ML19296A336
| ML19296A336 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 02/26/1979 |
| From: | Parr O Office of Nuclear Reactor Regulation |
| To: | Brian Lee COMMONWEALTH EDISON CO. |
| References | |
| NUDOCS 7903190102 | |
| Download: ML19296A336 (30) | |
Text
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o UNITED ST ATES "w
NUCLEAR REGULATORY COMMISSION 3. G.Z lf' *)
WASHING TON, D. C. 20555 S Nh[pI FEB 2 61979 Docket flos. 50-373 and 50-374 Mr. Byron Lee, Jr.
Vice President Commonwealth Edison Company P. O. Box 767 Chicago, Illinois 60690
Dear Mr. Lee:
SUBJECT:
REQUESTS FOR ADDITI0tlAL FIRE PROTECTI0il IrlFORMATIOt1 -
LA SALLE COUtlTY STATI0fi, UtlITS 1 & 2 As part of our continuing review of the La Salle Final Safety Analysis Report, we find that we need additional fire protection information to continue our evaluation. The specific information required is listed in Enclosure 1.
Please inform us af ter receipt of this letter of the date you can supply the requested information so that we may factor that date into our review schedule.
Please contact us if you desire any discussions or clarification of the information requested.
Sincerely, ole in. #
Olan I Parr, D ef Light Water Reactors Branch tio. 3 Division of Project Management
Enclosure:
1.
Fire Protection La Salle County Station 2.
Staff Requirements for Minimum Safe Shutdown and Fire Protection Systems
' cc w/ enclosures:
See next page 79031901o1
?--
Mr. Byron Lee, Jr. cc: Richard E. Powell, Esq.
Isham, Lincoln & Beale One First fiational Plaza 2400 Chicago, Illinois 60670 Dean Hansell, Esq.
Assistant Attorney General State of Illinois 183 West Randolph Street Suite 2315 Chicago, Illinois 60601 m
ENCLOSURE 1 FIRE PROTECTION LA SALLE COUNTY STATION UNIT NU!i3ERS 1 AND 2 DOCKET NU' E 50-373/374 010.0 AUXILIARY SYSTEMS BRANCi Note: The questions which identify a specific fire :one of Unit 1 copiy equally to the counterpart fire zone in Unit 2.
010.32 You state that "the fire protection system will be installed and tested (RSP) prior to reception and sto age of new fuel at LSCS."
It is our position stated in Section A.6 of Appendix A to BTP 915-1, tnat the entire fira protection procrea (plans, personnel, and ecuipment) for buildings storing new reactor fuel and for adjacent fire areas that could affect the fuel storage area should be fully coerational before fuel is received at the site.
Confirm that this item was completed before new reactor fuel was stored at the site.
Also, the administrative procedures of the fire protection program for the entire reactor unit should be fully operational prior to the first refueling".
010.33 Your response to Section 3 of STP 9.5-1, Appendix A, is inadequate.
Verify that you follow the staff supplemental guicance ccntained in
" Nuclear Plant Fire Protection Functional 0.e:pensibilities, Adnini ;ra-tive Controls and Quality Assurance," dated August 29, 1977.
010.34 Your response to Section D.l.(c) of BTP 9.5-1, Appendix A, is not (RSP) acceptable.
It is our position that all barriers separating safety related systems from other plant areas or from redundant systems be 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated barriers.
This includes walls and floor / ceiling construction. A floor / ceiling design which " qualifies" for 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rating from an internal source and a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rating from an external source is a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rated assembly and does not meet this position.
Likewise, a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rating from one side and no rating or 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> rating from the other side qualifies only as a no rating or i hour rated assembly.
For those areas where this applies describe how you will upgrade the construction to 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated construction.
010.35 Substantiate the fire resistance capability as they pertain to safety-related areas or areas exposing safety-related equipment, or high hazard areas by verifying that their construction is in accordance with a particular fire tested design.
Identify the design, the test method used, and the acceptance criteria for the following:
(1)
Rated fire barriers, including floor and ceiling construction structural supports, and doors.
Indicate the type of protective material used and the design number in reference to ASTM E-lly.
(2)
Fire dampers / fire doors, as well as how they are installed in the ventilation ducts that penetrate rated fire barriers of safety related areas; fire door dampers required in 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, rated barrier penetrations.
For all systems where credit is taken for equivalent
. rated doors, it is our position that you provide a cnufacturer's verification for these dcors.
(3) Fire barrier penetration seals around ducts, pipes, cables, cacle trays, conduits, and in other openings. Verify that all seals are of the same construction material and thickness specified in the tests, and that they meet the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> requirements for ASTM E-119.
