ML19343C763
| ML19343C763 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 03/19/1981 |
| From: | Linder F DAIRYLAND POWER COOPERATIVE |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| LAC-7424, NUDOCS 8103250182 | |
| Download: ML19343C763 (25) | |
Text
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D DA/RYLAND k
COOPERAT/VE. eo sox an. N5 FAST AV SOUTH. LA CROSSF WBCONS!N M601 (em 788a000 March 19, 1981 In reply, please refer to LAC-7424 DOCKET NO. 50-409 N
U.
S.
Nuclear Regulatory Commission a
D ATTN:
Mr. Darrell G. Eisenhut Division of Licensina 8
Office of Nuclear Reactor Regulation i
-j g ?.4gg,\\w" -[0 Division of Operating Reactors p-Washington, D.
C.
20555 SUBJFCT:
DAIRYLAND POWER COOPERATIVE o.5.'
A' LA CROSSE BOILING WATER REACTOR (LACBWR)
(3r PROVISIONAL OPERATING LICENSE NO. DPR-45 V'
FIRE PROTECTION MODIFICATIONS
References:
(1)
DPC Letter, LAC-7400, Linder to Eisenhut, dated March 9, 1981.
(2)
NRC-Letter, Crutchfield to Linder, dated
. February 13, 1981, supplement Mo. 1 to the July 27, 1979 Fire Protection Safety Evaluation.
(3)
NRC Letter, Denton to'Linder, dated February 13, 1981.
(4)
DPC Letter, LAC-7361, Linder to Eisenhut, dated February 6, 1981.
(5)
NRC Letter, Eisenhut to All Power Reactor Licensees with Plants Licensed Prior to January 1, 1979, dated November 24, 1980.
(6)
DPC Letter, LAC-7203, Linder to Eisenhut, dated November 3, 1980.
l (7)
URC Letter, Eisenhut to Linder, dated September 18, 1980..
(8)
DPC Letter, LAC-7100, Linder-to Director 1
of Nuclear Reactor Regulation, dated August 25, 1980.
(9). NRC Letter, Lainas-to Linder, dated June 16, 1980.
(10)
DPC Letter, Linder to Ziemann, LAC-6819, dated March 11, 1980.
i (11)
DPC Letter, Linder to Ziemann, LAC-6774,. dated February;6, 1980.
(12) : DPC 1 Letter, Linder to Zierann, LAC-6740, dated l
' January 17, 1980.
i (13)
NRC Letter,' Ziemann to Linder, dated Septerber 14, 1979.
(14)
Arendment No. 17.to Licence No. DPR-45, forwarded l
by.MRC Letter, Ziemann to.Linder, dated July 27, 1979.
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G Mr. Darrell G. Eisenhut LAC-7424 Division of Licensing March 19, 1981 References :-- (Cont' d)
(15)
DPC Letter, Linder to Ziemann, LAC-6099, dated January 31, 1979.
(16)
NRC Letter, Ziemann to Madgett, dated November 15, 1978.
(17)
DPC Letter, LAC-5503, Madgett to Ziemann, dated October 18, 1978.
(18)
DPC Letter, LAC-4482, Madgett to Stello, dated February 14, 1977.
Gentlemen:
On February 13, 1981, as Enclosure 1 of Reference 2, the NRC issued Supplement No. 1 to the July 27, 1979 Fire Protection Safety Eval-uation Report for the La Crosse Boiling Water Reactor.
This supple-ment to the Fire Protection SER incorporated the results of the evaluation by the staff of various fire protection rodifications. of Reference 2 provided a table of unresolved fire pro-tection items to be resolved by Dairyland Power Cooperative in conformance with the requirements of App 6ndix R to 10 CFR 50 on the schedule specified in 10 CFR 50.48 (c).
Enclosure.1 of this letter addresses each of the unresolved fire protection items listed in Enclosure 2'of Reference 2.
Several of these unresolved items have been grouped together based on previous correspondence and the inter-relationship of individual items.
The surmary statement of each item is taken from the Summary of Staff Requirements to Resolve Open Items which was forwarded by Reference 5.
Additional information and proposed actions are provided for the unre-solved items, and exemptions from certain requirements of Appendix R to 10 -CFR 50 are requested in accordance with 10 CFR 50.48 (c) (6).
If there are any questions concerning this transmittal, please contact us.
Very truly yours, l
DAIRYLAND POWER COOPEPATIVE pggfr/
N Frank Linder, General Manager FL: FAD:af Enclosure e
cc:
J.
G. Keppler, Reg. Dir., NRC-DRO III NRC Resident Inspectors l
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EMCLOSURE 1 LA CROSSE BOILING WATER REACTOR FIRE PROTECTION UNRESOLVED ITEMS UNRESOLVED ITEM:
SER 3.1.4(2)
FIXED SUPPRESSION SYSTFMS "To meet the requirements of Section III.D of Appendim R to 10 CFR 50, the licensen should provide an engineered oil containment and collection system (for the recirculation pump lube oil system).
DPC RESPONSE:
Paragraph 3.1.4 (2) of Reference 14, the LACBWR Fire Protection cafety Evaluation Report, st&ted "An automatic water fire suppression system, or an oil shield and collection system, will be provided to protect or prevent an oil fire at the reactor coolant recirculation pumps."
