ML19341B985
| ML19341B985 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 02/12/1981 |
| From: | Martore J Office of Nuclear Reactor Regulation |
| To: | Miraglia F Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8102280334 | |
| Download: ML19341B985 (16) | |
Text
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FEB 12 1981 NOTE T0:
F. J. Miraglia, Acting Chief, Licensing Branch No. 3, DL FROM:
J. A. Martore, Project Manager, Licensing Branch No. 3, DL
SUBJECT:
FIRE PROTECTION REQUEST FOR INFORMATION FOR GRAND GULF, UNITS 1 & 2 The purpose of this note is to infonn you of the fire protection request for information for Grand Gulf (Enclosure 1), and to request that certain of the questions be deleted for the reasons described in Enclosure 2.
Please advise whether this re' quest for~infromation can be modified per the enclosed recommendations, or whether a meeting should be set up to clarify and resolve this matter.
J YW Joseph A. Martore, Project fianager Licensing Branch No. 3 Division of Licensing cc:
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GRAND GULF NUCLEAR STATION, UNITS 1 & 2 DOCKET NUMBERS 50-416/417 CHEMICAL ENGINEERING BRANCH FIRE PROTECIION SECTION Part 1 013.la. Provide the results of the analysis you refer to on page 9A-21a'of your FSAR including drawings that show the locations of all safe shutdown circuits in the corridor areas of the auxiliary building.
Indicate'the proposed fire suppression systems and the fire rated barrier arrangements, b.
It is our position that the automatic sprinkler systems proposed for the corridor. area at elevation.139' of the auxiliary building
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be extended to. provide complete coverage for the corridor area at this elevation.
It is our posit' ion that the automatic sprinkler systems proposed to c.
provide protection where redundant shutdown systems are less than 20 feet apart be designed and installed in accordance with NFPA 13 with ceiling level sprinklers, with additional sprinklers as required below obstructions such as ducts, etc.
d.
Indicate the location cf redundant safe shutdown system circuits that are closer than 20 feet acar: in the ccntainment areas that are assess-ible curing plant ooeration.
It is our position that 'the control room and remote shutdown panels
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be electrically isolated from each other se that a fire in either area that destroys recundant safe shutdown circuits in that area will not affect the saf e shutdown capability from the other area.
Consictr that a postulated fire in tne remote snutccwn panel area will affect botn remote shutdown ;anels simultanecusly.
Indicate how you will comply witn this position, f.
Revise your FSAR to reflect your statements during our site visit that redundant safe shutdown circuits are not located in a single cable spread-ing room'or in the Computer and Control Panels room.(room OC403) or indicate how remote shutdown capability will be provided if a fire in either of these ar,as was to destroy redundant circuits in that room.
e 013.2
. Demonstrate that safe shutdown capability is maintained if a fire in a transformer at the west wall of the control building was to introcuce sufficient smoke into the fresh air intakes to cause shutdown' of all ventilation systems with fresh air intakes at the west wall of the
-control building.
013.3 Confirm that ventilation air flow' menitors' are provided for the battery room exhaust systems and that alarms will sound in the control room on loss of ventilation air flow.
013.4 See Question 013.le.
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. 013.5 a.
Response is adequate.
b.
It is our. position that the access door to the concealed ceiling space above the control room be maintained locked at all timits, and that the limited-combustible ductwork insulation be replaced with noncombustible insulation. Also, revise your technical specifica-tions to indicate that no work of any kind shall be condected in the ceiling space unless the plant is in a cold shutdown situation, c.
Response is adequate.
013.6 NEDO 10466 does not exempt Grand Gulf from the requirement to use Tefzel insulated' able in the PGCC system; it only states that all BWR/6 plants use Tefzel insulated cacles except Grand Gulf. However, we find your present. installation acceptable with the Halon suppression system installad provided you verify your statement made during our site visit that all termination and control cabinets in the control room which contain redundant safety-related systems will be provided with.an ionization-type smoke detector which will alarm in the control room.
