ML19313A257

Submits Request for Addl Info Re 780714 Amend 2 to Jm Farley Nuclear Plant Fire Protection Program Reevaluation. Review & Meeting Requested by 780929

ML19313A257
Person / Time
Site:	Farley
Issue date:	09/07/1978
From:	Schwencer A Office of Nuclear Reactor Regulation
To:	Barton A ALABAMA POWER CO.
References
TAC-8671, NUDOCS 8712220025
Download: ML19313A257 (12)

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UNITED STATES y

NUCLEAR REGULATORY COMMisSION -

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WASHINGTON, D. C. 20555

,o September 7,1978 -

Docket No. 50-348 50-364 Alabama Power Company ATTN: Mr. Alan R. Barton Senior Vice Presicent i

P. O. Box 2641 Bimingham, Alabama 35291 Gentlemen:

We have reviewed your letter dated July 14, 1978 which enclosed Amendment 2 to the report "Joseph M. Farley Nuclear Plant Fire Protection Program Reevaluation". The amendment was in response-to our request for infomation dattd March 7,1978.

We are enclosing additional staff requests for infomation and l

positions which resulted from our-review of your July 14, 1978 l

1 submittal. Except for items 19 and 54, which are new requests, i

tne items in the enclosure are numbered to coincide with numbers of our prior requests. In order for us to complete Fire i

Protection Safety Evaluation Report, we request that you review the enclosed outstanding items and meet with us by September 29, 1978.

s During the proposed meeting you should be prepared to finalize all outstanding items. For this reason, your qualified fire j

protection engineering personnel as well as appropriate manage-ment should attend the meeting. Please advise us of the earliest

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date you would be prepared to meet with us.

Sincerely, y

<h'.46f/4V A. Schwencer, Chief Operating Reactors Branch #1 Division of Operating Reactors

Enclosure:

l Request for Additional 3

Infomation and Staff Positions cc: w/enclosure See next page 8712220025 780907 CF ADOCK 05000348

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Alabama Power Company

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cc: Ruble A. Thomas, Vice President l.

Southern Services, Inc.

Post Office Box 2625

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Birmingham, Alabama 35202 l

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i George F. Trowbridge, Esquire Shaw, Pittman, Potts & Trowbridge i

l-1800 M Street, NW Washington, D.C.

20036 i

l John Bingham, Esquire j

Balch, Bingham, Baker, Hawthorne, a

Williams & Ward i'

600 North 18th Street l

Birmingham, Alabama 35202 i

i Edward H. Keiler, Esquire i

Keiler & Buckley

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9047 Jefferson Highway l

River Ridge, Louisiana 70123 i

ll George S. Houston Memorial Library 212 W. Yurdeshaw Street.

Dothan, Alabama 36.01 W

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September lo 1978 l

l ENCLOSURE 1 l

REQUEST FOR ADDITIONAL INFORMATION AND l

STAFF POSITIONS 1.

Train A and Train B Interaction (General) -

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L' We will require automatic sprinkler protection in all areas excluding

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(ON'areas adjacent to switchgear consoles and motor control c iedundant safe hot and cold shutdown equipment or circuits are not-l 3

separated by 3 hr. fire rated barriers.

In addition, a.1/2'hr.~fire IQJ ll fp4,9 n ;'y

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g 4[- rated barrier should be installed to completely enclosehredun-l dant i-

~iTO_trains._of_equipmentJnd cable wherever the redundant systemsRe l-ess than 20 ft. aparf.

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accordingly.

Identify the fire areas where these criteria will be

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'. M+ $ [Protection System Wirina -

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( 9* 9 It is our position that the wiring for all detecticn and suppression 0 '

systems be supervised in accordance with NFPA-72D, and that annuncia-tion be provided in the control room.

The wiring for detection systems which actuate suppression systems must be capable of actuating the suppression system under a single break or a single ground fault condition. Confim that your design will meet this position.

' 6.

Class 1E Systems and Components Recuired for Safe Shutdown: Identifi-

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cation of -

See request i for information needed.

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Safe Shutdown Ecuitment Identification l

See request 1 for information needed.

9. b' Ar,ti-Sweat Pire Insul ation -

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Response is adecuate for question. However, it is our position that the anti-sweat insulation be replaced with a noncombustible material in all areas.

h~ 10. ~Exposure Fire Consideration -

t See request 1 for information needed.

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11. Your response refers to the need for "minor repairs or modifications' i

which may be required to complete cold shutdown.

