columns N&P and at the doorway to the northwest stairtower.
3.28.2 Trapped Floor Drains (4.5) (5.13)
The need for additional floor drains in the reactor building (includes MG, set area) will be evaluated.
3-5
3.29 Fire-Rated-Doors (4.9.2) (5.12)
The non-fire-rated double doors separating the two 4160V initial switchgear rooms (reactor building, 932' elevation) will be replaced with fire rated doors.
3.30 Fire Hose Stations (4.3.1.4)
Four additional fire hose stations will be added in the reactor building; one each at northwest and southwest corners of the 931' elevation and at northwest and southwest corners of 976' elevation.
3.31 Fire Hoses and Racks (5.15)
The fire hoses will be changed from 75 foot to 100 foot hoses and the hose racks to hose reels at:
(1) the northwest and southwest corners of the 1,001' elevatNn of the reactor building; and (2) the 903' elevation and the 931 clevation of the control building.
3.32 Administrative Procedures for Fire Doors (6.0)
Administrative procedures will be established for the control of fire doors associated with safety-related areas.
3.33 HVAC Ducting (4.9.3) (5.6)
A fire and smoke barrier will be provided around the HVAC ducting to the control roca on the 931' elevation of the control building.
3.34 Control Valves for HEPA Filters (5.16)
The non-indicating control valves for the HEPA filters waterspray system of the augmented radwaste building will be replaced with 0.S. & Y. type indicating valves.
3.35 Sectional Control Valves (4.3.1.3)
Approved chain actuators will be provided for all sectional control valves which are not easily accessible.
3.36 Fire Hose Nozzles (4.3.1.4)
Existing fire hose nozzles will be replaced with the proper nozzles approved for Class A, B, and C fires.
3.37 Radwaste Building (5.16)
Wet-pipe automatic sprinkler protection wiil be provided to corridor V on the 918' elevation of the radwaste building.
2314 241 3-6
Table 3.1 Implementation Dates for Proposed Modifications
";difications Implementation Dates 3.1 Self Contained Breathing Apparatus December 1,1979 3.2 Emergency Radio-Communication Completed 3.3 Diesel Fire Pump
- 3. 3.1 Foam Suppression.
December 1,1979 3.3.2 Fuel Oil Line December 1,1979 3.4 House Boiler Room March 1, 1979 3.5 Diesel Generator Rocm 3.5.1 Floor Dike May 1, 1979 3.5.2 Fire Door Supervision June 1, 1979 3.5.2 Abort Switch Annunciation December 1,1979
- 3.6 Cable Chase - Turbir.c Building North Wall December 1,1979
- 3.7 MG Set Oil Coolers December 1,1979
- 3.8 Reactor Building Cable Trays -
December 1,1979 Northeast Corner - EL 903' 3.9 Battery Rooms 3.9.1 Fire Detection July 1, 1979 3.9.2 Air Flow Monitoring December 1,1979 3.9.3 Conduit Risers - Room 18 July 1,1979 3.10 Turbine Building 011 Isolation July 1,1979
- 3.11 Reactor and Control Building Automatic July 1,1980 Suppression Water Feed
- 3.12 Cable Expansion Room December I,1979 3.13 Manual Foam Suppression May 1, 1979 3.14 MG Set Curbing July 1, 1979 3.15 Control Room 3.15.1 Kitchenette December 1,1979
- 3.15.2 Particle Board Wall December 1,1979 3.15.3 Portable Fire Extinguishers Completed 3.16 Penetration Barriers December 1,1979 3.17 Fire Alarm System December 1,1979 3.18 Control Building Corridor - EL 903' Compl eted
- 3.19 Laundry Room Area December 1,1979 3.20 Air Compressor Room - Curbing March 1,1979 3.21 Instrument Storage Room December 1,1979 3.22 Fire Brigade 3.22.1 Staff for Fire Brigade July 1,1979 3.22.2 Fire Brigade Chief Ccmpl eted 3.23 Smoke Ejectors March 1,1979 3.24 Hydrant Fittings March 1, 1979 3.25 Hose House Equipment
'iarch 1,1979 3-7 2314 242
Modifications Implementation Dates 3.26 Drip Protection for Certain Vital December 1, 1979 Switch Gear
- 3.27 Fire Pwnp Discharge Header December 1, 1979 3.28 Reactor Building - EL 976' 3.28.1 Diking July 1,1979 3.28.2 Trapped Floor Drains December 1, 1979 3.29 Fire-Rated-Doors December 1,1979 3.30 Fire Hose Stations December 1,1979 3.31 Fire Hoses and Racks July 1,1979 3.32 Administrative Procedures for Fire Doors April 1, 1979 3.33 HVAC Ducting December 1,1979 3.34 Control Valves 'for HEPA Filters Completed 3.35 Sectional Control Valves Completed 3.36 Fire Hose Nozzles C mpleted 3.37 Radwaste Building December 1,1979 2314 243 3-8
- 4. 0 EVALUATION OF PLANT FEATURES 4.1 Safe Shutdown Systems There are several arrangements of safe shutdown systems which are capable of shutting down the reactor and cooling the core during and subsequent to a fire.
The exact arrangement available in a fire situation will depend upon the effects of the fire on such systems, their power supplies, and control stations.
To preclude a single event from affecting redundant systems these systems are separated into two safety divisions either of which are capable of achieving safe shutdown.
During or subsequent to a fire, safe shutdown could be achieved using safety-related equipment such as:
the reactor trip system; the reactor core isolation cooling system or the high pressure coolant injection system; the depressurization system; emergency condensate storage tanks; and the residual heat removal system.
Supporting systems and equipment such as the emergency diesel generators, engineered safety feature batteries, service water system, diesel generator building ventilation system, and residual heat removal room coolers would also be required.
We have evaluated the separation between redundant safe shutdown systems and components to determine that they are either separated from each other or protected by suppression systems such that a fire will not affect redundant equipment, and therefore a sufficient number of systems and components will be available to perform the shutdown function following a fire.
The adequacy of separation between redundant equipment is discussed in other sections of this report.
4.2 Fire Detection & Signaling Systems An extensive fire detection and signaling system is provided throughout many areas of the plant which transmit alarm and supervisory signals to the control room.
Supervisory signals are provided to indicate the locatior of the affected area of the unit.
The fire detection system is provided with emergency back up in case of power failure.
The system meets all the major provisions for NFPA 720 except for supervision of the trip circuit for the carbon dioxide system in the diesel generator room.
The licensee has proposed to monitor this circuit.
Visual and distinct audible annunciation is provided in the control room for detection systems, waterficw.ndicators, both sprinkler and deluge systems, manual pull stations, actuation of high and low pressure carbon dioxide and supervisory signals.
2314 244 4-1
Most areas of the plant are protected by fire detection equipment consisting of smoke, thermal and flame detectors.
The licensee has proposed additional detectors as indicated in Section 5 of this report.
The licensee will conduct a detailed ventilation air flow analysis to determine the effectiveness of the existing detector locations.
Additional detectors will be provided to correct any deficiencies noted by the study.
We find that, subject to implementation of the above described modifications, the < ire detection system satisfies the objectives identified in Sectici 2.2 of this report and is, therefore, acceptable.
4.3 Fire Control System 4.3.1 Water Systems 4. 3.1.1 Water Supply Fire water is obtained directly from the Missouri River at a single intake structure. Three automatic vertical pumps are provided wi.th each taking suction for a single bay in the intake.
The water is pumped from the intake structure to the underground mains.
We find that the water supply satisfies the objectives idertified in Section 2.2 of this recort and is, therefore, acceptable.
