ML19296D600
| ML19296D600 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 02/14/1980 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19296D599 | List: |
| References | |
| NUDOCS 8003070043 | |
| Download: ML19296D600 (8) | |
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ENCLOSURE 1 PILGRIM, UNIT 1 - FIRE PROTECTION SER SUPPLEMENT LIST OF SUBMITTALS AND STATUS OF ASSOCIATED ISSUES SER SECTION SUBJECT ISSUE SUBMITTAL STATUS 3.1.14 Exposed Structural Steel 3/14/79, 7/6/79 C
3.1.16 Breathing Apparatus 1/16/79, 2/5/79, 3/30/79, 7/6/79 R
3.1.17 Communication Systems 3/14/79 R
3.1.18 Alternate Shutdown Capability 10/5/79 I*
3.1.19 Penetration Seals 3/30/79, 7/6/79, 10/10/79 R
3.2.1 Safe Shutdown Analysis I*
3.2.2 Testing Fire Detectors I*
3.2.3 Battery Room Ventilation Airflow Monitor 1/16/79, 2/5/79, 3/14/79, 7/6/79 C
3.2.4 Cable Combustibility 1*
3.2.5 Spread of Combustible Liquid Fire via Drain 2/20/79 C
3.2.6 Charcoal Fire in A0GS 1/16/79, 2/5/79, 7/6/79 I**
3.2.7 DC Power System Hazard Analysis 2/1/79 R
3,2.8 CO2 System Discharge Test I*
C - Complete I - Incomplete R - Requirement
- The licensee's response either has not been received, or is incomplete.
- - L. Barrett of Environmental Evaluation Branch was requested on January 17, 1980 to evaluate the licensee's submittal on this issue.
8003070
ENCLOSURE 2 PILGRIM, UNIT 1 - FIRE PROTECTION SER SUPPLEMENT EVALUATION OF SUPPLEMENT ITEMS THAT ARE COMPLETE 3.1.14 Exposed Steel Protection SER Section 3.1.14 indicates that exposed structural steel will be protected by coatings to provide three hour fire protection in those plant areas where the failure of the steel might affect safe plant shutdown.
By letter dated March 14, 1979 the licensee proposed to provide three hour rated fire protection for exposed structural steel in various areas of the plant.
These areas include the recirculating pump motor-generator set room on elevation 51 feet, the cable spreading room, switchgear rooms A and B, and major parts of the reactor building open areas on elevation 23 feet.
The licensee proposed to apply a chloride, sulfide and asbestos-free fire-proofing material in accordance with basic designs shown by UL tests to provide three hour rated fire resistance for beams and columns.
The staff determined from its review of the design information provided by the licensee that:
o The licensee had not proposed to fireproof steel rods and other attachments to beams, which could conduct heat to the otherwise protected beams, o The proposed fireproofing designs were not applicable to certain small beams and columns in several plant areas.
Therefore, the thickness of the fireproofing compound might not be sufficient to provide a three hour fire resistance rating for these structural members.
o The licensee had proposed to leave structural steel in part of the reactor building open area without fireproofing.
By letter dated July 6, 1979, the licensee provided additional design details on the proposed fire proofing, and indicated that fireproofing of additional parts of the reactor building open area was being considered.
By conference call of October 12, 1979, the licensee also indicated that two different fireproofing compounds would be applied to columns in the following manner:
_2_
o A material with a surface which could be easily decontaminated would be provided on the lower ten feet of columns.
o A material which could be easily installed in hard-to-reach areas would be provided elsewhere.
o A Marinite separator would be installed at the interface between the two materials.
By conference call of October 16, 1979, the licensee responded to previous staff comments by agreeing to the following:
o Clamps on beam would be covered entirely with the proposed fireproofing compound and rods and other attachments covered to a distance of several inches from the beam.
o All exposed structural steel in the designated areas would be protected, and an analysis would be performed to show that the loss of certain small beams and columns to which the proposed fireproofing designs were not applicable,:ould have no adverse consequences on plant safety.
o All exposed structural steel in the reactor building open area on elevation 23 feet would be protected.
o The Marinite interface would not be used.
The staff has not yet received a docketed response confirming these agreements.
Subject to written confirmation of these items, we accept the licensee's proposal for protecting exposed structural
- steel, 3.2.3 Battery Room Ventilation Air Flow Monitor SER Section 3.2.3 indicates that each battery room will be equipped with a ventilation air flow monitor which alarms and annunciates in the control room on loss of the air flow to either battery room, or the licensee will provide justification that such monitors are not necessary.
