ML20005C121
| ML20005C121 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 11/06/1981 |
| From: | Lundvall A BALTIMORE GAS & ELECTRIC CO. |
| To: | Clark R Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8111180422 | |
| Download: ML20005C121 (30) | |
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?iovember 6,'loil:.M.
ARTH U R E. LU N DVA LL..J R.
WCE PRESCENT
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of ?'uclear Peactor Pegulation U. S. ?Iuclear Fegulatory Com ission k'ashincton, D. C.
20555 Attn:
"r. Robert A. Clark, Chief Operating Peactors Branch #3 Division of Onerating Reactors
Subject:
Calvert Cliffs ?!uclear Power Plant Units ??os.1 & 2; Dockets ?ios. 50-317 & 50-318 Fire Protection Safety Evaluation Report and Anend ents to Facility Oneratine License
Reference:
(a) BG&E letter fron C. H. Poindexter to D. G. Eisenhut dated Sentenber 30, 1031.
Gentlenen:
Please find enclosed forty conies of revised nares of our resnonses to the Fire Protection Safety Evaluation Report (SER) which was enclosed with Amendment ? o. hl to License IIo. DPR-53 and Anend ent
?!o. 23 to License ?io. DPP 69 Enclosure (1) nrovides the current status and comitnents vith respect to the SER and, to so:.e extent,10 CFR 50, Annendix R requirenents that are related to the original report.
Pnclosure (2) lists all correspondence in our files associated with fire protection since the issuance of the SES.
Please note that all SER requirements, except those nodified by Appendix R, have been completed. Anpendix F nodifications are expected to be conulcte by ?!cvenber 17, 1981 with the exception of nodifications identified by our Alternate Shutdown Study or Interactive Cable Analyses (Unit 1 submitted as enclosure to reference (a)). As reported by reference (a), Alternate Shutdown r.odifications and Auxiliary Feedvater nodifications affect many comon systens and are, therefore, beinc conpleted in parallel.
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Enclosures:
(1) Fire Protection Cafety Evaluation Penort v/ responses as revised (2) Peferences associated with Fire Protection requirements
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J. A. Biddison, Esquire G. F. Trowbridge "r.
D. Jafte - ?iPC 8111180422 811106 gFPDR ADOCK 05000317
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ENCLOSURE (2)
References :
September lh, 1979 NRC to BG&E, Reid to Lundvall transnitting the SER November 13, 1979
- BG&E to ImC, Lundvall to Reid December 21, 27, & 31, 1979 - BG&E to NRC, Lundvall to Reid January 11, & 29, 1980
- BG&E to NRC, Lundvall to Reid February 22, 1980
- BG&E to NRC, Lundvall to Reid l'ay 20,1980
- BG&E to NRC, Lundvall to Reid
? fay 19, 1980
- ?mC to BG&E, Clark to Lundvall May 23, 1980
- BG&E to NBC, Lundvall to Clark June 20, 1980 BG&E to NRC, Lundvall to Clark August 20, lo80
- BG'-E to IRC, Lundvall to Clark Sentenber 26, 1980 BGkE to IBC, Lundvall to Clark October 2, 1980
- ImC to BGLE, Clark to Lundvall October 28, 1930
- BG&E to NPCs Lundvall to Clark October 31, 1980
- NRC to BG&E, Eisenhut to Lundvall November 2h, 1980
- TRC to BG&E, Eisenhut to Lundvall l
December 29, 1980 BG&E to !RC, Lundyn11 to Eisenhut 1
f January 30, 1981
- BG&E to imC, Lundvall to Eisenhut I
March 19, 1981
- BG&E to NRC, Lundvall to Eisenhut T' arch 26,1981
- 9G&E to ImC, Lundvall ',o Clark April 6, 1981
- BG&E to IBC, Lundvall to Eisenhut May 7, 1981
- BG&E to NPC, Lundvall to Eisenhut i
l'ay 18,1981
- BGLE to IBC, Lundvall to Denton July 6,1981 BGLE to NRC, Lundvall to Eisenhut i
August 27, 1981
- BG&E to IRC, Lundvall to Eisenhut i
j September 1, 1981
- Imc to BGLE, Denton to Lundvall September 30, 1981
- BG&E to !BC, Poindexter to Eisenhut I
i N
1.
6 3' A CALVERT CLIFFS NUCLEarl POWER PLANT UNITS NOS. 1 AND 2 RESPONSES TO STAFF REQUIREMENTS CONTAINED IN ENCLOSURE 2 FURNISHED WITl! TIIS MAY 19, 1980 NRC LETTER RELATIVE TO TIIE SER FIRE PROTECTION
3.1.1
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ENCLOSURE 1 1
3.1.1 Curb in Diesel Room (4.5 5.18)
The licensee has provided information, showing that the curb will pre-l vent a possible communication of spilled oil between two adjacent i
diesel rooms in Unit I area. The staff will address its evaluation in a supplement to this report.
Response
The curb identified as required to prevent possible communication of oil between the two adjacent diesel rooms in the Unit I area has been provided. Calculations have been provided previously to demonstrate-that this curb is adequate. This item is complete.
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3.1.2 Additional Fire Fighting Equipment (4.3.1.3, 4.3.1.4)
The licensee will provide the following additional hose and equ'pment:
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(1) For'each exterior hose cabinet l
(a) 200' of 2%" fire hose (single Jacket, lined, synthetic)
(b) One 2%" x 1%" x 1%" gated wye (c) One 2%" combination fe'Jstraight stream nozzle rated at least 250 gallons per minute-4
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(d) One 1%" fog / straight stream nozzle rated at 60-90 GPM
.(e) Two each of 2%" and 1%" gaskets I
f (2) For each portable equipment cabinet l
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(a) 50' of 2%" fire hose l
(b) One Halligan type forcible entry tool (c) 100' of 1%" fire hose (3) For each interior hose station r
(a) One universal type hose spanner that can be used as a hose valve wrench and as a hose coupling spanner for buth 2%"
and 1%" hoses.
