ML20049J718
| ML20049J718 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 03/12/1982 |
| From: | Davidson D CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | Tedesco R Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8203190282 | |
| Download: ML20049J718 (29) | |
Text
e
.l Ii 14 -
i' Il
? 11 P O BOX 5000 e CLEVELAND, OHIO 44101 e TELEPHONE (216) 622-9800 e ILLUMINATING BLDG e 55 PUBLIC SOUARE
- "9
- 0 # I ' "' " '" "" ### "
Dalwyn R. Davidson viCE PHE 5lOf NY Lysit M E NG!NEImNG AND CONS 1HUC f 60N
.s D
(k OJ n
March 12, 1982 i
. j.+ e3
,)
~
T,Rl3lbbd' h Robert L. Tedesco 1
Assistant Director for Licensing ii d n > t ## #" '/
Division of Licensing M W3 ((""
g U. S. Nuclear Regulatory Co::: mission
'v',
y Washin6 on, D. C.
20555
.gy (p,
t f.
Perry thclear Power Plant Docket Nos. 50-W0; 50-W1 Response to Questions Raised on PNPP Fire Protection
Dear Mr. Tedesco:
This letter and its attachments are submitted in response to HRC questions on Perry Ihclear Power Plant's (PNPP) Fire Protection program. These questions were discussed in a meeting on February 9, 1982, between NRC representatives of the Chemical Engineering Branch and PNPP representatives.
Contact Rebecca B. Coffey, PNPP Licensing, if you have any further questions.
Very Truly Yours, N
l 0
Dal R. Davidson Vice esident System Engineering and Construction DRD: mlb cc:
John Stefano 9) 0 Jay Silberg, Esq.
Max Gildner j
f foh 3
F
Question Topic 1:
Qualifications of the fire pu=ps, controllers and their installation.
Response
Itmps and controllers are U. L. listed and installed in accordance with NFPA Standard 20.
i I
l l
1 1
Question Topic 2:
Supervision of valves in the fire protection water supply system.
Response
All valves in the fire protection water supply are supervised. Where the valves are internal, they are electrically supervised by valve monitor switches. Outside post indicator valves (PIV's) will be locked open with a padlock. Valve position will be checked at a 31 day frequency, b
Question Topic 3:
Fire pu=p rated capacity in relation to largest water decand.
Response
The rated capacity of the fire service water pumps exceeds the demand of hose streams @ 500 GIE plus the largest open nozzle water spray systen protecting equipment required for safe shutdown. At the time of the n'tH study the greatest water demand was estimated to be 2700 GIM (indicated on page 5-27 of the FPER). Since that study was done, the water requirements have been re-examined and the water requirenent is now less than the rated capacity of the pumps.
Page 5-27 of the FPER will be revised to reflect this new water requirement.
Question Topic 14:
Fire water supply for the hose standpipe system in the reactor building.
Response
The fire water for the hose standpipe system in the reactor building is supplied by a single seismically-supported pipe. Outside the reactor building, there is a cross-connection between the firewater pipe described above and the safety-class emergency service water system. This cross-connection provides a second reliable source of water for the containment standpipes.
Question Topic 5:
Spacing of hose stations throughout the plant.
Response
PNPP hose station locations shall be such that at least one effective hose stream will be able to reach any location that contains or presents an exposure fire hazard to structures, systems, or com-ponents important to safety. This includes locating hose stations outside drywell with adequate lengths of hose to reach any location inside the dry well with an effective hose stream. It will not be necessary to utilize a hose station located in one division to provide the required effective hose stream for a fire in the redundant division.
For example, a hose station will be added outside of the cable / spreading area to conform to this design criterion.
In addition, a study is being done by CEI's A/E to verify compliance with the above criteria.
l 7
Question Topic 6:
Size of standpipe supplying plant hose stations.
Response
The following design criteria, used for the calculation to deson-strate the adequacy of standpipe size, exceed the requirements of UFFA Standard No.14, and therefore exceed the criteria used for the original design. Where calculations show that the existing design does not meet the new criteria, the standpipe shall be increased in size as necessary.
I:erign Criteria:
1.
All interior hose stations are designed for Class II service and sized for a cinirm flow of 100 gallons per minute at 65 psi at the hose station outlet.
2.
The calculations will be based on:
A total flow of 500 Epm fron both internal building and external (yard hydrant syster) hose streams.
3 When a hazard area is within reach of several internal hose streams, the calculations will include simultaneous water flow from
(
rultiple hose streams.
4.
