ML20032B102
| ML20032B102 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 10/27/1981 |
| From: | Hood D Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8111040447 | |
| Download: ML20032B102 (44) | |
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.O APPLICNIT:
Consumers Power Coupany (CPCo) s, FACILITY:
Hidland, Units 1 and 2
Subject:
Su uary of October 7,'1981 tiecting on tiidland - 1/2
/
Fire Protecti@ Plan Review
/
cackground Consuuers Power cuiapany suouitteo an updateo Fire Prutection Plan via Revision 35 to the FSAR in July 1981. Division of Licensing has established a target date of 140vecher 6,1961 for preparation of a draf t SEK on this seguent of the F5AR. Tne staf f and applicant uutually agreed that a aceting to resolve open itcas would be beneficial at this tue. Such a meeting was held at the IIC bethesda offices on uctober 7,1961.
A list of meeting attendees is attacned as Enclosure 1.
The meeting agenda is attached as Enclosure 2.
Discussion After introduction of personnel ano a orief overview of the meeting purposit, 11r. Benaroya stated tnat the revised Stancard Review Plan has been published and snculo be obtained and used by CPCo in evaluating the aJequacy of the Midland Fire Protection Progra:a (FPP). CPCc was also advised that a full written coaparison between the requirements of Appendix R and how the itidlana FPP complies with tnose requirements should be developed prior to the Comission decision date. The Staff also suggested that it would be beneficial for future reviews of the Hidland plant if the Midland FSAR was revised to confor:a to the new SRP 9.5.1.
CPCo said it could not co.aplete a major refornatting of the Fire Evaluation Report prior to issuance of the operating license.
CPCo passed out and ciscussed a partial comparisort to Appendix R and stated that the coupleted cooperison would be available of October 23,1981 (Enclosure 3).
Mr. Benaroya advised deletion of certain words in tueu " Description of Corpliance" colunn for item G.2.
Problem areas typically encountered in cocplying with sections III.G and III.L of Appendix R were specifically discussed. CPCo stated that the Midland FPP takes credit for adainistrative controls in the Containment. The staff's position was that this woulc. probably suffice curing operation but that additional require.nents are necessarj curing ueintenance and refueling periods during which containr.,ent accessability exists.
In response to a Staff question, CPCo stated that not all circuits on the auxiliary shutdown panel (A5P) are electrically isolated froa tne uain coritrol roca (hCR). All channel A circuits on the A5P considered necessary for achieving and r.:aintaining hot standby have l avi a nd i v...
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A discussion of the r.(thodology for tue sate shutdown analysis was presented by CPCo. A circuit uy circuit evaluation was perforned and a detailed circuit schedule developed.
The makeup punp sys'em was selected as ari exavple arid a walk-througn of the procecure used was given. Color-coded couponent loca tions drawings and conduit / cable tray schematics were used in deteraining possible areas of noncoupliance. The Hidland design provides for a manually initiated transfer of control circuits for 4 safe-shutduwn systens on Train A to an auxiliary shutdown panel in the event of a control roca fire. Those systems are auxiliary feedwater, cuergency diesel m nerators, component cooling water and service water. uther systens wc ad be remotely operated frou outside of the control room at their individual notor control centers.
The analysis revealed that approxiaately 50 control and inoication circuits for each unit had inadequate electrical isolation and LPCo stated that the probacle solution would be to provide isolation with transfer switches.
The tupact of these cualfications as well as tne overall uilestone scnedule was briefly discussed. The handouts used for the safe snutuown enalysis are attached as Lnclosure 4.
The staff questioned how "as-built" conditions, such us actual conduit roating would be f actcred into this analjsis. LPLo stateo tnat updates of tiie diagracis and sjstes walkuonns would be a continuing process until installation was co...plete.
or the aat walkdown of the The statf was questioneu regarding the tininu fire protection systen. The staf f reiterated its previous position that the walkdown would not be scheduled prior to installation of at least 90% of all required cabling since the pri..;e purpose of the walkduan is tu verify final or near-final as built configurations.
The Laseload Forecast Panel for nioland was told in nu9ust 19o1 that installation of wire and cable was Las complete.
It is presently anticipated that the tire protection walkdcwn could be scheduled as early as uid-1982.
Ine next pn e of toe eeeting dealt specifically with control roca fires. lnere has been some misunderstav Jinj regarding assuaptions and requiren.ents concerning fires in tne control rumi.
In a peeting on April 16, 1961, the staff agreed to provide clarification of its position whether loss of nore tnan one cabinet by a centrol roon fire need be considered.
See Enclosure 6.
The specific case in question was a panel containing a series of logic instruoents for both trains of safe shutdown comporients.
CPLo questioned unether this panel (ICitb7 or 2Ll66) constituted 'several cabinets" since each instrunent section is separated frot1 adjacent instrument sections by sheet n.etal partitions or whether the panel was considered to be one caninet frm1 the standpoint of a control roou fire.