(4) At a suitable central location (a) One heat sensing device (b) 10 sets of fire fighting protective clothing; each set includes one turnout coat with removable liner, one helmet, cne pair of boots and one pair of gloves.
I Hevised:
11/ 6/81
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Response
Th-equipment identified above has been purchased and is available at the site. This item is completed.
3.1.3 Fire Water System Overpressurizat_;* ' 's. 3.1. 3 )
The licensee will identify and correct the cause of the fire water system overpressurization.
Response
As indicated in previous BG&E submittals dated April 19 and August 6, 1979, the cause of "overpressurization" has been identified with the on-of f operation of the electric motor driven fire pump _ and its check valves. One half inch pressure relief valves are to be installed on all thirteer. alarm check valves which trap pressure surges. These relief valves will be set to open at 175 nsi.
These pressure relief valves are installed. This item is complete.
l 3.1.4 Marking of Fire Water Valves (4.3.1.3)
The licensee will provide identification tags clearly marking post-indicator valves and controi valves for fire protection water systems so that reference to written descriptions or reference number is not necessary to identify the systems or areas each valve controls.
Response
Each valve in the fire suppression water system, excluding instrument stops, has been provided with an identification tag.
These are stain-less steel tags which identify the valve by number av4 provide suffi-cient description to facilitate the identity of the valves function by a qualified operator. This item is completed.
3.1.$
Breathing Apparatus Recharging System (4.4.3)
The licensee wiil:
(1) relocate the recharging system from the present location in ware-house No. I to a suitable central location within the Unit 1-Unit 2 operating area, (2) provide cooling water tank for each cascade system for air cylinders being recharged.
i llevised:
5/20/80 11/ 6/81
3.1.5 6
L
Response
The recharging system has been relocated from Warehouse No. I to a central location within the Service Building. This item is com-pleted.
3.1.6 Automatic Fire Suppression in Cable Spreading Rooms The licenses will install an automatic fire suppression system in each cable spreading room.
Response
A fixed automatic Halon 1301 fire suppression system is installed for each of the Cable Spreading Rooms. This item is complete.
3.1.7 Fire Water System Valves (4.3.1.1, 4.3.1.3)
The fire water tank discharge valves are locked open. The fire water tank interconnection valve has been locked closed. All locked valves in the fire protection system will be checked monthly to verify their position.
Response
As indicated above in the SER, this item has been completed.
3.1.8 Miscellaneous Usage of Fire Water (4.3.1.1)
An additional centrifugal prap, taking suction from the fire water tank standpipe and discharging to the fire protection system header, will be installed with adequate capacity to meet the intermittent use of fire water for purposes other than fire protection. Administrative procedures will be implemented to limit such usage of fire water to a single 1-1/2" hose stream at any time.
In the event of a fire, non-fire fighting water usage will be terminated immediately.
Response
An additional electric driven centrifugal fire pump is installed in the Turbine Building. This pump meets intermittent use of fire water for purposes other than fire protection. The pump takes suction from the fire water tank standpipe and discharges into the fire protection system header. This pump is arranged to start and stop automatically.
This item is complete.
Administrative procedures have been established to insure that the fire system usage for purposes other than the fire fighting will be limited to a single 1-1/2" hose stream at any one time.
Hevised:
5/20/60 11/ 6/81
3.1.9
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3.1.9*
Low Water Tank Level Interlock (4.3.1.2)
The fire pump controller will be modified to remove the fire water storage tank low level interlock from the control logic. Alarms will be provided to annunciate, in both the control room and the fire pump house, low level in fire water storage tanks.
Response
The fire pump controller has been rewired to remove the pretreated water storage tank low level interlock from the fire pumps control logic. This modification prevents the fire pu=p from stopping on a 1cw pretreated water storage tank level. The level switches on the pretreated water storage tank now provide pretreated water i
tank low level alarms which annunciate in both the control room and the fire pump house. This item is completed.
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3.1.10 Single Isolation in Fire Water Piping System (4.3.1.3, 5.18, 5.30) 1 A 2-1/2" hose connected to Hydrant No. 5 will be prelaid to provide hose coverage for Diesel Generator Room No. 21, when the fire water supply to the automatic sprinkler system and manual hoses stations protecting j
these areas are valved out simultaneously.
Response
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As indicated in the SER, this item has been completed. Technical Specification No. 3.7.11.2, Unit 2 covers this condition and CCI 133 specifically addresses the temporary corrective action required.
4 3.1.11 Portable Smoke Ejectors (4.4.1) t i
Three portable smoke ejectors and associated portable ducting will be provided to aid in manual smoke removal. The ejectors will be of the explosion-proof type that are used for fire fighting and have a minimum combined capacity of 17,500 CFM.
Response
Three portable smoke ejectors and associated portable ducting have been provided to aid in manual smoke removal. The ejectors, two explosion-proof elece.ric motor driven and one water-motor driven, provide a com-bined capacity of 17,500 cfm.
This item has been completed.
Revised:
5/20/80
4 3.1.12 3.1.12 Battery Room Ventilation (4.4.4, 5.11)
Telltales have been installed at the exhaust and supply air grills in each battery room and the air flow is being verified twice each shift.
