ML20064E231
| ML20064E231 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 11/09/1978 |
| From: | Gilleland J TENNESSEE VALLEY AUTHORITY |
| To: | Varga S Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7811150123 | |
| Download: ML20064E231 (85) | |
Text
I i
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November 9, 1978
~
i Director of Nuclear Reactor Regulations Attention:
Mr. S. A. Varga, Chief Light Water Reactors Branch No. 4 Division of Project Management j
U.S. Nuclear Regulatory Commission Washington, DC 20555
/
Dear Mr. Varga:
~
37 i
i In the Matter of the Application of
) Docket No 50-327,
Tennessee Valley Authority 50-u e l
j g
l Enclosed are TVA's responses to the fire protection review questions from the Auxiliary Systems Branch transmitted in your September 1, a
1978, letter to N. B. Hughes. These responses will be incorporated into the next amendment to the Sequoyah Nuclear Plant Final Safety i
Analysis Report.
Very truly yours, 1
/
. E. Gi leland Assistant Manager of Power i
Enclosures:
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s.o AUXILIARY SYSTEMS BRANCH FIRE PROTECTION REVIEW SEQU0)AH NUCLEAR PLANT - UNITS 1 AND 2 DOCKET t< UMBERS 50-327/328 1.
Your submittal provides only part of the information requested in to our letter dated September 30, 1976. A fire hazards analysis should be conducted for each plant fire area, and the effects of postulated fire involving permanent and/or transient combustibles on systems, circuits, or equipment required for safe plant cold shutdown should be evaluated.
The fire detection and primary and secondary fire suppression systems for each area should also be indicated.
In the fire hazards analysis you should identify all the redundant mechanical and electrical systems necessary for safe cold shutdown which are separated only by distance (no fire barriers). The fire hazards analysis should demonstrate that, assuming failure of the primary suppression system, a fire in installed or transient combustibles will not damage redundant trains or divisions of systems required for safe plant cold shutdown. Where this cannot be demonstrated, an alternate means of assuring safe plant shutdown (cold shutdown) should be provided.
\\
TVA Response Fire suppression and detection systems are provided in the various plant areas as identified in Table 1-1.
A discussion of the sequoyah fire hazards analysis will be provided by Detember 15, 1978.
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. s TABLE l-1 The following table summarizes the fire protection systems provided in the Sequoyah Nuclear Plant. The table covers only those areas where an unmitigated fire could affect a unit's ability to reach and maintain a safe cold shutdown condition.
Notes:
(1)
Refer to the SK-1000 series of compartmentation drawings in the Sequoyah Nuclear Plant Fire Protection-Reevaluation for the location of the tabulated areas.
(2) The compartmentation fire rating column identifies the rating of the most limiti'ng component in the compart-mentation boundary. Refer to the response to question 3 for additional compartmentation information.
(3) Refer to the response to question 12 for a discussion of the fire retardant coating of exposed cable trays.
(4) Legend:
I - Ionization smoke detector IR - Infrared flame detector
(
LT - Linear thermistor PE - Photoelectric smoke detector RC - Rate compensated thermal detector T - Fixed temperature thermal detector
TABLE l-1 I
9 F
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,g eia uutttt ua u....
- o...~
FIRE m5 5
~
z RETARDANT 55 00 M
w$
.t00ri TYPE OF COMPARTMENT COATING OF Cdr E*
zE a
BUILDlHG ELEV.
NO.
ROOM NAME FIRE. PATING L.XPOSED CABLES yyy 5y ygg
@g gy gl9 3
E 5 g3 FIRE DETECTOR $
EA5 ciS USE UU 20 5E CONTROL 669.
Cl MECHANIC %L EQUIPitENT 1-1/2 HR.
X X
X I, RC Ci MECHANIr ECU!P? ENT' 1-1/2 HR.
X X
X I, RC C-250V,0ff tu p1 Na. 1 1-1/2 Hr..
X X
X I, RC C4 25UV BAT " IUAr 0 RN NO. I 1-1/2 HT.
X X
I CE 250V BATit,sf I-0AG Pft f.0. 2 1-1/2 HR.
X X
.I
(. t 250V BAl' r/ RM NO. 2,
1-1/2 HR, X
X X
I, RC C?
24V & 48/ i:t.TTERf RM 1-1/2 HR.
X X
X
! RC
"}
"V'& 48. 3AT. 80. & CHARGER Rf1 1-1/2 HR.
q rf..tv4! CATIONS RM X
X 1-1/2 HR X
X X
- 4. n dir. tCAL EQUIPMENT 1-1/2 HR.
X X
I, RC J
e 1-1/2 HR.
X X
X g
ij S:Af" 1-1/2 HR X
X C
ST4d 1-1/2 HR.
X X
685. 1 C1 UNIT I AUX. INSTRUMENT RM 1-Y/2 HR.
X X
X X
I. RC C;
CORRIDOR 1-1/2 HR.
X X
X X
X X
I, RC C4 UNIT 2 AUX. INSTRUMENT Pf1 1-1/2 HR.
X X
X X
I, RC Cl STAIR 1-1/2 HR.
X X
C; STAIR 1-1/2 HR.
X X
706. J C1 CHART STORAGE 3 HR.
X X
X X
C;-
X X
'X X
X C1 STAIR 1-1/2 HR.
C2 STAIR X
X 1-1/2 MR.
X X
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- - M =.
Er dS C
m EUILDIliG CLE7. 40.
- Cort firJ
- E FIRE. RATING
..XPOSED CABLES yy zg ggy jy y
gk DETICTORS FIRE a: a. >.
a n.
o=
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X X
X C2 JAN I TOR",
- d.,1 ;
1-1/2 HR I*, RC X
CJ CORRibR X
X 1-1/2 114.
X C4 KITCuift X
X
! RC 1-1/2 HR, X
C5 T0!LE T X
X RC 1-1/2 HR.
X C6 LOCKIR RM X
X I, RC 1-1/2 HR.
X C7 SHOWER X
X I, RC 1-1/2 HR.
C8 SHOWiR X
X 1-1/2 HR.
X X
C9 INST. Call; 1-1/2 HR.
X X
X Clf SHIFT ENGR. GFFICC 1-1/2 HR.
I, RC X
X X
C11 SHIFT ENGR. CFFIfE 1-1/2 HR.
I, RC X
X X
C12 FAlti CONTREL RM.
1-1/2 HR.
I, RC C1:i RELAY RM X
X I"
1-1/2.'t.R.
X
.X Clz RECORD STOPAGE 1-1/2 HR.
X X
X' I, RC
- LOCATED IN FILTER DUCTWOPK Af40 GENERAL AE'A.
" LOCATED IN CABINETS AND GEr ERAL AREA
"* CLOSED HEAD SPRAY Ift CHARCiAL FILTERS.
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,51.r Al WASTE 90trw TArv X
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Al COnimit X
X A2 HOLDt# TR: 4 4 ffi A X
X I
A3 If0LDUP TAfr: R%M C X
X 1
A4 FLOOR DRAI:s (OLL Pts 4P &
FILTER R'U4 X
X 1
A4 f. FLOOR ORA!r. Cull TANK ROOM X
X 1
X 1
A6 5UPfP FUttP i:W1 X
X 1
A7 Sutt? TAriK ROON X
X A8 CONTAlfettroi SPRA% 18-8 1-1/2 HR.
X X
I A9 CONTAINMENT SPRAY PLHP 1A-A 1-1/2 Hk.
X X
AIC RHR PLHP R00t1 18-8 1-1/2 HR.
I X
X I
All PHR PUMP ROOM 1A-A 1-1/2 HR.
X X
A12 RHR PUMP ROCH 2A-A 1-1/2 HR.
X X
Al:
PHR PUMP ROOM 28-8 1-1/2 HR.
I X
X A14 CONTAlf4 tiff 4T SPRAY PUMP 2A-A 1-1/2 HR.
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Alt CONTAlfif1Ef17 SPRAY PUMP 28-B 1-1/2 HR.
I X
X 53.0 Alf PIPE CALLERY 1-1/2 HR.
A17 PIPE GALLERY X
X 1-1/2 HR.
569.0 Al CORRIDOR X
X I
X X
A2 VALVE GALLERY X
X X
A3 GA5 DECAY ROOM X
X 85407 X
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X X
I AS GAS DECA) o it X
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I AG AUX f fetu 'F9 PJb 1A-A 1-1/2 IfP-X X
X 1
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X X
X 1
AS PIPE GAttr Gy.L CliA5E X
X
.X I..
A9 CHAPGIf4G,W I A-A 1-1/2 HR.
X X
X 1
Air otAp;ING nyp 18 8 1-1/2.HR.
X X
X All CHARG!r4G r iP IC-C 1-1/2 HR.
X X
X 1
Alf SATETY ItW DION PUMP ID-B 1-1/2 HR.
X X
X I
Ali SAFETY Iri:LCTIOri PUMP 1A A 1-1/2 HR.
X X
X I
A11 CASK DEC0r.rN. COLL. TANK ROOM X
X X
I A15-SPENT RESl?i TANK ROON X
X X
I Alf VAliE GALLLPY X
X X
g A17 WASTE EVAP PACKAGE X
X X'
I All' Aux WASTE EVAP PACKAGE X
X X
Alt SAFETY INJECTI0rt PUMP 2A-A 1 1/2 HR.
X X
X 1
A2' SAFETY INJECTION PUMP 28-B 1-1/2 HR.
X X
X 1
A21 CHARG!!;G PUNP 2C-C 1-1/2 HR.
X X
X
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A2P CHARGING PUMP 2B-B '
1-1/2 HR.
X X
X I
A21 CHARGING PUMP 2A A 1 1/2 HR.
X X
X g'
A24 PIPE GALLERY & CHASE X
X I
A2f' PIPE GALLERY 1-1/2 HR.
X X
X I
A2t AUX. FEEDWATER PUMP 2A-A 1-1/2 HR.
X' X
X
'l A2; CONCENTRATE FILTER X
X X
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X A4 PADIO,CHF." U 2.
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X X
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X 1-1/2 HR I
X A6 PIPE GALLI v.
X X
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A7 VOL CONTFCf i'!M ROCM 1-1/2 HR.
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A8 FEACTOR PL 7, ACCESS 0001 3-HR.
X X
I M
VALVE GAtt: Tr X
X Alt SEAL t,iATir -DT EXCdANGEle 1A X
X X
All HEAT EXCHET '."5 la X
X I
3 HR.
X Al2 !. EAT E tCHAMET.S 1A X
X I
3 HR.
X A12 $ AMPLE ROO*t I X
X I
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X Alc SAMPLE P0 ort !!
X X
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X A1!
ffEAT EXCliANGERS 2A X
X 3 HR, 1
X Alf HEAT EXCHAtoGERS 28 X
X 3 HR.
I X
Al7 SEAL NATER HEAT EXCHANGER 2A X
X X
Alf VALVE GALLERY X
X I
AIS PIPE GALLERY X
X 1-1/2 HR.
X A2C VOL COUR0t TANK ROOM X
X 1-1/2 HR.
A21 REACTOR BLDG. ACCESS Rff.
3 HR.
X X
I X
X I-
- IN CHARCOAL FILTERS
" LOCATED IN CHARC0AL FILTD DUCTS AliD GEN. RAL AREA.
- LOCATED IN CHARC0AL FILTEl-DUCTS.
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COMPARTMENT COATING OF C d :t 8"
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FIRE m
5E of CETECTORS MEO Ma ESU bU EO E2
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A2. VALVE CAL; ?Y X
X I
A2 CVC5 VALVt' ;/ LL ray X
X X
32 VAL'iE/CAu {n X
X I
A2 WASTE GAS.47.7 3 X
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A2+ WASTE GA5 M? A X
X I
X A?
