ML19318A883
| ML19318A883 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 06/20/1980 |
| From: | Lundvall A BALTIMORE GAS & ELECTRIC CO. |
| To: | Clark R Office of Nuclear Reactor Regulation |
| References | |
| 013-261-0, 13-261, L-037-F, NUDOCS 8006240320 | |
| Download: ML19318A883 (10) | |
Text
.
BALTIMORE GAS AND ELECTRIC COM PANY P. O. B O X 1475 B A LTI M O R E. M ARY L A N D 21203 June 20, 1930 ARTMUm E. LuNovAn. Ja.
Vsct Pats.ctst s v..o Mr. Robert A. Clark, Chief Operating Heactors Branch #3 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Subject:
Calvert Cliffs., lear Power Plant Units No. 1 C 2, Docket.*io. 50-317 C 50-318 Fire Protection Safety Evaluation Report and Amendments to Facility Operating License File:
013-261-0. L-037-F
Reference:
(1) NRC letter dated May 19, 1940 from Clark to Lundvall (2) BCCE letter dated ::ay 23, 1930 from Lundvall to Clark
Dear ?;r. Clark:
In accordance with our letter referenced above, attached is our response to items 3.1.13, 3.2.1, 3.2.2, 3.2.4. and 3.2.5.
We still have not received a schedule for your staff's response
.to items 3.1.19, 3.1.20, 3.1.21, 3.2.3, 3.3.1, 3.3.2, 3.3.3, 3.3.4, 3.3.5, 3.3.6, and 3.3.7 that were listed in your May 19, 1330 letter as "Incom-plete - staff's evaluation is not complete." As stated in our letter of May 23, 1930, these itens are related to the resolution of item 3.2.1.
Therefore, you will note that in our response we are unable at this time to commit to your staff's requirements for that item.
We will, however, p?oceed with the necessary en;;ineering required to scope such requirements.
Very truly yours, N. J. Bowmaker for Enclosure
,A.
E. Lundvall, Jr.
cc:
J. A. Biddison, Esquire G. F. Trowbridge, Esquire Messrs. E. L. Conner, Jr. - NRC J. W. Brothers - Bechtel 004
.5 THIS DOCUMENT CONTAINS P00R QUAUTY PAGES l8 00624 0 W
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CALVERT CLIFFS NUCLEAit Por;ER PLANT UNITS NOS. 1 AND 2 RESPONSES TO STAFF REQUIRD'.E!;TS CONTAINED IN E.'.* CLOSURE 2 FUltiISifED V;IT!! Tl!E :LW 19, 13d0 NRC LETTER ltELATIVE TO !!!E SEit FIRE PROTECTION O
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3.1.'13 Energency Communication
' Separate the existing' two-hardwired communication systems, the sound powered system and tne page/ party syste=, by 3-hour rated fire barriers so that both systems will not be subjected to simultaneous damar,e due to a single fire; or provide a third communication systea independent of ' the exis ting sys tems.
Response
In response to the concerns outlined by the Brockhaven National Labo-ratories (BNL) contained in Enclosure 3 of the NHC ::ay 19, 13d0 letter, we wish to advise that the new system is not an extension of the exist-ing sound powered system but rather a completely new and independent con =unication system. There are no common conduits used for this new system with the old. The routing is shown on the enclosures contained in our response dated January 11, 1940. The routings are through stair towers and sprinklered areas and not common with the existing system (i.e., through the Cable Spreading Rooms, cable chases and tunnels, etc.).
No conduit is run through the Control Room, nor is any portion of the systen in the control noom co==on to both the original sound powered and the standard page/ party systems. As indicated in our May 20, 1980 response, these modifications have been completed except for the sound powered equipment within the Unit No. 2 contair.nent.
The latter will be installed during the next scheduled refueling outage.
3.2.1 Fire !!azard Analysis Provide alternate shutdown capability independent of cabling and equip-ment in the following areas:
(1). The control room.
(2) Two cable spreading rooms and the adjoining cable chases (lC and 2C).
(3)- Six cable chases (lA, lu, 2A, 23, !!orizontal U1, 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 li=ited to, the following:
(a) Auxiliary building corridor and adjoining areas, Elevation
(-)l0'-0".
(b) Auxiliary buildin2 corridor and adjoining areas, Elevation 5'-0".
(c)
Component cooling pump rooms..
(d) Each service water pu=p roo=s.