4. 3.1. 2 Fire Pumps Three vertical shaft fire pumps are provided in a single room in the intake structure.
Each pump has a design capacity of 2000 gpm 0 125 psig. One pump is diesel engine drive with right angle drive and an eight hour fuel supply frcm a day tank located outside the structure.
Supervisory pressure in the fire system is maintained at 117 psig by a jcckey pump and c.learwell pump. All three fire pumps start automaticall, snen the pressure in the fire mains drop. The first electric pump starts at 80 psig while the diesel fire pump starts at 75 psig and the remaining electric fire pump starts at 68 psig. The fire pumps can be manually controlled from the control rocm or can be started from the pump room.
Pump supervisory signals such as pump power and pump running are annunciated in the control room.
All fire pumps have controllers approved for fire pump service.
We find the fire pumps satisfy the objectives identified in Section 2.2 of this report and are, therefore, acceptable.
4-2 2314 245
4.3.1.3 Fire Water Piping System The fire pumps discharge into' individual 10-inch main which flow into a 12-inch ccnmon header without isolation capability.
The licensee will provide an isolation valve (s) to preclude loss of fire pump capability to the fire protection system due to a single pipe break occurrence.
The 12-inch main then has three 12-inch nains, two leading to strainers and one normally closed bypass.
Two 12-inch mains leave the intake structure and supply a 12-inch loop header which encircles the entire plant.
The northern section of the loop is above ground and passes through the turbine gen-erator building, the control building, the radwaste building, and the augmented radwaste building. A single break in the above ground loop impairs both automatic and manual suppressi, n in the control building and reactor building. The licensee has agreed to provide the necessary valving or piping to eliminate this situation.
All yard hydrants, automatic and manual water suppression systems are supplied by the yard loop.
Sectional valves and OS&Y valves are provided to help isolate various sections of the loop. All hydrants have curb box valves tot isolation of the hydrants in case of repair or maintenance. All post indi-cator valves and OS&Y valves in the fire water piping system will be administrative 1y controlled by the use of locks or seals, and periodic inspections will be made to verify that the valves are in the proper position.
Nine yard hydrants are strategically located around the exterior of the plant on three sides.
Hose houses have been provided at, as a minfmum, every other hydrant.
Each hose house contains 250 feet of 2-1/2 inch hose, 2-1/2 inch fog nozzle and other manual firefighting equipment.
Two hose carts will be provided each to contain 250 feet of 2-1/2 inch hose, 200 feet of 1-1/2-inch, one 2-1/2 inch by 1-1/2 inch by 1-1/2 inch gated wye plus other manual fire-fighting equipment.
A 2-1/2 gated fitting will be provided on each 2-1/2 inch outlet on the yard hydrants thrcughout the plant.
Approved chain actuators will be provided for fire protection system control valves which are not easily accessible in the radwaste and reactor control buildings.
We find, subject to the inplementation of the above described modifications, the fire water system satisfies the ojectives identified in Section 2.2 of this report and is, therefore, acceptable.
2314 246 4-3
4.3.1.4 Interior Hose Stations Fifty-four interior hose stations are strategicall.y located throughout the plant.
Each hose station is equipped with 75 feet of 1-1/2 inch woven jacketed rubber lined hose with adjustable fog nozzles.
The hose stations in the augmented radwaste and administration building have 1-1/2 inch unlined linen fire hose.
Four additional fire hose stations will be provided in the reactor building to adequately protect the area.
Additional hose (25 feet) will be provided for the computer room and 903' elevation of the control building. With the addition of these lengths of hose, all safety related areas can be reached by at least one hose stream.
Some interior nozzles will be replaced by spray only types.
We find that, subject to the above described modifications, the hose stations satisfy the objectives identified in Section 2.2 of this report and are, therefore, acceptable.
4.3.1.5 Automatic Water Suppression Systems Three different types of water suppression systems have been installed.
The type is dictated by the hazard to be protected plus the environmental conditions. Wet pipe sprinkler systems provide protection in the turbine building, boiler room, machine shop and motor generator oil pump area in the reactor building.
Pre-action sprinkler systems are provided in the cable spreading room and reactor MG set area.
Numerous deluge systems protect oil hazards, transformers and open hatch areas.
The filters in the augmented radwaste are also protected by a water suppression system.
Water suppression systems are supplied by various connections to the fire main loop.
A number of automatic and manual systems in the same area can be disabled by a single impairment. The licensee has proposed to install sufficient additional valving and additional feeds to assure that no aingle failure will disable manual and automatic systems serving the same area.
The 'icensee will install additonal water suppression in various areas of the facilities as noted in Section 3 or Section 5 of this report.
We find that, subject to implementation of the above described modifications, the water suppression systems satisfies the ojectives identified in Section 2.2 of the report and are, therefore, acceptable.
2314 247 4-4
4.3.1.6 Foam Suppression System No fixed or manual foam suppression capabilities are presently provided.
The licensee will provide an automatic foam suppression system over the diesel fire pump in the intake structure and nanual foam capability to include inductors and foam concentrate in a readily available location.
We find that, subject to implementation of the above described modifications, the foam systems satisfies the objectives identified in Section 2.2 of this report and are, therefore, acceptable.
4.3.1.7 Effects of Suppression Systems on Safety Systems Inadvertent operation of a fire protection system will not disable safety-related equipment. The tops of safety-related electrical cabinets where automatic water suppression will be installed or manual suppression is the main means of suppression will be provided with drip protection to minimize the potential for water damage.
4.3.2 Gas Fire Suppression System An automatic total flooding high pressure carbon dioxide system protects each of the diesel generator rooms.
Actuation of the system is by automatic, remote manual or direct manual means.
The automatic actuation is by a detection system consisting of both thermal and smoke detectors.
Each system has 38 cylinders located within the respective diesel generi. tor rooms.
The systems are cross connected and can be used as a second shot, or if a system fails, used as the initial shot.
The minimum design concentration of carbon dioxide is 34%. The abort switch for the systems will be supervised by remote annunciation in the control room.
A low pressure carbon dioxide system provides protection for the turbine bearing and supplies hose reel stations located in the reactor building, cable spreading room, control roca entrance and turbine building switchgear. The supply actuation for the hose station is at the station itself.
We find that, subject to implementation of the above described modification, the gaseous suppression systems satisfy the objectives identified in Section 2.2 of this report and are, therefore, acceptable.
2314 248 4-5
4.3.3 Portable Fire Extinouishers Portable dry chemical pressurized water and carbon dioxide fire extinguishers have been distributed throughout the plant. Two 2/12 gallon pressurized water extinguishers will be provided for the control room. The fire extinguishers meet the requirements of the National Fire Protection Association.
We find that, subject to implementation of the above described modifica-tion, the fire extinguishers satisfy.the objectives identified in Sec-tion 2.2 of this report and are, therefore, acceptable.
4.4 Ventilation Systems and Breathing Ecuipment 4.4.1 Smcke Removal The plant does' not have exhaust systems designed specifically for smoke removal.
The normal air handling systems in most areas can be used for smoke removal; however, their effectiveness may be limited by several factors.
The fans and other equipment in the air handling system are not' designed to withstand the high temperatures and can be rendered inoperative by the heat from a significant fire. The capacity and configuration of the normal air handling system may be inadequate for effective smoke renoval.
The licensee has proposed to provide three 5,000 CFM portable explosion proof fire service smoke ejectors to aid in the removal of smoke from fire areas.
We conclude that, subject to the implementation of the abcve described modification, smoke provisions for the plant satisfy the objectives identified in Section 2.2 of this report and are, therefore, acceptable.