The staff's position was that tne sheet u.etal partitions do not constitute tire barriers and therefore the panel is considereo to be all one cabinet. The concern in this instance, however, is not propajation of fire troa one section to another within the cabinct but rather propagation of an exposure (external) fire to more than one instruuent section within the cab. net. One possibl remedy for this problea wnica was discussed would be to erect a l-hour fire barrier around the caninet and install ari auto..atic halon suppression syste.a. LPio will evaluate corrective action. A second area, tne safety related equipe.ent roaa for eacn reactor, was also discussed troni the stdiidpoint of protection tral control room fires.
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Tne previously identified problem (discussed during the April 15, 1981 ceeting) of having only lo feet separation between the Auxiliary Shutdown Panel (2C114) and the Auxiliary Feedwater Control kack was discussed.
The staff indicated that an acceptable solution would be to erect an 8 f t. high 1-nour tire barrier and din eutouatic lialon suppression syste:3.
The af ternoon session of the aceting was devoted to discussion of and response to (in soue cases) the 15 open items supplied to CPCo with the ueeting a gen th.. A stGMry of the ydestions dnd proposed resolutions is attdCned as Lnclosure 6.
Two questions of interpretation evolved from the af ternoon session. Tne first was wnether the requireuent that " detection systems should oe provided for all areas tnat contain or present a fire exposure to safety-related equipmeat" (section C.6.a.(1) of BTP ChEB 9.5-1) applies to areas Containing Jdfety-related cable but no safety-related components (i.e.
does "equipnent" includc cable?). The other question is whether suone oetectors in uYAL system ducts were considered to provide adequate detection for the fire area itself. The staff responded that the duct detectors would not necessarily provide valid detection for the area due to allution and cooling.
CPCo described tue construction of missile and pressure relief doors identified in the fire area analysis of FSAR Section 9A.2.
because of tneir superior construction and securing occhanism, 'it was CPCo's judgement that these doors are equivalent to a 3-nour fire-rated door.
lue Staff stated taey were in agreement witn this position.
A short aiscussion on fire damper installation was held. The concern was that fire da;r.per installations do not meet taanufacturers' tested installa-tion details because of construction wall variances.
It was recomienced that the gap between the damper and the penetration oc sealed with steel angle iron so as to reseable the manufacturers' detail as closely as possible. This modification, waich would ensure that fire woulo not propogate through the penetration, would be satisf actory to the staff.
It became obvious curing tne af ternoon session that in or&* for a draf t Stri to be issued as presently scheduled, a mit would be needed to the aidland Plant Site by the CM.b reviewer and his fire protection consultant.
The final SER issuance dote was recently uoved up to day 1982 Dy aka. The final fire protection plant walkdown will not likely be able to be perforued until several months af ter tnat. Therefore, the Division of Licensing consioers intarim site visits necessary to support the early SLR date. The meeting was concluded with a statement of intention by the staff to schedule a site visit by CnLb in late October 1981.
In response to items froa the April 15, 1981, meeting between CPCo and tne Staff, the Staff said a failure taode analysis for fire protection woulo not be needed. The Stoff also pointed out that an exception to 10 CFR 60 Appendix R criteria would be required if automatic suppression is not installed in the main control roca.
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_ Post-ffeetino Actions l
The following the meeting, Cf1EB nanagement was requested to provide clari-fication on the question discussed above, relating to whether or not detection systens nust be provided in fire areas containing only safety-related cable.
The staff's position is that cable is included under the definition of " safety related equip.1ent" and therefore detectio') nust be orovided in those areas.
Darl S. Hood, Project Manager Licensing Branch f?o. 4 Division of Licensing
Enclosures:
As stated DISTRIBUTION Docket File LB#4 r/f e
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ENCLOSURE 1 LIST OF ATTENDEES OCTOBER 7,1981 - MIDLAND FIRE PROTECTION MEETING NRC V. Benaroya*
R. Anand H. Li
- E. Sullivan*
W. LeFave*
V. Panciere*
R. llernan Consumers Power C.ompany R. Huston R. Berry D. Perry R. Teuteberg Bechtel Power Corp.
R. Burg A. Strunk H. Singh J. Guy D. Lewi s*
Gage-Babcock and Assoc.
J. Behn
- Part Time
ENCLOSURE 2 AGENDA OCTOBER 7,1981 - MIDLAND FIRE PROTECTIbh REVIEW l.
Introduction of attendees and overview of purpose.
2.
Presentation of Midland Fire Protection Plan vs.10 CFR 50 by Consumers Power Co. (CPCo).
3.
Discussion of Safe Shutdown Analysis methodology.
4.
Discussion of requirements relating to control room fires including interpretation of SRP Section 9.5.1.
5.
Review of itens discussed in CPCo letter of August 6,1981 (J. W. Cook to H. R. Denton) regarding Midland Fire Protection Evaluation Effort.
6.
Detailed discussion of 15 open itens supplied to CPCo prior to meeting.