Verify that the inplant cable tray supports are sinilar to the supporting arrangements used in the fire tests, and that in case of a collapse of the trays, the resultant unsupported icad and ;crque on the penetration seal, will not affect the integrity cf the penetration seals. Those penetrations in rated fire barriers (walls, floors or ceilings) which are not sealed should te sealed in a manner providing a fire resistance rating equivalent to that of the barrier.
(4) Fire stops in cable trays.
(5) Indicate the types of materials being used as interior finishes unich have not been tested for fire characteristics and indicate wnere they are being used.
010.36 You state in Section H.l.3 of the FSAR that you are in ccmpliance witn Section D.l.(e) of Appendix A.
However, you have not orovided any evidence to indicate tha the rcof deck construction is liste as Class I by Factory Mutual or as conccmoustible by Underwri:ers _abcratcries, Inc. '!erify that the construction meets the guidelines of this sec:icn.
_4 010.37 Verify that the floor drains are adequate to handle runoff from fire protection systems and hose streams as required by Section D.I.(i) of Appendix A.
Where drains are not provided, analyze the effects of standing water or water runoff through floor openings on safety-related equipment, and describe any water seals provided.
Describe the pro-tection to be provided for any equipment that is exposed to water damage.
010.38 You state in Section 9.5.1 that oil separators are provided for drains which will collect oil spills or leaks.
Indicate where these oil separators are located on the drawings, and indicate tne presence of any safety related equipment or circuits in these areas.
010.39 You have not indicated in the drawings the locations where flammable (RSP) liquids will be stored in the plant.
Provide a list of all flammable liquids used in the plant as well as their storoge location.
For those areas where flammable liquids are stored near safety-related equipment, it is our position, as stated in Section D.2 of Appendix A to BTP 9.5-1, that the storage area be moved or automatic fire detection and suppression systems be provided.
010.40 Your statement in Section 9.5-1 that hydraulic oils are noncombustible (RSP) is not correct. All presently available hydraulic fluids will burn under certain conditions.
Provide data for the specific fluids used at-La Salle County Station to substantiate your claim that they do not
. present a significant hazard under the conditions in which they are _: sed.
Consider in the justification a line rupture which would e:<;eli the fluid within the normal pressure range of the system.
010.41 Verify that fire stops are installed between levels or in vertical cable chases.
Fire stops should be installed at the midheight if the vertical run is 20 feet or more but less than 30 feet, or at 15-fcot intervals in vertical runs of 30 feet or more unless such vertical cable routings are protected by automatic water systens directed en the cable crays.
Individual fire stop designs should prevent the prcpcgatico of a ire for a minimum period of thirty minutes when tested fer the largest number of cable routings and maximum cable density.
010.42 Your resconse to Section D.4 of Appendix A to STp 9.5-1 is incer;1e.e Provide the following infornation:
(1) Describe the procedure employed for heat cnd sacke remcvai using fixed or portable equi; ment in areas that house-safety related systems or ccmponents.
Describe how these areas can be ventilated for manual firefighting purposes.
Consider that control or pcwer cabling for normal ventilation may not be functicnal in these areas.
- nclude c
_s.
discussion regarding control access t: the equipment (including fire dampers) as well as the ability to handle high temperature gases and particulates.
_ (2) Describe where the interlocks or local manual controls for resetting the ventilation systems in areas protected by CO, systems are located.
c Consider the effects of closed dampers in these areas, and indicate how these dampers would be reset for venting the area for manual firefighting.
(3) In each area where safety-related systams or ccaconents are located, verify that products of ccabustion exhausted from the area will not be exhausted to other safety-related areas of the plant.
(4) Describe the quantity, placement, capacity and reserve supply (6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> onsite required) for the self-contained breathing apparatus used at various locations.
010.43 Your response to Section 0.5.(a) of BT? 9.5-1, Appendix A, is not accept-(RSP) able.
It is our position that fixed 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> capacity self-contained emergency lighting of the fluaurescent or sealed beam tyoe be arcvided in accordance witn Section D.5.(a).
Verify that you will comply with the guidelines.
010.44 Address the folicwing items which relate to the interior cc:munica:icn system:
(1) Identify tne primary and any alterna:e source cf pcaer fcr these systems as well as typical circuit details.
(2) Identify the partions of tne cccmunicaticn system (s) wnich is ccanon to both Unit Number i and Unit humber 2.
. (RSP)
(3) Ic is our position as stated in BTP 9.5-1, A::endix A thac cetabia radios be provided ncorocratino receaters as necessary for the fire i
brigade and other operations personnel required to acnieve safe piant shutdown. Preoperational testing should dencnstrate that the frecuen-cies used for portable radio communication will not affect the actuation of protective relays. Fixed repeaters installed to permit use of portable radio cccmunication units should be protected fecm exposure fire damage. Also, indicate the location (s) where the fixed repeater (s) is (are) installed.