4.4.2 Filters Automatic water spray fire protection systems have been provided to protect the charcoal filters in the standby gas treatment filter unit and in the augmented radwaste building ventilation filter unit.
Suppression systems are not required for the turbine building filters, nor for the charcoal filter for the emergency bypass filter unit snving the control and cable spreading room since decay heat would not be sufficient to cause ignition.
Accordingly, we find these provisions acceptable.
4.4.3 Breathing Equipment A total of 27 self-contained breathing apparatus using full face positive pressure masks and 18 spare cylinders have been provided.
The licensee has proposed to modify the on-site air reserve supply to provide 10 men with a six hour reserve air supply.
We conclude that, with these additions, portable breathing equip-ment will be adequate to support manual fire fighting activities.
4-6 2314 249
4.5 Floor Drains The existing building floor drain system, in areas where water type fire suppression systems are located, may not bb adequately sized to accept the water discharged from fixed suppression systems or manual hose stations should the discharge period exceed two hours. Equipment has been installed on pedestals and curbing has been provided around floor penetrations.
Additionally, floor drains in areas containing potentially com-bustiole liquids are connected to the building sump collection system.
Each drain is also provided with a trap to prevent spread of fire frcm one area to another through the drain system.
The licensee is evaluating the need for additional floor drains in the reactor building. Areas of concern include:
(1) the motor generator set room, EL 976' near column Q and 11.7; and (2) the area of the rotor generator set oil pumps and motors on EL 958'.
We conclude that, with the above described modifications, the drain systems will satisfy the objectives identified in Section 2.2 of this report and will, therefore, be acceptable.
4.6 Lighting Systems In addition to normal plant lighting, both AC and DC emergency lighting is provided.
The AC lights are supplied from the emergency power supply; DC lighting is supplied by self-contained battery units with two 25 watt, 6 volt, seal beam lights and a 40 amp hour battery supply.
Portable hand lights are also provided for emergency use.
Because the plant lighting systems are divided into a number of circuits, a fire in an area could cause loss of both nomal and emergency lights in the fire area, but would not cause loss of lighting to areas served by other circuits.
Sufficient emergency lighting has been provided to facilitate access and egress to safety related areas during a fire situation.
We conclude that, the lighting systems for the plant satisfies the objectives identified in Section 2.2 of this report and, therefore, is acceptable.
4.7 Ccmmunications Systems The normal communication within the plant is provided by a single channel page/ call-back system. Additional ccmmunication is provided by sound power telephones with jacks at various key locations throughout the plant.
Reliance on the normal page/
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call-back system and the installed sound powered telephone system is not considered adequate for fire fighting capability.
The licensee has proposed to provide three self-contained two-way radios for exclusive use of the fire fighting teams.
We conclude that, subject to the implementation of the above described modifications, the communications systems satisfy the objectives identified in section 2.2 of this report and are, therefore, acceptable.
4.8 Electrical Cable Ccmbustibility Flame tests conducted on the electrical cables used at Cooper Plant were comparable to the cenbustibility tests set forth in IEEE 383.
The results show that, in the configurations and with the ignition sources used in the tests the cable insulation tyns slowly.
Nevertheless, we consider all cable insulation made of organic material as combustible and, therefore, we find that retest to the IEEE 383 procedures and criteria wculd not provide information that would alter our conclusions. Accordingly, we find the electrical cables used at the Cooper Plant acceptable.
4.9 Fire Barrier Penetrations Fire barriers are penetrated by doors, ventilation ducts, electrical cables, pipinc and conduit.
- 4.9.1 Electrical Cable and Conduit Penetrations Fire stops are provided where cables penetrate fire barriers.
Floor penetration openings were fil. led with Five Star grout and wall penetrations were filled with cellular concrete. There were also Styrofoam spacing blocks within several fire barriers.
The licensee, at present, has no testing documentation to sub-stantiate the adequacy of the penetration barriers. The licensee has committed to provide data to document the fire resistant capebility of the existing cable tray and conduit wall penetra-tions and floor penetrations. We will address the review of the adequacy of these fire stops in a supplement to this report.
4.9.2 Fire Doors Doorways used as barriers between fire areas have been evaluated and found to be consistent with the fire rating of the fire barriers with the exception of the double doors between the critical switcis-gear rooms.
The licensee has proposed to upgrade thi.s doorway to a 3-hour rating.
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We' find that, subject to implementation of the above modifi-cation, the fire doors satisfy the objectives of Section 2.2 of this report and are, therefore, acceptable.
4.9.3 Ventilation Duct Penetrations Fire dampers equivalent to the barrier requirements have been provided where ventilation ducts pass through fire barriers.
We find that this satisfies the objectives of Section 2.2 of this report and is, therefore, acceptable.
4.10 Separation Criteria The licensee has stated that safety-related systems and non-safety-related systems which provide core cooling are in accord-ance with IEEE 279 - 1971, Paragraph 4.2.
In areas where this criteria is not met, cable trays have metal covers installed or the cables have been placed in metal conduit.
In areas containing concentrations of cable trays and conduits, automatic sprinklers have been or will be installed. Smoke detection has been provided for these areas.
We find that, subject to implementation of the above described modifications, the separation criteria satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
4.11 Fire Earriers Fire areas are enclosed by floors, walls, and ceilings which have three hour fire ratings with few exceptions. Areas not having three hour fire ratings are found acceptable on the basis of light ccmbustible loading, or that redundant safe shutdown equipment will not be jeopardized. We conclude that the fire barriers satisfy the objectives identified in Section 4.2 of this report and are, therefore, acceptable.
4.12 Nonsafety-Related Areas We have evaluated the separation by distance or by fire barriers of nonsafety-related areas to determine that fires in such areas will not adversly affect the ability to safely shutdown the plant.
We conclude that fires in ncnsafety-related areas will not pre-clude the safe shutdown of the plant.
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4.13 Instrument Air A noninterruptable air supply is required to operate the main steam isolation valves and the main steam manual blowdown valves.
This air is supplied by installed seismic air reservoirs which are kept charged by the instrument air system, which is not seismic. We find that the present method of supplying noninter-ruptable air to the main steam isolation valves and the main steam manual blowdown valves is acceptable.
4.14 Access and Egress Access to various floors of the reactor building is by two enclosed stairs in the northwest and southwest corners.
A partially enclosed stairway in the southeast corner services all floors. The corner rooms in the reactor building are accessible by a single stairwell plus a watertight door to the torus.
Access to the control building is by a corridor from the service building, stairways from the turbine building, and direct access from the turbine building.
A discontinuous enclosed stairway services various floors of this building.
Areas in the lower parts of the control building and reactor building generally have low combustible loading or are protected by three hour enclosures.
We find that the access and egress provided for manual fire-fighting is acceptable since a number of areas are equipped or will be equipped with automatic suppression systems to mitigate areas where accessibility may be a problem.
4.15 Toxic and Corrosive Combustion products The products of combustion for many plastic materials, most common being cable insulation and jacket materials are toxic to humans and corrosive to metals.
Fire retardant coatings, fire detectior, and extinguishment are relied upon to minimize the quantities of such products.
Additional means of smoke removal will be provided as an aid in firefighting access as noted in Section 4.4.
The fire brigade is provided with and trained in the use of emergency breathing apparatus for fighting fires in-volving such materials.
We find the precautions taken to minimize the effects of toxic and corrosive products satisfy the objectives identified in Section 2.2 of this report and are, therefore, acceptable.
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5.0 EVALUATION OF SPECIFIC PLANT AREAS Tne licensee has performed a fire hazard analysis of the facility to determine the fire loading of various plant areas, to identify the consequences of fires in safety-related and ajoining nonsafety-related areas, and to evaluate the adequacy of existing and proposed fire protection systems.