DEC01 tat 11Mi'ON ROCH X
.X I,
X A2 PIPE CHASF X
X I
1-1/2 HR.
A2 PIPE'OtAsE X
X 1-1/2 HR.
A3 AIR LOCF X
X I
X X
A3 WASTE GAS At'tLYZER ROOM 706.
Al MAIN STEAff VALVE ROOM X
X I
^
A2 f1AIN STEArt VALVf ROOM X
X I
x x
I A3 WA5TE PACrl.SE AREA 1-1/2 HR.
A4 WASTE PACVAGE APEA X.
X I
X X
A5 CASK LOADING AREA 1-1/2 HR.
I X
X A6 ft STORAGE AREA 1-1/2 HR.
I 2
A7 CASK DECON ROOM X
X I
X X
I A8 FUEL TRANSFER VALVE ROOM A9 FUEL TRAi45fER VALVE ROOM X
X I
Al-MAIN STEAM VALVE ROOH X
X Al MAIN STEAM VALVE ROOM 8
X X
I A1, STEAM VALVE INST. ROOM'A X
X I
Al STEAM VALVE INST. ROOM 8 X
X I
Al-UHI EQUIP X
X
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X 95404 Alt UHI EQUIP X
X 1-1/2 Ho.
X y
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BUILDIZ (LEV. t:0.
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DETECTORS MEO Ma QSU
$U 80 42 amo om von mm aw 3 x AUXILIAM 114.0 Al 00litM ARN 1-1/2 HR.
X A2 HDT IflSTRH: Fr!T 5!U 1-1/2 HR.
X X
X 1
X X
.I A3 HGT. & Vln. Yt1 111/2 HR.
X X
X X
I A1 A!R LUCK X
X 1
AS VEf4T. & Pl.
AIR l'00?1 1-1/2 HL X
X X
X 1
A6 AIR LOCK X
X 1
A7 LETDOT4Iti, EXrPAr.GER X
X X
A8 LEIDOWN HFAI EXChAWGER X
X*
X X
1**. LT***
A9 VENT.' & T't). f.t AIR R00ft 1-1/2 HR.
X X
X X
I AIC AIR LOCK X
X All AIR LOCK X
X A12 HTG. & VEfF E00M 1-1/2 HR.
X X
X A13 AIR LOCK X
X 1
A14 AIR LOCK X
X A15 FUEL DETECTOR ROOM X
X X,
I A16 FUEL DETECTOR ROOM X
X X
- IN CHAPCOAL FILTERS
- LOCATEL' IN CHARCOAL FILTEF DUCTS AND GEN RAL AREA.
- LOCATED IN CHARCOAL FILTD DUCTS.
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z $:r Er di3 E
FIRE TYPE OF m
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X X
X X
A3 12SV 'JITAL :f7 1:i. RM !!
1-1/2 PR X
X X
X t
M 125 / Viitt 't T T.
PM I 1-1/2 im.
X X
X X
A5 4P,0V SHUTP si.. r00t1 IL2 1-1/2 HR.
X X
X X
A6 460V SHUIP' ?f CD. F0(tf 1?!
1-1/2 HR.
X X
g X
X A7 480V SHUTE W 1 3D. 900M TAl 1-1/2 HR.
X X
1-1/2 HR.
X X ~
1.-
X X
M 4E07 SHUTN u'i CD. ROOM 1A2 X
X 1
A9 PERSr# f4EL 1. ioulP ArCESS X
X 1-1/2 HR.
X
.I Alf STEAM GEN. I LtwDOWri X
X 1-1/2 HR.
X Al' REACTOR BL(q EQUIP HATCif 3 HR.
X X
1 Ali RE4CTOR ELC; ACCESS RM.
1-1/2 HR.
X I
X X
Al REFUELING PrC1 1-1/2 HR.
X X
I A1: FEACTCR SLOG ACCESS RM.
1-1/2 HR.
X
[
X X
Al' FEACTOR BLDG. EQUIP. HATCH X
X 3 HR.
Al' If*EPGE* ICY CAS TREATMENT FILTE:
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X X
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Ali PERSGt;;iEL & EQUIP. ACCESS X*
X X
1-1/2 HR.
X I",LT***
A1) 480V SffuTD0titi 80 ROOM 282 X
X 1-1/2 HR.
X X
1 Al' 480V SHU100Wii 80. ROOM 281 1-1/2 HR.
X X
X X
1 A2t 480*/ SHUTDCNN BD. Rom 2A1 X
X 1-1/2 HR.
X X
1 A21 480V SHUT 00WN BD. ROON 2AZ X
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X X
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I M1 6.9 d 'r *".c4 r:1 P'13 1-1/2 HR.
X X
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1 A25 AUX CONil:
I 5T. 01 1 A 1-1/2 HR.
X X
X X
g A26 AUX CCNTP isT. m 1B 1 1/2 HR.
X X
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g A27 AUX CONTR;
X X
X X
I
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X X
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X g
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X X
X X
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A2 480V BOARI R!1. 18 1-1/2 HR.
X X
X X
A3 125V VITAL tuTT. Pff !!
1-1/2 HR.
X A4 125V VITAL BATT. PM. I 1-1/2 HR.
X X
X A6 480V TRANSTORMER RM 1B 1-1/2 HR.
X X
X X
I A7 480V TRANSTOPMER RM 1A 1-1/2 HR.
X X
X X
I A8 MECH. EQUff ftfr4T RM.
1-1/2 HR.
X X
X X
I A8A HEFA FILTER PLENUtt PM.
1-1/2 HR.
X X
X A9 NECH. EQUIPMENT ROOM 1-1/2 HR.
X X
X X
I A9A HEPA FILTE1 FLENUM PN.
1-1/2 HR.
X X
X X
I A10 480V TRANSFORMER RM. 28 1-1/2 HR.
X X
X X
[
All 480V TRANSTOPRER RM. 2A 1-1/2 HR.
X X
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I A13 125V VITAL BATT. RM. IV 1-1/2 HR.
X X
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A14 125V VITAL BATT. PJf. III 1-1/2 HR.
I X
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A15 480V BOARD RM. 28 1-1/2 HR.
X X
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2.
Item n - Administrative Procedures, Controls, and Fire Brigade -
You plan to use administrative procedures, controls, and fire brigade programs previously accepted by the staff for the return to service of Browns Ferry, Units Nos. 1 and 2.
We request that you review these procedures against the staff supplemental guidance contained in " Nuclear Plant Fire Protection Function Responsibilities, Administrative Controls, and Ouality Assurance," dated June 14, 1977.
It is our position-that you either (1) confirm that your existing administrative procedures and fire brigade program meet the staff supplement guidelines, or (2) provide a commitment that they will be revised accordingly.
TVA Response Me are presentiv reviewing our administrative nroceduros, controls, and fire brigade programs against the staff supplemental guidance contained in " Nuclear Plant Fire Protection Function Responsibilities, Administrative Controls, and Ouality Assurance," dated June 14, 1977 We plan to revise these procedures accordingly.
e
3.
Item D, General Guidelines for Plant Protection A.
You state that the majority of the materials used will conform to NFPA definitions of noncombustible or limited combustible material. During our site visit, we noted that some materials such as ventilation duct insulation were not UL listed or FM approved. Therefore, modify your fire hazard analysis to include the limited combustibles or show that these materials will meet the criteria of Section C.4.a(4), BTP ASB 9.5-1, Revision 1.
B.
For the follow;ng listed items substantiate their fire resis-tance capabilities as they pertain to safety-related areas or high hazard areas by verifying that their construction will be in accordance with a particular fire tested design.
Identify the design, test method, and acceptance criteria.
(i) Rated fire barriers including floor, ceiling, wall systems, structural members and doors.
Indicate the type of protective material used and the design number in reference to ASTM E-119.
(ii) Fire dampers and fire doors, including the installation of the same in ventilating ducts penetrating fire barriers of safety related areas; fire door dampers are required in a 3 hr. rated fire barrier penetration.
(iii) Fire barrier penetration seals around ducts, pipes, cables, cable trays, and conduit or any other openings. Veri fy -
that the seals will meet the 3 hr. requirements for ASTM E-Il9. Verify that the inplant cable tray supports are similar to the ones used in the fire tests and that, in case of collapse of the trays, the resultant unsupported load and torque on the penetraticn seal will not affect the integrity of the seal.
C.
It is our position that where the fire loadings exceed a 1-1/2 br. duration (see Table 6-8A, Fire Protection Handbook) and thus, exposes safety related conduit-cables or equipment that such barriers be upgraded to a 3 hr. fire resistance.
Confina that your design will peet this position.
D.
You hw.. oc. responded to the Appendix A guidelines concerning-fire doors being locked and alarmed. Confirm that you will reet this-position.
In particular, all fire doors used to protect openings in the wall separating the control building from the turbine building be alarmed and annunciated in the control room. These circuits should be electrically supervised.
TVA Response A.
The duct insulation installed in safety-related plant areas has been tested by Underwriters Laboratories and has a flame l
spread rating 25 and s,oke driciered t a'ing cf 50.
TVA did l
not require the manufacturer to label tne duct insulation.
i 577043
B.
(1) Compartmentation has been provided in accordance with the SK-1000 series compartmentation drawings submitted in the Sequoyah Nuclear Plant Fire Protection Program Reevaluation.
These drawings indicate the boundaries where fire-resistive construction and assemblies will be utilized to maintain the integrity of fire areas and fire cells. Additional information is provided'in Table 1-1 showing the minimum fire resistive rating of the most limiting structural components in each area or cell.
A minimum three-hour fire resistive rating has been assigned to the construction between the following buildings:
Reactor Building and Auxiliary Building Control Building and Auxiliary Building Service Building and Au. iliary Building Control Building and Turbine Building The 3-hour and 1-1/2-hour fire rated wall and floor /
ceiling construction consists of reinforced concrete or reinforced concrete block. These ratings are assigned based on the equivalency to similarly rated construction denoted by Figure 6-7H of the NFPA Fire Protection Handbook and Data Sheet 1-21, Table 2, of Factory Mutual loss Prevention Data.
A minimum three-hour fire rated coating, Pyrocrete 102, is applied to all exposed structural steel within the cable spreading room. Applications are in accordance with UL Design flo. X-716 and Code approved design based on Design D-717 (BOCA R.R. 73-42-I-C-1-b).
Fire-rated door assemblies are provided for most fire cell and fire area boundaries. These doors have a fire resistance rating at least equivalent to that designated for the wall.
The remaining fire cells and fire areas are located in the Auxilia n Luilding and are provided with nonfire-rated, special purpose pressure or flood doors. These doors are iduntiff d in the SK-1000 series compartmentation dr n ir g 2:4 ara listed in Table 3.B.(i)-1.
