ML20062D686
| ML20062D686 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 11/14/1978 |
| From: | Reid R Office of Nuclear Reactor Regulation |
| To: | Stewart W FLORIDA POWER CORP. |
| References | |
| NUDOCS 7811280382 | |
| Download: ML20062D686 (20) | |
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UNITE 3 STATES
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NUCLEAR REGULATORY COMMIS$10N g
WASHWGTON, D. C. 20085 November 14, 1978 I Docket No. 50-302 Mr. W. P. Stewart Director, Power Pros;ction Florida Power Corporation P. O. Box 14042, Mail Stop C-4 St. Petersburg, Florida 33733
Dear Mr. Stewart:
We are reviewing the Crystal River Unit 3 fire protection program as described in your June 22, 1977 submittal and have detemined that the additional information requested in Enclosures 1 and 3 s~
4s necessary to continue our review.
In addition, the NRC staff positions in Enclosure 2 must be addressed. You should be paparmt 40 discuss these items at the forthcomfag fine protection Ttte virit.Thovember-28 -tecembert) and you are requested to provide your written response within 30 days from receipt of this letter.
Sincerely, h
hl-Robert W. Reid, Chief Operating Reactors Branch #4 Division of Operating. Reactors
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.J Enclosures.
1.
Request for Additional Infomation
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2.
NRC Staff Positions 3.
Request for Drawings
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cc w/ enclosures:
See next page 1
7811280 %
Florida Power Corporation cc: Mr. S. A. Brandimore Vice President and General Counsel P. O. Box 14042 St. Petersburg, Florida 33733 Crystal River Public Library Crystal River, Florida 32629 I
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UCLOSL1tt 1 CRTSTAL RIVER LTIT 3 Docket No. 50-302 REQLTST FOR ADDITIONAL INFORMATION
- _ INDEI 1.
Combined Tire and Security Emergency 2.
Tire Hazard Analysis 3.
Instrument Air Systen 4.
Valve Concern 5.
Failure Analysis 6.
Effect of Eatinguishing Agents n, w
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Safety Related System Interlocked with Tire Fighting Systen 9.
Fire Brigade Equipment
- 10. Shared Emergency Equipment
- 11. Operation, Maintenance, and Testing Procedures
- 12. Renoval from Service Procedure
- 13. Fire Barrier
- 14. Steel Structures
- 15. Safety Areas Without Fire Protection
- 16. Curbs and Drains
- 17. Piping Containing Coebustibles
- 18. Pipe and Ventilation Duct Penetrations
- 19. Diesel Fuel Transfer Shut-Of f
- 20. Combustible Fluid Reservoirs and Storage 21.
Interface Between Safety and Non-Safety Equipment
- 22. Cable Insulation Materials
- 23. Prevention of Fire and Seoke Spread 24 Ventilation System Power and Control
- 25. Preventing Recirculation of Ventilation Air 1
- 26. Autaastic Operation of Fire Dampers / Doors
- 27. Separation of Reduedsat Communication Systems
- 28. Prostaity of Regular and Emergency Lighting Wiring
- 29. Fire Detection System Desiga
- 30. Tire Suppresstoa Systes Desiga
- 31. Requirseents for Manual Hose Stations
- 32. Fia-type Hose Rack
- 33. Fire Hazard at the containment Cable Penetration
- 34. Portable Eatinguisher Rating
- 35. Tire Hazard Associated with the Plant Computer
- 36. Remote $butdown Panels r
- 37. Radiological Consequences of a Tire 38-71 Plaat Specific Concerns 2-t-
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1.
Combined ytre and Security Eserneocy Describe the responsibilities of key plant personnel, in the event of a combined fire and security emergency.
2.
ytre Essard Analysis Discuss the capability to safely shutdown the reactor in the event of a destga basis fire in each plant fire area. This discussion should include:
(1) A description of the methods available to safely shut down the reactor and remove decay heat. The general functional require-seats should include but not be limited to:
(a) the ability to scattor and control primary systes coolant inventory; (b) the ability to monitor and control reactor neutros level, to assure suberiticality is asistained; (c) the ability to remove decay heat to bring the plant to a cold shutdown condition;
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(d) auxiliary services such as cooling water, lubrication, control air and ilVAC for the components performing these general functions.
(2) A desertption of the electrical power and control requirements for each shutdown sethod.
(3) A description of the location of the equipment, and the routina of electrical power and control cable required for each method.
with respect to each individual bounded fire area.
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e (4) A description of the systes redundancy which esists to insure its capability to carry out its intended function. Describe any other systems which can alternatively perfore the required
- function, (5) Tor electrical systems, provide ene set of the electrical distri-bution diagraee, earked showing the boundaries of the required power distributica.
