ML19317G994
| ML19317G994 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 11/16/1976 |
| From: | Walbridge W SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | Stello V Office of Nuclear Reactor Regulation |
| References | |
| 11797, NUDOCS 8004020653 | |
| Download: ML19317G994 (14) | |
Text
{{#Wiki_filter:_ - _ h (, uc. NUCLE AXE 2VLATO3Y CC ISSIONh O DOCKEg_ NRC PC,RM 195 (2 78) NRC DISTRIBUTION FOR PART 50 DOCKET MATERIAL FROM: SACRAMENTO MUNICIPAL DISTRICT DATE OF DOCUMENT TO: V. STELLO SACRAMENTO, CALIFORNIA 11-16-76 W.C.WALBRIDGE oATE RECEivEo 11-19-76 OLETTE R ONOTORizED PROP INPUT FORM NU.MBER OF COPIES RECEIVED GMfGINAL OUNCLASSIFIED g OCOPY "L DESCRIPTION LTR. RE. THEIR SUBMITTAL OF 8-31-76...TRANS AMENDMENT // 1, BRANCH TECH. POSITION 9.511 THE FOLLOWING...... GUIDLINES FOR FIRE PROTECTION....... ( 1 SIGNED CY. RECEIIED) ( 13 PAGES) D.0]$@L$U-PLANT NAME: RANCHO SECO SAFETY FOR ACTION /INFORMATION ENVTRO SAB 11-19-76 ASSIONED AD: ASSIGNED AD: / BRANCH CHIEF: REIDI,)/l, BRANCH CHTEF+ PROJECT MANAGER: PROJECT MANAGER? / LIC ASST.: INGRAM LIC. ASST.? INTERNAL DISTRIBUTION r'D F r: rn D SYSTEMS SAFETY PTANT SYsrRMs SITE SA m f & ENVIRO ANALYSIS '/ NRC PDR F'INEMAN TFnpsco / I&E W SCHROEDER BENAROYA DENTON & MUTT.FR LAINAS / OELD GOSSICK & STAFF ENGINEERING IPPOLITO ENVIRO TECH _ MIPC MACCARRY KIRKWOOD FRNST l CASE KNIGHT BALIARD HANAUER SIHWEIL OPERATING REACTORS SPANCTFR J l PAWLICKI STELLO HARLESS RTTE Tren J PROJFCT MANAGEMENT REACTOR SAFE ~EY OPERATING TECH. CAMMTLL U E ROSS / EISENHlTP STEPP J BED P,_ COLLINS NOVAK / SHAO Min. MAN i HOUSTON ROSZTOCZY / BAER PETERSON CHECK / BtHLER SITE ANALYSTS / GRIMES VOT.T MER ,.MELTZ BUNCH 2 IIELTEMES AT & I / .7 COLLINS SKOVHOLT SALTZMAN VRFCFR RUTHERG CONTROL NUMBER j EXTEllNAL DISTHIDUTION g LPDR: SACRAMENTO. CAI. NAT IAB: BROOK 116YEF_NAT LAB Y REG. VIE ULRIKSON(_O,RNL) ^00402Oo O fTIC: O 2_ NSIC: LA_PDR hp 11797 ASLB: CONSULTANTS If ACRS__.lsCIS____y @ _ft:p ACRS CAT M "
{, c., s. (SMUD SACRAMENTO MUNICIPAL UTILITY DISTRICT D 6201 S Street, Box 15830 Sacramento, California 95813; (916) 452-3211 gqij
- {bOI.'N N
6, 1976 . v. s, c.i$ N.,g9 % a Director of Nuclear Reactor Regulation ' g' DgQ 1 O'k Attention: Mr. Victor Stello, Jr. x 8 Division of Operating Reactors t U. S. Nuclear Regulatory Comission
- 2-a Washington, D. C.
20555 Ao Docket No. 50-312 Rancho Seco Nuclear Generating Station, Unit No. 1
Dear Mr. Stello:
In response to certain verbal questions raised by the NRC's fire inspection team during their visii. to the Rancho Seco Nuclear Generating Station, Unit No.1, on October 19, through 22,1976, we are hereby submitting Amendment No.1 to the District's submittal of August 31, 1976. Forty (40) copies of this amendment are enclosed. Si cerely ours ) / AJ ' Q., m. ~ Wm. C. Walbridge General Manager Enclosures O 4 I/ k D t nowv Qsg' N 11Ya7 AN ELECTRIC SYSTE M S E RVIN G MORE THAN 600,000 IN THE HEART OF C ALIF O R N I A
(' o Reguldcry Docket Bl#l AMENDMENT N0. 1 t~' SACRAMENTO MUNICIPAL UTILITY DISTRICT RANCHO SECO NUCLEAR GENERATING STATION, UNIT NO. 1 RESPONSE TO: NUCLEAR REGULATORY COMMISSION BRANCH TECHNICAL POSITION 9.5-1 GUIDELINES FOR FIRE PROTECTION FOR NUCLEAR POWER PLANTS DATED MAY 1,1976 Amendment No. 1 November 16, 1976
(' 0 m Amendment No.1 includes revised response items as ' listed below. The text material changed by this Amendmerit is coded in the outside margin by a bar and the Numeral 1.
