ML20064G264

Forwards Addl Fire Protection Program Info Requested in NRC ,Including Responses to Deviations from Cmeb 9.5-1 & Revised Responses to FSAR Questions 010.57 & 010.58

ML20064G264
Person / Time
Site:	Byron, Braidwood, 05000000
Issue date:	01/06/1983
From:	Tramm J, Tramm T COMMONWEALTH EDISON CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
5671N, NUDOCS 8301110400
Download: ML20064G264 (18)

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j~ Commonwealth Edison oru, ratst N; tion 11 Plus. Chicago [Illinoes

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\ ,/ Chicago, Illsnois 60690 Janua ry 6, 1983 Mr. Harold R. Denton, Director Of fice of Nuclear Reactor Regulation U.S. Nuclea r Regulatory Commission Washington, DC 20555

Subject:

Byron Station Units 1 and 2 Braidwood Station Units 1 and 2 Fire Protection NRC Docket Nos. 50-454, 50-4 55,50-456 and 50-457 Re fe rences : (a): October 5, 1982 letter from B. J. Youngblood t o L . O . De l Geo rg e .

(b): August 17, 1982 letter f rom T. R. Tramm to H. R . Denton.

(c): May 5, 1982, letter from T. R. Tramm to H. R . Den t o n .

(d): Ma rc h 2 5, 1982, letter from T. R. Tramm to H. R . Den t o n .

Dea r Mr. Denton :

This is to provide additional information on the Byron /Draidwood fire protection program which was requested by the NRC in reference (a) . Review o f this information should help close outstanding Item 13 o f the Byron SER.

At tachment A to this letter contains our responses to the seven deviations from CMEB 9.5-1 which were identified in Enclosure 1 of reference (a) .

At tachment B contains the information requeste'd in items 3 and 4 o f Enclosure 2 o f reference (a) . Items 1 and 2 were reviewed in detail with NRC technical management personnel in a conference call on December 15, 19'32. Additional information regarding these four topics was provided in references (c) and (d).

Attachment C contains revised responses to FSAR questions 010. 5 7 a nd 010. 58. These revisions contain information missing from the responses transmitted in reference (b). These revisions will be incorporated into the FSAR at the next opportunity.

8301110400 830106 Sc5 PDR ADOCK 05000454 F PDR

H. R'. Denton Janua ry 6, 1983 ,

One signed original and fif teen copies of this letter and the attachments are provided for your review. One copy o f the marked-up drawings listed in Attachment B have been. forwarded under separate cover to Len Olshan.

Please address further questions to this o f fice.

Very truly yours, Yk T.R. Tramm Nuclea r Licensing Administrato r i

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Attachment A Response to Deviations from CMEB 9.5-1 Deviation 1 The applicant's submittals do not indicate if any self-contained positive pressure air masks are reserved only for -fire brigade use as stipulated by Section C.3 o f CMEB 9.5-1. In addition, the applicant has not committed to provide an on-site, 6-hour supply o f reserve air and extra air bottles for fire brigade breathing

. apparatus.

Response 1 Ten sets of pressure demand self contained breathing apparatuses (SCBA) will be maintained at each station for use by the onsite fire brigade. At least a one hour supply of breathing air will be maintained in extra bottles for each of the ten SCBA's reserved for the fire brigade. In addition, a six-hour supply of reserve breathing air will be provided on site to permit quick and complete replenishment of exhausted SCBA units as they are returned by the fire brigade.

Deviation 2 Fire pump alarms indicating pump running and driver availability are provided in the control room for the ;notor-driven fire pump.

The diesel fire pump alarms for these conditions indicate only as a trouble alarm in the control room. " Failure t o sta rt" alarms no t provided as stipulated by Section C.6.a o f CMEB 9.5-1. Separate alarms should be provided in the control room to indicate pump running, driver availability and f ailure to s tart for each pump. In addition, low fire main pressure should also be alarmed in the control room. .

Response 2 The following alarms will be provided in the main control room for the motor driven fire pump OA:

a. The present alarm window for " Auto Start" will be modified to indicate " Pump Running". The alarm will be initiated by a manual or automatic start of the pump. Appropriate window engraving and wiring changes will be made,

b. A " Driver Availability" alarm will be provided in the main control room. When the control switch for the pump is placed in the pull-to-lock position, an alarm will be initiated indicating " Pump O A Ou t-o f-Servic e".

