ML20082A616

Informs That Util Will Comply W/Requirements of App R to 10CFR50 & in Particular Section G,J & O.Util Will Also Provide Listed Info as Discussed at 810325 Meeting

ML20082A616
Person / Time
Site:	Susquehanna
Issue date:	03/26/1981
From:	Curtis N PENNSYLVANIA POWER & LIGHT CO.
To:	Youngblood B NRC
Shared Package
ML20079F008	List: ML20082A616 ML20082B190 ML20082B277 ML20082B291 ML20082B301 ML20082B304 ML20082B310 ML20082C348 ML20082C350 ML20082C364 ML20082C371 ML20082C373 ML20082C407 ML20082C410 ML20082C481 ML20082C487 ML20082C494
References
FOIA-94-137 PLA-683, NUDOCS 9504040152
Download: ML20082A616 (52)

Text

m one m q u u m u, nows.,. u,o,

,a..m,3 3,,, ;,,, ' bg/lp.

J.

r-L i

-M,...

mm

---

3 x.~

~

. k'..

j

• Q, ;

.' '< b-23A med;

/' APR l'5198l, i j llnrnu "e-

. - !c

.. m. c. w..,. c ce,w es.n.n ui..,

< s

[ p}

% nnn', : y e745381 i

.,g,

)

T.u. cR!f.iMINs.

00ii.rsg,ggE."My

%ff h W i ll S [.0 g.. j x a. w.s g

\\g

'.le$. ha,;. ii; 5P.ico 450 Harch 26,'198'1 O /#3 Mr. B.J.

Youngblood Licensing Branch 1 U.S. Nuclear Regulatory Cbmmission Washington, D.C.

20555 Susquehanna Steam Electric Station Docket Hos. 50-387 and 50-388 Fire. Protection EF.100450 File 841-2

.di.A-5E3

Dear Mr. Youngblood:

_As discussed in the'PP&L/HRC meetin'g on MErch 25, 1981,

.(

PP&L will comply with the requir.ements of Appendix R to 10 C.FR Part 50 and.in par.ticular Section G, J'and O.

c;.....

PP&L will elso provide the following as. discussed at the March 25, 1981 meeting:

Fir'e Detectors

. Fire detectors will be installed in all ' areas containit:g safe shutdown equipment as committed in~Rev~ision 1 i

t o t h e 'S u s q u e h a n n a S E 5 F i e eAot-ectterr-Rmrivvt-RK.

S&L-i n t~eWdrTo c omp l e t e t h i s i n s t a l l a t i o n b_y t h e e n d N pf 193.2.

Earlier com'pletion is'not possible due to

\\,

problems encountered"in the design and procurement effort'.

PP&L will provide a more detailed schedule analysis for the fire detector installation by May 22, 1981.

s.

/

F'i r e De t e c-t i~o n P-e nel - (cfr50 )

J The fire detection panel (C650) will be modified to satisfy the criteria for NFPA Class B wiring permitting the detection of'a wiring fault condition without resulting'in an alarm condition.

Additional-ly, indicator bulbs on the panel will be supervised.

9504040152 941114 PDR FOIA GUNTER94-137 PDR

c' 2,

(.

n. a. u n c

e-Prott ation 4

Fire Ratino-Gypsum Board Wall PP&L.wi.11. install doublesided Gypsum Board Walls (minimum one inch thictness) with a 3-hour fire rating.

PP&L provided 'for NRC review three (3) reports technically just.ifying that position.

Dampers PP&L will analyze drywall constrbcted walls to determine

~ ~if a fire induced f ailure of ducting will res01t'in wall failure.

In cases where the analysis indicates

- addit.ional duct supports and/or fire protective coating load.

is required, they will be installed prior to fuel Battery Room Area In.the Equipment Room (Fire Zone 0-28B), a two-hour l

E:

....r.ated fa'se ceiling will be installed prior to fuel raceways frc. an externai Tire.

' Wing 4:ac to pro.ect

.. wTTTs with doors rated as two-houi-barriers separate r

major Division T and T,T equfpcent within the fire '

z o n e..

The D.ivision 11 D.C. distribution panels located

t, i.n

t'he' : corridor near the cold ' instrument shop are enclosed wi thi n' t h e ;o n e - h o u r r a t e d.b akr..igrg,.,. ' g..... :..,,.;;: :.,7.,., ;,.,.,._,,41

~

C1 a ri fi e d W a t e r 5 t o r a o e '.T a nk' +.,* c.',..

;, f..? - 4,: ".c :.g.. '. ~.

~

~

~

.,. p., ;. :.,.4

~' ' suc'ti6n for 'the fire protection water source'fi oni t'he cl a ri fi e d w a t e r s to r a g e -t a n k. wi.1.1 b.e.t h ro.u.g h.. a s t a n dp.i p e in the-tank-such that at 16ast 300,0~00 ga'11ons of' the tanks. capacity is.available for fire protection use.

Thij action is being-taken~ in lieu' of providing a control room ' alarm of low water level?..-

yery truly'yours,.

~

.; h y:

'N.'W. 'C u r f;i s N.i.ce : president-Engineering and construction-Nuclear

-oc:

.it. K:..St a rk

.- ;~ :

~.

bec:

.N.W. Cu.rtis W.E. Barbarich

.B.A Snapp

~

C.T.'Coddingten

~~

R.J. Shovlin

-*.4.

e e <e e e

f h

lL acc on%

s VL Each diesel generator room is provided with its own ventilation system to main-tain temperature between 72 degrees Fahrenheit and 120 degree Fahrenheit.

Each supply fan starts with its associated diesel or when the room temperature exceeds 95 degrees Fahrenheit and continues to run after the diesel stops until the room temperature reaches about 78 degrees Fahrenheit.

Each of the four fan systems is located in a separate room within the seismic Category I diesel generator building and is protected against floods and tornadoes.

Each of the two areas of the engineered safeguards system service water pump-house is individually ventilated to maintain temperature between 60 degree Fahrenheit and 104 degrees Fahrenheit.

Each of the emer'gency service water system and residual heat removal service water pumps is provided with its own ventilation system.

Each supply fan starts with its associated pump or when the temperature exceeds 95 degrees Fahrenheit and continues to run after the pump stops until the temperature reaches 67 degrees Fahreheit.

The eight fans and components serving the engineered safeguards system pump-i house are located in the seismic Category I, flood and tornado protected pump-l house structure, which is divided into two areas with a missile proof separa-tion wall.

l j

Since the ventilation systems for both the diesels and engineered safeguards system pumphouse are designed to seismic Category I requirements in accordance with the guidelines of Regulatory Guide 1.29 and are located within seismic Category I, flood and tornado protected structures they meet the requirements i

of General Design Criterion 2 with regard to protection against natural phenomena.

The systems are also protected against high energy pipe breaks by virture of

)

J their location away from high energy systems, and are protected from missiles by virture of barriers.

They therefore meet the requirements of General Design Criterion 4 with respect of protection against pipe breaks and missiles.

Refer l

1 to Sections 3.5.1.1 and 3.6.1 for a more detailed evaluation of the protection against missiles and pipe breaks respectively.

Based on our review as described above we conclude that the engineered safe-guards system ventilation systems meet the guidelines of Regulatory Guide 1.29 regarding seismic design and meet the requirements of General Design Crite-rion 2 with respect to protection against natural phenomena, and Criterion 4 with respect to protection against the effects of pipe breaks and missiles.

We, therefore, conclude that the engineered safeguards system ventilation i

systems are acceptable.

)

9.5 Fire Protection Systems We have reviewed the Susquehanna 1 and 2 fire protection program reevaluation and fire hazards analysis submitted by the applicant by letter dated January

)

1978, including Revision 1.

The Susquehanna Steam Electric Station is a two unit site.

Since Units 1 and 2 are of the same design except as noted, the comments made in this report apply to both units.

The Susquehanna 1 and 2 reevaluation was in response to our request to review their fire protection program against the guidelines of Appendix A to Branch Technical Position (Branch Technical Position) ASB 9.5-1, " Guidelines for Fire Protection for Nuclear Power Plants." As part of our review, we visited the 9-17 i

• lant site to examine the relationship of safety related components, systems

(

id structures in specific plant areas to both combustible materials and to rire detection and suppression systems.

The overall objective of our review was to ensure that in the event of a fire at Susquehanna 1 and 2, personnel and the plant equipment would be adequate to safely shutdown the reactor, to maintain the plant in a safe shutdown condition, and to minimize the release of radioactivity to the environment.

Our review included an evaluation of the automatic and manually operated water and gas fire suppression systems, the fire detection system, fire barriers, fire doors and dampers, fire protection administrative controls, and the fire brigade size and training.

9.5.1 Fire Protection Systems Description and Evaluation 9.5.1.1 Water Supply Systems The water supply system is common to both units.

It consists of two fire pumps connected through a common header to a 12-inch cast-iron, cement-lined pipe yard main loop.

Both the electric motor and diesel driven fire pumps are rated at 2500 gpm at 125 psi head each.

The fire pumps and their controllers are UL listed.

Their design and installation conforms to the requirements of NFPA 20, " Standard for the Installation of Centrifugal Fire Pumps." The pumps are located in the circulating water pump house with the diesel fire pump cnclosed in a 3-hour fire rated enclosure with automatic sprinklers.

'he pumps take suction from th two larified water storage tanks of which t

J0,000 gallons are reserved for protection in each tank.

A second water source is provided by the six million gallon cooling tower basins.

The pumps discharge.into a common header with two separate connections to the under-ground 12-inch yard main loop.

A separate jockey pump automatically maintains yard main pressure from 105 to 125 psi.

The fire pumps start automatically on low header pressure.

If the water supply system pressure falls to 95 psi, the electric fire pump would start automatically.

As the pressure falls to 85 psi, the diesel engine driven pump would start.

The pumps can also be started manually from the control room and at the pumps.

The pumps can be stopped only at the pump controller panels located adjacent to the pumps.

Separate alarms are provided in the control room to monitor pump operation, prime mover availability, and failure of a fire pump to start.

The largest single fire suppression system water demand for areas that need to be protected is 1750 gpm.

Adding 500 gpm for hose streams creates a total water demand of 2250 gpm. One of the two fire pumps can deliver the required water flow.

A total of 27 yard hydrants are provided at intervals not exceeding 250 feet.

A hose house is provided for each hydrant.

All valves in the fire protection water supply system are electrically super-vised except for the post indicator valves, which are in the underground yard ain system.

The post indicator valves a're locked open under administrative i

i

},.

9-18 W

controls.

The electrical supervision of valves alarms in the control room.

The water supply valves meet the guidelines of Section C.3.b of Appendix A to branch technical position ASB 9.5-1, and are, therefore, acceptable.

We find that the water supply system can deliver the required water demand with one pump out of service.

We conclude that the water supply system is adequate, meets the guidelines of Section C.2 of Appendix A to branch technical position ASB 9.5-1 and is, therefore, acceptable.

9.5.1.2 Sprinkler and Standpipe Systems The wet pipe sprinkler systems, preaction sprinkler and deluge systems are i

designed to the requirements of National Fire Protection Association Standard No. 13, " Standard for Installation of Sprinkler Systems," and National Fire Protection Association 15, " Standard for Water Spray Fixed Systems." The manual i

hose stations are connected separately to the underground water supply loop.

Appropriate sectional and diversion valves are provided such that primary and secondary fire protection water supply will always be available should a single break develop.

The water supply valves to the sprinklers are electrically supervised with alarm and annunciation in the control room.

In addition, the sprinkler systems have water flow alarms which alarm in the control room.

The areas that have been equipped with water suppression systems include the following:

Reactor Core Isolation Cooling Pump Room High Pressure Coolant Injection Pump Room Heating, Ventilation and Air Conditioning Filter Rooms Railroad Airlock Control Building Auxiliary Rooms Condenser Area i

Reactor Feed Pump Turbine Turbine Central Area Turbine Condenser Gallery Turbine Hydro Control Power Room North Railroad Bay Turbine Condenser Mezzanine Diesel Engine Fire Pump Room Lower Cable Spreading Room Upper Cable Spreading Room PFP Turbine Room Diesel Generator Building Charcoal Filters Standby Gas Treatment Filter Emergency Outside Air Filters Centrifuge & Conditioner Turbine Pump Area Turbine Hydro Seal Oil Unit Turbine Lube Oil Area Turbine Motor Generator Area Turbine Filter Room Turbine Moisture Separation Area Radwaste Tank Vent Filter Room Radwaste Auxiliary Rooms Radwaste Controlled Zone Shop 9-19

~

{.

Manual hose stations are located throughout the plant to ensure that an effec-tive hose stream can be directed to any safety related area in the plant.

The standpipe systems are consistent with the requirements of National Fire Protec-l-

tion Association 14, " Standpipe and Hose Systems for Sizing, Spacing,-and Pipe Support Requirements."

l Based on our review, we conclude that the water suppression systems meet the guidelines of Appendix A to branch technical position ASB 9.5-1, and are, therefore, acceptable.

9.5.1.3 Gas Fire Suppression Systems low pressure carbon dioxide systems are provided for primary _ protection in the electrical equipment rooms as well as generator purging.

The design quantity of the agent is based on a 50% concentration.

Both automatic total flooding and manual suppression systems are used.

Automatic systems are activated by heat detection with the manual system being used to protect cables in concealed spaces on the control room level.

l The Power Generation Control Complex modules are provided with self-contained l

l Halon 1301 fire extinguishing systems.

Products of combustion or thermal detection activate automatic discharge of Halon to the panel and floor section produces a 20% concentration for 20 minutes. -The Halon fire extinguishing system complies with the specifications contained in the NED0-10466 Report, Revision 2 dated March 1978.

(

We have reviewed the design criteria and bases for'the Halon and CO., fire suppression systems. We conclude that these systems are in accordahce with the applicable portions of National Fire Protection Association Standard Nos. 12 and 12A, satisfy the provisions of Appendix A to Branch Technical Position ASB 9.5-1 and are, therefore, acceptable.

9.5.1.4 Fire Detection Systems The fire detection systems consist of the detectors, associated electrical power supplies, and the annunciation panels.

The types of detectors used l

are ionization (products of combustion), thermal, photoelectric and flame.

Fire detection systems give an audible and visual alarm which annunciates in the plant control room.

Local audible and/or. visual alarms are also provided.

The fire detection systems will be installed in all areas having safety related equipment and safety related cables.

This includes the control room area, the new and spent fuel pool storage areas, and area of cable concentration.

The fire detection systems, with the exception noted below, are installed according to National Fire Protection Association No. 72D, " Standard for the Installation, Maintenance, and Use of Proprietary Protection Signalling i

Systems." Those fire detection systems which are used to actuate suppression j

systems are a class A system defined in National Fire Protection Assocation 720.

I We are concerned that an open or break in the circuit from the local fire alarm control panel, located at various areas in the plant, to the control room i

e I

9-20

results in a fire alarm condition.

Also, the bulbs in the annunicator panel in the control room for the preceeding circuits are not supervised.

We will l

require that the applicants verify these conditions by providing circuit and bulb supervision per National Fire Protection Association 720.

We will report on this item in a subsequent safety evaluation report.

9.5.2 Other Items Related to Fire Protection Programs 9.5.2.1 Fire Barrier and Fire Barrier Penetrations Exterior walls and walls that separate buildings are three-hour fire rated walls.

The floor / ceiling assemblies separating areas in buildings contain-ing safe shutdown systems are either two or three-hour fire rated barriers.

With the exception of the drywall assemblies, for fire areas not having a three-hour fire rated assembly, we analyzed each individually with respect to its fuel load, fire suppression and detection systems, proximity to safe shutdown equipment, and concluded that the fire rated assemblies provided were adequate for the areas affected, meets sections D.1.d and D.I.j of Appendix A to branch technical position ASB 9.5-1 and therefore, is acceptable.

l I

Certain interior wall assemblies are required to have a three-hour fire rating and are constructed of drywall.

We are concerned that the drywall assemblies cannot provide the required fire rating.

The applicants have not verified the drywall design. We require that the applicants either verify the fire rating of the existing drywalls or provide a three-hour fire barrier. We will report I on this item in a subsequent safety evaluation report.

t By referencing specific UL designs, the applicants have provided documen w tion to our satisfaction to substantiate the fire rating of the fire penetra-tion seals used in the penetration cable trays, conduits,'and piping.

We have concluded that the fire seal ratings meet the guidelines of Appendix A to branch technical position ASB 9.5-1 and, therefore, are acceptable.

9.5.2.2 Fire Doors and Dampers We have reviewed the placement of fire doors and verified that all doorway openings to areas containing safe shutdown equipment or curcuits are provided with fire doors with ratings comensurate with the fire ratings of the wall.

L The fire dampers installed in the drywall assemblies are of an approved ty However, we are concerned that the actual installation of an approved damper in a drywall assembly has not oeen previously fire tested or approved.

The applicant has not provided enough information for their fire damper installa-tions. We will require that the applicants provide us with verification that the drywall assembly fire dampers are rated for three hours or upgrade the dampers to a three-hour design / installation.

We will report on this item in a Q ubsequent safety evaluation report, j

J l

The applicants have provided three-hour fire door dampers wherever ventilation ducts or openings penetrate three-hour fire rated walls or ceiling / floor assemblies.

All ventilation ducts or openings penetrating two-hour fire rated walls or floor / ceiling assemblies, and all such penetrations of one-hour assemblies for areas containing safe shutdown equipment or circuits, are provided with 1 1/2-hour fire dampers.

9-21 l

r l

l l(

Based on our review and the commitments, we conclude that the fire doors and dampers will be provided in accordance with the guidelines of Appendix A to l

BTP ASB 9.5-1, Section D.1.j, and are, therefore, acceptable.

l 9.5.3 Emergency Lighting Eight hour battery pack emergency lights are required for areas of the plant l

necessary for safe shutdown.

The applicants have installed self-contained eight-hour battery pack emergency lighting in all areas of the' plant which could be manned to bring the plant to a safe cold shutdown and in access and egress routes to and from all fire areas.