We have evaluated the assumptions, methodology, and conclusions of the fire hazards analysis in detail.
The results of the fire hazards analysis, other docketed information and site visit observations were used in the staff's evaluation of specific plant areas to assure that the objectives stated in Section 2.2 were met. The staff's evaluation of specific areas is discussed in the following subsections.
5.1 Cable Spreading Room 5.1.1 Safety-Related Equipment The cable spreading room is located at elevation 918', directly below, the control room area. The cable spreading rcom contains redundant cabling associated with safe shutdown and other safety-related equip-ment.
The room also contains control centers which are supplied from redundant Class lE power sources.
~
5.1.2 Combustibles The combustibles in this area consists of a large quantity of cable insulation.
These cables have been tested to meet or exceed criteria of IEEE 383, " Flame Test." A large part of the cables are in conduit with the remainder in cable trays.
5.1. 3 Consequences if No Fire Suppression An unmitigated fire in this area could become large enough to involve redundant divisions due to heat generation and potentially due to combustible materials in the separation space between the trays and redundant divisions. The complete loss of the cable spreading room presently would cause loss of control of certain safe shutdown equip-ment.
5.1.4 Fire Protection Systems The primary method of fire suppression in
'- 'rea is by automatic pre-action sprinkler system located at the 1 above the cable trays. Actuation of the suppression sy m.o is provided by a heat detection system.
Products of combustion detectors have also been provided at the ceiling for early warning detection.
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5.1. 5 A_d_eauacy of Fire Protectio _n There are three entrance ways to the cable spreading room, and reasonibly good access is available to fight the fires nanually.
The existing sprinkler system and manual backup fire fighting capability should be sufficient to assure that redundant safe shutdown eaufpment will not be lost in a fire.
5.1. 6 Modifications There are no nodificaticns scheduled for this area.
In the very unlikely event of a larger fire, safe shutdown of the plant can still be accomplished using remote shutdown capability. Accordingly, we find that the fire protection of this area satisfies the objectives of Section 2.2 of this report and is, therefore, acceptable.
5.2 Diesel Generator Roons 5.2.1 Safety Related Eauipment Each of the two diesal generators and associated equioment are located in separate rooms in an independent structure adjacent to the turb'ine building. One diesal generator is capable of supplying power for safe shutdown upon the loss of offsite power.
5.2.2 Combustibl es Each diesel generator has a 2500 gallon day tank in a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated enclosure within the diesel generator room itself. The lube oil in the crankcase of the generator consists of 392 gallons.
The transfer of oil to the day tank is autcmatic.
In case of a fire the supply can be shut off frcm two readily accessible locations.
5.2.3 Consecuences if No Fire Sucoression An unmitigated fire in a diesel generator roon would cause the loss of the diesel generator and associated equipment.
5.2.4 Fire Protection Systems An automatic total flooding high pressure carbon dioxide extin-guishing system protects each of the diesel generator rocms and associated day tank room.
The system is actuated by a fire detec-tion system censisting of both thernal and products of combustion detectors. A separate detection system censisting of ionization provides local and remote annunciation in the control rocm. The diesel generator rcoms are separated frcm each other by 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire resistive construction.
Fire doors into and between rocns are rated for 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.
Manual firefighting equipment consists of hose staticns, portable and wheeled fire extinguishers.
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5.2.5 Adecuacy of Fire Protection The doors between rooms are not electrically supervised to insure their being closed to maintain carbon dioxide concentration in case of actuation.
The present curb at the door does not prevent an oil spill from flowing under the door and affect the adjacent room.
An oil spill in the boiler room could affect the diesel generator adjacent to this room.
5.2.6 fiodifications The licensee has proposed to electrically supervise the doors between diesel generator rocas.
A curb will be provided at the entrance to the boiler rocm to prevent oil frcm entering the diesel generator room.
The curb between the two diesel rocms will be modified to prevent an oil spill from affecting the adjacent room.
The abort switch for the carbon dicxide systens will be electrically supervised to annunicate in the control rocm.
We find that, subject to the implementation of the above described modifications, the fire protection of the diesel generator room satisfies the objectives identified in Seccion 2.2 of this report and is, therefore, acceptable.
5.3 -
Battery Rocms 5.3.1 Safety-Related Ecuipment The unit has two redundant safety-related banks of batteries.
These redundant batteries are in separate rooms which are located adjacent to one another.
5.3.2 Combustibles The significant amount of combustibles in the battery rocms are the plastic battery cases and a small amount of electrical cable insula-tion. Hydrogen buildup is precluded by continuously operating the supply and exhaust ventilation fans for each battery rocm, either of which provide sufficient ventilation to maintain hydrogen ccncen-tration bel.cw 2% (by volume). Across the hallway frcn the battery rocms is an instrument storage room that contains substantial quantities af class A conbustible materials.
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5.3.3 Consecuences'if No Fire Suppression An unsuppressed fire in the battery room could cause the loss of one of the redundant batteries, but would not affect the redundant battery room due to the fire wall separating the two rooms.
It could,.
however, affect redundant safe shutdown cabling in non-fire rated vertical conduit risers.
An unvippressed fire in the non-fire rated instrument storage room could affect both control panels for the two banks of batteries.
5.3.4 Fire Protection Systems There are no automatic fire suppression systems in the battery rooms or the instrument storage room.
Mcwever, due to the physical configuration of the battery rooms overhead, the single smoke detec-tor in the rooms are not considered adequate.
(See Section 5.3.6 below.)
5.3.5 Adequacy of Fire Protection Considering the limited quantity of combustible material., manual fire suppression is adequate to extinguish fires 1n the battery rooms.
Manual suppression alone is not acceptable for the instrument storage room.
5.3.6 Modificaticns The licensee has proposed four nodifications for the battery room area. These modifications are listed below:
a.
The ifcensee has propdsed to install one additional smoke detector in each battery rocm to assure that there is sufficient detection to detect a fire anywhere in the room.
b.
Air flow supervision will be provided in the exhaust ducts of each battery room.
c.
The power cables for the service water pumps frcm the intake structure are enclosed in a vertical conduit riser at the rear of 1B battery rocm. The licensee has proposed to con-
' struct a 1-hour fire barrier around these risers.
b.
An automatic sprinkler system will be provided for the instrument storage rocm.
We conclude that, subject to the implenentation of the above described modifications, fire protection for the battery rooms satisfies the objectives identified in Section 2.2 and is, therefore, acceptable.
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5.4 Laundry Room Area - Controlled Access Corridor 5.4.1 Safety Related Equipment No safety-related equipnent is located in the laundry rocm and controlled access corridor areas per se.
However, these areas are not isolated by a rated fire barrier from the cable expansion room on the above floor which does contain redundant safety-related cables.
5.4.2 Combustibles The combustibles in these areas include mostly anti-C clothing and transient combustible materials.
5.4.3 Consequences if No Fire Suppression An unsuppressed fire in the laundry rocn or controlled access corridor could propagate to the cable expansion room on the floor above and cause an unacceptable loss of redundant safety-related ; ables.
5.4.4 Fire Protection Systems There are no autcmatic fire detection or suppression systems in the laundry room and controlled access corridor. The only means of fire suppression is manually utilizing hose stations and/or portable extinguishers.
5.4.5 Adecuacy of Fire Protection Considering the quantity of combustible materials, manual suppression alone cannot be relied upon to extinguish a fire before it involved the cable expansion room.
5.4.6 Modifications The licensee has proposed to install fire detection and an auttmatic sprinkler systems for the laundry room and control access corridor.