In response to this requirement, on February 6, 1980, DPC submitted plans for installation of oil _ drip shields for forced circulation pumps and reported progress being made in the implementation of this modification in Reference 11.
On June 16, 1980, in Reference 9, the NRC and its consultant requested a more detailed design descrip-tion of the lube oil collection system and imposed the following additional criteria on the oil collection cystem:
i a.
The proposed system provides a ecmplete enclosure for j
all potential leakage points, including lift pump and i
piping, external oil cooler,' flanged connections, i
i drain plugs, fill points, upper and lower reservoirs, sight glasses, and overflow-lines.
b.
During a safe shutdown earthquake, the effects of the i
seismic event on the system will not adversely affect plant safety.
l c.
Strainers or other means of preventing clogging of' l
drain piping are'provided; or the system is capable of containing the entire content of lube oil in each pump.
r DPC replied on November 3, 1980, by reporting in Reference 6 that the installation of oil drip shields around Forced Circulation Pumps had been completed as planned during the April 1980 outage and that a i
l further evaluation of the oil drip shields in light of the recent criteria would be conducted by DPC.
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ENCLOSURE 1 Subsequently, on November 24, 1980 as Enclosure 1 to Reference 5, the NRC forwarded the final version of Appendix R to 10 CFR 50 which required the backfitting on all plants of Section III-0, Oil Collection Systems for Reactor Coolant Pump.
In Enclosure 2 to Reference 5, the NRC reached the following conclusion:
We find that the proposed drip shield system does not provide adequate protection against all postulated oil p
leaks _in the reactor recirculation pump lube oil system and is, therefore, not acceptable.
'During the recent refueling outage which commenced in November, 1980, the oil drip shields were partially removed in the course of maintenance and DPC plans to remove remaining drip shields other than those which protect lagging, during future outages.
DPC has reviewed the requirements of Appendix R to 10 CFR 50 and previous correspondence and has re-evaluated measures taken to mitigate potential consequences of an oil leak from the Forced Circulation Pump Lube Oil System or the Forced Circulation Pump Coupling Oil System.
f As previously reported in_ Reference 18, the LACBWR Fire Hazards Analysis,. there are two 15-gallon' lube oil tanks and and two 90-gallon fluid drive coupling oil tanks located _ in the Containment Building.
In order to avoid the expense and radiation exposure l
associated with providing an engineered oil containment and collection system, LACBWR plans to replace the coupling oil with a non-flammable fluid.
This modification would leave approximately 15 gallons of lube oil in containment for each of the two Forced Circulation Pumps.
In Section-3.2.8 of Reference 18, the LACBWR Fire Hazards Analysis, the total fire load in the Containment Building was calculated to be 73.8 x 106 BTU or 26,000 BTU per square-foot.
Combustibles in the i
Containment Building at the time of the Fire Hazards Analysis 6 BTU, Forced Circulation included. cable insulation with.7.8 x 10 6
Pump Lube Oil and Coupling Oil with'32 x 10 BTU, bcrated polyethylene neutron shield blocks with 32 x 10 BTU, and other combustibles with 6
2 x 106 BTU.
As reported in Reference.4, the polyethylene neutron shield blocks.were removed from the Containment Building basement and-Boraflex neutron shielding was installed in the lower reactor cavity.
The Boraflex shielding is fire retardant with a minimal fuel
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contribution and is~1ocated away from potential sources of ignition, thus effectively eliminating it as a potential contributor to a fire in the Containment Building.
In1 addition, fire hoses in the Contain-ment Building have'bcen. upgraded and the Containment Building is covered by 15 ionization chamber type, products of combustion, smoke 3
ENCLOSURE 1 and fire detectors which alarm in the Control Room.
The Contain-ment: Building is readily accessible due to the small size of the plant resulting in a rapid response by the Fire Brigade.
With the proposed substitution of a non-flammable fluid in the Forced Circulation Pump Coupling Oil System, the fire loading in Contain-6 ment due to oil would be reduced from 32 x 10 BTU to approximately 4.6 x 10s BTU.
The replacement of neutron shielding which was compl'ated in December 1980 and the proposed nodification of the Forced Circulation Pump Oil System will result in a total reduction of approximately 80% of the total fire loading in Containment from the 73.8 x 106 BTU reported in the LACBWR Fire Hazards Analysis.
Under Section III.P of " Supplementary Information" accompanying Appendix R to 10 CFR 50, the Commission stated the following:
P.
Reactor Coolant Pump Lubrication Systen.
Technical Basis.
Fach reactor coolant pung notor aseenbly typically contains-140 to 220 gallons of tube oil.
Oil leaking fran some portions of the lubc oil system may cone in contact uith surfaces t 'ic a are hot enough to ignite the oil.
The resulting fire could be large,-and access to the fire vould be de-Layed because of the time required to enter the con-tainment.
Containment air temperature could increase,.
severe localised environnents vould develop in the area of the fire, and a large amount of smche could be generated.
These conditions could affect operabit'ty of safety-related equipment inside containment.
There-fore, an oil collection systen is necessary to confine 8
any oil discharged due to leakage or failure of the lubrication systen and to prevent it from becoming a fire hasard by draining it to a cafe location.
These occurrences could be randon or could be seismically induced because the existing tube oil system piping l
and'oit collection systems may not be designed to with-stand a-design basis seicmic event.
j DPC submits the following information relevant to the recuirement for an engineered oil collection system.for reactor coolant pumps:
i-1.