By letter dated January 16, 1979, the licensee indicated that calculations had been performed to determine the hydrogen evolution rate and time required to reach a 2 percent concen-tration of hydrogen in each battery room.
- By letter dated February 5,1979, the licensee provided the assumptions and methodology (but not the details) used in the analysis.
By letter dated March 14, 1979, the licensee proposed to install an air flow monitor in the outlet duct of each battery room and provided detailed information on the associated mechanical and electrical systems. The proposed monitors would alarm and annunciate in the control room on:
o Loss of air flow, or any reduction of air flow greater than 25 percent, or o Loss of power to the air flow monitors.
By conference call of May 4,1979, the staff discussed various concerns regarding details of the proposed design.
By letter dated July 6,1979, the licensee provided written confirmation of the conference call discussion.
We accept the licensee's proposal to install the air flow monitor.
3.2.5 Prevention of Spread of Combustible Liquid via Drain Systems The Safety Evaluation Report (SER) states that the licensee will perform a study to determine the extent to which backflow valves need to be installed in the drain systems for the reactor building quadrants and any other plant areas containing large quantities of combustible liquid.
In a letter dated February 20, 1979, the licensee addressed this problem for three areas: the reactor building quadrants, the recirculation M.G. sets and the hydrogen seal oil system in the turbine building.
The reactor building quadrants contain the RCIC turbine which has 20 gallons of lubricating oil with a valve between the turbine and the drain line.
This valve is normally closed so that in case of a fire and at oil leak the oil would not go into the drain system.
If the valve were left open a 12" water seal assures that the fire would not spread to any other area.
The HPCI turbine contains 225 gallons of lubricating oil.
This oil if spilled could go into the reactor building equipment sump or the reactor building floor sump.
Each of these sumps has a capacity of 879 gallons made up of 468 gallons from high level alarm to overflow and 411 gallons for high capacity.
There appears to be no likelihood of a fire spreading from one area to another by way of the drainage *.ystems from either the HPCI and RCIC oil supplies.
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The recirculation M.G. set each has a supply of 700 gallons of oil and have curbs to contain the combustible liquid.
There is an oil separator installed in the drainage system, the oil leaves the separator and goes to a non-safety related area.
The oil free waste from the separator goes to a neutralizing sump. There appears to be no change for spread of combustible oil to another safety related area.
The hydrogen seal oil system is located in the turbine building and contains 410 gallons of oil. There are curbs installed to collect the oil in case of a spill. The drainage system has an oil separator located our of the fire zone. There appears to be no change of spread of a fire to a safety related area.
By telecon dated February 7,1980, the licensee was requested to confirm that drain systems serving redundant emergency diesel generator (D/G) rooms are separated from and independent of each other so that a fire in one D/G room will not spread to the redundant D/G room via the drain system.
On February 12, 1980, the licensee confirmed over the telephone that although drain systems from redundant D/G rooms are tied together before draining to a common sump they are provided with backflow protection val es so that spread of a combustible liquid fire between redundant D/G room via the drain systems is not possible.
We accept the licensee's conclusion on this study.
ENCLOSURE 3 PILGRIM, UNIT 1 - FIRE PROTECTION SER SUPPLEMENT EVALUATION OF SUPPLEMENT ITEMS FOR WHICH
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TH1 LICENSEE'S PROVOSAL IS NOT ACCEPTABLE 3.1.16 Self-Contained Breathing Apparatus SER Section 3.1.16 indicates that the licensee will provide sufficient additional compressed air bottles, a cascade filling system and a compressor to assure emergency breathing air capability to sustain ten men for six hours.
By letters dated January 16, 1979, February 5,1979, and March 30, 1979, the licensee described the arrangement and procurement of self-contained breathing apparatus for the control room only.
By conference call on May 4, 1979, the staff requested the licensee to provide information pertaining to the commitment in SER Section 3.1.16.
By letter dated July 6,1979, the licensee provided information in response to the conference call request.
The licensee's response indicated that a cascade filling system and compressor located in the warehourse were designed to fill 16 air bottles without using the compressor and had unlimited capacity when the compressor was used.
The rate at which bottles can be filled was not specified.
We require that the cascade filling system and compressor be capable of refilling air bottles at a rate sufficient to concurrently supply ten men for six hours each.
We will also require the licensee to provide two spare air bottles, rated at least 30 minutes, for each of ten telf-contained breathing apparatus.