TABLE 3.B.(i)-1 Door flo. Door Type Elevation Column A55 Flood door 690.0 s-t, Al A57 Flood-oressure door 690.0 r-q,Al A60 Pressure voor 690.0 r-s,Al-A2 A64 Pressure door 690.0 u-v,A15-Cl3 A77 Pressure door 690.0 u-v,Al-Si 577044
i TABLE 3.B.(i)-1 (Continued) f Door flo. Door Type Elevation Column A101 Pressure door
.706.0 u-v,A2-A3 A105 Pressure door 706.0 u-v,A13-A14 All2 Flood door 706.0 x-y,AS A115 Pressura door 706.0 w-x,A6-A8 Al23 Pressure door 714. 0 t-u,A3 4
A132 Pressure door 714.0 t-u,A13 A153 Pressure door 734.0 t-u,A8 A154 Pressure door 734.0 u-w,A8-A10 A173 Pressure door 734.0 u-x,AS-A6 A184 Pressure door 749.0 r-s,A3-A4 A191 Pressure door 749.0 r-s,A12-A13 A214 Pressure door 714.0 w-x,A12-A13 A215 Pressure door 714.0 w-x,A3-A4 These doors are designed to ASME Standards and are of heavy welded steel construction. They have multiple side hinges and multiple latch points on the sides, top, and bottom. TVA has evaluated these doors and determined that they will provide an equivalent fire rating comnien-surate to the fuel loading in the areas or cells that they separate.
Doors C44, C50, CSS, and C56 are nonlabeled security doors (refer to drawing SK-1007). These doors are made of bullet resistant heavy gauge steel and have not been tested by UL.
However, the manufacturer has certified that the doors are equivalent' to UL tested fire doors rated for three hours.
B.
(ii) Fire dampers and fire doors are provided in ventilation ducts when the ducts penetrate fire barriers. The dampers and doors have a fire resistant rating equivalent to the designated rating of the barrier. They are UL 4
listed and tested in accordance with UL standards 10B and 555.
B.
(iii) The design of the Sequoyah el'ectrical penetration fire L
stops aPfi: for cables and cable trays and their installa-tion are based on TVA tests of full-scale neckups that must, seal against air pressure. The tested design was nodified to provide a greater depth of sealant material to give protection equivalent to a 3-hour fire resistance rating. The modification was based on a similar design, using the same type of cables and sealant material, and I
tests cordocted by others to the stardard tine-temperature curve of A5Til E-il9.
i The design of the wall and floor electrical penetration fire stops through a fire barrier utilize a separate cable sleeve or slot for each cable tray. The design and installation of these pu.etration fire stops employ Dcw corning 3-6548 577045
silicone RTV (room temperature vulcanizing) foam as the sealant material and inorganic fire barrier materials.
From each side of the wall or floor opening, the cables are separated within the cable sleeve or slot using an inorganic fiber. The sealant material is then installed within the cable sleeve or slot.
The cable sleeve opening is covered with a fire barrier board that is cut to fit around the cables and cable tray configuration.
In addition, the exposed surfaces of cables are coated from the fire barrier board for a minimum distance of five feet or to the nearest electrical panel or enclousre with material similar to Flamemastic 77 that is approved by Factory Mutual Research Corporation. Typical electrical penetration firestops through walls and floors are shown in Figures 3.B.(111)-1 and 3.8.(fii)-2, respectively.
Conduit penetrations, containing cables, through designated fire barriers, utilize RTV silicone rubber as the sealant material.
This material is installed around the cables in either the end of the conduit termination or in the nearest available conduit box on each side of the barrier.
Inorganic fiber is used on each side of the sealant material.
Spare conduits are plugged or capped until used.
The sealant material used in cable tray penetration fire stops is Dow Cornino's 3-6548 silicone RTV foam (com-ponents A and B). This material in its cured foam state is noncorrosive and fire resistant. A sample of this material has been tested by an independent laboratory according to ASTM E84, standard-method of testing of " Surface Burning Characteristics of Building Materials." The result of the test was that the material has a flame spread rating of 20.
The fire barrier materials used in the design and instal-lation of the penetration fire stops employ a combination of inorganic fiber and fiber board similar to Johns-Manville Cerafiber and Cera Form Beard. These materials are made f rom exceptionally high purity alumina and silica constitueats and are capable of withstagding conginuous esosure to c tuperature range of 2000 to 2300 F.
TVA has conducted fire tests on full-scale assemblies of i
electricaPpenetration fire stops that must seal against air pressure. The required differential air pressure across the penetration under test was maintained by adjusting a nonnal damper togethe with an exhaust fan in the exhaust duct.
An enernal gn burner was loca:.ed uncer the cables outside the area of coated cables. The burner was ignited on the fire ? He ci test facility and allowed to burn for 30 minutes before shutoff. The fire was allowed to self-extinguish; therefore, no water spray test was conducted.
l l
577046
-I e
The results' of the tests were that no fire burned through the penetration onto the cold side of the test facility and pressure seal maintained its integrity. The results from the tests demonstrate that the design provides an effective fire stop and pressure seal under simulated conditions when tested as a completed system.
In addition, fire tests on similar designs using the same type of cables and sealant material have been conducted by others. The mockup was for a floor penetration arrange-ment. and was tested to the time-temperature curve of ASTM E-Il9. Test results are recorded in report serial No. 26543 dated October 28, 1975, of Factory Mutual Research Corporation.
The installed cable tray supports 'are similar to those used in the fire tests. From a review of the design of the cable i
trays supports tcgether with post-test observations of the TVA mockup, we have determined that in case of collapse of trays on the fire side of the barrier, no loss of seal integrity will occur.
The design of the inplant cable tray supports are typically shown in Figures 3.B.(111)-1 and 3.B.(iii)-2 for wall and floor penetrations with cable trays, respectively. During i
the tests. conducted by TVA, warpage of the cable trays 4
and supports was observed to occur outside the cable coated No visual distortion of the cable trays or their supports area.
was observed at the wall opening following the test.
The design of the mechanical wall and floor penetration i
fire stops through fire barriers are based on similar i
designs, using the same type of sealant and danning -
materials, and tests conducted by.;thers to the standard time-temperature curve of ASTM E-110 The design of the mechanical fire stops utilize mechanical duct and pipe sleeves for each penetration. Fire barrier penetration fire stops for pipe and duct penetrations consist of Foamed-in-place Dow Corning 3-6548 silicone RTV foa.a installed to a depth of 12 inches or the thickness of the wall
' minimum 8 inches). Typcial mechanical duct and pipe penetration fire stops of this type are shown in Figures '.".fiii)-3 and 3.B.(iii)-4, respectively.
In those pipe penetrations where pir iovements are present, t
a fire step assembly consisting of a
,11ed silicone foam coated ceramic fiber blanket is wrapped around the pipe and stuffed into the sleeve on each side of the penetration.
Airtight bellows seals are then installed over these fire stops. A typical fire stop of this type is shown in Figure 3.B.(111)-5.
l l
Fire tests un similar penetration fire stop designs have i
been conducted by Factory Mutual Research Corporation.
577047 1
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The results are recorded in Factory Mutual Report Serial No. 26543 dated October 28, 1975. The tests were performed following the procedures for evaluating floor-ceiling assemblies as defined under the Standard for Fire Testing of Building Construction and Materials ASTM E-119 (HFPA 251).
C.
The following safety-related fire cells have been identified fromthefiregazardsanalysisashavingafireloadinggreaterthan i
120,000 Btu /ft (1) Auxiliary Instrument Rooms (unit 1, 685.0-C1; and unit 2, 6B5.0-C4).
(2) Cable Spreading Room (706.0-C2).
(3) Diesel Generator Rooms (lA-A, 2A-A, IB-8, 28-8).
(4) Diesel Generator Lube Oil Storage Room.
(5) 480V Electrical Board Rooms (lA-A, 2A-A, 10-8, 28-B)
(6) Intake Pump Station (El. 705.0 Upper Deck-ERCW Pump Trains)
(7) Additional Equipment Buildings TVA has provided equivalent three-hour fire rated compartmentation for these fire cells with the exception of the Auxiliary Instrument Rooms.
The unit I and unit 2 auxiliary instrument rooms (685.0-C1 and C4) e' are separated from the Turbine Building and Auxiliary Building by minimum three-hour fire resistant barriers.
The Auxiliary Instrument Rooms are separated from each other by two 1-1/2-hour fire resistant barriers and the nonsafety-related computer room and a corridor.
(Refer to drawing SK-1006 in the Sequoyah Nuclear plant Fire Protection Program Reevaluation.)
i Although the fire loading of each Auxiliary Instrument Room exceeds a 1-1/2-hour duration, the fire loading consists mainly of exposed cable insulation in trays and all exposed cabling within the rooms is ceated with a fire retprdant raterial'similar to Flamemastic 77.
s In aoditico, encn Auxiliary Instrument Room is provided with an early warnir.g fire detection system that actuates an automatic total flooding CO, system. This is supplemented by a fire hose station located ih each stairwell.
t TVA feels that with these measures implemented, the two as-built 1-1/2-hour fire barriers that separate the safety-related Auxiliary Instrument Roers are acequate.
825342 i
D.
The fire doors listed in Table 3.0-1 are alarmed in the main control room through the security system. Refer to the SK-1000 series of compartmentation drawings for details showing door numbers and column lines. TVA does not propose to supervise the operation of other fire doors.
TABt.E 3.D-1 Door flo.
Building Elevation Column A3 Auxiliary 653.0 t-u,A6-A7 A4 Auxiliary-653.0 t-u,A6-A7 A5 Auxiliary 653.0 u-v,A6-A7 A6 Auxil ia ry.
653.0 v-w,A50A7 A8 Auxi!iary 653.0 v-w,A9-A10 A9 Auxiliary 653.0 u-v,A9-A10 A10 Auxil ia ry' 653.0 t-u,A9-A10 All Auxiliary 653.0 t-u,A9-A10 A25 Aux 11isry 669.0 t-u,A2 A46 Auxiliary 669.0 t-u,A14 All7 Auxilia ry.
706.0
..w-x,A3-A4 Al18 Auxiliary 706.0 x-y,Al2-A13 Al25 Auxiliary 714.0 u-v,A2-A3 A130 Auxiliary 714.0 u-v,A13-A14 A169 Auxiliary 734.0 q-r,All-A12 A170 Auxilia ry 734.0 q-r,A11-A12 A172 Auxiliary 734.0 q-r,A8-A10 A181 Auxiliary 749.0 q-r,A6 A182 Auxiliary 749.0 q-r,A4 A194 Auxiliary 749.0 q-r,Al2 A195 Auxiliary 74 9.0 q-r,A10 A203 Auxiliary 759.0 w-x,A4-A5 A204 Auxiliary 759.0 w-x,All-Al2 A207 Auxiliary 763.0 s-t,A6-A8 Cl Control 669.0 n-p,C3-C4-i C10 Control 669.0 n-p,C9-C10 C12 Control 669.0 n-p,C10-C11 C21 Control 685.0 n-p,C3-C4 C22 Control 685.0 n-p,C6-C7 C23 Control 685.0 n-p,C6-C7 C24 r^ntn1 685.0 n-p,C7-C8 C25 9 tal 685.0 n-p,C10-C11 9
C30 control 706.0 n-p,C3-C4 C33
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I i-l 825337 l
Doors separating the control building from the turbine building are normally closed, heavy equipment doors which are locked and operated by card readers. Operation of these doors (except for flood-pressure door C27) is alarmed in the main control room.
All of the heavy equipment doors separating the control and turbine buildings are augmented by 3-hour rated sliding fire doors which are held open by fusible links. There is no alarm capability associated with the sliding fire doors.
825338
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Item 3.e. - It is our position that fire stops be installed every 2U f t. iTong horizontal uncoated cable routings in areas not protected by automatic water systems. Between levels or in vertical uncoated cable chases, fire stops should be installed at the mid-height if the vertical run is 20 ft, or more, but less than 30 f t.
or at 15-foot intervals in vertical runs of 30 f t. or more unless such vertical cable routings are protected by automatic water systems directed on the cable trays.
Individual fire stop designs should prevent the propagation of a fire for a minimum period of 30 minutes when tested for the largest number of cable routings and maximum cable density. Confirm that your design will meet this position.