After the proposed substitution of'a non-flammable fluid in the' Forced Circulation Pump Coupling Oil System, the quantity of flammable oil' associated with each Forced j
Circulation Pump will'be 15 gallons as opposed to between 140 gallons and 220 gallons of oil per pump on which the recuirement for a collection system is based.
It should be noted that the original design of the Forced Circulation f
ENCLOSUPE 1 Pump Coupling System called for use of a non-flammable mixture of glycol and water, but that oil was used due to concerns over possible leakage into the Lube Oil System.
Operating experience indicates that no such leakage has occurred and a glycol-water mixture is one of two fluids being considered for use in the Forced Circulation Pump Coupling Oil System.
2.
Installation of an engineered oil collection system would necessitate substantial radiation exposures of up to several hundred man-rem.
Replacing coupling oil with another fluid would involve much lower radiation exposures and would be consistent with ALARA considerations.
3.
The fire detection system in the Containment Building consists of 15 smoke detector heads located throughout the Containment Building including 6 heads in ventilation ducting.
Any fire would be quickly detected and cause an alarm in the Control Room.
-4.
Due to the small size of the plant, fire brigade response to a fire in containment would be very rapid.
In addition to portable fire extinguishers, four non-collapsing lb" fire hoses on FM approved FD47 reels are located at various levels of the Containment Building.
This arrangement allows quick acting service without unreeling the entire hose.
5.
Plant operators routinely make shift tours of'the Containment Building and inspect the building for abnormal conditions.
6.
In spite of the postulated clogging of floor drains, we believe this system would remain effective during an oil leak.
[
Especially in view of the small amount of oil involved, we l
believe that'a great part of any oil leakage would be collected l
-by the present. drain system.
L For the reasons listed above, DPC believes that the use of a non-flammable fluid-in the Coupling Oil System will provide an adequate degree'of fire protection in the Containment Building and also reduce radiation exposure.
Therefore, DPC requests an exemption from the recuirements of Section III.0 of Appendix R to 10 CFR 50,
" Oil Collection System for Reactor Coolant Pump".
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ENCLOSURE 1 UNRESOLVED ITEM:
SER 3.1.E REAT DETECTOR CIRCUIT SUPERVISION DPC RESPONSE:
Paragraph 3.1.5 of Reference 14, the LACEWR Fire Protection Safety Evaluation Report, stated:
The circuits of heat detectors chich actuate the carbcn dioxide suppression system protecting the "B" diesel-generator room vitt be electrically supervised for power failure, ground fautes or circuit breaks to alarm and annunciate in the control room these abnormal conditions.
In Reference 11, DPC submitted a proposal to install a meter relay at the "end of line" thermal switch "C" to monitor the voltace along the detector string for short circuit, open circuit, and grounds.
The NRC responded to DPC's proposal in Reference 9 by stating:
We:vitt require the licensee to provide a supervisory device listed by UL or FM for the intended purpose.
DPC replied in' Reference 6 that it was working on an alternative design using-FM or UL approved ecuipment.
Subsecuently, in Reference 5, the NRC reiterated its previous position with the following staterent:
The ' ticeneee 's propocal to instatt an "end-of-line" meter relay'is not acceptable.
The description of operation indicates that the proposed meter relay vill not perform att of the required functions; i.e.,
a ground fault con-dition on the neutral pocer teg vitt not be annunciated.
To meet the-reccmmendation of NFPA 72D, the licensee should instatt a UL or FM listed device to perform the required supervisory functions, uith supervisory alarms in the controt'rocm.
DFC has determined that in order to provide a UL or FM listed supervisory device, the. existing control circuits for the IB Diesel
. Generator Room CO2 system would have to be replaced resulting in
'significant' expense and rewiring work.
Fe do not believe that there is justification for such a modification and arc' submitting the followi ng ' additional information: _
m ENCLOSURF 1 1.
The neutral leg in our Heat Detector Circuit is not an elevated ground as was apparently assumed by the NRC's consultant in Enclosure 2 to Reference 9.
The neutral leg in our Heat Detector Circuit is normally grounded and therefore there is no need to detect a ground on the neutral leg.
2.
In the event that the 1B Diesel Generator CO2 System Heat Detector Circuit failed, the 1B Diesel Generator Room is covered by an approved, ionization chamber type, products of combustion, smoke and fire detector head in the 1B Diesel Generator Room which alarms in the Control Room.
3.
The 1B Diesel Generator Room is a fire zone within Fire Area No. 7 which includes the entire 1B Diesel Generator Building.
The 1B Diesel Generator Room is separated frcm the Turbine Buildine by a 24-inch cr more reinforced concrete wall.
The IB Diesel Generator Room is. separated from other fire zones in the IB Diesel Generator Building by a 12-inch masonry wall and Class A, 3-hour fire doors.
Cable penetrations to adjacent
- .r e zones are protected by approved cable penetration seals with a 3-hour-rating.
4.
The 300 gallon diesel daytank, which is by far the largest fire load in the 1B Diesel Generator Building, has been provided with a curb capable of containing the entire centent of the tank plus an additional 10a. for fire fighting water.
The curbing insures that no large quantity of oil would spill onto the floor or possibly into adjacent fire zones.
The curbing is designed based on the assurption that the floor drain under the day tank is plugged, but we believe it is highly likely that any oil spilled from the tank would go into the drain.