ENCLOSURE 3 PARTIAL APPENDIX R* COMPARISON MIDLAND UNITS 1 AND 2 DOCKET NO 50-329 AND 50-330 CONSUMERS POWER COMPANY OCTOBER 7, 1981 l
- Note:
Appendix R Noticed 45 FR76602 on November 19, 1980 and as amended 46FR 44734 on September 8, 1981.
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mi1081-0450a100 i
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9 A/PENDIX R DESCRIPTION OF REG';LATORY POSITIONS COMPLIANCE G.
Fire Protection of Safe Shutdown Capability G.
Fire Protection of Safe Shutdown Capability 1.
Fire protection features shall be 1.
The Midland Plant has been analyzed to ensure provided for structures, systems, and safe operation given the occurrance of any components important to safe shutdown.
transient or exposure fire.
Safe operation These features shall be capable of includes quickly attaining hot standby and limiting fire damage so that:
maintaining cold shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
a.
One train of systems necessary One train of systems required to achieve and to achieve and raintain hot shutdown maintain hot standby from the control room conditions from either the control or alternate emergency control station will room or emergency control station (s) be free from fire damage. Further the is free of fire damage; and analysis demonstrates that the systema neceasr y to achieve and maintain cold shut -
b.
Systems necessary to achieve and down fru either the control room or emer-maintain cold shutdown from either genef control stations are available or can the control room or emergency control be repaired and made available within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
station (s) can be repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
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2.
Except as Provided for in paragraph G.3 of 2.
Unless specified in the Fire Hazards Analysis this section, where cables or equipment, Section 9A.2 one of the three items designated including associated non-safety circuits as a.,
b.,
or c. ensures that one of the redun-that could prevent operation or cause dant trains is free of fire damage. These were maloperation due to hot shorts, open cir-utilized outside of the main control room and cuits, or shorts to ground, of redundant primary c.ndainment.
Inside containment the items r
trains of systems necessary to achieve designated as a, b, c, d, e, or f was provided to and maintain hot shutdown conditions are ensure one train is free of fire damage. The located within the same fire area outsied review considered only one fire and the failures of primary containment, one of the considered were those caused by the fire. The following means of ensuring that one of fire was assumed to cause hot shorts, shorts to the redundant trains is free of fire ground, or open circuits in those compoents damage shall be provided:
required to operate during or after a fxte.
Components whose loss of power position it the a.
Separation of cables and equipment desired position for shutdown are assumed to go and associated non-scfety circuits of to their loss of power position.
redundant trains by a fire barrier having a 3-hour rating. Structural steel forming a part of or supporting such fire barriers shall be protected mioae'-0219a100
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10 APPENDIX R DESCRIPTION OF j
REGULATORY POSITIONS COMPLIANCE to provide fire resistance equivalent to that required of the barrier; b.
Separation of cable and equipment and associated non-safety circuits of re-l dundant trains by horizontal distance of more than 20 feet with no intervening combustible or fire hazards.
In addition, fire detectors and an automatic fire suppression j
system shall be installed in the fire area; or c.
Enclosure of cable and equipment and associated non-safety circuits of one redundant train in a fire barrier 4
j having a 1-hour rating.
In addition, fire detectors and an automatic fire suppression system shall be installed 2
in the fire area.
^f Inside noninerted containments one of the fire protection means specified i
above or one of th' following fire protection.means s.411 be provided:
d.
Separation of cables and equipment and associated non-safety circuits of redundant trains.by a horizontal distance of more than 20 feet with no intervening combustibles or fire hazards; e.
Installation of fire detectors and an 1,
automatic fire suppression system in the fire area; or f.
Separ, tion of cables.and equipment 4
and associated non-safety circuits of redundant trains by noncombustible miO381-0219a100
11 APPENDIX R DESCRIPTION OF REGULATORY POSITIONS COMPLIANCE radiant energy shield.
3.
Alternative or dedicated shutdown capa-3.
Alternate shutdown capability and its associated bility and its associated circuits circuits, independent of cable, systems, or (alternative shutdown capability is components in the area, room, or zone under provided by rerouting, relocation or mod-consideration are provided where the protection ification of existing systems; dedicated of systems whose function is required for hot shutdown capability is provided by shutdown does not satisfy the requirements of installing new structures and systems _for Item 2 above.
the function of post-fire shutdown),
independent of cables, systems or com-ponents in the area, room or zone under consideration, shall be provided:
a.
Where the protection of systems whose fun,; ion is required for hot shutdown does not satisfy the requirement of Paragraph G.2 of this section; or b.
Where redundant trains of systems required for hot shutdown located in the same fire area may be subject to damage from fire suppression activites or from the rupture or inadvertent operation of fire suppression systems.
In addition, fire detection and a fixed fire suppression system shall be installed in the area, room, or zone under consideration.
H.
Fire Brigade A site fire brigade trained and equipped for fire fighting shall be established to ensure adequate manual fire fighting capability for all areas of the plant containing structures, systems, or components important to safety.
miO381-0219a100
24 t.