In addition, verify that the Halon system installed to protect the PGCC floor sections is designed to provide a 30% concentration, and is designed to protect the specific PGCC floor layout at Grand Gulf.
013./
at is our position that you verify that a crack or rupture of the recirculation. pump lube oil system at any point in the system (incluc-ing the. reservoir and bearings) will not allow oil to leak outside of the motor housing. Or, if this cannot be demonstrated taan an engineered oil containment and collection system must be installec which will meet Reg. Guide 1.29, paragraph C.2.
013.3 1.
Provide revised Table 9A-2 and provide revised Figures 9.A (includin; Figures 9.A-16 thru 9.A-35) se that they reflect your commitment to install automatic fire detection in all areas of the plant which centain safety-related equipment or circuits, b.
Respense is adequate.
013.9 (1) It is our position that all floor / ceiling construction in safety.
related buildings will have the structural steel protected to provide compliance with the referenced OL design numbers D903 and D916. -In addition, identify and justify the fire rating of all floor / ceiling con-struction in the safety-related' buildings that are less than 3-hours.
(2) Response is adequate.
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. (3) Indicate ' here and justify the use of any "non-fire rated pene-w trations,'? which you reference in Table 9A-1, sheet 6 of 20, subitem J.
013.10 Your. response indicates that water. spray systems will be installed to avoid direct impingement on Class IE equipment and Class IE cables near such equipment. Indicate how this will be compatible with the requirement for total area sprinkler coverage where redundant shutdown systems are located in the same fire area.
013.11 Verify that the control room and the remote shutdown panel area are the only areas that need to be occupied to perform all functions required to achieve a cold shutdown.
In addition, our position on S-hour emergency lighting also applies to access anl egress routed to all fire areas that need to be used during safe shutdown. Verify that you will comply with this position.
013.12' Response is adequate.
013.13 Provide'the results of the field acceptance tests of the fire pumps.
a.
Sections E.2(d) and (e) of Appencix A to ETF 9.5-1 state that fire b.
water supplies should be calculated on the basis of the largest expected flow rate for a period of tv; hours (but not less than 300,000 gallons),
and that, if tanks are usec tc supply the water, two 100% capacity tanks should be provided. The maximum demand at 3 rand Gulf was given to be 27';0 gpm for sprinklers plus 500 gpm for hose streams, or a total of 3200 gpm. The recuired water supply for a 2-nour duration is 384,000 gallons. Two 300,000 gallen tanks do not rest the Appendix A guidelines.
Therefore, indicate how you will comply witn our Appendix A guidelines.
On page 9A-17 of your FSAR ycu state that che fire protection water supply also provices water fcr constructior, use.
It is our position that you comply with tne requirements of Secticn C.l.e cf Appendix A regarding the fire water supply.
Indicate your intent to comply with this requirement.
013.14 No response was received for this question. Provide the design criteria for the Halon and CO2 system used in safety-related areas of the plant.
013.15 Response is adequate.
013.15
-(l) Verify that the five men assigned to the fire brigade on each shift will not be required to perform any other functions (i.e. emergency shutdown) in a fire emergency.
(2) Response is. adequate.
013.17 Response is adequate.
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.4 Part 2 POST SITE VISIT OUESTIONS 013.18 It is our position that all valves. in the fire protection water supply system be provided with electrical supervisory switches arranged to give visual and audible alarm in the control room if the valve position.is changed. An acceptable alternate for sectionalizing valves which do not control suppression systems i.s that the valves be locked ope with'a strict key control procedure, with periodic verification of the valve position.
Your fire protection system diagrams indicate that the suppression 013.19 and standpipe hose systems in containment are not connected to the plant fire water supply system.
It is our position that these systems be part of the overall plant fire water system and receive their water supply from that system. As an alternate, demonstrate that the condensate and refueling water storage anc transfer system is adequate to supply the requireo fire fice, assuming loss of off site power, and that it otherwise meets the requirements for re-liability and water supply storage reserve expected of fire water supply systems.
Also, verify that the functional capability of the condensate and refueling water transfer system would not be de-gradec.