Indicate your pre-j planned procedures for dealir.g with such emergency situations. Submit for staff review any modifica:icns to existing system designs. Also 4

'indicate where the necessary ecuipment/cable for these "minor repairs or modifications" are stored on site.

Confirm that these procedures and "minor repairs or modifications" will assure achieving safe cold shutdown using the guidelines in Attachment I considering,'in particu-y!

lar, a fire in the cable chase area (Fire Area 13), control room cabinets, switchgear rooms, or the cable spreading room (see P

request 3?c-) 'wnicn cisables redundant divisions of safe shutdown

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13.

Combustible P.aterial Storace -

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In your submittal, you state that storage of combustible materials is authorized only in areas separated f rom safe-shutdown-related i

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areas by approved fire walls, doors, and ceilings. During our site 1

visit, we observed many instances of combustibles, including flammable l

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liquids, clothing, and trash barrels, in rooms containing safe-shutdown-related cabling. 7ur position is that such items includino tne usea HEPA filters, ce removed immediately from safety-related ~

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areas.

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Fire Resistance Verification -

The specific references to the tables in the Unifonn Building ptC a.

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Code do not coincide with any tables in the UBC.

Provide a reference to a specific desien number (as you did for steel beams) that has j

been fire tested, or provide test results for the designs used or i

1 othen<ise verify the fire-resistance ratinc. 3 hr. rated fire i

,i barriers are required for all individual rooms which contain safe 4

butixn systems regardless of the actual fire zone boundaries, j

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No reference is made in your response to our request concerning j

non-labeled fire doors or doors which were only 1-1/2 hr. doors where j

3 hr. doors are required.

Exterior 'doors which provide access to i

i safety related areas must be appropriately labeled for fire resis-i

, tance.

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Your reference to the various fire dampers cannct be verified in all j

,cases in Uncer,griters beboratories' "Building Materials Directory."

j Provide verification from the mar.ufacturer or a testing laboratory i

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which will support your claims for 3 hr. rated fire door dampers and verify that all duct penetrations of 3 hr. rated barriers are provided with 3 hr. rated fire door dampers.

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1 The practice of installing a fire door/damper at a location other than in the fire barrier penetration provides no protection for the barrier per.atration even with the fire resistant material.

It is our position that where such installations were made in safety related areas, the dampers be replaced with appropriate dampers installed in accordance i

with their listings.

c Verify all your fire rated pen'etration seals with reference to c.

P tests. Some observed penetration seals at Farley are not supported D

I similarly to that described in the test reports that we know of.

Cables/cable trays must be supported such that tray collapse will i

not create forces, moments, and/or torques that will affect the l

integrity of the penetration seals.

I It is our position that all' penetrations of required fire barriers i

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trated. Your response indicates some exceptions to this position.

Identify any areas where sealing a penetration for a three hour rating is not possible and state the proposed alternative.

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15.

Concealed Scace Containino Combustibles -

Your revised analysis does not address our position. Therefore, our position still stands.

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17. 3,$yC_Cable

( ffW Location and Quantity -

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t j Th:: rcsponse is adequate; however, it is our position that Jhe PVC j

a "f.? cable involved between the solid state protection demultipliers in Q# /? the cable spreading room and the main control board annunciator light j

u //garray should be coated with a fire retardant material.

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Smoke Pemoval -

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j qH Verify that the portable smoke exhaust fans will be of a type speci-fic::11y made for this purpose and that they will be capable of j

operatia with lors of offsite po.eer.

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p t V19. Charcoal Filter Protection - (Inadvertently omitted from 3-7-78 Letter) p' Your fire hazards analysis does not clearly indicate that the ESF charcoal filters meet Regulatory Guide 1.52.

Additionally, the

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fire hazards analysis does not address the fire exposum to the l

j filter created by the contents of the fim area. Revise your fire hazards analysis accordingly.

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22.

Batterv Lichtino Units.

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Yerify that main access and egress routes to fire areas will also be j

provided with battery pack emergency lighting.

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1. gao # 3 d

i 26.b. Verification of Aporoved Fire Pump Controller -

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w-Response is not acceptable.

Reference to NFPA 20 Section:

7-1.1.1.

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The Underwriters Laboratories' Fire Protection Equipment Directory:

i contains no listing under "Pump Controllers Fire" for any Allis-4 '" !

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unit is listed for electric motor driven fire pump Chalmers equipment.

Provide verification of your claim that f

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J you are not in compliance with the following requirements: 7-2.1; 1

j 7-3.5;7-3.7.1;7-3.9;7-4.1;7-4.2.7(a);7-4.3;7-6.3;.7-6.5;and;)T'~~

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7-6.6.