APPENDIX R DESCRIPTION OF REGULATORY POSITIONS COMPLIANCE I
extinguishant to the fire, comm-i unication with the control room, i
and coordination with outside fire departments.
g.
Potential radiological and toxic
+
hazards in fire zones.
h.
Ventilation system operation that ensures desired plant air distribution when the ventilation j
flow is modified for fire fire containment or smoke clearing operations.
t i.
Operations requiring control room and shift engineer coordination or authorization.
j.
Instructions for plant operators and 1
d general plant personnel during fire.
L.
Alternative and Dedicated Shutdown capability L.
Alternate and Dedicated Shutdown Capability 2
i 1.
Alternative or dedicated shutdown 1.
The alternate shutdown capability capability provided for a specific fire provided for a specific fire area is area shall be able to (a) achieve and able to achieve and maintain suberitical i
maintain subcritical reactivity reactivity conditions in the reactor, conditions in the reactor; (b) maintain maintain reactor coolant inventory, reactor coolant inventory; (c) achieve achieve and maintain hot standby con-and maintain hot standby (as defined ditions, and achieve and maintain cold in the Standard Technical Specifications) shutdown in 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The reactor i
conditions for a PWR (hot shutdo*; : for coolant process variables are maintained' i
a BWR); (d) achieve cold shutdows (as' within those predicted for a loss of defined in the Standard Technical normal AC power.
Specifications) conditions within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; and (e) maintain cold shutdawn conditions thereafter. During the postfire shutdown, the reactor coolant system process variables shall be ciO381-0219a100
O 25 APPENDIX R DESCRIPTION OF REGULATORY POSITIONS COMPLIANCE 1
maintained within those predicted for a loss of normal A.C. power, and the fission product boundary integrity shall not be affected; i.e.,
there shall be no fuel clad damage, rupture of any primary coolant boundary, or rupture of tne contain-ment boundary, i
2.
The perfor:snce goals for the shutdown 2.
The performance goals for the shutdown functions shall be:
function have been met.
a.
The reactivity control function shall be capable of achieving and main-taining cold shutdown reactivity I
conditions.
b.
The reactor coolant makeup function shall be capable of maintaining the reactor coolant level above the top of the core for BWRs and be within the level indication in the pres-surizer for PWRs.
c.
The reactor heat removal function shall be capable of achieving and maintaining decay heat removal.
d.
The process monitoring function shall be capable of providing direct readings of the ocess variables necessary to pe' orm and control the above functior.
e.
The supporting functions shall be capable of providing the process cooling, lubrication, etc., necessary to perait the operation of the equipment used for safe shutdown functions.
4 oiO381-0219a100
e 26 APPENDIX R DESCRIPTION OF REGULATORY POSITIONS COMPLIANCE 3.
The shutdown capability for specific fire 3.
The alternate shutdown capability is in-areas may be unique for each such area, dependent of the specific fire areas and or it may be one unique combination of shall accomodate post fire conditions for systems for all such areas.
In either 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Procedures will be in effect to case, the alternative shutdown capability implement this, shall be independent of the specific fire
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area (s) and shall accommodate postfire conditions where offsite power is avail-able and where offsite power is not available for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Procedures shall be in effect to implement this capa-bility.
4.
If the capability to achieve and maintain 4.
The capability to maintain hot standby cold shutdown will not be available until cold shutdewn can be achieved 'as because of fire damage, the equipment and been verified. The required number of systems comprising the means to achieve personnel will be reviewed.
and maintain the hot standby ~or hot shut-down condition shall be capable of maintaining such conditions until cold shutdown can be achieved.
If such equip-ment and systems will not be capable of being powered by both onsite and offsite electric power systems because of fire damage, an independent onsite power system shall be provided. The number of operating shift personnel, exclusive of fire brigade members, required to operate such equipment and systems shall be on site at all times.
5.
Equipment and systems comprising the 5.
The damage to systems required to achieve means to achieve and maintain cold shut-cold shutdown will be limited so that down conditions shall not be damaged by cold shutdown will be achieved within fire; or the fire damage to such equip-72 hours.
ment and systems shall be limited so that the systems can be made operable and cold shutdown can be achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Materials for such repairs shall be miO381-0219a100
e 27 APPENDIX R DESCRIPTION OF REGULATORY POSITIONS COMPLIANCE readily available on site and procedures shall be in effect to implement such repairs.
If such equipment and systems used prior to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after the fire will not be capable of being powered by both onsite and offsite electric power systems because of fire damage, an independent onsite power system shall be provided. Equipment and systems used after 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> may be powered by offsite
. power only.
6.
Shutdown systems installed to ensure 6.
Midland complies with this section.
postfire shutdown capability need not be designed to meet seismic Catagory I criteria, single failure criteria, or other design basis accident criteria, except where required for other reasons,-
e.g., because of interface with or impact on existing safety systems, or because of adverse valve actions due to fire damage.