010.45 For the main control roca fire system panei and fire alarm and dctcction system, provide the folicwing:
(1) Provide a description of these panels and their associated electri-cal circuitry and devices. Supplement this descripticn wi;h elcctricil schematics which show the source of power fcr these panels and assccia'.cd devices.
Also, include a wiring diagram which shcws a typical circuit for this panel and includes the detector element (s) and associaced circuitry as well as the final indicating light and/cr alarm.
This description should also include a discussion of any forn of superviscry circuitry which is provided for this panel or its associated devices.
Also, provide sufficient data to shcw that the ccmclete fire alarm system, including waterficw and valve sucervision, confcens to appi -
cable guidance in NFPA 723 for Class A systems and in NF?; 70 for Class I circuits.
Include. a discussion of the primary and sa::n:ary ::< er
-e-supplies for the alarm system, and ir.dicate hcw ccwer is transferred to the secondary supply.
(2) Identify any differences in the associated electrical design for the fire system panel of Unit Mumber 1 and that of Unit Number 2.
(3) Provide an analysis, supported where necessary by test data, which substantiates that the sensitivity of fire detection devices and the number and placement of detectors are sufficient to provide detector response in time to prevent loss of safety-relatad system cr conocnents.
The analysis should include both fire detection devices used to notify personnel and those used to activate fire protection systems.
010.46 For the diesel driven fire pumps, provide the locaticn of tne fire puraps and their associated fuel storage tanks and lines, amount of separation between ccaconents and fire protection and description of any physical barriers between redundant ccmponents, and physical layout i.n: coeration of the control circuitry.
Indicate the normal pressure carried in the fire protection system mains and the settings for the start-uc of the fire pumps. Also, vedfy that each fire pump will be ncnitored #ce "pcwer availability" and " pump failure' in accorcance witn NFFA 20.
010.47 In the FSAR you state that the service water system can be used as a backup to the fire cumos. Provide details on Scw this would be accen-olished if the # ire cumo system is unavailable.
!# the essen:ial service water system is used to supply water to the fire ceccecticn system, show that the non-seismic section is acecua:ely isciatec ":r the seismic section.
_g_
010.43 For those areas protected by auttmatic sprinkler or c'.her aater s; ray sys-tems, provide the rationale used to determine the design cf the 5y502~.
Verify that the fire pumps can provide, in accordance wit" A::er. dix A of BTP 9.5-1 Scction E-2(e), for the largest system ficw and pressure at each elevation in the plant plus the required number of hose streams with the largest pump out of service.
010. 49 For the CO and Halon systems provide the following infomation:
2 (1) The Halon and CO systen design concentration and soaking times, 2
including allowance for leakage for those areas which are protected by total flooding systems. Sufficient information shocid be ;covided tc alicw verification of tne design concentration and soak ti e.
riso provide information to demonstrate that the Halon or CO systars will 2
be effective against tne potential fires, including deep seated cable fires, in each area. Provide the results of any system tests conducted.
(2) Describe the provisions for personnel access folicwing a gas systen discharge to pemit manual firefighting and cleanuo.
(3) For fire zones that are ecuisced with low pressure carbcn dicxice systems, provide a descriotion of the electrical actuation circuitry (frcm detectors to final actuated devices) including the autcm.atic and manual portions. Supplement this description where acorcpriate with typical electrical schematics and also provide single line diagrams which show the source of power for the active elements (these cevices in the systems which must receive electrical energy in ceder :: ce rfa rn
- neir func:fon) in these systems. 'lerify that :re cetecticn systems used to actuate the Halen and CO systems are alamea and annuncia:a:
3 in the control rocn independently of the suscressi:r syste, 3::.ati:r
. (4) Indicate the location and fire pro:ection syster.s provided f:- :"e 10-ton CO storage vessel.
2 (5) Provide typical electrical schematics for the types of ca.pers that are associated with the ventilation systems which are orovided for the fire zones served by CO r Halon. The sample schematics provided 2
should show how these dampers are powered and signaled to close when the carbon dioxide or Halen system is actuated. 'leri fy tha t the ;c'..er and control cables erving them are rcuted inde?er. cent of the 'i:3 Zcne.
010.50 You state in the FSAR that "... cables [whica ". ave satisfac:crily passed the IEEE Standard 383) will not burn unless there is a sustaining external source of heat....[and that] a fire cannot propagate unless there is a direct continuity of ccmbustibles and a centinuous flame source.
This statement is not entirely correct. Tests have sh:..n tha:
cables that have passed the IEEE 353 test will burn.
