ML19290E563
| ML19290E563 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 01/31/1980 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19290E560 | List: |
| References | |
| NUDOCS 8003140211 | |
| Download: ML19290E563 (5) | |
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SUPPLEMENT TO THE FIRE PROTECTION SAFETY EVALUATION REPORT OYSTER CREEK NUCLEAR STATION DOCKET NO. 50-219
' 3.0 EVALUATION The following provides our evaluation of the incomplete items.
Numbers in parentheses following each heading refer to the sections of our previously issued SER which address these incomplete items.
3.1 Administrative Controls (3.2.1) 3.1.1 General Thr administrative controls for fire protection consist of the fire protec-tion organization, the fire brigade's training, the controls over combus-tibles and ignition sources, the prefire plans and procedures for fighting fires, and the quality assurance provisions for fire protection. By letter dated April 7, 1978, the lic.ensee provided a description of the elements of his administrative controls for fire protection to demonstrate conformance to staff guidelines contained in " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls, and Quality Assurance."
This description was supplemented by letter of September 22, 1978.
3.1.2-Organization The licensee's fire protection organization description contains the functional responsibilities and the lines of communication between all positions involved in the fire protection program.
The fire protection organization description identifigs the management and staff positions responsible for formulation, implementation, and assessment of the fire protection program. The organizational responsibilities are delineated for design, selection, installation, testing, maintenance, modification, and review of fire protection systems and for fire brigade training. Qualification requirements have been established for the training instructors, and the positions responsible for formulating and implementing the fire protection program.
We find that the fire protection organiution satisfies the staff guide-lines identified in Section 3.1.1 and is, therefore, acceptable.
3.1.3 Fire Brigade Training The fire brigide training program consists of classroom instructions, fire drills, and practice in fire fighting. The fire brigade training program contains the following essential elements: use of fire fighting equipment, fire fighting principles and techniques, use of fire fighting procedures, periodic practices in actual fire fighting, and periodic fire drills to assess brigade effectivenes'. These drills also provide practice in the use of equipment, fire figt ting procedures, and brigade leadership.
Records of fire brigade meabers' training and drills are main eined and available for review.
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We find that the fire brigade training program satisfies the staff guide-lines identified in Section 3.1.1 and is, therefore, acceptable.
3.1.4 Control of Combustibles The licensee has identified the measures establish'd to minimize the amount of combustibles that a safety-related area may be exposed to.
These include provisions to: limit the use and storage of combustibles in safety-relatad areas; establish work controls and required additional fire protection where transient fire loads are introduced; assure the removal of waste, debris and scrap materials following work activities; and provide for periodic housekeeping inspections.
We find that the control of combustibles satisfies the staff guidelines identified in Section 3.1.1 and is, therefore, acceptable.
3.1.5 Control of Ignition Cources The control of ignition sources minimizes the potential for fire resulting from work in olving ignition sources such as welding, cutting, grinding, and open flame work or smoking. The controls on ignition sources to be established by the licensee require: use of a work permit authorized by a qualified individual prior to performing cutting, welding, grinding, or other flame work; removal of moveable combustible material; use of trained and equipped fire watches; provisions for protection by curtains or covers when performing cutting, welding, grinding, or other flame work; and restrictions on smoking in safety-related areas.
Use of open flames or combustion generated smoke for leak detection in safety related areas is prohibited.
Subject to implementation of procedures to control ignition sources, we find that the control of ignition sources satisfies the staff guidelines identified in Section 3.1.1 and is, therefore, acceptable.
3.1.6 Fire Fighting Procedures The licensee has pro'vided a description of the current fire fighting procedures and the procedural elements to be changed in the near future.
The fire fighting procedures identify the actions to be taken by the individual discovering the fire, action to be taken by the control room operators, the fire brigade actions, and the necessary strategies.
These fire fighting stratagies will be developed following completion of the detection and alarm sy:, tem design.
Subject to implementation of.nese changes to fire fighting procedures, we find that the fire fighting procedures satisfy the staff guidelines identified in Section 3.1.1 and are, therefore, acceptable.
3.1.7 Quality Assurance The licensee has elected to meet NRC's fire protection QA criteria by applying their existing QA program under 10 CFR Part 50, Appendix B, to fire protection with certain exceptions. We have reviewed these 3->
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4 exceptions and find that these satisfy the intent of our guidelines identi-fied in Section 3.1.1.
This QA program should adequately cover the quality assurance provisions for fire protection in safety related areas such as the control of the design, procurement, installation, testing and maintenance of fire protection equipment.
We find that the licensee's commitment to apply the existing QA program under 10 CFR Part 50, Appendix B, to fire protection activities as noted above, satisfies the staff guidelines identified in Section 3.1.1 and is, therefore, acceptable.
3.2 Radwaste Fires (3.2.2)
Our SER noted that the potential for release of radioactive material due to fires in radwaste areas should be evaluated. By letters of April 7, 1978 and August 31, 1979, the licensee provided the results of an evaluation of fire protection for radioactive waste facilities, including the potential for a fire to cause a release of radioactive material.