7.
The safe shutdown equipment and systems 7.
A postulated fire involving associated for each fire area shall be known to be circuits will not prevent a safe shut-isolated from associated non-safety down of the Kidland Units.
circuits in the fire area so that hot shorts, open circuits, or shorts to ground in the associated circutis will not prevent operation of the safe shut-down equipment. The separation and barriers between trays and conduits containing associated circuits of one safe shutdown division and trays and conduits containing associated circuits or safe shutdown cables from the redundant' division, or the isolation of these associated circuits from the safe shutdown equipment shall be such that.a postulated fire involving associated circuits will not prevent safe shutdown.
niO381-0219a100
o s
29 DESCRIPTION OF APPENDIX R REGULATORY POSITIONS COMPLIANCE inspected semiannually to verify that automatic hold-open, release and closing mechanisms and latches are operable.
One of the following measures shall be provided to ensure they will protect the opening as required in case of fire.
1.
Fire doors shall be rept closed and electrically supervised at a continuously manned location; 2.
Fire doors shall be locked closed and inspected weekly to verify that the doors are in the closed position; 3.
Fire doors shall be provided with j
automatic hold-open and release l
l mechanisms and inspected daily to verify l
that doorways are free of obstructions; l
or 4.
Fire doors shall be kept closed and 1
it.spected daily to verify that they are l
in the closed position.
The fire brigade leader shall have ready access to keys for any locked fire doors.
Areas protected by automatic total flooding gas suppression systems shall have' electrically supervised self-closing fire doors or shall satisfy option 1.
above.
O.
Oil Collection System for Reactor Coolant O.
Oil Collection System for the Reactor Coolant Pump Pump The reactor coolant pump.sh-11 be equippe3 Midland complies with these requirements. NUS with an oil collection system if the Corporation is designing and fabricating an ciO381-0219a100
r-e
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30 APPENDIX R DESCRIPTION OF REGULATORY POSITIONS COMPLIANCE containment is not inerted during normal engineered oil collection system able to operation. The oil collection system shall withstand an SSE.
be so designed, engineered, and installed that failure will not lead to fire during normal or design basis av:cident conditions and that there is reasonable assurance that the system will withstand tte Safe Shutdown Earthquake (See Regulatory Luide 1.29 "Sesimic Design Classification" Iaragraph C.2.).
Such collection systems shall be capable of collecting lube oil from all potential pressurized and unpressurized leakage sites in the reactor coolant pump lube oil systems.
Leakage shall be collected and drained to a vented closed container that can hold the entire lube oil system inventory. A flame arrester is required in the vent if the flash point characteristics of the oil present the hazard of fire flashback. Leakage points to be protected shall include lift pump and piping overflow lines, lube oil cooler, oil fill and drain lines and plugs, flanged connections on oil lines, and lube oil reservoirs where such features exist on the reactor coolant pwips.
The drain line shall be large enough to accommodate the largest potential oil leak.
miO381-0219a100
]
ENCLOSURE 4 i
l FIRE PROTECTION - SAFE SHUTDOWN ANALYSIS REGULATIONS AND GUIDELINES I
e 10 CFR 50 APP A, CRITERION 3 (FIRE PROTECTION) e NRC BRANCH TECHNICAL POSITION ASB 9.5-1 (GUIDELINES FOR FIRE PROTECTION FOR NUCLEAR POWER PLANTS,'i e 10 CFR 50 APP R (FIRE PROTECTION PROGRAM FOR OPERATING NUCLEAR POWER PLANTS)(OPERATING LICENSE PRIOR TO JANUARY 1,1979)
MIDL.AND UNITS 1 AND 2 G-1512-10 l
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FIRE PROTECTION - SAFE SHUTDOWN ANALYSIS OBJECTIVE l
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e ENSURE THAT AT LEAST ONE MEANS OF
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i ACHIEVING AND MAINTAINING SAFE SHUTDOWN CONDITIONS REMAINS AVAILABL E l
DURING AND AFTER A POSTULATED FIRE
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M0t.AND UNITS 1 AND 2 G-1512 08 V-10 i
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l FIRE PROTECTION - SAFE SHUTDOWN ANALYSIS GOAL 1
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e ACHIEVE HOT STANDBY IMMEDIATELY
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e ACHIEVE COLD SHUTDOWN WITHIN 72 HOURS
-muo ums, ~m
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FIRE PROTECTION - SAFE SHUTDOWN ANALYSIS ASSUMPTIONS l
e EXPOSURE FIRE OUTSIDE PRIMARY CONTAINMENT l
i e EXPOSURE FIRE INSIDE CONTROL ROOM CAUSING DISRUPTION OF ANY SINGLE CONTINUOUS CABINET MIDLAND UNITS 1 AND 2 G 1540-08
i FIRE PROTECTION - SAFE SHUTDOWN ANALYSIS CRITERIA l
l e SINGLE FIRE i
e HOT SHORTS, OPEN CIRCUITS, SHORTS TO l
GROUND i
1 e FAILURES CAUSED BY FIRE ONLY i
i I
j MIDLAND UNITS 1 AND 2 V 14 G-1540 06 4
i
FIRE PROTECTION - SAFE SHUTDOWN ANALYSIS CRITERIA (cont'd) l l
e OFFSITE POWER AVAILABLE OR UNAVAILABLE e LIMITED MANUAL ACTION INSIDE CONTROL ROOM l
e EXTENSIVE MANUAL ACTION OUTSIDE l
CONTROL ROOM i
i j
V-15 wouno ums uno 2 a.,340.or I
l' FIRE PROTECTION - SAFE SHUTDOWN ANALYSIS j
APPROACH e IDENTIFY EQUIPMENT NEEDED TO ACHIEVE AND MAINTAIN SAFE SHUTDOWN CONDITIONS e IDENTIFY POSSIBLE EFFECTS OF FIRE ON i
THAT EQUIPMENT l
i e PROVIDE PROTECTION TO ENSURE OPERATION l
MIDLAND UMTS 1 AND 2 y.16 G-151212
e PECHTEL JOB 7220 8.
