ML19312E311
| ML19312E311 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 05/19/1980 |
| From: | Clark R Office of Nuclear Reactor Regulation |
| To: | Lundvall A BALTIMORE GAS & ELECTRIC CO. |
| References | |
| NUDOCS 8006040192 | |
| Download: ML19312E311 (23) | |
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",i NUCLEAR REGULATORY COMMISSION g
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-E WASHING TON,0. C. 20S55 o e e
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May 19, 1980 Docket No. 50' 7 318 Mr. A. E. Lundvall, Jr.
Vice President - Supply Baltimore Gas & Electric Company P. O. Box 1475 Baltimore, Maryland 21203
Dear Mr. Lundvall:
We have been reviewing your Fire Protection submittals for the Calvert Cliffs Nuclear Power Plant, Units No. 1 and 2, dated September 14, November 13, December 21 and 27, 1979, and January 29, 1980. The current review status of the items requiring evaluation by our November 13 1979 Safety Evaluation Report (SER) is presented in Enclosure 1.
Enclosure 2 is the staff requirements necessary to resolve SER Items 3.1, 3.2 and 3.3.
The Fire Protection Review performed by Brookhaven National Laboratory is provided for your information in Enclosure 3.
We request that you provide a written response to our concerns presented in the enclosures for Items 3.1.13, 3.1.20, 3.1.21, 3.2.1, 3.2.2, 3.2.4, 3.2.5 and 3.2.9 within 30 days of receipt of this letter. Your response should include commitments necessary to resolve all fire protectton items by October 1, 1980. Should you desire to meet with the staff on this subject, please arrange such a meeting with the assigned Operating Reactor Project Manager, Mr. E. L. Conner.
Sincerely, L
Robert A. Clark, Chief Operating Reactors Branch #3 Division of Licensing cc: w/ enclosures See next page 8006040lO f
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i Baltimore Gas and Electric Company W==
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Mr. Bernard Fowler EE Janes A. Biddison. Jr.
President, Board of County General Counsel
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Commissioners G and E Building Prince Frederick, Maryland 20768 3
Charles Center gg Baltimore, Maryland 21203 Director, Technical Assessment 55 iEE Division George F. Trowbridge, Esquire Office of Radiation Programs EEE Shaw, Pittman, Potts and (AW-459)
EEE Trowbridge U. S. Environmental Protection Agency EE5 1800 M Street, N.W.
!Ei Washington, D. C.
20035 Crystal Mall #2 Eii.
Arlington, Virginia 20460 Isr Mr. R. C. L. Ol son U. S. Environmental Protection Agency l@
Baltimore Gas and Electric Company O!
Room 922 - G and E Suilding Region III Office Post Of fice Box 1475 ATTN:.EIS COORDINATOR EE Curtis Butiding (Sixth Floor)
!E Baltimore, Marylano 21203 E
Sixth and Walnut Streets Mr. Leon B. Russell, Chief Engineer Philadelphia, Pennsylvania 19106
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i5 Calvert Cliffs Nuclear ?ower Plant Ralph E. Architzel E
Baltimore Gas and Electric Company Resident Reactor inspector g
Lusby. Flaryland 20657 NRC Inspection and Enforcement g
P. O. Box 437
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Bechtel Power Corporation Lusby, Maryland 20657 M
ATTli: fir. J. C. Jude E.
Chief Nuclear Er.gineer
.Ei 15740 Shady Grove P.oad Gaithersburg, liaryland 20760
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Administrator, Power Plant Siting Program E
Combustion Engineering, Inc.
ATTil: Mr. P. W. Kruse, l'.anager Energy and Coastal Zone Administration ti Department of Natural Resources if Engineering Services Tawes State Office Building E'
Post Of fice Box 500 Windsor, Connecticut 05095 Annar.olis, Maryland 21204
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Calvert County Library I-Prince Frederick, !!aryland 20678
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Director, Department of State Planning 301 West Preston Stree-i Baltimore, Maryland 21201 t
Mr. R. M. Douglass, tiarager l
Quality Assurance Department Roor. 923 Gas & Electric Buf1 ding
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ENCLOSURE 1 STATUS OF RESOLUTION OF INCOMPLETE ITEMS FIRE PROTECTION PROGRAM FOR CALVERT CLIFFS 1 & 2 Su tmittal Status 3.1. 9 Low Fire Water Tank Level Interlock 11/13/79 C
3.1.15 Addition of Curts 11/13/80 C
3.2.3 Fire Pump Flow Test 11/13/79 C
3.2.10 Fire Water Drainage 11/13/79 C
3.2.11 Control Air 11/13/79 C
3.1.13 Emergency Comunication 11/13/79 R
3.2.1 Fire Hazards Analysis 12/21/79 12/27/79 R
3.2.2 Adequacy of Detector Installation 12/21/79 R
3.2.4 Ventilation Duct Penetrations 11/13/79 R
3.2.5 Backflow Protection 11/13/79 R
3.2.9 Effect of Fire on Radiation Monitors 12/21/79 R
3.1.14 Hydrogen Piping 1/11/80 Il 3.2.6 Electrical Penetration Fire Resistance 9/14/79 Il 1/2 9/80 3.2.7 Piping Penetration Fire Resistance 9/14/79 I1 1/2 9/80 3.1.19 Fire Detection in Safety Related Areas 12/21/79 12 12/27/79 3.1.20 Unprotected Dooreys 12/21/79 I 2 3.1.21 Manual Hose Coverage 11/13/79 1 2 3.2.8 Radiological Consequences of Fire 12/21/79 I2 3.3.1 Halon System Backup Pour 11/13/79 12 3.3.2 Emergency Lighting 11/13/79 I2 3.3.3 Fire Door Supervisor 11/13/79 12 3.3.4 RCP Lube Oil Collection System 11/13/79 I2 3.3.5 Fire Pump Separation 11/13/79 12 3.3.6 Fire Fighting Strategies 11/13/79 I2 3.3.7 Quality Assurance 11/13/79 I2 C = Completed Incomplete - licensee's information outstanding Il = Incomplete - staff's evaluation is not complete I2 = Staff requirement
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CALVERT CLIFFS UNITS 1 AND 2
SUMMARY
OF STAFF REQUIREMENTS TO RESOLVE SER ITEMS 3.1, 3.2 AND 3.3 3.1.13 Emergency Communication Separate the existing two hardwired connunication systens, the sound powered system and the page/ party system, by 3-hour rated fire barriers so that both systems will nct be subjected to simultaneous damage due to a single fire; or provide a third communication system independent of the existing systems.