Cl3.20 Your fire protection system diagrams indicate tnat the control building and diesel generator buildings water suppressicn and standpipe and hese station systems are supplied by a single ccnnection to the looped. fire water system from each building.
It is our ;osition that you provide additional connections.to portions of the iccoed fire water system ar.c provide sufficien valves so that a single break in the fire water system will not preclude all fire water su:o:y to any areas of the plant.
013.21 Your fire prctection system diagrams indicate -hat the radwaste building fire pre ection water sup:ly neacer 11 nc: sectionali:ec by-shutoff valves.
It is our position that valves be provided in the radwaste building header so that a single Dreak in the header or in the systems-connected to the header will not necessitate shutting down the fire protection water supply for the entire build.ing.
Verify that a sincie fire which could destroy the RHR "A" and "B" 013.22, instrument panels and the RCIC instrument canel in the east corridor at. elevation 93'-0" of the auxiliary buildine would not have any adverse effect on safe shutdown systems.
013.23 Your analysis states that the north wall cf the HPCS pump room, room lA109 at elevation 93'-0" of the auxiliary building, is non-rated.
Your Fire Protection Plan, Figure 9.A-3, indicates that this wall is a 3-hour rated fire wall. Confirm that this wall, including pene-
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tration seals, is a 3-hour rated wall.
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5-013.24 It is our position that the unassigned area (room la 404) on elevation 166'-0" of the auxi4iary building be provided with a smoke detection system as a minimum, and that an automatic sprinkler system be provided if the room occupancy causes con 6ustibles to be stored.
013.25 During our site Yisit we noted that many of the doors identified on your. Fire Protection Plan drawings as 3-hour rate fire doors are actually air-tight doors or other doors that have not been tested for. fire resistance. Although you have a statement from the manufacturer that these doors are "similar" in design to rated fire doors, it is our position that you provide 3-hour rated, labeled fire doors at all such location, which include. the doors from the turbine building to the auxiliary and control buildings.
013.26 During our site hisit you indicated that redundant safe shutdown system cable was routed.through both the Division I and Division II switchgear areas on elevation 111'-0" of the control ouilding. These areas are presently protected by CO2 total flooding systems, and you indicated that the redundant train of cables in each area would be wrapped with a one hour fire rated barrier.
It is our pcsition that an automatic water suppression system be installed in enca area in addition to the one hour fire rated barrier around o-vision of c ab le.
As an alternate, the cable could be relocate ^
- nat it is no; routed througn the redundant c vision switchgear r.r..
013.27 I
is cyr position that the Division I safe shutdown cable located in the HVAC equipmen rcom.(room OC302) on elevation 133'-0" of the centrol building te previded with a 1-hour fire barrier to separate it frcm the remainder of the area.
At our site visit, you indicated that the only Division I safe shutdown. cable in this area was along
- ne east wall; verify that no othe-Divisicn I safe shutdown system cable or equipment is in this room An area automatic suppression system is not recuired.
013.?5 Verify that all floor openings between the. control room and the lower cable spreading room will be sealed to provide a 3-hour fire resistance, including the opening identified on Figure 9.A-36 as " Openings in ceiling above where r? quired for bottom entry to termination cabinets in control room" 013.29 It is our position that you comply with Section F.3 of Appendix A to STP 9.5-1 by providing a fixed pipe water suppression system in both the upper and lower cable. spreading room.
013.30
~ Indicate the type of floor covering which will be used in the control
.It is our position that carpet not be utilized.
room.
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e 013.31 Verify tnat the interface between the con:rel rcra viewing gallery (room OC 601) and the concealed space above the control room suspended ceiling will be separated with at least a 1-hour fire barrier.
It is our position that the wall separating the Unit 1 and Unit 2 013.32 sides of the control room be replaced with noncombustible material if it is to remain in. place when Unit 1 is operating and Unit 2 is under construction.
0 It is our position that you comply with Sections 0.l(d) of Appendix A
'013.33 to BTP 9.5-1 by replacing all insulation, radiation shielding and sound-proofing materials that are other than noncombustible with noncombustible materials in all safety related areas of the plant.
