ML19345D496
| ML19345D496 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 12/11/1980 |
| From: | Baynard P FLORIDA POWER CORP. |
| To: | Reid R Office of Nuclear Reactor Regulation |
| References | |
| 3-120-22, NUDOCS 8012150238 | |
| Download: ML19345D496 (6) | |
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Decc.nber 11, 1980 File:
3-F-2 3-120-22 Mr. Robert W. Reid Chief Operating Reactors Branch #4 U.S. Nuclear Regulatory Comission Washington, D.C. 20555 4
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Subject:
Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 NRC Letter dated October 14, 1980 FIRE PROTECTION PROGRAM K)DIFICATIONS
Dear Mr. Reid:
Enclosed is our response to the unresolved items of the SER identified in the Enclosure 1 of the subject letter.
Should you require any additional information, please contact this office.
Very truly yours, l
FLORIDA POWER CORPORATION
. Y. Baynard i
Manager l
Nuclear Support Services i
Lobo (Response)DN63-2 Enclosure t
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General Office 320i Twy.tourtn street soutn. p o so seo42. st Petersburg Ficrda 33733 813-866 5151 l
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STATE OF FLORIDA COUNTY OF PINELLAS P. Y. Baynard states that she is the Manager, Nuclear Support Services Department of Florida Power Corporation; that she is authorized on the part of said company to sign and file with the Nuclear Regulatory Com-mission the information attached hereto; and that all such statements made and matters set forth therein are true and correct to the best of I
her knowledge, information and belief.
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0 UP. f. Baynard Subscribed and sworn to before me, a Notary Public in and for the State and County above named, this lith day of December,1980.
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Notary Public g
Notary Public, State of Florida at Large, My Commission Expires: June 8, 1984 PYB/MAHNotary(DN-98)
4 FPC RESPONSE TO NRC STAFF POSITION ON FIRE PROTECTION (Enclosure 1, NRC letter dated October 14,1980)
NRC STAFF POSITION Fire Detection Signaling System, Section 3.2 In our Fire Protection Safety Evaluation Report of July 27, 1979, we were concerned that emergency power was rot supplied to those portions of the detection and signaling system serving areas containing safety-related equipment.
By letter dated December 6,1979, the licensee provided additional in-formation on emergency power to the fire detection system.
We have reviewed the information and conclude that the information is not acceptable because it does not meet our Branch Technical Position (BTP) 9.5-1.
To meet the guidelines of section E(1) of Appendix A to BTP-APCSB 9.5-1 the licensee should provide emergency power by:
1.
Using normal off-site power as the primary supply with a four-hour battery supply as secondary supply; and 2.
Providing capability for manual connection to the Class IE emer-gency power bus within four hours of loss of off-site power.
Such connection should follow the applicable guidelines in Regu-latory Guides 1.6
" Independence Between Redundant Standby (On-site) Power Sources and Between Their Distribution Systems",
1.32 " Criteria for Safety-Related Electric Power Systems for Nuclear Power Plants", and 1.75 " Physical Independence of Elec-trical Systems."
FPC RESPONSE I
Item 1 l
On December 6,1979, we provided additional information to you on our proposed design which would insure emergency power to those portions l
of the fire detection system protecting safety-related areas.
Draw-ing EC-220-224 of our December 6, 1979, submittal shows the Cardox, Cable Spreading Room fans, Halon and plant products of combustion con-trol cabinet powered from Lighting Panel CC-5, CC-1 and CC-6.
Light-l ing Panels CC-5 and CC-1 receive power from Engineered Safeguard (ES) i Motor Control Center (MCC) 3A1.
Lighting Panel CC-6 receives power from ES MCC 3Bl.
The primary source of power for these two MCC's is from the off-site circuit through the Unit 3 startup transformer.
Upon loss of off-site power, our two 3000 KW emergency diesel genera-tors (secondary source) provide power to the ES MCC's and Lighting t
Panels CC-5, CC-1 and CC-6; consequently, we believe we have met or exceeded the requirements of Section E (1) of Appendix A to BTP-APCSB 9.5-1.
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Item 2 CR-3 is comitted to Appendix A of BTP-APCSB 9.5-1 and Fire Detection Systems receive power from the emergency diesel generators upon loss of off-site power.
Therefore, this item does not apply.
NRC STAFF POSITION Steam Driven Emergency Feedwater Pump, Section 3.18 In the Fire Protection SER, the concern was that fire in the area would damage redundant saftey-related equipment and cables.