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c. A " Fall to Start" alarm will be added in the main control room. If the pump f ails to start within 30 seconds a f ter a start. signal is received, the alarm will be initiated.

This alarm will be combined with the " Pump OA Out-of-Service" alarm in one annunciator window.

The diesel driven fire pump 08 has already been provided with the following alarms in the main control room:

a. " Pump Running" ala rm.

b. " Pump OB Trouble" alarm, which will actuate when the control switch for the pump is placed in the OFF position,

, causing the pump to be unavailable.

c. " Fall to Sta rt" alarm.

In addition to the alarms for the fir pumps, alarms are currently installed in the main control room that indicate Low and Low-Low Fire Main Pressure.

Deviation 3 The applicant has not supplied suf ficient information to provide reasonable assurance of the reliability of the fire protection water supply ( Section C.6.b) . Specifically, the applicant proposes to use the basin of the cooling tower as a source of water for fire protection. We need to know if the required quantity of water (336,000 gallons) will always be available from the basin during all modes o f plant operation.

The valve arrangement at the fire pumps is such as to prevent pumping capability by the diesel pump during testing of the motor driven pump. This must be changed to assure that one pump is available at all times to supply the required fire flow.

1 The applicant has provided cross-connections between the fire protection and ESW systems to provide water to standpipe hose stations in the event of a SSE. The applicant needs to verify that the ESW system can supply at least the two most hydraulically remote hose stations with adequate flow and pressure. In addition, check valves should be provided in the cross-connections to prevent using fire protection water for any other purpose.

Response 3 The required quantity of water for fire protection purposes will always be available from the basin o f the natural draf t cooling tower during all modes o f plant operation. We f oresee no reason to ever drain the whole cooling tower basin.

Station procedures require an operator and other station personnel be present for the duration o f fire pump flow, testing which is normally about 30 minutes per pump. Flow testing is normally conducted once a year as requested by the insurance carrier. The diesel fire pump is exercised once a week to verify operability. If a fire situation develops, the fire detection system will alarm the control room, and the control room operators will alert the operator at the fire pump to isolate the test header.

The SX System has sufficient flow capacity to supply up to 1000 gpm to hose stations. Pe r Branch Technical Po sition CME 8 9.5-1, Article C.6.C.4, a minimum of 75 gpm to two hose stations is required (150 gpm minimum total) . The TOH o f the SX pumps is 169 ft. The worst case hose stations are HS-1 and HS-2 on the Auxilia ry Building roof and HS-233 in Fire Zone 11.7-0 (Fan Deck, El.

47 5 '-6") . The low flow rates will not produce any noticeable friction losses in the piping (10" and 4") so the only loss will be the elevation head which is 80 f t. With the available head and assuming 1 1/2 inch hose and solid stream nozzles, a maximum of 250 f t. of hose could be attached and still give the required flow rate. Therefore, the flow and pressure criteria o f the regulatory guide are met.

The butterfly valve which separates the FP and SX systems will be administratively controlled so that fire protection water will not be used in the SX system.

Deviation 4 The design of the standpipe system does not conform to Section C. 6. c o f CMEB 9.5-1. Specifically, the following plant areas are not provided with adequate hose stream protection:

Zone 3.1-1, Unit 1 Electrical Cable Tunnel Zone 3. 4 A-1, Unit 1 Cable Riser Area Zon e 4.1-1, Unit 1 Compute r Room Zo ne 9. 2-1, Diesel Generator Room 1A Zone 9.4-1, Diesel Generator Day Tank Room 18 Zone 10.1-1, Diesel Fuel Oil Storage Room 1B Zone 10.2-1, Diesel Fuel Oil Storage Room 1A Zone 11.6A-0, Laboratory HVAC Equipment Room In addition, lengthy runs o f 1 1/2 inch pipe will be used to supply select hose stations. Hydraulic calculation will have to be provided to verify that an adequate quantity o f water at sufficient pressure will be available at the hose nozzles.