The tests at Sandia have also shcwn that where more than one cable tray can be exposed to a fire, for scme configurations, the fire will propagate to the other trays even if the exposure fire is extinguishec.
The reascn is that the initial tray ignited by the fire beccmes the conor ray or exoosure fire for the trays above and around it.
Therefore, revised your fire hacard analysis to include this assumation a.d make the neces-sary modifications iq your design.
010.51 In your fire hazards analysis at various locations in the plant (Section (RSP)
H.l.l(C)), you fail to consider that a fire of transient combustibles (including a possible liquid spill) could expose redundant trains of safety-related equipment or circuits to a single fire.
It is our position that for any redundant conduit / cable trains located within 20 feet of each other, automatic sprinklers and a half hour fire barrier be provided.
010.52 In Section H.l.2.(e) of the FSAR you state that " credit is taken for the tripping of breakers and other electrical protective devices to mitigate the consequences of electrical faults due to fires." Provide the following:
(1) Verify that the breakers will automatically trip.
If the breakers are not automatically tripped, provide an analysis which shows that the plant can be brought to a safe shutdown condition assuming that the breaker and/or protective device is not tripped before extensive damage is done to the circuit.
(2) A list of the equipment, its location and the location of the circuit breaker and/or protective device where such credit is taken.
010.53 Fire Area 1 Refueling Floor Your response to Sections F.12 and F.13 of BTP 9.5-1, Appendix A, is not acceptable.
Provide the following:
(RSP)'
(1)
It is our position that automatic fire detection, which alarms and annunciates in the control room and locally, be provided throughout the new fuel and spent fuel pool area.
Indicate the type of system to be provided.
b.I
, S..M TD 3
D**]D Y o o ju (2) You stated in your response to recues 010.17 ?.at "fices of such magnitude as to require the use of great ar.ounts of low density fluids, e.g. ' fogging mists' or fire retardant focms are rot possible in that area of the plant." Verify that the storage configuration for ne'., fuel will limit the criticality to a Keff of 0.98 for the water dersity which results in optimum moderation.
010. 54 Fire Areas 2 and 3 Reactor Building (RSP)
(1) You response to Section F.5 of BTP 9.5-1, Appencix A, is nct accent-able.
It is our position that fire detection system be provided in rooms housing safety-re'i.ted pumps or other safety related equi; rent.
Indicate thc' type of system to be installed in each such area.
(RSP)
(2) It is our position stated in Section C.5.f of Regulatory Nide 1.120 that portable extinguishers be installed throughout the plant in accordance with NFPA 10. Verify that you will comply with this position.
(RSP)
(3) You state that combustible penetration seals are used in the secon-dary containment ventilation systems.
It is our position stated in ST?
9.5-1, Appendix A, Section D that nonccatustible Ta:erials ce used for ventilation seals. Verify that you will comply with tnis position.
(RSP)
(4) Your fire hacards analysis indicates :na: there is unprotected floor openings throughout the reactor building.
In case of a fire, these openings could jeocardice the redundan: divisions of safety-related equipment and circuits in the building.
It is our posi:icn :na: conec automatic # ire detection capability be provided :nroughca: tha reactor building witn alarm and annunciatica in the c:n:rol rocn rd alar, locally. Also, it is our position that for any redundant conduit / cable trains located within 20 feet of each other, automatic sprinklers and a half hour fire barrier be provided.
(5) You indicate that two walls of fire zone 2D - Unit 1, elevation 786 feet 6 inches " extend up to within 1 inch of the steel beam," and in the next paragraph you indicate that the ceiling slab is supported on concrete beams. Verify that the steel beam is provided with a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> protective coating in accordance with ASTM E-119.
(6) You state in Appendix H that for fire zone 2G-Unit 1, elevation 210 feet 6 inches, that the ventilation air flow is supplied from elevation 740 feet and is exhausted to the RHR heat exchanger cubicles on the floor below this zone. Analyze the effect on fire detection capability for fire zone 2G if the ventilation airflow is as you state from the ceiling through the floor.
(RSP)
(7) You indicated that a transient fire load is not considered in fire zone 2H2-Unit 1, HPCS cubicle, because it is a controlled access zone.
This assumption is not acceptable.
It is our position, as stated in Section C.b of Regulatory Guide 1.120 Revision 1, that transient fire loads be considered in all areas of the plant, regardless of administrative controls.
Revise your fire hazards analysis to consider transient fire loads in this zone and in any other zones where transient fire loads were not considered, and shcw that the plant can be safely shut down.
. (8) For fire zone 2J-Unit 1, primary containment, provide the following information:
(a) More detailed drawings showing the various equipment and barriers inside containment.