The consequences of a design basis fire in es:h bounded fire area should then be evaluated to determine the effects of that fire on the plant's safe shutdown capabilities. A design basis fire is assumed to disable all equipeent within a bounded fire area and all equipment associated with cabling passing through an area.
Provide the results of this evaluation, with its basis to include the consequences of a design basis fire in each bounded fire area with respect to the plant's safe shutdown capabilities. In those areas where a destga basis fire could effect a safe shutdown, provide a sumanary of the existing and proposed fire protection for the area, and a justificatica of the adequacy of this this fire protection. Fire protection for the area incl.ades detection, suppression capabilities.
flame retardant coating, physical separation, separation by strinite, j
separation by conduit, etc.
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3.
Instrument Air System Verify that the ef fects of a fire on the instrument air system will not cause a transient more severe than those already analyzed in the (SAR.
4.
Valve Concern (1) Provide a list of remote operated valves, with their f ait positions, in safe shutdown systems identified in No.1.
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(2) Discuss the possibility of fire induced faultings in electric circuits causing such valves to fail in unsafe positions.
(3) Describe the provision and accessibility to manually operate these valves, if necessary, during the shutdown operation.
(4) Since fire induced faultings could be a common mode failure, discuss the possibility that a fire in the cable spreading roos, the control roce, etc., could fail a certain combination of valves, in safety-related systems, in such positions as to cause an accident which is more severe than those analyzed in the TSAR.
5.
Failure Analysis Provide failure analysis which verifies that a single failure does not impair the primarr and bacaun fire suppression capabilities (active or passive). The analysis should include consideratica of failures in the suppression systes, the fire detection system or the power sources for such systems.
6.
Effects of Extinautshing Atents Provide the results of an analysis which shows that rupture or inadvertent operation of a fire fighting systes will not subsequently cause damage or failure of safety-related equipment required for safe shutdown.
7.
I.ishtning Effects Describe the means provided to prevent Inghtntng from inattating fires which could damage safety-related equipment. Desertbe the means provided to prevent lightning f ree damaging the fire protection system.
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Safetv-Related Systems faterlocked with Fire Finhtina Systems Identify any safety-related systees or their sua111 aries which are interlocked to and could be disabled by operation of a fire fighting system.
9.
Fire Brinade Equipment Describe the equipment provided for the fire brigade. Describe means that will be used to either override the locking mechanise, or breach a barrier to provide fire brigade access and personnel egress in the event of a locking mechanise failure. Describe the training and tools provided for this purpose.
10.
Shared Emertency Equipment List the emergency equipment that is shared or proposed to be used by both the fire brigade and the security tese. Provide the results.of an analysis that demonstrates the number of units available and unit (or system) design is adequate to support a combined fire-security energency.
- 11. Operation, Maintenance, and Testing Procedures Provide a sumery of the procedures established to control operation, esintenance and testing of fire protection (detection and suppression) systems and components.
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- 12. Removal free Service Procedure Provide a summary of the procedures estabitshed to control the disaretog of any autoestte or manually actuated fire protection systee. Identify the management posatton responsible for authorizing
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the disaressent and the means used to assure the system ts returned to i
normal.
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- 13. Fire Barriers Identify fire barriers, doors, dampers and seals that do not have three hour rating. Tor those barriers, describe the fire rating of the associated doors, ventilation dampers and seals for cable, pipe and ventilation duct penetrations.
- 14. Steel Structures Identify areas which contais unprotected structural steel. Describe the type of existing or proposed fire protection.
- 15. Safety Areas Without Fire Protection Identify all areas that contain safety-related equipment and/or cables in open cable trays that are not provided with either fire detection or automatic fire suppression. Justify the lack of either of the above.
- 16. Curbs and Drains (1) Provide the results of an analysis which shows that drains have sufficient capability, and/or equipment pedestals have sufficient height to prevent standing water from sprinklers and fire hoses free damagtng safety-related equipment or supporting syst ems necessary for safe shutdown of the plant. As an alternative.
show that the standing water does not damage such equipment.
(2) Identify the areas containing safe ahutdown equipment t hat are not provided with floor dratns. Desertbe the drainage path for those areas without drains.
(3) Identify the areas containing combustable liquids that are not provided with floo r drains. Desersee the drainage path and provisions for contatning or diverttag the combustible liquid in 7
6 those areas without drains. In those areas with drains, state the capability and location of the drain reservoirs and describe the provisions to prevent the spread of flaseable liquid fires via the drain system to areas which may jeopardize safety-related equipment.