'5.
A' lined, l inch FM approved fire hose station is located within a few feet of the double door to the IB Diesel Generator Room.
Adequate portable fire fighting equipment is_ located within the 1B Diesel Generator Building and in nearby fire areas.
6.
Due to the small size of the plant, Fire Brigade response time to a fire'in the 1B Diesel Generator' Room is very short. _
ENCLOSURE 1 7.
In addition to automatic actuation of the 1B Diesel Generator CO2 System by heat detectors, the selected bank of CO2 bottles can be manually discharged by use of an electric switch near the 1B Diesel Generator Room doors and either the Main or Reserve bank of CO2 bottles can be manually discharged by strictly mechanical means using pneumatic actuators located near the 1B Diesel Generator Room doors.
Due to the features described above, we believe adecuate fire pro-tection exists in the 1B Diesel Generator Room and that the DPC proposal to install a meter relay at the "end-of-line" thermal switch "C" to monitor the voltage along the detector string for electrical faults will provide additional assurance that the Heat Detector Circuit is functioning properly.
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<A ENCLOSURF 1 UNRESOLVED ITEM:
SER 3.1.20 UNRATED BARRIER "To comply vith the requirements of Section III.G of Appendi: R to 10-CFR 50,'the licensee should upgrade the fire resistance of the (1A Diesel Generator Room) call to a 3-hour rating, based on the
- estimated fire resistance ~ rating of 1.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> for the cristing va Z l. "
'DPC RESPONSE:
The following information was submitted in Enclosure 1 to Reference ll:
CALCULATION:
The wall consists of concrete block 15" long x 7 " high x 6" thick.
The blcck dimensions are combined with an estimate of 58% solids provided by the American Insurance Association to util-ize the " equivalent-thickness" formula:
)
s lid volure
' TC=
. length x height j
The equivalent thickness of this block is-3.48 inches and yields a 2.3-hour
-l fire rating per Table 2 of~" Factory Mutual System 1-21 Fire Resistance of 1
Building Asserbly".
Although not stated in the previous submittal, the concrete block is
- composed of. expanded slag and therefore the calculation above is
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correr:t.
- The fire hazards associated with the 1A Diesel Generator Room have been re-evalaated and lead us to conclude that present reasures are adequate due to the following-fire protecticn features:
1.
As described.above, the 1A Diesel Room wall has a fire rating
-of 2.3-hours.
~2.
The lA Diesel Room has 3-hour rated fire doors.
3.
'There is an. ionization chamber. type, products of combustion, smoke and fire' detector located in the lA' Diesel Room which alarmst in-the Control Room.
'4.
'Due to.the small size'of'the plant, the fire brigade would reach the 1A riesel Room almost immediately.
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ENCLOSURF 1 5.
The lA Diesel Room is equipped with a manually actuated sprinkler system which would quickly extinguish a fire in the event portable fire fighting equipment were inadequate.
6.
Oil transfer to-the 100-gallon lA Diesel Day Tank can be shut off-from outside the room.
Oil cannot be transferred unless the diesel is in operation.
7.
An oil curb has been installed which is capable of containing all the oil in the room plus 102 for fire fighting water in case the floor drain is plugged.
This ensures oil will not flow into the machine shop.
8.
Structural steel over the machine shop has been upgraded to a 4-hour rating.
9.
The short runs (2 to 3 feet) of safety-related cables through the machine shop receive protection.from concrete and metal enclosures and also'from fireproof insulating material in the enclosures.
In Reference 18, " Fire Hazards Analysis of the La Crosse Boiling Water. Reactor", the 1A Diesel Room was designated as a fire zone within fire area number 5, which also included the machine shop,
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the machine shop office, and the electrical shop.
As shown in Figure 5-2 and the DPC RESPONSE to NRC Question 5 in Enclosure 1 to Reference 17, with the subsequent' upgrading.of the fire rating of structural steel over the machine shop, the fire rating-of all barriers between fire area number 5 and adjacent safety-related fire-areas is at least 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.
Branch Technical position APCSB 9.5-1 includes the following definitions:
Fire Area - That portion of a building'or plant that is separated from other areas by boundary.
Fire Barriers (walls, floors, or roofs) with any openings or-penetrations protected with seals or closures having a fire resistance rating equal to that of the barrier.
Fire Zones - Subdivisions of fire areas in which.the fire-suppression systems'are designed to combat particular types of fires.
The concept of fire zone aids in defi.".ing-to the fire fighter the fire parameters and the actions which would be n necessary.
ENCLOSURE 1 Based on these definitions and the fact that the lA Diesel Room is designated as a fire zone within fire area number 5, there is no inherent requirement for a 3-hour wall between the lA Diesel Room and the Machine Shop.
In fact, Reference 14, the LACBWR Fire Protection SER, Section 3.1.20 states, "The licensea will upgrade the unrated barrier between the "A" Diesel Room and the machine shop to provide the fire resistance commensurate with hazards on both sides of the barrier".
The 100 gallons of diesel fuel in the day tank in the lA Diesel Room is by far the greatest potential fire hazard on either side of the barrier and it is LACBW"'c position that any fire in the lA Diesel Room would be out..