We conclude that, subject to the implementation of the above described modificaticns, fire protection for the laundry rocm and control access corridor satisfies the objectives identified in Section 2.2 and is, therefore, acceptable, 2314 258 s_s
5.5 Air Compresscrs - Control Building Basenent 5.5.1 Safety-Related Equipment The air compressor room contains safety-related cables including the redundant cables feeding the service water pumps.
5.5.2 Combustibles The ccmbustibles in the area consist of electrical cable insulation and about 7 gallons of lube oil in each air compressor. The quantity of available lube oil would at least be doubled when the compressors are serviced.
5.5.3 Consequences if fio Fire Suppression An unsuppressed lube oil fire could spread and possibly damage the 4160 volt pcwer cables to the service water pumps.
5.5.4 Fire Protection System Early warning fire detection has been installed in the compressor room area. There is no autcmatic fire suppression system. Manual hose reels and portable CO, extinguishers are available. Curbing has not been provided to pi' event lube oil from involving the pcwer cables for the service water punps.
5.5.5 Adequacy of Fir'e Protection Manual suppression alone, without curbing to restrain lube oil may not prevent the fire from damaging the redundant cables for the service water pumps.
5.5.6 Modifications The ifcensee has proposed to add curbs around the conduit risers adjacent to the south wall and in front of the manways adjacent to the east wall of the compressor room. Manual foam suppression will also be provided to supplement hose stations and portable C0 fire extinguishers for lube oil type fires.
2 We find that, subject to the implementation of the above described modificaticns, the fire protection of the ccmpressor room satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
5-6
5.6 Control Room 5.6.1 Safety Related Ecutoment The control room contains safety-related control cabinets and cables.
At the present time, certain of these cables and control cabinets would be required for safe shutdown of the reactor.
However, the licensee has remote shutdown capability independent of the control room so that safe shutdown can be achieved by operation of equipment from remote locations, even if the control room is functionally lost due to a postulated fire.
5.6.2 Ccnbustibles The combustibles in the area consist of electrical cable insulation, electrical ccmponents in panels and consoles, a small amount of Class A combustibles such as log books, drawings, operating procedures and computer printcuts, cooking oils and grease in the kitchenette and a particle board wall.
5.6.3
-Consecuences if no Fire Suporession A postulated fire in the control room has the potential for damaging significant amounts of safety-related equipment within a single division. A postulated fire in certain control room cabinets or cabling may affect redundant systems. Also, a fire involving the particle board wall could cause a much more severe fire due to the unknown flame spread characteristics. The li-censee has agreed to supply the flame spread characteristics of the wall board.
5.6.4 Fire Protection System Smoke detectors have been provided at the ceiling throughout the room. The kitchenett and safety related panels do not contain detecto rs. The licensee has cccmitted to do an analysis of the kitchenette and air flow study of the safety related panels and cabinets.
If detectors are required, they will be installed.
There is no automatic suppression in this area. Manual CO hose 2
ree'; are provided.
5.6.5 Adequacy of Fire Protection The presently installed detector may not respond quickly enough to postulated fires in panels and cabinets.
The CO hoses may 2
not provide effective suppression for certain electrical insulation Class A combustible fires.
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4 e
5.6.6 Modifications The licensee has proposed the following modifications:
(1) Provide a photoelectric cell type products of combustion detector for the kitchenette.
(2) Certify that the particle board walls have acceptable flame and smoke spread ratings; or replace the particle board walls.
(3)
Provide two 213 gallon portable water fire extinguishers for the control rocm.
(4)
Provide smoke detectors in safety-related panels if air flow analysis shcw them to be necessary.
(5) A fire and smoke barrier will be provided around the HVAC ducting to the control rocm on the 931' elevation of the control building.
We find that, subject implementation of the above described modifications, fire protection for the control rocm satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
5.7 Cable Exoansion Room 5.7.1 Safcty-Related Equipment The cable expansion rocm is located between the cable spreading room and the reactor building. The cables that pass through this room are those safety-related cables which leave the cable spreading room to enter the reactor building.
5.7.2 Combustibles The combustibles in this room consist of cable insulation. Scme of the cable passing through this room are enc 1csed in steel conduit.
5.7.3 Consecuences if No Suppression An unmitigated fire in this area could become large enough to involve redundant divisions due to heat generation. The conplete loss of the cable expansion roca presently would cause loss of control of certain safe shutdown equipment.
2314 261 s_,
5.7.4 Fire Protection Systems The primary method of fire suppression in this area is by manual means.
5.7.5 Adecuacy of Fire _ Protection Reliance on manual suppression for this room is not considered adequate.
5.7.6 Modifications lhe licensee will provide an autonatic suppression system in the rocm.
We find that, subject to the implementation of the above described modifications, the fire protection of the cable expansion room satisfies the objective identified in Section 2.2 of this report and is, therefore, acceptable.
5.8 Intake Structure 5.8.1 Safety-Related Equipment The category 1 portion of the intake structure contains the four plant service water pumps, two electric fire pumps, and the diesel driven fire pump.
The service water pumps provide cooling water to equipment required for safe shutdown. The room also contains the three punps necessary for fighting fires within the structure.
5.8.2 Combustibles The significant combustibles in this building include. lubricating oil associated with the service water pumps, lubricating oil associated with the electric fire pumps and the 27r gallons of fuel oil associated with the diesel driven fire puup.
5.8.3 Consecuences if No Fire Suppression Due to the construction of this category 1 room, an unmitigated fire in this area would affect all of the service water pumps and all three fire pumps.
5.8.4 Fire Protection Systems The room is separated from the remainder of the intake structure by 3-hour fire rated construction.
A fire detection system is provided over the pumps with annunciation in the control rocm.
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Portable fire extinguishers are provided throughout the intake structure with a hydrant and hose house located adjacent to the structure.
5.8.5 Adecuacy of Fire Protection There is no automatic suppression system over the diesel fire pump and it is not isolated from the remainder of the fire pumps and safety related pumps.
A line break in the fuel oil line for the diesel fire pump would permit oil outside the dike area of the diesel fire pump.
5.8.6 Modificaticns The licensee will install an area sprinkler system over the diesel fire pump with waterflow annunciation in the control rocm.
An automatic foam deluge system will also be provided over the diesel fire pump.
The water feeds to the foam system ~will be indeper. dent of the feed to the sprinkler system.
The fuel line to the diesel fire pump will be rerouted so that the line remains outside the rocm until it penetrates the wall in the diked area of the diesel fire punp.
We find that subject to the implementation of the above modifications, the fire protection for the Intake Structure satisfies the object-ives identified in Section 2.2 of this report and is, therefm 9, acceptable.
5.9 Turbine Building 5.9.1 Safety-Related Equipment There are no safe shutdown related equipment or cabling in the turbine building. However, several safety-related cables are located i.n the vertical electrical cable chase adjacent to the north wall of the turbine building.
5.9.2 Combustibles The combustibles in the turbine building cons'st mainly of lubricating and seal oil with minor amounts of cabling and transient combustibles.
5.9.3 Consequences if No fire Suppression A fire in the turbine building could affect several safety-related cables, but would not prohibit safe shutdown. The fire would not 5-10 2314 263
have an adverse effect on safety-related equipment in the diesel generator room or control building except for lack of rating on cable penetrations and a spill fire adjacent to the entrance to the control building.
5.9.4 Fire protection Systems Automatic sprinklers for area protection are provided throughout most of the turbine building except for the operating floor. De-luge systems protect the oil hazards throughout the turbine building. The reactor feed pumps, hydrogen seal oil unit, turbine lube oil storage tank, turbine lube oil reservoir are separated from the remainder of the building by masonry construction and fire doors.