We conclude that the emergency lighting meets the requirements of Appendix A to BTP ASB 9.5-1, and, the provisions of Section III.J of Appendix R to 10 CFR Part 50 and is, therefore acceptable.

9.5.4 Fire Protection for Specific Areas 9.5.4.1 Control-Room l

The control room complex is separated from the radwaste building by a three-hour rated wall and from other areas by three-hour fire rated walls, and floor / ceiling assemblies.

Support areas within the control room complex, are separated from l

the control room by two-hour fire rated walls and 1 1/2 hour fire rated doors.

Smoke detection has been provided for the entire control room fire area, in t

the ventilation system ducts, and-in the main control board, and any other cabinet which contains redundant safe shutdown circuits.

Standpipe hose stations and portable extinguishers are provided for manual fire suppression activities.

At our request, the applicants have provided water type portable fire extinguishers.

As discussed in Section VI, the applicants have installed an emergency shutdown panel so that alternate shutdown capability exists independent of the control room.

Based on our review, we conclude that the control room fire protection meets the guidelines of Appendix A to BTP ASB 9.5-1 and is, therefore, acceptable.

9.5.4.2 Cable Spreading Room The cable spreading rooms (two for each unit) are separated from the balance of plant by three-hour fire-rated walls and floor / ceiling assemblies.

A drywall barrier separates unit one from unit two in both the upper and lower cable spreading rooms.

l Automatic fire suppression capability is provided by a pre-action sprinkler system with. supervised piping and activated by ionization and heat detectors.

Manual fire suppression capability is provided by standpipe with hose ststions and portable fire extinguishers.

The ventilation system is available for smoke i

l venting.

In addition, installed smoke detectors will initiate an early warning l

alarm in the control room prior to the pre-action sprinkler system actuation.

l 9-22 i

i

We were initially concerned that a fire could affect redundant shutdown systems I

located in the cable spreading room.

However, as discussed in Section VI the applicants have installed an alternate shutdown capability independent of the cable spreading rooms.

The fire protection for the cable spreading rooms meets the guidelines of Appendix A to BTP ASB 9.5-1 and is, therefore, acceptable.

9.5.4.3 Containment and Reactor Building Containment and Reactor Building fire protection features include hose stations, fire detectors, and fire extinguishers.

The applicant have committed to implement the provisions of III.G.2 of Appendix R to 10 CFR Part 50.

The recirculation pumps contain lube oil that could leak out after a seismic activity. We were concerned that this oil could be ignited and create a fire inside the containment structure.

To preclude this possibility, we required and the applicants agreed to provide an engineered oil collection system that will meet the requirements of Regulatory Guide 1.29, Paragraph C.2.

Based on our review and the applicants commitment, we find the oil collection system to be adequate and, therefore, acceptable.

We have reviewed the applicants' fire protection for the areas inside the containment and Reactor Building and conclude that the fire protection meets the guidelines of Appendix A to BTP ASB 9.5-1 and is, therefore, acceptable.

9.5.4.4 Emergency Diesel Generator Rooms The diesel generators are located in different fire areas separated by three-hour fire rated barriers.

At our request the applicant has agreed to seal the numerous openings in the east-west walls of each diesel generator room to maintain the fire integrity separating the diesels.

Each diesel generator room is protected by an automatic pre-action sprinkler system activated by combination smoke and flame detectors.

The applicant, at our request, agreed to supervise all doors leading to the emergency diesel rooms.

t Based on our evaluation and the commitments, we conclude that the fire protection for the diesel generator rooms meets the guidelines of Appendix A to BTP ASB 9.5-1 and is, therefore, acceptable, f

9.5.4.5 Battery Room Area 5-During-ourTC'e~vElt3e~ noticed-that"in the Battery ~ Room'therelere numerousN interactions between redundant divisions.

We are concerned that a single exposure fire could damage redundant cables and equipment in the battery room There is a heavy congestion of cables and equipment handling 125 volt area.

de power. We will require that the applicants meet the requirements set forth (inSectionIII.G.2ofAppendixRto10CFRPart50.

~

9.5.4.6 Other Plant Areas The applicants' Fire Hazards Analysis addressed other plant areas not specifically discussed in this report.

The applicants have committed to installed additional detectors, protable extinguishers and automatic sprinklers, prior to fuel load.

9-23

l

r..

.i 1

! j.

le find that the fire protection for these-areas, with the commitment made by.

-\\

che applicants to be in accordance with the guidelines of Appendix'A to BTP

}

ASB 9.5-1 and are, therefore,' acceptable.

9.5.8 Appendix R Statement-On May 23, 1980, the Comission issued a Memorandum and Order (CL 1-80-21) which i

states that:. "The combination'of the guidance contained in Appendix A to BTP 9.5-1 and the requirements set forth in this rule define-the essential elements for an acceptable fire protection program at nuclear' power plants docketed for Construction ~ Permit prior-to July 1,1976, for demonstration of compliance with

{

General Design Criterion 3 of Appendix A to 10 CFR Part 50."

On October 27,.

1980, the Commission approved a rule concerning fire protection.

The rule and j

,[

its Appendix R.were developed to' establish the minimum acceptable fire protection requirements necessary to resolve certain areas of' concern in contest between 4

the staff and licensees-of plants operating prior to January _1, 1979.

Although this fire protection rule does not apply to Susquehanna Units 1 and 2, the 4-i applicants verbally comitted to implement the following three issues identified in Appendix R as items to be backfitted.

1.

Section III G, Fire Protection of Safe Shutdown: Capability L

j_

2.

Section III.J, Emergency Lighting l

3.

Section III.0, Oil Collection System for Reactor Coolant Pump.

j i(

"he applicant will confirm this commitment in the near future.

Based on these commitments and our evaluation,~we. conclude that upon completion of required modifications the Susquehanna Units 1 and 2 fire protection program will meet the intent of all the requirements of'Appendir R.to 10 CFR Part 50 and therefore meets General Design Criterion 3, and, is acceptable.

(

9.5.9 Conclusion l

There are five unresolved fire protection items to be reviewed.

These five

'i i

items involve fire ratings of barriers and dampers, alternate shutdown systems, fire alarm system and protection of redundant divisions in the battery room-4 area. -We will report our review of these five items in a subsequent safety i

evaluation report.

The applicants have been informed that all fire protection i

items need to resolved prior to fuel loading date.

{

9.6 Other Auxiliary Systems

]

9.6.1 Comunication Systems The comunication system is designed to provide reliable intraplant and i

plant-to offsite-communications under both normal plant operation and accident conditions.

4 The communication systems provided for the Susquehanna Nuclear Station include:

4

};

i) an. intra plant public address system, b) a maintenance test jack telephone system, c) a private telephone system, d) a plant to offsite comunications i

9-24 i

1

g:

M/

3e z

-v i

Tthe NC requested the foilowing infornetlon:

j i

l i

i i

-l l

NC's ATTAC4BK 1 1.A Request:

l~

IVby 13,1982 PFEL Letter PLA-1094 including proposed installation procedures.

I l

Response

PLA-1094 Deted Wy 13, 1982 is atto,cd. The TSI test reports are not attached since they a re nevar accepted by-the N C.

The instalIation instructions, FieId Change Request and CC

' instructions ere in Appendices B, C, and D of Specification i-F1001. See iten 1.B belou.

1.8 Request

SouthestResearchinstituteProject 2. 01-7163 Report 2.1 I

n j g o %N, including the PRIL Test Specification.

%,L j

Response

PP8L's 1982 Fire Test Report 2. 01-7163 Heport 2. 1 is j

attached.

Also attached is Pl4L Specification F1001 that served as the test specification for the test.

1 j

1.C Request:

August 24, 1982 Southnest Research Institute Project 2.

01-7163 Report 2.

2 including the j

enclosures.

i

Response

This is a short report transmitted by a letter dated August i

24, 1982 and it is attached. The test camared te conduits j

that are wrapped with Therno-lag, but one us ccTpletely cured and the other was only partially cured. The test e s i

conducted to determine the irrpact of cure time but - the test i

articles were not representative of installations at SSES.

1 I

1.D Request:

}

August 1981 TSI Technical 2te 80181, Revision 1.

Response

This iten is included with item 1B above. The NC indicated j

in SSER #4 that PI4L censnitted, in a letter dated August 31, 1982, to suppletant the. cable wrap in Fire Zone 1-D in 4

accordance with the installation used in a October 27, 1981 test. Wille the letter (PLA-1288) indicated revision 1, the i

test was the Texas Utiiitles - test.

PFBL used the Texas i

Utilities test procedure in our 1982 test and TSI Technical

}

(

Mte 80181 Revision 2 is included in Texas Utilities Test Procedure vhich is Appendix A to PF8L's Spectfication F1001.

l

/

t 1

i o"-

e b

4 i

1.E Nguest:

'4 PRIL Letter PLA-1250.

Response

Attached is this letter thct transnittad PFBL's 1982 Fire Test

)

Report.

j 1.F Request:

Provide docurentation providing NC approval of PF8L request i

oontained in Letter PLA-1013 (approving the use of Therrro-Lag 1-hour wrap in Fire Zones 0-2fB, 0-2&l, and 1-2D) including deviation request (m )-8.

l Response-Attached is an excerpt formSSER #4 that approves the request i

nede in PLA-1013. The m-8 designation ves not added untiI i

1985 vien other Deviation Requests vere issued.

t 1.G Request:

l Provide documentation providing NC approval of PPBL i

procedures stimitted by PLA-1094.

\\

i

Response

The infornetion provided in PLA-1094ves questloned by the NC and ultirretely led to License Condition #7 and the August 1982 fire test. The instalIation procedures were then approved for conduit as indicated in SSSt #4.

1.H Request:

Provide PP8L procedures for actual initial installation of 4

l Thenro-Lag in Fi re Zones 0-288, 0-2fH, and 1-2D and provide CA records docuTenting the instalIation ves in accordance wita j

i these procedures.

1

i 4

Response

This infonTat ion is included with iten 1B above.

The j

identical Bechtei proceduresvere use to install Thenvo-f ag in l

these areas as vere used to install lherrro-lag for the 1982 i

j Fire Test.

These are in Appendix B to PRIL Specification F1001. The OA records wiii be retrleved to support the August 1

l 24 audit.

l

1.1 Request

Provide the PFEL procedures for adding fiberglass to the j

initial instalIation of ThenTo-Lag in Fi re Zones 0-288, 0-2fH,

^

and 1-2D and provide OA records docuranting the addition of l

the fiberglass ves in accordance with these procedures and 151 i

Techr.ical hbte 80181, Revision 1, dated 8/81 4

Response

I-fM1 82-474 is attached. The fiberglass was installed on the only cable tray that ves protected with lhenTo-lag in the i

e

' ~

thrse fire zones. 'that cable tray ves ire Fire Zono 1-2D and the tradifIcation ves M 82-474.. The CR records wili be f

retrleved to support the August 24 audit.

l 1

I k

t

i MC's ATTAO*BE 2 4

i 2.A Request:

Provide a. list of locations in thit 1 vdiere Therriu-Lag has i

been used to prwide a fire berrier to satisfy the requirarrents of Appendix R and identify this traterial as 1-i j

hour or 3-hour ratedtraterlal.

1

Response

A copy of PRIL drawings E-294 and E-295 are attached and they l

identify the fire zone and the rating prwided.for each l

recenay protected with Thertro-lag.

2.B Request:

Prwide a copy of the PI4L procedure used to install this g

,[)

Vi rinter ial.

O Response:

i

._. D. 2 Gopies of PF8L Specification F1000 f rem revision 0 to revision i

a g,.

,14' 4 are attached. In addition, Bechtel installed this Taterial i

~d, ',:s ' d e

r to Specification 8856-E-61 vdiich is contained in PRIL

\\ g< @1.M -

\\

i t

Specification F1001. See iteTi1B abwe.

, g (,

g 2.C Request:

1 If the traterial ms not installed in the sain tranner as the j

rraterial installed in Fire Zones 1-2D (RsTote ShutdoAn Pane!),

l 0-288 (Equipment Rxrn), and 0-2EH (Cold InstruTant Repair Shop), pravide the doctmentation vdiich justifles the 1-hour (or 3-hour) rating of thistraterial.

Response

i PP8L indicated to the NC in our response to NC But letin 92-01 that u vould conduct fire test in order to resolve this l

issue, since our test doctmentation relles on tests conducted i

l by TSI.

l Nbre docuTents grey be needed at a later date. Will provide additions as they are identified.

2 i

i 1

i 5

I

[..

~

i k.

\\

g\\

i 1

ATTACHMBir 7 l

SUSQUEEANNA HISTORY AND DOCUMENTATI I

REVIEWED BY SPECIAL REVIEW TEAM j

l (Docket No. 34 387)

Meeting between NRC r.aff and PP&L to discuss fire March 25,1981

/

SER input, with several open items, including the battery room March 26,1981 Uconsee letter committing to lostall 2-hour fire rated sel March 26,1981 enclosure in battery room.

i SSER with only open itsm being alterna shutdown system.

'i April 15,1981 Ucensee informed NRC of tesdng of Queloor cable wrap in i

June 19,1981 Licensee letter submitted two test reports for cable wrap ma i

October 26,1981 Included April 1981 and August 1981 TSI test reports.

Ucensee letter with proposed modifications to the Are protect program including a 1-hour rated cable wrap for battery i

February 9,1982 remote shutdown panel with only manual suppression and dete 1.stter referenced previous NRC acceptance of C.serds Pei b In December 1981.

i Meeting between the NRC staff and PP&L to discus Febhary March 11,1982 submittal. NRC requested a copy of the'TSI test results, as installe and installation procedure.

SSER anoopted PP&L's February 9,1982' proposal, but required April 16,1982 inst:11ed test or automatic satinguishing system.

'The proposed cable wrap was previously accepted based on independent laboratory test data... The applicant verbe!!y st the manufacturer's recommended installation procedure had not been followed when the cable wrap was insta!!ad. We do not accept the material as a 1-hour fire barrier when insta!1ed differently.'

Licensee provided TSI Technical Reports 8232-1 sad 8275-1 May 12,1982 l

(June 1981) and Bechtel installadon procedures.

Licensee provided TSI letter, June 3,1982, in response to NRC

~

~

June 9,1982 questions on tests submitted on May 12,1982. TSI report '

correct some noted errors.

M 1

L

~

'~ ~ - - - - - - - -

0 I

~

t

~'

APPROVAL PROCESS BTP APCSB 9.5-1 (APPEt0lX A) ISSUED BY NRC (FEB, 77) o SSES FIRE PROTECT!oN REVIEW REPORT (FPRR) ISSUED (JAN, 78) o NRC PROPOSED RULE 10 CFR 50.48 Ato APP. R PUBLISHED FOR o

CO*iENT (MAY, 80) o NRC SITE WALKDOWN ON FIRE PROTECTION (0CT/Nov, 80) o NRC ISSUED 10 G R 50.48 N o APPEf0lX R (Nov, 80)

{

NRC ISSUED 40 AND 281 SERIES QUEST!oNS (FIRE PROTECT!oN) o To SSES (JAN, 81) o PPal RESPONDED TO NRC QUESTIONS (FEB, 81) o REVISloN 1 To SSES FPRR ISSUED (thR, 81) o PPal/NRC MEETING (l%R, 81)

PP&L ComlTTED To lli.G, J & 0 (D0cUMENTED IN PLA-683) o NRC ISSUED NUREG 0776 (SSES SER) (APR, 81) o NRC 1SSUED SUPPL. #1 To SSES SER (JUN, 81) o NRC ISSUED SUPPL #2 To SSES SER (SEP, 81)

PPat COMPLETED REf0TE SHUTDOWN ltDIFICATION (DEC, 81)

- f o

PPal REQUESTED VARIANCE FOR USE OF 1-HOUR WRAP (FEB, 82) o o

NRC ISSUED SUPPL. #3 To SSES SER (JUL, 82).

o UNIT 1 OPERATING LICENSE ISSUED (JUL, 82) o PPal CatilTTED To tODIFY l-HOUR WRAP (Ats, 82)

PP&L COMPLETED WRAP ltDIFICATION (OCT, 82) o o

NRC ISSUED SUPPL. #4 To SSES SER (Nov, 82)'

o REVISloN 2 To SSES FPRR ISSUED (DEC, 82)

PPal REoVESTED LICENSE AMEtaiEfff To INCORPORATE REV. 2 o

To FPRR (JAN, 83) o NRC ISSUED SUPPL. #5 To SSES SER (ihR, 83)

AMENDMENT 16 To UNIT 1 LICENSE ISSUED To INCORPORATE j

o REV. 2 To THE SSES FPRR (SEP, 83) o NRC ISSUED GENERIC LETTER 83-33 (0CT, 83)

PP&L REoVESTED EXEMPTION FROM APP. R SEPARATloN CRITE o

(DEC,83) o NRC ISSUED SUPPL. #6 To SSES SER (f%R, 84) o UNIT 2 OPERATING LICENSE ISSUED (PAR, 84) l I

SSER stating that TSI tests submitted by Pl &L were not p accordance with adequats QA procedures and therefore no June 28,1982 De application procedun wp also not clea thermocouples. The licensee should conduct an ASTM E 1 approved tesdag laboratory,' or install automade fire ext system.

Licensee committed to perform a 1-hour test of TSI matadaj Comanche Peak test procedure. Material to be installed per P July 6,1982 procedures submi'.ted on May 12,1982.

~

Licensee subm!tted copy of Test $#%*m.

July 23,1982 Licensee sub'mitted test report from SWRI. hst conducted on August 25,1982 August 10,1982.

Licensee committed to modify the Insta11adon of cable wrap trays by adding fiberglan armoring in accordance with TS August 31,1982 Note !01:1, Maion I, August 1981.