- in 15 minutes, well within the 2.3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rating of the wall. 1
ENCLOSURE 1 UNRESOLVED ITFM-SER 3.1.22(2)
PRO 1 ECTION FOR THE ELECTRICAL EQUIPMENT AND THE CONTROL ROOMS The licensec should provide fire protection nodifications in accordance eith Section III.G of Appendi: R to 10 CFR 50.
(Previde an cutcnctic cuppression cystem for the Electricci Ecuipment Room.)
DPC RESPONSE:
Preliminary design drawings and documentation for a HALON syster to be installed in the electrical equipment room were submitted by Reference 6.
Mechanical installation of the HALON system was completed during the recent refueling outage and the electrical installation is in progress.
As-built drawings and docurentation will be submitted when available.
The system will be operable within the deadline established by paragraph (c) (3) of 10 CFR 50.48.
On February 13, 1981, in Reference 2, the NRC recommended that LACEFP commit to the following rodifications of the HALON system:
(1)
A backup, a single reserve supply of Halon of similar size to the primary cylinder should be provided.
(2)
If the abort switch is to be provided, it should be removed from the proposed system; (3)
All accessible openings within the room crea should be provided with automatic closing mechanisas which operate on system actuation.
All such openings should be fully weatherstripped to assist in achieving the required SS concentration; and (4)
Details of the installation should conform with the recctmendations of FM Data Sheet 4-8N, and all applic-able equipment used should be FM approved.
DPC takes the fcllr; wing positions on the four recommendations listed above:
(1)
Fe plan to verify arrangements discussed with the contrector installing the HALON system to provide for promptly refil'-
ing the HALON cylinder within 24 to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after a system discharge.
Until restoration of system operability, appropriate corpensatory measures would be implemented such as increasir.g the frequency of tours of the Electrical Equiprent Room.
It should be noted that no fire has occurred in the Electrical Equipment Roon over a period of 14 years of plant operation.
We therefore believe this is justification for allouing the system to be inoperable for a shor period until the HALON bottle can be refilled after a system discharge.
ZNCLOSURE 1 4
(2)
DPC plans to include an abort switch in the HALON system due to the fact that the Electrical Equipment I-Room is occasionally occupied and is located near a frequently occupied area.
In the event of a HALON i
system malfunction or a very small fire easily con-trolled by other means, we believe that plant personnel should be provided the option of aborting a discharge of the HALON system which would force personnel to evacuate'the Electrical Equipment Room.
t The Abort Switch is a spring-return push-tutton which must be held depressed by a person in the 11ectrical Equipment Room.
Releasing the Abort Switch will return the system to autcmatic operation.
Therefore, the system cannot be inadvertently left in an aborted condition and inclusion of the Abort Switch does not reduce the reliability of the HALON system.
(3)
The HALON system is.being electrically interlocked with the ventilation sys tem -in the Electrical Equipment
-Room to secure ventilation when the HALON system is electrically actuated.
Small openings to other areas along windows and structural members at the outer wall cf the building will be sealed to prevent HALON leakage
' on the Electrical Equipment Room.
The door to the ectrical Equipment Room from the Office Building c rridor is self-closing and is a security door which is continuously monitored by the security system computer i
and is equipped with security card readers tc control entry _and exit from the~ Electrical Equipment Rocm.
The double doors between the Electrical Equipment Rcom and-
-the Turbine Building are self-clesing and are r.larmed as fire doors.- In addition,. thera are two access doors from
-the Electrical Equipment Room to the. Control Room Bench-board.
These access doors are used for maintenance and are generally not opened during plant operation.
The access doors to the Control Room Benchboard have been alarmed to-give a HALON system Trouble Alarm when either door is not fully closed.
This will give a visual and audible alarm to insure the doors are not inadvertently lef t open after maintenance.
c (4)
The HALON system equipment was provided and installed prim-
-arily by a reput.able fire protection company in accordance j
with NFPA requirements.
DPC will obtain a copy of FM Data Sheet 4-8N and verify that the system has been properly installed.
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4 ENCLOSURE 1 i
t UNRESOLVED ITEM:
SER 3.1.29(3)
SIGNALING SYSTEMS DPC RESPONSE:
We installed 24-hour timers on bypass switches in the detection system zone circuits in order to satisfy the following requirereau included in Reference 14, the LACBWR Fire Protection Safety Eval-uation Report:
S3. t em (4. 2)
- 3.1.29** Signaling 4
(3)
Install a timer for each detector zone to provide a warning when a detector zone has been bypassed for a certain period of time.
Subsequently, the NRC-specified a maximum timer setting of two hours in the following section of Enclosure 2 of Reference 9:
?3.1.29 Signaling System i
We will require the licensee to:
2.
Verify that the maximum timer setting possible does not exceed two hours.
J DPC then modified the 24-hour bypass timers by adding mechanical-stops to satisfy the';equirenents quoted above from Reference 9.
i f
The NRC then recommended in Enclosure 2 to Reference 5 that tha timer-bypass switches should be reroved.
Subsequently, in_Peference 2, the NRC stated the following:
l'
" Based on our revice, ce conclude'that timera chich permit a detector zone to be incperable for as long ae 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> j
are not accepcubse.
'To'he in accordance with our Standard l
Technical Specificationo for detectors, the maximum time a, j
detectors zone may be bypasced should be limited to one I
hcur."
The mechanical limit stops in the detector zone bynts, timers have l
been set at approximately 1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> which is the minimum te which the stops can be installed.
