ML20137G693
| ML20137G693 | |
| Person / Time | |
|---|---|
| Site: | 05200003 |
| Issue date: | 03/27/1997 |
| From: | Diane Jackson NRC (Affiliation Not Assigned) |
| To: | NRC (Affiliation Not Assigned) |
| References | |
| NUDOCS 9704010472 | |
| Download: ML20137G693 (40) | |
Text
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t UNITED STATES j ,j
'2 NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20066-0001 i
..... March 27, 1997 i
l l APPLICANT: Westinghouse Electric Corporation i FACILITY: AP600 t
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SUBJECT:
SUpttARY 0F TWO MEETINGS TO DISCUSS WESTINGHOUSE AP600 FIRE PROTEC- !
l TION ANALYSIS j The subject meetings were held at the Nuclear Regulatory Commission (NRC) l t
office in Rockville, Maryland, on February 10, and March 7, 1997, between I representatives of Westinghouse Electric Corporation (Westinghouse) and the 3 Nuclear Regulatory Commission (NRC) staff. The purpose of the meetings were to discuss unresolved open items related to standard safety analysis report j
(SSAR) Section 9.5.1 and 9A.
Over the two meetings, the open issues were discussed and resolution paths for some items were identified. It was agreed, in the first meeting, that a followup meeting would be scheduled in the last week of February. This meeting was delayed due to schedular conflicts until March 7,1997.
February 10. 1997. seetina:
Attachment 1 is a list of meeting participants. Attachment 2 is a NRC meeting handout that lists the recent correspondence for this review area. In the 1 meeting, Westinghouse and the staff discussed the open items using the open l item tracking system (OITS) as a guide. During the discussion, the staff I expressed its concerns regarding several unresolved issues that its believes l have the potential to impact the review schedule. The status of the open items and the draft SSAR markup with agreed-upon words, as a result of the meeting, are provided in Attachment 3. Attachment 4 is SSAR markups provided by Westinghouse at the meeting to assist the staff's review. Attachment 5 is a Westinghouse response sent by facsimile on February 6, 1997, for discussion at this meeting.
March 7. 1997. meetino:
Attachment 6 is a list of meeting participants. During this meeting, the l remainder of the open items were discussed. Westinghouse discussed their responses to some of the actions from the February 10, 1997, meeting.
Westinghouse was requested to provide these responses formally for review.
Westinghouse agreed to this action. Draft responses were sent via facsimile on March 20, 1997 (Attachment 7). s The open items to be discussed duriag this meeting were related to safe i I
shutdown. Westinghouse has respoided to all of the request'ed questions.
Westinghouse assisted the staff's review by discussing their responses and I providing additional information. The staff has the action to review the adequacy of the responses. Westinghouse expressed a concern on an apparent 0 1 0 0 4 ,e NRC FEE CENTER COPY 9704010472 970327 PDR ADOCK 05200003 E PDR
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1 March 27, 1997 lack of staff progress since the February 10, 1997, meeting. The staff disagreed and informed Westinghouse that an internal meeting had been held with upper management and that staff positions for several issues were being prepared. Additionally, the staff has recently involved management more in this review area and the two meetings had assisted in focusing the management on the key issues necessary for the completion of this review.
It was agreed that if the OITS was not assisting review progress that it be set aside. The staff and Westinghouse agreed to a telephone conference to discuss the review progress at the end of March. i original signed by: ,
Diane T. Jackson, Project Manager Standardization Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation Docket No.52-003 Attachments: As stated cc w/ attachments:
See next page DISTRIBUTION w/ attachments:
- Docket File PDST R/F TKenyon PUBLIC TKenyon BHuffman DTJackson JSebrosky JHolmes, 0-8 D1 TMarsh, 0-8 D1 SWest, 0-8 DI PMadden, 0-8 D1 DISTRIBUTION w/o attachment:
SCollins/FMiraglia, 0-12 G18 AThadani, 0-12 G18 RZimmerman, 0-12 G18 TMartin MSlosson TQuay Dross, T-4 D18 WDean, 0-17 G21 ACRS (11)
JMoore, 0-15 B18 GHolahan, 0-8 E2 BThomas, 0-8 D1 DOCUMENT NAME: A:SFP2 10. MIN T2 eneelve a copy of todo docuenent,Indiiste In the ben: 'C" = Copy wuthout attachment / enclosure *E' = Copy with attachment / enclosure 'N' = No copy 0FFICE PM:PDST:DPRM ,; gSPLB: DSS $ , D:PDST:DRPM l l ,
NAME DTJackson:sg % #3 West F TRQuay 1 tu DATE 03/1$97 \J 03f/f//97 03/WI/97 ,
OFFICIAL RECORD COPY
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I i l Westinghouse Electric Corporation Docket No.52-003 i i l 4
cc: Mr. Nicholas J. Liparulo, Manager Mr. Fran; A. Ross i Nuclear Safety and Regulatory Analysis U.S. Department of Energy, NE-42 )
i i Nuclear and Advanced Technology Division Office of LWR Safety and Technology i i
Westinghouse Electric Corporation 19901 Germantown Road !