SSER approved the 1-hour fire barder installadon. August 198 was only sooepted for conduit, The cable tmys exceeded 325 September 15,1982 I

which was applied. The approved method ofinstalladon is based o CPSES submittal of October 27,1981, and was referenced.

h e

e I

~

[

O/

UMi f i

Pennsylvania Power & Light Company shall' implement and maintain 9

N.

2.C(3) in effect all provisions of the approved fire protection program as described in the Fire Protection Feview Report for the

~ t r. g facility and as approved in the Safety Evaluation dated August 9, 1989 subject to the following provisions

The licensee may make changes to the approved fire protection w

program without prior approval of the Commission only if those changes.would not adversely affect the ability to l

achieve and maintain safe shutdown in the event of a fire.

4

~

l (4) Operation with Partial Feedwater Heatino at End-of-Cycle (Section 15.1 1

SER, 55ER #1) i i

PP&L shall not operate with partial feedwater heating for the purpose 2

of extending the normal fuel cycle unless acceptable,iustification is t

provided to and approved by the' NRC staff prior to such operation, j

l 1

[

(5) Initial Test Prooram (Section 14, SER, SSER #1)'

2 PP&L shall conduct.the post-fuel-loading initial test program described 1

in Section-14 of the Final Safety Analysis Report, as amended without l

i

~

making any major modifications unless such modifications have prior l

!!RC approval. Major modifications are defined as:

4 I

(a) Elimination of any safety-related test *;

(b) Modifications of objectives, test met' hods or acceptance criteria jj i

for any safety-related test;

.g l j {f ~,

l Performance of any safety-related test at a power level different (c) from that stated in the licensees' Final Safety Analysis Report by more than 5 percent of rated powe'r; i

Failure to satisfactorily complete the entire initial startup l

(d) test program by the time core burnup equals 120 effective l-full power days; Deviation from initial test program adminstrative, procedures or 1

(e) quality assurance controls described in the licensees' Final Safety Analysis Report; and Delays in the test program in excess'of 30 days (14 days if power (g)

If

)

, levels exceeds 50 percent) concurrent with power operation.

continued power operation is desired during a delay, the licensees shall provide justification that adequate testing has been per-formed and evaluated to demonstrate that the facility can be operated at the planned power level with reasonable assurance that the health and safety of the public will not be endangered.

i u,

.,n.

• Safety-related tests are those test which verify the design, construction,

(

'?!

and operation of safety-related systems,, structures, and equipment.

f e

I

ll l

,l i

~

=

iaf r

r

'w

(

w Fns8

.e T

f

^

w P

p n

r A

e r,.-

a ee v

I c

s t

e mmmr h u

O

)

r, i

l n

[&

s ak sC e

4d

=

\\

k s, &

w s

h a

c c

e T @o

~

l N

i s

T o

gh r

(

H a

t h

t x

uaJ h

c i

t

/

a

\\

g%

C R

6 t

y r

P l

e n

+

1

/

s o

o h Q A w

G pt R9 w

s

(

=

9 a

w r

n v 4!

o a

I e

i t

iW s

t r

2~-

y 4i h'

w c

n w

4 w

a o

m a

)

t 9

d.

s e

s xN a

w D]

M

~

+

d n

k O

$s I

l l'

5 w

w c

w f(a ef e

/

n e

v S

da d

2 (t

e o

o

_ /-

S i

e n

a P

%n 0

v a

O

+

s v;

T mnu e

o J

S. V A9 s

i e

o s

_ h ewyw.

o c

i t

l sad

)

c e

Me u

d(

L d

/

L w 'B w k

O o

a P

ds M

o e

at mn c

n k

a

/

e i

oy mju e

W 'J rw 2

c 1

r o h~

r B

hPT

/

6

a

[f i/-!

j cool the core following the postulated LOCA.

GE has performed analyses te l

show that acceptable core cooling is maintained unoer these conditions if the j

i single LPCI pump operates for at least 10 min.

Refer to Section 6.3 of this l.

supplement for an evaluation of the ac:eptability of the emergency cere ecoling system (ECCS) analyses under these conditions.

)

To meet the conditions of the assumptions used in the analyses performed by GE, i

the licensee had to show that the LDCI pump cculd operate f:r 10 min withcut cooling water to the pump room coolers; lube oil coolers, and seal coolers without loss of function.

By letter dated November 8, 1982,.the licensee l

provided data from the manufacturers backed up by actual testing to'show that the pump would operate for the required 10 min without exceeding any design l

limits on the bearings or seals.

Refer also to Section 6.3 of this supplement l

for an evaluation of the test results and operation of the pumps under these conditions.

For the specific LOCA identified above, the ESW loops are actually not capable of providing 100% of the heat loads for both units as originally reported-in I

the FSAR and the SER. However, the licensee has shown by the ECCS analyses, LpCI tests, and manufacturers' data that cooling from the inoperable ESW loop i

is not necessary to meet the results of the ECCS analyses.

For all other acci-i dent scenarios that the staff is aware of, one ESW loop is capable of removing 10C% of the heat load following an accident in one unit and an crderly shutdown and cooldown of the remaining unit.

Based on its review of the ecdifications proposed to transfer the diesel cooling water from ESW loop A to loop B plus the acceptability of the ECCS analyses and LPCf' pump data as evaluated in Section 6.3 of thi.s supplement,- the staff con-cludes that the ESW system meets' the single-failure criterien of GCC 44, " Cool-ing Water," and is, therefore, acceptable.

l l

9.5 Fire protectien Systems

)

i l

9.5.4 Fire Protection for Specific Areas l

9.5.4.5 Battery Room Area By letter dated February 9, 1982, the licensee proposed a change to the design that the staff had previously approved for the protection'of redundant trains l

of equipment in the battery room area (Fire Zones 0-288 and 0-28H). The pro-l posed change involved the use of a 1-hour-fire-rated cable wrap instead of a 2-hour-fire-rated ceiling.for the battery rooms and remote shutdown panel area (Fire Zone 1-2D).

In the SER, the staff found the proposed change acceptable, however, it noted that the licensee had not installed the 1-hour-fire-rated cable wrap in accordance with the manufacturer's recommended application pre-cedure. The staff requested that the licensee either provide test data demonstrating that the fire-resistance rating of the cable wrap, as insth ' 16,

is I hour or install an automatic extinguishing system.

l By letter dated May 12,11982, the licensee provided additional test data to demonstrate the fire-resistance rating of the cable wrap..The staff reviewed 1

i Susquehanna SSER 4 9-2 l

c e j g,

I this information and concluded that the wrap w'as not acceptable as a barrier.

It reported its conclusion in Supplement 3.

By letter dated August 25, 1982, l

the licensee provided additional information.

The licensee has conducted an ASTM E-119 test on the proposed cable wrap in its as-installed configuration.

The test results are documented in a report entitled, " Qualification Fire Test of a Protective Envelop System," dated August 1982. The tests show that con-duits protected by the proposed method possess a full 1-hour rating.

Cable trays and air drops, however, exceeded the acceptance criteria of a temperature i

rise of 250' F above ambient in approximately 45 minutes.

The proposed method

~

of protecting cable trays and air drops is, therefore, not acceptable as a 1-hour-rated fire barrier.

By letter dated August 31, 1982, the licensee has proposed to supplement the cable wrap on all cable trays in Fire Zone 1-2D (re-mote shutdown panel area) before 5% power is exceeded.

Fire Zones 0-2BH and 0-280 do not contain any protected cable trays.

The licensee has committed to provide the' cable wrap, previously approved, and to install it in the manner originally tested. The details of this test and installation procedure are documented in a report entitled, " Fire Qualification Test of a Protective Envelop System," dated October 27, 1981.

The staff finds this an acceptable method of providing a 1-hour-rated fire barrier for cable trays. With this commitment, the staff finds that the fire protection for Fire Zones 1-2D, 0-28B, and 0-28H meet its guidelines and is, therefore, acceptable.

With the resolution of this item, the basis of its evaluation, the staff con-l cludes that the Fire Protection Program for the Susquehanna Steam Electric Station meets the guidelines contained in Apoendix A to Branch Technical Posi-tion ASB 9.5-1, the technical requirements of Appendix R to 10 CFR 50, and the l

requffements of GDC 3, and is, therefore, acceptable.

~

1 1

i

~

i Susquehanna SSER 4 9-3

~

V

~ -

' ^ '

I

_..... a : w..

g (o N\\ T

\\

]_...

1Ie ll (3)

Conduct of Work Activities During Fuel Load and Initial Startup (i

PP&L shall review by committee all facility construction, Preoperational 1

Testing, and System Demonstration activities performed concurrently with facility initial fuel loading or with the facility Startup Test Program to assure that the activity will not affect the safe performance of the. facility fuel loading or the portion of the facility Startup Program being performed. The review shall address, l

as. a minimum, system interaction, span of control, staffing, security i

and health physics, with respect to performance of the activity d

concurrently with the facility fuel loading or the portion of the facility Startup Program being performed. The committee for the 1

review shall be composed of a least.three members, knowledgable

]

in the above areas, and who meet the qualifications for professional-y technical personnel specified by section 4.4 of ANSI N18.7-1971.

j' i

At least one of these three shall be a senior member of the Assistant i

Superintendent of Plant's staff.

]l

)I (4)

Thermal and Hydraulic Design (Section 4.4, SER)

H (a)

~

PP&L is prohibited from power operation under natural circulation conditions.

0 (b) Prior to startup following the first refueling outagb, PP&L

)

]

shall provide, for NRC review and approval, a new stability 1

analysis, indicating the results for appropriate exposure

'm core conditions.

5)

Octlification of-Purge-Yalves i

Khenever the operational condition is other than cold shutdown or re#ueling, PP&L shall naintain each containment purge and vent isolation valve greater than 2-in. nominal diameter in one of 3

o the folicwing conditions:

g- @ $

Closed and electrically prohibited from opening, a) 1 l

d b)

Blocked so as not to permit opening by more than 50 degrees, oi-

/

c)

Operated to permit opening by more than 50 degrees after denenstrating that the valves are qualified to close from the full open ;csition against peak LOCA pressure, and are also qualified per the criteria of Branch Technical Position CSB 6-4.

Purge valve cualification documentation must be approved by the NRC prior to c:erating valves in this mode. -

(6) Fire Protection Program 7

PP&L shall' maintain in effect and fully implement all provisions of

._h !

i the approved Fire Protection Review Report, as amended through i t; Revision 2 dated November 1982.

In addition, PP&L shall maintain

~

.l

..... q the fire protection program set forth in Appendix R to 10 CFR Part 50.

}

t~

j

(

,a 7

l

[lN W E 2]

j 1

j Docket tb. 50-[#]

i

[LIGNIEE KIMHi]

4 l

Dear [ TITLE /NME]:

1 1

i SJulLT: IEIST RR AfDITIOMt. INUBATICN FENDifG GNERIC LETTER 92-08, "1HinO-LAG 330-1 FIE BMRIEHi," RHUoNT TO 10 CFR 50.54(f) -

[PUINT NME]

i In your response of [DATE),1993, to Generic Letter (G.) 92-08, I

"Thornn-Lag 330-1 Fire Barriers," you indicated that actions necessary to j

restore the operability of these barriers at [PUINT NWE] vould be based on 1

the results of the industry test program being coordinated in the NJclear 4

lenagenent and Resources CounciI (NMWC). During recent meetings with l

U.S. Itclear Regulatory OnnissIon (NC) staff, the Executive Director for Cherations and the Onnission, NMEC described the scope of its Themn-Lag j

fire barrier progran, the results of the Phase 1 fire tests, and planned i

Phase 2 tests. The progran is Iimited to cartain 1-hour and 3-hour conduit 1

and cable trmy fire barrler configurations and the deveIoprant of guidance for 1

applying the test results to plant-specific fire barrler configurations.

l Mmever, NM40's progran is not intended to bound all in-plant Thernn-Lag i

fire berrler configurations. DJring a MMUC-sponsored industry verkshop on Decarber 1 and 2,1993, NMWC presented the scope of its program and the j

l Phase 1 test results to the licensees.

In view of the Iimited scope of the NMUC progran and the Iimited success of the Phase 1 tests, it is clear to the staff that the NMEC prograrnwill not be sufficlent to resolve ali Thernu-Lag fire barrler iasues identifled in j

G. 92-08. Therefore, Iicensees may need to take additianal actions to address fire endurance and agacity derating concerns with their in-plant ThenTo-Lag l

barrlors.

i To help ensure timeiy resolution of the fire barrler issues at [ PLANT NWE],

the staff requires additional inforrration on the configurations and arounts of Therrro-Lag fire barrlers installed in the plant and the cable loadings within 4

particular Themn-Lag configurations. This inforrration is necessary to revias l

NMUC's guidance for applying the test results to plant-specific barrler l

confI rations and to identify configurations that are outside the scope of

's test progran. For those configurations that are outside the scope of i

the progran or for those configurations that you dean are irrpractical to tegrade, ve request that you provide plans and schedules for resolving the l

technical issues. Identifled in G. 92-08.

1 i

/

a i

/

i,

(

O e

i s

[LICBGEE) (Date]

You are required, pursuant to Section 182(a) of the AtoTile Energy Act of 1954, as amended, and 10 GR 50.54(f), to sutmit a written report that contains the infomtion specified in the enclosure to this letter within 45 days f ran receipt of this letter. Your response riust be sutmltted under oath or af f I rrrut lon. Please sutmlt your response to the undersigned, with a copy to the appropriate Regional AdT)inistrator. Please retain all infonTution and docurentation used to respond to this request on site for future NC audits or inspections.

This request is covered by Of fice of 2nageTent and Budget Clearance Nnber 3150-0011, vdilch expires June 30, 1994. Tho estirTated average runber of burden hours of 300 person-hours is anticipated to increase by an additional 1

120 person-hours for each addressee's response, including the tirre required to assess the requirerrants for information, search data sources, gather and analyze the data, and prepare the required letters. This revised estirrated l

average runter of burden hours pertains only to the identifled response-related : Tatters and does not include the time to irrpleTent the actions required to conply with the applicable regulations, Iiconse conditions, or conni tments. Osanants on the accuracy of this estimste and suggestions to reduce the burden msy be directed to the Office of Inforristion and Regulatory Af fai rs (3150-0011), PEB-3019, Of fice of 2nageTent and Budget, Mshington, D.C. 20503, and to the U.S. POclear Regulatory Cannission, Infornation and Records %nagstent Branch M4E-7714), Division of Infonration Support Services, Of fice of Infonration and Resources 2nagsrent, %shington, D.C.

20555, if you have any questions about this riutter, please contact [PUM RW at 301-504-[#] or Patrick % dden at 301-504-2854.

Sincerely, i

i L. J. Callan Acting Associate Director for Projects Office of POclear Reactor Regulation

Enclosure:

Request f>,r Addi:lonal Information cc w/ enclosure:

See next page

' [LIC8%EE] [Dato]

You are required, pursuant to Section 182(a) of the Atornic Energy Act of 1954, as arended, and 10 GR 50.54(f), to sutmit a written report that contains the infomation specified in the enclosure to this letter within 45 days f rcm receipt of this letter. Your response nust be sutmitted under oath or af f i nTut ion. Please sutmit your response to the undersigned, with a copy to the appropriate Regional Adninistrator. Please retain all information and docurentation used to respond to this request on site for future N E audits or inspections.

This request is covered by Office of % nagerent and Budget Clearance NJTber 3150-0011, vhich expires June 30, 1994. The estirrsted average nuTber of burden hours of 300 person-hours is anticipated to increase by an additional 120 person-hours for each addressee's response, including the tirre required to assess the requirarents for inforrration, search data sources, gather and analyze the data, and prepare the required letters. This revised estirTated average nuTber of burden hours pertains only to the identified response-related tratters and does not include the tirre to irrplarent the actions required to caiply with the applicable regulations, Iicense conditions, or ccnsni trTents. Carrerents on the accuracy of this estirrste and suggestions to reduce the burden rrey be directed to the Of fice of Inforrration and Regulatory Af fairs (3150-0011), ND3-3019, Of fice of Mnagerent and Budget, Mshington, D.C. 20503, and to the U.S. N; clear Regulatory Omsnission, Information and Records 2nagerent Branch MBB-7714), Division of Information Support Services, Of fice of Infonretion and Resources Mnagerent, Mshington, D.C.

20555.

If you have any questions about this ristter, please contact [ PLANT INI] at 301-504-INNBER] or Patrick 2dden at 301-504-2854.

Sincerely, l

L. J. Callan Acting Associate Director for Projects Office of NacIear Reactor Regulation

Enclosure:

Request for Additional Infornution cc w/ enclosure:

See next page DISTRIRKl0V Docket File 04:Cracken M3aTberoni RA NC PER IWbdden R!ngran, R&B LA Local F m CBerlinger Region [#]

CMJiley (OlG)

PD[#] FUg FUenkins OCC EPaul ik (RI I I /01)

Div Dir O h!Iey (OiG)

AGE (10)

Asst Dir LCalIan FD OFFI LA:FD IMFD PD:PD (A)ACP Ntf LJCalIan IV.TU 12/ /93 12/ /93 12/ /93 12/ /93 COP (

Yes/bb Yes/hb Yes/Bb Yes/rb Yes/rb CFFICIAL RECDD CDP /

F1IB#tVE: G:\\WOOCS\\INWE]

IN1rn E i

1 FRIET FCR EDITIO@L IfRRATICN FENDIN3 GMRIC LETTER 92-08 l

"'IFUh0-LAG 330-1 FIFE IWElERS" RRDNT TO 10 CFR 50.54(f) 1.

Thernro-Lag Fire Barrier Cbnfigurations and Arounts A.

Discussion Generic Letter (GL) 92-08,"ThenTu-Lag 330-1 Fire Barriers," applied i

to ali 1-hour and al13-hour ThenTD-Lag 330-1 materials and barrler systems constructed by any asseTbly method, such as by joining preformed panels and conduit preshapes, and trcmel, spray, and brush-on applications. This includes alI fire barrlers, alI barriers to achieve physical independence of electrical systers, i

radiant energy heat shields, and barriers installed to enclose intervening carbustibles.