Response
As indicated above in the SER, this item has been completed and is considered acceptable to the NRC staff as indicated in Section 4.4.4.
3.1.13*
Emergency Communication (4.7)
Communication equipment 5.11 be provided which is capable of maintain-Ing communication between the control room and all areas of the plant, :
including the interior of containment, considering possible damage due to a single fire.
Response
Existing plant co=munications systems include a page cystem and sound powered phone system which are capable of maintaining communications between the control room and all areas of the plant including the interior of the containment. A sound powered phone system has been l
installed to provide back-up communications from the control room, in the event of loss of normal communication during a fire. This system consists of 18 remote sound powered phone jacks. Jacks are located as follows:
(1)
L'n i t I and 2 Containments - 3 jacks each at El.
10'-0",
Ei.
45'-0",
El. 6 c '-0" in vicinity of east stairway.
(2)
Stairways AB-1 and AB 5 jacks each at El.
(-)l5'-0", El.
5'-0",
El.
27'-0",
El.
45'-0", El. 69'-0" at stairway entrances.
(3) Rooms 603 and 605 (Aux. Feed Pump Hooms - El. 12'-0") 1 jack each.
The system is installed-in such a way as to maintain adequate separation from existing communications facilities. East Electrical Penetration Rooms are utilized for containment entrances to avoid a common route in the west Penetration Room. No new cable was routed through the cable spreading room. Five (5) circuits were installed to minimize impairment of the remainder of the system due to a fire in any one are a.
New sound powered equipment is compatible with the existing system. These modifi-cations have been completed.
Hevised:
1/11/80 5/20/80 11/ 6/81
3.1.14*
3.1.14*
Hydrogen Piping (5.4, 5.8, 5.9)
An excess flow stop valve will be installer! in the line to the hydro-gen supply to auxiliary building to automatically secure hydrogen to the building in the event of a piping system rupture.
Response
The hydrogen piping has been modified during the last two unit outages to include excess flow stop valves, isolation, bypass and flange con-nections. This item is complete.
Revised:
5/20/d0 11/ o/81
3.1.15 3.1.15*
Addition of Curbs (5.9)
The licensee sill provide means to curb or contain a possible oil /
solvent spillage in the hot machine shop and in the hot instrument shop.
Response
Both the hot machine shop and hot instrument shops have been provided with two inch curbs at their respective entrances to contain possible oil / solvent spillage to the rooms. These curbs are sufficient to con-tain 1640 gallons in the hot machine shop and 425 gallons in the hot instrument shop. Calculatic - are shown below. This item is com-plete.
Revised:
5/20/d0
3.1.16 3.1.16 Control of Combustibles (5.9, 5.2'*, 5.46)
All combustibles that are not required for the routine operation and maintenance of the plant will be removed from all safety-related plant areas. Storage of combustible materials necessary for the routine operation or maintenance of the plant will be limited to approximately one week's supply. Metal cabinets, removed from the vicinity of any safety-related cables / equipment will be provided for such storage.
Response
,..ge of combustible material within safety related areas will be istricted to a one week supply of those materials required for routine operation and maintenance of the plant. Storage of combus-tible materials in excess of a one week supply inside or adjacent to safety related buildings or systems is prohibited except where such combustibles are stored in covered metal containers (i.e., drums or cabinets). No combustible material will be stored directly under safety related cabling or components. Cambustible material which is removed from systems in the course of normal maintenance activities, such as charcoal filter material, will be properly packaged and removed from the vicinity of safety related equipment as soon as practicable.
Transient Fire Loading inside or adjacent to safety related buildings or systems during maintenance or modification will be minimized con-sistent with the requirements of the job. When transient combustibles are introduced into these areas, the responsible supervisor shall specify the additional fire protection, if any, required. He may be assisted by the Fire Protection Inspector as necessary in making this determination. Debris, scrap, rags, oil spills or other waste com-bustibles resulting from the work activity will be removed either after the completion of the activity or at the end of the shift, whichever Comes sooner.
At least weekly iuring normal plant operation, the Fire Protection Inspector will make a tour of all accessible safety related areas of the plant. During this tour, he will inspect for hazards as noted above. Should items presenting unacceptable risk be noted, the cog-nizant supervisor will immediately be notified to correct the hazard.
Results of these inspections will be documented on a Fire Protection Inspector Report, which shall be retained for one year. During outages involving major work, in addition to the tours required above, the Fire Protection Inspector will make frequent inspections of the safety related work areas for fire hazards. Additionally, he will note equip-ment and materials used on the job which may change the combustible loading of the area and require fire protection measures over and above the installed equipment. This item is complete.
l Revised:
11/ 6/31
'3.1.17 3.1.17 Dedicated Ladder,s (5.10) 1 The licensee has provided a dedicated ladder of fiberglass construction in each cable spreading room to provide access to the areas above the battery rooms and the overhead cable chases.
Response
As indicated in the SER, this item has been completed.
>l 3.1.18 Miscellaneous Protection for Control Room (5.16)
(1) The licensee has provided a fog nozzle for the manual he e pro-tecting the room.
(2) All wooden furniture and shelves will be removed from the control room complex except for work benches in the Log and Test Instru-ment' Room.
1 (3) Metal partitions will be provided to separate the adjoining panels from the computer terminal in the middle of the main panel.
Response
i As indicated above in the SER:
(1) The fog nozzle has been provided, (2) Wooden furniture and shelves have been removed except for work benches, and (3) A metal enclosure for printout paper has been provided as shown on the attached sketch.
This item is completed.
