ML20083N552

Forwards Draft Technical Evaluation Rept,Per Contract NRC-03-82-118

ML20083N552
Person / Time
Site:	Harris
Issue date:	02/08/1983
From:	Behn J GAGE-BABCOCK ASSOCIATES, INC.
To:	Nolan F Office of Nuclear Reactor Regulation
Shared Package
ML20083L871	List: ML20083N541 ML20083N552
References
CON-NRC-03-82-118, CON-NRC-3-82-118, FOIA-84-35 NUDOCS 8404190222
Download: ML20083N552 (16)

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G AGE-BABCOCK & ASSOCIATES, INC.

CHICAGO OFFICE

• 135 ADDISON AVENUE. ELMHURST. IL 60126 * (312) 530-1494 V ;vy( .

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February 8, 1983 File 8271-2 Mr. Frank Nolan, Project Officer Cehmical Engineering, NRR U.S. Nuclear. Regulatory Commission Washington, DC 20555 .

Dear Mr. Nolan:

In accordance with Contract #NRC-03-82-ll8, Task 2 of Article 1, Section C, enclosed is the Draft Technical Evaluation Repo?t (DTER) for Shearon Harris.

Very truly yours, B. W* ,

James D. Behn Encl.

cc: w/o Encl.

Director, Div. of Engineering, NRR Contracting Officer, Div. of Contracts 4 90222 840313 P

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Draft Technical Evaluation Report

, DTER

Shearon Harris Nuclear Power Plant .

I Units Nos. I and 2 4

Docket Nos. 50-400 and 50-401 i

{ The applicant states in the FSAR that for the units fire alarm system the main

loop cables connecting local panels with annunciator panel are carried in separate 4

non-safety cable trays with connections to devices, panels or loop cross overs

carried in conduit. Interconnecting cable to system devices generally are carried

in conduit.

i Fire detection systems (heat, smoke, or flame) are provided in all safety-related i

~ areas, or in areas that present potential fire exposure to safety related systems

or equipment. Annunciators and alams.are transmitted to the MFDCP, located in the Unit 1 Communications Room, which in turn, alerts the affected Unit Control Room.

Each local panel displays local alam, trouble, normal and actuation signals.

When a fire condition is sensed by a detector, a white zone light is energized on the detector's respective LFDCP. Whenever there is a fire condition indicated at a LFDCP, an audible alarm, which produces a sound operate in conjunction with the

! LFDCP. This unit gives the layout of the fire zone and the exact arrangement and i location of fire detection therein. The unit operates on a "first-out" annunci-

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ation basis by lighting an indicating lamp representing the initially activated detectory ,

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A supervisory system is provided for each detection, actuation and alarm circuit.

He supervisory system is designed to actuate an audible alarm distinct from the fire alarm and an amber light at the LFDCP as well as an amber light on the MFDCP on the occurrence of any of the following:

1) Loss of electrical integrity in any detection circuit.

2) Loss of electrical integrity in any actuation circuit.

3) Loss of electrical integrity in any alarm circuit.

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4) Failure of water to flow within five seconds after any deluge valve release is activated.

E} Operation of any isolativ, of sectionalizing valve in the Fire Protection Systet., upstream from deluge, pre-action, multi-cycle alarm valves and strainers away from their normal active position. ,

6) Availability of operational power to fire pumps.

7) Loss of air pressure in supervised suppression system (pre-action and multi-cycle sprinkler systems).

8) Operation of waterflow detection devices.

9) Changes in distribution system water pressure.

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2 The applicant states that the supervisory system for each detecton, actuation and alarm circuit is in accordance with NFPA No. 26. NFPA 26 is the Super-vision of Valves Controlling Water Supplies for Fire Protection. We will require that the supervision of the entire system meet NFPA 720 " Standard for the Installation, Maintenance and Use of Proprietary Protective Signaling Systems."

The Fire Detection System satisfies the following general design requirements:

(a) All detection and transmission circuits are Class A as defined in NFPA Std. 720 and 72E.

(b) All fire detection devices and associated quipment are either OL listed

and/or FM approved and so labeled. They are installed in accordance with manu-facturer's specification and applicable NFPA standards. '

i (c) The system consists of a main signaling ' loop used to carry all fire and trouble alarms from the local fire detection control panels (LFDCP) to the

, main fire detection control panel (MFDCP). The alarm signals are transmitted by a solid state digital multiplexing technique. The signal transmission system is completely supervised by automatic built-in-test-equipment and alarmed on the MFDCP when a trouble condition exists. The system power is nominal 24V DC.

f Power for operation of fire detection systems and for actuation of fire suppres-sion system is supplied Dom the balance of plant static uninterruptible power supply. The MFDCP located in the Communications Room of Unit 1 supervises the Fire Detection System of plant Units 1 and 2 including their directly associated s aported buildings. Each fire zone is displayed on the MFDCP as a mimic of each of the LFDCP's. Included on the MFDCP are ' indicating lights for the oper-ational status of the fire pumps, various suppression systems, and the fire de-y tection signal transmission system. The MFDCP initiates a visual and audible alarm in the Control Room of the affected Unit.