4 B.

Required information l

1.

Describe the ThenTo-Lag 330-1 barriers installed in the plant to

)

a.

meet 10 OR 50.48 or Appendix R to 10 CFR Part 50, b.

support an exeTption f rorn Appendix R, c.

achieve physical independence of electrical systers, 1

d.

meet a condition of the plant operating license, i

e.

satisfy licensing ocrunitments.

I The descriptions should include the foilouing infonTatlon:

the intended purpose and fire rating of the barrier (for exaTple, 3-hour fire barrier, 1-hour fire barrier, radiant energy heat

{

shield), and the type and dimension of the barrier (for exarple, j

8-f t by 10-f t welI, 4-f t by 3-f t by 2-f t equipTent enclosure, 36-inch-wide cable tray, or 3-inch-diameter conduit).

a 2.

For the total population of ThenTo-Lag fire barrlers described i

under Itan I.B.1, sutrnit an approxirretion of.

i a.

For cable tray barriers:

the total linear feet and square feet of 1-hour barriers and the total linear feet and square feet of 3-hour barriers.

b.

For conduit barriers:

the total linear feet of 1-hour barriers and the total linear feet of 3-hour barriers.

c.

For all other fire barriers:

the total square feet of 1-hour barriers and the total square feet of 3-hour barriers.

f.

d.

For all other barriers and radiant energy heat shields:

the total linear or square feet of 1-hour barriers and the total linear or square feet of 3-hour barriers, as appropriate for j

the barrier configuration or type.

J

l 4

' 1 i

11.

Irrportant Barrier Paramters i

j A.

Discussion II in a letter of July 29, 1993, f ran A. Nhrion, N.NpfC, to i

C. NbCracken, NC, NMfC stated:

" Relative to bounded configurations,... [ilt will be the utilities' responsibility to verify their baseIine instalIations are bounded." Furthertrore, i

NMfC stated that the pararmters of inportance for utility use of i

data f rcm the industry Therrro-Lag fire barrier test progran are:

j

1. h et orientation (horizontal, vertical, radial bends)

2. Condult i

3. Junction boxes and lateral bends i

4. laMar-back cable tray with single layer cable fill i

5. Cable trmy with T-Section j

6. Racaney traterial (aluninun, steel) j

7. Support protection, therrral shorts (penetrating eleTants)

{

8. Alr drops l

9. BaseIine fire barrler paneI thickness i

10. Preforrred conduit panels 1

11. Panel rib orientation (parallel or perpendicular to the racaney) i

12. Lhsupported spans i

13. Stress skin orientation (Inside or outside) 2

14. Stress skin over joints or no stress skin over joints

15. Stress skin tles or no stress skin ties

16. Dry-fit, post-buttered joints or prebuttered joints

17. Joint gap width j

18. Butt joints or grooved and scored joints

19. Steel bands or tie wires

20. Band / wire spacing

21. Band / wire distance to joints l

22. hb internal bands in trays

23. bb additional tronel traterial over sections and joints or j

additional troneltraterial applied j

24. It edge guards or edge guards 1

\\

j Each N.MfC cable tray fire test specirran includes 15 percent cable fills (i.e., a single layer of cables uniformly distributed across 1

the bottan of the cable tray). This approach requires consideration i

of plant-specific cable infomation during the assessments of tested i

configurations and test results in relation to plant-specific Thenro-Lag configurations; for exarple, cable trays with less j

therrral trass (cable fiII) than the N.hpfC test specimens, dif ferent j

cable types, and the proximity of the cables to the Thorno-Lag j

(e.g., cables nay be installed in contact with the unexposed surface i

of the Therrm-Lag or Tay core inta contact during a fire if the-i ThenTo-rraterial sags).

In its letter of July 29,1993, IGPFC j

stated:

iiitles using the results of the MhpfC testing wiii need to evaluate their installed cable fill and ensure that it is i

bounded by the tested cable fill." PG pfC is not conducting any l

cable functionality tests or evaluations and stated that cable 4

functianality evaluations will be perforned by utiIitles using data f ron the generic progran.

i 4

' The parareters of inportance concerning cables protected by fire barriers are:

1.

Cable size and type (pmer, control, or instrurentation).

I 2.

Cable jackst type (thenroplastic, thenroset) and materials.

3.

Cable conductor insulation type (thenroplastic, thernoset plastic) and traterials.

i 1

4.

Cable fiII and distribution of cables within the protected i

conduit or cable tray.

5.

Proximity of cables to the unexposed (inside) surfaces of the fire barrier.

j 6.

Presence of rraterials between the cables and the unexposed side of the fire barrlertraterial (for exarple, SealteTp cloth, which Is used in the PGDIC test specimens).

7.

Cable operating tarperature, j

8.

Terperatures at which the cables can no longer perform their intended function when energized at rated voltage and current.

Other paraTaters that are unique to particular barriers, such as i

interfaces between Therrio-Lag rraterials and other fire barrier l

nutarials or building features (weils, etc.) and internal supports, i

are also irrportant.

In addition, because of questions about the uniformity of the Therrro-Lag fire barrler treterials produced over j

tirre, PGNC stated in its letter of July 29, 1993, that "[c]henical i

analysis of Thenro-lag traterials provided for the progran, as welI as sarples f rom utility stock, will be performed, and a test report prepared contparing the chenical ocnposition of the respective sarples." The results of the chenical analyses may indicate that variations in the chemical properties of 1henro-Lag are significant i

and nay require addltional plant-specific Infonration in the future.

1 B.

Required Inforristion 1.

State whether or not you have obtained and verifled each of the

{

aforsrentioned parareters for each Therrro-Lag barrier installed in the plant.

If not, discuss the parareters you have not i

obtained or verified. Retain detailed infornation on site for

]

NC audit where the aforarentioned parareters are knen.

(

2.

For any parameter that is not knaan or has not been verified, i

describe hcw you wilI evaluate the in-plant barrler for acceptabiiity.

3.

To evaluate PGNC's application guidance, an understanding of the types and extent of the unknen parareters is needed.

Describe the type and extent of the unkroon parareters at your t

plant in this context.

4 i

i i

l a

a i

}

l j

111. Thernu-Lag Fire Barriers Outside the Scope of the N.NpfC Progran 1

A.

Discussion

~

In your response to a 92-08, you indicated that actions necessary to restore the operability of these barriers vould be based on the results of the NASFC test program. Ouring rscent rmetI with the i

NC staf f, the Executive Director for (berations and the

ssion, j

NASFC described the scope of Its Theso-Lag fire berrler progran, the results of the Phase 1 fire tests, and planned Phase 2 tests.

'ihe progran is Iimited to certain 1-hour and 3-hour condult and i

cable tray fire barrler configurations and the developent of i

guidance for applying the test results to plant-specific fire barrier configurations. ftmover, MA8FC's progran is not intended to bound alI in-plant Therrm-Lag fire barrler configurations.

In viav of the scope of the NApfC progran and the limited success of l

the Phase 1 tests, it is clear that the MASIC prograrnwill not be -

sufficient to resolve all Themo-Lag fire barrler lasues identifled in a 92-08. Therefore, Iiconseesrrey need to take additional 4

actions to address fire endurance and aTpacity deratIng concerns j

with in-plant Themo-Lag barriers.

l B.

Required info mation 1.

Describe the' barriers discussed under Itan I.B.1 that you have determined wili not be bounded by the NASIC test progran.

2.

Describe the plant-specific corractive action progran or plan

]

you expect to use to evaluate the fire barrier configuratlons i

particular to the plant. This description should include a discussion of the evaluations and tests being considered to resolve the fire barrler issues identifled in a 92-08 and to deronstrate the adequacy of existing in-plant barrlers.

3.

If a plant-specific fire endurance test progran is anticipated, describe the foiloving:

a.

Anticipated test specimens.

b.

Test rinthodology and acceptance criteria including cable functionality.

IV. ATpacity Derating A.

Discussion MA#fC has informed the staf f that it intends to use the Texas UtiIitles (1U) Electric CbTpany and Tennessee Valley Authority (TM) arpacity derating test results to develop an electrical racanay caTponent nudeI for the industry. AddItlonal Inforrration is needed to determine vhether or not your Therrro-Lag barrler configurations 1

(to protect the safe-shutdoan capabiiity f ron fire or to achieve physical independence of electrical systers) are within the scope of the NASFC progran and, if not, how the in-plant barriers will be evaluated for the arpacity derating concerns identifled in a 92-08.

s-

o l !

F B.

lisquired infornution l

1.

For the berrlers described under iten I.B.1, descrlhe those that l

you have detennined will fall within the scope of the MANC progran for arpecity derating, those that will not be bounded by' the MANC progran, and those for which-srpecity derating does j

j not apply.

j i

j 2.

For the barriers you have determined fall within the scope of the NANC progran, describe what addltlonel ~ testing or I

evaluation you wiii need to porfonn to derive valid arpacity dorating factors.

l l

1 j

3.

For the barrler configurations that you have determined wili not j

be bounded by the NANC test progran, describe your plan for

{

evaluating whether or not the sTpacity dorating tests rolled won for the sTpacity dorating factors used for those electrical caTponents protected by Therrro-Lag 330-1 (for protecting the i

safe-shutdcun capability fran fire or to achieve physical independence of electrical systems) are correct and applicable r

j to the plant design. Describo alI corrective actions needed and sutmlt the schedule for caTpleting such actions.

i 4.

In the event that the MANC fire barrler tests indicate the

~

i need to upgrade existing in-plant barriers or to replace i

l existing ThenTo-Lag barrlers with another fire barrier system, i

describe the alternetIve actions you wiII.take (and the schedule i

for performing'those actions) to confinn that the arpecity l

dorating factors were derived by valid tests and are applicable l

to the tradified plant design.

l Your response to Section IV.B rney depend on unkncun specifics of the MANC arpacity derating test progran (for exarple, the final barrier upgrades). H mover, your response should be as conplete as possible.

In addition, your response should be updated as j

additlonal inforrration boccmss available on the NANC progran.

j!

V.

Alternatives 1

i A.

Discussion Ch the basis of testing of Thornn-Lag fire barriers to date, it is not clear that gener ic upgrades (using additional lhento-Lag i

naterials) can be developed for trony 3-hour barrier configurations j

or for sors 1-hour barriers (for exaTple, 1-hour barriers on wide i

cable trays, with post-buttered joints and no Internal supports).

Nbreover, sore upgrades that rely on additional thicknesses of i

Thernu-Lag naterial (or other fire barrier rTaterials) rrey not be j

practical due to the effects of aTpacity derating or clearance j

problers.

l 1

B.

fiequired Infornation i

Describe the specific alternatives available to you for achieving I

l' corpliance with NC fire protection requirerents in plant areas that i

l t

y

. contain Therno-Lag fire barrlers. Exanples of possible alternatives to Therno-Lag-based upgrades include the follorving:

1.

L.hgrade existing in-plant barriers using other traterials.

2.

Ileplace Thernu-Lag barriers with other fire barrler traterials or systers.

j 3.

lieroute cables or relocate other protected emponents.

4.

Chalify 3-hour barrlors as 1-hour barrlers and instalI detection and suppression systems to satisfy NC fire protection requirements.

VI.

Schedules A.

Discussion The staff expects the licensees to resolve the Thernu-Lag fire barrler issues identifled in G. 92-08 or to propose alternative fire i

protect!on rinasures to be irrplarented to bring plants into ccTpliance with NC fire protection requirarents. SpecifIcally, as test data becores available, licensees should begin upgrades for Thernu-Lag barrler configurations bounded by the test resuits.

B.

fisquired Infornution Subnit an integrated schedule that addresses the overall corrective action schedule for the plant. At a minirnm, the schedule should address the foilarving aspects for the plant:

1.

Irrptgrantation and corpletion of corrective actions and fire barrier upgrades for fire barrier configurations within the i

scope of the FGNC progran, 2.

inplwentation and conpletlon of plant-specific analyses, tett!ng, or alternative actions for fire barriers outside the r, cope of the fGMC progran.

VIi.

Sources and Correctness of Information Describe the sources of the infonTution provirtd in response to this request for inforrration (for exarple, f ran plmt drawings, quality assurance docurentatlon, walk doans or inspections) and harv the accuracy and validity of the inforrretion ves verifled.

4

S

}g ~,

l "Z

c r e, yt a

7,,, [L d

~

5,, N w ((, ~ _

.b

".L

,,,; n p y g,

-/v e Ta

,.s >

, / A__ /

4//,

4, <

tv~-

s<.

sI;,,:L fL 2 r ?,

~

~

S u -c frek, z S-3

//

fL.

m v,h s.

A/

5 ~

W h

p 0 s ls cl., k -

a

-g 4,.

for f $,.e*

c y.s

'i p

l l

b a ~ ~ e t -y

• fp for s, s l

C Al.,

Pl ~

sp i

3i h alc, b ro. lm l ' c bs </]

o l k ff A'.,

I.

M$f Ye f

1 0

3.t Y.1, /

/

- sr w -

q,.

t 6

I 1

I I

-w->

--y.r w

+r

i o

+

i l

%f i

DATE REFERENCE DOCUMENT SYNOPSIS j

3/26/81 M EM O FOR Unresolved issues:

1. PP L i

TEDESCO(w/NRC) FROM has utilized drywall l

NOONAN(w/NRC)

FIRE assemblies for their 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> l

PROTECTION SAFETY

. fire walls for which the l

EVALUATION REPORT drywall design has not been i

verified. The concern is that i

the drywall cannot provide j

the required fire rating.

2. PPL has not provided

[

details of the design for the alternate safe shutdown i

system for the cable i

spreading. rooms and the-control room.

l 4/15/81 M EM O.

F'O R The applicant provided fire l

TEDESCO(w/NRC) - FROM test data per ASTM E-119 test procedure which BENAROYA(w/NRC)

SUPPLEMENTAL FIRE demonstrated a three hour PROTECTION. SAFETY' fire - rating. The drywall EVALUATION REPORT assemblies were deemed i

acceptable.

l l

6/19/81 LETTER F0R PPL indicated plans to have SCHWENCHER(w/NRC) fire retardant wrapping FROM PPL-TESTING OF material manufactured by ELECTRICAL RACEWAY

Quelor, Inc.

tested to MATERIAL determine whether the material satisfies NRC requirements for use as a fire i

barrier (wrap) for electrical raceways.

'/

i

c 7/9/81 M EMO F0R PPL has not provided TEDESCO(w/NRC) FROM sufficient information to JOHNSTON(w/NRC)- FIRE conclude that the alternate PROTECTION SAFETY safe shutdown system for the EVALUATION REPORT cable spreading room and the control room meet the intent of the safe shutdown requirements.

10/26/81 LETTER FOR The enclosure of the report SCHWENCER(w/NRC) states that the THERMO-FROM P P L-TEST LAG is capable of providing REPORTS FOR THE 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire resistance to a WRAPPING MATERIAL barrier as per ASTM E-119 time /temperaturetransmission prerequisites and as per IEEE 634 standard cable penetration fire stop qualification tests. Results of tests demonstrate that prerequisites to appendix R paragraph G, fire protection for safe shutdown capability are met.

2/9/82 LETTER FOR PPL stated that NRC had SCHWENCER(w/NRC) indicated acceptance of FROM PPL-THERMO-LAG at Comanche SUSQUEHANNA STEAM Peak. PPL considers one ELECTRIC STATION FIRE hour to be sufficient to satisfy PROTECTION REQUEST original intent of NRC FOR VARIANCE requirement for fi re protection.

3/19/82 MEMO FROM A

meeting took place P E R C H (w / N R C)-

between PPL and NRC. PPL

SUMMARY

OF FIRE presented information PROTECTION MEETING regarding fire protection BETWEEN PPL AND NRC issues. NRC requested that PPL provide documentation that a one hour fire barrier is provided by the THERMO-LAG.

i

~-

1 i

5/12/82 LETTER FOR Enclosed documentation that

.SCHWENCER(w/NRC) the THERMO-LAG (TSI j

F R.-O M P P L- -

wrap) provides a one hour l

SUSQUEHANA STEAM fire barrier.

l l

l ELECTRIC FIRE PROTECTION 6/9/82 LETTER FOR PPL responded to NRC SCHWENCER(w/NRC) questions resulting from the i

i F R O M-PPL-letter dated 5/12/82. Stated SUSQUEHANA FIRE that one exception to the PROTECTION procedures was taken in -

l deleting the use of the fiberglass armoring.

-l l

'7/6/82 LETTER FOR PPL indicated that a fire test l

SCHWENCER(w/NRC) of the one hour fire barrier F' R O M PPL-material (THERMO-LAG)

SUSQUEHANNA' FIRE would be conducted.

BARRIER MATERIAL 7/23/82 LETTER F0R Enclosed a copy of the test-SCHWENCER(w/NRC) specification. Indicated that FORM PPL-the objective of the test was SUSQUEHANNA FIRE to provide documented QUALIFICATIONTEST OF evidence of a one hour-i PROTECTIVE ENVELOPE effective barrier.

j SYSTEM 8/25/82 LETTER FOR PPL indicated that the. ASTM SCHWENCER(w/NRC)

E-119 test of the one hour FROM PPL-cable wrap had-been SUSQUEHANNA FIRE conducted. Enclosed the test PROTECTION report prepared by Southwest Research Institute.

i

8/31/82 LETTER FOR PPL intends to nsodify their.

SCHWENCER(NRC)FROM fire wrap installation _ by PPL-SUSQUEHANNA adding the fiberglass LICENSE CONDITION NO.

armoring in accordance with 7

TSI (TH ER M O-L AG) i Technical Note 80181. PPL indicated that they had the understanding that this l

satisfied the requirements of the license condition, and that i

this installation' was i

acceptable to the NRC.