Waterflow from sprinklers and system actuation of deluge systems are annunciated in the control rocm. All the areas in the turbine building are protected by hose stations and portable extinguishers.
5.9.5 Adequacy of Fire Protection Due to the lack of drainage facilities or adequate curbing for the lube oil reservoir and oil cooler room, an oil spill fire could affect the control building.
The lack of an automatic sprinkler system for the vertical cable chase and an hourly rating on the cable penetraticns to the control building could result in the loss of several safety-related cables and open the control building to fire effects from the turbine building.
5.9.6 Modifications The licensee will provide a drainage system for the lube oil reservoir room at elevation 903'.
Information will be provided by the licensee to assure satisfactory fire resistance capability of the penetration barriers.
An automatic sprinkler system will be installed to provide coverage of the vertical electrical cable chase and penetra-tions in the north wall of the turbine building.
We find that subject to the implementation of the above modifications, the fire protection for the turbine building satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
5-11 23j4 }64
5.10 Reactor Building Elevation 859'.-9 (Ouads) 5.10.1 Safety-Related Ecuipment The safety-related equipment includes the reactor core isolation cooling pump, the core spray pumps (lA & IB), the residual heat removal pumps (la,1B,1C 110), the high pressure coolant injection pump ani divisian II cables.
The equipment required for safe shutdown in the. event of a fire emergency is the reactor core isolation pump or the high pressure coolant injection pump.
5.10.2 Cembustibles The significant combustibles are limited to lube oil and cable insulation.
5.10.3 Consecuences if No Fire Suppression Postulated fires in electrical cables or lube oil could cause loss of certain equipment within one division but would not affect the redundant division since redundant division equipment is located in separate quads (corner rocms).
5.10.4 Fire Protection _ Systems Fire protection is provided by thermal type fire detectors, water hose stations, and portable CO extinguishers.
2 5.10.5 Adequacy of Fire Protection A fire on this elevation would be limited to one divisien and would not effect the redundant equipment in other quads.
It could successfully be extinguished using manual means.
5.10.6 Modifications No modifications have been proposed for this area.
We find that the fire protection for the above listed safety-related equipment satisfies the objectives identified in Sr.. ion 2.2 of this report and is, therefore, acceptable.
5.11 Reactor Building Elevation 903'-6" 5.11.1 Safety-Related Equipment The safety-related equipment includes the control rod drive hydraulic units, residual heat removal heat exchangers lA and 18, and, in the northeast corner, all safety-related cabling entering the reactor building from the control building.
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5.11.2 Combustibles The significant combustibles dering periods of nomal operation are limited to cable insulation.
However, during maintenance activities, a significant amount of transient combustibles accumu-late in the northeast area by the maintenance hatch.
5.11.3 Consequences if No Fire Suppression A postulated unmitigated fire in the northeast quadrant of this elevation could involve all safety-related control and power cables of Divisions I and II that enter the react'or building. However, the fire would not prevent the reactor from beinc safely shutdown to the hot shutdown condition.
If, during the course of the fire, the power cables to the service water pumps were damaged, temporary power can be rigged to at least one service water pump within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
This will allow placing the reactor in the cold shutdown condition and naintain-ing it in that condition.
5.11.4 Fire Protection Systems Fire protection is provided by product of ccmbustion detectors, hose wate. stations, and portable C0 extinguishers.
2 5.11.5 Adecuacy of Fire Trotection A fire on this elevation in the northeast quadrant could involve both Divisions I and II.
Due to the location of the Division I and II cabling (18 to 20 feet above the floor), manual suppression of a fire in this area is considered inadequate.
5.11.6 Modifications The licensee has proposed to install automatic suppression system in the area of the cabling to preclude the possibility of a fire affect-ing redundant sets of cable trays.
We find that, subject to implementation of an acceptable modifi-cation, the fire protection of the Division I and II cabling in this area satisfies the objectives of Section 2.2 of this report and is, the efore, acceptable.
5.12 Reactor Building Elevation 932'-6" 5.12.1 Safety-Related Equipment The safety-related equipment includes the 4160V and 480V Division I and II critical sw'tchgear, reactor pressure and level instrument 5-13 2314 266
racks, residual heat removal heat exchangers, reactor building closed cooling water pumps l A,1B,1C and 10, reactor building closed cooling water heat exchangers, cabling and the non-safety-related MG set oil coolers.
5.12.2 Combustibles The significant combustibles are limited to the ?1G set oil from the coolers in the northwest corner, a small amount of oil from the reactor building closed cooling water pumps, and cable insulation.
5.12.3 Consecuences if No Fire Suppression Postulated fires in electrical cables or lube oil could, in scme instances, involve Divisions I and II cabling. This would not prevent the reactor from safely being placed in the hot shutdown condition, but may prevent the reactor from being placed and maintained in the cold shutdown condition.
5.12.4 Fire Protection Systems Fire protection is provided by product of combustion detection, water hose stations, portable dry type and C0 extinguishers.
2 5.12.5 Adecuacy _of Fire Protec_ tion Except for unmitigated fires in the critical switchgear rooms and the area where the MG set oil coolers are located, the protection systems are adequate.
In the critical switchgear area, the double door separating the rooms is not fire rated.
In the MG set oil cooler area, there are safety-related cables in the area that could be affected.
5.12.6 Modification:
The licensee has proposed to upgrade the double door separating the critical switchgear room to doors with 3-hour fire ratings.
Also proposed is an automatic suppression system over the MG set oil coolers.
We find that, subject to implementation of the above described modifications, the fire protection for the above listed safety-related equipment satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
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5.13 Reactor Building Elevation 958'-3" 5.13.1 Safety-Related Eouicnent The safety-related equipment is limited to Division I and II cabling.
5.13.2 Combustibles The significant combustibles are limited to lube oil in the MG set oil pumps in the northwest corner and cable insulation.
5.13.3 Conseauences_ j f "o Fire Suppression A postulated urhitigated fire in the area of the MG set oil pumps could affect safety-related cabling.
In addition, the drain inside the curbing surrounding the oil pumps may not be able to drain both the oil and water from the automatic sprinkler system.
This would cause the fire to sp.ead if the burning oil-water volume became too great for the curbing cacacity.
5.13.4 Fire Protection Systems Fire protection is provided by product of combustion detectors, wet pipe sprinklers (oil pumps), water hose stations, wheeled dry chemical (150#), and portable CO extinguishers.
2 5.13.5 Adequacy of Fire Protection A fire on this elevation would be unlikely to involve more than one division of safety-related cabling, provided a postulated oil fire could be contained within the curbing surrounding the MG set oil pumps.
5.13.6 Modifications The licensee will examine the need for additional drainage inside the area surrounded by the curbing. The need for addi-tional drains in the reactor building will also be evaluated.
We find that, subject to inplenentation of the above described modification, the fire protection for this elevation satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
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5.14 Reactor Building Elevation 976'-0" 5.14.1 Safety-Related Equipment The safety-related equipment includes the standby ' liquid control system, standby gas treatment system, safety related cabling, and the two non-safety related M'i sets.
5.14.2 Combustibles The significant combustibles are limited to approximately 360 gallons lube oil for each M'i set and cable insulation.
5.14.3 Consecuences if i'o Fire Suppression A postulated unmitigated fire involving lube oil from one MG set could involve the re aining MG.
Involvement of the second MG could cause another oil system failure, thereby compounding the fire.
5.14.4 Fire Protection Systens.
The fire protection in this area is provided by thermal and pr. duct of ccmbustion detectors, pre-action sprinkles (over the MG sets), water hose stations, a low pressure C0 hose 9
stations, and portable C07 extinguishers.