i P.O. Box 355 Germantown, MD 20874 l Pittsburgh, PA 15230 ]
1 Mr. Ronald Simard, Director i
Mr. B. A. McIntyre Advanced Reactor Program Advanced Plant Safety & Licensing Nuclear Energy Institute i Westinghouse Electric Corporation 1776 Eye Street, N.W.
- Energy Systems Business Unit Suite 300 l Box 355 Washington, DC 20006-3706 4 Pittsburgh, PA 15230 -
Ms. Lynn Connor i
Ms. Cindy L. Haag Doc-Search Associates i Advanced Plant Safety & Licensing Post Office Box 34 i Westinghouse Electric Corporation Cabin John, MD 20818 i Energy Systems Business Unit i Box 355 Mr. James E. Quinn, Projects Manager l
Pittsburgh, PA 15230 LMR and SBWR Programs GE Nuclear Energy Mr. M. D. Beaumont 175 Curtner Avenue, M/C 165 Nuclear and Advanced Technology Division San Jose, CA 95125 Westinghouse Electric Corporation One Montrose Metro Mr. Robert H. Buchholz 11921 Rockville Pike GE Nuclear Energy Suite 350 -175 Curtner Avenue, MC-781 Rockville, MD 20852 San Jose, CA 95125 Mr. Sterling Franks Earton Z. Cowan, Esq.
U.S. Department of Energy Eckert Seamans Cherin & Mellott NE-50 600 Grant Street 42nd Floor 19901 Germantown Road Pittsburgh, PA 15219 Germantown, MD 20874 Mr. Ed Rodwell, Manager l Mr. S. M. Modro PWR Design Certification ;
Nuclear Systems Analysis Technologies Electric Power Research Institute Lockheed Idaho Technologies Company l 3412 Hillview Avenue Post Office Box 1625 Palo Alto, CA 94303 !
Idaho Falls, ID 83415 Mr. Charles Thompson, Nuclear Engineer AP600 Certification NE-50 19901 Germantown Road Germantown, M) 20874 1
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WESTINGHOUSE /NRC AP600 MEETING I FIRE PROTECTION i
FEBRUARY 10, 1997 i M8 tie ORGANIZATION JEFF HOLMES NRR/DSSA/SPLB DIANE JACKSON NRR/DRPM/PDST l PAT MADDEN NRR/DSSA/SPLB TAD MARSH NRR/DSSA/SPLB ,
HAROLD WALKER NRR/DSSA/SPLB STEVE WEST NRR/DSSA/SPLB ED CUMMINS WESTINGHOUSE DON HUTCHINGS WESTINGHOUSE JIM WINTERS WESTINGHOUSE I I
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Attachment 1 1
Recent Fire Protection Communication by date Date Written by Type February 6, 1997 NRC meeting minutes - 1/7/97 meeting February 6, 1997 WEST fax - air compressor and fire pump in turbine building January 31, 1997 WEST fax - SSAR p. 9.5-5 and 9A-5 Markups (3 pages)
January 30, 1997 WEST letter January 24, 1997 WEST fax - Example table from meeting open item (3 pages)
January 17, 1997 WEST fax - SSAR 9A Markups for parts of 306 (18 pages)
January 15, 1997 WEST fax - SSAR 9A.3 Markup from meeting open item (1 page)
January 14, 1997 WEST fax - SSAR p. 9.5-4 and -5 Markup for OITS 309d (2 pages)
January 14, 1997 WEST letter January 13, 1997 WEST fax - SSAR 9.5.3.2.2 Markup (1 page) '
January 10, 1997 WEST fax - SSAR page 3.4 No SSAR change proposed (1 page)
January 8, 1997 NRC telecon summary - 12/31/96 and 1/3/97 January 7, 1997 WEST letter January 3, 1997 NRC meeting minutes - 11/19/96 December 10, 1996 WEST letter September 20, 1996 WEST letter September 10, 1996 WEST letter October 11, 1996 WEST letter October 4, 1996 WEST letter August 13, 1996 WEST June 24, 1996 NRC Open Issue Summary for fire protection Attachraent 2
- ____. . -. -- _ .- - _- _. ~
i Recent Fire Protection Communication by date :
Date Written by Type February 6, 1997 NRC meeting minutes - 1/7/97 meeting January 8, 1997 NRC telecon summary - 12/31/96 and 1/3/97 January 3, 1997 NRC meeting minutes - 11/19/96 1