3.2.l Fire Hazard Analysis Provide alternate shutdown capability independent of cabling and equipment in the following areas:
(1) The control room.
(2) Two cable spreading rooms and the adjoining cable chases (lC & 2C).
(3) Six cable chases (lA,1B, 2A, 2B, Horizontal Ul, U2).
(4) Other plant areas where redundant cabling / equipment required for safe shutdown cannot be separated by fire barriers of appropriate rating.
Such plant areas include, but are not limited to, the following:
(a) Auxiliary building cooridor and adjoining areas, Elevation (-) 10'-O".
(b) Auxiliary building cooridor and adjoining areas, Elevation 5'-0".
(c) Component cooling pump rooms.
(d) Each service water pump rooms.
This requirement is in addition to other requirements and commit-ments such as, automatic fire suppression, automatic fire detection, fire doors, penetration seals, manual hoses, etc., that will provide capabilities to detect and suppress fire, and separate different fire areas.
Alternatively, a separate and independent dedicated shutdown system pio.iding additional means to perform those safe shutdown functions for which redundant cabling / equipment cannot be adequately separated, will be acceptable.
The alternate / dedicated shutdown capability should conform to the staff position on safe shutdown capability (Enclosure 4).
. 3.2.2 Adequacy of Detector Installation (1) Describe the parameters considered in both the original detector system design and the subsequent detector system design.
(2) Verify that the spacing between detectors, and between detectors and walls, is within allowable limits as provided in NFPA 72E.
(3)
Provide a fixed automatic or manually operated water spray system per NFPA 15 to protect cables in cable chases 1C and 2C.
3.2.4 Ventilation Duct Penetrations Verify that the proposed method of fire damper installation conforms to the conditions of listing of the fire damper by the testing laboratory.
3.2.5 Backflow Protection 1
(1) Verify that a backflow check valve is provided in each drain line from the. charging pump cubicles and diesel r coms, or that each cubicle / room has a separate drain system.
(2) Verify that each piping from individual room sumps on Elevations (-) 10'-0" and (-) 15'-0" to the waste.
receiver tank is equipped with a backflow check valve.
(3) For each - ant area which contains five gallons or more combustible liquids and have a drain system common with safety related areas, verify that backflow from these areas to the safety related areas can be prevented if drain piping is clogged immediately downstream of the common junction or the header.
The study should include the consideration of backflow from nonsafety-related areas.
ENCLOSURE 3 4
CALVERT CLIFFS NUCLEAR POWER PLANTS UNITS 1 & 2 I
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Fire Protection Review
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Brookhaven National Laboratory
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Ytem 3.1.9 *LowWater Tank Level Interlocks ty Brookhaven National'LaEoratory The SER states that the fire pump controller will be modified to remove the fire water storage tank low level interlock from the control logic and that low water level storage tank alarms will be provided to annunciate in both the control room and the fire pump house.
The licensee responded November 13, 1979 by stating that they will remove the control relays, that provided low storage water interlock, from each fire pump controller. They further stated that they would provide the required low level alarms incorporating the low water level switches in the storage tanks.
Th's is entirely acceptable to us and we recommend that the staff accept item I
3.1.9.
Item 3.1.13 - Emergency Communication (additional information)
The SER states that communication equipment will be provided which is capable of maintaining communication between the control room and all areas of the plant, including the interior of containment, considering possible damage due to a single fire.
The licensee responded on November 13, 1979 stating an additional communica-tion system will be provided which will be capable of maintaining canmunica-l tions between the control room and all areas of the plant including the con-tainment. They further stated that adequate separation between the new system l
and the existing systems will be provided so that a single fire at any loca-tion cannot disable both systems. On a later submittal (January 11, 1980) the licensee described the proposed new system and enclosed sketches that showed the proposed layout.
The new system provides an adequate extension of the existing sound powered system so that the containment, containment stairways and turbine building are better covered for communications. The containment penetration rou:e shown on the sketch is satisfactory. However, the rest of the routing is not shown; we reconcend that the separaticn of the sound powered wiring and the plant paging system be documented by the licensee and reviewed by the staff.
In addition, the licensee has not addressed the possibility of a fire des-troying the cabinet in the control room and the conduits from the control room that are cancon to both the sound pcwered and the standard page/ party systems.