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Response 4 The adequacy of hose station coverage for the zones listed in this question is addressed below.

l Zone 3.1-1 An additional 50 f eet of hose will be provided f or hose s ta tion s No . 4 7 an d No . 51, which results in 150 feet l of hose a t each station. This will provide adequate coverage for fire zone 3.1-1.

l Zone 3.4A-1 An additional 50 feet of hose will be provided for hose station No. 22 at column-rows 11 and L in the auxiliary building. With this additional hose, fire zone 3.4A-1 will be within easy reach o f hose station No. 22.

Zone 4.1-1 The extra 50 f eet o f hose at hose station No. 22 will

) also now reach fire zone 4.1-1 with ease.

Zone 9.2-1 An additional 50 feet of hose will be provided for hose station No. 87 in the turbine building, allowing this hose station to provide full coverage to fire zone 9.2-1.

Zone 9.4-1 Hose station No. 87 will also provide coverage to this zone with the additional 50 feet o f hose to be provided.

Zones 10.1-1 and 10.2-1 These zones a re already provided with full coverage from hose station No.129 in the turbine building (elevation 364'-0" column-rows 7/L.

Zone 11.6A-0 Hose station No. 52 in the auxilia ry building will be provided with an additional 50 f eet o f hose, with which full coverage o f this fire zone will be provided.

With the additional hose to be provided as described above, all fire zones will have adequate coverage from manual hose stations.

All standpipes supplying manual hose stations are a minimum o f 3 inche s in diamete r. The 1 1/2 inch piping is only used in short horizontal runs between the standpipes and the hose stations. i With one exception, the runs of 1 1/2 inch piping are all less than 5 feet long. The one exception is hose station No. 253 (Braidwood only), which has a 15 foot run of 1 1/2 inch pipe. The sho rt lengths o f 1 1/2 inch piping used will have minimal e f rect on the available flow rates. Therefore, the fire protection water supply pressure is adequate to supply required flows to all hose stations.

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Deviation 5.

The- applicant _ has not committed to provide water-type portable

.. fire extinguishers for the control room in conformance with Section C. 7.b o f CMEB 9. 5-1.

Response 5

, The main control room'will be equipped with a halon 1211 fire i

extinguisher rated fo r type A, B, and C -fires. The computer room, which is adjacent to the control room, is also equipped with halon fire extinguishers. A hose reel is located on an adjacent wall of the turbine floor. This is used as a backup to the hand held fire l extinguishers. Water-type portable fire extinguishers are therefore l unnecessary.

Deviation 6 The applicant has not committed to. provide smoke detectors in i

all panels (including unventilated panels) l'n the control _ room tha t t

contain_ safe shutdown related circuitry (Section C.7.b) .

Response 6 Ionization detector sensor elements are provided in the Main Contro1' Boards which contain safe shutdown related circuitry (Panels 1/2PM0lJ through 1/2PM06J) . The detectors a re located in the return air duct of each panel and alarm both at a local panel _ and in the Main Control Room.

Deviation 7 The applicant has .not committed to provide curbs at the entrance to each diesel generator room in conformance with Section C.7.j o f l CME 8 9.5-1.

Response 7 l

Curbs are not considered necessary as the fuel oil supply and return piping to the diesels from the day tanks are embedded in the t

floor except for the short lengths rising up to the engine mounted l diesel fuel oil pump from the floor, which are exposed. Allowing for a line break, the ' day tanks cannot drain f aster than 40 gpm, which is considerably less than the floor drain capacity (90 g pm/d r ain, four drains provided). Thus, the fuel oil will not accumet. ate and curbs are unnecessary.

Attachment B Information Required to Resolve Open Item s Open Item ~ 3: Oil ' Collection System fo r RCP The staf f has evaluated the applicant's request and technical basis for an exemption from this requirement. In order to proceed in its review, the staf f needs additional information, specifically: documentation of the cost of installing a similar system at the applicant's Zion Station and information on the actual exposures incurred from changing the mechanical seal before and af ter the oil collection system was installed.