January 17, 1997 l WEST fax - SSAR 9A Markups for parts of 306 (18 pages)
December 10, 1996 WEST letter January 30, 1997 WEST letter January 7, 1997 WEST letter January 31, 1997 WEST fax - SSAR p. 9.5-5 and 9A-5 Markups (3 pages)
January 14, 1997 WEST fax - SSAR p. 9.5-4 and -5 Markup for i OITS 309d (2 pages)
January 14, 1997 WEST letter January 30, 1997 WEST letter January 13, 1997 WEST fax - SSAR 9.5.3.2.2 Markup (1 page)
August 13, 1996 WEST January 10, 1997 WEST fax - SSAR page 3.4 No SSAR change proposed (1 page)
January 15, 1997 WEST fax - SSAR 9A.3 Markup from meeting open item (1 page)
January 24, 1997 WEST fax - Example table from meeting open item (3 pages)
September 10, 1996 WEST letter September 20, 1996 WEST letter October 4, 1996 WEST letter October 11, 1996 WEST letter June 24, 1996 NRC Open Issue Summary for fire protection l
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Recent Fire Protection Communication by OITS !
i j 9111[ Date/tyne Comments i
} 306 January 17, 1997 fax SSAR 9A Markups for parts of 306 (18
- pages) li j 306(a) January 30, 1997 letter
! 308 January 7,1997 letter -
309 January 31, 1997 fax SSAR p. 9.5-5 and 9A-5 Markups (3 pages) l I i 309d January 14, 1997 fax SSAR p. 9.5-4 and -5 Markup for OITS 309d I
- (2 pages) i~ 314 January 14, 1997 letter 1 January 30, 1997 letter 319 January 13, 1997 fax SSAR 9.5.3.2.2 Markup (1 page) 1162 August 13, 1996 letter 1996 January 10, 1997 fax SSAR page 3.4 No SSAR change i proposed (1 page)
{
stg 01 January 15, 1997 fax SSAR 9A.3 Markup from meeting open item l (1 page) l 1
atg OI- January 24, 1997 fax Example table from meeting open item (3 l pages)
RAI 280.10 September 10, 1996 letter i RAI 280.11 September 10, 1996 letter 1 RAI 280.12 September 20, 1996 letter I RAI 280.13 October 4, 1996 letter :
RAI 280.14 October 11, 1996 letter RAI 280.15 October 11, 1996 letter RAI 280.16 October 11, 1996 letter RAI 280.17 October 11, 1996 letter RAI 280.18 October 11, 1996 letter RAI 280.19 October 11, 1995 letter RAI 280.20 December 10, 1996 letter RAI 280.21 September 20, 1996 letter RAI 280.22 September 20, 1996 letter RAI 280.23 September 20, 1996 letter RAI 280.24 September 20, 1996 letter RAI 280.25 September 20, 1996 letter RAI 280.26 September 20, 1996 letter RAI 280.27 October 4, 1996 letter RAI 280.28 October 4, 1996 letter j RAI 280.29 October 4, 1996 letter October 4, 1996 letter RAI 280.30 l RAI 280.31 October 11, 1996 letter-
s AP600 FIRE PROTECTION MEETING
[ FEBRUARY 10, 1997 OPEN ITEN STAfUS
- 1. OITS# 306 - Action W & N
- The example " effects" table sent by Westinghouse via facsimile on January 24, 1 1997, was discussed. Westinghouse was requested to complete the table for all i fire areas and to include non-safety related systems that would be used in a j normal shutdown (Action W). It was understood that Westinghouse did not address this earlier because they used their fire analysis as Lasis for their responses, which relies on safety-related equipment only. This table will assist the staff in evaluating the effects of fires on the plant.
The staff expressed a concern for the reliance on non-safety related systems to reach cold shutdown. Westinghouse discussed that for the AP600, the Commission approved the use of " safe shutdown." However, the staff noted that this applies to accidents. The staff needs to evaluate the acceptability of safe shutdown as the end state for fires (Action N).