Water flow frc= hose streams will be based on hose stations located on the same floor level and within the same building as the area being protected.
5.
'Ihe water flow from outside (yard hydrant system) hose streams is the difference between the 500 gp: (recuired allowance frc:
all home streams) and the internal building j
hose er, ream protection.
6.
The water supply for the standpipe and hose system will b e based on rated capacity of the fire pumps.
Tne naxirm water pressure available will be based en the fire p=p relief valve settings.
l l
f i
Question Topic 6:
(Iage 2) 7 In areas of the plant where fixed fire suppression systems are located, the calculations will be based on a simultaneous operation of both the fixed fire suppression system and all fire hose stations whose hose streams would reach the area protected by the fixed fire suppression system.
a.
Tne demand for the fixed water spray system will be based on " automatic" Sprinkler Corporation of Arezica's (ASCoA) calculations.
b.
The demand for sprinkler systems will be based on the density curves of NFPA 13, Table 2-2.1(B) for the largest 1' ire area within the protected area of the system, but, with an area of sprinkler operation not to exceed 3000 square feet.
1 Question Topic 7:
I Selection of fire suppression aEent for the control room.
l
Response
The Cleveland Electric Illuminating Company changed the initial design proposal from use of Halon 1301 to carbon dioxide as the primary suppression aEent in the control room subfloor area in response to the HRc's 1974 SER on the construction permit for Ferry 1 which stated HRC concerns on the use of halogenated compounds in the control roo=.
The 1974 SER on Perry 1, CP stage, reads as follows:
i "We stated our concerns in Section 9.4.1 of the SER, regarding the use of haloEenated compounds in, or in the vicinity of, the control room, due to the reported detrimental effects on operating personnel of these halogenated compounds as well as their pyrolyzed end products. We also expressed our concerns regarding the potential artificial aging or disabling of the safety-related charcoal beds in the control room...
l In response to our concerns, the applicants propose in Amendment 17 in the PSAR, to remove their Halon 1301 firefighting system from the control room complex and replace it with a carbon dioxide (CO ) fire extin--
2 guishing system which will be per:mnently installed in the cable spreading area under the raised control l
room floor...
I We find that the proposed use of CO2 in the firefi hting 8
system of the control room complex will not adversely decrease the habitability of the control room since CO2 is stable and will not produce any toxic decomposition -
l products when used as a fire extinguishing agent. We conclude, therefore, based on our review, that the proposed design criteria for the fire fighting systems in the control room complex are acceptable."
(p. 9-17)
Since the NRC found the CO2 system acceptable in a 1974 CP/SER on Terry 1, it is inappropriate for IEC now to require PNPP to change l
the CO2 system back to a Halon 1301 system as long as both systems i
can provide an equivalent level of fire protection. CEI will perform
]
an acceptance test for the CO2 system prior to fuel load to assure i
that adequate CO2 concentrations can be maintained for 20 minutes l
Cuestion Topic 7:
(Iage 2) as required by UFPA 12; this will assure an equivalent level of protection.
CFI will co==it to three ceasures to assure that personnel safety cannot be endangered by C0 :
- 1) breathing apparatus will be available p
in the control room; 2) the alarm initiated by smoke detectors in the subfloor area is zoned to indicate Wich floor section requires attention for canual firefighting, if needed; and 3) should the control room become uninhabitable due to a fire, a renote shutdown panel can be canned on elevation 620' 6" of the control co: plex.
Question Topic 6:
Activation of the carbon dioxide extinguishing systems in the diesel generator rooms.
Response
The carbon dioxide extinguishing systers in the diesel generator roots will be activated automatically instead of manually.
Question Topic 9:
Supervision of Auto =atic Fire Suppiession System Detection Circuits.
Pesponse Where an automatic fire suppression system (which requires fire detectors for its operation) is provided to protect equipment re-quired for safe shutdown, one of the following detection arran6ements will be utilized:
- 1) Class A supervision of the system activation detection circuit, or
- 2) Class B supervision of the system activiation detection circuit plus an independent Class A c=oke detection system (this consists of Class B wiring between the smoke detector panels and the czoke detectors and Class A wiring for the remainder of the signalling circuitry)
Question Topic 10:
Secondary power supplies for all fire detection systems.
Response
Section C-6a(6) of the SRP states that primary and secondary power supplies should satisfy the provisions of Section 2220 of NFEA 72D, and that this can be acco=plished by using normal offsite power as the primary supply with a 4-hour battery supply as secondary supply; and by providing capability for manual connection to the Class lE enerEency power bus within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of loss of offsite power.