We believe that this arrangement is accept-able since the detector zone bypass switches are located in the
_ Control Room under the supervision-of an operator who has much more direct ~ control over the positioning of detector zone bypass switches than he has -over. other plant conditions requiring an hmirly fire l
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ENCLOSURE 1 watch patrol under Technical Specifications, such as inoperability of an automatic fire suppression system or maintenance resulting in breaching a fire barrier.
These requirements are satisfied through administrative controls and training of plant personnel.
We therefore believe that a similar upproach will ensure that Technical Specification requirements will be satisfied for inoperable detector zones and that the detector zone bypass timers with a max-imum setting of 1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> will act as an additional aid to operators.
i l
l ENCLOSURE 1 UNRESOLVED ITEM:
SER 3.1.27,
- 3. 2. 2, 3.2.3,
- 3. 2. 8 COMBINED WATER SYSTEM To meat the requirements of Section III.A of Appendi: R to 10 CFR 50 and provide sufficient vater for the fire suppression and safety systems simultaneoucig, the licenacc should install an additional fire pwrp of cufficient capacity to provide the required fire cater supply concurrent with any safety cysten water demand.
DPC RESPONSE:
LACBWR presently has two diesel fire pumps located in the Crib House.
In addition, LACBWR has recently implemented plant modifications to provide another source of water from a new Emergency Service Fater Supply System.
The ESWSS System includes up to four portable pumps which can be placed in operation to supply water to Alternate Ct e Spray and fire suppression systems in less than 28 minutes based on ECCS requirements in the unlikely event that the Crib House is icst due to a seismic event or due to a fire.
The new system provides adequate water' supplies for both fire suppression systems and safety systems in the event the Crib House is lost, as described in Reference 8.
As shown in Attachment A, the ESWSS provides sectionalizing capability by allowing the yard loop to'be isolated in the event of a pipe rupture in the underground fire water system loop or in the Crib House.
With the yard loop isolated, ESWSS can supply fire suppression systems and High Pressure Service Water in the plant and can also directly provide water for exterior fire hoses.
The pumps can be set up away from the Crib lause in the event of a fire in the Crib House and prtvide capability at least equivalent to a separate con-nection to the underground fire water system loop.
As stated in Section 3.2.11 of Reference 18, the~ Crib House is noncombustible with a concrete on steel roof and masonry walls and is separated frcm all other areas by detachment.
Reference 6 demonstrated that with the ESWSS system, the plant can be safely shut down in the event the Crib House is lost.
The ESWSS can be placed in operation in less
-than 28' minutes to fight a postulated fire in the Crib House, and due to separation from the Crib House,-no postulated fire in the Crib House would spread to other fire areas.
Therefore, the ESWSS provides thecapability to sectionalize fire water systems and to fight a postulated Crib House fire while supplying-HPSW to the plant.
In addition to the ESWSS system already implemented, DPC plans to j
upgrade the existing. Diesel Fire Pumps by~the addition of a sixth j
impellor stage to each pump.
This modification will substantially 1pgrade the capacity of. these pumps at the required pressures while reraining well within the rated capacity of the diesel engines and will iLJure that a single Diesel Fire Pump can meet'any F
. l t
~n.--.----u--,.,.----.--.-.-.-._-
EMCLOSURE 1 demand from : fire suppression sys ems-and plant safety systems in the
[
event of a postulated. fire-in any area other than the Crib House.
J.
i Section 3.2.11 of~ Reference 18, the LACBWR Fire Hazards Analysis, states, "There is only the diesel oil in the pipes to the diesel; pumps in the area (Crib House)*.
The fuel oil is stored in outside tanks."
The analysis goes on to say, "The only fire that might start in the area would be a small fuel oil fire from one of the diesel engines.
The fire would not be expected to spread from the engire involved."
In the event of such a fire, approved, ionization chamber type, products of combustion, smoke and fire detectors over the diesel would cause the Fire Detection System to alarm in the Control Room.
Due to the small size of the site, Fire Brigade response time is very short and fire fighting equipment including an exterior hose house and a fire hydrant in the immediate vicinity of the Crib House are readily accessible.
Thus, it is considered highly unlikely that any fire in the Crib House would incapacitate both Diesel Fire Pumps.
It is DPC's position that existing fire suppression water supplies with modifications described above combined with the ESWSS system meet the intent of Section III.A of Appendix R.
Therefore, DPC requests that the La Crosse Boiling Water Reactor-be exempted by the Commission from the specific requirements of Section III.A of Appendix R.
t
)
t Ui f
i i
- Approximately 7 feet of 3/8" and. 3/4" diameter fuel lines in. Crib House for each diesel and approximately
.2 gallons of fuel oil assoc-iated with each diesel.
i ENCLOSURE 1 UNRESOLVED ITEM:
SER 3.2.1 S A FE SHUTDOWN A NA LYSIS To meet Section III, Paragraph G of Appendim R to 10 CFR 50, the licensee should provide an alternate shutdown capability for the following areas of the plant:
1.
Electrical Equipment Roon and Control Room.
2.
Crib House; and 3.
Electrical Penetration Room The alternate shutdoun system should meet the requirements of Section L, Paragraph III of proposed Appendim R to 10.CFR 50.
DPL RESPONSE:
Reference 12 forwarc'ed NES Report 81A0037, Rev.