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~s 29.a.

Fireweter Header Motor Ocerated Valve -

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Your response indicates that the motor-operated valves will be changed Oh

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m 'A from automatic to remote-manual-switch operation', which satisfies our I

r g concern about automatically stopping the waterflow. However, we mquest

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your rationale for establishing the excess flow

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c inn a7 rat point below the largest calculated firewater demand.

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Firewater Systems Cress Connection -

F Without an alternate feed you'still have a single underground feec 1

for all water suppression systems in the building. Our position remains that an alternate feed is needed for the header and that i

additional valves should be installed so that a single break will j

not impair both sprinkler and standpipe hose systems in any area.

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Fire Pump Capability Verification -

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Explain what the "proposed modifications"'are which you referred to in your response.

b) Verify that the fire pump met the required neeptance tests.

1 c) State the density and spacing for the existing automatic water suppression systems.

g. c 33.

Containment Standoipe Systems -

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Response is adequate; however, verify that the water supply connection will be able to provide any hose station inside containment with 75 -

grm at a nozzle pressure of 60 psi.

lW c 37.a.

RCP Oil Collection System -

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Your proposed oil cor,tainment and collection system appears to provide

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rotection only at flanges and jointsin the lube oil system.

It is i

our position that this system must provide a means of containing a

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' pressurized oil leak from a crack in any part of the lube oil system external to the pump. Verify if your proposed system is capable of 1

p' satisfying this requirement.

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38. Control Room Comolex Pericheral Walls -

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.. /a. Our position stands with regards to the requirement that the

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,lis J control room proper should be separated from kitchedand office i

d facilities by a one-hour fire rated partition~tfiat extends from Also, the kitchen and office facili ' _ ffgj" i

true ficor to true ceilino.

ties W u'd be provided 9.5th smoke detectors.

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It is our position that a survey be conducted of the detection i

1 J, system in the control room which will demonstrate, with test results,

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I Llkthat ceilir.g mounted detectors will be as sensitive to cabinet fires l

as detectors mounted in the cabinets. This position applies to all cabinets which contain hot and safe cold shutdown circuits.

The air.

flow from the ceiling to exhaust ducts 4 feet above the floor must be conside red.

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40.

Switchcear Rooms; Fire Areas No. 18,19, 21, 23, 41, SEA, 56B, and l

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See raqueets 1 and 11 for information needed.

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41. Diesel Generator Fire Zones -

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Response is adequate; however, verify that installation of these Zones 56A, B, a6d C.

doors will provide a complete 3 hr. fire.rated barrier between Fire b.

Indicate the separetion/protection provided fcr the redundant

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fuel oil transfer pumps.

Demonstrate that a fire in this area will

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1 not damage redundant pumps for either unit.

i 44.

Dry Resin Sterace Locations -

1 9 k Your fire hazards analysis does not indicate your intent to install q

a water suppression system in room 2403.

Revise'your fire hazards analysis accordingly.

I 46.

Cable Tunnel Hose Line Access -

J b-Verify that the hose lines are adequate to reach all areas of the-

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cabic tunnels.

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Fire Area No. 4; Duct Chase Enclosure Fire Resistance -

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Response is not acceptable. Our position stands in that the duct chase

~I enclosure should qualify for a 2 hr. fire resistar:e ratino with 1-1/2 j

hr. rated dampers for all duct penetrations into tne duct chase.

49.

Fire Areas No. 9 & 22; Wall Ooenines -

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fhb See ecuest 1.

If separation' is not provided ectween the cable chases, tne 1-1/2 hr. barrier must be applied to all cables in l

both chases.

51.

Fire Area No. 47; Corrbustible Storace -

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J-Your analysis does nc' indicate your intent to install an automatic water suppression systsm in room 404.

Revise your fire hazards j

analysis accordingly.

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Fire Area No.13; Cable Chase penetution -

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gh hespenst is not adequate.

The 3 hr. separation of the turbine a;1ding 'rca safety-related areas is required.

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Administrative Controls, Procedures, and Fire Bricade -

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Q' We have reviewed Section 4.4.2 against the staff supplemental guidance contained in "Nuclear Plant Fire Protection Function Responsibilities.

Administrative Controls, and Quality Ascurance," dated June 14, 1977.

ke find it does not follow those guidelines. It is our position l

that you should revise your administrative, controls to follow the

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Coqfirm that you will revise your j

ad7inis trative controls accordingly.