Response

The cost of installing oil collection system at Zion Station Units 1 and 2 are:

Estimated design and analysis costs: $ 30,000 Estimated material costs: $ 50,000 Actual labor costs: $ 172,000 Total cos t: 5 252,000 Current Additionally, estimates have been obtained from two vendors to install an oil collection system at Byron Units 1 and 2 and Braidwood Units 1 and 2. The costs are as follows:

Estimate 1 To furnish and install:

Byron Unit 1 $ 475,000 Byron Unit 2 $ 325,000 Braidwood Unit 1 $ 325,000 Braidwood Unit 2 $ 325,000 Total $1,450,000 Estimate 2 Furnish only , not installed, excludes drain header :

Byron Unit 1 $ 140,000 Byron Unit 2 $ 140,000 Braidwood Unit 1 $ 140,000 Braidwood Uni t 2 $ 140,000 Es timated drain header cost: $ 50,000 (4 units)

Estimated labor cost: $ 500,000 (4 units)

Total cost: $1,110,000

Before an oil collection system was installed on the reactor coolant pumps at Zion . Station, records were not kept to segregate radiation exposure by job activity.. .The May 5,1982 estimate of the increase ~in radiation exposure during coolant pump maintenance due to an oil collection system is the most accurate information available.

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Open Item 4: Hydrogen Line Routing It is the staff's position that the applicant must strictly conform to Section C.5.d(2) of BTP CMEB 9.5-1 as it relates to the routing o f hydrogen piping.

Response

The routing of the hydrogen piping in the auxiliary building is in full conformance with BTP CMEB 9.5-1. The following Sargent &

Lundy drawings document the routing of this piping:

M-255, Rev. N, Auxiliary Building Piping Plan, EL 401'0" M-240, Sheet 2, Rev. C, Auxiliary Building Piping Plan, EL 383'-0" M-241, Sh ee t 2, Re v. C , Auxiliary Building Piping Plan, EL 383'-0" M-242, Sheet 2, Rev. C, Auxiliary Building Piping Plan, EL 383'-0" M-238, Sheet 2, Rev. C, Auxiliary Building Piping Plan, EL 383'-0" M-253, Rev. M, Auxiliary Building Piping Plan, EL 401'-0" and 4 01 '-0" M-265, Sheet 2, Rev. A, Auxiliary Building Piping Plan, EL 426'-0" M-265, Sheet 3, Rev. A, Auxiliary Building Piping Plan, EL 426'-0" M-228, Sheet 2, Rev. C, Auxiliary Building Piping Plan, EL 364'-0" M-229, Shee t 1, Re v. N , Auxiliary Building Plan Piping, EL 364'-0" M-225, Sheet 2, Rev. C, Auxiliary Building Piping Plan, EL 364'-0" 5671N

O e Attachment C Revised Responses to FSAR QJestions 010.57 010.58 l

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QUESTION 010.57

" Table 2.4-4a of the safe shutdown analysis identifies safe shutdown instrumentation. However, the analysis indicates that following a fire in a number of separate plant fire zones, redundant channels of certain of these instruments which'must be availabic during hot shutdown will be lost. This is unacceptable. It is our position that at least once channel of instrumentation essential for safe shutdown be protected f rom fire damage in accor-dance with Section III.G.2 of Appendix R or an alternate be provided which meets the requirements of Section III.L of Appendix R. The backup instrumentation justifi-cation discussion of these fire zones in the safe shutdown analysis does not comply with Section III.L. Instrumen-tation affected includes source range neutron flux mon-itoring, steam generator wide range icvel indication, reactor coolant hot and cold leg indication and auxiliary feedwater flow indication in the following areas:

a. Control room

b. Lower cable spreading room .

O c. Auxiliary electrical equipment room

d. Auxiliary building general Area, elevation 383'-0"

c. Radwaste and remote shutdown control room; and

, f. Radwaste drumming station and tunnel."

RESPONSE

A discussion of each of the arcan listed in the question follows. Note that the lower cable spreading rocms are divided into five fire zones. A discussion is provided for each zone. Table 010.57-1 lists the number of channels of instrumentation affected in each fire zone for each of

,the instrumentation types listed in the question.

, a. Control Room (Fire Zone 2.1-0)

Both channels of cource range neutron monitoring instru-mentation would be affected by a fire in this zone.

This is due to the fact that the neutron monitoring system panel IPM07J is located in the control room.

It is the Applicant's position, however, that the source

[]g range neutron monitoring instruments are not required 010.57-1

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I to achieve or maintain the plant in the hot standby or hot shutdown conditions. In the event of a fire in thin zone, the operators would have sufficient time to scram the reactor prior to evacuating.the room.