We recommend that the staff keep this as an open item until the conditions of the SER are met.
1-Item 3.1.14 - Hydrogen Piping SER Section 3.1.14 indicates that an excess flow stop valve will be installed in the hydrogen supply line to the auxiliary building to automatically stop the flow of hydrogen in the event of a piping system rupture.
By letter dated January 11, 1980, the licensee indicated that design drawings and details will be furnished for NRC staff review prior to iq,lementing the above-described modification.
The implementation date for this modification is October,1980. We have not yet received the licensee's design drawings and details and recomend that this item remain open.
Item 3.1.15 - Addition of Curbs SER Section 3.1.15 indicates that the licensee will provide means to curb or contain potential oil / solvent spills.in the hot machine shop and in the hot instrument shop.
By letter dated November 13, 1979, the licensee indicated that 2 inch high curbs had been installed at the entrances to the hot machine shop and hot in-strument shop, and provided calculations showing the capacities of the respective floor areas with the curbs installed.
We find the licensee's submittal satisfactory and recommend that the staff accept this item.
Item 3.1.19 - Fire Detection in Safety-Related Areas Section 3.1.19 indicates that the licensee has proposed to install appropriate fire detection devices in some additional safety-related areas.
By letter dated December 21, 1979, as part of the response to SER Section 3.2.1, the licensee proposed to install smoke detectors or automatic sprinkler systems in various safety-related plant areas (except for the containment) previously described in the SER as lacking fire detection devices. The licensee's response to SER Section 3.2.2 also indicated that the successful bidder on the proposed new fire and smoke detection system will be required to test and verify that the new detectors will respond to the anticipated fires from fixed as well as postulated transient combustibles. The test for response characteristics will consider the physical parameters of the installation such as detector spacing, type of ceiling, ventilation characteristics and mounting details. The success-ful bidder will be required to furnish written certification that the new system is adequate for the intended purpose.
By letter dated December 27, 1979, the licensee indicated that the evaluation of the containment area would be provided by January 11, 1980. This has not as yet been received by us.
The licensee's December 21, 1979 submittal did not provide sufficient detail for the staff to determine the acceptability of the method proposed for testing the effectiveness of the detectors to be installed.
Recent studies have indicated that the type of test requested by NRC is probably beyond the present state-of-the-art.
NRC is in the process of developing alternative acceptance criteria for fire detector installations. We will address this issue when such criteria become available.
Our evaluation of the acceptability of sprinkler systems as detection devices in lieu of smoke detectors is discussed in our evaluation of l
the licensee's response to SER Section 3.2.1.
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' i 3.1.20 - Unprotected Doorways
- I SER Section 3.1.20 indicates that UL or FM listed fire doors of appropriate ratings
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will be installed or acceptable alternatives will be provided to protect the un-j protected doorways in fire barriers separating various safety-related plant areas, t
including five doorways in the computer rooms currently provided with non-fire-rated bulletproof doors.
By letter dated December 21, 1979, the licensee proposed to upgrade two pairs of existing nonrated doors, and to install automatic sprinkler systems in various other areas in lieu of installing rated fire doors. The licensee also proposed to retain the bulletproof doors in the control room complex on the basis that.
fires in this area would be detected promptly because the area is continuously occupied.
Our evaluation of the acceptability'of the licensee's proposals regarding pre-sently unprotected doorways is contained in our evaluation of the licensee's response to SER Section 3.2.1.
3.1.21 - Manual Hose Coverage SER Section 3.1.21 indicates that the licensee has performed hose reach tests and proposed to provide several additional hose stations, and that the staff will further evaluate these modifications when the design details are available.
By letter dated November 13, 1979, the licensee provided drawings indicating the locations of existing and proposed interior hose stations and also those areas which would not be within effective range of a hose stream following the modifications.
There are seven plant creas which will be beyond the effective rance of pre-connected hose streams.
In all of these, the combustible loading is estimated by the ' licensee to be 2,500 Btu per square foot or less. The evaluation of the acceptability of the licensee's proposal is included in our evaluation of the licensee's response to SER Section 3.2.1.
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- 4 Item 3.2.1 - Fire Hazard Analysis SER Section 3.2.1 indicates that the licensee will provide results of an an-alysis to:
1.
demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and pene-trations) of appropriate fire resistance, 2.
identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area, 3.
identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combustibles which may be introduced into or moved through the area, 4.
identify the worst damage that could result from such fire, and 5.
demonstrate that such damage will not have an adverse effect on safe shut-down or cause excessive radioactive release to the environment.
The analysis will, as a minimum, include the following considerations:
i 1.
The possibility that redundant cables (in trays or in conduits)/ equipment may be. involved in an. exposure fire due to fixed or transient combust-ibles.
2.
Effects of the fire and possible explosion, and fire fighting activities.
3.
Shutdown capability without offsite power.
4.
Safe shutdown consequences of possible system transients resulting from a fire induced faulting of electrical cables.
Where assumptions are made, such as operability of damaged cabling / equipment, or effectiveness of protection, etc., they will be substantiated by the re-suits of tests and/or analyses.
In those plant areas where it cannot be demonstrated that safe shutdown f
capability can be preserved during and following the postulated fire, appro-i priate modification (s) will be provided to assure that the plant's shutdown capability will meet the following criteria as the minimum:
1.
Following any fire, the plant can be brought to hot shutdown conditions using equipment and systems that are free of fire damage.