FIRE PROTECTION SAFE SHLTTDOWN ANALYSIS - SHITIDOWN COMPONENTS Cable Component Sep Local Remote Control Points System Number Description Needed TS TS Norm Alt Alt Restrks Pressurizer 1M-93A Pressurizer heaters X
X 1C12 1C114 Ensure separation of power and controle heaters IM-93B Pressuriser heaters X
for bank 5 from bar.k 63 provide TS 2M-93A Pressurizer heaters X
X 2C12 2C114 for bank 53 one heater bank is suffi-2M-93b Pressurizer heaters X
cient for pressure control. Bank 5 is a subset of 93-A.
Bank 6 is a subset of 93-B.
Reactor IPSV-0131 RC pressurizer Self-actuated valves coolant safety valve system 1PSV-0132 RC pressurizer safety valve 2PSV-0231 RC pressuriser safety valve 2PSV-0232 RC pressurizer safety valve Control rod Pailure mode is safe with rods drive trip inserted.
circuitry Main steam 1XV-3111A Main steam isola-Failure mode is safe.
system tion valves 1XV-31118 Main steam isola-tion valves 2XV-3211A Main steam isola-tion valves 2XV-3211B Main steam isola-tion valves Main feed-1XV-3866A Mrw isolation to Failure mode is safe.
water sys-steam generator tem 1XV-3866B Mrw isolation to steam generator 2XV-3966A Mrw isolation to steam generator 2XV-39665 MrW isolation to steam generator Makeup and IP-58A RCS makeup pumps X
X IC12 1C114 SWGR purifica-1P-588 RCS makeup pumpe X
tion system 1P-58C RCS makeup pumps X
X IC12 1C114 SWGR 2P-58A RCS makeup pumps X
X 2C12 2C114 SWGR 2P-588 RCS makeup pumps X
X 2C12 2C114 SWGR
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FIRE PROTECTION - SAFE SHUTDOWN ANALYSIS l
MEANS OF RESOLVING L
PROBLEMS I
e PHYSICAL PROTECTION AND/OR SEPARATION i
. Fire Barriers i
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.. Fire-Retardant Wraps and Sprinklers i
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. Increased Spatial Separation MIDLAND UNITS 1 AND 2 G-131215 i
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FIRE PROTECTION - SAFE SHUTDOWN ANALYSIS i
FUNCTIONS REQUIRED FOR i
MAINTAINING SHUTDOWN l
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e REACTIVITY CONTROL i
e INVENTORY CONTROL e PRESSURE CONTROL
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j e DECAY HEAT REMOVAL MOLAND UNITS 1 AND 2 G 1540-03 j
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l FIRE PROTECTION - SAFE SHUTDOWN l
1 ANALYSIS e SYSTEMS REQUIRED TO ACHIEVE AND MAINTAIN SAFE l
l SHUTDOWN CONDITIONS Makeup l
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Emergency Boration l
l Pressurizer Heaters, Safety Valves l
Auxiliary Feedwater Service Water l
Component Cooling Water e
l Emergency Diesel Generators l
Chilled Water - Safeguards il Reactor Building HVAC Service Water Pump Structure HVAC l
e Control Room HVAC l
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Auxiliary Pressurizer Spray e
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Power-Operated Atmospheric Vent Valves Decay Heat Removal e
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FIRE PROTECTION - SAFE SHUTDOWN ANALYSIS l
SYSTEMS USING REiEOTE-l OPERATED TRANSFER SWDTCM ES l
w AUXILIARY FEEDWATER SYSTEM rs2s l
e COMPONENT COOLING WATER SYSTEM
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e DIESEL' GENERATOR oy 1
i e SERVICE WATER SYSTEM 3 c c,. s 4-
- ccs, mot.AND UNITS 1 AND 2 G-1540-02 l
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FIRE PROTECTION - SAFE SHUTDOWN ANALYSIS CONTROL ROOM FIRE EVACUATION ACTIONS l
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e REACTOR SCRAMMED BY OPERATOR l
I e REMOTE-OPERATED TRANSFER SWITCHES l
ACTUATED BY CONTROL SWITCH i
i e CONTROL ON AUXILIARY SHUTDOWN PANEL l
ESTABLISHED AFTER TRANSFER SWITCHES l
ARE PLACED IN REMOTE POSITION I
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i FIRE PROTECTION - SAFE SHUTDOWN ANALYSIS l
MEANS OF RESOLVING PROBLEMS t
L li e ELECTRICAL ISOLATION
!I Approximately 50 Control and Indication Circuits Per Unit identified as Having Insufficient Electrical isolation j