The normal and reserve tattery chargers associated with the 125VDC power system, and the normal and alternate inputs for the 120 VAC UPS system are powered from norcal 460V plant power with provision of being canually transferred to Class 1E diesel generator power.
This power distribution schere concurs with Section 2223.b of NFEA 72D, with the exception that the 4-hour battery requirement is not cet.
The battery for the 125VDC system is capable of a 15 minute duty cycle, and the battery for the UPS system is capable of a one hour duty cycle. However, on loss of offsite power, the fire suppression and detection loads can be transferred to diesel generator power within 15 minutes.
(The only exception to this is in the case of a LOCA. On LOCA initiation, the 4.16kV stub bus, which connects the fire suppression and detection loads to Class lE power, is tripped.
In this case the 15 minute interval from the LOCA initiation until when the stub bus can be re-connected to Class 1E power may be exceeded.
However, this would affect the power supplied to the fire suppression and detection loads only if a LOCA is simultaneous with a loss of offsite power condition. This is a double contingency, and does not have to be postulated.)
Furthermore, Section 2223.e of NFPA 72D states that if two or more engine driven generawors are provided in addition to the primary i
l power supply, a battery is not required.
If a Joss of offsite power l
would occur resulting in the need to transfer to Class lE diesel --
l tacked power, the power would be supplied by the Class lE Division 2 diesel generator. However, if the Division 2 diesel generator is not available, the Division 1 diesel generator can be used to power the stub bus via the Class lE 4.16kV system tie breakers. This l
cross tieing of the Division 1 diesel can not be accomplished within the 30 second lititation of Section 2223.e of UFPA 72D, but it can l
be accomplished within the 15 minute duty cycle of the 125VDC system
<attery.
l l
t
Question Topic 10:
(Isge 2)
Although the specific details set forth in any one of the provisions of Section 2220 of NFPA 72D are not ccepletely ccc1 plied with, the reliability of the power sources used to power the fire suppression and detection equi cent is considered to be comparable to that of a I
system r.eeting Section 2220 requirements.
Cuestion Topic 11:
Local audible fire alar =s.
Response _
Au fire fighting and evacuation activities win be coordinated from the Unit 1 Control Room. No local fire alarms have been provided due to the fact that cany areas in the plant viu not be manned during nor:al plant operation. In the event of a fire, an alarm will be sounded in the Secondary Alarm Station located in Unit 1 Control Room which is manned 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day. B e control room operator will then send an experienced fire fighter to investigate the alarm, i
mis individual, along with the control room operator, will coordinate' all fire fighting and evacuation activities. If evacuation of the area is required, the control room operator will use the plant PA 4
system to direct unnecessary plant personnel away from the fire, to safe locations, while the fire is brought under control by the PPD I
fire brigade.
i j
Tnis procedure for fire fiChting and evacuation has distinct ad-vantages over local fire alarms:
1.
All activities are coordinated from the control room, which is,
j canned 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day.
1 2.
If evacuation is required, personnel are directed away from the fire and the possibility of panic due to unnecessary evacuation is minimized.
I 3
Fires win be investigated and fought by experienced individuals trained specifically to fight fires and all unnecessary individuals will be directed away from the area.
l
\\
l t
i
Question Topic 13:
Qualification of fire barriers and penetration seals.
Response
Fire rated penetration seals for conduit, cable tray or piping penetrations vill be qualified as a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> barrier in accordance with the ASE4 E-119 test.
Fire rated barriers throughout PNPP have been designed as three hour fire-rated barriers as follows:
1.
Doors - UL labeled per UL10B 2.
Frames - UL labeled per UL63 3.
Hardware - UL listed / stamped 4.
Walls -
a) Concrete - Ratings per Portland Cement Association, Research Departtent Bulletin 223, " Fire Endurance of Concrete Slabs as Influenced by Thickness Aggregate Type and Moisture" b) Gyprum - Ratings per NFPA Handbook 14th Edition, Section 6, Chapter 7,
" Structural Integrity During Fire" and " Estimates of Fire Resistance by Interpolations" (see attached calculations).
ASU4 C-36 " Type X" gypsum board (see attached letter to R. S. Bittle from U. S. Gypsum Association of 04/13/77).
1 U. S. Gypsum Company's 08/17/81 letter to R. S. Bittle of Gilbert Associates confirming the fire protection capability of GAI's wall assembly design (letter attached).
c) Metal Clad (Exterior) - Ratings per U. L.