Revised:
5/20/d0
3.1.19 3.1.19 Fire Detection in Safety-Related Areas (4.2, 5.1, 5.2, 5.3, 5.4, 5.5, 5.6, 5.7, 5.8, 5.9, 5.14, 5.19, 5.21, 5.27)
The licensee has proposed to install appropriate fire detection devices in some additional safety-related areas. We will further evaluate this modification when the design details become available.
Response-Reference the original response to SER Item 3.2.1, " Fire Hazards Analysis". Table 1 lists " Proposed Plant Modifications for Fire Protection Upgrade" and identifies those rooms that are to be equipped with fire / smoke detection. This work is complete. -Addi-tional fire detection devices have been added to the remaining safety-related areas due to Appendix "R" requirements; dhis work will be completed by November 17, 1981.
Revised:
11/ 5/81
4 3.1.20 3.1.20 Unprotected Doorways (4.9.1, 5.1, 5.2, 5.4, 5.5, L.7, 5.16, 5.18, and 5.22)
UL or FM listed fire doors of appropriate ratings will be installed, or acceptable alternate provided to protect the unprotected doorways in fire barriers separating various safety-related plat areas, including five doorways in the computer rooms currently provided with nonfire rated bullet-proof doors.
Response
Reference the original response to SER Item 3.2.1, " Fire llazards Analysis", and in particular the methodology discussion on Criteria 2.
Conclusion of the analysis shows that no listed fire doors need to be replaced. Several existing unrated doors were upgraded.
Installation of wet pipe sprinkler systems with dedicsted sprinkler heads at door-ways in areas with unrated doorways are used in lieu of rated doors.
The use of bullet-proof doors in the control room complex is for security purposes and since.this area is continuously manned on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basis, detection of an incipient fire would be prompt enough to mitigate any significant damage due to a fire and certainly before safe shutdown would be jeoptrdized. An ASTM fire test of unrated bullet-proof doors and dedicated sprinklers at doorways is scheduled for November, 1981 to verify adequacy of protection. Further, the Interactive Cable Analysis when completed will identify any other doorway or wall modifications necessitated by Appendix "R" require-ments.
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Hevised:
11/ 6/81
3.1.20-3.1.21*
Manual Hose Coverage (4.3.1.4, 5.6, 5.12, 5.17, 5.19, 5.21, 5.24, 5.25, 5.26, 5.28)
The licensee has performed hose reach tests and proposed to provide several additional hose stations. We will further evaluate this modification when the design details become available.
Response
Hose reach tests were performed and have been previously submitted.
Additional hose stations have been added as proposed. This item has been further evaluated in light of Appendix "R" requirements and additional hose stations were also added as a result. This item is complete.
Revised:
5/20/80 11/ 6/81
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3.2.1
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3.2.1 Fire Ha::ard Analysis f
Provide alternate shutdown capability independent of cabling and equipment 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 (IA, 1B, 2A, 28, Morizontal 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 'nclude but are not limited to, the following:
1 (a) Auxiliary building corridor and adjoining areas, Elevation (-)l0'-0".
(b) Auxiliary building corridor and adjoining areas, Elevation 5'-0".
1 (c) Component cooling pump rooms.
4 (d) Each service water pump rooms.
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3.2.2 This requirement is in addition to other requirements 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 separata different fire areas.
Alternatively, a separate and inde,,andent dedicated shutdown system providing additional acans to perform those safe shutdown functions for which redundr 4t cabling / equipment cannot be adequately separated, will be acceptable.
The alternate / dedicated shutdown capability should conform to the staff position on safe shutdown capability.
(Revised by the NRC May 19, 1980.)
Bcs;,ar.se This item has been changed to an Appendix "R" requirement and is no longer considered part of the original scope of the SER. The Inter-active Cable Analysis (ICA) for Unit I was submitted on September 30, 1981. The ICA for Unit 2 will be submitted by February 1,1982 as-reported in BGEE letter of May 18, 1981. Since the proposed modi-fications denoted in the ICA are closely related to the Auxiliary l
Feedwater Modifications project, the time frame for completion of i
these projects is planned to coincide.
3.2.2 Adeouacy of Detector Installation (1) Describe the parameters considered in both the original detector system design and the subsequent detector system design.
(2) Verify that the spacing between detectors, and between detectors and walls, is witFin allowable limits as provided in NFPA 72E.
(3) Provide a fixed automatic or manually operated water spray system per NFPA 15 to protect cables in cable chases IC and 2C.
(Revised by the NRC May 19, 1980.)
Response
In response to the concerns outlined by BNL contained in Enclosure 3 of the NHC May 19, 1980 letter, we wish to advise in regard to the above itemized itens:
(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, 1979.
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 Revised:
6/20/80 11/ 6/81
3.2.2 the burning characteristics of the combustibles anticipated in the area, cable tray and equipment locations, structural design, shape and height, HVAC air distribution patterns and velocities and room air change rates. The Pyrotronics DIS-3/5A detector sensitivity is adjustable and each detector was calibrated (i.e.,
voltage setting verified). A certification statement was tur-nished by a professional fire protection engineer which covers the design of the new fire detection systems for Calvert Cliffs.
These detection systems are installed as required by our original Fire Hazards Analysis. This item is complete.
(2) BGCE has verified that the spacing between Pyrotronics DIS-3/5A detectors and between thic type detector and walls is within the allowable limits as provided in NFPA 72E.
This item is complete.
l (3) The Halon system is installed for cable cha's'es 1C and 2C, includ-ing its automatic detection components. The fire detection system consists of fixed temperature detectors and multiple " products of combustion" type detectors installed at two elevations. There-fore, if the early warning " products of combustion" type detectors 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. This item is complete.
i Revised:
6/20/80 11/ 6/81
)
3.2.3 3.2.3 Fire Pump Flow Test (4.3.1.2)
The licensee will perform full scale pump tests and furnish the results of such tests.