l Probable Solution: Provide Electrical isolation with Transfer Switches i
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NC RESENT TON FIRE PROTECTON 9/28/81 si e
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IDENTIFIED IMPACT ON MIDLAND i
i e 40 STARTUP SYSTEMS AFFECTED BY TRANSFER SWITCHES i
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e 13 OTHER STARTUP SYSTEMS AFFECTED BY j
FIRE PROTECTION CHANGES l
l e 9%-MONTH (maximum) SCHEDULE IMPACT l
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FIRE PROTECTION SAFE SHUTDOWN ANALYSIS l
MILESTONE SCHEDULE I
1980 1981 1982 l
JJASONDJFMAMJJASONDJFMAM 1
LICENSINGINRC ACTIVITIES M
b M=d ANALYSIS TO DETERMINE PROGRAM AND RESOLUTIONS M
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I DESIGN OF RESULTING CHANGES R
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PROCUREMENT AND DELIVERY OF TRANSFER SWITCH PANEL i
TURNOVER OF AFFECTED SYSTEMS j
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r NOTES:
Schedule milestone
- 1. Initial FPSS meeting with NRC prompting new analysis
- 2. CPCo implementation letter to conduct analysis
- 3. NRC agreement for transfer switches on single channel
- 4. Meeting with NRC to discuss FPSS analysis
- 5. Revised fire hazards analysis issued
- 6. NRC site survey 7.SER
- 8. Color coding of raceway drawings started
- 9. CPCo/Bechtel site survey
- 10. Task force begun
- 11. Update of site survey
- 12. Electrical schemes completed to support panel procurement
- 13. Fire protection DCP
- 14. New sprinkler installation begun
- 15. Wiring of transfer switch panelin field
- 16. Award of transfer switch panel
- 17. Delivery of transfer switch panel
- 18. T/O service water
- 19. T/O borated water storage
- 20. T/O component cooling water
- 21. T/O diesel generator 4
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i CONTACTS WITH NRC ON FIRE PROTECTION e JUNE 1980 - CPCo/NRC MEETING l
. Assume Exposure Fire Everywhere Except Containment i
. Assume Disruption of any Single Control Panel j
. Provide Capability for immediate Hot j
Shutdown 1
Ocin"es"e""f1tu".?'neenorection 9,28,82 a.ieer.2a j
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l CONTACTS WITH NRC ON FIRE PROTECTION (cont'd) l e SEPTEMBER 1980 - CPCo/NRC TELEPHONE j
CALL Agreement on Protection of One Channel of e
Safe Shutdown Equipment by Electrical Isolation Devices 1
i NC RESEN ATION F E PROTECTION 9/28/81 G-1867-27 i
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i CONTACTS WITH NRC ON FIRE
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PROTECTION (cont'd) i.:
e APRIL 1981 - CPCo!NRC MEETING U
. Presentation of Design for Control Room Fire
- I Protection q
. Presentation of Design for Transfer Switches b
e8 N C RESENTATON-FIRE PROTECTON 9/28/81 G 1867-28
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ENCLOSURE 6 FIRE PROTECTION REVIEW OPEN ITEMS - MIDLAND 1/2 Question #1:
The staff will require early warning detection in all areas which contain safety-related equipment, conduit and/or cable trays.
Fire areas involved: 1, 6, 7, 9, 10, 12, 14, 15, 23, 24, 25, 33, 42, 43, 50, 52, 73C, 73D, 83, 89, 90, 91, 92.
Discussion:
The staff pointed out that fire detection is required in all areas containing at least one channel of safety-related systems and canponents. CPCo asked if cabling was defined as a component, and the Staff agreed to provide a res-ponse.
The Staff said that duct-mounted fire detectors are not acceptable and that area detectros should be used. CPCo said a review of the installation of fire detectors would be done.
Response
Areas 1, 7, 24, 25, 89, 90, 91, 92 - CPCo feels there is no problem -
reviewer need to visit plant site to agree.
Areas o, 9, 10, 12, 14, 15, 50, 52, 83 - CPCo must evaluate the need for detectors if the definition of safety-related equipment includer cables ( see summary).