Response
NRC Included on Original Item No. Position No. Submittal Page Nos. 18 IV.B.l. (j ) 14 19 IV. B.2. (a )
- 5-16 26 IV.B. 3. (d )
20 40 IV.B.4.(h) 28 59 IV.C.2.(g) 41-42 65 IV.C.3.(f) 46 74 IV.D.5 57-58 79 IV.D.10 62-63
m l. Item 18 - Page 14 Response to Position IV.B.l.(j): The Rancho Seco plant is in compliance with this guideline with the following four exceptions: 1. The sealing system used for cable tray penetrations through walls and ceiling have not been tested for a three-hour rating in accor-dance with ASTil E-119. 2. The battery room doors and the corridor doors to the safety related 1 AD/DC distribution panel rooms do not have a three-hour rating. 3. All doors into separate fire areas are not locked nor are they eauipped with alarms to annunciate in the Control Room. 4. Not all piping and conduit penetrations are provided with three-hour l1 rated seals. In the Auxiliary and Containment Buildings all wall and ceiling construction is noncombustible and has a three-hour fire rating with the exceptions I: noted above. All doors have UL Listings for three-hour ratings with the exceptions noted above. The battery and AC/DC distribution panel room doors were purposely furnished with glass windows to pmvide the capability of security surveillance without entering the rooms. The battery room doors l1 are nonnally kept locked and all but essential entrance is eliminated due to the potential hydrogen fire hazard. We do not propose to replace the doors to the battery rooms or the AC/DC distribution panel rooms for doors without l1 glass. The Rancho Seco plant cable tray floor and wall penetration system is discussed in Item No. 26. Electrical conduits passing through zone fire walls and floors in the CO2 protected rooms and the control and computer rooms are either poured or grouted in solid with concrete or they pass through a cabic tray type of penetration fire barrier. It is considered not to be necessary to provide 1 a three-hour rated seal for all cases of metallic conduits passing through fire barrier wells in other plant areas as it is not considered conceivable that a metallic conduit will burn and transmit a fire from one side of a wall to the other. i Pipes passing through walls and floors have a small solid foam filled gap between the outside wall of the pipe and the concrete to allow for expan-sion and contraction. It is not considered to be necessary to provide a three-hour seal in this gap because we did not consider it to be credible for a metal pipeline to burn and transmit a fire from one room to another. Consequently, we are proposing no changes to pipe penctrations. The doors to all critical areas of the plant containing safety related systems are not locked because of personnel safety reasons. A very stringent administrative control procedure is in effect at the Rancho Seco plant to maintain the critical interior fire rated doors in the proper positions. This procedure has proven to be very effective; con-sequently, we propose to make no changes to the door control system. i UL listed fire dampers for isolation. 2 protected zones are provided with The ventilation penetrations in the CO l AmeTdment 1
~Q ( .g. 2. Item 19 - Page 15 - 16 Response to Position IV.B.2.(a): The Rancho Seco plant is in compliance with the-intent of this guidel'ine. The diesel generator fuel oil day tanks are integral parts of the diesel i generator assembly and cannot-practicably bs. separated from the equipment. Each diesel generator is isolated from other zones by three-hour rated fire walls, floor, ceilina and doors, and, in addition, is orotected by wet pipe sprinkler systems and automatic carbon dioxide fire protection systems. The turbine-generator lube oil systems are not contained within a separate fire enclosure, howevar, the oil distribution systems are protected either by hydraulically designed wet pipe systems or by permanently installed carbon dioxide fire protection systems and the main lube oil storage reservoir. is protected by an automatic deluge spray system. The generator hydrogen seal oil system is protected by a deluge water spray system and i the piping between the seal oil system and the generator is in an area protected by a hydraulically designed wet pipe system. The turbine-generator electro-hydraulic system is filled with nonflammable fluid. In i addition. a spatial separation of at least 30 feet is provided between the turbine-generato oil systems and the Auxiliary Building which contains safety related systems. The reactor coolant punps do not have automatic fire suppression systems installed; however, the lube oil systems for the pumps and motors are enclosed by a metal oil catch basin designed to contain any oil leakage and prevent its contact with high temperature components in the vicinity. 1 The oil catch basin is also designed to prevent the spread of burning oil to any safety related system components that could be disabled by fire. There are no safety features components within the reactor coolant pump motor cavities with the exception of steel pipes and one safety features motor operated valve. The steel pipes would not be significantly affected by a reactor coolant pump motor bearing oil fire and the one motor operated safety features valve is backed up by redundant safety features valves 1' located outside of the motor cavities and adjacent to the containment building wall. The reactor coolant pump motors are separated from other safety features components by 4 feet thick concrete shield walls. The only other safety related items within the same cavities in the reactor coolant pump motors are some electrical conduits containing reactor protection signal ci rcuits. These conduits are separated such that an oil fire in one reactor i coolant pump motor could only conceivably affect one out of the four protective instrument channels. It is our opinion that the oil leakage catch enclosures plus the concrete shield walls will provide sufficient containment of any credible fire such that damage to safety features components will not occur. Consequently, we propose to make no changes to the fire protection for the reactor coolant punp motors. i h i Amendment 1