(4) Provide the results of ar. analysis that shows that curbed areas surrounding combustible liquid tanks have sufficient capacity to contain the full contents of the tanks plus the quantity of water required for extinguishment of a fire involving the combustible liquid.
- 17. Pipine Containina Combustibles (3
Identify all piping containing flaasnable gas or combustible liquid which is routed through areas containing safety-related equipeent, safety-related cables or though which personnel sust pass to reach safety-related equipment for local operation. Provide an analysis to show that a fire involving the liquid or gas will not prevent safe shutdown or result in the loss of function of a safety-related system.
18.
/ipe and Ventilation Duet Penetrations Provide the results of an analysis which shows that the fire barrier
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penetration seals for pipe pesetrations and ventilation ducts are adequate to prevent the spread of smoke and fire through the barrier considering the combustible loading and possible att pressure differential.
- 19. Diesel Fuel Transfer Shut-Off Describe the seans provided to autoestarally and/or manually stop the i
transfer of diesel oil. rom the bunser tanks to the diesel generator day tanks in the event of a fire to the area housing the day tank, or i
i through watch the fuel otl transfer piptog as routed.
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- 20. Combustible T1uid Reservoirs and Storate Provide a listing of all fixed tanks and pumps which contain oil or other combustible fluids, and indicate the location of the container and quantity of combustible fluid contained. Describe the fire protection provisions associated with each such location.
- 21. Interface Between Safety and Non-Safety Equipeent c
Certain cables electrically connected to equipeent necessary for safe shutdown may be used for functions designated as non-safety related and therefore classified as non-safety related. Examples of these might be remote indicating lights for valves breakers, etc. Describe whether such cables are kept with the safety division to which they T
were originally connected and if not, describe the effects on safe shutdown equipment due to shorts to these cables as a result of fire.
- 22. Cable Insulation Materials Identify whether flame test procedures were performed on electrical cables. Provide the acceptance criteria and results of the flame tests.
- 23. Preventton of Fire and Seeke Spread I
Describe the sanner in which fire and sacke are prevented from spreading free area to area via the the normal and emergency ventilation systems in all parts of the plant areas. Describe the location, actuation method and fire rating of daspers used for f are and smoke control in both air supplf and return air systess. Describe the details of interlocks for ventilatson systes shutdown or mode f
change that can be utilized for fire and smoke control.
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24 Ventilation Systes Power and Control Identify the areas where ventilation systems power supply or controls are located within the area they serve. Provide the basis for leaving ventilation systes power and control cables within the area they serve.
- 25. Preventina Recirculation of Ventilation Air Describe the separation between the air intakes and exhausts for normal and emergency ventilation systems and the provisions which prevent smoke from being drawn back into the plant.
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- 26. Autoestie Operation of Fire Dampers / Doors Discuss the arovisions for automatic closure of ventilation fire dampers and fire doors in all areas protected by total flooding as suppression systems and provisions for re-opening the fire dampers remotely for post fire smoke venting.
- 27. Separation of Redundant Communication Systees Describe the proximity of the cables for redundant coansunication systees to each other at the contatneent penetration. Identify anv 2
parts of the plant to or from which communteation by all systees nic" be lost to a single fire and discuss how the communication will be maintained during the fire energency.
- 25. Proxistty of Regular and Emergency Lighting Virtna Provide the results of an evaluation of the potential for a fire in a safety-related area to cause damage to electrical wtring whteh would result to the loss of both regular and energency ligftting to areas providing access for fire fighting and/or safe shutdown operations.
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- 29. Fire Detection Systes Desian Provide design data for the automatic fire detection system in each fire area, including such items as type, number, and location of the detecton; and signaling, power supply and supervision of the systes.
Identify any deviation (s) from NTPA 72D.
- 30. Fire Suppression States Desian Provide the design data for all automatic suppression systems (both existing and proposed) including such items as design densities, soak times, power supplies, and associated alares. Identify areas of non-compliance with appropriate NFPA standards.
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- 31. Requirements for 'tanual Mose Station _s Provide the results of a study which verifies that the manual hose stations confore to all the recommendations contained in NFPA 14.
Verify that all points of safety-related areas and other areas with major fire hazards can be reached with the hose line stored at the manual hose stations.
- 32. Pin-Type Hose Rack B
Verify that the pin-type rack, if used, is approved to store the rubber lined hose by the hose manufacturer.
- 33. Fire Hazard at the Containment Cable Penetration Identify the consequences on safe shutdown of a fire at the cable penetration area on either side of containment..