The fire detection alann panels are supplied from Uninterruptible Power ~ Supply

! (UPS) Bus #1, which is supplied from the 60 kVa static UPS system. The UPS .

. system in turn is supplied fron non-Class IE mo' tor control centers (MCC). In the event of loss of offsite power, the station 250 volt DC battery which is -

capable of supplying the 6D kVa inverter for 4 hc,urs, is connected via the 250 voit Bus OP-1-250 tc the 60 kVa static UPS system. Bus DP-1-250 is also conr,ected via battery chargers to the Class IE emergency diesel generator manual load block. ,

The applicant uses a hand wired standby battery for the entire system. As re-quired by NFPA 72D each individual FACP should have its own standby battery source so that a fault, open or ground in a hard wired system will not elininate multi FACP on the same circuit. ,

The applicant should meet BTP CMEB 9.5-1 and provide the following:

Primary and secondary power supplies should be provided for the fire detection system and for electrically operated control valves for automatic suppression systems. Such pri' nary and secondard power supplies should satisfy provisions

j of Section 2220 of NFPA 72D. This can be accomplished by using normal offsite power as the primary supply with a 4 hr. battery supply as secondary supply; and by providing capability for manual connection to Class IE emergency power bus within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of loss of offsite power. Such connection should follow the applicable guidelines in Regulatory Guides 1.6, 1.32, and 1.75.

The applicant states on 9.5.1-7 of the FSAR that the storage and use of flam-mable and combustible liquids meet the intent and basic criteria of NFPA 30.

" Flammable and Combustible Liquids Code." In order to meet Section C.5.d of BTP ASB 9.5-1, we will require that all deviations from NFPA 30 be iden+ified and justified.

.The applicant states that the bulk storage of compressed or cryogenic gases is not permitted within structures housing safety-related equipment. The applicant does not state if hydrogen lines are routed through safety-related areas. In order to prevent a hydrogen explosion in safety-related areas of the plant, any hydrogen line in safety-related areas should be relocated outside such areas or be sleeved such that the water pipe is directly vented to the outside.

The applicant states in the FSAR that with regard to NRC criteria, the SHNPP fire protection program meets the intent of the guidelines outlined in Appendix A to Branch Technical Position APCSB 9.5-1 dated August 23, 1976.

t also states that the information on various aspects of the fire protection

.)rogram are detailed as required to show conformance with the guidelines or to demonstrate the equivalency of alternative approaches as previously described in the SHNPP PSAR Sectich 9.10, " Fire Protection System" submitted to the NRC as Amendment 54, dated May 1, 1977.

. The applicant's. fire protection program is only acceptable if it is in.accordance

with the following criteria:

l. 10 CFR Part 50 50.48, and General Design Criterion 3, as related to fire prevention, the design and operation of fire detection and protection systems, and administrative controls provided to protect safety-related struc-tures, systems, and components of the reactor facility.

2. General Design Criterion 5, as related to fire protection for shared safety-related structures, systems, and components to assure the ability to perform their intended safety function.

The following specific criteria provide information, recommendations, and guid-ante and in general describe a basis acceptable to the staff that may be used to meet the requirements of 50.48, GDC 3 and 5:

a. Branch Technical Position (BTP) CMEB 9.5-1 as it relates to the design provisions given to implement the fire protection progran.

The fire protection program will be reviewed to the guidelines of BTP CMEB 9.5-1 (NUREG-0800), July 19B1. The applicant should provide a comparison that shows conformance of the plant fire protection program to these guidelines. Deviations from the guidelines should be

• specifically identified. A technical basis should be provided for each deviation.

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b. F.egylatory Guide 1.78 as it relates to habitable areas such as the c:ntrol room and to the use of specific fire extinguishing agents.

c. Regulatory Guide 1.101, as it relates to fire protection emergency planni ng.

Three-hour fire separations can be incorporated into the design of new plants but are often difficult to achieve in plant already constructed. Initially, in the reviews of plant fire hazard evaluations, engineering judgment was employed to decide what additional protection, if any, was required in situations where 3 hr.

separations were not feasible. Because of variations in arrangements as well as differences in judgment, apparent inconsistencies in approach were noted. To attempt to standardize on the approach, a policy was developed for situations cere the fire hazard is not severe to allow automatic sprinklers plus a minimum tount (1 hr.) of fire resistance on exposed safety related systems.

In normal U.S. practice, it is common to allow lesser fire resistance for struc-tura' systems or fire barriers where the building is sprinklered. Typically, a reduction of 1 hr. of fire resistance is allowed, although it is not uncommon to find larger reductions, particularly where the life hazard is low. A study of failure modes due to fire in high-rise buildings showed that it would not be unreasor,able to equate a construction type that requires 3 hr. floors and beams without sprinklers to one that requires only 1 hr. floors and beams but with sprinklers.