{ f~ ) Certain air handling units located both inside and outside of the Reactor Containment Building are provided with charcoal filters. The charcoal filter elements are not enclosed within a separate 3-hour fire rated enclosure nor are they directly protected by automatic fire suppression systems. The charcoal filter elements are completely enclosed by substan-tial metal air handling unit enclosures. Also, spatial separation is provided from redundant safety. features equipment items. The air handling units with charcoal filters located outside of the containment are covered by overall wet pipe sprinkler systems. Please see Item No. 36 for additional discussion regarding charcoal filters. Certain redundant safety features pumps arid motors have oil lubricated bearings; such as, high pressure injectio'n pumps, low pressure injection pumps and nuclear service raw water pumps. These cumps are in separate rooms with 3-hour fire rated walls, floors and ceilings, or they are separated by spatial distance to the extent that a bearing oil fire in one unit would not conveivably disable the redundant safety fe:.:. ares function. Amendmer.t 1
a ,m n ( _4 x' f 3. Item 26 - Page 20 Response to Position IV.B.3.(d): The Rancho Seco plant does not comply with this guideline. The fire stops installed on cable tray penetration of fire barrier walls l . at the Rancho Seco plant have not been tested in accordance with ASTM E-119. I It is our opinion that the test methods specified in ASTM E-119 is one that was intended for general industrial construction and is not applicable to the configuration present in cable tray penetrations. We have carefully . studied the requirements of ASTM E-119 and we feel-that there is no possible modification that could be made to our cable tray wall or floor barriers that would make them capable of meeting the requirements of this i standard. ASTM E-119 requires that the exposed surface of the penetration be raised to 1925*F over a three-hour period while the unexposed surface shall not increase by more than 250 F above its initial temperature. With continuous steel trays and heavy copper conductors extending throught the penetrat.on,- we maintain that it is physically impossible to meet the acceptanca criteria of ASTM E-119. A wall and floor cable tray fire barrier identical to the design installed at the plant was fire tested in a vertical configuration. This test con-sisted of direct impingement of a 1900 F gas flame from a ribbon burner, 10" long, on the underside of a barrier through which cables penetrated. The flame was directed at the junction of the barrier and the cable. The Rancho Seco cable tray penetration fire barrier design withstood this test for a period of one full' hour without any flame passing above the barrier or without destruction of the barrier. The barrier could have withstood the flame test for a much longer period, However, we considered i that a one hour period was adequate time to place the plant in a safe j shutdown condition and to have put into effect the necessary manual j suppression effort required to put out the fire. We have reached agreement with NELPIA on a means of upgrading our cable j tray fire stops-to an equivalent three-hour rating. At the present time we have Hasite board and Flameastic on one side of the penetrations. We propose.to add a minimum.of six inches of silicone foam in the penetration cavity covered with fire retardant compressed felt. NELPIA has infonned us 1 that they will approve this construction as pmviding a three-hour fire stop suitable for the application without requiring the ASTM E-119 test. If the above proposed modification would be acceptable to the NRC without testing, we would proceed with the work as soon as practicable. . Amendment l'. . -.i
(- n -S-4. Item 40 - Page 28 Response to Position IV.B.4.(h) We meet this guideline with the exception that the Rancho Seco plant does not have onsite provisions for recharging air bottles, and the recommended number of spare bottles are not provided for the self-contained breathing units. The self-contained breathing units are 1 MSA Demand Type. The following respiratory equipment is located at different plant areas: 12 Scott air pack srlf-contained respiratory units with full face masks 12 Full tace piece canisters 12 Full face piece filters with organic car'tridge The Scott air pack units have a 30-minute capacity and in addition there are onsite 10 spare air cylinders. l1 One Scott air pack is located at each of two emergency relouation areas (the Warehouse and the Administration Building), two in the control room and eith in the Health Physics Office near the control room. At the present time we do not have any plans to install the equipment necessary to recharge air cylinders or otherwise augment the respiratory equipment list. i l Amendment 1