TVA Response In areas outside primary containment containing redundant divisions of systems, all exposed surfaces of cables in horizontal or vertical routings will be coated with a flame-retardant material such as Flamemastic 77. Thus, the design meets the stated tiRC position and no
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fire stops will be installed at intervals in horizontal or vertical routings.
(
117111
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5.
Item D.4, Ventilation - Describe the procedure employed for heat
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a Rf si2IKe removal using fixed or portable equipment in areas that house systems or components necessary for cold shutdown of the plant. Describe how these areas can be ventilated for manual firefighting purposes.
Include a discussion regarding control accesses to ventilation equipment (including fire dampers) as well as the ability to handle high temperature gases and particulates.
TVA Response In general, heat and smoke removal capability is provided in areas that house systems or components necessary for cold plant shutdown by the normal ventilatica systems discussed in FSAR Section 9.4.
A developing fire will cause the isolation of these ventilation systems in the immediate vicinity of the fire throu of fusible link or fire detector actuated dampers. gh the closing Snoke venting at this point will be accomplished by the use of portable smoke ejectors.
Two ejectors are provided for the use of the fire brigade and each is rated at 7200 cfm. Smoke will be vented from a fire area to adjacent areas, where it will be removed by the nnrmal ventilation systems.
l Those areas of the plant utilizing recirculating ventilation systems will rely upon portable smoke ejectors exclusively.
Due to containment requirements, smoke removal in the reactor building will be provided by the containment purge air system.
Should the smoke and fire gas temperautres exceed the capability of the containment purge air system, it will automatically isolate and smoke removal will be accomplished by the redundant trains of
(
the standy gas treatment systems.
577314
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6.
Item 0.5, Lighting and Communication A.
Item (a). You state that adequate emergency lighting system is provided in safety-related areas of the plant. Power supply for the system is from the plant emergency diesel generator.
Your proposed emergency lighting system is unacceptable.
It is our position that fixed self-contained lighting consisting of fluorescent or sealed beam units with an individual 8 hr. minimum battery power supply be provided in areas that must be manned for safe cold shutdown and for access and egress routes to and from all fire areas.
8.
Item (d).
You indicate that fixed repeaters are being installed in the Sequoyah plant to facilitate the use of portable radio equipment.
It is our position, however, that the fixed repeaters should be protected against exposure fire danage using 1/2 hour fire rated barriers such as 1" mineral wool.
In addition, verify that the portable radio communica-tion system will be tested to demonstrate that its frequencies will not interfere with the actuation of protective relays.
TVA Response i
A.
Item (a). Fixed self-contained lighting consisting of fluorescent or sealed beam units with an individual 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> minimum battery power supply will be provided in areas that must be manned for safe cold shutoown and for access and egress routes to and from all fire areas.
B.
. Item (d). The protection of fixed radio repeaters by 1/2 hour fire rated barriers such as mineral wool is not feasible since the repeater would be damaged by overheating.
It is TVA's position that such protection is not necessary due to the redundancy and physical separation of the repeaters.
1 There are three independent intraplant radio repeater systems at Sequoyah. Two of these systems known as the inplant repeaters, i
i' operate with 20 two-channel portable radios (this group includes tne six fire brigade portables).* One of these repeaters is located in the turbine building and one is located in the auxiliary buiiding, prosiding tui'.iple fire barriers between systems. The associated protables can address either of these repeaters.
The third intrapicnt repeater system (the public safety service repeater system) consists of one repeater located in the turbine building and 18 portable radios. These portable radios have three channels capable of addressing all three intraplant repeater systems. The public safety service repeater is located on a different turbine building elevation from one inplant repeater and in a different building from the other.
The portable radio communication system will be tested during the preoper4".tocal t:st reagio, to Jo:onstrata that its frequencies will not interfere with other plant systems.
117112
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t 7.
Item E.1, Fire Detection -.Your description of the fire detection f
system is incomplete. Describe the type of detector provided for each room or area conteining safety related equipment or systems.
Also, pro' vide a detailed description of the fire detection system, supported where necessary, by diagrams or appropriate prints (in-clude a single line dratwng from the detection circuits, waterflow i
alarms, through the subpanels and into the control room).
It is our position that primary and secondary power be supplied as follows:
A.
Using nornal offsitte power as the primary supply with a 4 hr. battery supply as secondary supply; and 1
B.
Having capability for manual connection to the Class 1E emergency pcwer, but within 4 hrs. of loss of offsite power. Such connection should follow the applicable guidelines in Regulatory Guides 1.6, 1.32, and 1.75.
Confirm that your design will meet this position.
TVA Response
(
The fire detection system is designed in accordance with f1FPA 720 and 72E.
The system consists of initiating devices, loccl control panels, remote transmitter-receivers providing remote multiplex (MUX) functions, and computerized multiplex central control equipment.
Refer to Figure 7-1 for a block diagram of the system.
The system's initiating devices consist of fire detectors which are identified as to type and location in Table 1-1 and flow alarm pressure switches which are provided for each fixed suppression system.
A central processor unit (CPU) communicates with the local control panels via the rer.ute MUX units over looped circuits. The MUX equip-ment allows the processor to interrogate each local control panel in turn and to receive data from the panels. When an initiating device changes from normal to a trouble or alarm status, it is detected at the remote MUX transmitter-receiver and when next interrogated by the central processor will transmit this status change.
The change is evaluated by t6e processor and visual and audible indications ornvided, j
An alarm conditiop results in the following system responses:
(1) Sounding of audible devices locally and in the main control room.
(2) lilumination of' indicating la.rps on the local control panel l
indicating the locaticn of the alanning device.
(3) Actuation of local control panel circuits for the control of automatic suppression systems, fire pumps, fire dampers, fire doors, and ventilation equipment.
577311
(4)
Identification of the location and time of receipt of the alarm condition on a cathode ray tube (CRT) display in the main control room and on a line printer in the unit 2 auxiliary instrument room.
The system is electrically supervised for ground and open wiring faults in the detection, power supply, alarm, and itUX data transmission circuits.
Supervision is Class A in the detection and data transmission circuits and Class B in local audible alarm circuits.
A wiring fault in the above circuits results in an audible and visual trouble indication at both the local and control locations.
displaying multiple alarm and trouble conditions.The system is capable o A second CPU is provided in the hain control room as an installed spare.
Upon failure of the primary processor, the spare can be connected to the system by jumper cables in less than 30 minutes.
The fire detection systen is powered from a single 120V ac distribution panel as shown in Figure 7-2.
The panel is provided with a manual transfer switch to allow normal or alternate power 1Al-A and 2Al-A, respectively. feed from 480V ac control and auxilia Both ventilation boards are auto-matically connected af ter 10 seconds to the emergency diesel generators on loss of offsite power.
The system's power supply complies with the applicable guidelines in Regulatory Guides 1.6 and 1.32 and partially complies with Regulatory Guide 1.75 as discussed in FSAR section 8.3.
The momentary loss of power to the CPU resulting from the transfer main control room.to the diesel generators will cause a loss of the CRT display in the alarm and trouble conditions will be redisplayed.However, when powe Fire detection system components are located as identified in Table 7-1.
iluclear Plant fire Protection Program Reevaluation for definitio the column lines.
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577312
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1 TABLE 7-1 i
Component Building Elevation Column Room Name Central processor unit Control 732.0 p,C7 Main control room and CRT display Line printer Control 685.0 p,C10 U2 aux. inst. room Local control panels
Located throughout plant -----------
Power distribution Auxiliary 734.0 t.A8 6.9 kV shutdown panel board room B 480V cont, and aux.
Auxiliary 734.0 t,A3 489V shutdown bldg. vent board 1Al-A board room 1A2-A Transformer 1
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. Auxiliary 734.0 u,A2 4dOV shutdown board room 1Al-A 480V c'ont. and aux.
Auxiliary 734.0 r,A13 480V shutdown b1dg. vent board 2Al-A board room 2A2-A r
Transformer 2 Auxiliary 734.0 r,A15 480V shutdown board room 2Al-A G
l 577313
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8.
Item E.2.c., Fire Protection Water Supply System - In Section E.2.c you state that the fire pumps at the Sequoyah tJuclear Plant are electric motor driven and are connectable to the emergency diesel genera tors.
Confirm that these pump motors will be connected automatically to the lE bus, upon loss of offsite power.
The required alarms and status are annunciated in the main control It is not clear that the pump monitoring system meets the room.
guidelines of BTP 9.5-1, Appendix A.
Therefore, verify that the fire pumps are individually monitored and the monitoring circuits are electrically supervised. Alarms indicating pump running, driver availability, or failure to start, should be provided in the control room.
TVA Response The electric motor-driven fire pump motors are powered by the 480V shutdown boards. Upon loss of offsite power, these boards are auto-matically loaded on the diesels.
Two minutes after the power loss, the fire pumps are in turn loaded on the 480V shutdown boards. ~ Alarms indicating that the fire pump switchgear has operated into a motor A
running condition and alarms indicating loss of line power on the line side of the switchgear are provided in the main control room. Neither BTP 9.5-1, Appendix A, or NFPA 20 require electric supervision of these monitoring circuits, and none has been provided.
6 682487
l 9.
Item E.3, Water Spr inklers and Hose Standpipe Systems A.
Item (a). You state that the fire protection system or plant equipment will be so designed such that a pipe break or a single inadvertent actuation of the fire protection will 4
not prevent the functioning of both trains of the safety-related system. This design arrangement is unacceptable.
It is our position that the safety related systems or equipment should be protected against moderate energy line cracks in accordance with BTP APCSB 3-1, by water shields or baffles.
B.
Item (d). Verify that the hose station will be able to reach any locations that contain or present a fire hazard to safety related equipment with at least one hose not over 100' long.
C.
Your submittal does not indicate the hourly fire rating of the protected openings in the stairwell.
Indicate their hourly fire ratings.
D.
Throughout your fire hazards analysis, you state that sprinkler systems will be installed in various areas of the plant. We observed during our site v.' it that the sprinkler systems were installed at the ceiling level. However, no provisions
(
-were made to locate sprinkler heads clear of overhead obstructions, especially in areas housing the auxiliary feed-water pumps and the component cooling water pumps.
It is our position that where such systems are to be installed that additional sprinkler heads be provided below any obstructions to obtain minimum interference to dishcarge patterns of the sprinkler heads on the floor below.
TVA Response A.
The Sequoyah fire protection system in safety-related areas is a seismically qualified, preaction sprinkler systen. This system is charged witn water only when a cross-zoned detector system enters the alarm state. To provide the operator continuous assurance of the integrity of the system in areas which are sensitive to water damage, low-pressure air supervision which alarms in the control-room is provided.
In addition, water shields are provided in areas where actuation of the fire protection system would unacceptably impair saf ety-ralated eceipment. This design philosophy complies fully with BT0 ed CSB 3-i, hections B.1 and B.3a which requires protection of assential systems and components against postualted piping failures in high or nederate energey fluid systems that operate during normal plant conditions.
B.
All areas of safety-related structures are within reach of fire hose stations equipped with 100' of hose.
I 117113
C.
The protected stairwells in the control building have equivalent 1-1/2 hour rated reinforced concrete and concrete block construction.
The plaster partition assemblies above the fire doors have a fire resistive rating at least equivalent to that assigned the wall construction.
Fire barrier seals around pipe penetrations in the stairwells are in accordance with the designs discussed in 3.B.
There are no cable tray or ducts penetrating the stairwells.
D.
Additional sprinkler heads shall be provided or existing heads relocated in order to clear overhead obstructions and obtain minimum interference patterns where possible.