6/5/92 MEM O FOR It was indicated that the NRC -

l MARTIN (NRC)

FROM had been informed that PPL used failed qualification tests

[

TH AD ANI(N RC)

REQUEST FOR to install THERMO-LAG. In INSPECTION OF addition, the manufacturer's THERMO-LAG F1RE-installation procedures had BARRIERS AT not been followed.

SUSQUEHANNA 6/9/92 MEMO FOR MILLER (NRC)

Information regarding the FROM MCCRACKEN(NRC) design and installation of the REQUESTING raceway barriers was A DDITI NA L requested.

INFORMATlON REGARDING THE TESTING AND INSTALLATION OF THE THERMO-LAG I

L

n

...,--J~--34e,Je.---_.

s..-.-.f.*A.a4 t,

W

<.W.

A-a a

.4.J.u 44__,,,i.

.__._,--.,m,.2,,_._.,,,mym--,ua,-

,,,m g-7 9a l

0 v a,a m e w ans a w m e ma Tan _o-LAQ ANb T4 E. UCMdQk OF UNtT 1. bChdk 14E T%\\ Asb iTL j

m ne VSAn 4

i 1

i t

I l

1 i

Mts. kME ASSAFxeMT C c1A G M TeT Tkn 1 - bJ R 9?cug-e 7mcow4 -LAR hsh

. p s T. n u - m %

vole 7&S l

l

\\d 9oT ECW%Twes %g. A AQALT9Rgiid :

~ TEST (Wtte7 ves sus we mesa *g,a MLE A

( - 2bj. Tut 9%eT 7g AT 79 9.

GLeLWiuTM T6CT THAT %

PES.%%Et i9

\\ 9 "B L s,J 03 Ud5Ah SFALTofLA\\

WMS

\\ tf D F,%

) A SS%'t 24 or4 E J T R P9EAAS TypT Ne /RToN Wrd TgppJ Te E@ w AT6

~T9 E QeAELa t i m etiq A T eo! 2 i

C)F Tr4 q Mse.,

THE STAWs twJer>gA13 BP50T GkOA LI F3 CAT ord TESm W9 MS TRE Sh WEgTS 9% %GT)rdS EIi )

ira SSSA %. 3 Ms QERE ibFATS ise Q ta%RSE CedB3Tcd 2(tY

\\T ALSe A

PE rd T9 AT THE 5 @ t V A E T x)

P A

va%dj')

MD N-%

v u S 1r3 { % E % 0,A T EQL-K W

n4, %% - M QL '89-O\\

3 1rJ TH n

~

TSR LfR\\t 0F ficCEcT4tV 104Lr Rt(Ed TtsT5 WAS N 6T G.Q TSSE g>

P:

- Q,:

" i% n

' i

~,p: '

z f

OEllbUS TSS Vv't ly'0': fi;?~t"f]lk Til1E ITSs is 15 5 h > QE S r 51 A' 50 70 K6(/cWAL-Rig.N8 G WeEv'7 Fe= fru'i PW

-a,

-.a.-

\\

3 OT Tut %39%Urs %gGLh Tat Abr&cM.N T.A t Lt%O 0- E%

Q%E D AS A

\\ - Rcr0 Rs-

% m ses asa d Tu e Ae % ste m to d sonw uw Tem *u et usmag 7o SUReo%T Tge.

SPEtsVs t.

Co6%%GLAT ed S, i

\\d E R LS O

%Aili.

A A0 ES Ts otJ Rsn4tRGLMt k Qw Tuv e 3% V A 4 q GLO Atmtpha Te s,s (3 vetewsww,wS

@btg S9e?@_T Aut Tue ir S Ta tt A T ot4 CstavAouT, eas, of CALE u94 e mATscunts l

6 Ab Tut Tg.4c%T, eN,1 3ETtRE.7J mnTcwtS l

ERev/ rdL To TMdroo-uQ l

l

i e

@ E C_cneCEArd

\\S

'A \\ Ts4 Cld At G AS sT RQ7t\\ES.

To 'TA E

% GLE 9M E tm Ord 9 7_eG S o m

~Tb s ces4tvac3 is t o tse gcees

%g 'N e vue4%

Eum9LES 1

4 l

L e

1 i

4

(

E i

i

a 4-4

-m.

U<1--*ma.a

.,- yq 44p.a

+.

J

_L:.e.4 4-4 e ap sa.A

,m b

e

.L.

,.d.

4.as 79 s

J

-n,J-1 4

4' h

h set ww sw9ctssswo wTat u

wme-w o-zu mac osscs gs en ne sem_

ss e

6

@tE.-

%cn3 P--.

SA (14L \\E-(c.

DDE i NOT Agesect. Te R O

w N n.,ae_E W TA 990 AC (LO911 V,QxAT M 9-E.QMST

\\9 AWr>

s 7..\\5.7 e V

' Tug SpysT4 Ei A0 v7T,W T e(2 9 s a. 1 e,c T u s V9 OR,-

d d M G d 1 D M T.t d T G k ' k N h,b O~O M C) i

\\@

T\\W C- \\ 9 0'D - SEMEL DMv4bdkS Af41; IE ~ 19 9, R'tiBT V ed AL' W S E D O.4v3\\4 c.c..ss m e m e w -a e u g i

wm bg4vanacS.

has ape'E ARs toeT

~To 3r-;

m

> ? u @ C.E.

u t T g sw g.__

hwsh0hT

-To AP PE 36 x A

Tc, 3

T4%

D9-4 AC.M TG'QB rd%%(.. M D Tsaf4 N) bb Exen9GS.

W e s s Y0-or B W WG F-9_

a Leew+

vu s m T w Tau xes i r s

a 9AGL4 (LAN kM.I[

4 he c.ee--e a pt%

or wstuxem sese m tat M Y2 % E-4

~

I

@ES.3. ~ 6t.1 1cWE5 0 % 300 J-4 A T4TS 1 DE A TT V4S A LA 8 0( Q Ontg6 uJ T Q 6 e fi>

1 A s h t o T W 6 b o O N ---

)

~

1 I

l

?

d W

s t

w:ntu mwa (seetag.

s 3 mk %aus%-ucs s

WE dha eGL %vme 'LAq (Qgt 4eweh smTotuwws mecct To ess @tm

\\ pS'TA tL Eb. O NL h VE U WirJ%L hE5iECTS 3

Q At.s\\, $?? Ebb TC) E 14 E WALT 09kD MD b d\\ h g

i I

l f

l l

a 2

a 1

e

?e sasmw -x ss4 wem m -

l

@\\b u STAT m TnAT T14E E M MA1.A&O

%3 M. ~\\% E Uf6 W AbEutG ATE To StAU CSmqu Aasq u rTH AP PEAbw R. T41S i

~

\\ Tse Q As Gts vsr45 t Te N LL Y %

c p s e.iAsescas@ @seceT se

'8 % Z '

\\h 3TATTNS TlifT f

CLDSs t TgiS T

Tgs sT u w w urs Ta we h

%3

~

t QX3, RW s N

%C GLT4.3 W WR 0

5% 99&TRT3d 954sTJ fLE0*T-T@ A \\we

\\p TnttGcA C BP9EAbx L l

l S

l QRgahss

\\bsh%se2 9 3 4. 3 ) S otN E i

os#isnupsvwM 9tAF%x%

ng.3 T9EE l

M He9EsA b wuumsT%

w l

)

w Tus ve4R 4ta

s. t%Axg sA 64 V% %kOJ.

O

\\s NbTQ yg I

N

\\thSMTCTM 0AS;.*%N M TORF#O l

t N % C4\\ QAR N%t\\%%

Um9Lin;S % Wma i

AQWNha R A N 'S Tsps COL)EQ T %/Ji l

9ME CTM @@ \\hJ M;T%T TOER.T. fRQ eT8s % Qw' M $N9% PA I

xp tb4 94%vs s 794T nW i

\\40RT4 sxt t%906% m Ttt TK i

(Q M0% TE.x),% 6 Tpt T9 kl 8 MNuW0

7 l~

N..

Y O

V-

?/

l2 I

F MAR 2 61981 HEMORANDUM FOR: Robert L. Tedesco, Assistant Director for Licensing Division of Licensing Vincent 5. Noonan, Qualifications Engineering FROM:

Assistant Director for Materials &

Division of Engineering C, p.'M 4

- +.

SUBJECT:

FIRE PROTECTION SAFETY EVALUATION REPORT -

p N

8 SUSQUEHANNA STEAM ELECTRIC STATION

_! "*l'EOjy0616-Plant Name: Susquehanna 5 team Electric Station Docket Musbers: 50-387/5

\\g 8 %,**%e, Licensing Stage OL N a..,,

i Milestone Nusbert N/A Responsible Branch: L8 #2 t-Project Manager R. Stark

=

Chemical Eng'neering Reviewer G. Harrison Requested Completion Dates N/A Review Status: Complete Enclosed is the fire protection section of the Safety Evaluation Report of the Susquehanna Steam Electric Station Units 1 and 2.

The Fire Protection Program was reviewed in accordance with Appendix A to Branch Technical Position A58 9.5-1. At this time. there are no deviations from Appendix R requirements. The Fire Protection Program will be implemented prior to fuel load.

There are five unresolved fire protection items:

1.

The applicant has utilized drywall assemblies for their three-hour fire walls. We are concerned that the drywall assembly cannot provide a three-hour fire rating. The applicant has not verifled the drywall 1

design. This information has not been provided yet. We will require that the applicant provide a three-hour fire barrier.

2.

The fire dampers installed in the drywall assed11es are of an approved type.. However, we are concerned that the actual installation of an appv'oved damper in a drywall asses 61y has not been previously fire tested or approved. The applicant has not for their fire damper installations.provided us with any documentation We stil require that the applicant provide us with verification that the. drywall assed ly fire dampers are rated for three hours.

3. We are concerned that a single exposure ~ fire could damage redundant cables I

and equipment in the battery room area. There is a heavy congestion of 4MA G 3 0(g74-

\\

f..i...

-~~+

.ptq t-otg.,

co ronu sia no,em nacu o 4o.-

.; OFFICIAL RECORD COPY mo ' =- >

1

.i >

j x

Robert L. Tedesco P

" "61 l

l j

cables and equipment handling 125 volt de power in the battery room j

area. We will require that the applicant meet requirements set forth i

in Section !!!.G of Appendix R to 10 CFR Part 50. We will report on l

this at a later date.

4 We are concerned that a break in the circuit from the loaal fire alarm control panul wil11 result in a fire alam signal. Also the bulbs in 1

the annunicator panel in the control room for these circuits are not i

supervised. We will require that the applicant rectify these conditions j

j by providing 41rcuit and bulb supervision per NFPA 720. We will report i

on this item in a subsequent safety evaluation report.

i 4

I 5.

The appiteent has not provided the details of the design for the alternate l.

safe shutdeun system for the cable spreading rooms and the control room.

lt We will report the results of our review at a later date.

l We have infenned the applicant that all five unresolved items need to be j

coupleted prior to fuel load.

a I

' k'.

Msind ggnedE i

Vincent S. Noonan, Assistant Director for Materials & Qualifications Engineering Division of Engineering i

j Enclosures As stated j

j

Contact:

G. Harrison X27877 cc:

R. Vollmer V. Noonan 4

l R. Tedesco i

V. Benaroya R. Ferguson S. Hudson R. Stark i

G Herrison H. Levin i

F. Rosa

a. x..a

^Em

')~

2 A/

t

-+

.%M....%Bl.ip.C$...c.s.9.:.9.E.w...

A,Q,:,M&g,E:,9,,,,,,

j y=^"9

.MATI.D.9Ri!@.M.f!SVA.m......YBe.nar,9xa,,,,,,y,No,,

l

" >..sM/t.a1........3MM.\\..........n59.1........ 3.MW.8.1........

j g u:e ronw sie no. oin cw ouo OFFICIAL RECORD COPY a

j

i i

l l' 4

t i

l i

i 4

FIRE PROTECTION l

SAFETY EVALUATION REPORT I

BY THE 0FFICE OF NUCLEAR REACTOR REGULATION 4

f IN.THE MATTER OF T_HE 3

PENNSYLVANIA POWER AND LIGHT COMPANY SUSQUEHANNA STEAM ELECTRIC STATION

}

UNIT NOS. 1 AND 2 DOCKET NOS. 50-387/388 i

MARCH 23, 1981 1

i 1

\\

}

i 5

f r

1 A

J k

4 I;

1 l

4 k

b.

]

?V -

~

SUSQUEHANNA EVALUATION REPORT

!t FIRE PROTECTION REVIEW l

TABLE OF CONTENTS PAGE I.

INTRODUCTION............................................

I 1

II. FIRE PROTECTION SYSTEMS DESCRIPTION AND EVALUATION......

1 A.

Water Supply Systems................................

1 B.

Sprinkler and Standpipe Systems.....................

2 C.

Gas Fire Suppression Systems........................

3 D.

Fire Detection Systems..............................

4 i

III. OTHER ITEMS RELATED TO FIRE PROTECTION PROGRAMS..........

4 i

i A.

Fire Barrier and Fire Barrier Penetrations..........

4 B.

Fire Doors and Dampers..............................

5 IV. EMERGENCY LIGHTING

.............................l........

5 V.

FIRE PROTECTION FOR SDECIFIC AREAS......................

6 A. Control Room........................................

6 B.

Cable Spreading Room................................

6 C.

Containment and Reactor Building....................

6 D.

Emergency Diesel Generator Rooms....................

7 E.

Battery Room Area...................................

7 F. Other Plant Areas...................................

7 VI. ALTERNATE SHUTDOWN......................................

8 VII. ADMINISTRATIVE CONTROLS AND FIRE BRIGADE................

8 VIII. TECHNICAL SPECIFICATIONS................................

8 IX. APPENDIX R STATEMENT....................................

9 X. CONCLUSION..............................................

9 1

l l

P

• 1>* * -

e t

>b

%,= (

MElllMMIMMMEIM

CHEMlCAL ENG!NEER!NG BRANCH / FIRE PROTECT 10N SECT 10!1 FIRE PROTECTION REVIEW

. I SUSOUEHANNA 1 & 2 j(

DOCKET N05. 50-387/388 j

l I.

INTRODUCTION We have reviewed the Susquehanna 1 & 2 fire protection program reevaluaticn j

and fire hazards analysis submitted by the applicant by letter dated January, 1978, including Revision 1..The Susquehanna Steam Electric Station 2

j is a two unit site. Since Units 1 & 2 are of the same c'.: sign except as j

noted, the comments made in -this report apply to both L1its.

The Susquehanna 1 and 2 reevaluation was in respcnse to )ur request to review i

their fire protection program agSinst the guidelines of Aopendix ; to Branen i

Technical Position (BTP) ASB 9.5-1, " Guidelines for Fire Potection for i

Nuclear Power Plants." As part of our review, we visited the olant site to examine the relationship of safety related components, systems and structures j

in specific plant areas to both. combustible materials and.to fire oetection and suppression systems. The overall objective of our review was to ensure 1

that in the event of a fire at Susquehanna 1 and 2, personnel and the plant equipment would be adequate to safely shutdown the reactor, to maintain the plant in a safe shutdown condition, and to minimize the release of j

radioactivity to the environment.

Our review included an evaluation of the automatic and manually operated i

water and gas fire supprcssion systems, the fire detection system, fire j

barriers, fire doors and dampers, fire protection administrative controls, l

and the fire brigade size and training.

II.

FIRE PROTECTION SYSTEMS DESCRIPTION AND EVALUATION A.

Water Supply Systems l

The water supply system is cornon to both units.

It consists of two fire pumps connected through a commm header to a 12-inch cast-iron, cement-lined i

pipe yard main loop. Both the electric motor and diesel driven fire pumps i

are rated at 2500 gpm at 125 psi head each. The fire pumps'and their 1

controllers are UL listed. Their design and installation conforms to the i

requirements of NFPA 20 " Standard for the Installation of Centrifugal Fire Purps." The pumps are located in the circulating water pump house with the diesel fire pump enclosed in a 3-hour fire rated enclosure with automatic j

sprinklers.

The pumps take suction from the two clarified water storage tanks of which 300,000 gallons are. reserved for fire protection in each tank. A second water source is provided by the six million gallon cooling tower basins.

j The pumps discharge into a common header with two separate connections to l

the underground 12-inch yard main loop.

A separate jockey pump automatically maintains yard main pressure from 105 to 125 psi. The fire pumps start automatically on low header pressure.

i c

l 2-il.

~

If the water supply system pressure f alls to 95 psi, the eittetric fire pump j

would start automatically. As the pressure falls to 85 psi, the diesel

{

engine driven pump would start. The pumps can also be started manually j

from the control room and at the pumps. The pumps can be stopped only at the pump controller panels located adjacent to the pumps.

Separate alares are provided in the control room to monitor p.mp operation, prime mover j

availability, and failure of a fire cump to start.

l The largest single fire suppression system water demand for areas that need i

to be protected is 1750 gpm. Adding 500 gpm for hose streams creates a

.otal water demand of 2250 gpm. One of the two fire pumps can deliver the required water flow.

A total of 27 yard hydrants are provided at intervals not exceeding 250 feet.

j A hose house is provided for each hydrant.

f i

All valves in the fire protection water supply system are electrically supervised except for the post indicator valves, which are in the underground l

yard main system. The post indicator valves are locked open under administra-l tive controls. The electrical supervision of valves alarms in the control room.

)

i The water supply valves meet the guidelines of Section C.3.b of Appendix A to BTP ASB 9.5-1, and are, therefore, acceptable.

i We find that the water supply system can deliver the required water demand with i

one pump out of service. We conclude that the wate* supply system is adequate, j

meets the guidelines of Section C.2 of Appendix A to BTP ASB 9.5-1 and is, i

therefore, acceptable.

B.