(b) (i) An automatic sprinkler or deluge system for each pump with alarm and annunciation in the control room. Adequate curbs and drains should be provided and discharged to a safe location to prevent such a fire from spreading to other areas, or (ii) An engineered completely self-contained oil collection system around all pressurized oil piping with proper drainage (including capacity) to a safe location.
010.55 Fire Area 4 Auxiliary Building (1)
Your fire hazards analysis of fire zone 4A, upper ventilation equipment floor, states that the zone does not contain any safety-related equipment. However, both Figures 9.5-1, Sheets 5 and 6, and Table H.3-1 indicate the presence of safety-related equipment.
Revise your analysis to consider the effects of a fire on these systems and show that the plant can be safely shut down.
(RSP)
(2) Table H.3-2 indicates the presence of wood as a combustible material in fire zone 4A, upper ventilation equipment floor.
It is our position that you provide an adequate fire suppression system.
(RSP)
(3) You indicate that the dampers provided in the wall which separates fire zone 4B, lower ventilation equipment floor, from the reactor building do not qualify for a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rating.
You also indicate that " fire dampers" rather than 3' hour rated " fire door / dampers" are installed in other ventilation openings in fire walls.
It is our position that ventilation openings in 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire-rated construction be provided with 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire door / dampers.
Verify you will comply with this position in this area, as well as any other areas of the plant.
(4) Several " air risers" are indicated on Figure 9.5-1, Sheets 9 and 10, in fire zone 48, but the rating of the enclosing walls is not indicated in all cases.
Verify that the fire rating of the walls whicn enclose the ventilation shafts is a minimum 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
(5) Your analysis has not included the charco-filters as part of the combustible loading in fire zone 4B, yet it was toiaidered in other areas. An exposure fire in this area could damage the units and expose the charcoal. This would result in a propagation of the fire in this area which could effect the safety-related equipment ir, this area.
Revise your analysis to include charcoal filte s as par' of your fire loading in all safety-related areas where you ha.e r 't alreafv done so and show that the plant can be safely shut down.
(RSP)
(6) You state in your analysis for fire zone 4Dl-Unit 1,.able spreading room, that backup manual protection consists of a fire hose station with 75 feet of hose.
Indicate the location of this hose stction with 75 feet of hose.
Indicate the location of this hose station on Figure 9.5-1, Sheet 15 of 16, none is indicated.
Figure 9.5-2 indicates the presence of a hose station near column 12N wnich is fed from tne same header segment as the primary protectico for this fire zone.
It is our position as indicated in Sections A.4 and E.3(a) of BTP 9.5-1, Appendix A, regarding single failure criteria of tne fire suppression-system, that a single break or other failure should not impair both the primary and back up fire suppression capability as would be the case in this area.
Revise your design accordingly and also comply with part (7) below.
(7) Your standpipe hose instrllation in fire zones 401 and 402-Unit 2, cable spreading room, and 4El-Unit 1, auxiliary equipment room, is not in compliance with Section E.3(d) of BTP 9.5-1, Appendix A, or with NFPA 14.
The present installation is not adequate to provide an effective hose stream to all areas of the cable spreading room.
Revise your design to provide adequate hose streams to deliver an effective hose stream to all areas of this zone as well as all other plant areas with a maximum of 100 feet of hose at each location.
(8) You state in Appendix H, that " provisions are made to purge this zone (fire zone 4El) with 100 percent outdoor air by manually repositioning dampers with a control switch on the remote control panel located within this zone." Describe how the purge with 103 percent outdoor air will be initiated if there is a fire in fire zone 4El which prevents access to the control panel.
i (RSP)
(9) No fire dampers are provided in the ventilation ducts in fire ::ne 4El.
If the fans are not shut dcan during a fire, de effe:: cf the Halon system concentration on the fire is ne;ligible.
It is cur p si-tion that 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire door / dampers be provided.
Verify that you will ccmply with this position.
(RSP) (10) You indicate that the battery rooms' fans are relied upcn to are /ent hydrogen buildup.
It is cur position as stated in Section C.6.g of Regulatory Guide 1.120 Rev. I that loss-of-ventilation-fica alarns be p'ovided for these ventilation systcms and that the alarn chculd scund r
and annunciate in the control room.
Verify that you will c:mply.ith this position.
(RSP) (11) Section F.6 of Appendix A to STP 9.5-1 recc : mends th:t fire detection systems be provided in areas where safety-related panels are located. Comply with this guideline.
It is also our cosition that in unmanned areas where enclosed cabir.ets or panels, which ccn:ain redun-cant divisions are located, that an autcoatic Halen syster ce insulled.
Verify that you will ccmply with this position.
010.56 Fire Zone aC Control Room Comolex (1) You state in the FSAR that Division i cat:ies are spreac c.er ;ne control roca panels and enter the panels fr:' the top.