Response
Full-scale fire pump tests were performed August 29 1979. These tests were witnessed by representatives of the American Nuclear Insurers (IRI personnel). The results of the tests were previously submitted. This item is complete.
3.2.4 Ventilation Duct Penetrations Verify that the proposed method of fire damper installation conforms to the conditions of listing of the fire damper by the testing labora-tory.
(Revised by the NRC May 19, 1980.)
Response
BGCE did 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 installation provides the required fire resis-tance to meet the Fire llazards Analysis. This item is complete.
3.2.5 Backflow Protection (1) Verify that a backflow check valve is provided in each drain line from the charging purp cubicles and diesel rooms, or that each cubicle / room has a separate drain system.
(2) Verify that each piping from individual room sumps on Eleva-tions (-)l0'-0" and (-)l5'-O" to the waste receiver tank is equipped with a backflow check valve.
(3) For each plant area which contains five gallons cr more com-bustible liquids and have a drain system common with safety related areas, verify that backflow from these areas to the safety related areas can be prevented if drain piping is clogged immediately downstream of the cocoon junction or the header. The study should include the consideration of backflow from nonsafety-related areas.
(Revised by the NRC on May 19, 1980.)
i
Response
NRC letter of October 2, 1980 approved previous response to all areas except diesel room drains which would require backflow protection.
This item was changed to an Appendix "R" requirement. Diesel backflow check valves are installed. This item is complete.
l Revised:
6/20/80 11/ 6/dl
3.2.4 3.2.6 Electrical Penetration Fire Resistance (4.9.3, 5.4, 5.5, 5.6, 5.9)
The licensee will provide the results of a standard ASTM E-119 test to demonstrate the adequacy of fire resistance of the Calvert Cliffs electrical penetratiors.
Response
On March 7,1980, the Southwest Research Institute performed an
" ASTM E-119 test" in accordance with BGCE specifications. Copies of the Southwest Research Report containing the results of the tests were submitted to the NRC staff for their review and com-ments. NRC staff and consultants witnessed the fire tests. Tnis item is complete.
3.2.7 Piping Penetration Fire Resistance (4.9.4, 5.4, 5.5, 5.5, 5.9)
The licensee will provide the results of a standard ASTM E-119 test to demonstrate tha.t piping penetraticns have fire resistance ratings commensurate with fire hazards on both sides of the barriers.
Response
Refer to Item 3.2.6 " Response". This item is complete.
Revised:
5/20/80 11/ 6/81
- - c 4
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3.2.8 Radiological-Consequences of Fire (4.14, 5.3, 5.7, 5.9, 5.20, 5.24 5.25)
The licensee will provide the results of a study of radiological consequences of a fire in areas containing radioactive materials 1
(including a fire in a charcoal or a HEPA filter), or other areas where a fire could cause the release of radioactive materials.
Additional modifications will be provided in areas where a fire
]
could cause the release of radioactive materials that could pre-clude the norms.1 usage or occupancy of areas surrounding the plant.
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Response
During the analysis and review of the plant to complete the response l
to SER Item 3.2.1, " Fire Hazards Analysis", the radiological conse-quences of a fire was entertained and the various radioactive mate-rials (combustible as well as noncombustible) were categorized into the following:
(1) Radioactive materials contained within pipes, pumps, tanks, and vessels.
(2) Charcoal and HEPA type filters.
(3) Spent resins.
(4) Wastes such as coveralls, gloves, boots, paper, and plastic.
Radioactive materials contained ithin pipes, pumps, tanks, and "essels (including the spent fuel in the pool) are not released
- d. -ing a fire as these means of material confinement are not assumed to burst or leak during a fire. This position is appar-ently shared by the NRC as demonstrated in SER Section 5.
The only credible discharge from a closed system would be from the plant radioactive liquid and gaseous discharge systems. These 1
systems each have two valves in series which fail closed on loss of electric power or air supply. Discharge piping contains an
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on-line radiation monitor which will close the valves on a high radiation reading. Additionally, the discharge piping contains normally locked shut isolation valves which are only opened after a tank is sampled and its activity level is determined to be acceptable for discharge. Therefore, it the radiation monitors should fail, an unacceptable discharge would not occur. As an additional safeguard against fire damage to the liquid waste sys-tem, a wet pipe sprinkler system is installed in Room 106. The gaseous waste system is in a fire area which has no postulated fire loading, Rooms 207 and 208.
Charcoal and HEPA type filters were reviewed with a total of 16 charcoal filters installed in the plant:
six inside containment, two in the control room HVAC system, four in the penetration room exhaust systems, two in the fuel pool exhaust system, and two in the ECCS pump room exhaust systems. All filters are normally by-passed. The filters in containment, and those for the penetration Revised:
11/ 6/81
3.2.d room exhaust system, and those for the ECCS pump room, are used only during post-accident conditions. The containment filters are provided with high temperature alarm and manually actuated emergency cooling water suppression systems. The spent fuel pool filters are used during fuel handling evolu-tions and after fuel handling accidents. The control room filters are used only on detection of high radiation in the control room ventilating system.
Charcoal filters are e Tined in steel casings. The amount of combustibles in th.
- a of these filters, other than the filters themselves, is low HEPA and other filter media used in the plant are of fire resistive cat
- rials. After removal, these filters are packaged in Federally approved containers for the appropriate radioactive level and held in the Bailing Waste and Dru= ming Root 418 which is protected by a wet pipe sprinkler system until removal is arranged.