The staff expressed a concern that the safety related, passive systems should not be relied upon for every fire and that the non-safety related, defense-in-depth (DID) systems need to be adequately protected to prevent this. The staff referred to Generic Letter 86-10 regarding the philosophy of not using emergency core cooling systems (ECCS) for fire fighting. Westinghouse needs to explain how it protects defensa-in-depth (DID) systems from fire (Action W).
Westinghouse requested any additional information or guidance on meeting fire protection regulations (Action N).
- 2. OITS# 307 - Action N The staff review is continuing on associated circuits.
- 3. OITS# 308 - Action W Westinghouse will explain how the AP600 meets the requirements in Appendix R and provide justification for deviations. This discussion should be included l in the standard safety analysis report (SSAR).
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- 4. OITS# 309 - Confirm W Westinghouse will revise the SSAR with the agreed upon attached markup.
1 Attachment 3 m% -
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' l i 5. OITS# 310, 312, and 316 - Action N l
' I Westinghouse provided the staff will large plant drawing to assist the staff in identifying cable routing and sprinkler coverage. The~ staff will continue !
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its review. I 1
- 6. OITS# 311 - Resolved Previously resolved item.
f 7. OITS# 314 - Action N The staff is concerned that the use of fire water supplied from the passive i
1 containment cooling tank is insufficient for well developed fires. The staff asked if the seismically-qualified fire system had seismic detectors.
- Westinghouse will check on this question.
1
) 8. OITS# 319 - Action N
!: The staff reviewed that Westinghouse facsimile of January 13, 1997. The staff j stated that Westinghouse did not address completely address the issue. The staff is continuing its review of this item including the January 13, j facsimile.
t l 9. OITS# 321 - Action W i
a) Air Compressor: The staff discussed its concern that the air compressor was located in the turbine building. Westinghouse discussed its February 6, l 1997, facsimile, which did not completely address the staff's concern.
j Westinghouse proposed to dedicate 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> of bottled air for fire fighting in
- a fire area separate from the turbine building. This resolution was accept-1 able to the staff.
- b) Fire pumps: The staff discussed its concern about the location of t'he fire i pump in the turbine building and the location of the air intake for the pump.
- The staff also questioned if the AP600 had the capability to isolate the
! turbine building for the fire main and the routing of cables to the electrical fire pump was safe.
f The staff expressed its concerns regarding the qualification of electrical and 1
I&C equipment in both pump rooms. The staff also requested Westinghouse to look at distance requirements for the fire water tanks from buildings, especially the turbine building.
- 10. OITS# 322 - Action W Westinghouse needs to demonstrate that the floor drains are adequately sized 4
using the fire main in safety-related areas. Westinghouse also needs to i provide justification that Class 2 is adequate for the seismic standpipe.
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- 11. OITS# 323 - Action W Westinghouse needs to include in the SSAR a description of the smoke centrol system, its logic, and operation. In this description, Westinghouse needs to consider reopening of fire and smoke dampers.
- 12. OITS# 324 - Action N 4
The staff will continue its review on smoke control in the turbine building.
) 13. OITS# 1996 - Action N
- 14. OITS# 1114 - Action N l
- 15. OITS# 1120 - Action N l i 16. OITS# 3439 - Action W Westinghouse needs to update this RAI response.
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! As deamtied la sidisassion 9.5.1.2.1.1, - 6 fke terriers are provided in accordance wim i FrP 04E3 9.51 and NFPA 803 (Raferesse 2). The equivaless Are barrier ratees are aboom in risuses 1 tsough 9A-5 '" "" --
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, are surrounded by Src bemers, rm gi __' J = "__ L.* -
. ., Are bemer pencersone j praisadon, and odwr devices, such as shoes wishla she haanns and air condinoemas ducss, sbst isonese
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oossaisement. Are annes are usually acunese ey paysamal strussures equivaleur to a 3-hour Grc bemer. In some cases, other fire pranaaeh= fuseures apply, such as distanne or lack of feel. For esamiple, fise some 1100 AP 11300A has no physical barrier busween k and are ages 1100 AF i
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U l l WSStinghouse FAX COVER SHEET i RECIPlENT INFORMATION i SENDER INFORMATION i DATE: Fe.loraorg 4 , m *7 _ Name: Den $4 d h{q$ f TO: Dian[ ac6 e LOCATION: ENERGY CENTER - EAST PHONE: PHONE: Offica: 412-374 trioq COMPANY: Facsimile: win: 284 5535 R$ MRC. outside: (412)374-5535 LOCATION: Cover + Pages 1+d The following pages are being sent from the Westinghouse Energy Center, East Tower, Monroevlue, PA. If any problems occur during this transmission, please call: WIN: 284-5489 (Wanda)/4031 (Delina) or Outside (4121374-5449/4031. l COMMENTS: D lQt12.i ,
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- N 86) DffYC 48( l hd.:W9tfd,1$ fogA, f$1TOLI.