The following summarizes the results of this evaluation:
(1) Existing radioactive waste facility - The building is separated from other areas by at least 3-hour rated barriers and most radioactive material is contained in tanks and demineralizers which are enclosed in at least 3-hour fire rated vaults. The only area where a fire could cause release of radioactive material is the waste storage area, where some contaminated combustible material is accumulated prior to being compacted in steel storage containers. The licensee has indicated that since this material is low level and of small quantity, and the airborne particulates would be removed by ventila-tion filters, the resulting offsite dose levels would be insignificant.
The licensee's evaluation indicated that barrels of waste are sealed in steel drums in the old radwaste facility; however, a maximum of five barrels of compactable waste could be burned that are not sealed. Release of radioactive material would c~onservatively result in an activity of less than.13 curies (Ci). The ventilation filters for this area would contain most of the radioactive material; however, even if all of the material were relased out of the plant, resulting doses would be well within 10 CFR Part 100 limits. We have discussed this analysis with the licensee and agree with his conclusions.
(2) Augmented off gas facility - Licensee analyses have demonstrated that release to the environment of all contained radioactivity in the facility, with the exception of that contained in charcoal filter beds, would result in offsite doses that are well within 10 CFR Part 100 limits. The charcoal filters are contained in steel cylinders and thus not likely to be ignited by an exposure fire'.~- The effect of release of contained radioactive material in off-gas charcoal filters, whether due to a fire or other causes, is being reviewed in a separate generic task.
(3) New solid liquid radwaste facility
.All high level waste is contained in tanks enclosed in vaults that are at least 3-hour fire rated. The facility contains only minimal combustibles, and therefore, fires that could occur would not damage the tanks or cause release of radioactive material.
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Despite the above evaluation, fire protection will be provided to assure prompt detection and suppression of fires that may occur.
This will include fire detection devices that alarm locally and in the control room, portable fire extinguishers, and hose houses with yard hydrants.
Based on the above we find that fire protection for radwaste facilities satisfies the objectives of Section 2.0 of our SER and is, therefore, acceptable.
3.3 Fire Barrier Penetrations (3.2.3)
Our SER noted that the licensee had proposed to upgrade a limited number of fire barrier penetrations, but had provided no justification for those which were not to be upgraded.
Our SER noted that f.he staff had taken the position that all door, ventilation duct, natchway, electrical cable, conduit, and piping penetrations be upgraded to a rating equivalent to that required of the fire barrier.
In most instances this would need to be a 3-hour fire rated barrier unless it was demonstrated that a lower rating was adequate. By letter of August 1,1978, the licensee provided the results of an evaluation of all such penetrations through fire barriers.
This evaluation showed that in nearly all cases, the penetrations will be upgraded to a 3-hour fire rating, as recommended by 8TP 9.S-1.
Penetrations that will not be protected to a 3-hour fire rating and the basis therefore have been reviewed by the staff and are found Riceptable.
The electrical cable penetration fire stops are being upgraded using a silicone foam material that has been tested to demonstrate its ability to withstand a 3-hour exposure fire. The adequacy of this firestop design was addressed in our fire protection SER.
Based on the above we find that penetrations through fire barriers will be adequately protected to limit the spread of fire between areas and satisfy the objectives of Section 2.0 of our SER. Accordingly we find the protec-tion provided such penetration is acceptable.
3.4 Communications Equipment (3.2.4)
Our SER noted that fixed in plant communications systems were not installed to any separation criteria and thus were susceptible to simultaneous loss in a fire.
To provide communications capability for fire fighting and plant shutdown activities, the portable communications system would have to be relied on.
The licensee had proposed to evaluate the adequacy of the existing portable ccmmunicatinns system to provide communications
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between plant areas. By letter cated April 7, 1978 the licensee indicated that tests showed communicatiori between the control room and certain areas in the reactor building e.id turbine building was not possible using the portable communication equipment.
To assure that adequate communica-tions capability will be available for fire fighting and safe shutdown activities, the licensee has proposed to install fixed repeaters for these areas, compatible with the existing portable communications equipment.
The repeater system will be tested to assure its compatibility with safety system instrumentation.
Subject to implementation of this modification, we find the communications system satisfies the objactives of Section 2.0 of our SER and is, therefore, acceptable.
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3.5 Fire Hazards Analysis -(3.2.5)
Our SER noted that the licensee would provide an update of the fire hazards analysis after the completion of all modifications. All modifications with the ext-stion of the alternate shutdown system will be completed by about July 1980, and a fire hazards analysis update may be submitted at that time. However, final evaluation of the fire hazar'Js analysis cannot be made until design and location of equipment and cabling for the alternate shutdown system have been finalized. The design of the alternate shutdown system has been deferred to be coordinated with requirements from the Systematic Evaluation Program (SEP). Accordingly our review of this item will be deferred to the SEP.
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