This is similar to the guidance developed by NRC. Providing an' automatic sprin-kler system in areas allows the use of I hr. fire barriers rather than the nortnally required 3 hr. barriers. Without sprinklers, I hr. barriers alone would not provide the desired degree of safety, even in areas with light fire loadings. This is consistent with normal fire protection practice as well as the codes coronly used today as indicated above. Also, because of the normal time lag in the operation of sprinklers, the less-than-perfect reliability of sprinklers, and the high susceptibility of electrical cables to damage from fire, deletion of all fire resistance to separate closely-spaced redundant divisions in sprinklered areas cannot be justified. ,

If the intent is to avoid concurrent damage to both trains of redundant safety systems fro:- the same fire incident, obviously the two trains can be secarated by sufficier.t distance so that no fire that can reasonably be envisioned is likely to affect botr. In a typical building fire, fire, heat and products of combustion often trasel for several hundred feet, but in mest parts of a nuclear power plan, there is insufficient continuity of conbustibles to cause extension of a fire very far fro- the area of origin. Particularly in spaces where under normal conditions the combustibles are linited to the insulation on electrical cables and there is r.o storage and no combustible construction, the most severe fire that can reasonaoly be envisioned is one that occurs in transient materials.

However, a fire in transient cor.bustibles can be of sufficient magnitude to cause concurrent damage of redundant safety systems if they are in close proxim-ity to each other. (A fire that has been postulated as being likely solely from transient coTbustitles is a 25 sq. ft. flammable liquid pool fire, with i suf ficient fuel for 15 : in. of burning.) Except in spaces with very high l

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, ceilings, temperatures exceeding 1000 F are reached very rapidly directly above

$ w M or some distance horizontally from the fire. Temperatures drop off as 4

the distance from the fire is increased, and as a generalization for the con-ditions likely to be encountered, it appeared reasonable to assure that tempera-

! tures which could affect the reliability of ' control wiring would not be reached in at least one division if the cables are at least 20 ft. apart with no inter-i vening combustibles. .

I At separations of less than 20 ft, with no intervening barrier, there is suffi-i cient likelihood that an exposure fire will damage both divisions that relaiable  !

protection is necessary. Automatic sprinkler protection will provide an ade-  !

quate level of safety in such situations, where the hazard is light and prin-l cipally from transient combustibles. However, as indicated earlier, ' automatic 2

sprinklers cannot be relied on as the sole means of protection where redundant divisions are in close proximity to each other. It was felt that at least a

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20 ft separation should be provided to obtain sufficient reliability in suppres-

! sing a fire before failure due to excessive temperatures is likely in both di-visions.

l In the FSAR the applicant also states that where redundant systems could not be l separated by fire barriers, as in Containtnent, the Control Room as well as

other areas, other measures were emoloyed in order to prevent a fire-caused i loss of function of safety related systems. t Utilization of fire-resistive con-struction, provision of fire breaks and/or f; ire retardant coatings in cable

! trays, and installation of fire detection systems and automatic fire extinguish- '

) 1 7 systems were also us$ed. i h applicant should verify that fire protection has been provided for safe shut-do-n so that one train of systems necessary to achieve and maintain hot shutdown  ;

1 conditions from either the control room,or emergency control station (s) is free l of fire damage and that system necessary to achieve and maintain cold shutdown i

from either the control room or the emergency control station (s) can be repaired l

!- within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

The applicant should provide an analysis which shows that one redundant train j of equipment structures, systems, and cables necessary for safe shutdown can be

maintained free of fire damage by either

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(a) Separation of cables and equipment and associated circuits of redun- f dant trairs by a fire barrier having a 3 hr. rating. Structural steel forming a part of or supporting such fire barriers should be protected to provide fire resistance equivalent to that required of the barrier; '

i (b) Separation of cables and equipment and associated circuits of redun-l dant trains by a horizontal distance of more than 20 ft. with no interventing combustible or fire hazards. In addition, fire detectors and an automatic fire suppression system'should be installed in the fire area; or

, (c) Enclosure of cable and equipment and associated circuits of one redun-4 dant train in a fire barrier having a 1 hr. rating. In addition, fire detectors

} and an automatic fire suppression system should be installed in the fire area.

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Tjeapplicantshouldidentifythoseareasoftheplantthatwillnotmeetthe

1. guMnes of Section C.5.b of BTP CMEB 9.5-1 and, thus alternative shutdown will be provided. Additionally provide a statement that all other areas of the plant will be in compliance with Section C.S.b of BTP CMEB 9.5-1.

a) List the system (s) or portions thereof used to provide the shutdown capability with the loss of offside power.

i i b) For those systems identified in "a" for which alternative or dedicated shutdown capability must be provided, list the equipment and components of the normal shutdown system in the fire area and identify the functions of the circuits of the nomal shutdown system in the fire area (power to what equip-ment, control of what components and instrumentation).

Describe the system (s) or portions thereof used to provide the alternative shutdown capability for the fire area and provide a table that lists the equipment and components of 1 the alternative shutdown system for the fire area. For each alternative system identify the function of the new circuits l being provided. Identify the location (fire zone) of the alternative shutdown equipnent and/or circuits that bypass j the fire area' and verify that the alternative shutdown equip-j mend and /or circuits are separated from the fire area in accordance witn Section III.G.2.

, c) Provide drawings of the alternative shutdown system (s) which highlight any connections to the normal shutdown systems

• (P& ids for piping and components, elementary wiring diagrams i of electrical cabling). Show the electrical location of all .

breakers for power cables, and isolation devices for control

! and instrumentation circuits for the alternative shutdown systems for that fire area.

i d) Verify that procedures have been or will be developed which

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describe tasks to be perfomed to effect the shutdown method. *

! Provide a sumary of these procedures outlining operator actions.