This includes the limited-combustible duct insulation presently being installed.
013'.34 It is our position that, in addition to the automatic sprinkler
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system proposed for the area, one of the two divisions of diesel generator cable required for safe shutdown ce enclosed in a minimum 1-hour fire barrier in the corridor between the auxiliary building and the diesel generator building (Room 1A 301).
It is our position that the diesel generatcr.rcom outside air fans 013.35 te arranged to start automatically in the Division I or II diesel generator rooms upon detection of smoke in either of the other two diesel generator room to prevent the smoke from a fire in one room from filtering back into the other rooms througn the exhaust openings to the ' cannon corridor, room 1A 301. As an alternate, the fire dampers presently installed in the exhaust openings should De arranged to also close as a smoke damper.-
Verify that the citection systems which are used te actuate fire 013.36 suppression systems will alarm in the control room independently of the suppression system actuation.
In Table 9A-1 of your FSAR, you indicate that the normal plant 013.37 ventilation systems would be used to ventilate smoke and other pro-Since the ventilation equipment may not handle ducts of combustion.
the smoke because of clogged filters, it is our position that portable smoke exhaust fans and ducts be provided. The portable units provided should be designed for such use, should be capable of being used with-out.offsite power, and should.be sufficient in num:er and capacity to provide ventilation for any area of the plant where normal ventilation systems cannot be relied upon.
Verify that automatic fire detection is being provided in the new and 013.38-spent fuel pool area.
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W It is our position that water type portable fire extinguishers 013.39 be installed at strategic locations throughcut the plant, including
- ne control room and cable spreading rocms. Confira :na; ycu will meet this position.
It is our position that, due to the large fire load, the miscellan-013.40 eous equipnent. area (room 1A 509) at elevation 184'-0" of the centain-ment building be protected with an automatic sprinkler system.
Part 3 FIRE PROTECTION SUPPLEMENTAL QUESTIONS POWER SYSTEMS BRANCH
- n a :ordance vith secticn 9.5.1, Branch Technical Position ASE 9.5-1, position C.a.a.(1) of NRC Standard Review Flan and section !!!.G of new A;per. dix R to 10 CFR Par: 50, it is the staff's position that cabling for redundant safe shu:d:wr. systems should be separated by walls having a three-hour fire rating k
- r e;uivalent protection (see secticn III.G 2 cf *;:er. dix R).
That is, catling required for or associated with the prima.7y method Of shu;d: n, should ce physically separated by the equivalent of a three-h ur raten fire barrier from catling required for or associated w?
the redundant or alternate method of she:::wn.
To assure *.1at redundan shu.cewn cable systems and all other cable are associated wit.*. the shutd wn cable systems are sa;arated fr:m systats ina each c ner so that both are not subject ;c damage from a single fire ha:ard, we require the following information for each system needed to bring the olant to a s,afe shutdown.
1.
Fr: vide a table that lists all equipment inciu:ing instrumentation and vital supper: system equipment required to achieve and maintain h:: and/or :cid shutdown.
For each equipment listed:
Differentiate between equipment required :: achieve and maintain hot a.
s_hutdown and equip' ment required a 3chieve and maintain cold shutdown, o
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Define each equipment's location by fire area, c.
Define each equipment's redundant counterpart, d.
Identify each equipment's essential cabling (instrumentation.
, control, and power).
For each cable identified: (1) Describe the ca bl e routing (by fire area) from source to ter=ination, and (2) Identify each fire area locatien where the cables are separated by less than a wali having a three-hour fire rating from cables for any redundant shutd:wn system, and e.
List any proble areas identified by item 1.d.(2) above that will be corrected in accordance with Section III.G.3 of Appendix R (i.e., alternate or dedicated shucdown capatility).
2.
Fr:vice a ta$:le that lists Class iE and Non-Class 1E ca:les that are associated with the essential safe shutdown systems identified in ite: 1 as:ve.
For each cable listed:
a.
Define the cables' association to the safe shutd:wn systa= (common power source, cor=cn raceway, separation less than Tsegulatory Gu'.de 1.75 guidelines, cables for equipment whose spurious operation.