Once the control rods are inserted into the core, suf-ficient negative reactivity han been inserted to ensure suberiticality while hot standby or hot shutdown con-ditions are maintained. Should it be necessary to deter-mine or verify the available chutdo,wn margin, 's primary coolant system comple can be drawn and analy:cd for boron concentration. This operation can be performed onsite by station personnel. -

Thus, no reliance is placed on the neutron monitoring system instrumentation until actions are begun to take .

the plant to cold shutdown. ~ '

The Applicant believen this ponition moots Appendix R requirements. In particular,Section III.L.l.a, which

' states that alternative shutdown capability shall be capabic of achieving and maintaining suberiticality,

' in met by manually scramming the reactor, since suberit-icality in accured by~innecting the control rods into the core and maintaining hot standby conditions,Section III.L.2.d, which states that direct indication of procosc variables nececcary to perform and control the reactivity control function chall be provided, in met because once the control rods have boon innerted into the core, direct indication of neutron flux is not required to control reactivity while hot standby is maintained. Credit is taken for repairing fire damage to neutron monitoring

' system cablen prior to initiating cold shutdown actions, as por Appendix R.

In nummary, the current position meets Appendix R and protection of neutron monitoring system cables from fire damage is not warranted.

b. Lower Cable Spreading Rooms: -

1) Fire Zone 3.2A Thin zone does not contain any of the instrumentation cable listed for this question.

2) Fire Zone 3.2B This zone contains cables from both traina of the neutron monitoring system. Refer to part a of this response for the Applicant's pc:! tion on this system. Cables for not more than one train out of two of inctrumentation for other parameteer listed in thia question are routed through this one. ,

010.57-2

e B/B-FSAR Thus, additional fire protection features are not required for this zone.

3) Fire Zone 3.2C This zone contains cables from both trains of the neutron monitoring syste=. Refer to part a of this response for the Applicant's position on this system. Cables for not more than one train out of two of instrumentation for other parameters

- listed in this question are routed through this zone.

4) Fire Zone 3.2D Cables for not more than one l train out of two of instrumentation for parameters listed in this question are routed through this zone. Thus, additional fire protection features ,-

are not required for this zone.

5) Fire Zone 3.2E Cables for not more than one train out of two of instrumentation for parameters listed in this question are routed through this zone. Thus, additional fire protection features are not required for this zone. '

c. Auxiliary Electric Equipment Room (Fire Zon'e 5.5-1)

This zone contai s cables from both trains of the neutron monitoring system. Refer to part a of this response A for the Applicant's position on this system.

Also routed through this zone are four-out-of-four cables for the steam generater wide range level and reactor coolant hot and cold leg temperature instrumentation.

A fire in this zone could potentially render all channels of these instruments inoperable. Although diverse inszru-mentation which would provide equivalent information is available to the plant operators independent of this zone, the Applicant will install additional indication for these three parameters in a location which is inde-pendent of this fire zone (and Fire Zones 11.4-0 and ll.4C-0: refer to parts d and e of this question).

The general scheme to be implemented for the new indi-cation is as follows. The signal from one of the four existing transmitters will be intercepted with a local transfer switch located between the containment penetration and the Auxiliary Electric Equipment Room. A new indicator will be provided. New equipment consists of the transfer switch, any required signal conditioning / processing circuitry, the indicator and associated cabling. In accordance with Section III.L.6 of Appendix R, the new 010.57-3 J

B/B-FSAR equipment and components will not be designed to meet seismic Category I criteria, the single failure criteria, or other design basis accident criteria. Only the inter-face needs to be designed so as not to degrade the perfor-mance or reliability of the existing equipment. The detailed design of this modification is expected to

, be available by January 31, 1983, at which time further

_ details will be provided.

Once this modification is complete, an operator would be dispatched to the local indicators for these three parameters should a fire in this zone render the normal indication inoperable. Using a portable radio or other plant communications equipment, the operator would maintain contact with the control room. Thus, the safe shutdown of the plant would not be impaired by a fire in this Zone.

d. Auxiliary Building General Area - Elevation 383 feet O inch (Fire Zone 11.4-0)

Only one out of two channels of the neutron monitoring [

system are present in this zone. Four-out-of-four channels of steam generator wide range level and reactor coolant hot and cold leg temperature instrumentation are present, ,

however. Refer to part c of this question for a descrip- I tion of the resolution for these instruments.