1,
" Analysis of the Ability of LACBWR to Achieve Cold Shutd.wn in the Event of a Fire".
A " mini-review" of LACBWR's Safe Shutdown Analysis was performed by the NRC's consultant and the resulting comments were forwarded to DPC by Reference 7.
As a result of these comments and a rabsequent re-evaluation of the requirements "? Paragraph III.L of AJpendix R to 10 CFR 50, we conclude that with the recently installei Emergency Service Water Supply System, certain plant modifications to protect a small number of cables from hot shorts including additional pro-tection for cabling to the Manual Depressurization Valves will be necessary to provide Alternate Shutdown Japability satisfying Paragraph III.L of Appendix R to 10 CFR 50 and the plant specific requirements of Item 3.2.1 of Enclosure 2 of Reference 5.
Install-ation of an Alternate Shutdown Panel will not be necessary in order to meet the requirement for Alternate Shutdown Capability to achieve
[
and maintain hot sh tdown for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
In addition, further review of Alternate Shutdown Capability leib us to conclude that LACBFR can achieve cold shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> without the use of any electrical 0
equipment by cooling down to a temperature of 270 F. to 300 F. using the Shutdown Condenser System and completing the cooldown and maintain-ing the plant in_ cold shutdown through a feed and bleed process at approximately 15 to 25 gallons per minute.
Water could be fed into the reactor vessel from the Mississippi River using the diesel-driven Alternate Core Spray pumps with the gasoline powered Emergency Service i
Water Supply System pumps as a backup, or water could be fed into the j
reactor vessel from the Overhead Storage Tank through the Low Pressure Core Spray Valve.
Water would be bled from the Reactor Vessel using gravity head to the Main Condenser using the Decay Heat Blowdown Valve.
Plant modifications necessary to insure Alternate Shutdown Capability will be implemented within the schedule establish d by Paragraph (c) (4) of 10 CFR 50.48.
I ENCLOSURE 1 LACBWR har, a highly reliable alternate capability for safely shutting down the reactor, maintaining hot shutdown, and quickly cooling down the reactor at a controlled rate.
Il the event that a fire in the Control Room, Electrical Equipment Room or Electrical Penetration Area carmed a less of reactor control from the Control Room, the operators at LACBWR ere trained to per-form the necessary control functions manually.
Volume I of the LACBWR Operating Manual presently contains two procedures, Emergency
.teactor Shutdown and Cooldown When the Control Room is Inaccessible and Complete Loss of Electrical Power, which provide the directions for maintaining the plant in a safe condition.
Additional procedural guidance will be provided for controlling the plant in the event loss of reactor control from the Control Room is caused by a fire.
The specific operator actions required in the event one or more of these vital areas is lost will depend on what actions can be taken prior to evacua': ion of the Control Room or loss of control functions resulting from a massive cable failure.
In the event of a serious fire in the Cor. trol Room requiring plant shutdown, licensed operators would make every_ effort to scram the reactor manually, if the reactor had not already scrammed automatically, and operators would verify insertion of control rods prior to evacuation of the Control Room.
It is difficult to imagine a fire so catastrophic that the plant could not be shut down prior to evacuation of the Control Room.
Assuming the worst case where the plant cannot be scraemed before leaving the Control Room, two operators will enter the Containment Building and manually scram the reactor.
The neutron level will be monitored with a portable instrument stored in the Containment Build-ing to verify reactor shutdown in accordance with the procedure for Emergency Reactor Shutdown and Cooldown When the Control Rocm is Inaccessible.*
One operator will control reactor pressure (and also cooldown rate) by manually throttli:p the~ steam inlet valves to the Shutdown Condenser af ter locally failing the steam inlet control valves on the Shutdown Condenser.
This is accomplished at the Shut-down. Condenser Platform by valving out the air supply and venting the air regulator.- Reactor pressure will be monitored at the Reactor Heise Gage located on the mezzanine level of the Containment Building.
Reactor cooldown rate will be monitored and recorded based on reactor pressure and the steam tables.
Radio communication will be established with the second operator stationed at the Decay Heat Blowdown Valve and the nearby reactor water level gage which is conpletely mechanical and not affected by any electrical fault.
The second operator will The manually fail open the Shutdown Condenser Condensate Valves.
combined actions of these operators will provide manual con 2rol of reactor water level, temperature and pressure within acceptable limits.
- This neutron detector is routinely calibrated. - - - -
ENCLOSURE 1 If 480V A.C. power is not interrupted, numerous methods are avail-able to provide makeup water as necessary to the reactor or shut-down condenser.
Manual control of pump breakers outside the affected fire area for Demineralized Water Pumps, High Pressure Core Spray Pumps, and the Decay Heat Pump would be utilized.
- However, a loss of all A.C. power as a result of the postulated fire would require use of one of two diesel driven High Pressure Service Water Pumps located in the Crib House that draw their suction from the Mississippi River.
These pumps would start automatically on loss of header pressure due to loss of power to the electric HPSW pump and provide makeup cooling water to the Shutdown Condenser.
The reactor would not require makeup since the closed cooling loop utilizing the Shutdown Condenser would not cause a loss of inventory.
The total shrink of primary coolant during plant cooldown from operating temperature to cold shutdown lowers reactor vessel water level by less than 9 inches.
The procedure detailing the safe shutdown from outside the Control Room have been part of the Operating Manual since 1975.