's 117114
- 10. Safety related pumps of both trains for both Unit 1 and Unit 2 are contained in the Auxiliary Building elevation 653' and 660' area. Each train is in its own room however, no fire rated door separates the room from the corridor and adjacent pump rooms.
It is our position that each room be provilei with a 3-hr. fire rated door, mounted in an approved fire ra ted frame to properly protect the room.
in lieu of fire rated coors, provide a wet pipe sprinkler system to completely cover the corridor separating Unit No.1 from Unit No. 2.
The sprinkler system should alarm and annunciate in the control room.
TVA Response Three-hour fire doors are provided for each of the eight openings from safety-related pump rooms. At the time of the NRC site visit, these doors had not been installed.
117115
i
- 11. ' On elevation 690' of the auxiliary building at Al and V, all four power cables (both trains of both units) of the ERCW pump from the yard pump house come into a metal enclosure nounted on the concrete wall approximately 10 ft. above the floor. Each cable within the i
junction box is separated by a metal baffle. From the enclosure, the cables are run in conduits and go up the wall and through the ceiling.
We were informed that at the ceiling, all the conduits are supposed to be buried in concrete back to the switchgear room of the various trains and units.
it is our position that:
A.
Verify that these conduits are actually buried back to their L
switchgear rooms from the ceiling level above the junction box.
l B.
A 3-hr. fire rated barrier be installed around the metal enclosure as well as around the conduits located on the wall above the enclosure and terminating at the ceiling to protect against potential exposure fires.
In addition, we are concerned that the metal enclosure and metal baffles are inadequate to prevent an electrically initiated fire that i
may damage all power cablings in the enclosure. Revise your design of the metal enclosure and metal baffles to protect the cables such that an electrically initiated fire will cause damage to no more than one power train.
TVA Response A.
The conduits are not buried back to their switchgear rooms from the ceiling level above the junction box. The conduits ascend from the junction box-to elevation 734.0 embedded only as they penetrate floor slabs.
On elevation 734.0 the conduits terminate in cable trays that extend to the switchgear.
B.
A 3-hour fire rat.1 barrier around the junction box and conduits would cause an ur c.ceptable derating of the installed ERCW pump power cables.
in lieu of tne 3-~nour fire rated barriers, TVA will provide a 1" raineral wool barrier between the re~dundant power cables in the 4
junction Le as metection c;einst an electrically initiated fire. A fleec reater sp ay system will also be provided to protect the junction bqx and conduits on elevation 690' from installed and' transient exposure hazards.
Protection of the CRCW puup power cables on elevation 714' and above will be handled as discussed in tne response to question 12.
4 577315
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- 12. During our site visit we noticed nu.nerous places where redundant safety related cable trays as well as conduits were in close proximity to each other. This was noticed on ainost all elevations.
Some of these locations are to have flamemastic and preaction sprinkler systems iristalled at the interaction. At the time of the site visit the function of these various cables-conduit could not be detennined at these interactions.
It is our positon that:
A.
Identify all such interactions in the areas of both Units 1 and 2 where the redundant safety related trains are within 20 f t. of each other. Also, the consequence of electrically initiated or exposure fires should be evaluated with regard to plant shutdown capability (see item 1).
B.
For tnose areas indicated in item (A) above, where a fire can affect tne plant shutdown capability, an area automatic sprinkler system should be provided to afford protection against exposure fires. Also, a 1/2-hr. fire rated barrier such as l" of mineral wool should be provided to separate one safety related train from the other or from a concon exposure fire source. The sprinkler system shoudl alarm and annunciate l
in the control room.
TVA Response Response will be provided by December 15, 1978.
117116
f 13.
On elevation 690' of the auxiliary building at coordinate A-3 and T, all five (two from each unit and one swing) cor:ponent cooling water pumps are located together. Adjacent to thi:Se safety related pumps are the two motor driven auxiliary feecwater pumps (both trains), of Unit 1, which are also safety related. Both Unit No. 2 auxiliary feedwater pumps are located approximately 125' away down the corridor at coordinates A-12 and S.
Power operated control valves for the component cooling water (CCW) pumps are located immediately above the CCW purrps on an open grating mezzanine. Various safety related cable trays are also located in the area. A preaction sprinkler system is proposed for the ceiling level only and would offer very little protection against an exposure fire due to the many obstructions between the ceiling level sprinkler and the floor below.
It is our position that:
A.
A half hour fire rated barrier be provided betwen the redundant auxiliary feedwater pumps and extend up to the trezzanine above these pumps. At present, a metal decking barrier is used to partially separate each auxiliary feedwater pumps. This applies to both Unit I and 2 pumps.
B.
Provide automatic sprinkler protection under the partition above the auxiliary feedwater pumps of both Unit I and 2. Activation of the system should alarm and annunciate in the control room.
- C.
Provide automatic sprinklers over all five conponent cooling water purrps under the mezzanine above them.
D.
Provide a 1/2-hr. fire rated barrier separating each component cooling water pump from each other. The barrier should extend to the underside of the mezzanine above. Also provide a 1/2-hr fire rated barrier for the n'ezzanine floor above these pumps.
The 1/2-hr. fire rating should protect against a fire from either side of the barrier.
E.
Provide a 1/2-hr. fire rated barrier protection (l" mineral wool or equiv2 lent) for the ccntrol and power supplies to the various valves on the mezzanine level above the component cooling water ouvf.
F.
Providt at tunsl Ermke <ietection throughout the area for early a ;r, a ne m 'ign ebculd be tied into the existing iire alarm systen and alarn and annunciate in the control room.
G.
Verifyth3t the existinn hose station location will be sufficient with the above fire rated barriers in place for protection of all pumps and valves.
TVA Response Response will be provided by Dece:rter 15, 1976.
117119
i 3-
.,, \\.
14 The emergency raw cooling water pump house is ieparated into three con'partments with train A of both units locatca ca either end and train B of both units located together in the middle compartment. 'It is our position that the following be provided for the ERCW pump house.
?
A.
Provide a 3 hr. fire rated door to separate the center compart-ment from the south compartment. The door should be alarmed and annunciated in the control room.
B.
provide a 1/2-br. fire rated partial barrier to separate the two B trains in the center compartment. Barriers should be at least 6" high.
r TVA Response A.
A 3-hour rated fire door is provided between the center and south compartments of the intake pumping station containing the ERCW pumps. At the time of the flRC site visit, the door had not been installed.
The door shall be locked in its normally closed position with the keys administratively controlled. Therefore, alarm and
(
annunciation of the door is not necessary.
B.
Separation within the B train is not required. The ERCW system is not designed as a separated system beyond that which is required 1
for the two train assignments (train A plus train B); i.e., there are not two B trains. All four B train ERCW pumps supply the same B train ERCW header. Train A of the ERCW system provides complete and fully qualified redundancy to the train B pumps. A more complete description of the ERCW system is provided in FSAR section 9.2.2.
4 9
117121
- 15. All four wood and PVC cooling towers for the Auxiliary Essential 9.3w Cooliag Water System are located within 50 ft. of the emergency diesel generator building and approximately within 50 ft, from the two large diesel fuel oil storage tanks (also located approximately within 50 ft. from the emergency diesel generator building and approximately 50 ft, from the AERCW pumps). These cooling towers are not protected by a deluge system. We are concerned that a fire in the cooling towers can threaten the diesel generator building, the diesel storage tanks, and the auxiliary essential raw cooling water pumps. It is our position that the cooling towers be protected in accordance with Section 0.18 of Appendix A, i.e., providing deluge system, hydrants, and hose stations.
TVA Response TVA is not providing a deluge system or hose stations for the four auxiliary essential raw cooling water (AERCW) cooling towers for the following reasons:
i A.
The AERCW system (pumps and cooling towers) is required to shut down the plant only upon loss of Chicamauga Dam (the downstream dam). The safety feature will be transferred to the new ERCW station when it is completed (prior to unit 2 operation).
B.
The diesel genrator building is about 50 feet from the closest tower (the distances of the other towers are 120, 200, and 280 feet). This distance is great enough so that an AERCW cooling tower fire would not constitute a hazard to this structure. The diesel generator building is a seismic 1 A structure, designed to be tornado and missile resistant and its exterior walls are equivalent to at least a 3-hour rated fire barrier.
C.
The yard storage fuel oil tanks are 70 feet away from the closest ccoling tower (distances to remaining towers are 75,120, and 180 feet). This separation distance is sufficient such that an AERCW tooling Lcwr fire woulo not constitute an exposure hazard to these tanks (see taole 4-4,15PA 30). The fuel oil tanks are diked and yard hydrant and hose /eouipment capabilities are provided fur the et. tiro 3rea. Furtrer, the yard fuel oil tanks serve no safety function. The safety-related diesel seven-day tanks are embedded'in concrete undct the diesel generator building.
D.
Salient features of the cooling tower design are as follows:
The use of fire retardant, corrugated fiberglass casing and a.
- louvers, b.
Fire retardant glass rt:inrorced polyester fan cylinder.
PVC fill and eliminators with a flame spread rating of c.
25 or Hss.
-117122
a 16.
It is our position that when the C0 total flooding system is locked 2
out locally in any emergency diesel generator room that the operator in the control room receives an alarm and annunciator indicating that the system is inoperative.
TVA Response The system will be under administrative control when locked out in accordance with Physical Security Instruction PHYSI-13 section 4.4.
Therefore, alarm and annunciation in the control room is not necessary.
(
117123
4 a
17.
A.
The corridor outside each diesel generator room of the emergency diesel generator building has a preaction sprinkler 3
system. Power conduits from each diesel run up the west wall i
of the corridor. A concrete barrier. extending out approxi-mately 3 ft. from the west wall separates the redundant power trains. Unit No. I power conduit is located at one end e
of the corridor and Unit No. 2 at the opposite end.
It.is our position that a 1-1/2 hr. fire rated barrier separate each redundant train of each unit from each other in the corridor for protection against an exposure fire in the event of failure of the sprinkler system.
It is also our position that the doors leading to each emergency diesel generator from the corridor be kept in tne closed positon (at all times) and alarmed and annunciated in the control room.
B.
Also verify that a fire in any one of the four switchgear rooms above the corridor of the diesel generator building, elevation 740 ft., will not involve cables and/or conduit for any other safety related train or unit.
I TVA Response A.
The NRC understanding of the conduit assignment is in error. Unit 1 and unit 2 train A power conduits are located on the north end of the corridor, and unit I and unit 2 train B conduits are located on the south end of the corridor. There is approximately 50 feet separation between train A and train B conduits. TVA considers the spacial separation to be adequate and does not propose to add a fire rated barrier.
Normally open, 3-hour rate'd sliding fire doors are provided for the opening leading to each energency diesel generator room from the corridor. The doors are provided with electromagnetic door holders. The doors are actuated either by detection systems located on each side of the door, by thennally actuated links or by a diesel generator room CO system release.
2 The detection systems that actuate the fire doors annunciate a fire signal in the centrol roo;. Likewise, a CO, initiation in any one of the diesel generator rooms is annunctated in the main control room. We conclude that the door release system, as designed, provides sufficient redundancy and alarm features to assure door closure in the event of a fire.
B.
There are ni cable trays and/or conduit that penetrate switchgear i
rooms of opposite divisions.
116200 m
. - ~ _.
i i
- 18. We were informed at the time of the site visit that an alternative means of achieving cold shutdown if both redundant trains of conduit-cable trays (of both units) are lost due to a fire in the control room, or cable spreading room or remote shutdown panel room.