' will adversely affec't shutdown systems, etc.),
i b.
Describe each associated cable routing (by fire area) fn:m source to termination, and Identify each location where the associated cables 'are separated c.
,by less than a wall having a three-hour fire rating from cables required for or associated with any redundant shutdown syste=.
0 b D Provide one 'of the folicaing for each of the circuits identified in ite-3.
2.c above:
(a) The results of an analysis that demonstrates that failure caused affect it's by open, ground, or hot short of cables will not associated shutdown system, (b) Identify each circuit requiring.a solution in accordance with section Ill.G.3 of Appendix R, or (c) -Identify each circuit meeting the requirements of section III.G.2 cf Appendix R (i.e., three-hour wall, 20 feet of clear space with automatic fire suppression, or one-hour barrier with automatic fire suppression).
Te assure compliance-with GDC 19, we require the following information be 2
provided for the contrcl room.
If credit is to be taken for an alternate or dedicated shutdown method for other fire areas (as identified by ite:
t 1.e~ or 3.b above) in accordance with section III.G'.3 ' f new Appendix R o
to 10 CFR Part 50, the following information will also be required for i
,each of these plant ar,eas.
A table that lists all equipment including instrumentation and vital a.
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support system equipment that are required by the primary method of achieving and maintaining fat and/or cold shutdown.
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.2 b.
A table that lists all equipe.ent ibeluding instrumentation and vital support system equipment that are. required by the alternate, dedicated, or remote method of achievtng and maintaining hot and/or cold shutdown.
O c.
Identify each alternate shutdown equipment listed in item 4.b above with essential cables (instrumentation, control, and power) that are located'in the fire area containing the prir.ary shutdown equipment.
For eac.i equipment listed rovide one of the following:
(1) Detailed electrical schematic crawings that show the essential cables that are duplicated elsewhere and are electrically isolated from the subject fire areas, or 4
(2) The results cf an analysis that demonstrates that failure (open, ground, or hot short) of each cable identified will not affect the capability to achieve and ma#ntain hot or i
cold shutd:wn.
l d.
Provide a table that lists Class 1E and Non-Class lE cables that are associated with the, alternate, dedicated,or remote method of shutdown.
ror each item listed. identify each associated cable located in the fire area containing the primary shutdown equipment.
For each cable so identified provide the results of an analysis that derenstrates that failure (open, i
ground, or hot short) of the ass'ociated cabl'e will not adversely affect
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the alternate. dedicated.or remote method of shutdown.
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The residual heat removal systeE is generally a Icw pressure syste: tha ir.terfaces with the high pressure primary ccclant system. To preclude a LOCA.through this interface, we require cc:;1iance with the re::: enda-
' tion: of Branch Technical Fositten RSS 5-1.
Thus, this interface most likely consists cf tw: redundant and independent act:r c;arated valves with diverse interlocks in accordance with Eranch Technical Position ICSE 3.
These two. motor operated valves and their associated cable may be subject to a single fire ha:ard.
It is our cencern that this siagle fire could cause the two valves te open resulting in a fire-initiated LOCA through the subject high-lcw pressure system interface.
Te assure that this interface and other high-low pressure interfa:es are adequately prete:ted fect the effe::s cf a single fire, we require the f:ll: wing information:
a.
Identify each high-lcw pressure interface that uses redundant electrically contr:lled cevi:es (su:h as wc series :::r c;erated valves) te isolate or preclude rc::ure of any primary cc:lant
- boundary, b.
Identify each device's essential cabling (p:wer and centr'l) and c
describe the cable routing (by fire area) fr:m source ::
termination.
Identify each location where the. identified cables are separated c.
by.less than a wall having a three-hour fire rating fros. ables c
.for the redundant device.
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For the 6reas identified in ite: 5.c cbove (if any), pr vi:fe tne bases a'nd justification as to the acceptability cf the existing design or any proposed c.cdifications.
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_ Enclosure 2 COMMENTS ON FIRE PROTECTION REQUEST FOR ADDITIONAL INFORMATION 013.la.