2.
The plant shall be capable of maintaining hot shutdown conditions for an 1
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 />.
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Fire damage to systems necessary to achieve and maintain cold shutdown conditions shall be limited so that repairs can be made and cold shutdown conditions achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
4.
Repair procedures for cold :hutdown systems shall be prepared now and material needed for such repairs shall be on the site.
5.
The hot shutdown condition shall be achieved with power 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 systems.
6.
The power needed to achieve the cold shutdown condition may be obtained from any one of the offsite power, onsite power, and dedicated power sys-tems.
7.
When these minimum systems are provided, their adequacy shall be verified by a thorough evaluation ef:
a.
Systems required for hot shutdown; b.
Systems required for cold shutdown; c.
Fire damage to power distribution systems; and d.
Interactions caus.ed by fire damage to power and water supply systems and to supporting systems, i.e., component cooling water supply.
By letters dated December 21 and 27,1979, the licensee provided a fire hazards analysis and plant drawings, including a description of safe shutdown' equipment required for hot and cold shutdown.
Individual room analyses, and a compilation of propcsed plant modifications. The analysis did not include the containment, which the licensee ~ proposed to provide separately.
The staff has reviewed the criteria and assumptions which form the basis for the licensee's analysis and has concluded that they are not consistent with Appendix A to BTP 9.5-1, or with proposed Appendix R to 10 CFR part 50.
Specifically, o The licensee has assumed that an automatic fire suppression system will always prevent the concurrent loss of redundant divisions of cables or equipment as the result of a single fire, regardless of their arrangement, proximity and nature of the fire, or geometry of the room.
In addition, the licensee has assumed that automatic fire suppression systems have 100 percent reliability.
e The licensee has proposed use of automatic sprinklers on one side of a fire barrier in lieu of doors, in many doorways. The reliability and ef-fectiveness of this form of protection has not been demonstrated, especial-ly where redundant cables are present on opposite sides of the doorway.
The licensee proposes to limit automatic fire suppression systems if ade-e quate physical separation exists between redundant divisions of safe shutdown cable or equipment, or where significant fire hazards do not exist. The licensee has not provided the basis for determining the adequacy of separation between redundant divisions of cables or equipment.
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l In addition, several of the licensee's assumptions regarding transitat com-bustibles are not acceptable. The staff does not view as realistic the as-sumption that the contents of the 55 gallon drum of liquid would spread over the entire floor area crior to ignition, regardless of the floor area. Also, the licensee's assumptions that a five gallon pail of combustible liquid would not spill is not conservative.
We are reviewing the room by room details of the licensee's response to this SER item, and will provide a complete evaluation of the licensee's response when this review is complete.
Item 3.2.2 - Adeouacy of Detector Installati n SER Section 3.2.2 indicates that the licensee will provide the results of a study or tests to verify that proper consideration has been given to such factors as ceiling height and configuration, ventilation air Gow rate and pattern, location and arrangement of plan). equipment and combustibles, etc.,
in detennining the type, number and locati' n of the existing and proposed fire o
detector installations.
By letter dated December 21, 1979, the licensee indicated that the type, number and location of the existing fire detectors was detennined prior to installation by representatives of Pyrotronics and reviewed and approved by The licensee the licensee, its architect / engineer and its insurance company.
indicated also that the fire detection system has been reevaluated and that actual area coverage is one-hair to one-third manufacturer's reconsnended cov-erage.
In general, it appears that th~e reduction in detector spacing as a function of air-change rate and ceiling height is reasonable, except for cable chases IA, In 1C, 2A, and 2C, which have ceiling heights on the order of 50 to 60 feet.
reoc:s of this height, an array.of detectors only at the ceiling will probably not detect a small fire. Therefore, there is no assurance.that ceiling de-tectors alone can prevent fire damage of redundant divisions to cables in The licensee has proposed to install automatic sprinklers in these spaces.
cable chases 1A and 2A automatic and total flooding Halon 1301 systems to protect cables in chases 1C and 2C. However, since the Halon system would be actuated by a smoke detection system, credit cannot be taken for a Halon sys-tem if the-detectors are not effective.
Also, the licensee's response did not Ascribe the details of the original de-sign method or the details of the subsequent review. Moreover, the licensee did not indicate that the spacing between detectors, and between detectors and walls, is within allowable limits.
6-We recannend that the licensee in. stall an automatic sprinkler system to pro-tect the aLles b cable chases 1C and 2C, or to provide acceptable physical barriers for one of the redundant divisions there. We will also recommend that the licensee verify that the spacing between detectors, and between de-tectors and walls, is within allowable limits.
3.2.3 - Ft e pumo Flow Tests SER Section 3.2.3 indicates that the licensee will perform full scale pump tests and furnish the results of such tests.
By letter dated November 13, 1979, the licensee confirmed that full scale fire p==p tests were performed August 29, 1979 and witnessed by representatives of A:er1:an Nuclear Insurers.
The test results were also submitted.
Based on the submitted test results (corrected' to constant pump speed) the fire pump performance is within 10 percent of rated ' output and therefore satisfactory.
We recommend that the staff accept this item.