I e) Verify that the manpower required to perfore the shutdown functions using the procedures of d) as well as to provide

, fire brigade members to fight the fire is available as re-

, quired by the fire brigade technical specifications.

f) Provide a comitment to perfom adequate acceptance tests of the alternative shutdown capability. These tests should verify that: equipment operates from the local control station when the transfer or isolation switch is placed in the " local" position and that the equipment cannot be oper-

! ated frors the control room; and that equipment operates from the control but cannot be operated at the local control station when the transfer isolation switch is is the " remote" position.

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g) Verify that repair procedures for cold shutdown systems are 4 developed and mater'ial for repairs is maintained on site.

Provide a summary of these procedures and a list of the i material needed for repairs.

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The applicant states in this Fire Protection Hazards Analysis that a circumfer-ential section of the reactor vessel mirror insulation between Elevation 246.6 ft.

and Elevation 251.2 ft was modified to incorporate neutron shielding. The neutron streaming shield is a composite of approximately 3 in, thick, consisting of 1-1/2 in. of "Microtherm" high-temperature insulation manufactured by Micropore Insulation Limited bonded to a varying thickness layer of "Ricorad" i neutron shielding material manufactured by the Richardson Company. The appli-cant states that each component of the composite is indicated by its manufac-

, turer to have " Excellent Fire Resistance Properties." Furthermore, the neutron streaming shield is encapsulated in stainless steel which will provide an ade-quate barrier. Since the " shield assembly" is encased and isolated inside the reactor vessel cavity, it is not considered to have a significant combustible loading and no fire will be postulated for this feature.

The applicant states that the neutron shielding material has excellent fire re-sistive properties as well as Leing encapsulated in stainless steel; it is r.ot considered a significant combustible loading. The applicant should provide.

technical justification on the preceding material to demonstrate the properties of the material are as stated.

The applicant states in the fire hazards analysis that structural barriers,

! partial or full height, are provided between redundant safety-related components a within the containment fire area. In addition, suitable fire barriers are pro-vided at points of close proximity between safety and non-safety relatdd cable trays where Regulatory Guide 1.75 criteria cannot be fully met.

The fire suppression system provided in the containment area is an automatic multi-cycle sprinkler system hydraulically designed to provide a density of 0.3 gpm/sq.ft. for either reactor coolant pump surface, airborne radioactivity removal unit housing top area, or cable tray run area. The system is actuated automatically by the thermal detectors located around each reactor coolant pump, over airborne radioactivity removal unit housing top, or over cable tray run area, when the area temperature reaches 200 F. The sprinkler headc open when area temperature reaches 225 F. The system water flow is shut off automatically 1

from the control valve when the area temperature drops below 200 F. The multi-ycle control valve for the system is located outside this fire area, in the RAS, Elevation 236 ft. Sprinkler System piping is seismically supported inside the *

. Containment, and in areas conta.ning safety related quipment inside the RAB.

Manual actuation of the system is provided from the multi-cycle control valve emergency mechanical release. Remote manual actuation of the multi-cycle system is provided from any manual alarm station strategically located throughout the Containment Building. Electrical supervision of this suppression system includes control valve position, system valve position supervisory air pressure and lack of water flow through the control valve. Hose stations and portable fire extinguishers are also previded.

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4 The applicant has not provided for the containment area (as well as all other areas of the plant), assurance through a defense in-depth design, that a fire will not prevent the performance of necessary safe plant shutdown functions and will not significantly increase the risk of radioactive releases to the environ-

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ment in accordance with General Design Criteria 3 and 5. The fire hazards analysis does not provide a list of systems and components needed to provide safe shutdown capability as well as lack of identification of locations where redundant trains or division of safe shutdown systems are separated by less than 20 ft. The following fire protection should be provided for the containment fire area:

Inside noninerted containment one of the fire protection means stated in ETP-CMEB 9.5-1 Section C.S.b.1 and C.5.b.2 or the following fire protection means should be provided: separation of cables and equipment and associated nonsafety circuits of redundant trains by a noncombustible radiant energy shield having a minimum fire rating of one-half hour.

In primary contain6ent, fire detection systems should be provided for each fire hazard. The type of detection used and the location of the detectors should be the most suitable for the particular type of fire hazard identified by the fire hazard analysis.

4 l A general area fire detection capability should be provided in the primary containment as backup for the above described hazard. detection.

To accomplish this, suitable smoke or heat detectors compatible with the radiation environment should be installed.

Standpipe and host stations should be inside PWR containments and BWR l containments that are not inerted. ' Standpipe and hose stations iriside containment may be connected to a high quality water supply of sufficient quantity and pressure other than the fire main loop if plant-specific features prevent extending the fire main supply inside containment. For BWR drywells, standpipe and hose stations should be placed outside the

, drywell with adequate lengths of hose, no longer than 100 ft, to reach any location inside the drywell with an effective hose stream. . .

i The reactor coolant pumps should be equipped with an oil collection system if the containment is not inerted during normal operation. The oil colle: tion syste should be so designed, engineered, and installed that failure will not lead to fire during normal or design basis accident conditions and that there is reasonable assurance that the system will withstand the safe shutdown earthquake.