Scrinkler and Standpice Systems 4

The wet pipe sprinkler systems, preaction sprinkler and deluge systems are i

designed to the requirements of National Fire Protection Association (NFPA)

Standard No. 13. " Standard for Installation of Sprinkler Systems," and NFPA 15,

" Standard for Water Spray Fixed Systems." The manual hose stations are connected i

separately.to.the underground water supply loop. Appropriate sectional and diversion valves are provided.such that' primary and secondary fire protection water supply will always be available should a single break develop. The water supply valves to the sprinklers are electrically supervised with alarm and i

annunciation in the control room.

In addition, the sprinkler systems have water flow alarms which alarm in the control room. The areas that have been j

equipped with water suppression systems include the following:

RCIC Pump Room D._

HPIC Pump Room H8N Filter Rooms Railroad:Afrlock t

Control Buildir.g Auxiliary Rooms

/.

Condenser Area Reactor Feed Pump Turbine Turbine Central Area Turbine Condenser Gallery

4 i.

I i'

ii l

Turbine Hydro Control Power Room j

North Railroad Bay i

Turbine Condenser Mezzanine Diesel Engine Fire Pump Room i

Lower Cable Spreading Room i

Upper Cable Spreading Room PFP Turbine Room i

Diesel Generator Building Charcoal Filters Standby Gas Treatment Filter Emergency Outside Air Filters

-r i

f-Centrifuge & Conditioner

(

Turbine Pump Area Turbine Hydro Seal 011 Unit Turbine Lube Oil Area Turbine Motor Generator Area Turbine Filter Room Turbine Moisture Separation Area Radwaste Tank Vent Filter Room Radwaste Auxiliary Rooms Radwaste Controlled Zone Shop 4

Manual bose stations are located throughout the plant to ensure that an

]

effective hose stream can be directed to any safety related arm in the plant.

g The standpipe systems are consistent with the requirements of NFPA 14, j

" Standpipe and Hose Systems for Sizing, Spacing, and Pipe Support Requirements."

l Based on our review, we conclude that the water suppression systems meet the guidelines of Appendix A to BTP ASB 9.5-1, and are, therefore, acceptable.

j C.

Gas Fire Suppression Systems I

Low pressure carbon dioxide systems are provided for primary protection in the electrical equipment rooms as well as generator purging. The design quantity of the agent is based en a 50% concentration.

Both automatic j

total flooding and manual suppression systems are used.

t Automatic systems are activated by heat cetection with the manual system being used to protect cables in concealed spaces on the control room level.

7 The Power Generation Control Complex (PGCC) modules are provided with self.

' r.

contained Halon 1301 fire extinguishing systems. Products of combustion or A,

thermal detection activate automatic discharge of Halon to the panel and ji floor section: produces a 20% concentration for 20 minutes. The Halen fire i

Q' extinguishing systemcomplies with the specifications contained in the NEDO-10466 Report, Revision 2 dated March,1978.

i i

~

We have reviewed the design criteria and bases for the Halen and C0 fire 7

suppression systems. We conclude that these systems are in accordance with the applicable portions of NFPA Standard Nos.12 and 12A, satisfy the provisions of Appendix A to BTP ASB 9.5 1 and are, therefore, acceptabic.

D.

Fire Detection Systems The fire detection systems consist of the detectors, associated electrical power supplies, and the annunciation panels. The types of detectors used are ionization (products of combustion), thermal, photoelectric and flare.

Fire detection systems give an audible and visual alarm which annunciates in the plant control rocm. Local audible and/or visual alarms are also provided. The fire detection systems will be installed in al! areas having safety related equi This includes the control room area, pment and safety related cables.

the new and spent fuel pool storage areas, and areas of cable concentration.

The fire detection systems, with the exception noted below, are installed according to NFPA No. 720. " Standard for the Installation, Maintenance, and Use of Proorietary Protection Signalling Systems." Those fire detection systems which are used to actuate suppression systems are a class A system defined in NFPA 720.

We are concerned that an open or break in the circuit from the local fire alarm control panel, located at various areas in the plant, to the control room results in a fire alarm condition. Also, the bulbsin tne annunicator panel in the control room for the preceeding circuits are not supervised.

We will require that the applicant verify these conditions by providing circuit and bulb supervision per NFPA 720. We will report on this item in a subsequent safety evaluation report.

!!!. OTHER ITEMS RELATED TO FIRE PROTECTION PROGRAMS A.

Fire Barrier and Fire Barrier Penetrations Exterior walls and walls that separate buildings are three. hour fire rated walls. The floor / celling assemblies separating areas in buildings containing safe shutdown systems are either two or three-hour fire rated barriers.

With the exception of the drywell assemblies, for fire areas not having a three-hour fire rated assembly, we snalyzed each individually with respect to its fuel load, fire suppression and detection systems, proximity to safe shutdown equipment, and concluded that the fire rated assemblies provided were adequate for the areas affected, meets sections D.I.d and 0.1.j of Appendix A to BTP ASB 9.5 1 and therefore, is acceptable.

Certain interior wall assemblies are required to have a three. hour fire rating and are constructed of drywall. We are concerned that the drywall assemblies cannot provide the required fire rating. The applicant has not verified the drywall design. We require that the applicant either verify

?.

~.

(h.i,

w i i the fire rating of the existing drywalls er provide a three-nour fire barrier. We will report en this item in a subsequent safety evaLatien l

report.

1 By referencing specific UL designs, the applicant has provided deccenta-tion to our satisfaction to substantiate the fire rating of the fire penetration seals used in the penetration cable trays, ccnduits, anc piping. We have concluded that the fire seal ratings meet the guidelines of Appendix A to BTP ASB 9.5-1, and, therefore, are acceptable.

B.

Fire Doors and Dampers t

i We have reviewed the placement of fire doors and verified that all doorway i

openings to atdas containing safe shutdown equipment or circuits are provided with fire doors with ratings cornensurate with the fire ratings of the wall.

The fire dampers installed in the drprall assemblies are of an approved type.

However, we are concerned that the actual installation of an approved damper in a drywall assembly.has not been previously fire tested or approved. The applicant has not provided enough irformation for their fire damper installa-tiens. We will require that the applicant provide us with verification that i

the drywall assembly fire dampers are rated for three hours or upgrade the q

dampers to a three-hour design / installation. We will report on this item in j

a subsequent safety evaluation report.

The licensee has provided three-hour fire soor dampers wherever ventilation i

ducts or openinos. penetrate three-hour fire rated walls cr ceiling / floor assemblies. All ventilation ducts or openings penetrating two-hour fire i

rated walls or floor / ceiling assemblies, and all such penetrations of one-hour i

assemblies for areas containing safe shutdown equipment or circuits, are i

provided with l\\-hour fire dampers.

Based on our review. and the commitments, we conclude that the fire doors and dampers will be provided in accordance with the guidelines of Appendix A to BTP ASB 9.5-1, Section D.1.j, and are, therefore, acceptable.

1 1

l j

IV. EMERGENCY LIGHTING 1

Eight hour battery pack emergency lights are required for areas of the plant i

necessary for safe shutdown. The applicant has installed self contained 4

eight-hour battery pack emerge cy lighting in all areas of the plant which could be manned to bring the p ant to a safe cold shutdown and in access and 4

egrets routes to and from all fire areas.

We conclude that the emergency lightin!1ons of Section It! J of Appendix R meets the requirements of Appendix A 4

to BTP ASB V.51, and, also, the provi l

to 10 CFR Part 50 and is, therefore acceptable.

l t

6-'

~~

~

' - - ~ ' - - - ' '

l, 6

ii V.

FIRE PROTECTION FOR SPECIFIC AREAS A.

Control Room The control room complex is separated from the radwaste building by a three-hour rated wall and from other areas by three-hour fire rated walls, and floor / ceiling assemblies. Support areas within the control room complex, are separated from the control room by two hour fire rated walls and its hour fire rated doors.

1 l

Smoke detection has been provided for the entire control room fire area.

in the ventilation system ducts, and in the main control board, and any l

other cabinet whish contains redundant safe shutdown circuits.

Standpipe hose stations and portable extinguishers are provided for manual fire 4

suppression activities. At our request, the applicant has provided water type pcrtable fire extinguishers.

As discussed in Section VI, the applicant has installed an emergency shutdown j

panel so that alternate shutdown capability exists independent of the control

room, t

j Based on our review, we conclude that the control room fii) y itection meets j

the guidelines of Appendix A to BTP ASB 9.5-1 and is, the et3r.. acceptable.

l 8.

Caule Spreadino Room The cable spreading rooms (two for each unit) are separated fr a 'he balance of plant by three-hour fire-rated walls and floor / ceiling assembli n,

A dra a11 i

i barrier separates unit one from unit two in both the upper ant. m er cable I

spreading rooms.

Automatic fire suppression capability is provided by a pre actior sprinkler l

system with supervised piping and activated by ionization and heat detectors.

Manual fire suppression capability is provided by standpipe with hose stations i

and portable fire extinguishers. The ventilation system is available for smoke venting.

In addition, installed smoke detectors will initiate an early i

warning alarm in the control room prior to the pre-action sprinkler system i

actuation, i

We were initially concerned that a fire could affect redundant shutdown systems located in the cable spreading room. However, as discussed in Section VI the applicant has installed an alteraate shutdows. capability indeaendent of the i

cable spreading rooms. The fire protection fu the cable spreading rooms meets the guidelines of Appendix A to BTP ASB 9.5-1 and is, therefore, acceptable, i

C.

Containment and Reactor Building Containment and.Rea'ctor Bui.1 ding fire protection features include hose stations, i

l fire detectors, and fire extinguishers. The applicant has committed to j

implement the provi'41ons of III.G.2 of Appendix R to 10 CFR Part 50.

I bl "

, 7. 9;.;~.;V, j

v...

..y e, w a n.

j

~

1 J'

-7 1

1 i

The recirculation pumps contain lube oil that could lea < cut efter 3 seismic activity. We were concerned that this oil coulc ce t; nite arc j

create a fire inside the containment,tructure.

To preclude this pcssi-bility, we required and the applicant agreed to provide an engineerec cil collection system that will meet the requirements of Reg. Guide 1.29, j

paragraph C.2.

Based on our review and the applicants commitment, we find tne oil i

collection system to be adequate and, thereforE, acceptable.

l We have reviewed the applicant's fire protection for the areas inside the containment and Reactor Building and conclude that the fire protection 1

meets the guidelines of Appendix A to BTP ASB 9.5-1 and is, therefore, acceptable, i

3 l

D.

Emergency Diesel Generator Rooms l

The diesel generators are located in different fire areas separated by three-hour fire rated barriers. At our request the applicant has agreed to seal the numerous openings in the east-west walls of each diesel gen-

)

erator room to maintain the fire integrity separating the diesels.

Each

]

diesel generator room is protected by an automatic pre-action sprinkler system activated by combination smoke and flame detectors. The applicant, at our request, agreed to supervise all doors leading to the emergency ciesel j

rooms.

Based on our evaluation and tne commitments, we conclude that the fire protection for the diesel generator rooms meets the guidelines of Appendix A to BTP ASB 9.5 1 and is, therefore, acceptable.

j I

E.

Battery Room Area I

During our site visit, we noticed that in the Battery Room there were numerous l

interactions between redundant divisions. We are concerned that a single i

exposure fire could damage. redundant cables and equipment in the battery j

room area. There is a heavy congestion of cables and equipment handling 125 volt. de power. We will require that the applicant meet the requirements 1

set torth in Section III.G.2 of Appendix R to 10 CFR Part 50.

F.

Other plant Areas l

ihe appliants' Fire Hazards Analysis addressed other plant areas oct.

Specifically discussed in this report.

The applicant has committed to l

install additional detectors, portable extinguishers and automatic sprinklers, prior to fuel load. We find that the fire protection for these areas, with the comitment made by the applicant to be in accordance with the guidelines

~

of Appendix A to BTP ASB 9.5-1 and are, therefore, accep'able.

4 4

i 4

4 I

J

~

8

~

VI. ALTERNATE SHUTDOWN At our request, the soplicant perfortred a fire analysis,,,hich t rc h,ded l

consideration of the potential effects of a transient exposure f tre on equipment and cables (within 20 f 9et of each other) reovired f or safe l

Shutdown, The Itconges 13 pf neng te to the 11 v.,14r,,ee n e,

• t w,,

s N iUi W [t b.f in sne Ieacsor*,$ N W e N # Td

't N !N U I !.I/>reinei:nertae;ontrol MNkt o

pedh Suboing.

i room or cable spreading rooms would not jeopardize operation of the alternate shutdown panels nor would a fire in the panels cause functions in the control room or in the cable spreading room.

The applicant has not provided enough information for our review for the alternate safe shutdown system for the cable spreading rooms and the control i

room. Further, the alternate shutdown system may have to be installed in other ple" areas, such as the battery rooms (See Section V.E).

We will report the results of our review in a subsequent safet/ evaluation report.

Vll. ADMINISTRATIVE CONTROLS AND FIRE BRIGADE The administrative controls for fire protection consists of the fire protection organization, the fire brigade training, the controls over combustibles and ignition source, the prefire plans and procedures for fighting fires and quality assurance. The applicant has agreed to implement the fire protection program contained in the staff supplemental guidance " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance," dated August 29, 1977, including (1) fire brigade training (2) i control of combustibles, (3) control of ignition sources, (4) fire fighting procedures, and (5) quality assurance.

The applicant will implement the plant administrative controls and procedures before fuel loading.

The applicant will have a five-man fire brigade which meets our guidelines, and is, therefore, acceptable.

We conclude that, with the comitments, the five man fire brigade equipment and training will conform to the recomendations of the National Fire Protection Association, to Appendix A to BTD ASB 9.5-1, and to our supplemental staff guidelines and, therefore, are acceptable.

VIII. TECHNICAL SPECIFICATIONS The applicant has cocnitted to follow our Standard Technical Specifications.

We find this acceptable.

.g.

j

)

i IX. APPEh0!X R STATEMENT Cn May 23, 1980, the Commission issued a Memorandum and Jrcer,;.. 21, which states that:

"The combination of the guidance containe: in appercix to BTP 9.5-1 and the requirecents set forth in tnis rule define the essential elements for an acceptable fire protection program at nuclear power plants docketed for Construction Permit prior to July 1,1976, f or demcnstration of compliance with General Design Criterion 3 of Appendix A to 10 CFR Part 50."

On October 27, 1930, the Commission approved a rule concerning fire protection.

The rule and its Appendix R were developed to establish the minimum acceptable fire protection requirements necessary to resolve certain areas of concern in contest between the staff and licensees of plants operating prior to January 1, 1979. Although this fire protection rule does not apply to Suscuehanna Units 1 and 2, the applicant verbally committed to implecent the following three issues identified in Appendix R as items to be backfitted.

1.

Section Il!.G, Fire Protection of Safe Shutdown Capability 2.

Section Ill.J. Emergency Lighting 3.

Section III.0, Oil Collection System for Reactor Coolant Pu p.

m The applicant will confirm this cummitment in the near f.ture.

Based on these commitments and our evaluation, we conclude that the Susquehar.na Units 1 & 2 fire protection program will meet the intent of all the requirements of Appendix R to 10 CFR Part 50 when the committed modifications have been completed, meets the requirements of GDC 3, and, therefore, is acceptable.

X.

CONCLUSION There are five unresolved fire protection items to be reviewed. These five items involve fire ratings of barriers and dampers, alternate shutdown systems, fire alarm system and protection of redundant divisions in the battery room area. We will report our review of these five items in a subsequent safety evaluation report. The applicant has been inforced that all fire protection items need be resolved prior to fuel loading date.

I men- -umme

~

Y O

s 0

r APR 151981

-Q 4

\\

N P/g8

)

MEMORANDUM FOR: Robert L. Tedesco, Assistant Director t

/A '-

for Licensing Division of Licensino e

FROM:

t fena Ing'AsbstantDirector Qg for Materials & Qualifications Engineering Division of Engineering

SUBJECT:

SUPPLEMENTAL FIRE PROTECTION SAFETY EVALUATION REPORT -

SUSQUEHANNA STEAM ELECTRIC STATION Plant Name:

Susquehanna Steam Electric Station Docket Hunters: 50-387/39 Licensing Stage OL Hilestone Number N/A Responsible Branch: LBf2 Project Manager:

R. Stark Chemical Engineering Branch Reviewer:

G. Harrison Requested Completion Date April 15, 1981 Review Status: Complete Enclosed is a supplemental fire protection safety evaluation report on the Susquehanna Steam Electric Station Units 1 and 2.

Our SER identified five open items to be resolved. The enclosed SSER resolves four of these; however, one item, the review of their alternate shutdown system, remains open.

Enclosed is our evaluation of the following fire protection items:

1 Drywall assemblics 2.

Fire dampers 3.

Battery room area 4

Fire alarm system Based on our review, we find that the applicants' proposed modifications regarding the above listed items are acceptable with regard to fire protection.

a anned h7,

[

'l ~

dc o-Victor Benaroy'a, Acting Assistant Director for Materials & Qualifications Engineering Division of Engineering

Enclosure:

As stated

Contact:

G. Harrison 344234

~

X27877 i

}

Im i kap nm

""I I

E Ob.

i.AD M l

9

J i

lk tit G

Q.

T k. '

1 s

j APR 151981 i

Robert L. Tedesco y i,

j cc:

R. Vollmer V. Benarcya R. Ferguson S. Hudson R. Stark H. Levin F. Rosa

{

J. Knox l

D. Eisenhut P. Check B. J. Youngblood AE00 i;

i 1

1 i

l.

d i

\\

i l

l l

t i

j.

r--

i

......)

i

. l..

j 3

i

..e u o.-. - ~,.. ' -

UFFICIAL RECORD COPY i

1 1

i

.L G.

c.

=<

i l'

ENCLOSURE 1 1

CHEMICAL' ENGINEERING BRANCH / FIRE PROTECTION SECTION FIRE PROTECTION SUPPLEMENTAL SAFETY EVALUATION REPORT SUSQUEHANNA STEAM ELECTRIC STATION DOCKET NOS. 50-387/368 Drywall Fire Rated Assemblies In the SER, we were concerned that the drywall assembly could not provide a three-hour fire rating. The applicant could not, at that time, verify their design. By letter dateo March 26, and at a meeting held on March 25, the applicant described the drywall fire barriers in detail and, also, provided the (ire test data obtairied per the ASTM E-119 test procedure which demonstrated that the assembly warranted a three-hour fire rat.ing.