Based on this and the NRC's acceptance of the installation as stated in SER Section 4.4.2, no significant release can be expected.
Spent resins are stored in steel tank i and transferred in steel pipes. Transfer of this material is done by directly piping the material into a Federally approved disposal cask in a specially designed room, within the waste disposal area, shielded for radiation and devoid of any combustible material.
The casks are stored in the waste disposal area whien is pro-tected by a wet pipe sprinkler system until shipment. Based on the existing method of handling and storage, no release of radio-activity can be expected.
Wastes are stored in steel 55 gallon drums supplied with fusible link tops or steel cabinets. The use of these special tops will prevent the spread of fire into or out of the drum and will pre-clude the dispersion of airborne radioactive contaminates. A survey of the plant shows a majority of the drums having a dose rate of less than 1 millium/ hour with the major isotopes being Cobalt 58 and 60.
These isotopes form a particulate wh'.ch is readily removed by sprinkler sprays, filters and by place out.
Based on this, radioactive releases due to a fire involving these types of materials would not provide a release in excess of site boundary limits nor would it preclude the normal usage or occupancy of any area of the plant. This item is complete.
l Revised:
11/ 6/81 f
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3.2.9 3.2.9 Effects of Fire on Radir. tion Monitors The licensee will provide the results of a study to demonstrate i
that ;he radiation monitor will remain operational when exposed to smoke andivr heat of a potential fire.
j
Response
4 The radiation monitoring system is not required to place the i
plant in a safe shutdown condition or to maintain it in a safe shutdown condition. As demonstrated in the results of a study for the radiological consequences of a fire, there exist only minimsl r.reas where a postulated fire could cause the release of raciaactive materials. It is also stated that tnese releases do not result in a condition which exceeds the requirements of 10CFR20.
CONTAINMENT RADIATION SIGNAL:
Four independent radiation area detectors located within the con-1 tainment are provided and, upon coincident of two-out-of-four trip signals or manual initiation from the control room, actuation occurs to isolate and secure the containment purge system. These devices are designed to operate in a LOCI environment for 100 per-cent relative humidity at 273 F and will provide audible and visual i
alarms if the radiation levels exceed a pre-set value or if tl detector malfunctions. Due to separation between locations for j
the area monitors and the containment volume available, a postu-lated fire that could conceivably effect all four system channels is not considered credible. The smoke resulting from a fire will not effect the system function. A device malfunction for any rea-son will provide a single input to the 2 out of 4 coincident logic, such that a second device malfunction will isolate end secure the l
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containment purge system.
4 WASTE PROCESSING AREA AND MAIN PLANT VENT:
I The waste processing area ventilation exhaust fans discharge is provided with a continuous off-line gaseous radiation monitor system. This system extracts a sample from the ventilation sys-tem, analyzes the sample via a geiger-mueller tube and returns the sample to the ventilation system prior to the main exhaust pleminum. A flow indicating switch is provided to indicate mal-function of the system. The system will operate normally under the following environment conditions:
+40 F minimum to 1200F 0
maximum, sample temperature 167 F maximum and smoke atmosphere.
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3.2.9 The plant vent is monitored for particulate, iodine, and gaseous activity. The equipment continuously withdraws a repre.entative sample from the plant vent and passes the sample through a moving filter paper having a collection efficiency of 99 percent for particle sizes greater than 1.0 micron. The amount of deposited activity is continuously scanned by a lead-shielded detector.
The remaining air is monitored by a separate gaseous monitor prior to returning to the plant vent.
A flow indication switch is providzd to indicate malfunction of the system. The gas moni-toring portion of this system is identical to the previously described waste processing system. The particulate monitoring portion of this system will operate normally under the following environment conditions:
+40 minimum to 120 F maximum and a sam-ple temperetture of 140 F maximum. This portion of the monitoring system is not expected to function properly with a smoke atmos-phere from a fire. The particulate monitoring portion is provided with a normally closed bypass piping to the gas monitoring portion.
Continuously on-line charcoal filters are provided in parallel with the particulate and gas analyzing system.
Due to the significant olume of air flow associated with ventila-tion systems within the Auxiliary Building, dilution will reduce the resultant temperature rise caused by a fire. Further, since the majority of the plant areas served by the ventilation systems are provided with fire dampers to isolate the effects of a fire, temperatures are not anticipated to affect the gaseous monitoring portion of the main plant vent system. It should also be noted that the main plant system provides redundant monitoring for the waste processing plant areas.
In the unlikely event that both of the described radiation moni-toring systems simultaneously fail, qualified plant personnel with sufficient quantities of portable radiation monitoring equipments are available to monitor effluents from the plant. This item is complete.
Revised:
11/ 6/81
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3.2.10 3.2.10 Fire Water Drainage (4.5) l The licensee will perform An additional study, following the comple-tion of hose reach teset aad addition of interior hose stations and other automat;- wecer systems, to verify that fire water drainage in all safety-related areas is adequate and possible fire water accumu-lation in any safety-related area will be acceptable.
Response
The largest gostulated fire is cne that. actuates a sprinkler coverage of 3,000 ft.~.
A sprinkler actuation of this magnitude could occur in one of the following three areas:
No. 419 (Cask and Equipment Leading Area), Nos. 228 and 201 (Component Cooling Water Pump Rooms, Units 1 l
and 2).
All other sprin arealessthan3,000ft.gledareasintheauxiliarybuildinghavean
, so the largest flow rate of fire water will come from one of these three areas. Also, there are three hose stations which could serve each of the areas.