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c 1s This requirement is in addition to other requi ements and commitments such as,' automatic fire suppression, automatic fire detection, fire doors, penetration seals, manual hoses, etc., that will provide capa-bilities to detect and suppress fire, and separate different fire areas.
Alternatively, a separate and independent dedicated shutdown system provjding additional means to perform those safe shutdown functicns for wl.. h redundant cabling / equipment cannot be adequately separated, will be'acceptabic.
The alternate / dedicated shutdown capability should conform to the staff position on safe shutdown capability (Enclosure 4).
Response
- Preliminary engineering is underway to determine the scope of this requirement.
Upon completion of our engineering and the receipt of the outstanding items still pending staff review, we will respond to this requirement. As this is a new require-ment, we do not consider it as a part of the work required in connection with our previous commitments.
3.2.2 Adecuacy of Detector Installation (1) Describe the parameters considered in both tne original detector system design and the sut.ieq:en,t 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 caoles in cable chases 1C and 20.
Response
In response.to the concerns outlined by bNL contained in Enclosure 3 of the NRC :.tay 19, 1930 letter, we wish to advise in egard to the
~ ove-itemized items:
4 (1)
In respect to the original detector system design parameters, BGCE has furnished verbal responses on several occasions, furnished drawings showing location of detectors to the site inspection team, which included ' representatives of BNL, and described the basis of the design in our response to the staff dated December 21, 1973.
We repeat that the layout, spacing and mounting of the existing fire detection system was determined by representatives of the Pyrotronics Company and its sales engineering representatives.
.The, design organization took into consideration such factors as
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. the burning characteristics of the combustibles anticipated in the area, cable tray and equipment locations, structural desi*;n, shape.and height, HVAC air distribution patterns and velocities and room' air change rates.
The Pyrotronics D:6-3/5A detector sensitivity is adjustable and each det:ctor was caliorated (i.e.,
voltage setting verified). Attached is a certification statement furnished by a professional fire protection engineer which ccvers the desi n of. the. proposed new fire detection systems for Calvert 3
-Cliffs. These detection systems are currently being designed and installed as required by our Fire Hazards Analysis.
(2) UCCE.has verified that the spacing between ?yrotronics DIS-3/5A detectors and between this type detector and walls is witnin the
. allowable limits as provided in NFPA 72E.
'(3) UNL has acknowledged that detector spacing as a function of air-change-rate and ceiling height is recsonable except for the cable chases. As indicated by sNL, BGCE proposed to install automatic sprinklers in cable chases lA and 2A and total flooding Halcn 13J1 systems to protect' cable chases 1C and 2C.
BNL acknowledges that automatic sprinklers are satisfactory while Halen systems actuated by smoke detection systems may not be satisfacto.ny because of ne ceiling heights. involved rendering smoke detectors ineffective.
The Halon systen is currently being designed, including its auto-natic detection components. The fire detection system consists of, fixed temperature detectors and mul.ipic " products of combus-tion" type detectors installed at two elevations.
There fore, if l-the early warning " products of combustion" type detecturs do not respond to a slow developing fire, the fixed temperature detector, which is similar to a sprinkler head, will actuate the Halon 1301 fire suppression system to suppress the fire, i
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3.2.4 Ventilation Duct-Penetrations verify that the-proposed method of fire damper installation conforns to the conditions of listing of the fire damper by the testing labora-l tory.
Response
i BGGE will verify.that the method of fire damper installation conforms to the? conditions of the listing of the fire damper by the testing laboratory and that the installatica provides the required fire resis-tance to meet the Fire Hazards Analysis. A report of our findings will be. furnished to the staff, r
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" Application Engineering Fundamentals" cf Pyrctrer.ics, the detectcr r.anu-t facturer, Copyright cate 1974 i
Tnis statement applies to the following drawings:
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_4 3~2.5 Dachflow Protection
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Verify that-a backficw chech valve is provided in cacf1 drain
,line from the char,;ing pu;;:p cubicles and diesel rooms, or that
.cach cubicle / room has a acparate drain Oystem.
(2)~ Verify that each piping from individual roen sumps on Eleva-tions (-)l0'-0" and (-)l5'-0" to the waste receiver ta:2 is equippe) with a backflow chech valve.