The preseht protection is based on fire involvement of only cne "G set. Mcwever, an oil spill could involve the other MG set.
5.14.5 Adecuacy of Fire Protection A postulated fire could involve both MG set lube oil systems.
This would, in turn, involve substantially all electrical cable in the room.
This would not prevent safe shutdcwn and cooldown of the reactor.
5.14.6 Modifications The licensee has proposed to install curbing between the MG set to lessen the possibility of one M-G set oil fire involving the other MG set.
'de find that, subject to implementation of the above described modification, the fire protection for this elevation of the reactor building satisfies the objectives of Section 2.2 of this rerort and is, therefore, acceptable.
'~
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5 15 Reactor Buildinj Elevation 1001'-0" 5.15.1 Safety-Rel ated_Elu_ipment The safety-related equipment on the elevation is the spent fuel pool.
5.15.2 Combustibles The significant combustibles are limited to a small amount of cable insulation, cardboard containers, anti-contaminant clothing and plastic bags.
5.15.3 Consequences if No Fire Protection _
A postulated fire on this level would damage non-safety related equipment and would have no effect upon safe shutdown of the reactor.
5.15.4 Fire Protection Systems The fire protection in this area is provided by themal type detectors, water hose stations, and portable CO2 extinouishers.
5.15.5 Adecuacy of Fire Protection Postulated fires on this elevation can be adequately extinguished with the installed manual suppression system if longer hoses wera available.
5.15.6 Modifications To enhance the ability to suppress fires by attacking them from nore than cne direction, the licensee has proposed lengthing the hose available from 75 f t. to 100 ft. at each hose station.
We find that, subject to implementation the above described modification, the fire protection on this elevation satisfies the objectives of Section 2.2 of this report and is, therefore, acceptable.
5.16 Radwaste and Augmented Radwaste Buildings 5.16.1 Safety-Related Eauicment There is no safety-related equipnent installed in these buildings.
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5.16.2 Ccmbustibles The ccmbustibles in these areas consist of charcoal filter beds, anti-contaminate clothing, solid waste material, plastic bags, wooden pallets, filter material, packing materials, dry resins, and cable insulation.
5.16.3 Consequences if ho Fire Suppression Postulated fires in these buildings would not affect the ability to safely shutdown and cooldown the reactor.
5.16.4 Fire Protection Systems Fire protection is provided by thermal and product of combustion detectors, deluge sprinkles for the filter, water hose stations, portable CO and dry chemical extinguishers.
2 5.16.5 Adequacy of Fire Protection Postulated fires in these buildings can be adequately extinguished with the present suppression except in corridor V, EL 918 where considerable ccmbustible material is stored.
5.16.6 Modifications The licensee has proposed to install a wet pipe sprinkler system in corridor V, EL 918' and replace the non-indi ating sectional control valves en the HEPA filter deluge sprinkler system with OS&Y type on EL 932'.
We find that, subject to implementation of the above described mcdifications, the fire protection of the radwaste and augmented radwaste buildings satisfies the objectives of Section 2.2 of this report and is, therefore, acceptable.
5.17 Yard Area 5.17.1 Safety-Related Ecuic.nent There is no safety-related equipnent in the yard area.
5.17.2 Combustibles Combustibles in the yard area include transformer oil in the transformers adjacent to the reactor building and turbine building.
The fuel oil storage tank is located in a diked area.
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5.17.3 Consecuences if No Fire Suppression The consequences of an unmitigated fire in the yard does not impact safe shutdown or safety-related equipment.
5.17.4 Fire Protection Systems The transfomers are protected by automatic deluge systems actuated by heat detectors.
The fuel oil tank is within a diked area well removed from equipnent. The yard is protected by hydrants with a sufficient numb'er of hose houses associated with them.
5.17.5 Adequacy of Fire Protection The plant does not have manual fcam capability nor does it have and adequate amount of manual fire fighting equipment.
5.17.6 Modifications The licensee will provide manual foam capability and also a hose cart equipped with hose and related firefighting equipment. The 2-1/2 inch outlets on the hydrants will be equipped with gated fittings.
We find that, subject to the implementation of the above described modifications, the fire protection for the yard area satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
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6.0 ADMIl41STRATIVE C0tiTROLS The administrative controls for fire protecticn consist of the fire protection organization, the qualifications and training for fire protec-tion personnel, the controls to be exercised over combustibles and ignition sources, plans and procedures for fighting fires in the various plant areas, The licensee has and the quality assurance provisons for fire protection.
provided a detailed description of proposed administrative controls.
Plans and procedures stipulating the management and staff organization and its qualifications; the fire brigade training program; controls over cenbust-ibles and ignition sources; and the prefire plans for fighting fires are being developed and implemented.
The program and its implementing pro:e-dures as provided by letter frce the licensee dated December 17, 1976, as supplemented by letters dated April 6,1977; July 20,1977; December 19, 1977; June 21, 1978; August 16, 1978; December ll, 1978 and April 12, 1979, are found acceptable by the staff using items referenced in Sections 1.0(e) and 1.0(f)
We have evaluated the areas at Cooper fluclear Station to determine the minimum required fire brigade size to cope with fires that may occur, and have determined that a five man brigade is required. The licensee has agreed to a five man fire brigade to be available onsite during all shifts, and independent of demands placed on operating personnel and the security force in a fire situation.
This requirement is being incorporated into the Technical Specifications with implementation 90 days after issuance of this report.
All five of the brigade members receive the same instruction and practice, including familiarization with the contents of the pre. ire plans with the f
exception that two members will not receive fire fighting strategy train-ing because they are under the direction cf a trained brigade leader.
These two members do receive an acceptable level of training to perform their assigned tasks.
Strategy training is only required for br.gade leaders and includes decision factors, direction of brigade, problem sessions and' coordination of various pieces of equipment.
The licensee has proposed to establish administrative procedures for the control of fire doors associated with safety-related areas.
We find that, subject to implementation of the above described programmatic changes, the fire protection program satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceotable.
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7.0 TECHNICAL SDECIFICATIONS The Technical Specifications have oreviously been nodified to incorporate interim Technical Specifications which include limiting conditions for operation and surveillance requirements for existing fire protection systems and administrative controls. The ifcensee will propose a Technical Specification change to require that at least five individuals with fire protection training be ensite at all times. This would be an increase in the size of the Fire Brigade.
We find the change acceptable.
Following the implementation of the modifications of fire protection systems result-ing from this review, the Technical Specifications will be similarly modified to incorporate the limiting conditions of operation and surveillance requirements for these mcdifications.
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8.0 CONCLUSION
S The licensee has performed a fire hazards analysis and has proposed certain modifications to improve the fire protection program. Additional modifica-tions have been proposed by the licensee during the course of our review, which are based upon the fire hazards analysis and our onsite evaluation of the fire protection program.
These proposed modifications are summarized in Section 3.0.
In addition, we have concluded that the licensee should implement certain evaluations or improvements related to the fire protection p rog ram. These are summarized in Section 3.0.
Significant steps are being taken to provide additional assurance that safe shutdown can be accomplished and the plant can be maintained in a safe condition during the following potential fire situations.
Upon implemetation of the licensee's proposed modifications, we find that the objectives identified in Section 2.0 will be satisfied.
We find that the licensee's proposcd 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 (NUREG-0050) dated February 1976, consideration of the safety of operation of all cperating nuclear power plants pending the completion of our detailed fire protection evaluation was presented.
The following quotations frcm the report summarize the basis for the Special Review Group's concluster that the operation of the facility need not be restricted for public safety:
"A probability assessment of public safety or risk in quant'itative terms is given in the Reactor Safety Study (WASH-1400). As the result of the calculaticn based on the Browns Ferry fire, the study concludes that the poten-tial for a significant release of radioactivity from such a fire is about 20% of that calculated from all other causes analyzed.