All eight channels of auxiliary feedwater flow are present.

A fire in this zone could render all auxiliary feedwater  ;

flow indication here inoperable. The auxiliary feedwater '

flow transmitters (located in Fire Zone 11.3-0) are indicating transmitters, however. Thus, if indication j

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, is lost in this zone, an operator could be sent to read the local indication at the transmitters. The operator {

5 would maintain communication with the control room by i

portable radio or other plant communications equipment.  !

Thus, the loss of the auxiliary feedwater flow indication due to a fire in this zone is acceptable.

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Radwaste and Remote Shutdown Control Rooms (Fire Zone ll.4C-0)

The discussion under part d of this question for Fire Zone 11.4-0 is also applicable for this fire zone.

Q10.57-4 i

B/B-FSAR

f. Radwaste Drumming Station and Tunnel (Fire Zone 14.1-0)

The fire zone boundary of this zone is redefined in the revised Fire Protection Report. The original boundary was arbitrary and did not conform to plant structural features. The new boundary follows a structural concrete wall. As a result of this change, the area on elevation 383 feet 0 inch roughly between column-rows 21 and 25 and P to Q was deleted f rom Fire Zone 14.1-0 and added to Fire Zone 11.4-0. This area included the cables l from the safe shutdown instrumentation listed in this question. Fire Zone 14.1-0 now contains no safe shutdown cables. Refer to part d of this question for a resolution of this question for Fire Zone 11.4-0.

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TABLE Q10.57-l ,

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INSTRUMENTATION CHANNELS ROUTED THROUGH FIRE ZONES INSTRUMENTATION ~

RC HOT &

FIRE NEUTRON SG WIDE COLD LEG AUXILIARY '

AREA ZONE MONITORING RANGE LEVEL TEMPERATURE FEEDWATER FLOW

a. Control Room 2.1-0 SR: 2/2 --- --- ---

b. Lower Cable 3.2A-1 --- --- --- ---

Spreading Rooms 3.2B-1 SR: 2/2 2/4 Cold Leg: 4/4 4/8 (One Train) o 3.2C-1 SR: 2/2 ---

Cold Leg: 4/4 4/8 (One Train) E[

w c$ 3.20-1 2/4 Cold Leg: 4/4 4/8 (One Train) h m >

y 3.2E-1 SR: 1/2 2/4 Hot Leg: 4/4 4/8 (One Train) W m

c. AEER 5.5-1 SR: 2/2 4/4 Hot Leg: 4/4 ---

(Power Sources) Cold Leg: 4/4 .,

d. Aux. Bldg. 11.4-0 SR: 1/2 4/4 Hot Leg: 4/4 El. 383 ft 0 in. Cold Leg: 4/4 8/8

e. RSP 11.4C-0 SR: 1/2 -

4/4 Hot Leg: 4/4 Cold Leg: 4/4 8/8

f. Radwaste 14.1-0 (1/2) * (4/4)* ---

, (8/8) * =

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• Due to redefinition of fire zone boundaries, Fire Zono 14.1-0 now has no safe shutdown cables routed through it.

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, QUESTION 0010.58 "The safe shutdown analysis indicates that a fire at the remote shutdown control (Section 2. 4. 2. 45, Fire Zone 11. 4C-0) will result in a loss of operability of all main steam atmospheric relief valves. Credit is taken for maintaining h,ot standby utilizing the main steam safety valves. This approach is unacceptable as the capability to maintain hot shutdown and achieve cold shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> can not be demonstrated without a means to depressuri e the secondary side. It is our position that one division of atmospheric relief valves be protected from fire, or provide discussion on the capability to locally manually control the atmospheric dump valves and maintain communi-cation with the control room." ..

RESPONSE

, The new hydraulic operators for the main steam atmospheric relief valves have the capability of local manual operation via a hand pump which is provided with the operators. In the event of a fire-induced failure to power or control cables which prevents the remote operation of these valves, the hand pump can be connected to the operator in a few minutes, allowing local operation of the valve. Once the hand pump is connected, the valve can be opened or closed locally. No possible failure mode of the power and control cables (open circuit, hot short, ground) can affect the local control capability.

A member of the plant operating staff would maintain communication i with the control room using a portable radio.

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