In order to evaluate this alternative, we require a description of how the alternate shutdown method for each area will be carried out, system modifications associated with the shutdown method, and confirmation that written. procedures have been established for innediate use by responsible individuals. The staff position 1
with respect to providing alternate or dedicated shutdown methods for fire protection is stated in Enclosure 1.
Provide information that demonstrates that the requirements of Enclosure I will be satisfied.
TVA Response Emergency Operating Instruction E01-7, Control Room Inaccessibility, provides for safe plant shutdown from the auxiliary control room should the main control room become inaccessible due to a fire (or for other i
reasons such as toxic gas, etc.) in either it or the spreading room.
This instruction provides a discussion of symptoms, automatic actions, j
(-
(a) control room inaccessibility at powe,r or hot standby; (b) control immediate operator action, subsequent operator action, and recovery for:
room inaccessibility at hot shutdown, cold shutdown, or refueling shutdown; (c) hot standby to cold shutdown in the auxiliary control mode; and (d) return to main control room operation from test of E01-7.
E01-7 and all E0l's have been subnitted to NRC Region 2 Office of Inspection and Enforcement for review.
The auxiliary control room has been divided : 1to five independent compartments (a central control hrea and four transfer switch rooms).
which are separated from each other by 1-1/2 hour fire rated barriers.
The central' control area is the only room where a fire could affect both safety trains. Panels and cables in the central area are normally inactive and their loss would have no effect upon plant control. A fire in one of the other four rooms could affect only a single train and would not prevent safe shutdown from tne main control room.
(
116201
19.
It is our position that the ventilation system of each safety-related battery room be alarmed and annunciated in the control room upon failure of such systems. Confirm that you will meet this position.
TVA Response Redundant ventilation systems are provided for each safety-related battery room. Failure of one system results in an alarm and annunciation in the main control room and the automatic starting of the second system.
(
t 117102
- 20. Control Room Complex r
A.
Provide the flamespread, snake developed, and fuel contributed test results as per E-84 of the dropped plastic ceiling in the control room.
We were informed at the time of the site visit that this ceiling was a UL-approved dropout ceiling. Verify that the ceiling material meets the guidelines of Section C.4.a(4) of Revision I to BTP 9.5-1 or replace it with a ceiling material that does.
B.
It is our position that you provide a 3-hour fire rated barrier at T5 and T12 on the ends of the control room. Present doors are not labeled as well as openings are above the suspended ceiling into the corridor.
Verify that the doors are of 3-hour fire rated construction and that 3-hour fire doors /damners are used in all ventilation doct penetrations where they penetrate the 3-hour barrier.
C.
The main safety-related consoles actually extend through the floor three to four feet into the cable spreading room. These are completely enclosed with metal walls and floor.
A 3-hour fire rated coating is to be applied to the sides and bottom of these consoles from the cable spreading room side only. There is no fire rating from the control room side. The consoles are i
congested with cables (all non-IEEE-383 rated) and would make manual firefighting difficult.
It is our position that taking the above factors into consider-ation and providing a defense-in-depth protection that an auto-matic or local manual operated gas suppression system (either high or low pressure CO consoles.
2 or halon) be provided for protection of these D.
Verify that the sprinkler system for protection in the records storage area conforms to NFPA 13.
It was noted that the riser nipples appear to be 1/2-inch pipe, which is not permitted by liFPA 13.
Also, verify that the wall separating the records storage room from the relay room is of 3-hour fire rated con-struction, including protection of all duct penetrations.
\\
TVA Response A.
The translucent panels in the main control room ceiling are not UL listed.
They will be replaced with material that meets the guidelines of section C.4.a(4) of Revision 1 to BTP 9.5-1.
B.
The control room complex is separated from other plant areas by minimum 3-hour fire rated contruction.
Within the complex, the peripheral rooms are generally separated from the main control room by 1-1/2-hour fire rated construction, nne-and-one-half hour fire separation between the main control roon and the remainder of the control room complex satisfies the requirements of section C.6.b of Regulatory Guide 1.120, Revision 1.
561981
. = _ -
. =.__ -
Refer to contrul building elevation 732.0 on compartmentation drawing SK-1007 in the Sequoyah Nuclear Plant Fire Protection j
Program reevaluation for tne layout of the control room complex.
The mechanical equipment room on elevation 732.0 contains venti-iation equipment that is essential for continued operation of the main control room. Therefore, the equipnent room is considered an extension of the main control room 'fre cell. The two rooms are connected by ventilation ducts located above the suspended ceiling for the housekeeping area between columns C2 and C4. These ducts do not penetrate a fire barrier and are not provided with fire dampers. The housekeeping area is separated from the main control room, the mechanical equipment room, and the essential ventilation ducts for the main control room by 1-1/2-hour rated suspended ceilings and fire walls. The ventilation supply ducts penetrating the ceiling of the housekeeping area consisting of the shift engineer's office, instrument calibration shop, toilet and locker area, and the kitchen area are not provided with fire dampers at the ceiling penetration. Smoke dampers actuated by ionization smoke detectors are provided in the main supply trunk above the 1-1/2-hour fire rated ceiling for each of these areas. These dampers are UL listed and have a 1-1/2-hour fire rating. Upon detection of smoke in any of the housekeeping area rooms, the dampers in the main supply trunk to the affected room or rooms will be isolated thereby closing off supply air to the room or
.\\
rooms without interrupting essential ventilation supply to the main control room.
Return air ducts from the chart storage room and instrument calibration room are also provided with a rated smoke detector actuated damper in the main return trunk above the suspended ceiling.
Isolation of this darner will prevent smoke in these rooms from returning to the control room complex air-handling units thereby preventing contamination of the main control room.
Return ventilation from the shift engineer's office is through a louver in the wall to the corridor and back to the mechanical e,quipment room. The louver in the wall between the shift engineer's office and the corridor is provided with a 1-1/2-hour fire rated damper.
Exhaust ventilation for the kitchen area and the toilet and i
locker rooms is through an exhaust' fan located in the mechanical equipwnt room exhausting to the outside through the ontrol buildiny roof. 40 fire dampers are provided for these ducts.
I Additional dete'ctor-actuated rated fire dampers are provided between the corridor and the mechanical equipment room to prevent smoke present in the arridor from entering the nechanical equipment room, and in the return air duct within the mechanical equipment room supplying 5200 cfm makeup air to the main control room air-handling units to prevent smoke present in the riechanical i
equipment room from enteri.g the main control room.
The relay room is separated f rom the main control room by 1-1/2-hour nted fire wall that extends through the suspended ceilings. Refer to part D. of this response for a discJssion of the separation i
between the relay room.and the record storage room.
C A1 Atb and E7An77 i
~--_
4 1
All fire barrier openings are prr vided.with appropriately rated, UL-labeled assemblies excapt the previously mentioned housekeeping area ventilation Suppl and CS6 (refer to drawing SK-1007) y ducts and door openings C55 which contain special purpose security doors.
These doors are made of bullet-resistant, heavy gauge steel and have not been tested by UL.
However, the manu-facturer has certified that the two doors are equivalent to UL-tested fire doors rated for three hours.
The above-described fire rated separation and smoke control provide adequate protection of the main control room from a fire originating i n the peripherial areas of the control room complex.
As described in u.; response to question 20.C, loss of the main control room is an acceptable event since reactor shutdown can be accomplished from the backup control room located in the auxiliary building.
C.
Automatic smoke' detection is provided within the control room consoles to provide the earliest possible indication of a fire.
Hand portable fire extinguishers are provided within the main control room and manual fire hose backup capability is provided immediately outside the room.
The control room consoles contain only low-voltage cable, which minimizes the possibility of internally generated fires.
The consoles are provided with full access doors on the rear of the panels which afford access to the lower recessed portions of the consoles with an extinguisher or fire hose nozzle.
With early detection capability in the control room consoles, a fire can be detected and extinguished in the incipient stage with minimal effect on equipment and electrical circuits.
Should a fire occur that deve' cps beyond the capability of the extinguishing equipment, the main control room can be abandoned and reactor shutdown accomplished from the backup control room located in the auxiliary building, it is TVA's position that a gaseous suppression system is not necessary for the main control room consoles.
_D.
The 1/2-inch riser nipples will be replaced with 1-inch nipples to conform to NFPA 13 in the records storage area. The wall separating the records storage room from the relay room is of 1-1/2-hour fire rated construction including 1-1/2-hour rated fire dampers in duct penetrations.
i 4
4770a7
21.
In the control building on elevation 685 ft. in both Units 1 and 2, auxiliary instrument ' rooms, both safety related divisions of one unit are located in each room. The consequence of electrically initiated or exposure fires should be evaluated with regard to plant shutdown capability.
In the event that the plant shutdown capability cannot be maintained, an alternate shutdown method should be provided.
TVA Response-The auxiliary instrument room (s) located on elevation 685.0 of the control building are considered an extension of the main control room for the sake of the design of the backup control system.
Hence, Sequoyah can establish and maintain a safe shutdown with a total loss of an auxiliary instrument room. See response to question 18.
l.
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e 1
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t f
f 117103
22.
In the cable spreading room of the control building, a preaction sprinkler system is used for protection with one layer of sprinklers located at the ceiling and an intermediate level located spproximately half way between the floor and the ceiling.
Provide heat collectors for the lower sprinkler heads to prevent ceiling level sprinklers from cold soldering the lower layer of sprinklers.
TVA Response Heat collectors are provided for lower level sprinkler heads in the spreading room. At the time of the NRC site visit the heat collectors had not been insta71ed.
t 117104
t
- 23. Verify that the controllers of the four fire pumps are separated such that an exposure fire will not jeopardize more than one controller. List the location of each such controller.
TVA Response The four fire pumps are controlled by switchgear located in separate 480V shutdown board rooms. Refer to compartmentation drawing SK-1004 in the Sequoyah Nuclear Plant Fire Protection Program Reevaluation and Table 23-1 for the switchgear locations.
Table 23-1 Fire Pump 480V Shutdown Board Room Number 1A-A 1A2-A 734.0-A8 IB-B 182-B 734.0-A5 2A-A 2A2-B 734.0-A21 28-B 282-8 734.0-A18 i
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117105
e 24 Verify that the main control valve of the C07 system used for protection of safety related equipment in vaPious rooms is supervised and alarined and annunciated in the control room.
TVA Response The C07 system is provided with all alarm and annunciation functions required by flFPA 12, 1973.
of the master control valve is not necessary,It is TVA's position that the su i
577415
25.
The information obtained as the result of the site visit was that the cable used at the Sequoyah fluclear Plant will not pass the flame test in the current IEEE Standard 383.
We were informed that some testing had been performed on this cable.
Provide the information on the test used as well as the necessary data and criteria.
TVA Response Table 25.1 contains the requested data for the purchased electrical cable.
A description of the various flame tests is given in table 25.2.
S.
s 117106
^
TABLE 25.1
'T7A l
Flc e Tests Cable Description
~
Cable Tvee U3, UC I? CIA S-19-81 Single conductor, stranded, nylon
~
jachet, polyethylene insulation W7, tr.;
~
N 383-1974 Multi-conductor, twisted, stranded, IPCEA S-19-81 shielded, chlorosulfonated polyethylene IPCEA S-61-E02 jacket, crosslinked, polyethylene MID'-22759/16 insulation l
UL-44 2
IPCIA S-19-81 Single conductor, PVC jacket, crosslinked M, TC IEEE 383-1974 Polyethylene insulation
'?