If a fire were to actuate 3,000 ft.2 of sprinkler coverage and 3 hoses were used in any one of the three rooms, the drain capacity of the room would be exceeded. In addition, if we assume that the miscellaneous waste receiving tank is full at the start of the fire (all drains will flow into this tank), the drainage will overflow from the tank to a sump, fill and overflow the sump, and begin to flood elevation -15'-0".
The area being sprinkled will accumulate up to two inches of water but no more, as the water will flow down the staircases and eventually reach elevation -15'-0".
Some fire water may backflow from the drains to other areas, but this will eventually drain dcwn to the bottom elevation.
without significant accumulations.
At elevation -15'-0" only the corridor, Area 100, will flood as the other areas at this elevation are provided with watertight doors. Ele-vation -10'-0" will begin to flood, and this is acceptable up to the top of the equipment pedestals. For firt water to reach this point, the sprinklers and hose stations would all have to operate continuously for at least 60 minutes. It will actually take longer for all the water to reach the bottom elevation, as the water will not instantaneously flow down. Considering all fixed and transient combustibles in the area, and the operation of 3 hoses and a coverage of 3,000 ft.2 of sprinklers, 60 minutes would be adequate to extinguish a fire in these areas.
The effects of fire water drainage in all of the other areas in the auxiliary building would be less severe with the exception of the ECCS pump rooms, Areas Nos. 118, 119, 102, and 101. For iire fighter admis-sion to these rooms, a watertight door must be opened. Fire water could accumulate up to the top of the equipment pedestals in this room. Two hose stations can serve any of the rooms. With a fire ir. one of the smaller ECCS pump rooms, the miscellaneous waste receiving tank full, and two hoses used, it would take 48 minutes to flood the room but this would not prevent safe shutdown as the redundant room would be sealed from flooding by watertight doors. These time periods would be suffi-cient to extinguish a fire within the room. This item is complete.
l Revised:
11/ 6/81
3.2.11 3.2.11 Control Air (4.15)
Loss of control air to the salt water system valves causes the service water heat exchanger and the component cooling water heat exchanger inlet and outlat valves to fail open. The licensee will provide the results of his study to verify that possible over-cooling of service water and/or component cooling water will not have adverse effects on the plant safety.
I
Response
1 Loss of control air to the salt water system valves causes the service water heat exchanger and component cooling water heat exchanger inlet and outlet valves to fail open.with a resultant decrease in service water and component cooling water temperatures. This failure mode is consistent with the positions to which the valves would automatically i
be positioned in the event of an Engineering Safety Features Actuation.
Therefore, all equipments serviced by component cooling or service water are designed to accept this reduced temperature water with no adverse impact on plant safety. This includes the diesel generators which utilize service water to cool integral jacket cooling, air cool-t ing, and lube oil cooling heat exchangers. Ow ecooling of these systems is prevented by thermostatically actuated valves ;>ich bypass service water around the heat exchangers to maintain jacket cooling water 170-185 F, scavenging air 100-1150F, and lube oil 190-2050F.
This item i
is ccmplete.
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i Revised:
11/ 6/81 4
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3.3.1 3.3.1 Halon System i..ckup Power (4.3.2)
The *
.tsee has not provided sufficient justification fer not pro-viu._g oackup power for the Halon suppression systems.
Response
The staff accepted the existing Halon systems power supplies without further modification during a meeting held on October 2, 1979. This item is complete.
3.3.2 Emergency Lighting (4.6)
The licensee has not provided sufficient justification for not replac-ing the existing 1-1/2 hour rated batteries of the emergency lighting units with those of 8-hour rating. The distribution of existing emer-gency lighting units has not been demonstrated to provide adequate lighting for shutdown opet 6 ton and fire emergency responses.
Response
The normal lighting throughout the plant is fed from the station aux-iliary transformers. The normal / emergency lighting in the Control Room consists of normal AC/ emergency AC and emergency DC.
Upon loss of AC power, the emergency DC lighting in the Control Room is provided from the 125 volt station batteries.
(DC Control Panel Bus 24). Also, the emergency AC is provided by the auxiliary busses which are fed by emergency diesel generators upon loss of offsite AC power.
The normal AC/ emergency AC lighting is provided for Cable Spreading Room (elevation 27'-0") and Switchgear Rooms (elevation 27'-0" and 45'-0").
The emergency AC is provided by the auxiliary busses which are fed by the emergency diesel generators upon loss of AC power.
For personnel safety and safe egress during the period of time it takes the diesel generator to pick up the lighting load, less than 5 minutes, battery-operated emergency lights have been provided.
These battery-operated emergency lights actuate immediately upon loss of normal AC power.
All safety related areas of the plant contain fixed emergency lighting units, which have individual batteries and are presently rated for 1-1/2 hours. These units are automatically actuated upon loss of nor-mal AC power. We have replaced the existing 1-1/2 hour units with new l
8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> battery-operated units in the areas listed below. The new units will be Exide Model B-200, or equal.
(See attached literature.)
Revised:
11/ 6/31
3.3.2 Corridors 100, 103, 104, 120, and 122 (elev. -10' and -15')
l Corridors 200, 202, 203, 212, and 224 (elev. 5' and 10')
Corridors 300, 308, 309, 315, 319, and 327 (elev. 27')
Corridors 410 and 426 (elev. 45')
Corridors 506, 517, 521, 522, 525, and 527 (elev. 69')
l Stairtowers AB-1, AB-2, AB-3, AB-4, AB-5, and T-3 Auxiliary Feed Water Pump Rooms 603 and 605 (including passageway in Heater Bay)
Diesel Generator Rooms 416, 421, and 422, Rocm 419 Automatic Steam Dump Valve Rooms 408 and 428 Auxiliary Feed Water Valve Rooms 310 and 316 j
Fire Pump House This item is complete.
l 3.3.3 Fire Door Supervision (4.9.1)
The licensee has not provided sufficient justification for not provid-ing electrical supervision or locking closed those fire doors which are presently not supervised or locked.