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54. Auxiliary Building Acc_e_ss Limitation -

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Analyze the need to provide a second stairwell into the west areas l

,[s' of the auxiliary building containing the battery rooms, remote

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shutdown panel, switchgear roo.ns, and cable spreading room.

l Present access to these areas and egress;is limited to a single i

stairway.

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ATTACHMENT.1 -_

STAFF REQUIREMENTS (REFER TO REQUEST 11) 1.0 Minimum safe shutdown systems when one division of all safety systems is not available.

1.1 Following any fire, the plant can be brought to hot shutdown conditiodt using equipment and systems thatart free of fire damage.

u 1.2 The plant should be capable of maintaining 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 />.

1.3 Fire damage to systems necessary to achieve and maintain, cold shutdown conditions should be limited so that repairs can.

be made and cold shutdown conditions achieved within 72 hoc s.

1.4 Repair procedures for cold shutdown systems should be prepared now and material needed for such repairs should be on the site.

1.5 The hot shutdown :endition must be achievable 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 system.

1.5 The power needed to achieve the cold shutdown condition may be obtained from any one of the offsite power, onsite power, and cecica:Ed power system.

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1.7 When these minimum systems are provided their adequacy shall be verified by a thorough evaluation of:

a.

Systems required for hot shutdown; b.

Systems recuired for cold shutdown; c.

Fire damage to power distribution systems; and d.

Interactions caused by fire damage to power and water supply systems and to supporting systems, i.e., component cooling water suoply.

2.0

" -.rum fire protection when dedicated or alternate shutdown systems are provided.

2.1 The fire protection systems in areas (such as cable spreading rooms) tnat contain cables for a large number of systems should consist of:

a.

Fire detection sys tem; b.

Hose stations; and c.

Fixed manual suppressien system (gas or water)

NGTE: Consideration to creventing fire propagation via covered trays, fire retardant coating, barriers or blankets on a case-by-case basis.

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i 2.2 Where access is difficult or impossible automatic systems should be provided.

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2.3 Where modifications will not be implemented for' an extended '

period. interim protection measures should be required to compensate for the lack of protection.

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l9 REGULATORY INFORMATION DISTRIEUTION SYSTEM (RIDS)

DISTRIEUTION FOR INCCMING MATERIAL 50-548/364 J

REC: STOLZ J F ORG: CLAYTON F L DOCDATE: 07/I4/78 NRC AL PWR DATE RCVD: 07/1S/78l DOCTYFE: LETTER NOTARIZED: NO COPIES FECEIVED

SUBJECT:

LTR 1 ENCL 40 AMEf>CMENT 2 TO REPORT ENTITLED "JOSEPH M.

FARLEY NUCLEAR PLANT FIRE PROTECTION FROGRAt1 REEVALUATION" NOTING THAT A SCHEDULE FOR IMPLEMENTATION WILL EE PROVIDED UPON NRC APPROVAL OF REPORT.

PLANT NAME.:FARLEY - UNIT I REV'.EWER INITIAL:

XRS FARLEY - UNIT 2 DISTRIBUTER INITIAL o***************

DISTRIBUTION OF THIS MATERIAL IS AS FOLLOWS ************+**o*

i FIRE PROTECTION (PRIOR TO ISSUANCE OF OL).

(LISTRIBUTION CODE BOO2)

-4 FOR ACTION:

PR CHIEF ORE#1 BC**W/ENCL PROJ MGR E REEVES**W/ENCL LIC ASST C PARRISH**LTR ONLY INTERfjAL.

REG FILE**W/ENCL NRC PDR**W/ENCL DELD**LTR ONLY I & E**W/S ENCL DIRECTOR DPM**LTR ONLY DE YOJNG**LTR ONLY VASSALLO**LTR ONLY DIRECTOR DSS**W/ENCL AD FOR PLANT SYSTEMSn W/ENCL AUXILIARY SYS ERwW/2 ENCL I & C SYSTEMS ER**LTR ONLY AD FOR QA & O**LTR ONLY CAB*-W/ENCL R.

MURANAKA**LTR ONLY HANAUER**W/ENCL STet.Z. W/6 N E XTERt;AL.

LPDR'S L, g nynOS E. h//G^#0 DOTHAN, AL"W/ENCL EETO A) w/G^#-'I-

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TERA**W/ENCL NSICMW/ENCL POWER SYS ER+*W/ENCL i

PLArJT SYSTEMS ER**W/2 ENCL i

AD FOR SYS & PROJ**LTR ONLY l

DIRECTOR DORuLTR CNLY OPERATOR L.IC ER**W/ENCL ACRS CAT C++W/16 ENCL i

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bISTFIEUTICN-LTR A ENCL M.

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