Based on the test results and our evaluation, we conclude that the applicants' drywall fire barrier design meets the requirements of a three-hour firewall, meets the guidelines of Appendix A to BTP 9.5-1, and is, therefore, acceptable.

Fire Dampers In the SER, we were concerned that the actual installation'of an approved fire damper in a drywall assembly has not been previously fire tested or approved. By letter dated March 26, and during a meeting held on March 25, the applicant comitted to analyze duct f ailure potential and provide, where required duct support fire proofing and/or additional supports sufficient to prevent the duct dampers from being pulled out of the wall.

'1stalla-Based on the appliants' comitments, we conclude that the fire

.o

ore, tion will meet the guidelines of Appendix A to BTP 9.5-1 and is, acceptable.

Fire Alarm Control Fanel in the SER, we were concerned that a break in the circuit from the local fire alarm control panel will result in a fire alarm signal. Also, the bulbs in the annunciator panel in the control room for these circuits are not supervised.

By letter dated March 26, 1981, the applicant committed to have the fire detec-tion panel (C650) modified to satisfy the criteria of a NFPA Class B. wiring permitting the detection of a wiring fault condition without resulting an alarm condition. Also, indicator bulbs on the panel will be supervised.

Based on applicants' proposed modifications, we conclude that the fire alarm control panel meets the NFPA Class B criteria, meets the guidelines of Appendix A to BTP 9.5-1 and is, therefore, acceptable.

Battery Room Area in our SER, we were concerned that a single exposure fire could damage redundant cables and equipment in the battery room area. There is heavy congestion of cables and equipment in this area. By letter dated March 26, 1981, the appli-cant comitted to install a two-h.our fire rated ceiling barrier and a two-hour w

=wrw

--mm

+e

-m

t

,e s.

4

?-

t.

}

fire rated enclosure for major equipment. The two-hour rated barrier 1,5*

j adequate based on our onsite review of the area in terms of its fire loading and fire protection features, j

Based on applicants' proposed modifications, we conclude that this area conforms to Appendix A to BTP 9.5-1 and is, therefore, acceptable.

l i

4 4

i i

l l

}

1 l

l l

+

I l

h i

l 4

i t

I i------i-

W '. s w g v i ry l

)

SuWtp T1

[g 55M Aj i

VNT

/

9 AUXILIARY SYSTEMS f

9.5.1.4 Fire Alarm Control Panel In the Safety Evaluation Report, we were concerned that a break in the circuit from the local fire alarm control panel would result in a fire alarm signal.

Also, the bulbs in the annunciator panel in the control room for these circuits are not supervised.

By letter dated March 26, 1981, the applicants committed to have the fire detection panel ( C650) modified to satisfy the criteria of a i

NFPQ Class B wiring permitting.the detection of a wiring fault condition without resulting an alarm condition.

Also, indicator bulbs on the panel will be supervised.

Based on applicants' proposed modifications, we conclude that the fire alarm control panel meets the NFPA Class B criteria, meets the guidelines of Appendix A to BTP 9.5-1 and is, therefore, acceptable.

9.5.2.1 Drywall Fire Rated Assemblies In th'e Safety Evaluation Report, we were concerned that the drywall assembly could not provide a three-hour fire rating.

The applicants could not, at that time, verify their design.

By letter dated March 26, and at a meeting held on March 25, the applicants described the drywall fire barriers in detail and, also, b

provided the fire test data obtained per the ASTM E-119 test procedure which demonstrated that the assembly warranted a three-hour fire rating.

Based on the test results and our evaluation, we conclude that the applicants' drywall fire barrier design meets the requirements of a three-hour firewall, meets the guidelines of Appendix A to BTP 9.5-1, and is, therefore, acceptable.

9.5.2.2 Fire Dampers In the Safety Evaluation Report, we were concerned that the actual installation of an approved fire damper in a drywall assembly has not been previously fire tested or approved.

By letter dated March 26, and during a meeting held on March 25, the applicants committed to analyze duct failure potential and provide, where required duct support fire proofing and/or additional supports sufficient to prevent the duct dampers from being pulled out of the wall.

j Based on the applicants' commitments, we conclude that the fire damper installation W 11 meet the guidelines of Appendix A to BTP 9.5-1 and is, therefore, acceptable.

9.5.4.5 Battery Room Area In our Safety Evaluation Report, we were concerned that a single exposure fire i

could damage redundant cables and equipment in the battery room area. There is heavy congestion of cables and equipment in this area.

By letter dated March 26, 1981, the applicants committed to install a two-hour fire rated ceiling barrier and a two-hour fire rated enclosure for major equipment.

The N

v[a h'

( V/I 9-1 f,

7

.m

.~.. ~_....-

l

~ s.'

A/

1 ij$

i r

10 STEAM AND POWER CONVERSION SYSTEM i

10.3.3 Steam and Feedwater System Materials l

Genera 1' Design Criterion I requires, in part, that systems important to safety shall be designed to quality standards commensurate with the importance to safety of the. functions to be performed.

The materials utilized in the Steam and Feedwater System are reviewed for compliance with General Design Criterion 1.

The mechanical properties of materials selected for Class'1, 2, and 3 components of the steam and feedwater systems provided in Final Safety Analysis Report, Section 10.3.6.2 satisfy Appendix I of Section III of the ASME. Boiler and l

Pressure Vessel Code, and Parts A, B, or C of Section II of the Code.

]

l Based upon our review of the available fracture. toughness data and material fabrication histories, and the use of correlations between metallurgical characteristics and material fracture toughness, we conclude that the ferritic steel components in Susquehanna 1 main steam and feedwater systems meet the.

j fracture toughness requirements of the Code.

The fracture toughness tests and mechanical properties required by the Code.

provide reasonable assurance that ferritic materials will have adequate safety margins against the possibility of nonductile behavior or rapidly propagating fracture.

Sii.ce austenitic stainless steels are not used in the main steam and feedwater systems, the numerous requirements specified for these materials do not apply to the Susquehanna station.

The onsite cleaning and cleanliness controls used during fabrication are in conformance with the positions given in Regulatory Guide 1.37, " Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants," and the requirements of ANSI Standard N 45.2.1-1973,." Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants."

Since low alloy steels are not used in the main steam and feedwater system pressure containing components, Regulatory Guide 1.50, " Control of Preheat Temperature for Welding "or c-Alloy Steel" does not apply to these systems, as Low they are made of carbon arbon manganese steels.

Conformance'with the codes, standards, and Regulatory Guides mentioned constitutes an acceptable basis for assuring the integrity of steam and feedwater systems and for meeting in part the requirements of General Design Criterion 1.

10-1

k'

![.-

MEMORANDUM FOR: Technical Staff l

FROM:

William T. Russell, Regional Administrator

SUBJECT:

TEMPORARY WAIVERS OF COMPLIANCE WITH TECHNICAL SPECIFICATION LIMITING OONDITI)NS FOR OPERATION OR OTHER LICENSE CONDITIONS I

Enclosed is a revision to Regioral Instruction No. 1310.1 concerning relief j

from technical specification ibniting conditions for operations (LCO) or other license conditions that woulo ti2necessarily require reactor shutdown or delay reactor startup absent some regulatory relief. Depending on the circumstances, such relief is granted by either the Region or NRR.

The purpose of this revision is to incorporate revised guidance received from the Director, NRR, in a memorandum dated February 22, 1990. That memorandum supersedes the guidance previously set forth in Enforcement Guidance Memorandum (EGM)85-05B, dated February 27, 1985.

You should familiarize yourself with the enclosed regional instruction and its enclosures (particularly the February 22, 1990 memorandum from NRR), and any j

questions concerning this matter should be directed to your supervisor. The i

l following items highlight the significant changes:

t 1.

Relief granted by the Region is now entitled " Regional waiver of l

compliance" rather than " enforcement discretion".

2.

The Director, DRP, now has been delegated the authority by the Regional Administrator to approve a regional waiver of compliance.

3.

A licensee's written request for a waiver of compliance must address seven specific items, and those items are set forth in the enclosed procedure and in the February 22, 1990 memorandum. Further, the licensee must confirm that the waiver has been reviewed and approved by the Plant Operations Review Committee (PORC), or its equivalent.

4.

Although NRR concurrence is still required prior to the region approving a regional waiver of compliance, the separate " justification memo " to NRR is no longer warranted. Rather, the region's letter to the licensee granting the temporary waiver shall summarize the basis for the approval, and copies of that letter shall be sent to NRR as well as other parties, as described in the enclosed instruction.

l l

l f

C) l l

/

(

.....s a

x.<.a.-,.__

n...

a..

e.

O a

A-Technical staff 2

5.

Examples are provided concerning when regional or NRR waivers are appropriate.

?

William T. Russell Regional Administrator j

Enclosure As stated i

i i

e e

?

I i

a I

f 1

t l

l l

1 l

l l

l I

I I

= _ _ _ _

4 4

(

Technical Staff 3

cc w/encis T. Martin K. Smith D. Holody K. Christopher M. Miller J. McGrath M. Perkins DRP EGM Files DRS EGM Files DRSS EGM Files Resident EGM Files-bec w/encit T. Murley, NRR J. Lieberman, OE 9

4

i

' Technical Staff 3

cc w/encle T. Martin K. Smith D. Holody K. Christopher

'M.

Miller J. McGrath M. Perkins DRP EGM Files DRS EGM Files DRSS EGM Files Resident EGM Files bec w/ encl:

T. Murley, NRR J. Lieberman, OE RI: OE RI:DRMA RI:DRP RI DRA RI:RA Holody/kl/ms Harrison Kane

' Martin Russell 3/

/90 3/

/90 3/

/90 3/ '

/90 3/ /90 l

l

~~

~..

. i j

RI 1310.1/2 Page 1 of 5 REGION I INSTRUCTION 1310.1, Revision 2 TEMPORARY WAIVERS OF COMPLIANCE A.

Purpose To set forth the regional procedure for implementing the general guidance provided to the staff in a maanrandum dated February 22, 1990 from the Director, NRR, to the Regional Administrators. That memorandum describes the procedures to be followed by the staff when a facility appropriately seeks to operate its reactor, eeen though there is an applicable technical specification limiting condition of operation (Tech Spec LCO) or other license condition that requires shutdown, or precludes startup.-

B.

Backaround j

One of two procedures should be followed when a licensee seeks a temporary waiver of compliance with a Tech Spec LCO (or other license condition) so as not to unnecessarily require shutdown or delay startup.

These waivers may be used when the licensee has not abused the emergency I

provisions of 10 CFR 50.91 by failing to apply for an amendment in a timely manner, and the NRC is clearly satisfied that such action.is consistent with protecting the public health and safety.

Where the relief being sought is short term-(not to exceed 7 days except I

in unusual circumstances) and nonrecurring such that a permanent. license amendment would not be appropriate, a regional temporary waiver of-compliance may be used to grant relief from a Tech Spec LCO for some specified period provided good cause has been shown. -A regional waiver of compliance may be granted by the Regional Administrator or the Director, Division of Reactor Projects (this authority may not be'further delegated), and may only be exercised if it is clear that operating in excess of the Tech Spec LCO action statement.for the period of time that relief will be granted will not place the plant in an unsafe condition.

The intent of a regional waiver of compliance is to promote safety by not-imposing unnecessary transients on an operating plant or not unnecessarily delaying reactor startup. However, a regional temporary waiver of compliance should not be exercised repeatedly for the same. set of circumstances. Whenever a regional waiver of compliance is granted, the licensee will adhere to the existing requirement upon expiration of the waiver.

CONTACT:

Director, Division of Reactor Projects Revision Responsibility:

Division of Reactor Projects 4

m.m.-

t

.--,a-,,.-,

a e,-

-a----

.r-

4 i

}

TEMPORARY WAIVERS OF COMPLIANCE RI 1310.1/2 Page 2 of 5 i

i 2

Examples of when a regional temporary waiver of compliance is appropriate j

includes relief of a short duration from the limits of a function specified j

l in an Tech Spec LCo.

extension of an action statement time limit.

e 1

I extension of a surveillance interval or a one-time change in a j

surveillance requirement if the extension is for a short duration.

1 j

Where relief from a Tech Spec Loo is needed until an emergency of exigency amendment can be procured, an NRR temporary waiver of complianca j

is required.. An NRR temporary waiver of compliance may be granted by the appropriate Associate: Director for Projects, NRR with the concurrence of-

~

the Region I Director, DRP, subject to the' procedures set forth in the.

j February 22, 1990 memorandum from the Director, NRR..

Examples of when an NRR temporary waiver of compliance is appropriate includes a change in an element specified in.a limiting condition for operation until such time as the element can be revised by an l

emergency or exigency license amendment.

I extension of an action statement time limit for which an emergency

{

or exigency license amendment will be processed to make the.

extension a permanent change to the Tech spec Loo.

1 an extension of a surveillance interval or change.to a surveillance requirement that will be incorporated as a subsequent change to the 3

Tech Spec Loo by an emergency or exigency licence amendment.

i a case in which a licensee has submitted a timely proposed Technical a

Specification change that would alleviate a. Tech spec Loo situation, j

but the change has not yet been approved by the NRC and it will now be processed as an emergency or exigency license amendment with suitable additional justification by the licensee.

i J

C.

Procedure Imolementation

?,

1.

Recional Temoortry Waiver of Comoliance i

Any regional employee who identifies or is. informed of a facility that seeks a regional temporary waiver of compliance from a Tech Spec Loo action statement, should immediately inform his or her-supervisor, who in turn, through their management, should contact the Director, DRP.

The Director, DRP, should then contact the t

licensee to ensure that its request, if oral, is confirmed in writing, to document the rationale for its request.- The Director, DRP and other cognizant Division Directors, if appropriate, should-I

)

I i

4 i

q.

.- -.. - = - _ -... _.

l TEMPORARY WAIVERS OF COMPLIANCE RI 1310.1/2 Page 3 of 5 immediately brief the Regional Administrator concerning the licensee's request, and the licensee's justification for such relief from the Tech spec LcO.

The licensee's written request for a regional: waiver of compliance should normally be sent by electronic mail to the Regional Administrator. The licensee's written request should' include:

1.

a discussion of the requirements for which a waiver is requested, i

2.

a discussion of circumstances surrounding the' situation including the need for prompt action, and a description of why the situation could not have been avoided, 3.

a discussion of compensatory actions (if any),

4.

a preliminary evaluation of the safety significance and potential consequences of the proposed request, 5.

a discussion which justifies the duration of the request,

6. -

the basis for the licensee's conclusion that.the request.does not involve a significant hazards consideration, 7.

the basis for the licensee's conclueidn that the request does not involve irreversible environmental consequences, and 8.

confirmation that the action has been reviewed and approved by the Plant Operations Review Committee (PORC), or its equivalent.

If the Regional Administrator or his designee agrees to exercise a regional waiver of compliance, the Director, DRP shall first consult with, and receive the concurrence of, the appropriate Assistant Director ~for Projects, NRR.

Further, the Regional Administrator (or his designee) will so inform the licensee by letter (normally within one working day of receipt of the licensee's written request)..The NRC letter, which shall be prepared by DRP, shall document the circumstances of the regional waiver, including a description of the compensatory measures and an evaluation of the licensee's request, and the time period for which the waiver is in effect. copies of the letter shall be placed in the PDR'and sent to the Director, NRR; the appropriate Director, NRR Projects Division; the Director, Office of Enforcement; and the Technical Assistant, Division of-Reactor Projects - I/II, NRR.

If circumstances do not permit the use of electronic mail, the licensee may make the request orally and read or describe the above I

information to the NRC.

The licensee's oral request shall be followed promptly (usually within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) by the written documentation describing its rationale for the request.

If the w

g-c,-

.rcre w ~~, saw,

n.a s we-r

. - ~

i TEMPOAARY WAIVERS OF COMPLIANCE RI 1310.1/2 3'

Page 4 of.5 i

3 l

licanese's request is oral (to be followed with a written request),

i the Region may orally grant the request (with NRR concurrence),

followed by written documentation, provided the NRC has sufficient information to reach the same conclusions as if it received a I

written submittal. The licensee's followup written request must-

.{

f confirm the information which the NRC relied upon in arriving at its l

conclusion in granting the regional waiver of compliance.

j If the Region decides to terminate a regional waiver of compliance for any reason, the licensee must take steps to achieve the required plant status and implement the existing Tech spec Loo required actions immediately upon oral notification of the termination by the Director, DRP.

For example, assuming a 7-day action statement of 1

which 3 days have passed, the licensee does not have 7 days to j

initiate the required steps, since time will already have elapsed I

during the waiver period.

In that case, the Tech spec Loo required

)

{

action is to be taken within 4 days. Alternatively, the licensee i

i should promptly initiate an orderly shutdown or other required Tech Spec LOO actions if the action statement has lapsed during the i

discretionary period. However, assuming such action is taken, the NRC should not normally take enforcement action if the action j

i statement lapsed during the period and the waiver was subsequently l

j terminated..

l 1

l NRR Waiver of Comoliance 2.

S i

Any regional employee who identifies or is informed of a facility i

that seeks a temporary waiver of compliance with a Tech spec LOO l

{

(for a sufficient period of time to allow the NRR staff to process a emergency or exigency amendment) should immediately inform his or l

j her management, who in turn shall inform the Director, DRP.

It is l

l the responsibility of the Director, DRP, to notify the appropriate

}

3 staff within NRR of the need for a NRR temporary waiver of l

j compliance. The responsible Project Director in NRR, with the s

concurrence of the Region I Director, DRP,Lwill' process the' request t

in accordance with the guidance in the February 22, 1990 memorandum l

l-from the Director, NRR, and may grant the request provided the t

conditicas set forth in that memorandum have been met.

t

{

D.