Indicate if a suspended ceiling is provided in the control room, and if such a ceiling is provided, indicate whether the cables are above or below the cailing.
If the cables are above the ceiling, veri y tha: the :e:ec-tion and suporessicn systems wnich will be ins alled :: :r::s:: re concealed cable will ce in accordance witn Sectico C.6.b of Reculatory Guide 1.120.
If a false ceiling is not installed, or cables are located 'elow the ceiling, indicate what will be done to put out the cable fire in the control room.
(RSP)
(2)
It is our position as indicated in Section C.6.b, of Pegulatory Guide 1.120, Revision 1 that individual control room cabinets and consoles which c~.tain redundant safety-related circuits be provided with detection capability as well as an automatic fire suppression system.
In lieu of providing detectors in the other cabinets as required by Appendix A to BTP 9.5-1 Section F.2, detectors may be installed in the fire area above the console or cabinets or in the pler.ums, provided that these detectors will be as responsive to fires as would integral detectors within the cabinets.
(RSP)
(3) Your statement, that fire dampers are not provided in the supply and returr, ducts for the control room, is not acceptable.
It is our position stated in Sections D.1.(j) and F.2 of Appendix A of BTP 9.5-1 and Section C.6.b of Regulatory Guide 1.120 Revision 1 that 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated fire door dampers be installed to protect ventilation duct openings through barriers which separate areas which contain safety-related equipment or circuits from other areas. Verify that you will comply with this position.
(RSP)
(4) You state in the FSAR that a wood block base is set into the wall and that carpeting is provided in the control room.
It is our position that both the wood block base and the carpeting be removed fecn the control room. Verify that you will ccmply with tnis position.
(5) You state that " smoke detection of 100 percent" in the supply air system will initiate a recirculation mode.
Explain what is meant by
" smoke detection of 100 percent" and why it is acceptable.
pD 9 0'3' D (Q a
k 19 6
.UJ<JL 3
(6) In your analysis you state thct fire :enes aC2, at: and 2C' 30 n:
contain any safety-related equi; tent. Mcwever, Table H.3-1 and Figure 9.5-1 Sheet 13 indicate the presence of safety-related cabies and cable trays.
Revise your analysis to include these cables and the effects of a fire on them and sho.4 that the plant can be safely shut d:.sn.
(RSP)
(7) 'fou state in your Fire Hazards Analysis tcw varicus safety-related cable trays, conduit and equip. Tent are separated by distance 'cc-its redundant counterpart, and the criteria that were used to estab'.ish barriers between these redundant trains.
- n order to pr:vice a de'ensc-in-depth design, so that a fire will not prevent the perfor ance of necessary safe plant shutdown functions, a detailed fire ha:ards analysis should be conducted for ca:h plant area.
It is essential that the analysis include the effects of ;cstulated fire in.olvi.7 permanent and/cr transient cc.mbustibles (e.gcuure fires) ca. syste 3, circuit cable trays or equi; rent required for safe plant cold snatcc.4n.
The fire hazards anciysis should identify all the recandar.; ce c h a-i ;3 '.
and electrical systems and ccTponents necessary f e safe co'.: :hu ::wr which are separated only by distance (r.o fire bar-iers ard witr redun-cant trains 20 feet or less from each other).
Redundant trains within 20 feet of each other, as a minimum, will be required to be protected by a half hour fire rated barrier as well as area aut: ati: 2 7ilers.
This cCes not mEan that in SCe instances, such 35 Catle I 'ea0i'; r0:~
and rel3y roCm,150'! and 1150'! switChgear '00m, '3Ca'03n! I'l#"s se:arated by 7Cre inan 20 feet will not require additional protection.
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'D
' M $ oof of,2U$ h The fire hazards analysis need to dem:nstrate tha., assr.ing f ailure cf the primary suppression system, a fire on installed cr transien
- cm-bustibles will not result in the loss of capability to achieve safe cold shutdown. Where this car.r.ot be demonstrated, an alternate means of assuming safe plant shutdown (, cold shutdcan) should be provided.
Demonstrate that:
(a) Safe shutdown frca the main control roca where a fire disabics any safe shutdcun equipment including conduit / cable trays centrolle'. fr:m remote locations.
(b) Safe shutdcwn from remote locations when the main cen:rol rcm is uninhabitable due to a fire or when fire disables safe shutdowe equip-ment of the relay room or 46CV switchgear roca cr "160V switchgear roca.
Remote location need only be provided for the essential instra entation, controls and eqJipment necessary to bring the plar.t :: a nct s g.dtj condition.
Fire damage to systems necessary to acnieve ar.d maintain cold shutdcun should be limited so that repairs can be made and col::
shutdown condition achieved within 72 hrs.