! Such collection systems should be capable of collecting lube oil from all potertial pressurized and unpressurized leakage sites in the reactor coolant pump lube oil systems. Leakage should be collected and drained l to a vented closed container that can hold the er, tire lube oil system inventory. A flame arrester is required in the vent if the flash point characteristics of the oil present the hazard of fire flashback.

l Leakage point's te be protected should include lift pump and piping over-flow lines, lube cil cooler, oil fill and drain lines and plugs, flanged l connections on oil lines, and lube oil reservoirs where such features i

j exist on the reactor coolant pu ps. The drain line should be large

The applicant states in the FSAR that for safety related charcoal filter assem- -

blies, a low-flow air bleed cooling system is provided. This consists of air circulated through the charcoal adsorbers removing the decay heat, thus main-taining the charcoal below conibustion temperature. The control room operator will be alerted to any charcoal heating by the high-adsorber temperature in-strumentation alarm. In the event of fire in the adsorbers, the fire will be controlled by closing the isolation dampers to the pressure-tight filter cabinet, thus restricting the fire's oxygen supply. ,

1 Further means of protection of safety related equipment located adjacent to the I charcoal filters is provided oy automatic fire suppression systems over the

, charcgiter housings for limitation of the extent or damage from possible fires It is our position that engineered safety feature filters be protected in accor-dance with the guidelines of Regulatory Guide 1.52 as required by BTF CMEB 9.5-1.

The applicant also states in the FSAR that cable, cable tray and conduit penetra-tiens of fire barriers (vertical and horizontal) are sealed (fire stops) to give prctection at least equivalent to that required for the fire barriers. Fire stops at penetrations of cable trays through fire barriers and all floors are designed to meet the requirements of NFPA 803-1978, Section 6-3, " Protection of Openings in Fire Walls and Subdivisions."

Also the applicant stated in the response to NRC question #280.8 that the speci-fication for the design and installation of penetration seals through fire bar-riers requires that the seals be constructed, tested and installed per the applicable fire protection codes, standards and guidelines listed in FSAR section 9.5 l.2.1. ,

According to Sectica 6-3.1.l(c) of NFPA 803-1978, the penetration seal (fire stop) shall be determined acceptable provided that:

(1) Fire does not propagate to the unexposed side of the test assembly nor shall there be any visible flaming on the unexposed side.

(2) Temperature readings on the unexposed side shall not be high enough to ignite combustible material as evaluated in the fire hazard analysis.

(3) Penetration seal does not permit projection of water from hose stream test.

According to NFPA 251-1979 Section 7-2 for nonbearing walls and. partitions, the test shall be regarded as successful if the following conditions are met:

(a) The wall or partition shall have withstood the fire endurance test without passage of flame or gases hot enough to ignite cotton waste, for a period equal to that for which classification is desired.

. 10-(b) The wall or partition shall have withstood the fire and hose stream

tests without passage of flame, of gases hot enough to ignite cotton

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waste, or of the hose stream. The assembly shall be considered to have failed the hose stream test if an opening develops that permits a projec-tion of water from the stream beyond the unexposed surface during the time of the hose stream test.

(c) Transmission of heat through the wall or partition during the fire endurance test shall not have been guch as to raise the temperature on its unexposed surface more than 250 F (121 C) above its initial temper-ature.

4 There is a direct conflict on the utility's criteria as to what is or is not 1

acceptable cable trays penetration through a fire-rated barrier. The fire hazards does not analyze combustible materials in the fire area on the unexposed i side and its ignition temperature. The criteria of BTP CMEB 9.5-1 should be used (which includes NFPA 251) as the acceptance criteria since this criteria is also similar to UL 1479, Fire Tests of Through-Penetration Firestops. These standards are based on p'rotection of redundant safety systems and not on property protection. The following criteria should apply:

Penetration designs should utilize only noncombustible materials and should be qualified by test's. The penetration qualification tests should use' the time-temperature exposure curve specified by ASTM E-119, " Fire Test of Building Construction and Materials." The acceptance criteria for the

, test should require, that:

• i (a) The fire barrier penetration has withstood the fire endurance test without passage of flame or ignition of cables on the unexposed side f6r a ' period of time equivalent to the fire resistance rating" re-quired of the barrier.

(b) The temperature levels recorded for the unexposed side are analyged and demonstrate that the maximum tenperature does not exceed 325 F.

(c) The fire barrier penetration remains intact and does not allow pro- -

jection of water betond the unexposed surface during the hose stream test. The stream shall be delivered through a 1-1/2-inch nozzle set

at a discharge angle of 30% with a nozzle pressure of 75 psi and a mir.imum discharge of 75 gpm with the tip of' the r,czzle a maximum of 5 ft from the exposed face; or the stream shall be delivered through a 1-1/2-inch nozzle set at a discharge angle of 15*. with a nozzle

! pressure of-75 psi and a minimum discharge of 75 gpm with the tip of the nozzle a maximum of 10 ft from the exposed face; or the stream shall be delivered through a 2-1/2-inch national standard playpipe equipped with 1-1/8-inch tip, nozzle pressure of 30 psi, located 4 20 ft from the exposed face. ,

l The applicant states in the FSAR that for early warning of fire conditions in the cables, ionization type smoke detectors are provided along major cable trays runs throughout the plant. This is~not acceptable. Smo,ke detection shall be

l provided in all areas containing safety-related equipment and/or cable trays /

conduit regardless of the number or function as required in BTP CMEB 9.5-1 to ensure early warning.