These procedores will be modified to emphasize operator action to overcome potential electrical faults as a result of a fire which may hamper the safe shutdown and cooldown of the reactor.
Of particular concern is the potential for opening of Manual Depressur-ization System valves due to a hot short, while the Shutdown Condenser is in operation.
Opening of MDS valves due to a hot short can be prevented by manually shutting these valves at the Shutdown Condenser platform in the early phase of establishing plant control from within the Containment Building.
If the MDS valves opcn electrically due to a hot short prior to being manually shut, they can be isolated by electrically shutting the Shutdown Condenser S+.eam Inlet and Condensate Valves from the Control Room if this capability still exists and an operator has not yet been stationed j
at the Shutdown Condenser or by manually shutting the Shutdown l
Condenser Steam Talet Valves if an operator has already been stationed at the Shutdown Condenser Steam Inlet Valves.
When the Shutdown Condenser has been isolated, the MDS valves can be manually closed and the Shutdown condenser can be manually returned to oper-ation to continue a controlled plant cooldown.
Due to the unlikely possibility that a hot short in cables to the MDS valves could i
hamper safe shutdown, DPC proposes to implement moaifications to l
eliminate the possibility of hot shorts in the MDS cabling.
In August 1974 an instrument bus fault occurred which caused a loss of instrumentation in the Control Roon.
This essentially rendered the Control Room inoperable.
Incident Report DPC-74-20 documents the actions taken by the operators.
The reactor was operating at 96% power when the fault caused the scram.
Two operators entered the containment building and controlled the reactor cooldown.
One [
ENCLOSURE 1 s
operator manned the steam inlet valve to the Shutdown Condenser and the second operator immediately manned the Decay Heat Blow-down valve since the HPCS pumps were available to provide makeup.
This method of operation was relied on for a period of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 15 minutes when the instrument bus was restored.
Water level and pressure were monitored with direct readout non-electrical equipment.
In the event of a postulated fire in the Crib House which resulted in the loss of LPSW and HPSW, the plant could be shut down from the Control Room and maintained in hot shutdown by use of the Shutdown Condenser.
Makeup water for the shell side of the Shutdown Condenser could be provided by the Demineralized Water System.
In addition, the recently installed Emergency Service Water Supply Fystem could be.used to provide HPSW and cooling water to the shell side of the Component Cooling Water coolers in the event the Crib House is lost.
This would allow use of the Decay Heat System to attain cold shutdcwn as is done in a routine plant cooldown.
Therefore, the plant could be maintained in hot shutdown for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and brought to a cold shutdown condition within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, satisfying the require-ments of Paragraph III.L of Appendix R to 10 CFR 50.
- - i
ENCLOSURE 1 UNRESOLVED ITEM:
SER 3.2.4 EXPOSED STRUCTURAL STEEL IN TURBINE BUILDING To nect the requirements of Section III.G of the proposed Appendim R to 10 CPR 50, the licensee should provide 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> fire rated protection for the structural steel in the Turbine Building.
DPC RESPONSE:
DPC has re-evaluated the vulnerability of structural steel in the Turbine Building to damage from a fire.
The majority of the major structural steel in the Turbine Building obtains its vertical support by its attachment to the Turbine Building's reinforced concrete vertical columns.
These concrete columns along the reinforced concrete walls extend to the Turbine floor or higher and are not susceptible to fire damage.
Additional vertical support is provided by massive reinforced concrete pillars which form the Turbine Pedestals.
DPC believes it is highly unlikely that any postulated uncontrolled fire in the Turbine would cause structural damage leading to failure of a fire barrier between the Turbine Building and any adjoining safety-related fire area.
In order to upgrade the fire resistance of structural steel, DPC will provide a fire resistance rating of at least two hours to an exposured vertical steel column located near the Turbine lube oil tank whose function may be compromised in the event a postulated turbine oil line were to burn for an extended period coincident with the complete failure of all fire protection features in this area.
We believe that even in the event of complete failure of all fire protection features in the Turbine Building, no appreciaDle structural damage of safety significance could occur other than to the column which will be upgraded.
DPC also believes that it is not credible that an uncontrolled fire large enough to cause any structural damage would occur, due to the following:
1.
The small size of the plant would quickly make the existence of a large fire in the Turbine Building directly apparent to plant personnel, and would allow very rapid response by the Fire Brigade.
2.
The fire detection system, which alarms in the Control Room, would alert plant operators in the event of small fire or smoldering.
3.
Passive features such as the drain system and curbing around the Turbine Oil Tank would gre -ly limit the extent of a fire.
One-hour fire walls near the Turbine Oil System would also greatly reduce the effect of a Turbine Oil fire on plant equipment. 1
E!! CLOSURE 1 4.
An extensive autcratic sprinkler system of the Turbine Oil grineOilpipingwouldactuatewhenfusiblelinks Tank and S.
We find it inconceivable that with the celted at sprinkler system operable, structural steel could be heated to the point of failure prior to the melting of fusible links.
5.
Extensive manual fire fighting capability serves as a backup to autcmatic suppression.
Manual features include portable fire fighting equipment, five fire hose stations in the Turbine Building, and fire hydrants and exterior hose houses located outside the Turbine Building.
DPC will imple. ment the modifications described above within the deadline established by Paragraph (c) (3) of 10 CFR 50.48. 1
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