IPCEA S-61-402 Telephone and coaxial cable IPCEA S-19-81 Multi-conductor, singles - crosslinked WL, W polyethylene PVC jacket, PVC overall Jacket t
UP IPCEA S-19-81
' Single conductor, asbestos braid jacket, VTFT3 silicone rubber insulation P7,'iG,IG
~
IPCEA S-61 402 PVC jacket, overall PVC jacket IPCEA S-19-81 Multi-conductor, singles - polyethylene
~
UR VTFT.
Multi-conductor, singles silicone rubber ',rith glass braid, overall jacket asbestos brcid W
IPCIA S-19-81 Ther=ocouple cable
~
MILW22759/16 1 The TVA cabic type is actually a three letter designation. The third 15tter as dropped for table brevity as the cable description remains unchanged.
2 Single conductors ses.ller than No. 8 AWG are installed in conduits 3 ' VA Vertical Trny Flame Test T
I
4 2
A TABT3 95.P 1EEM 333-1974 1.
An elght foot ceble tray ran crected vertically and londed with multiple length of cables arranged in a single layer.
l 2.
The finme source van a ribbon cas burner placcd very near the bottom of the vertical tray.
3 The criteria for ft.51ure was a propagating fire in the troy above the flame source for the total length,of the tray.
UL-kh
~
1.
A three sided metal enclosure was erected vertically and loaded with a single conductor.
2.
The finme source was a Turrill gas burner placed opproximately near the center of the cable specimen.
3 The following is the criteria for failure:
A.
A single conductor wire that finmed longer than 1 minute follouing any-of the, five 15-second applications of the finmc.
B.
The wire igniting any combustible material in its vicinity during, betucen, or after the various applications of the flame, j
C.
A damage of more than 25 percent of the indicator material.during, between, or after the various opplications of the flame, e
TVA Vertical Trav Finmc Test 1.
An cicht foot ladder type metal cable tray was.orected vertically and loaded with several conductors from end to end on a singic level, i
2.
A 120/2h0-volt ac test circuit was used to monitor circuit integrity during the test.
l 3
The floon source nas crumpled burlap sonhed uith trcnsformer insulating j
oil and placed several inchen ebove the lower cable end.
h.
The follouing was the criteria for failure:
A.
Propocating fire results.
B.
Circuit integrity loss in less than 15 seconds after ignition.
C.
Excessive smoke appearing frem cable.
D.
Ilot drippincs from cable that may Icuite fire in lower areas.
1 6
f
-..~..._,
m
- 26. Verify that hose houses equipped with hose and combination nozzle and other auxiliary equipment recommended in NFPA 24, "Outside Protection," is spaced not more than 1000 ft. apart.
TVA Response Hose houses are spaced less than 1000 feet apart. However, they are not completely furnished with the equipment listed in NFPA 24. The following will be provided:
250 ft 1/2" hose (on wheeled cart) 150 ft 1/2" hose 2 1/2" variable fog nozzles 2 1/2" variable fog nozzles 1
- Fire axe 1
- Crow bar 2
- Hydrant wrenches 4
- Coupling spanners 2
- Hose and ladder straps 1
-( 1/2" by 2-1/2" by 2-1/2" gated wye 1 1/2" by 1-1/2" by 1-1/2" gated wye 2 1/2" by 1-1/2" reducers 2 1/2" adapters (female to male) 2 1/2". adapters (female to nale) 2 1/2" adapters (double male) 2 1/2" adapters (double male) 2 1/2" adapters (double female) 2 1/2" adapters (double female) 1
- Wheeled fire extinguisher (rated 320 B:C) 1
- Tee handle wrench 1
- Portable hand lantern (battery operated) i
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577416
27.
Provide a description on the operation and sequencing of the station fire pumps including isolation of the RWST valves, pushbutton stations located next to fire hose stations including supervision of _the circuits and how they are connected to the fire alarm control panel as well as the fire pump controllers.
Consideration should be given to failure of any of the above circuits and its affect on the fire protection system.
TVA Response The four station fire pumps are capable of three modes of operation--
automatic, manual, and standby.
In normal operatien, two pumps are placed in automatic mode and two in standby. Upor. receipt of an auto-matic start signal, one automatic pump starts immediately and the second starts three seconds later. If the fire protection system pressure cannot be maintained above 130 psig because of high system demand, the two standby pumps start ten seconds after the receipt of the initial signal. Manual operation of the pumps is also provided from the main control room and the individual pump switchgear.
The automatic start signals are originated in the circuits shown in block diagram form in Figure 27-1.
Local control panels are provided for each fixed suppression system to actuate the system and
(
to transmit a signal to start the fire pumps.
These panels receive initiation inputs from the fire detection system and/or from hand-switches located in the protected areas. Additional fire pump start signals are generated by pushbuttons near fire hose stations located throughout the plant. All the start signals are processed through the centralized automatic start logic located in three panels in the unit I and 2 auxiliary instrument rooms.
From this logic, the start signals are transmitted simultaneously through separation relays to the individual pump switchgear. The pump sequencing is controlled by the switchgear as determined by the position of the handswitches located in the main control room. Refer to Table 27-1 for the location of the major system components.
Upon starting a fire pump in any mode, its switchgear provides an output to close the raw service water head tank isolation valves.
The pushbutton stations located next to the fire hose stations are provided to start the fire pumps only.
They are not connected to the fire detection system and they are not supervised.
fio single failure in the circuits shown in Figure 27-1 or their power supplies will result in an unacceptable loss of firefighting capability.
A failure in a local control panel could prevent the automatic initiation of the associated suppression system and the fire pumps during a fire. However, the failure would not affect the detection system's annunciation capability so the unit operator can manually start one or more fire pumps and can dispatch the fire brigade to manually initiate the suppression system.
Automatic start logic failures can prevent the automatic actuation of all fire 572824 e
This would not affect the suppression system operation, but pumps.
would require manual starting of pumps frcm the main control room upon receipt of a aetection system annunciation. A failure in the separation relays, 480V switchgear, or fire pumps would affect one pump only.
The remaining three pumps would be operable in any mode.
in the handswitches, pilot-valves, pushbuttons, and the system's con-Failures necting circuits are no more restrictive than those failures discussed-above.
The fire pumps are assigned trained designations with two pumps in train A and two in train B. The manual control circuits (main control roo switch, 480V switchgear, power supply, and connecting circuits) for the pumps are separated per the requirements for Class IE electrical com-ponents.
i t
1 4
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' s 572825 I
, _.. ~.,
.__,m,
,7
~
y
1000T
$ Lef t FIRE CETECTI0fl SYSTEM LOCAL MULTIPLE I:iPUTS CONTROL FROM LOCAL PAllEL CONTROL PA'iELS C
HAtlDSWITCil PUSHBUTTON 9
s
>(*
MULTITLE INPUTS FROM AUTOMATIC PUSHBUTTONS LOCATED PILOT VALVE FOR FIRE PU:'.P NEAR FIRE HOSE STATIONS SUPPRESS 10li SYSTEM START LCGIC 1
SEPARATION SEPARATI0ii SEPARATION SEPARATION RELAYS RELAYS RELAYS RELAYS HAflDSWITCil Ig..
a a
a l
Ft I CON ROL llANDSWITCH HANDSWITCH HAllDSWITCH ROOM (MCR)
MCR MCR MCR 480-V 480-V 480-V 480-V s
SWITCHGEAR SWITCHGEAR SWITCHGEAR SWITCHGEAR 1A-A 1B-8 2A-A 2B-B FIRE PUMPS FIGURE 27-1
1 TABLE 27-1 Component Guilding.
Elevation
. Column Room Nane Local control
Located Throughout the Plant-------------
panels Automatic fire Control-685.0 p,C5 Units 1&2 pump start logic
- p,C9 Aux. Instr.
Fire pump 1A-A Intake' 705.0 Pumping.
Station l A-A separation Control' 685.0 p,C5 Unit I relays **
Aux. Instr.
lA-A 480V switch-Auxiliary 734.0 t,A2 480V Shutdown gear Bd. Rm. lA2 Fire Pump 18-8 Intake 705.0 Pumping.
Station IB-B separation Control 685.0 p,C5 Unit I relays ***
Aux. Instr.
IB-B 480V swi_tch-Aux' ilia ry _
gear 734.0 r,A3 480V Shutdown Bd. Rm.182 Fire pump 2A-A Intake 705.0 Pumping -
Station-2A-A separation Control 685.0 p,C5 Unit I relays **
Aux. Instr.
2A-A 480V switch-Auxiliary 734.0 r,A13 480V Shutdown g
gear Bd. Rm. 2A2 Fire Pump 2B-B Intake 705.0 Pumping Station-28-8 separation
. Control 685.0 p,CS Unit I relays ***
Aux. Instr.
2B-B 480V switch-Auxiliary 734.0 t.A14-480V Shutdown gear Bd. Rm. 2B2
- Located in panels R-71,'R-72, and R-79.
- Located in panel 1-R-73.
- Located in panel 1-R-78.
1 576967
Quality Assurance Branch Request for Additional Information Your description in Sections A.1 and 8,5 of your submittals relative to your compliance with _ the " Guidelines in Appendix A of BTP 9.5-1" does not provide adequate information on your fire protection organization for us to complete our review.
- informa tion:
Therefore, please provide the following 1.
Describe the upper level management position that has the overall responsibility for the formulation, implementation, and assessment of the effectiveness of the fire protection program.
2.
Describe the offsite position (s) that has direct responsibility for formulating, implementing, and periodically assessing the effectiveness of the fire protection program for the nuclear plant, including fire drills and fire protection training.
3.
While the Plant Superintendent is generally responsible for all activities at the facility, describe any further delegation of these f
responsibilities for the fire protection program such as training,
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f maintenance of fire protection systems, testing of fire protection equipment, fire safety inspections, fire fighting procedures, and fire drills.
4.
Describe the authority of your fire brigade leader relative to that of your Shift Engineer.
TVA Response 1.
In the TVA organization structure, the General Manager has overall responsibility for the formulation, implementation, and assess-ment of the effectiveness of the fire protection program.
In accordance with the TVA policy of management accountability, the General llanager has delegated these fire protection program responsibilities through the respective managers of offices i
to the Director of Engineering Design, the Director of Construction, and the Director of Power Production within their respective To fulfill these responsibilities, these directors areas.
2 maintain qualified staffs to ensure that all aspects of the fire protection program are, at a minimum, consistent with applicable regulatory rqquirements. To ensure that an integrated program is maintained, TVA has established a fire protection panel composed of key management representatives from each of these three divisions for review and coordination of program policies and application in interface areas.
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2.
The offsite position (s) that has direct responsibility for formulating imnlementing, and periodically assessing the effectiveness of the fire protection program for the nuclear plant, including fire drills and fire protection training is the Fire Protection Section of Safety Engineering Services. The program is formulated and implemented through pivision Proceduros Manual N78S2. Section F8 of this manual establishes the requirement for an annual fire audit of each nuclear facility.
3.
Delegation of responsibilities for the fire protection program such as training, maintenance of fire protection systems, testing of fire protection equipment, fire inspections, firefighting procedures,.and fire drills is contained in Division Procedures Manual N78S2 4.
The authority of the fire brigade leader relative to that of the shift engineer is contained in Sequoyah Nuclear Plant Physical Security Instru,ction Physi-13, Section 1.0.
This instruction states in part that the duty assistant shif t engineer, unit 1, shall b<
the fire brigade leader. fie shall remain the leader unless relieve'. hv his inline supervisor (the shift engineer). It e
further stat-that he shall keep the control room informed as to the fire conditions.