The applicant states that fire protection system water will not be used for any non-fire related purposes, except limited use on intermittent bases to provide makeup water for isolated HVAC chillers in RAB and WPB. The applicant should verify that when water is taken from the fire system, the capacity should be limited so that the electric fire pump does not start on low pressure. Al so the applicant should verify that failure of the makeup water system will not degrade the fire water system.

.The applicant states that each vertical fire pump i' rated at 2500 gpm and 125 psi. The motor driven fire pump starts automatically when the pressure in the Nre main drops to 90 psi with the' diesel fire pump starting automatically at l' psi. The water pressure in the distribution system is maintained at approximately 100 psi by the jockey pump. In order to prevent unacceptable damage to the underground from water surges, the pressure on the system should be maintained at 175 psi which is the churn pressure of each fire pump. The pressure should not exceed the pressure. rating of the system.

In the FSAR, the applicant states that emergency DC lighting feed from the.125V station battery provides lighting in the Control Room, remote shutdown and computer rooms in the event that either train of the AC normal / emergency light-ing is lost. Fixed self-contained lighting consisting of fluorescent or seal-beam units with individual 8 hr. minimum battery power supplies should be pro-vided for the Control Room and the remote shutdown panel as required by BTP-CMEB 9.5-1, Section C.5.g.

The applicant states that a cast-in-place concrete trench'of approximately 11 ft long, 2 ft wide and 6 in, deep is provided under the HVAC control board located in each Unit Control Room. Covers are not provided for the trench, because of its small size and location, internal to the HVAC.

The applicant should provide smoke detection internal to the HVAC control board such that early detection is provided should an electrical melfunction develop in the trench. Also if manual fire suppression is dif ficult, an automatic gas fire suppression system should be provided to limit the development of smoke and toxic gtses in the control roo .

Ionization type smoke detectors are only provided at the ceiling level of the control room. The applicant states that the control room cabinets, panels and consoles are of the self-ventilating type permitting smoke to quickly migrate to the ceiling of the room. Since control room cabinets, panels and consoles cre of critical importance, the delayed time for the ceiling detectors to go into an alarm condition, cannot be tolerated. Since the combustion products are deluted into the room, smoke detectors should be installed within the cabinets.

This would insure prompt detection within the enclosure itself.

The applicant states in the FSAR that one and on-half inch hose connections, equipped with 100 f t. of hose and water spray nozzles, approved for use on energized electrical equipment and on corbustible liquid fires, are permanently

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• 12-provided in the Containment Building as standby fire extinguishino equipment for use during refueling and maintenance. Water supplies for t. e ..ose connec-tions are shut off during normal operation by means of shutoff valves located o.utside the Containment Building. Therefore, during normal operation the standpipe and hose system piping remain drained.

The applicant should verify that the conta.inment penetration of the standpipe system should meet the isolation requirements of General Design Criterion 56 and should be seis nic Category I and Quality Group B.

The applicant states that each turbine generator section of thie ~ plant is cut off from safety-related areas of the plant by 3 br. rated fire walls, with Class A fire doors. The applicant should verify that the turbine building is separated from adjacent structures containing safety-related equipment by a fire barrier with a minimum rating of 3 hrs. The fire barriers should be designed so as to maintain structural integrity even in the event of a complete collapse of the turbine structure. Openings and penetrations in the fire barrier should be minimized and should not, be located where the turbine oil system or generator hydrogen cooling system creates a direct fire exposure hazard to the barrier.

The applicant should identify such areas.

In the F5AF. it states that due to spatial separation of the diesel generatqr building from the main structure and to the fire barrier separations between redundant equipment, which precludes safet shutdown capability impairment from i

a single fire incident, interior standpipe hose stations, operable post SSE, have not been provided im these areas.

The applicant states that interior hose stations have not been provided for the diesel generator building and that secondary protection is provided by yard hydrants and hoselines. On Fig. 9.5.1-5, the piping layout for the building shows 2 fire hose rack and hose stations in the corridor. The applicant should clarify this discrepancy. Since this is a critical area with a significant fuel load, provision should be made to provide additional protection in the event of a safe shutdown earthquake since the only present protection are por. table fire extinguishers.

The diesel fuel oil storage tank and transfer pump building is protected by an

, automatic multi-cycle sprinkler system provided in the pump and piping areas i

with yard hydrants and heselines used for backup protection. A break in the undergrounc on tne west end of the building will leave only one hydrant on the east end that is a considerable distance from the building. The applicant should provide an additional sectional control valve such that protection is provided or the west end of the iuilding should a break occur. Also an addi-tional hydrant should be provided on the underground or the east side of the building tc provide closer. coverage of the of the building.