Design No. U635 5
Fireproofing (steel) _ U. L. Designs - UL N718 UL x736 x744 UL x733
Question Topic 11:
4 Ex.ergency Lighting.
Response
Ihe applicant will provide eight-hour battery pack emergency lights in areas of the plant necessary for safe shutdown and along routes of access and egress to those areas.
I b
l l
l i
{
t l
l l
Question Topic 15:
Carpeting in the control room.
Response
We will use the criteria of Alii on acceptability of carpet in the control room.
'Ihe position of AIiI is that t.arpet which has a critical radiant flux figure acceptable for use in hospital corridors or rest homes (where the occupants may not be ambulatory) is safe for use in the control room. Of all the test methods available, the critical radiant flux cethod is considered best for carpet installed on the floor (See liFPA 253). AITI requires a minimum CRF figure (the higher the figure, the better the perfor=ance of the caterial) of.45 watts per square centimeter for control rooms.1 The carpet we have celected, "14obility" by Collins and Aiken, has a CRF figure of 1.1.
In addition, the PGCC " Fire Hazards Analysis and Design Evaluation",
Appendix C of ITEDO 10466-A, prepared by Professor R. B. Willierson, states as follows on p. C-4:
"The desi n basis fire and its consequences in the PGCC E
floor section are described in the UCB test report.
The consequences of such a fire would not affect cabling in adjacent fire areas...There is a customer option to install carpet on the floor covers, but this would not affect the fire in the duct. 'Ihe carpet would not ignite from the fire in the duct and it would not change the results of the UCB tests."
This statement further supports our decision to place carpeting in the PGCC control room due to its low potential fire hazard.
1See letter from AITI to Jack Grier, GAI, of 12/12/81.
Question Topic 16:
Esoke Detection in the Control Rocn.
Response
C=oke detectcrs chall be provided throughout the control room.
Tne alarm from these detectors will annunciate in the control room via the plant fire and security monitoring system.
r"
Raestion Topic 17:
Irovision of water type portable fire extinguishers for the control rocc.
Response
In addition to the carbon dioxide fire extinguishers provided for the control room, we vill provide extinguishers suitable for use on Class A hazards.
'Ibe type selected and the quantity provided shall be in accordance with the requirements of NFPA Standard No.10.
t
Question Topic 18:
Fire extinguishers for contairment.
Response
A co=plement of fire extinguishers shall be located at the entrance to contain:ent.
These extinguishers shall be carried in during emergency fire situations. During shutdown a supply of fire extinguishers vill be taken into and kept in contain=ent during raintenance operations. A procedure shall be established substantiating this co :ittent.
These extinguishers will back up the fire fighting capability supplied by the standpipe hose stations and the carbon dioxide system for the reactor recirculation pu=ps.
Question Topic 19:
Oil collection system for the reactor recirculation pu=ps.
Response
Each reactor recircu]ation pump motor utilizes self-lubricated bearings.
An upper reservoir containing 52 Eallons of lubricating oil surrounds the upper guide bearing and thrust bearin6 A lower reservoir contain-ing 7 5 gallons of lubricant surrounds the lower guide bearing.
The lubricating oil system is contained within the metal motor housing with no external parts. An engineered oil leak collection system is not necessary at FNPP because the potential hazard from lube oil has been r.iti ated by the design of the pump and motor E
lubricating system.
C..2estion Topic 20:
3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> separation of diesel Nel oil day tanks from diesel generators.
Response
Each of the diesel generators are separated from each other and from the remainder of the plant by fire barriers having a minimum fire resistance rating of three hours. The design is such that the entire contents of any one diesel generator room could be lost without affecting the redundant diesel generator and inhibiting the safe shutdown process.
However, in order to mini -ize potential fire decage within any one of these rooms, they have been provided with extra protection as follows:
a) Automatic carbon dioxide fire extinguishin6 systems designed for operation when the diesel is running without affecting the diesel, b) An ionization type smoke detection syste=
independent of the carbon dioxide syste=
to provide early warning of a fire.
c) Coating of the day tank and its supports with a fire resistive coating equivalent to 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.
d) An oil collection pan beneath the day tank with a drain tied into the drainage system for the room.
For your review as requested, we have enclosed a series of 4 drawings of the FNPP diesel generator rooms.
l
Question Topic 21:
Drainage for Evitchgear roo=s.
Response
It has been deter =ined that a raxinn: water level of 4 inches could be tolerated in the switchEear roo=s without endangering the switchEear operation.
It is anticipated that hose streams would be used on fire in these areas only as the second line of defense.