k-O 5. Item 59 - Page 41 - 42 Response to Position IV.C.2.(g): The Rancho Seco plant complies with the intent of this guideline except that the laterals to each hydrant are not supplied with isolation valves. The laterals to the fire hydrants are very short, and adequate sectional-izing valves are provided in the main loop line to accomplish repairs or maintenance to hydrants without any significant disruption of the fire water system. We do not propose to add isolation valves to the hydrant laterals. Outside hydrants are spaced approximately 200 to 300 feet apart and are arranged in a loop configuration around the plant buildings. There are three strategically located fire equipment stations, and three equipped hose houses that provide fire hose within 500 feet of any safety related plant area. The fire equipment stations are provided with the following: A. Hose cart with 300 feet of hose B. Combination nozzles C. Shovels 1 D. Axes E. Hydrant wrenches The fire equipment stations and hose houses were discussed with representatives of NELPIA on Wednesday, November 3,1:176, and NELPIA concurred that the equipment we have does provide adequate fire protection. The threaded connections on the yard main hydrants are compatible with the local fire department equipment. t l Amendment 1
~ C) ( 6. Item 65 - Page 46 Response to Position IV.C.3.(f): The Rancho Seco plant is in compliance with tnis guideline. We have available portable foam equipment for use anywhere at the plant site with the manual hose stations. 1 The type of agent we have in stock is Firt: chem heavy water foam, however, the equipment could be used with aqueous film forming foam (AFFF). l l l Am Re-ftftll
(3 Q .g. 7. Item 74 - Page 57 - 58 Response to Position IV.D.5: The Rancho Se:o plant is in compliance with this guiddine with the -following exceptoins:
- 1. The fire barriers for the cable tray penetrations thmugh the switchgear room walls, floors or ceilings do not have a ASTM E-119 tested three-hour rating as previously discussed in Item No. 26.
2. The 480 volt switchgear room located on the mezzanirt floor also serves as a cable spreading room for the main control room. Also, the 480 volt switchgear rooms contain electrical and electronic equipment cabinets in addition to the switchgear. A backup telephone comunications teminal and the emergency shutdown metering panel are located in the east 4160 volt switcgear room. 3. All cables which enter switchgear rooms do not terminate there. However, the number of cables passing through switchgear rooms are not significant in comparison to the number terminating there. 4. The medium voltage switchgear (4160 and 6900 volts) cubicles are not mounted on pedestals nor are floor drains provided for these l rooms. The switchgear rooms are protected by Quality Class I, Seismic Class I, automatic actuated carbon dioxide total flooding fire suppression systems designed and tested to provide protection against deep-seated electrical fi res. Please refer to Item No. 67 for a discussion of the C02 system. Redundant safety related switchgear divisions are located in separate switchgear moms that have three-hour rated walls, floors, and ceilings with the exception of the cable tray penetrations as previously noted. The switchgear rooms are provided with automatic fire detection systems. The systems are actuated by ionization type smoke detectors which provide an alarm and annunciation in the control room upon actuation. A local warning alarm is provided in each C02 protected room which annunciates approximately 40 seconds prior to discharge of C02 gas. Fire hose stations and portable extinguishers are readily available. Portable CO2 and dry chemical type fire extinguishers are provided throughout the plant. Fire hose stations are located near the entrance to each switchgear room with sufficient hose to reach any location in the room. Electrical cabinecs and 480 volt switchgear cubicles located in the 480 volt switchgear rooms on the mezzanine level of the auxiliary building are located on 4" high concrete pedestals to prevent flooding of the I cubicles in the event that the use of fire hoses is required in these While the medium voltage switchgear is not mounted on pedestals, rooms. Amendment 1
r -{-?, 0- _g. the lowest control circuits in these cubicles are approximately 4-1/2" above the floor level-and the lowest location.of 4160 volt bus bars is approximately 10" above the floor. Adequate drainage is provided through 1 open doors in the event that the use of fire hoses is required in switch-gear rooms. Portable 10,500 cfm fans with portable ducts are available for removing smoke and fumes from the switchgear rooms in the event of a fire. Please refer to Item No. 31 for a discussion of these fans. We do not consider it to be reasonable or practicable to modify the plant to meet all of the requirements of this guideline; consequently, we propose to make no changes.
C o -10 8. Item 79 - Page 62 - 63 Response to Position IV.D.10: The Rancho Seco plant is in compliance with this guideline. The fuel oil storage tanks for the diesel generators are underground tanks located remote from the plant buildings. The boiler fuel oil storage tank 'is an above ground tank located remote (approximately 700 feet) from the plant buildings and is completely surrounded by a dyke area, and in addition foam forming equipment is available for use with the hydrants in the area. Refer to Item 65 1 for discussion of foam equipment. e f Amendment 1}}