The applicant states that for the fuel handling building operations in the building are not related to safe shutdown of the reactor but safety related equipment is present in the building. The applicant should verify if redundant systems (ecaipment, conduit, cable trays) needed for either hot or cold shutdown are located in the new fuel area for both Unit 1 & 2.

a Also for any location in which safety related equipment and/or conduit / cable

• trays are located, smoke detection should be provided in the general area.

This applies to the new fuel unloading, new fuel storage, and spent fuel pool areas.

For fire area 1-A-ACP (9.5A-21), the Auxiliary Control (Panel) Room, the appli-cant states that the fuel loading for the room is approximately 3 hr. duration.

Protection fot the area consists of ionization type detectors, portable fire extinguishers and 1-1/2 in, hose stations.

The applicant also states that full height, 3 hr. rated fire barriers are pro-vided between SA and SB safety related cable trays within the fire area at E-39.

. Also supplemental barriers are provided where safety and non-safety related cable trays are at close proximity and Regulatory Guide 1.75 criteria cannot be met fully.

A detailed fire hazards analysis should be done for fire area 1-A-ACP incor-porating the design criteria as stated previously to specific measures for fire prevention, fire detection, fire suppression and fire containment and alterna-tive shutdown capability as required. The applicant should also consider the consequences of an exposure fire in the room even though administrative controls are established to ensure that at least one means of achieving and maintaining safe shutdown conditions will remain available during and after any postulated fire in the room.

Figure 9.5A-7, fire zones 1-A-3-COMB, and 1-A-3-COME, elevation 236' . The appli-cant should verify that the 10' x 10' removable metal panels in the east wall 4

between C and D and G and H at column line 43 are fire rated for 3 hrs. per ASTM E-119 fire test. These panels were also noted in the following fire zones:

Fire Zone 1-A-3-COR at H-15 and G-13 Fire Zone 1-A-COMB, elevation 261 between C and D at column 43 4 Fire Zone 1-A-COME, elevation 261 at H-43 Fire Zone 1-A-COMI, elevation 261 at H-15 and between H and G at 13 On figure 9.5A-7, fire zone 1-A-3-COMI, elevation 236', the applicant is taking credit for a horizontal 3 hr. fire rated wall along column line 43 except a 1-1/2 hr. B labeled door is being provided. The applicant should provide a A labeled fire door to properly protect the opening to assure a 3 hr. fire rating.

On fi;ure 9.5A-8, fire zone 1-A-4-CHFB, elevation 261' at L-31, a personnel door is shown in the 3 hr. fire rated door, however, no fire rating of the door -

is given. This door should be a Class A, 3 hr. fire rated door.

On page 9.5A-31 of the applicant's fire hazards analysis between columns 41 to l 43 and E to H, the fire zone has two designations,1-A-4-COMB and 1-A-4 COME.

The applicant should correct this error. )

Figure 9.5A-8, fire zone 1-A-4-COMI, elevation 261', the applicant is taking l credit for a horizontal 3 hr. fire-rated wall between '! and J at Column line 43 i except a 1-1/2 hr. B labeled door is being provided., The applicant should i provide an A labeled fire door to properly protect the opening to assure a l 3 hr. fire rating.

. l e

• 14-I Fire area 12-A-CRCI on page 9.5A-ll7 of the FHA contains the visitors gallery within the 3'hr. fire barrier of the control room. The applicant should provide an automatic water suppression for the room in addition to providing a 1 hr.

noncombustible fire rated cutoff for the room to meet BTP CMEB 9.5-1. Section C.7.b.

On figure 9.5A-10, elevation 305', fire zone 12-A-6-CR, the computer room and fire zone 12-A-C-ARPI, the Auxiliary Relay panels room share a common wall.

Safety-related equipment is located in the relay room. Although the applicant does not consider Class A material in the room,a significant amount may be stored there. The applicant should provide a 3 hr. fire wall to separate these two areas from each other. All penetrations in this wall should also be properly protected. Also tne computer room communicates with fire zone 12-A-6-PICRI, the process instruments and control racks which are also safety related through a portion of an unrated wall and door. The applicant should provide a 3 hr.

fire rated wall and door for this portion of the wall. This would effectively cut off the computer room frce, any safety-related room of the control room complex.

On page 9.5A-32 cf the applicant's Fire Hazards Analysis, fire zone 1-A-5 HVA, HVAC Room 1A, elevation 285', floor area 2700 sq.ft. is described. An examina-tion of figure 9.5A-9, elevation 286', revealed that the preceding fire area could not be found. The applicant should clarify this discrepancy. .

The preceding problem also applies to fire zone 1-A-5-HUB, HVAC Room 18.

Also on page 9.5A-33 of the applicant's Fire Hazards Analysis, fire zone 1-A BATN, Battery Room Neutral, elevation 286', is shown; however, on figure 9.5A-9, this zone is listed on the drawing but the location is not shown. The applicant should clarify this discrepancy. .

The applicant states that mechanical piping penetrations through fire barrier walls are anchored or sealed with flexible or semi-rigid fire stop assemblies.