Effective 2R13 4

i j

This regional instruction is effective upon receipt and will remain in effect until superseded.

l l

I APPROVED: William T. Russell

[

j Regional Administrator 1

DATED:

4 2

i i

I t

1 I

f v

4 5

4 TEMPORARY WAIVERS OF COMPLIANCE RI 1310.1/2 Page 5 of 5 t

Enclosures:

1.

Memorandum, dated February 22, 1990 from the Director, NRR 2.

. Example of a Letter to a Licensee authorizing a regional waiver of compliance with Tech Spec LCO Distribution:

Office of Regional Administrator Division Directors Chief, Administrative Management Branch (original)

Resident Offices Enforcement Officer i

Regional Counsel 6

l

)

I l

i I

I l

I i

i f

4 l-TEMPORARY WAIVERS OF COMPLIANCE RI 1310.1/2 Page 5 of 5 l

1 l

I e

i

Enclosures:

i l

1.

Memorandum, dated February 22, 1990 from the Director, NRR l

2.

Example of a Letter to a Licensee authorizing a regional waiver of i

compliance with Tech spec LCO l

Distributions Office of Regional Administrator l

Division Directors i

j Chief, Administrative Management Branch (original) j Resident Offices Enforcement Officer j

Regional Counsel l

I i

I i

l 5

i e

l l

RI: OE RI DRMA RI:DRP RI DRA RI RA i

Holody/kl/ms Harrison Kane Martin Russell 3/

/90 3/

/90 3/

/90 3/

/90 3/ /90 l

b i

l l

I 4

TEMPORARY WAIVERS oF COMPLIANCE RI 1310.1/2 Prg) 6 cf 5 UNITED STATES NUCLEAR REGULATORY COMMISSION cc:

T. Martin WASHINGTON, D.

C.

20555 K. Smith D.

Holody FEB 2 2 1990 W. Kane TTH - 2/28/90 MEMORANDUM FOR:

William T. Russell, Regional Administrator, Region I Stewart D.

Ebneter, Regional Administrator, Region II A. Bert Davis, Regional Administrator, Region III Robert D. Martin, Regional Administrator, Region IV John B. Martin, Regional Administrator, Region V FROM:

Thomas E. Murley, Director Office of Nuclear Reactor Regulation

SUBJECT:

TEMPORARY WAIVERS OF COMPLIANCE This memorandum supersedes EGM 85-05B " Relief from Technical Specification LCOs" issued jointly by NRR and IE dated February 27, 1987.

The purpose of this revision is to reaffirm that there are two paths for waiving compliance with technical specification limiting conditions for operation (TS LCOS) or other license conditions that would otherwise unnecessarily require shutdown or delay startup absent some relief.

In case one, the Regions have the lead for waiving compliance for certain changes of short duration.

In case two, NRR has the lead.

In both cases, a violation of requirements may occur but the NRC is exer lcising discretion to temporarily waive compliance.

Backaround A licensee may depart from its technical specifications (TSs),

pursuant to the provisions of 10 CFR 50.54(x), without prior NRC approval, in an emergency when it must act immediately to protect the public health and safety.

However, situations occur occasionally for which waiving compliance from regulatory requirements may be appropriate, and which are not addressed by the provisions of 10 CFR 50.54 (x). In these situations strict compliance with the plant's TSs without some immediate waiver of compliance from the NRC would cause a licensee to initiate an unnecessary plant action.

Examples include cases where a required plant shutdown could subject the plant to problems / challenges that operating at steady state conditions would not.

Provided that the licensee has not abused the emergency provisions of 10 CFR 50.91 by failing to apply for an amendment in a timely manner, it is appropriate that the NRC have a procedure for expeditious action under these limited circumstances.

It is emphasized that any decision of this nature will not be exercised unless the NRC is clearly satisfied that such action is consistent with protecting the public health and safety.

Careful regulatory scrutiny must be given to any CQRgQfg

TEMPORARY WAIVERS OF COMPLIANCE RI.1310.1/2-Pege 7 of 5 I

e CONTACT:

Marylee Slosson, NRR j

49-21401 l

{

l i

l 5

I i

' i B

'r' t

t l

1 P

t P

l 3

I L

I

. i I

-r i

k

+

l

?

6 i

i i

e f

I'

.{

p.

i t

h F-l

.-..- F

t TEMPORARY WAIVERS oF COMPLIANCE RI 1310.1/2 Pags 8 of 5 Regional Administrators FEB 2 2 1990 request.for waiver of compliance for circumstances involving negligence (e.g., missing a required surveillance) or poor planning (e.g., a necessary repair part not available) or misinterpretation of a technical specification, or some similar avoidable situation.. Such instances may be indicative of a more pervasive problem with the plant or its management and should be identified and conveyed to the licensee via existing procedures such as SALP.

However, given that plant safety has not been unduly compromised, denying.a temporary waiver of compliance and thereby subjecting the plant to an unnecessary transient or delaying plant startup may not be in the best interest of public health and safety.

Reaional Waiver of Comoliance A Regional waiver of compliance is a vehicle for a Regional office to grant relief from TS LCOs in certain limited circumstances when the relief is temporary (not to exceed 7 days except in unusual circumstances) and nonrecurring such that a permanent license amendment would not be appropriate.

The intent of such a waiver is to promote safety by.not imposing unnecessary actions on an operating plant and to permit a reactor startup which would otherwise be precluded by TS under those circumstances where the proposed course of action involves minimal or no safety reduction.

Some examples of circumstances for.which a Region may waive compliance include (1) relief of a short duration from the limits of a function specified in i

an LCO, (2) extension of an action statement time limit, or (3) extension of a surveillance interval or a one-time change.in a surveillance requirement if the extension'is for a short duration.

In each of these situations, the licensee will adhere to the existing TS upon expiration of the waiver.

j The authority to exercise Regional waivers of compliance is gran'ted.

to the Regional Administrator, who may delegate the authority to the Regional Division Director for Reactor Projects, based on a written request (or in some cases an oral request followed by a written request) from a licensee.

Before waiving compliance, the Region shall consult with and receive the concurrence from the appropriate Assistant Director for Projects, NRR.

Whenever a Regional waiver of compliance is exercised, the circumstances (including a description of compensatory measure (s) and an evaluation of the request by the staff) must be documented in a letter to the licensee from the Regional Administrator or his/ her designated official.

The letter shall specify the period of time for which the waiver of compliance is in effect and shall normally be issued within I working day of the receipt of the licensee's written request.

Copies of the letter should be placed in the public document rooms (PDRS) and sent to the Director, NRR; the appropriate Director,'NRR Projects Division; and the Director, Office of Enforcement.

A copy should also be sent to i

the Technical Assistant, Division of Reactor Projects - I/lI, NRR, who will maintain a file of all temporary waivers of compliance.

In limited instances, a waiver may be requested and granted orally, followed by written documentation of the waiver.

This is discussed j

further under Licensee's Recuest.

(

r l

TEMPORARY WAIVERS OF COMPLIANCE RI 1310.1/2 P g3 9 of 5 l

t 1

i I

I I

l t

i i

~

b i

1 TEMPORARY WAIVERS oF COMPLIANCE RI 1310.1/2

}

Pcg3 10 of 5 1

i j!

I Regional Administrators FEB 2 2 1990 l

]

Regional waivers of compliance should not be exercised repeatedly for the same sets of circumstances for the same licensee.

Additionally I

if a waiver is requested for a time period exceeding 7 days (except j

i in unusual circumstances), an emergency or exigency technical

{

specification change should be processed and the waiver should be

[

handled as discussed below.

l

)

NRR Waiver of Compliance f'

i An NRR waiver of compliance is a vehicle for NRR to grant relief j

until an emergency or' exigency amendment can be processed. - An NRR' l

)

waiver of compliance may be appropriate when license conditions i

j including TS LCO's would require immediate but inappropriate action:

j under the circumstances by the licensee.or would preclude or j

interrupt plant startup.

Some' examples of circumstances for which i

NRR may exercise a waiver of compliance include (1) a change in an l

element specified in a limiting condition for operation until such I

time as the element can be revised by an emergency or exigency l

l license amendment, (2) extension of an action statement time limit l

)

for which an emergency or exigency license' amendment will be I

i processed to make the extension a permanent change to.the TS, (3) an extension of a surveillance interval or change to a surveillance i

i requirement that will be incorporated as a subsequent change to the l

1 TS by an emergency or exigency license amendment, and (4) a case in i

I which a licensee has submitted a timely proposed TS change that would

-i alleviate an LCO situation, but the change 1has not yet been approved j

by NRC and it will now be processed as an emergency or exigency i

license amendment with suitable additional justification by the licensee.

i j_

The authority to exercise an NRR waiver of compliance is granted to the appropriate Assistant Director for Projects in NRR, based upon a written request (or in some cases, an oral request followed by a written request) from a licensee.

Before granting an NRR waiver of j

compliance, the Assistant Director for Projects,-NRR shall consult i

with and receive concurrence from the responsible Regional Division 1

Director for Reactor Projects.

Whenever this waiver is exercised, 1

l the circumstances (including a description of compensatory j

measure (s), and an evaluation of the request by the NRC) must be documented in a letter to the licensee from the appropriate Assistant Director for Projects, NRR.

The letter is to specify the period of time for which the waiver of compliance is in effect.

The letter j

should normally be sent within I working day of receipt of the licensee's written request.

Copies of the letter should be placed in j

the public document rooms (PDRS) and sent to the appropriate Regional j

Administrator; the Director, NRR; and the Director, Office of j

Enforcement.

A copy should also be sent to the Technical Assistant, i

Division of Reactor Projects - I/II, NRR, who will maintain a file of i

all temporary waivers of compliance.

In limited instances, a waiver j

of compliance may be requested and granted orally followed by written i

documentation of the waiver.

This is discussed further under i

Licensee Request.

Following issuance of the waiver of compliance,

{

the NRC staff should proceed to expeditiously process the emergency v-..,.,,

l F

TEMPORARY WAIVERS OF COMPLIANCE RI 1310.1/2 P g3 11 of 5 or exigency TS amendment in accordance with existing NRR procedures.

l l

I i

1 i

i l

l i

I i

s i

l l

i

't f;

f i

I i

l h

f

?

P f

I i

l I

t l

l

?

?'

i e

6 g

F l

l

?

i t

l l

t l

i

TEMPORARY WAIVERS oF COMPLIANCE RI 1310.1/2 P:ga 12 of 5 1

Regional Administrators FEB 2 2 1990 s

1 j

Licensee's Recuest Whether a waiver of compliance is to be considered by the Region or by NRR, the licensee shall prepare a written request including: (1) a J

discussion of the requirements for which a waiver is requested, (2) a i

discussion of circumstances surrounding the situation including the need for prompt action, and a description of why the situation could

~

not have been avoided, (3) a discussion of compensatory actions (if any), (4) a preliminary evaluation of the safety significance and i

potential consequences of the proposed request, (5) a discussion which justifies the duration of the request, (6) the basis for the 1

d licensee's conclusion that the request does not involve a significant hazards consideration, and (7) the basis for the licensee's conclusion that the request does not involve irreversible environmental consequences.

The licensee's request should normally be sent by electronic mail to the Assistant Director for Projects, i

NRR or the Regional Administrator.

However, if circumstances do not l

permit time for electronic mail, the licensee may make the request j

orally and read or describe the above information to the NRC.

The licensee's oral request shall be followed promptly (usually within 24 4

hours) by written documentation describing its rationale for the request.

If the request is oral (to be followed with a written request), the NRC must have sufficient information to reach the same conclusions as if it received a written submittal.

The followup written request must confirm the information which NRC relied upon in 1

arriving at its conclusion in granting the relief.

The NRC must not i

act on the written or oral request until the licensee has confirmed that the action has been reviewed and approved by the Plant j

Operations Review Committee (PORC), or its equivalent.

Termination of Waiver i

j If NRC decides to terminate a waiver of compliance for any reason, the licensee must take steps to achieve the required plant status and i

implement the existing TS-required actions immediately upon oral notification of the termination by the appropriate Project Director, i

NRR or appropriate Regional Division Director.

For example, assuming a 7-day action statement of which 3 days have passed, the licensee does not have 7 days to initiate the required steps since time will already have elapsed during the waiver period.

In that case, the TS-required action is to be taken within 4 days.

Alternatively, the licensee should promptly initiate an orderly shutdown or other required TS actions if the action statement has lapsed during the discretionary period.

However, assuming such action is taken, the NRC should not normally take enforcement action if the action statement lapsed during the period and the waiver was subsequently terminated.

Summary The Regions may temporarily waive compliance to permit a licensee to not be in literal compliance with TS's in certain circumstances in which a license amendment is not appropriate because of the e

\\

TEMPORARY WAIVERS OF COMPLIANCE RI 1310.1/2 Pcgs 13 of 5 i

nonrecurring, short duration nature of the event.

NRR may temporarily waive compliance when a license amendment is appropriate

- but an emergency or exigency amendment cannot be processed before the time limit

[

for the action statement expires.

I i

f 4

t R

i i

I p

t p

f 4

i se 9

y

t TEMPORARY WAIVERS OF COMPLIANCE RI.1310.1/2 Pega 14 of.5 Regional Administrators FEB 2 2 1990 l

If a TS will be exceeded before a decision can be made to exercise a waiver of compliance, or if it is decided not to exercise a waiver of compliance, the licensee must take the action required by the TS (except as provided in 10 CFR 50.54(x)). A waiver of compliance is a discretionary action available to the NRC staff that need not be exercised unless the staff is clearly satisfied-that the i

exercise of such action is consistent with the public health and safety.

Notwithstanding the decision to waive compliance, enforcement action is to be.

considered in accordance with the enforcement policy for violations that led up to the situation that merited the waiver of compliance.

Thomas E. Murley Office of Nuclear Reactor Regulation i

cc: See next page l

l l

i I

I l

TEMPORARY WAIVERS OF COMPLIANCE RI 131o.1/2 Pega 15 of 5 Regional Administrators FEB 2 2 1990 cc:

J. Sniezek S. Weiss J. Partlow C.

Berlinger F. Miraglia J.

Calvo F. Gillespie C.

Cheng S. Varga L. Marsh i

D. Crutchfield G.

Bagchi G. Holahan S.

Newberry J. Richardson F.

Rosa A. Thadani C.

McCracken E. Rossi R. Jones i

F. Congel B.

Brach J. Roe P. McKee S. Liaw W.

Lanning B. Grimes R.

Erickson J. Lieberman R.

Barrett L. Chandler L. Cunningham i

B. Boger A.

Gody G. Lainas W.

Regan i

J. Zwolinski K. Perkins l

W. Travers C. Thomas l

W. Kane L. Reyes l

E. Greenman S. Collins R. Zimmerman S. Black R. Pierson l

B. Wilson C. Grimes J. Wilson J. Lyons R. Warnick R. Capra r

W. Butler l

R. Wessman J. Stolz E. Adensam H. Berkow D. Matthews J. Thoma i

J. Craig J. Hannon l

F. Hebdon C. Trammell C. Miller e

^

l TEMPORARK WAIVERS oF COMPLIANCE RI 1310.1/2 P ga 16 of 5 UNITED STATES NUCLEAR REGULATORY COMMISSION REGION 1 475 ALLENDALE ROAD KING OF PRUSSIA, PENNSYLVANIA 19406 Docket No. 50-443 Public Service Company of New Hampshire ATTN:

Mr. Edward A. Brown, President I

and Chief Executive Officer l

New Hampshire Yankee Division l

Post Office Box 300 Seabrook, New Hampshire 03874 Gentlemen:

Subject:

Temporary Waiver of Compliance Related to the Steam Turbine-Driven Emergency Feedwater (EFW) Pump This responds to your January 9, 1990 letter requesting a Temporary Waiver of Compliance for steam turbine-driven EFW pump testing at the Seabrook Station.

A copy of your letter is attached for reference.

After careful consideration of these issues, I have concluded that (1) the intent of the proposed EFW testing is to promote plant safety, and (2) that the relief granted will not put-the plant into an unsafe condition.

l A Temporary Waiver of Compliance is hereby granted for turbine-driven EFW pump operability testing.

The Temporary Waiver of Compliance is a 3-day (up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) extension of the 72-hour EFW pump inoperability action statement of Technic.al Specification 3.7.1.2 under the under the following conditions:

Reactor subcritical, with negligible decay heat.

l Motor-driven EFW pump and the startup feedwater pump operable, with the startup feedwater pump capable of being powered from an operable emergency bus and capable of being aligned to the dedicated water volume in the condensate storage tank.

If these conditions are not met for the motor-driven EFW pump and/or the startup feedwater pump during the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> extension, actions required by Technical Specification 3.7.1.2 shall be followed.

Notification of the NRC upon entry into and exit from the discretionary enforcement period.

Only one entry into this discretionary enforcement period under this authorization.

3('{3rman?t s ulV v

TEMPORARY WAIVERS OF COMPLIANCE RI 1310.1/2 Piga 17 of 5 Public Service Company of 2

FEB 01 1990 New Hampshire This extension and the condition detailed above, were discussed by Mr. E. McCabe of this office with-Mr. B. Drawbridge, Executive Director - Nuclear Production, on February 1, 1990.

Sincerely, William T. Russell Regional Administrator

Attachment:

As Stated cc w/ attachment:

J. C. Duffett, President and Chief Executive Officer, PSNH T.

C. Feigenbaum, Senior Vice President and Chief Operating Officer, NHY J. M. Peschel, Operational Programs Manager, NHY D. E. Moody, Station Manager, NHY T. Harpster, Director of Licensing Services R. Hallisey, Director, Dept. of Public Health, Commonwealth of Massachusetts S. Woodhouse, Legislative Assistant Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector State of New Hampshire, SLO Commonwealth of Massachusetts, SLO Designee Seabrook Hearing Service List t

1 i

l m