'(3). ' For each plant a:ca which ccatains five gallons or. core com-i bustible liquids and have a drain system ccamon with safety related areas, verify that backflow from these areas to the safe ty. rciated areas ' can be prevented if drain piping is clogged immediately downstream of the ecm.cn junction or
'the headcr.- The study should include the censideration of backflow from nonsafety-related areas.
Resnonse In response to'the concerns outlined by UNL contained in Enclosure 3 of the NHC 2:ay 19, 1930 letter, we wish to advise in regard to the above itenized items:
~ (1) Backflow check valven are not provided :n eacn crair. line frcs the charging pump cubicles and diesel rooms, nor are the cubicle /
rooms equipi;ed with separate drain sys t;m.;.
The charging pump cubicles within the Charging Pump neoms 105 and
.115 are equipped with interco:mected four inch drains which dis-charge to the Duplex Sump No. 11.
Two sump pumps are provided, each is equipped with a check valve, to discharge to the miscel-laneous waste. receiver a.d monitor tanks. Eacn charging pump installation contains approximately 3.75 gallons of lube and gear oil..The drain piping between laterals to adjacent cubicles is four inch diameter ar.d at least one foot below the finished floor.
This four inch diameter stainless s:cci pipe has a nominal draina;e capacity to hanale over 200 gallons per minute. This draina3e capacity is sufficient to handle the ' combined flow of the sprinkler system within one cubicle, plus the nominal discharge from a hose stream, plus the volume of the lube and gear oil ecntained in one charging pump. The four inch pipe between rooms is capable of accepting all the lube and gear' oil frca one charging pump without overflowing into adjacent rooms.
The diesel generator room floor drains are interconnected through four and'six inch piping to the oil interceptor associn.ed with the Diescl Generator Room Waste Oil Collection Tenk
'M. 11 which is buried in the yard westLof the Auxiliary Hcom.
This drainage
. system is so arranged that water. is allowed to flow to the Yard i
! Drainage. System and oil is captured by the interceptor. Each L
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, diescl. engine contains about 525 gallons of lube oil and a fuel oil day tank containing 510 gallons.
The largest openings from
- cither reservoir / tank are smaller than die four inen diameter floor drains in each roo thus assuring that the oil will be carried safely froa ' the room.
These floor drains are located more than four feet below the finished floors so that before backflow can occur liquid levels in adjacent rouus nust reach significant depths..The Diesel cencrator Huon drainage system
'is independent of the balance of the plant.
The Diesel Cencra-tor Hocas are at the same elevation precluding backflow of liquids since flow would be established throu;,h door openings
- to the yard.
In_ conc;usion, there is no useful purpose served by installing backficw check valves in the Diesel Generator Room floor drains and' the charging pump cubicic floor drains. With respect to the curbs proposed between the charging pump cubicies which UNL identified on page 7 of their 1:nclocure 3, these curbs were pro-
-posed to limit spread of the tranaient conbustible liquid spilled from a' tipped-over 55 gallon drum introduced into tne area. This transient combustible liquid was postulated in support of the Fire Hazards Analysis subsitted earlier on Deceuber 21, 1930.
(2) With respect to the piping from individual roon sumps on Eleva-tion (-)10'-0" and (-)15'-0" to the waste receiver tanks, the discharge -lines from the sump pumps are equipped with eneck valves.
Euch ECCS Hoo: is equipped with a dedicated sump ond purp, including a check valve to prevent backflow, and the rooms are equipped with supervised watertight doors to prevent flow of liquids into or between' the four rocca.
The Charging Pump Hoon drainar,e'systen is addressed in (1) above.
It should be recogni:cd that check valves are provided in all discharge lines from sump pumps to prevent communication between sumps.
(3) Each p'lant area was evaluated in our Fire Hazards Analys., con-templating ' transient combustibles cons Lsting of conbus tiole liquids being introduced into the area. This hypothesis is described in our Fi:7 Hazards Analysis, page FHA-4 of our sub-mittal'to the staff dated December 21, 1979.
-Attached is a tabulation of areas / rooms which have been identified as containing 5 gallons or more of combustible liquids.
This tab-
.ulation identifies the quantities and the ultimate drainage point or system. Each roca has been evaluated to determine the conse-
_quences of a failure of the containcent tank systen to cause the g
combustible liquid to reach the floor drainage systcas.
There'is no case where release'of cocbustible liquids fec: the largest component of a syste= could backflow to adjacent rooms / areas con-taining-safety related equipment.
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