- 34. Portable Extinauisher Ratina Verify that at least one portable estinguisher in the control room has a Class A rating.
- 35. Tire Hazards Associated with the Plant Computer Provide the results of an analysis which demonstrates that a fire within the computer area will neither expose any safety-related equipment, nor affect the safe plant shutdown. Verify that the barrier around the area is compatible with the combustible loading in the area.
- 36. Remote Shutdove Stations
( i Identify the locations from where remote shutdown can be accomplished and provide the res21ts of analysis to demonstrate that no fire which could impair the control from the control roce could also prevent the contrcl from these areas.
- 37. Radiological Consequences of a Tire Evaluate the radiological consequences of a fire in radwaste areas and areas containing contaetnated saterials such as filter cartridges, spent resin, etc.
PIANT SPECITlc CONCIRNS Referenced page number in Florida Power Corporation's subetttal are indicated in parenthesis followtag the question.
- 38. Clarify statement on 480 volt and D.C. power cable betag in the same tray (5-11). -.
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- 39. Provide technical inforestion substantiating effectiveness of fire retardant coating esterials used in the plants (5-15).
- 40. Justify lack of emergency back-up lighting for all safety-related areas in addition to egress lighting now being provided (5-36).
- 41. Provide locations of breakers controlling safe ' shutdown equipment (5-39.40).
42= Provide justification for not including cable insulation within inter-locked armor in combustible inventory.
43' Provide li'st of safety-related equipment.
'N 44, Justify quantities of gasses stored in the following areas:
Propane Elev. 95 Zone 7 Control complex Acetylene Elev. 95 Zone 9 Control Complex Acetylene Elev. 119 Zone 2 Inter. Building
- 45. Provide justification for not including cable insulation withta inter-locked armor in fire load.
46.
Resolve difference in separation of cable trays as noted an Page 5-44 as contrasted with those noted on Page 5-12,13. and 14 (5-44).
47.
Provide rating of fire barriers Radiation Protection Service Room for east and south walls and penetrations (Section 5 of THA Area /rone 3.
Elevation 95).
48.
Provide rating of other barriers and penetrations where FHA only gives fire resistance rating on certain walls..
- 09. Provide information as to how long safe shutdown ability would be asintained with the loss of battery chargers (Elev. 104 ft.
Ares / sone 6).
- 50. Justify position that cable tray covers could limit fire between redundant divisions (Elev. 108 ft. -- Area / zone 7).
- 51. Describe in detail the extent of the loss of communication systems with the loss of Zone 3 - Elev.124 - Control Complex (Elev. 124 -
Ares / zone 3).
- 52. Amplify as to the extent of the loss of communication systems with the loss of Zone 3 - Elev.124 - Control Complex (Elev.124 - Area / zone 3).
- 53. Explain combined fire zones such as Auxiliary Building, Elev.119 -
Zones 8, 9, 10, and 15. Justify calling this one zone in view of the fact 4 zone numbers are assigned.
- 54. Describe hazardous locations that the automatic CO system covers in 2
Turbine Building on Elevation 45.
- 55. Provide list of safety related and non-safety related cables located in concealed ceiling above control roce; provide fire analysis for this space.
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- 56. When will the results of the planned cable fire tests be
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(Page 5-9)
.57._ Will all parts of the fire detection and signalling system, including individual fire detectors, continue to function i
if normal AC and DC power sources are interrupted?
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fication is required.- (Page 5-18)
- 58. Are the hose threads on yard hydrants and interior fire hose stations compatible with the local public fire departments?
(Page 5-25) 59.
It is unclear whether, all areas containing safety-related equipment and electrical cables can be reached with an effective fire stream using existing hose at the hose stations.
(Page 5-26)
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- 60. Justify the use of Halon 1301 as the fire suppression system in the cable spreading room from an effectiveness and re-liabilig stan@::oint..
-( 2aga _5.221 61. Provide an analysis of the potential water damage fron fire-fighting in the Control Complex, considering the lack of floor drains in this area.
(Page 5-29)
- 62. Are there areas where the fire could cause loss of all lighting such that effective manual fire suppression in safety-related areas would be precluded?
(Page 5-36)
- 63. What is the basis for concluding that a fire loading of 80,000 Btu per square foot is equivalent to 1-hour severity, and what method was used to establish equiva-lent fire severity in other areas having different fire 3
m) loadings?
(Page 5-44) i
- 64. What data supports the assumption that cable tray fire separations of 3 feet horizontally and 5 feet vertically will prevent fire spread?
(Page 5-44) 65.
In the fire safety analysis, was potential fire damage to redundant ele ~ctrical cables in conduit (from fires in cable trays or other combustibles in ene area) given
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consideration?