3.1.17 Communication Systems SER Section 3.1.17 indicates that repeaters or antennas will be installed as necessary to ensure effective backup portable radio communication to facilitate fire fighting in the plant.
By letter dated March 13, 1979, the licensee proposed to install in-plant antennas and provided design criteria for such.
The licensee's submittal, however, did not indicate if:
(1)
The proposed system will provide portable radio communication between the control room, the guardhouse and all other points in the plant, including inside the containment, where both fixed communication system could be lost simultaneously to a fire.
- (2)
The arrangement of the antenna is such that the antenna system and the fixed communication systems are not subject to a simultaneous loss due to a fire.
We will require that the above listed criteria be included in the design of the proposed antenna system.
3.1.19 Penetration Seals SER Section 3.1.19 indicates that pipe and electrical cable penetration seal designs will be tested to determine their fire resistance ratings.
Seals with a rating of less than three hours will be upgraded to a three hour rating, or justification will be provided for the lower rating.
By letter dated March 30, 1979 the licensee indicated that the penetration seal designs would be tested by July 1,1979 and that the required modifications would be completed by June 1, 1980.
By letter dated July 6, 1979, the licensee indicated that 6 different designs typical of electrical penetration seals at the plant had been dusbjected to three hour fire tests, including hose stream exposure.
The licensee reported that all penetrations met the following criteria:
o No passage of the flame through the seal o No flaming on the unexposed surface o No penetration by the hose stream.
The licensee also indicated that fire tests of cable tray and process piping penetration seals would be completed by August 1, 1979.
By letter dated October 10, 1979, the licensee provided a preliminary summary of test results and a description of proposed changes in penetration seal designs.
The licensee indicated that the final test report would be available by the end of Novembe r, 1979.
We have not as yet received a copy of this report for our evaluation.
' Staff review of the preliminary test report indicates that o pressure differential was applied during the tests.
We w.I require the licensee to provide additional information, results of tests or analyses, that will establish the effects, on the fire rating of penetration seals, of the mwimum pressure differential a fire barrier in the plant expected to experience.
3.2.7 D.C. Power System Hazard Analysis Section 3.2.7 of the fire protection SER indicates that the licensee will analyze the effects of postulated fire damage and provide modification as necessary to the 125/250 volt DC systems to preserve the plant's safe shutdown capability.
The analysis will include safe shutdown considerations as further described in Section 3.2.1 of the SER.
By letter dated February 1,1979, the licensee responded with a basic description of the 125/250 volt DC systems.
They stated that all areas containing DC systems have satufactory separation except for the west CRD area of the reactor building (Fire Area 1.10).
In this area the safe shutdown equipment is the DC motor control centers D7, D8, and D9 and their ass ciated cables.
The loss of DC power and associated loads from MCC D7, D8, and D9 wil'.
esult in the loss of HPCI, RCIC and shutdown mode of the RHR system along with the diesel generator standby fuel oil booster pumps.
The diesel day tank have sufficient capacity for 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> operation and if offsite power is assumed available within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, the plant can be shutdown using ADS, core spray system, LPCI mode of RHR system and CRD pumps.
The licensee, however, did not describe what separation was considered satisfactory, nor provided any justification to substantiate the as weption that offsite power can always be restored within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
Indeed, in two major blackouts experienced by the nortrcast part of this country in the past two decades, power was not restored to the grid for several days.
Our guideline in the staff position on safe shutdown capability that was forwarded to the licensee by NRC letter dated October 22, 1979, provided that:
(a) Safe shutdown capability should be preserved considering both cases where:
(1) offsite power is available, and (2) offsite power is not available (Section 1 of the staff position).
_4 (b) The equipment and systems used to achieve and maintain ho.
shutdown should be (1) free of fire damage; (2) capable maintaining such conditions for an extended time period longer than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> if the equipment required to achieve and maintain cold shutdown is not available due to fire damage; and (3) capable of being powered by an onsite emergency power system.
We conclude that the licensee's proposal is unacceptable and will require the licensee to:
(a)
Provide an altcrnate shutdown capability independent of Fire Area 1.10, or separate one division of shutdown equipment and cabling, by 3-hour fire barriers, from the remainder of the area.
(b)
Identify and justify the separation criteria used in con;ucting the study of the availability of DC power systen,
and a summary of the study which includes (1) areas being considered, (2) actual separating versus the adopted separation criteria, and (3) all safe shutdown systems /
equipment in each area including those which are not directly associated with the DC power systems.