There is no reason to request'that the location of all safe shutdown circuits be datailed.
Grand Gulf has already submitted their Fire Hazards Analysis (FHA), and the staff indicated that for the most part it was one of the better evaluations received.
At the site visit it was. agreed that MP&L would indicate those redundant cables within 20 feet-(the staff's required separation distance) and that proposed barrier-arrangements would be submitted.
However, the staff agreed that this would be done by way of marked up drawings informally submitted for information only, not by way of a formal request for information.
1013.3' This question shouldn't have been asked.
The ressoase has already been provided in FSAR Amendment 42.
I 013.5b Why are we requesting that allyductwork insulation be replaced?
The FRA was performed using the insulation now in the plant.
In addition, the FHA specifies that all ductwork insulation has a flame spread rating of 25 or less.
It is my understanding that this thus qualifies it as noncombustible.
Finally, we should not require a tech spec ~ change as requested.
013.9 There is no reason to request that all floor / ceiling fire rating be identi fied.
Only those barriers separating areas / items where safe shutdown equipment-needs to be protected should be identified.
'013.10 Why are we requesting that Class IE switchgear be directly sprayed?
Other protection is provided, and in addition all redundant cables
- are separated by the. required 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire barriers, except in the switchgear room.
013.13 We should not request the results of the field acceptance tests.
- These are reviewed by I&E.
l-013.18 This quelon should be deleted.
The FHA indicates how Grand Gulf meets this position.
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L 013.'19 This question is unreasonable and should be deleted.
Introducing fire water supply to'the plant service water and suppression systems would adversely affect water quality. Also, the condensate system should be adequate to provide necessary water supplies..
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. 013.22 This question is unreasonable and need not be asked.
The subject corridor is about 150 feet long, with the 3 panels equally spread out. Only the RHR "A" and "B" panels are redundant ano they are on opposite ends of the corridor.
It is unreasonable to think that an exposure fire could spread across this distance, especially since the NRC position is that a 20 foot separation is adequate.
- Finally, what type of verification is expected that is not already in the FHA?
013.25 This question should be deleted.
This concern was discussed at the site visit, and the staff was told that the manufacturer has indicated that the doors are made of similar materials and to similar standards and specifications ac other fire rated doors. This question would require that each aad every " unique" door, be tested even though its "uniquene'ss" ray be insignificant (i.e., a different type of latch, bolt, etc.]
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013.26 This question should be deleted.
Again, why are we requesting that switchgear be sprayed? This area has very limited cables, is accessible for manual fire fighting, is protected by CO systems, and is alarmed.
2 013.27 This question should be revised, since it is uncertain how a fire can spread over the 40 foot distance between the cables.
013.2.0 This question is unreasonable and should be deleted. There are no redundant hot shutdown cables in the cable spreading rooms!
013.32 This question should be revised or deleted. The FHA indicates that flame retardent tarpaulins will be used to separate the Unit and 2 sides of the control room during construction of the Unit 2 cide.
Perhaps the staff was confused and didn't realize that the curt.1t plywood barrier will be replaced.
013.33 This question should be deleted.
See comment on question 013.5.
013.34 This question should be deleted. Why require a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> fire barrier around one cable when a sprinkler system is already provided. Also, the cables are 20.4 feet apart, and our position is that a 20 foot separation is considered to be an acceptable fire barrier.
013.38 This request ra.ises several questions.
Is this required at other plants? How many portable units would be required? Would there be additional requirements on inspection, maintenance, control, etc.
of these portable units?
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- Part 3 This entire part should be deleted.
I understand that it is a generic question that is sent to ill plants, but it may not be appropriate to issue it at this late stage since many of the concerns may have already been addressed.
At a meeting held about a year ago, the fire protection staff discussed our positions with the applicant and advised them to follow the Appendix R proceedings. The applicant has done this and has submitted their FHA addressing our concerns.
Why then do we ask for this type of information now, when it could have been easy supplied, if needed at all, if we asked for it when the FHA was being performed.
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