A detailed breakdcwn of staff requirements ter.cicsure 2) is encicsec for:
(a) Minir'um safe shutdown systems when or.e division of all saf at.
systems is not available.
(b) Minimu.1 fire pec:ection when decicated c alter. ate shutd;. r. sys am are prcvided.
..... (8) Supplement item (7) above as follows:
(a)
It is assumed that the motive and/or control power to systems and components required for achieving hot and cold shutdown would be lost as a result of a postulated fire.
Thus, for each fire hazards analysis that must be performed for a plant area, describe the design provisions and/or the procedures to be implemented that will assure that motive and control power supplies affected by the fire are restored to those systems and components that are essential for achieving hot and cold shutdown.
(b)
For each fire hazards analysis that must be performed of a plant area, identify those valves which are necessary for hot and cold shutdown and are not required to be acted upon because it has been assumed that these valves will remain in the same position as they are following a fire event.
It is our concern that the fire event may cause tne spurious operation of these valves to a position which is different from that required to accomplish hot or cold shutdown.
Describe in each case the design provisions and procedures to be implemented that will assure that the spurious. movement of these valves would not result in the loss of capability to achieve hot or cold shutdown.
(c) Confirm that the associated electrical design of the correspcnding remote shutdown instrumentation and control panels is the same for the two units, or explicitly delineate the differences.
. 010.57 Fire Area S Turbine Buildina (1) The walls which separate the auxiliary building from the turbine building are, at least in some cases, only 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated partitions, while the floor / ceiling construction is common to both buildings.
In the turbine building, much of the supporting structural steel is apparently exposed. Analyze the structural integrity of the areas of the auxiliary building which are adjacent to the turbire building given a fire in the turbine building which causes structural collapse of the turbine building. Consider the effect of the collapse of the continuous floor slabs which would cause corresponding destruction in the adjacent safety-related areas.
Show that the plant can be safely shut down.
(RSP)
(2) You state that fire zone 5B10-Unit 2, motor driven reactor feed pump room, is similar to fire zone 5B9. The description of fire zone 8Al, HPCS diesel ventilation equipment room, indicates that the east wall of fire zone 5B10 has no fire rating from external sources.
It is our position that this wall be upgraded to a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated barrier.
Also upgrade the fire barrier between fire zone 8Al ard SA2, Division 2 diesel ventilation equipment room, to a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated barrier. Verify that you will comply with these positions.
(3) Areas of fire zone SCll, turbine building ground floor, are adjacent to the diesel generator buildings and contain redundant divisions of safe shutdown cable.
Identify the locations of any flammable liquids in piping (including turbine oil lines) in this zone which is in the vicinity of the diesel generator buildings, the auxiliary building, or any safety-related cables and describe the fire suppression systems provided.
. (4) Verify that the motor-operated rolliag steel fire doors to the diesel generator buildings have automatic closing devices which would close the door in the event of a fire regardless of the position of the door.
(5) Since the ceiling to fire zone 506, clean and dirty oil tank room, has no fire rating and there is the 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> fire barrier between this area and the above auxiliary equipment rooms, describe how a fire in this zone would be extinguished assuming failure of the primary suppression system.
Indicate where the floor drains located in this zone are routed.
010.58 Fire Zone 7 and 8 Diesel Generator Buildings (RSP)
(1) Your statement in the FSAR regarding openings in the diesel generator building wall which are within 50 feet of the transformers is not acceptable.
It is our position that the intake louver be provided with 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated closure or that a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire barrier be constructed between the transformers and the wall openings. Verify that the already installed block barrier is a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated barrier.
(2) Verify that the exposed s-teel which supports the roof, for fire zcnes 7Al (HPCS diesel vencilation equipment room), 7A2 (Division 2 diesel ventilation equipment room), and 7A3 (Division 1 diesel ventila-tion equipment room) is not continuous from one zone to another.
Analyze the effect on safety-related systems located in these areas assuming the collapse of this roof structure.
Provide the same analysis for the scuth wall which is common to these zones.
Provide autcmatic detection systems in these areas.
If the consequences of the roof structure are not acceptable, provide fire suppression in tnese areas.
. (3) Analyze the effect on safe plant shutdown if the ventilation systems for RHR service water pumps lA and IB pump rooms is damaged due to a fire in fire zone 7A3.
(RSP)
(4) Your analysis indicates tha presence of a non-rated hatch from each of fire zones 781 (HPCS diesel generator room), 7B2 (Division 2 standby diesel generator room), and 783 (Division i standby generator room) to the fuel tank rooms below. This is not in compliance with Section F.10 of BTP 9.5-1, Appendix A, which recommends a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated, water tight barrier.