1 Item 3.2.4 - Ventilation Duct penetrations i
SER Section 3.2.4 indicates that the licensee has verified that all ventila-tion duct penetrations of fire barriers are protected with UL or FM listed fire dampers which will close automatically in the event of a fire, and the gaps between the ducts and the barriers are sealed. Fire rating of the dampers will be evaluated and appropriate modifications provided as necessary.
l By letter dated November 13, 1979, the licensee stated that the fire dampers provided in ventilation duct penetrations of fire barriers are one and one-half hour rated fusible link operated. The licensee has concluded tb.t the rating of each of these dampers is adequate for the fire hazard. The licensee's fire hazard analysis identifled ventilation duct penetrations in several more fire barriers in which fire dampers must be installed. Three i
hour rated fusible link fire dampers will be installed in these ventilation l
duct penetrations.
We accept the licensee's conclusions regarding the required ratings of fire dampers in the plant and recommend that the staff accept this item subject to the installation verification. The licensee's response included a drawing de-tail which showed that the installed fire dampers are located adjacent to the fire barrier. We recommend that the staff require the licensee to verify that this method of installation conforms to the conditions of the listing of the 1
fire damper by the testing laboratory.
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_7-1 3.2.5 - Backflow protection 4
The SER states that the licensee will provide the results of an analysis, including drawings or sketches of the drain systens as necessary, to demon-strate that the design of existing drain systems can prevent the back* low of coabustible liquids to other safety-related areas, or to provide additional modifications to prevent such possibilities.
The licensee. responded on November 13, 1979 and stated that. drains in safety related areas of the auxiliary building are connected to a conmon drainage system which empties into the miscellaneous waste receiver tank. The drain
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system consists of stainless steel floor drain fittings and connecting piping eccedded in the floor concrete. Four inch lines are aed as connecting head-ers for these. drains in the upper elevations. The headers are tied to a six inch gravity drain which leads to the receiver tank at Elevation -10'-0".
The piping from any given floor drain is enbedded at least 12" below the floor.
Spillage on Elevation -10'0" and -15'-0" is drained 'to individual roan sumps and then pumped to the waste receiver tank.
Check valves prevent backflow to other roans. At Elevation 5'-0" and above, spillage of combustible liquids in any given room will drain by gravity to the receiver tank. Connecting piping is sufficiently below the floor level to preclude transfer of conbustibles to other safety related rooms.
The new fire hazard analysis submitted December 21, 1979 notes the drainage problem in the charging pump rocas 105 and 115, but provides no further infor-mation. The new fire hazard analysis does not address the problem of backflow protection in the ECCS roans 101,102,118, and 119; the diesel generator rooms 421 and 422 or in the area of hydrogen liquid waste.
Since no drainage prints wre received by BNL, several of the statements made by the licensee are not clear. The ECCS roans and charging pump roans provide an acceptable drainage system if each of the 6 rooms involved has a separate check valve to prevent backflow to other roons. We reconmend that this part of item 3.2.5 be accepted by the staff subject to a review of drainage prints for these rooms.
If there is a conmon drainage connection between ar1y of these rooms and any other safety related area w recommend that separate check valves be installed in each such drainage line.
For those areas with a floor elevation 5'0" and above such as the diesel generator rooms 421 and 422, w recommend that the staff r quest the licensee to quantify the statenent that the " connecting piping is sufficiently below the floor level to preclude transfer of combustibles to 'other safety related roans."
If the licensee can demonstrate this statenent rumerically and with prints or sketches w reconmend that this part of iten ~.2.5 be accepted.
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I2 ens 3.2.6 and 3.2.7 - Electrical and Piping Penetration Fire Resistance SER Sections 3.2.6 and 3.2.7 indicate that the licensee will provide results of a standard ASTM E-119 test to demonstrate:
The adequacy of fire resistance of the Calvert Cliffs Electrical Penetra-e tions, and That piping penetrations have fire-resistance ratings commensurate with e
fire hazards on both sides of the barriers.
l By letter dated September 14, 1979, the licensee submitted a proposed pene-tration fire test method and criteria. On November 5, 1979, the staff telecopied to the licensee comments and concerns about the proposed test procedure.
By letter dated January 29, 1980, the licensee provided i revised test pro-cedure which included some of the staff's comments and indicated that the proposed test would take place during February,1980. The final results would be provided to the NRC staff in March,1980. The staff reviewed this revised i
procedure and forwarded its comments and conerns to the licensee.
l We will complete our evaluation following receipt of the test results.
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29 Item 3.2.9 - Effects of Fire on Radiation Monitors The SER states that the licensee will provide the results of a study to demonstrate that the radiation monitors will remain operational when exposed to smoke and/or heat of a potential fire.
The licensee responded on December 21, 1979 and stated that:
"The radiation monitoring system is not required to place the plant in a safe e
shutdown condition. As demonstrated in the results of a study for the radio-logical consequences of a fire, thece exist only minimal areas where a postu-lated fire could cause the releasr of radioactive materials; it is also stated that these releases would not rewit in a condition which would exceed the requirements of 10CFR20.
Four. independent radiation area detectors located within the containment are e
provided and, upon coincident of two-out-of-four trip signals or manual ini-tiation from the control room, actuation occurs to isolate and secure the containment purge system. ThesedevicesaredesignegtooperateinaLOCA environment of 100 percent relative humidity at 273 F and will provide audible and visual alams if the radiation levels exceed a pre-set value or if the detector malfunctions. Due to separation between locations for the area monitors and the containment volume available, a postulated fire that could conceivably effect all four system channels is not considered credible. The smoke resulting from a fire will not effect the system function. A device malfunction for any reason will provide a single input to the 2 out of 4 coin-cident logic, such that a second device malfunction will isolate and secure the containment purge system.