If two hose streams were used simultaneously a water flow of approximately 200 GPM could be predicted. Drainage in or adjacent to switch ear areas is such that the predicted waterflow would not E
create any appreciable accumulation on the floor of these areas.
9
Question Topic 22:
Fire barrier separation between the Reactor Build-ing, Intermediate Building, and Fuel Han414ng Building.
Response
Penetration (including rattle spaces) in fire barriers which separate the Peactor Building, Intermediate Building, and Fuel Handling Building from each other will be sealed with a penetration seal rated at 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.
l
Question Topic 23:
Fire Detection for } bel Handling Building.
Response
A automatic fire detection syste= shall be provided for the fuel handling building railroad bay area.
These detectors shall be installed in accordance with manufacturer's reco=cendations.
1
Question Topic 25:
Analysis of safe-chutdown capability.
Response
In accordance with section 9.5-1 Eranch Technical Position (BTP)
ASB 9 5-1, position c.4.a(1) of the IaC Standard Review Plan (SRP) and Section III.G of Appendix R to 10 CFR Part 50, cabling for redundant safe shutdown systems should be separated by wa n s having a three-hour fire rating or equivalent protection (see Section III.G.2 of Appendix R).
That is, cabling required for or associated with the primary method of shutdown, should be physicany separated by the equivalent of a three-hour rated fire barrier from cabling required for or associated with the redundant or alternate method of shutdown.
PNPP and its Architect / Engineer, Gilbert Co:mnonwealth, has completed an analysis of the safe shutdown capability of the power plant to identify locations where circuits serving redundant equipment are routed through a common fire area.
(This analysis.is beins reviewed
~
byASB.) Eleven examples of inadequate cable separation were dis-covered. In every area where problems were identified, a solution was developed to mitigate the potential fire hazard.
In some cases the recommended solutions meet the requirements of Section III.G of Appendix R.
In other cases, the recommended solutions do not reet Appendix R requirements but are thought by PHPP to provide an equivalent level of fire protection. PHPP will submit, by separate letter, a complete description of each proposed solution but two exanples are presented below:
1.
Control Building El. 574' 10" Fire Area CC-1/ Fire Zones CC-la, CC lb, CC-lc Problem Redundant safe shutdown related cable exists in Fire Zones CC-la, CC lb, and CC-lc, without adequate divisional separat, ion.
There is a low cctbustible lo' ding in these zones (under1/2 l
a hour each) and partial' fire barriers between equipment. Therefore, the following fire protection design modifications will be provided:
Solution A 1-hour' cable tray wrap on b'oth trains of cable tray will be f
provided;-
Opgrade the existing smoke detection system'in fire zones CC-la, CC lb, and the south end of fire zone CC-lc.
This solution will provide an equivalent level of fire protection to that required by section III.G of. Appendix R.
,j
+
/
2
Question Topic 25:
(FaSe 2)
El. 679' 6" 2.
Control Building 1 CC-6 Fire Zone Problem Redundant safe shutdown cables exist in Fire Zone ICC-6, with The com-h5 feet separation between redundant cable divisions.
bustibleloadingintheareaisunder1/2hourandDivision1and 2 cables are separated by 45 feet.
Therefore, the following fire protection design modifications will be provided:
Solution A 1-hour cable tray wrap on one train of cable tray and.a smoke detection system for early warning fire detection vin be pro-This solution vill provide an equivalent level of fire vided.
protection to that required by Section III. G of Appendix R.
6 e
ATTACIC4EUTS 12/28/81 from American Raclear Insurers (ANI) to Letter of 1.
Jack Grier, Gilbert Associates, describing Control Room Carpeting Criteria.(Question Topic 15)
Letter of 08/17/81 from Elmslie W. Wharton of U. S. Gypsps 2.
Company to R. S. Bittle of Gilbert Associates stating the accept-ability of Gilbert Associates 3-hour non-load bearing gypsum wallboard wall assembly design.(Question Topic 13)-
A calculation of Structurs.1 Integrity During Fire by Gilbert Associates of 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> gypsum wall assembly.(Question Topic 13).
3 Letter or 04/13/77 from U. S. Gypsu: Association to Mr. R. S.
4.
Bittle describing the AS24 c36 test criteria for gypsus wa11 board; note that GAI's wall assembly design calls for wallboard meeting ASD4 C36 test. Attachments describe similar wall designs and their laboratory tests.
(Question Topic 13)
(Question A series of four drawings of the diesel generator rooms.
5 Topic 20)
._