This question applies to numerous areas where it is stated that there are cable trays from one or both divisions, but there is no indication if there are redundant circuits in conduit in. the same area which could be damaged by a single fire.
I 66.. The function of redundant cables and the effect of their loss on safe shutdown should be identified in the following-areas:
A.
Battery' charger room 3A B.
Inverter room 3B C.
-Inverter room 3A D.
Heating and ventilation MCC area (IS, 119, A/Z4)
E.
Personnel access area (IB, 119, A/Z5)
F.
Hallway (AB, 95, A/Zl)
G.
Hallway (AB, 95, A/Z5)
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E.
Hallway (AB, 95, A/Z8)
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Miscellaneous radwaste rooms (AB, 95, A/Z10 and 12)
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Open area (AB, 95, A/Z13)
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maar-*=P 4eo4entetec m HIS,4, -*ft14 i L.
RCP seal injection filter room ( AB, 95, A/Z15)
M.
Equipment hatch area ( AB, 95, A/Z16)
N.
Sea water pump room (AB, 95, A/Z17)
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Pump and tank room (AB, 95, A/Z32)
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P., Nuclear service heat exchanger room (AB, 95,.A/Z33)
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Hallway a.a.d stairwell (AB, 119, A/Zl)
R.
Hallway (AS, 119, A/Z5) 5.-
Penetration area (AB, 119, A/Z7)
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Equipment hatch area (AB,. 119, A/Zl8)
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Area outside reactor compartment (RB, 95, A/Zl) 67.
Justify the adequacy of a 1/4 inch metal plate as the fire
.y barrier between the cable spreading room and the redundant ESF switchgear rooms below.
68.
Provide information on the plant breathing air supply, per
' the requirements of Appendix A to BTP 9.5-1.
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Will the deluge _ system renain functional..upon loss of. D C.-peer?
. (Page 5-27) Will the loss of D. C. voltaae neg(ate the automa start action of the fire service water pthps? Page 5-23)
- 70. How will three tons of the five ton total capacity of CO2 be reserved for fire protection? (Page 5-28) 71. How often and by what means are "POC" interlocks tested for the reactor building purge supply and exhaust fans? (Page 5-31) 1.
' Enclosure 2 NRC STAFF SISITIONS P-1.
There are several areas in the fire safety evaluation which contain safety-related equipment or cable trays for which no fire detection is provided or proposed. Fire detection should be provided for such areas having significant com-bustibles, which appears to include:
A.
Heating and ventilation MCC area (IB,119, A/Z4)
B.. Neutralizer room (AB, 95, A/Z6) (AB, 95. A/Z14)
C.
Reactor coolant evaporator room D.
Waste transfer pump room (AB, 95, A/Z19.and 20)
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Decant and slurry pump rooms (AB, 95 A/Z21, 22 and 23)
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Waste gas rooms (AB, 95. A/Z24 and 25)
G.
Wasta and recycle pump rooms (AB, 95, A/Z26, 27 and 28)
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Nuclear sampling room (AB, 95. A/Z34 and 35 I.
Seal return coolers and makeup tank rooms (AB,119, A/Z11, 12and13)
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Decontamination room (AB,119, A/Z19)
K.
Control rod drive cooling water filter room (AB,119, A/Z23) 1-2. Jhse stztfonswfth thew 11ty to reach allareas containing significant amounts of electrical cable, and areas which could be involved in a reactor coolant pump oil leak fire should be provided inside containment.
P-3.
Due to the significant quantity of combustible material involved,an oil leak collection system should be installed on each reactor coolant pump.
P-4.
Air flow monitoring of the ventilation exhaust from each battery room should be provided with loss of flow alarming in the control room.
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CRYSTAI, RIVER UNIT 3 DOCKIT No. 50-302 REQtIST FOR DRAVINGS Florida Power Corporation is requested to have the following drawings on band when the review team visits the plant site.
1.
Scale drawing of fire service water systes marked with valve supervision and proposed modification (s) in the systas.
2.
Ventilation and drain diagrams of various areas in the plant.
3.
Electrical one-line distribution diagrass.
4.
Electric tray layout prints.
5.
Control prints for each of the fire pumps.
6.
Elevation drawings of the plant.
7.
Tire protection drawings for proposed ano existing suppresston systems.
8.
Fire protection drawtags for proposed and extsting portable extinguishers.
9.
Fire protection dravtags for proposed and extstans sanual hose stations.
10.
Fire protection drawings for proposed and existing deteetton systems.
- 11. General arrangemer.t drawtag of the Fire Service Pump House.
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