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REQUEST FOR ADDITIONAL INFORMATION QA FOR FIRE PROTECTION FOR SEQUOYAH (AND WATTS BAR) NUCLEAR PLANTS F421.1 TVA's letter of January 24, 1977, to NRC regarding fire protection for Sequoyah (and Watts Bar) does not indicate whether the QA program for fire protection during design and construction is under the management control of the QA organization. This control consists of (1) formulating and/or verifying that the fire protection QA program incor-porates suitable requirements and is acceptable to the management responsible for fire protection and (2) verifying the effectiveness of the QA program for fire protection through review, surveillance, and audits. Performance of other QA program functions for meeting the fire protection program requirements may be performed by personnel outside of the QA organization. The QA program for fire protection should be part of the overall plant QA program. These QA criteria apply to those items within the scope of the fire protection program, such as fire protection systems, emer-c gency lighting, communciation, and emergency breathing apparatus as well as the fire protection requirements of applicable safety-related equipment.
We find that the letter does not describe sufficient detail to address the ten specific quality assurance criteria in i
Branch Technical Position APCSB 9.5-1 during design and construciton.
In order for the QAB to fully evaluate your plan to meet these criteria, additional detailed description is necessary. Examples of the detail we would expect TVA to provide are given in Attachment 6 to Mr. D. B. Vassallo's letter of August 29, 1977.
If, however, you choose not to provide this detail, you may apply the same controls to each criterion that are coreensurate with the controls described in your QA program description, Section 17.lA. These controls would apply to the remaining design and construction activities of Unit Nos. I and 2.
If you select this method, a statement to this effect would be adequate for our review of the QA program for fire protection.
TVA Response The QA program fire' protection has been reviewed by appropriate TVA management including the QA organization to verify that the program incorporates suitable requirements and is acceptable. The appropriate QA personnel are responsible for verifying the effectiveness of the program through periodic audits.
The QA criteria apply to all fire protection related systems equipment and components within the scope of the fire protection program including fire protection systems, emergency lighting, communication, and emer-gency breathing apparatus, to the extent that they may affect the fire 577301
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protection for nuclear safety-related plant features. Our submittal of January 24, 1977, to the NRC will be revised as follows to reflect a more detailed discussion of the existing procedures and programs within the Office of Enginering Design and Construction (0EDC) that are required for fire protection related systems:
C.
Quality Assurance TVA Compliance As indicated in the response to item A.1, Personnel, and as amplified in our response to Quality Assurance Branch question 1, TVA has delegated the responsibilities associated with the various aspects of fire prevention and protection to or-ganizations which have personnel qualified to handle those functions.
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The responsibility for the operational aspects of fire pro-tection has been delegated to the Division of Power Production i
i in TVA's Office of Power. The Office of Power utilizes TVA's established QA program designed to meet the requirements of Appendix B to 10CFR Part 50. This program applies, for the operational phase of TVA's nuclear power plants, to the activities affecting the quality of those critical structures, systems, and components (CSSC) whose satisfactory performance is required for safe plant operations; to prevent accidents that could cause undue risk to the health and safety of the public; and to mitigate the consequences of such accidents in the unlikely event that they should occur. Those fire protection features protecting critical structures or areas will be included in the CSSC list and as such will fall under TVA's operational QA program. The operational QA program is described in the Sequoyah Nuclear Plant Final Safety Analysis Report (FSAR), Chapter 17. Responsibility 3
for the design and construction aspects of fire protection has been delegated to the Office of Engineering Design and Construction (0EDC). OEDC has dqcumented procedures and specifications which govern its activities and which apply to all systems for which OEDC has responsibility.
These procedures are aimed at ensuring that the desigr. and construction of TVA facilities result in a reliable and s
quality product. As applied to fire protection, these documents will require, in part, that the actions required in C.1 through C.10 below be accomplished.
C.)
Design Control and Procurement Document Control TVA Compliance All fire protection related design criteria and procurement documents be reviewed by appropriate qualified indi-viduals to ensure that applicable regulatory and design requirements are properly and adequately specified and, as appropriate, quality standards such as fire
e protection codes and independent laboratory testing are included. All changes to these documents and deviations i
therefrom, including requests for field changes, are reviewed in a similar manner. The above includes appropriate design reviews to verify separation and isolation requirements as they relate to fire protection.
C.2 Instructions, Procedures, and Drawings TVA Compliance The design, installation, and tests associated with fire protection related systems be accomplished in accordance with written and approved instructions, procedures, and drawings. These documents must be reviewed by qualified personnel to ensure that applicable regulatory and design requirements are properly and adequately specified. This documentation includes any specialized training requirements for installation.
C.3 Control of Purchased Material and Equipment
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TVA Com)liance The procurement of fire protection related material and equipmen'. require either an inspection at the manufacturer's facility 3r a receiving inspection to verify conformance to procurement requirements.
C.4 Inspection TVA Compliance The installation of fire protection related systems be verified by independent inspection to ensure that it meets the specified requirements and conforms to installation drawings and procedures. The inspection must be conducted in accordance with documented procedures. The procedures i
controlling inspection activity require that the inspection procedures or instructions shall be available with necessary drawings and specifications to use prior to performing inspection operations.
Further, the procedures, instructions, and/or drawings, including revisions, supporting the inspection activiti.,es shall be documented. The results of these inspections shall be recorded.
C.5 Test and Test Control TVA Compliance Fire protection systems be tested under TVA's preoperational test program. This program requires that tests be conducted in accordance with written test instructions which are reviewed to ensure that applicable regulatory and design requirements are properly and adequately specified. The acceptance criteria shall be evaluated and documented and all exceptions documented and controlled.
577307
C.6 -Inspection, Test, and Operating Status TVA Compliance items that have satisfactorily completed tests or inspections be identified by appropriate means.
k C7 Nonconforming Items TVA Compliance Nonconforming items be identified and. controlled to prevent inadvertent use or installation. This includes documentation of the disposition of the nonconformance. The Thermal Power Engineering formance repo(rts and may request review by other branches within Eli DES as appropriate.
shall approve the disposition of the nonconformance.The TPE Design Proj C.8 Corrective Action f
TVA Compliance
{t Significant and repetitive conditions adverse to fire protection such as nonconformances with installation drawings and deviations from specifications be controlled and appropriate corrective action taken and documented.
fire incidents and the corrective actions taken shall beConditions involving promptly reported to a cognizant level of management for review and assessment.
C.9 Records TVA Compliance Records be maintained for fire protection systems to document conformance to the prescribed criteria.
These records must include review of criteria, procurement documents and drawings, inspections, test results, non-conformances, and modification records.
C.10 Audits TVA Comp 3iance Independent audits by QA personnel be conducted annually in accordance with written procedures to ensure conformance to procedural requirements applicable to fire protection related systems. The audits must be documented along with the corrective action taken and reviewed by the appropriate level of management to ensure that the program is effective.
577308
v TVA proposes to implement additional modifications resulting from commit-ments made in our responses to the following questions as soon after initial fuel loading for unit I as is practical, but prior to return to power after the first refueling outage for the first unit:
Response to ASB question 4 - Additional fire retardant cable coating Reaponse to ASB question 6A - Self contained 8-hour battery pack emergency lighting.
Response to ASB question 9D - Additional and/or relocation of sprinklers.
Response to ASB question llB - 1" mineral wool blanket between trains in ERCW junction box and additional suppression for junction box and conduit.
Response to ASB question 26 - These equipment houses presently contain 250 feet of 2-1/2-. inch hose on a wheeled cart, I to 2-1/2-inch variable fog nozzle, I hydrant wrench, 2-coupling spanners, and 1-wheeled fire
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extinguisher rated 320 B:C. Additional equipment listed in our response will be installed according to the above schedule, rJ All modifications resulting from commitments made in our submittal of January 24, i977, shall be implemented prior to the initial fuel loading of each respective unit.
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577304 4
e F421.2 Item 25 of Table 17.2-1 (Amendment 55) of the Sequoyah SAR lists the fire protection ar.d detection systems that are treated under the opera-tional QA program.
Confirm that the applicable QA program for fire protection during the operations phase will include fire protection and detection systems protecting all areas containing safety-related equipment.
TVA Response Item 25 of Table 17.2-1 (Amendment 55) of the Sequoyah SAR will be revised to read:
Fire Protection and Detection Systems in Areas Containing Safety-related Equipment.
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l EMERGENCY PLAhMING BRANCH 1.
The Sequoyah Site Radiological Emergency Plan (REP), page 2, states that an arrangement has been made with the Hixson Pike Fire Department and that the senior fireman responding "will work with and for the WA fire brigade chief..."
The letter of agreement in Appendix K (dated March 19, 1972) does not provide sufficient evidence of these arrange-ments. It is requested that this agreement be revised to more clearly describe the responsibility and authority of this fire department when fighting fires onsite (Regulatory Guide 1.101, Annex A, Section 5.3.2).
TVA Response we will revise the referenced sentence to delete the words "and for".
We will also contact the Hixson Pike Fire Department in writing and request that they add a statement to their letter of agreement with us stating that they understand that any responding firemen will report to and work under the direction of the TVA fire brigade chief.
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2.
Section XI of the Site REP states that training and periodic retraining will be provided to selected offsite agencies. Expand this portion of your plan to include additional details regarding the specialized training and annual retraining provided for the offsite fire department, to assure their familiarity with the plant, access procedures, and radiation protection precautions (Regulatory Guide 1.101, Annex A, Section 8.1.1).
TVA Response Details regarding specialized training and annual retraining provided for the offsite fire department to ensure their familiarity with the plant, access procedures, and radiation protection precautions are contained in Sequoyah Nuclear Plant Physical Security Instruction Physi-13, Section 3.5.
This section reads as follows:
Training shall be provided for Soddy-Daisy and Chattanooga Fire Department personnel. This shall include sessions concerning general plant orientation, basic principles of radiation, and hazards unique to Sequoyah Nuclear Plant. These sessions shall be held
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prior to plant operation and at least annually thereaf ter.
f The assistant
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plant superintendent shall prepare a report to document these training sessions, which shall become part of the plant master file.
The REP will be revised to reference this document.
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3.
Section XI B of the Site REP does not orovide for quarterly drills for each plant fire brigade or for annual participation by the offsite fire department in a drill or test exercise. Revise your plan to include this training - (Regulatory Guide 1.101, Annex A, Section 8.1.2).
TVA Resnonse Requirements for quarterly fire drills for each plant fire brigade and for annual oarticipation by the offsite fire depart Int in a drill or test exercised are contained in Sequoyah Nuclear Plant Physical Security Instruction Physi-13, Section 5.2.2.
This section reads in part as follows: A full-scale general fire drill for all employees and the Soddy-Daisy Fire Department shall be conducted annually...
The P PROD and PSS Fire Brigade.
. shall conduct at least one drill per shift per quarter.
. Each fire brigade member shall participate in at least two drills per year.
The REP will be revised to reference this document.
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The Site REP, at Section IV identifies several potential radiological incidents for which detection and subsequent protective actions are described. The plan does not include other incidents that have the potential of leading to a radiological emergency, such as fires.
It is our position that such incidents be considered in the Plan along with a discussion of those actions to be taken to correct or mitigate the situation (Regulatory Guide 1.101, Annex A, Section 4.2 and 6.3).
TVA Response Sequoyah Nuclear Plant Physical Security Instructions identify other incidents that have the potential of leading to a radiological emergency such as fires.
The following is a list of those instructions:
PIIYSI 10 - Sabotage PHYSI 11 - Civil Disturbance p /
PHYSI 12 - Bomb Threat
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PifYSI 13 - Fire P!fYSI 14 - Explosions PlfYSI 15 - Natural Disasters PHYSI 17 - Illegal Entry The REP will be revised to reference these documents.
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