Penetration. designs should utilize only noncombustible materials and should be qualified by tests. The penetration qualification tests should use the ,

. time-temperature exposure curve specified by ASTM E-119, " Fire Test of Building 3 Construction and Materials." The acceptance criteria for the test should be as required in BTF-CMEM 9.5-1, Section C.5.a(3).

On page 9.5A-43 of the applicant's Fire Hazards Analysis, it states, "Should the oil fire (55 gal. drum) prove to be more severe than anticipated, the heat released will actuate the multi-cycle sprinkler, as described under Item 8 of this analysis." This will control the fire a prevent possible damage to the redundant cable trays prior to the arrival of the fire brigace.

l A malfunction of the pre-action system, according to the applicant's own criteria, could cause the malfunction of redundant cable trays necessary for safe shutdown.

For this reason the criteria as stated previously should be used by the applicant to determine adequate and acceptable separation distance.

l

. \

On page 9.5A-135 of the applicant's Fire Hazards Analysis for Fire Area 5-F-BAL, fuel handling building, it states that only manual fire alarm stations are provided for the fuel building. In order to provide carly indication of a fire condition, automatic fire detection should be provided for all new fuel areas in the building which give audible and visual alarm and annunciation in the control room. Local audible alarms should sound in the fire area.

The applicant states on page 9.5A-179 of the Fire Hazards Analysis that for fire areas 1-D-DTA and 1-D-DTB, diesel generator fuel oil day tank enclosu c, a watertight door is provided in the 3 hr. fire-rated wall to prevent the spread of combustible liquids beyond the fire area. A watertight door is not a 3 hr. fire rated door due to the gasket material around the perimeter of the door which wnen burns off in a short period of time allows flames to propagate to the opposite side. A sliding 3 hr. fire-rated door should be installed on the outside of the tank storage room. ' This will prevent the spread o'f any fire in the tank storage area to the adjacent area.

The applicant also states that a floor drain valve located in the valve pit adjacent to fire zone 1-D-1-DGA-ASU or 1-D-1-DGB-ASU is normally closed and connects the day tank room to the diesel generator room. If this valve remained open, a fire in the storage tank room would spread into the diesel generator room. The applicant should supervise this valve on the fire alarm system with alarm and indication in the control room. The applicant should also verify that this drain system is not interconnected between the redundant trains of the diesel generators.

The applicant states that on page 9.5A-192 of the Fire Hazards Analysis for fire areas 12-I-E5WPA and 12-I-ESWPB, the intake structure-emergency service water pumps, a fire detection system is not being provided. Both trains B pumps are located on one side separated by 3 hr. fire barrier floor train A, located on the other side. The applicant should provide automatic fire detectors for the entire building to enable control room personnel to provide early re-sponse should a fire situation develop. The detection system should alarm and annunciate in the control room.

On page 9.5A-203, fire zone 5-W-2-RPOR, Relay and Process Instru ent Room, elevation 236 ft., the applicant describes tne contents of this room. The fuel loading for this room is 130,000 Btu /ft2 or approximately a 2 hr. fire duration.

The applicant has provided ionization smoke detection for the room. Due to the heavy loading in this roo . the applicant should provide a 2 hr. fire barrier (walls, ceiling and floor) such that any fire will be contained in the room.

Also an automatic fire suppression system should be installed to control and/or extinguish any fire that should develop. The applicant should also clasify the typo error on page 9.5A-203 from 5-W-2RPOR to 5-W-2RPIR.

Fire zone 5-W-2-LCHTr.-1, Low Conductivity Holding Tanks for Units 1 and 2, elevation 236', cannet be found on figure 9.5A-26. The applicant should correct this discrepancy.

On page 9.5A-215 of the applicant's Fire Hazards Analysis for fire zone 5-W-4-HL, 5-W-5-SLD and 5-W-5-FA, the only detection provided are manual pull station.

The applicant should provide automatic fire detection for these areas to provide early alarm should a fire situation develop. The detection should alarm and annunciate in the control room.

Box 2901 Irurham NC 27705 12 January 1964 Jose Liv.ph Felton of Rules & Records FREEDOM OF INFORMA110N USBBC ACT REQUEST washington , LC 20555 g

Q f f --g_g Laar Joseph Felton, -

'd / ~/4 -ff Under the Freedos of Information Act, NO Public Interest Research Group, a nonprofit organization, hereby requests copies

1. of all valuation extant drafts of sections or portions of the Safety Report (SER) for tne Shearon Harris Nuclear Power Plant, and any documents by or in the possession of Staff reviewers whien snow dissenting opinions as to any contents or conclusions of the Barris SEB.

NC P1hG is a research and advocacy organization with over 3,000 acabers and puolishes reports on various matters affecting the g

puclic interes t , e.g. generic drugs , tenant rightu , rape awareness ,

utility rates, toxic chemicals, and nuclear waste transportation.

hC PIRG is ful2y qualified to present information from this request to be used by the public, and therefore requests a waiver of fees since we do not have sufficient funds to pay for extensive copying unich may be required, given that the draf ts could excee the 2 inc thick SER in extent.

(work) or Please feel free to contact me 919-266-2275 919-286-3076 (home) concerning this request.

Welle Eddleman '$s w i

Staff Scientist

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