The waste processing area ventilation exhaust fans discharge is provided with e
a continuous off-line gaseous radiation monitor system.
This system extracts a sample from the ventilation system, analyzes the sample via a geiger-mueller tube and returns the sample to the ventilation system prior to the main exhaust
- pl enum.
A flow indicating switch is provided to indicate malfunction of the system. The gstem will operage nomally under the following engironment con-ditions: +40 F minimum to 120 F maxinam, sample temperature 167 F maximum and smoke atmosphere.
The plant vent is monitored for particulate, iodine, and gaseous activity.
e The equipment continuously withdraws a representative sample from the plant vent and passes the sample through a moving filter paper having a collection efficiency of 99 percent for particle sizes greater than 1.0 micron. The amount of deposited activity is continuously scanned by a lead-shielded detector. The remaining air is monitored by a separate gaseous monitor prior to returning to the plant vent. A flow indication switch is provided to in-dicate malfunction of the system. The gas monitoring portion of this system is identical to the previously described waste processing system. The par-4 ticulate monitoring portion of this sygtem will operate,nomally under the following environment conditions: +40 F minimum to 120 F maximum and a sample
temperature of 140 F maximum. This portion of the monitoring system is not expected to function properly with a smoke atmosphere from a fire.
The particulate monitoring portion is provided with a normally closed bypass piping to the gas monitoring portion. Continuously on-line char-coal filters are provided in parallel with the particulate and gas analy-zing system.
Due to the significant volume of air flow associated with ventilation e
systems within the Auxiliary Building, dilution will reduce the resultant temperature rise caused by a fire. Further, since the majority of the plant are.as served by the ventilation systems are provided with fire dampers to isolate the effects of a fire, temperatures are not anticipated to affect the gaseous monitoring portion of the main plant vent system.
It should also be noted that the main plant system provides redundant monitoring for the waste processing plant areas.
In the unlikely event that both'of the des' ribed radiation monitoring sys-c e
tems simultaneously fail, qualified plant personnel with sufficient quan-tities of portable radiation monitoring equipmen,ts are available to moni-tor effluents from the plant."
The containment radiation monitors are considered satisfactory in that smoke would cause the system to fail safe.
In the event of a fire the smoke would secure the containment purge system and the alann would notify the control i
room personnel. We recommend that the staff accept this part of item 3.2.9.
The waste processing area gaseous radiation monitors are also considered sat-isfactory in that the licensee has stated that they will not be effected by smoke and that there is a backup system for radiation monitoring in the main plant system. We recommend that the staff accept this part of item 3.2.9.
The main plant vent system has a gaseous raciation monitoring system which is considered acceptable and we recommend that the staff accept it. However, the particulate radiation monitoring system could fail in the case of a smokey fire and the licensee has not as yet justified the loss of the ability l
to monitor particulate radiation which could result at the line of a fire.
We recommend that the staff keep this part of item 3.2.9 open and request that the licensee develop an alternate particulate radiation monitoring sys-tem that will function in the event of a fire.
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' 3.2.10 Fire Water Drainage SER Section 3.2.10 indicates that the licensee will perform an additional study, following the completion of hose reach tests and addition of interior hose stations and other automatic water systems, to verify that the fire water drainage in all safety-related areas is adequate and possible fire water ac-cumulation in any safety-related area will be acceptable.
By letter dated November 13, 1979, the licensee provided the results of the required study.
The licensee estimated that in most areas of the auxiliary building, the flow of water from the largest sprinkler system and up to three fire hoses could result in the accumulation of up to two inches of water in the room of sprinkler operation, and flooding of Elevation - 10' up to the top of equipment pedestals after no less than about 60 minutes of sprinkler oper-ation.
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The' licensee has estimated that all fires in these areas will be extinguished in 60 minutes or less, and therefore the fire water drainage is acceptable.
For a fire in one of the ECCS pump rooms, the licensee has estimated that at least 48 minutes of sprinkler operation plus two fire hoses would be required to flood one of the rooms, but the redundant rooms would be available because of water-tight entrance doors. The licensee likewise concluded that this is acceptable.
We concur and recommend that the staff accept this item.
3.2.11 - Control Air The SER states that the loss of control air to the salt water system valves causes the service water heat exchanger and the component cooling water heat exchanger inlet and outlet valves to fail open. The licensee will provide the results of his study to verify that possible over-cooling of service water and/or canponent cooling water will not have adverse effects on the plant safety.
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The licensee in his letter of November 13, 1979 stated that loss of control air to the salt water systen valves causes the service water heat exchanger and component cooling water heat exchanger inlet and outlet valves to fail open with a resultant decrease in service water and canponent cooling water temperatures. This failure mode is consistent with the positions to which the valves would automatically be positioned in the event of an Engineering Safety Features Actuation. Therefore, all equipments serviced by component cooling or service water are designed to accept this reduced temperature water with no adverse impact.on plant safety. This includes the diesel generators which utilize service water to cool integral Jacket cooling, air cooling, and lube oil cooling heat exchangers. Overcooling of these systems 'is prevented by thennostatically actuated vcives sich bypass service water around the heat exchangers to maintain Jacket cooling water 170-185'F, scavengi ng air 100-115*F, and lube oil 190-205*F. We find that this answer is satisfactory and recommend that it be accepted by the staff.