It is our position that the entire floor construction, including the floor hatches, be qualified for a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire resistance rating. Verify you will comply with this position.
(5) Your description of the CO actuation system is not clear.
2 Explain whether the ventilation systems are shut down on actuation of the detection systems or actuation of the CO systems.
If the system is 2
shutdown on actuation of the detection system, analze the effect on C0 concentration if the CO system is actuated manually and the dampers 2
2 do not close.
(6) Assuming a fire occurs while the generator is running, describe the affect of the operation of the CO system in the diesel generator 2
room on the operation of the diesel generator.
If the operation of the diesel affects the capability of the CO to put out the fire, provide a 2
lockout device which lockouts the CO system while the diesel is running.
2 (RSP)
(7) Your analysis of fire zones 782 and 783 indicates the presence of two 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated fire doors in each zone in the barrier between the two zones. These are identified on Figure 9.5-1, Sheet 22 as the doors to fire zone 7B5, Division 2 diesel day tank room (two doors from fire
, zone 7B2) and fire zone 7B6, Division 1 diesel day tank room (two rooms from fire zone 783). However, Figure 9.5-1, Sheet 22 also shows a non-rated door between fire zones 782 and 783.
It our position stated in Section D.l.(j) and F.9 of Appendix A to BTP 9.5-1 that this door be replaced with a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated fire door and fr assembly.
Verify that you will comply with this position.
(8) Figure 9.5-1, Sheet 22 indicates the presence of the main and auxiliary transformers are within 50 feet of the diesel generator building.
Indicate the routing of the power lines from these transformers into the buildings, with particular attention to any areas where these cables may be routed through an area which contains ESF-1 or 2 cables.
For these areas, discuss the fire protection (detection, protection, and separation) provided for the ESF cables.
(9) Verify that the curbs provided at the doorways are sufficient to contain 110 percent of the capacity of the day tank in fire zones 7B4 (HPCS diesel day tank room), 7B5 and 786.
(RSP)
(10)
It is our position as stated in Appendix A Section D.l.(j) that the openings to and between fire zones 7C4 (HPCS diesel pump room),
7C5 (division 2 -RHR service water pump room) and 7C6 (division 1 -RHR service water pump room) which are presently provided with only non-fire rated watertight doors be provided with 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated fire doors.
Verify that you will comply with this position.
(RSP)
(11)
It is our position as stated in Appendix A Section D.l.(j) that the hatch provided in the ceiling of fire zone SC5, Division 1 RHR
26 -
service water pump room, be replaced with a hatch with a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire resistance to adequately separate this area from the turbine building.
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h 9
ENCLOSURE 2
(
Staff Requirements for 'tinimun Safe Shutdown and Fire Protection dystens (1)
Minimm safe shutdown systems wnen one division of all safety systems ts not available.
(a) Following any fire, the plant can be brougnt to hot shutdown conditions using equipment and systems thatare free of fire damage.
(b) The plant should be capable of maintain 1ng hot shutdown conditions for an extended time period significantly longer than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
(c) Fire damage to systems necessary to achieve and maintain cold shutdown conditions should be limited so that repairs can be made and cold shutdcwn conditions acnieved witnin 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
(d) Repair procedures for cold shutdcwn systems should be prepared now and material needed for Itch repairs should be en the site.
(e) The hot shutdown condition must be achievable witn pcwer from the offsite power system, and upon its loss, with power from the onsite power system.
A dedicated power supply may be substituted for the onsite power system.
(f) The power needed to achieve the cold shutdown condition may be obtained frem any one of the offsite power, ensite power, and dedicated power system.
(5) 'Ahen tnese minimum systems are provided their adequacy shall ce verified by a tnorough evaluation of:
(i) Systems required for hot shutcown; (ii) Systems required for cold shutdcwn; (iii) Fire damage to pcwer distribution systems; and (iv) Interacticns caused by fire canage to ::cwer and water su:: ly systems and to supporting systems, i.e., c:=cenent cooling water su::cly.
(2)
Minimum fire protection when cedicated or alternate snutdcwn systems are provided.
(a) The fire ;:rotection systems in areas (such as cable screacing reces) that contain cables for a large num::er of systems sacuic consist of:
(i) Fire detecticn system; (ii) Hose statiens; and (iii) Fixed manual suppressicn system (gas or water)
NOTE: Consideratien :: preventing fire :r~:::aga:icn via covered trays, fire retartant coating, barriers Or blankets on a case-by-case basis.
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-2 (b) Where access is difficult or impossible automatic systems should be provided."
(c) Where modifications will not be implemented for an extendac period, interim protection measures should be required to compensate,,for,the lack of p,ro,tection.
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