By letter dated Deember 6,1979, the licensee proposed to provide fire detection and a one-hour rated fire barrier around safety-related cables and motor-operated valves.
We have determined that the proposed fire rated barrier is not accept-able.
No fire barrier has been provided for the motor-operated val-ves.
The barrier provided for the cable trays does not provide ade-quate assurance for the integrity of the circuits for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
To meet the requirements of Section III.G. of proposed Appendix R to 10 CFR Part 50, the licensee should provide a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> rated barrier for the safety-related cables and motor-operated valves for the steam-driven emergency feedwater pump area.
The barrier should be tested against an ASTME-119 fire and should protect the motor and circuit in-tegrity-equipment of that system for one hour under the preceding fire conditions.
FPC RESPONSE In our Fire Protection SER, Section 5.8 describes Elevation 95' of the Intermediate Building.
Section 5.8.2 states only a small amount of combustibles are available and only cable trays from Channel A are located in the area. Section 5.8.5 states that with prompt detection, manual suppression would be adequate to suppress the fire.
Section 5.8.6 states that the fire barriers and detection will be pro-vided in the area. There are no cable trays leading from the Turbine-Driven Emergency Feedwater Pump to the Motor-Driven Emergency Feed-water Pump, the circuits are encased in conduit and further, we pro-posed to install fire barriers to keep an exposure fire from impinging directly on the conduit.
We were intending to build a UL approved i
l one-hour fire barrier between certain motor-operated valves per our l
comitment.
This information was inadvertently left out of our sub-mittal of December 6,1979.
We will provide design drawings within thirty (30) days of your approval.
This meets the intent of Appen-dix R to 10 CFR 50 paragraph III.G.
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NRC STAFF POSITION Evaluation and Corrective Action for Fire Consequences in Certain Areas, Section 3.25, 3.27, 3.28, 3.29, 3.30 and 3.31.
In the Fire Protection Safety Evaluation Report, we were concerned that a fire could damage redundant safety-related equipment and cables necessary to achieve safe shutdown.
By letter dated December 6,1979, the licensee provided additional in-l formation on the electrical circuits and the effects of their loss upon safe shutdown due to an unsuppressed fire. The licensee proposed I
to install a wet pipe fusible link sprinkler system in the following areas:
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1.
Auxiliary Building, Elevation 95, Fire Zones 1, 5 and 16.
2.
Auxiliary Building, Elevation 119, Fire Zones 1 West End, 7 and 18.
The licensee also proposed to install barriers in the makeup pump rocms, and the wet pipe fusible link water spray system in the Inter-mediate Building at Elevation 119', to protect the cable trays above the personnel airlock shield structure.
Based on our review, we conclude that the proposed modifications are not adequate to provide an acceptable level of fire protection because damage to redundant safety-related equipment and cables may result due to thermal lag of the sprinkler system.
The licensee has not demonstrated that adequate protection features have been provided for cables and equipment of redundant systems important to achieving safe shutdown conditions to ensure that at least one means of achieving such conditions survives postulated fires.
To meet our fire protection guidelines, alternate shutdown capability should be provided when safe shutdown cannot be ensi,' red by barriers and detection and suppression systems because of the exposure of re-dundant safe shutdown equipment, cabling, or components in a single fire area, to an exposure fire, or fire suppression activities,. or rupture or inadequate operation of fire suppression systems.
To meet Section III, Paragraph G of the proposed Appendix R to 10 CFR ' -t 50, the licensee should provide an alternate shutdown capabil andependent of these areas.
The alternate shutdown system should.
the requirements of Paragraph L,Section III of proposed Appendix R to 10 CFR Part 50.
FPC RESPONSE In our December 6,1979 submittal, we committed to add sprinkler pro-tection to Fire Zones 1, 5 and 16 of the Auxiliary Building EL 95' and Fire Zone 1 West End, 7 and 18 Auxiliary Building EL 119'.
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i The Drawing SK 70906, also submitted on December 6,1979, per Sect-ion 3.15, shows fire detectors to be located in all areas where we committed to sprinklers to ensure prompt alarming in the early stages of an exposure fire.
In order to completely meet Section III G.2.c of Appendix R to 10 CFR Part 50, we are investigating whether to enclose 4
one (1) redundant cable train with an approved one hour fire barrier or to reroute one (1) redundant cable train.
We are also investiga-ting rerouting of necessary safe shutdown and associated circuits out of the fire areas identified per Section 3.25, 3.27 through 3.31 of our SER to meet Section III G.2 a.
or b.
The results of these investigations will be completed by March 1,1981.
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-W Lobo (Response)DN63-2
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