STAFFPOSITION ENCLOSURE 4 SAFE SHUTDOWN CAPABILITY Staff Concern 0; ring the staff's evaluation of fire protection programs at operating plants, one or more specific plant areas may be identified in which the staff does not have adequate assurance that a postulated fire will not damage both redundant divisions of shutdown systems.
This lack of assurance in safe shutdown capability has resulted from one or both of the following situations:
. Case A: The licensee has not adequately identified th systems and components required for safe shutdown
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and their location in specific fire areas.
- Case B: The licensee has not demonstrated that the fire protection for specific plant areas will prevent damage to both redundant divisions of safe shutdown components identified in these areas.
For Case A, the staff has required that an ade*quate safe shutdown analysis be performed.
This evaluation includes the identification of the systems required for safe shutdown and the loc'ation of the system components in.the plant. Where it is determined by this evaluation that safe shutdown compenents of both redundant divisions are located in the same fire area, the licens.ee_.js required to demonstrate that a postulated fire will not damage both divisions or provide. alternate shutdown capability as in Case B.
For Case B, the staff may have required that an alternate shutdown capability be provided with is independent of the area of concern or the licensee may have proposed such a capability in lieu of cartain additional fire protection modifications in the area. The specific modifications associated with the area of concern along with other systems and equipment already independent of the area form the alternate shutdown capability.
For each plant, the mcdifications needed and the ccmbinations of systems which provide the shutdown functions may be unique for each critical area; however, the sh6tdown f nctions provided should maintain plant parameters within the bounds of the limiting safety consequences deemed acci'ptable for the design basis event.
Staff Position Safe shutdown capability should be demonstrated (Case A) or alternate shutdown capability provideo (Case B) in acccrdance with the guidelines provided below:
- 1. Desien Basis Event The design basis event for considering the need for alternate shutdown is a postulated fire in a specific fire area containing redundant safe shutdown cables / equipment in close proximity where i
it has been determined that fire protection means cannot assure that safe shutdown capability will be preserved.
Two cases should be considered:
(1) offsite power is available; and (2) offsite pcwer is not available.
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- 2. Limitino Safety Consecuences and Reouired Shutdo,in Functions 2.1 No fission product boundary integrity shall be affected:
a.
No fuel clad damage; 1
b.
No rupture of any primary coolant boundary; c.
No rupture of the containment boundary.
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l 2.2 The reactor coolant system process variables shall be within those predicted for a loss of normal ac power.
The alternate shutdown capability hhall be able to achieve l
2.3 and maintain subcritical conditions in the reactor, maintain i
reactor coolant inventory, achieve innd maintain hot standby
- conditions (hot shutdown
- for a BWR) for an extended i
period of time, achiefe cold shutdown
- conditions within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and maintain cold shutdown conditions thereafter.
As defined in the Standard Technical Specifications.
- 3. Perfontance Goals 3.1 The reactivity control function shall be capable of achieving
. and maintaining cold shutdown reactivity conditions.
3.2 The reactor coolant makeup function shall be capable of maintaining the reactor coolant level above the top of the core for BWR's and in the pressurizer for 'PWR's.
3.3 The reactor heat removal function shall be capable of achieving and maintaining decay heat removal.
The process nenito'ing function shall be capable of 3.4 r
providing direct readings of the process variables necessary to perform and control the above functions.
3.5 The supporting function shall be capable of providing th'e process cooling, lubrication, etc. necessary to permit the operation of the equipment used for safe shutdown by the systems identified in 3.1 - 3.4.
3.6 The equipment and systems used to achieve and maintain hot standby conditions (hot shutdown for a BWR) should be (1) free of fire damage; (2) capable of 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 shutdcwn is not available due to fire damage; and (3) -
pcwered by an onsite emergency power system.
3.7 The equipment and systems used to achieve and maintain cold shutdown conditions should be either free of fire damage or the fire damage to such systems should be limited such i
that repairs can be made and cold shutdown conditions achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Equipment and systems used prior to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after the fire should be powered by an onsite emergency power system; those used after 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> may.be powered by l
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offsite power.
3.8 These systems need not be designed to (1) seismic category I criteria; (2) sin 3 e failure criteria; or (3) cope with 1
other plant accidents such as pipe breaks or stuck valves (Appendix A BTP 9.5-1), except those portions of these systems which interface with or impact existing safety systems.
- 4. PWR Eouipment Generally Necessary For Hot Standby _
(1)
Reactivity Control Reactor trip capability (scram). Boration capability e.g.,
charging pump, makeup pump or high pressure injection pump taking suction from concentrated borated water supplies, and letdown system if required.
(2)
Reactor Coolant Makeup Reactor coolant makeup capability, e.g., charg.ing pumps
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or the high pressure injection pumps.
Power' operated relief valves may be required to reduce pressure to allow use of the high pressure injection pumps.
(3)
Reactor Coolant System Pressure Control _
Reactor pressure control capability, e.g., charging pumps or pressurizer heaters and use of the letdown systems if required.
(4)
Decay Heat Removal Decay heat removal capability, e.g.', power operated relief valves (steam generator) or safety relief valves for heat removal with a water supply and emergency or auxiliary feedwater pumps for makeup to the steam generator.
Service water or other pumps may be required to provide water for auxiliary feed pump suction if the condensate storage tank capacity is not adequate for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
(5)
Process Monitorina Instrumentation Process monitoring capability e.g., pressurizer pressure and level, steam generator level.