This indicates that predicted potential accident risks from all causes were not greatly affected by consideration of the Srcwns Ferry fire.
This is one of the reasons that urgent action in regard to reducing risks due to potential fires is not required.
The study (WASH-la00) also points out that 'rather straight-forward measures, such as may already exist at other nuclear clar.ts, can significantly reduce the likelihcod of a pctential ccre melt accident that night result from a large fire.
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" Fires occur rather frequently; however,' fires invclving equipment unavailability ccmparable to the Browns Ferry fire are quite infrequent (see Section 3.3 of (NUREG-0050)).
l The Review Group believes that steps already taken since March 1975 (see Section 3.3.2 of (NUREG-0050)) 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 cf the Browns Ferry event is small, and that there is no need to restrict cperation of nuclear power plants for public saf ety.
However, it is clear that much can and should be done to reduce even further the likeli-hood of disabling fires and to impreve assurance of rapid extinguishment of fires that occur. Consideraticn should be given also to features that wculd increase further the ability of nuclear facilities to withstand large fires without loss of important functions shculd such fires occur."
We recognize that the " Risk Assessnent Review Grcup Report to the U. S.
Nuclear Regulatory Ccmmission" 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 State-ment of Risk-Assessnent and the Reactor Safety Study Report (WASH-1400) in Light of the Risk-Assessment Review Group Report", the Commission indicated on page 3 that it " accepts the Review Group Report's conclu-sion that absolute values of the risks presented by WASH-1400 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 pro-babilities, the Comission does,not regard as reliable the Reactor Safety Study's numerical estimate of the overall risk of reactor accident."
In summary, it is our conclusion that the operation of the facility, pending implementation of all facility modifications, does not present an undue risk to the health and safety of the public based on our con-currence with the Browns Ferry Special Review Group's conclusions ident-ified above, (giving due consideration to the Commission Policy Statement) as well as the significant improvements in fire protection already made at the facility since the Browns 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 surveillance requirements for fire protection systems.
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We have determined that the license amendment does not authorize a change in e'ffluent types or total amounts nor an increase in power level and will not result in any significant environmental impact.
Having made this determinations, we have further concluded that the amendment involves an action which is insignificant from the stand-point of environmental impact and pursuant to 10 CFR 51.5(d)(4) that an environmental impact statement, or negative declaration and environmental 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 amendmeat does not involve a significant increase in the probability or consequences of accidents previously considered and does not involve a significant decrease in a safety margin, the amendment does not involve a significant hazards consideration, (2) there is reason-able 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 the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Dated:
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- 9. 0 CONSULTAitT'S REPORT Under Centract to fluclear Regulatcry Ccmmission, Brookhaven fiational 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 re-port, " Fire Protection Evaluation - Cooper fiuclear Station," dated December 20, 1978, discusses several matters which have been addressed in the SER. The consultant's report contains reccmmendations which have, for the most part, been implenented during our evaluation.
The consultant's recommendation which we have not adopted, along with cur basis, therefore, is as folicws:
Consultant's Comment:
"An item which related to the site visit which was not reconmended to the utility by f;RC was electrical valve supervision on all valves controlling fire water systems and sectionalizing valves.
The pre, sent proposal of administrative controls or locks is unacceptable."
Staff Resoonse:
The guidelines of Aopendix A to BTP 9.5-1 allcw electrical supervision, locking, or sealing with tamper proof seals with periodic inspecticn as means of assuring that valves in fire protection water system are in the correct position. Valves on other systems in the plant are presently under similar administrative control.
T'ne plant Technical Specifications require a nonthly check of all valves in the flow path to fire suppression systems. A review by the staff of Licensee Event Reports for all plants using such periodic checks indicates that valves being in the incorrect positan have not been a significant contributor to valve relate failures. Additionally, standing water as a result of failure of suppression system piping will not danace safety-related equipment due to curbs, drains, mounting of equipment above floor level, grating and doorways.
To date, the staff has not found any data that indicates that electrical valve supervision will significantly improve the availability of fire suppression systems in nuclear power plants.
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APPEflDIX A CHRON0 LOGY In February 1976, the report by the f1RC Special Review Group was issued as flVREG-0500, "Recomendations Related to the Browr.s Ferry Fire."
On May 1, 1976, Standard Review Plan 9.5.1, " Fire Protection," was issued, incorporating the various recomendations contained in fiUREG-0500.
By letter dated flay 11, 1976, fiebraska Public Power District was requested to compare the existing fire protection provisions at their facilities with new flRC guidelines as set forth in Standard Review Plan 9.5.1, " Fire Protection," dated May 1,1976, and to describe (1) the implementation of the guidelines met, (2) the modifications or changes underway to meet the guidelines that will be met in the near future, and (3) the guidelines that will not be met and the basis therefor.
By letter of September 30, 1976, flebraska Public Power District was requested to provide the results of a fire hazards analysis and prepose Technical Specifications pertaining to fire protection.
fiebraska Public Power District was also provided a copy of Appendix A to BTP 9.5-1 which includes acceptable alternatives to the guidelines of SRP 9.5-1.
On June 3,1976, fiebraska Public Power District replied to the Comission's correspondence of May 11, 1976, and indicated that they would provide information requested by the Comission's letter by December 17, 1976.
By letter dated December 17, 1976 flebraska Public Power District sub-mitted their report entitled " Fire Protection Review to Appendix A to Branch Technical Position APCSB9.5-1".
By letter dated February 4,1977, fiebraska Public Power District sub-mitted proposed Technical Specifications to meet the requirements of Appendix A to BTP 9.5-1.
By letter dated March 31, 1977 flebraska Public Power District submitted the fire hazards analysis for Cooper fluclear Station.
By letters dated April 6,1977 and July 20, 1977 fiebraska Public Power District revised their responses and proposed Technical Specifications pertaining to Appendix A to BTP 9.5-1.
By letter dated flovember 29, 1977 the staff transmitted proposed interim Technical Specifications to fiebraska Public Power District and requested their review.
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By letter dated December 19, 1977 flebraska Public Power District sub-mitted revised propored interin Technical Specifications in response to the staff's letter of flovember 29, 1977 and by letter dated June 21,
- 1978, fiebraska Public Power District expressed their position related to fire brigade staffing.
By letter dated February 24, 1978 the staff issued License Amendment flo. 42 which contained interim fire protection Technical Specifications for Cooper fluclear Station.
On May 11, 1978, flebraska Public Power District replied to the staff's August 12, 1977 letter outlining exceptions from the staff's guideline document entitled, "fluclear Plant Fire Protection Functional Respon-sibilities, Administrative Controls and Quality Assurance."
By letter dated June 20, 1978 the staff requested additional fire protection infomation from flebraska Public Power District.
By letter dated August 16, 1978 Nebraska Public Power District responded to the staff's questions of June 20, 1978.
From October 10 through October 13, 1978 an flRC staff fire protection review team visited the Cooper Nuclear Station and met with Nebraska Public Power District. Positions and questions arising out of this review were transmitted by the NRC staff letter dated November 1,1978.
By letter dated December 11, 1978 Nebraska Public Power District pro-vided implementation schedules and responses requested in the staff's November 1,1978 letter.
On January 24, 1979 the s,taff met with flebraska Public Power District at Regional Headquarters in Arlington, Texas to resolve residual questions from review and site visit.
By letter dated April 12, 1979 flebraska Public Pot:er District modified their training program commitment as expressed in their letter dated May 11, 1978.
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