Areas 23, 35
-2, 43 - CPCo agreed to evaluate the need for additional detector s in these areas.
Areas 73C, 730 - the staff agreed these areas presently meet requirements.
Question #2:
The staff Will require 1 1/2 inch fire hose stations for either primary or secondary protection for all areas containing safety-related equipment and/or cable trays - conduit.
Fire areas involved: 7, 9, 10, 718, 80, C7, 88, 95, 95A, 958, 95C.
r Discussion:
CPCo stated that there is an FSAR commitment to provide an effective hose stream to all plant areas and that field verification of this ability is under way. The Staff questioned whetner sufficient fire main and hydrant isclation was provided near the diesel gene. :or building and service water pump structure. CPCo said they would check this and add isolation valves, if necessary.
, Areas 7, 9,10, 80, 87 - CPCo feels there is no problem - reviewer needs to visit the plant site to agree.
Area 88 - CPCo will evaluate the addition of an isolation valve.
Areas 95, 95A, 95B, 95C - CPCo agreed to re-evaluate the need for additional hose stations.
Area 71B - the staff agreed this area presently meets requirements.
Question #3:
Has a postulated exposure fire been considered in all areas of the plant as outlined in Revision 35 and 37 of the Fire Hazards Analycis (FRA)?
Fire areas involved: 8,14, 15, 42, 43, 62, 64, 66, 73, k 73C, 74, 75, 89, 94.
Response
CPCo stated that a postulated exposure fire has, in fact, been considered for these areas in FSAR Section 9A.2.
Question #4:
Have automatic sprinklers been provided in all areas where 20 feet has not been obtained between redundant safety-related and for safe shutdown cable trays and/or equipmentf Fire areas involved: 11, 23, S1, 92, 93, 95
Response
CPCo stated that automatic sprinklers have been provided in all areas where safe shutdown cables do not meet separation criteria, unless an exposure fire is considered unlikely in the area. These cases are listed in FSAR Section 9A.2.
The Staff agreed that they would have to perform a visit to :he plant site to verify the adequacy of the design.
Question #5:
Fire barriers used for protection of safety-related equipment and/or cable trays should have a fire rating exceeding the in-situ combustibles and/or exposure fire.
Fire areas involved: 13, 24, 25, 39, 63 fasponse:
Areas 13, 39, 63 - After discussion, the staff agreed that t a present design meets the requirments.
Areas 24, 25 - The FSAR presently describes certain fire barriers as having a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rating when they in fact can be rated for 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.
CPCo agreed to amend the FSAR
4
.,,. i Question #6:
One hour ' fire rating on cable tray and/or conduits requires all structural supporting members to have the same fire rating.
Response
This requirement is understood and has been conplied with.
Question #7:
Need additional information on the fire retardant material used to achieve a one hour fire rating.
Response
This infonnation will be supplied after CPCo has selected which material will be used ts acnieve a 1-hour fire rating. The material selected will be subject to NRC approval. CPCo stated that a discussion of cable and tray wrapping is given in FSAR Subsection 8.3.3.
Question #8:
We will requiro rolling type fire doors +o separate the turbine building from other safety-related buildings.
Fire areas involved:
36, 39, 65
Response
CPCo stated that the doors in arecs 36 and 39 are dead doors and therefore rolling doors would not be appropriate. The reviewer stated that his j
agreement on all three areas was contingent upon a site-visit.
Question #9:
l Is hydrogen piping run through any safety-related areas?
Response
CPCo needs to complete a detailed plant walkdown prior to responding to i
t.his question. CPCo stated that it will verify whether large, high-pressure hydrogen piping for the turbine generator is run through areas containing safety-related comporents.
The Staff stated that its position on this piping is that it shoid be sleeved or relocated out of the safety-related area.
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,,.. Question #10:
Is a alternate shutdown provided for the control room such that safe hot shutdown c;n be achieved without its use and electrical circuits?
Responje:
This item was addressed in the discussion regarding safe shutdown and control room fires.
Question #11:
How does loss of transformer effect emergency diesels (area 98)?
.esponse:
CPCo stated that the diesels are not affected.
Question #12:
Is loss of ventilation systems alarmed in the control room?
Response
CPCo stated that alcrms have been included in the control room for high hydrogen concen; ration and loss of ventilation in the battery rooms as discussed in FSAR section 9A.l.7.
Question #13:
Was loss of offsite power considered in all cases for each area in the FHA?
Response
CPCo stated that loss of off-site powLr was considered in all cases.
Question #14 Isolation valves are needed for all laterals to each fire hydrant (ref.
page 9A.3-50).
Response
CPCo stated that post-indicating valves (PIV's) have been provided to meet the intent of the requirements. Addition of one more valve will be evaluated between the two laterals to the Diesel Generator building.
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Question #14:
Does RCP meet ; Appendix -R -(ref: page 9A.3-58)?
Response
' A contract has -een issued to NUS Corporation to design a system that-will meet the requirement.
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