(6)
Succort.
The equipment required to support operation of the above described shutdcwn equipment e.g., component cooling) water service water, etc. and onsite power sources (AC, DC with their associated electrical distribution system.
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- 5. PWR Equipment Generally Necessary For Cold Shutdown *
(1)
Reactor Coolant System Pressure Reducticn to Residual Heat Removal System (RHR) Capability i
Reactor coolant system pressure reduction by cooldown using steam generater power operated relief valves or atmospheric dump valves.
(2)' Decay Heat Removal Decay heat re: oval capability e.g., residual heat removal system, component cooling water system an'd service water system to remove heat and maintain cold shutdown.
(3)
Support v
... =,
Support capability e.g., onsite power sources (AC & DC) or offsite after 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and the associated electrical distributien system to supply the above equipment.
Equipment necessary in addition to that already provided to maintain
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hot standby.
- 6. BWR Ecuipment Generally Necessary For Hot Shutdown (1) ~ Reactivity Control Reactor trip capability (scram).
(2)
Reactor Coolant Makeup Reactor coolant inventory makeup c'apability e.g., reactor core isolation cooling system (RCIC) or the high pressure coolant injection system (HPCI).
(3)
Reactor Pressure Centrol and Decay Heat Removal Depressurization systira valves or safety relief valves for dump to the suppression pool.
The residual heat removal system in steam condensing mode, and service water system may also be used for heat removal to the ultimate heat sink.
(4)
Suopression Pool Coolino Residual heat remo/a1 system (in suppressica pool cooling mode) service water system to maintain hot shutdcwn.
(5)
Procecs Monitoring Process monitoring capability e.g., reactor vessel level
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and pressure and suppression pool temperature.
S-(6)
Suenorj Support capability e.g., onsite power source ( AC & DC) and their associated distribution systems to provide for the shutdown equip:r.ent.
- 7. S'4R Ecuipment Generally Nocessary For Cold Shutdown
- At this point the equipment necessary for hot shutdown has reduced the primary system pressure and temperature to where the RHR system may be placed in service in RHR cooling mode.
(1)
Decay Heat Removal Residual heat removal. system in the RHR cooling code, service water system.
(2) Supoort Onsite sources (AC & DC) or offsite after 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and their associated distribution systems to provide for shutdown equipment.
- ' Equip;r.ent provided in addition to that for achieving hot shutdown.
E. Infor. nation Recuired For Staff Review (a)
Description of the systems or portions thereof used to provide the shutdown capability and modifications required to achieve the alternate shutdown capability if recuired.
(b)
System design by drawings which show normal and alternate shutdown control and power circuits,' location of components, and that wiring which is in the area -and the wiring which is out of the area that required the alternate system.
(c) Vorification that changes to safety systems will not degrade safety systems.
(e.g., new isolation switches and control switches shi&uld meet design criteria and standards in FSAR for electrical equipment in the system that the switch is to be installed; cabinets that the switches are to be mounted in should also meet the same criteria (?SAR) as other safety related cabinets and panels; to avoid inadvertent isolation from the cor. trol room, the isolation switches should be keylocked, or alarmed in the control room if in the " local" or " isolated" position; periodic checks should be made to verify switch is in the proper position for normal operation; ar.d a single transfer switch or other new device should not be a scur:c for a single failure to cause loss of redund:nt safety sys ems).
(d)
Verification that wiring, including power sources for the control circuit and equi;;mant operation for the alternate shutdown method, is independent of equipment wiring in the area to be avoided.
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(e)
Verification that alternate shutdown power sources, including all breakers, have isolation devices en control circuits thtt are routed through the area to be avoided, even if the breaker is to be operated manually.
(f) Verification that licensee procedure (s) have been developed which describe the tasks to be performed to effect the shutdown method. A suc=ary of these procedures should be reviewed by the staff.
(9) Verification that spare fuses are available for control
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circuits where these fuses,may be required in supplying power to control circuits used for the shutdown method and may be blown by the effects of a cable spreading room fire.
The spare fuses shculd be located convenient to the existing fuses.
The shutdown procedure should inform the operator to check these fuses.
(h) Verification that the manpower required to perform the shutdown functions using the procedures of (f) as well as to provide fire brigade members to fight the fire is available as required by the fire brigade technical specifications.
(i) Verification tnat adaquate acceptanc'e tests are performed.
These should verify that: equipment operates from the local control station when the transfer or isolation switch is placed in the " local" position and that the equipment cannot be operated from the control room; and that equip-ment operates from the control room but cannot be operated at the local control station when the transfer or isolation switch is in the " remote" position.
(j) Technical Specifications of the surveillance recuirements and limiting conditions for operatien for that equipment not already covered by existing Tech. Specs.
For example, if new isolation and control switches are added to a service water system, the existing Tech. Spec. surveillance require-ments en the service water system should add a statement similar to the following,:
"Every third pump test should also verify that the pump starts from the alternate shutdown station after moving all service water system isolation switches to the local control pcsition."
(k)
Verification that the systems available are adecuate to perform the necessary shutdown functions.
The functions recuired shculd be based on previous analyses, if pcssible (e.g.,
in the FSAR), such as a loss of normal a.c. pcwer or shutdewn on a Group I isolation (BWR).
The equipment required for the alternate capability should be the same er equivalent to that relied on in the above analysis.
(1) Verification that repair procedures for cold shutdown systems are developed and material for repairs is maintained on site.
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