Response
NRC letter dated October 2,1980 has found our previous responses acceptable. This item is complete.
?.3.4 RC Pump Lube Oil Collection System (5.19)
The licensee has not provided sufficient justification to demonstrate that:
(a) The existing system provides a complete containment for all potential leakage points which include lift punp and piping, external oil cooler, flanged connections, drain plugs, fill-I points, tipper and lower reservoirs, sight glasses and over-flow lines.
(b) The copper drain tubing does have adequate capacity to accommo-e date drainage cf a large oil leak.
(c) Draining collected oil on the containment floor is safe.
(d) The effects of a seismic event on this system will not adversely affect the plant safety.
Respons,e An oil spillage protection system has been provided for each reactor coolant pump motor. The system consists of encapsu-lating devices installed around potential leakage points and to protect against a major oil leak. Typical motor compcnents encapsulated are: lube oil lift pump, lube oil cooler, connect-ing flanges and oil reservoir drainage points. Piping from the 7
Revised:
11/ 6/81
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3.3.4 encapsulations accommodate a major oil leak and are interconnected to a common drain leading to an oil spillage collection tank located at elevation 10'-0".
Two collection tanks are installed in each containment, sized to accommodate the largest potential oil leak.
Each of the tanks service two reactor coolant pump motors. The piping from the oil spillage protection systems to the tanks as well as the tanks themselves are seismically supported. The tanks are UL approved standard design and are vented to ensure proper system urainage. A drain valve is provided on each tank to per-mit oil removal. This item is complete.
3.3.5 Fire Purp Separation (4.3.1.2)
The licensee has not demonstreted that the sprinkler system installed in the fire water pump house provides equivalent protection to the 3-hour fire barrier in limiting the effect of a fire et the diesel fire pump, or its fuel tank, on the electric fire pump.
Response
The fire pump house is protected by automatic sprinklers. The sprinkler system water supplies consist of two - 2500 gpm at 125 psi U/L approved horizontal centrifugal pumps taking suction from two -
300,000 gallon pretreated water storage tanks and a 15,000 gallon pressure tank (10,000 gallon nominal capacity) located remote from the fire pump house. A make-up pump is installed which also will serve as an additional water supply.
Automatic sprinklers control temperatures and extinguish fires l
involving combustible liquids in the Fire Pump House.
In NFPA Standard 30, the Flammable and Combustible Liquids Code, automatic sprinklers are recommended for protection of flammable and combus-tible liquid hazards. American Nuclear Insurers specifically recommended automatic sprinklers to protect against fires in the Calvert Cliffs Nuclear Power Plant Fire Pump House.
It is anticipated that both the electric motor and engine driven fire pumps will properly function in the event that the sprinklers are actuated and cischarging in the Fire Pump House. The fire pump controllers have NEMA 3 drip-tight weather resistant enclosures which are elevated on foundation pedestals. The electric pump foundation pedestal and base plate are 16 inches above the floor Revised:
11/ 6/31 I
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0 3.3.5 a
so that air intakes are elevated more than 20 inches. The elec-tric motor is enclosed to NEMA Type MG1-1.25A Drip-Proof spec;'i-cations (i.e., motor ventilating openings are so constructed that successful operation '.s not interfered with when water particles strike or enter the enclosure at any angle from 0 to 15 degrees downward from the vertical). The diesel engine is also supported on a pedestal and steel base plate and the engine is qualified to operate when exposed to weather conditions subject to freeze pro-tection. The pump room floor is pitched to floor drains to pre-clude communication of water or fur's from one pump to another.
The diesel fuel oil tank is provided with a dike to contain its contents.
A hydraulic calculation of the in situ automatic sprinkler system for the pump house has been previously submitted. The hydraulic calculation shows that at least 5 psi can be maintained at the most remote sprinkler head with all sprinklers in the Fire Pump House operating when supplied by the 500,000 gallon pretreated water storage tanks which are 40 feet high. The Factory Mutual System has selected 5 psi because it is the approximate minimum required for effective sprinkler discharge.
Further, it should be recognized that an additional centrifugal pump is installed as required in Item 3.1.8.
This pump is capable of supplying the sprinkler demand for the Fire Pump House and has a power supply independent of the Fire Pump House. This pump is located in the Turbine Building and takes suction from the fire l
water tank atandpipe and discharges into the fire protection system header. Ni letter of October 2,1980 finds the sprinkler system acceptable t lieu of separation. This item is complete.
3.3.6 Fire Fighting Strategies (6.1)
The licensee has not provided sufficient justification that the fire fighting strategies he has developed for seven areas in the plant are adequate for all plant areas.
Response
Fire fighting strategies have been developed for plant areas which either contain significant quantities of combustible material or which would pose unusual prob.e=s for the fire brigade combating a fire in that area. All strategies are complete. This item is com-plete.
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Revised:
11/ 6/31 l
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e 3.3.6 3.3.7 Quality Assurance (6.2)
The licensee has not provided the comparison of his quality assurance program and the guidelines.
Response
A Fire Protection Quality Assurance Procedure (QAP-9) has been pre-pared. A comparison of QAP-9 and NRC guidelines was submitted December 31, 1980. This item is complete.
l Revised:
5/20/30 11/ 6/dl