I. D cc: Liegren Me h 4urs hLAJlhMS wfa 100*3 dud DEN 01 1833 NDIS3G 009dd WOdd 2C:8 46. 9 833 4889 PLE ETP pg. g
- c.
i 1 . i ISSUE l ne NRC has voiced concerns relative to protecting the fire pumps which are located in the turbine building in the event of a large turbine building fire. DISCUSSION i i i Postulated Imas of Fire Main in the Turblee Building i i The fire protection main includes an underground yard loop and a yard main ex'ension I that distributes water to suppression systems and hose stations within the main plant ! buildings. If the yard main extension in the turbine building is damaged due to a fire or any other reason, the damaged portion of the main can be isolated using installed sectionalization valves. With the damaged portion isolated, the underground yard loop j is still capable of supplying fire hydrants on the yard loop and supplying the other
- buildings connected to the yard main extension. Isolation of the yard main extension i in the turbine building results in loss of the ability to fill the PCS storage tank.
l However, the inventory of the PCS tank remains available to supply hose stations in j areas containing safety related equipment. l Postulated Loss of Fire Pumps i ne motor and diesel driven fire pumps are located in separate fire rated enclosures.- ! These enclosures are designed to prevent the spread of fires within the turbine building 3 to the fire pumps. The turbine building is provided with fire detection and suppression j systems designed to detect fires, extinguish fires, and limit fire damage. With these l systems functioning properly, a general turbine building fire that causes sttuctural j damage to the building and subsequent collapse resulting in loss of the Sre pumps is
- considered unlikely.
l l Even if the fire detection and suppression systems do not function properly, it is
- - unlikely that the turbine building structure would collapse due to fire. . As the turbine i building is designed for tornado and seismic loads, structural members are larger than j required for other load conditions. The building is laterally braced in both the north-j south and east-west directions. The structural steel members are designed for i temperatures up to 1000*F. Allowable stress values for the steel members are reduced for the increased temperatures. The turbine building's large steel members would have I to be exposed to very high temperatures for several hours before even minor warping j or distortion might occur. This provides significant time for fire fighting activities.
i 1 j ne location of the fire pump rooms in the heavily braced northwest corner of the l turbine building make It unlikely the fire pumps would be damaged even if building l { collapse did occur. The fire pumps are located on the basemat at el.100'-0". The j j turbine building floors directly above the fire pumps are lightly loaded, i.e., the ; j secondary sampling laboratory on el.117'-6", the electrical switchgear room on el.135'-3", and an open portion of the operating deck on el.161'-0". There is no } 1 01/28/97 i l , zee ased can oi 1833 Neissa easde woes ac:e ts. e sas
1 heavy equipment located above the pumps that might cause the structure above the pump rooms to collapse during a fire However, should a fire in the turbine building result in a loss of the fire pumps, this would not affect the ability of the plant to shut down. As the turbine building is separated from areas containing safety related equipment by 3-hour rated fire walls, a fire in the turbine building is not postulated to result in fire damage in any area containing safety-related equipment. Following loss of the fire pumps, fire hrme i stations in safety-related areas will continue to be supplied from the PCS storage tank. l The fire pumps and any damaged portions of the fire protection yard main extension in the turbine building can be isolated. It is anticipated that a fire pump truck could be used on a temporary basis to charge the fire protection main until the fire pumps were replaced. 4 .i i d i i 1 2 01/28/97 C00*3Ddd DEN 01 1833 NDIS30 009dd WOdd CC:8 46. 9 833
l A ISSUE ! l The NRC has voiced concems relative to protecting the high pressure breathing I compressor which is located in the turbine building in the event of a large turbine building fire. l l REQUIREMENTS: 4
)
l BTP CMEB 9.51, Paragraph C.3.c states in part: l "At least 10 [self-contained breathing apparatus] masks shall be available for fire ! brigade personnel." i l
" Service or rated operating life shall be a minimum of one half hour for the self contained units."
l "At least two extra bottles should be located onsite for each self-contained breathing unit." . i s
"In addition, an onsite 6-hour supply of reserve air should be provided and arranged to permit quick and complete replenishment of exhausted supply air l 1
bottles as they are returned. If compressors are ured as a source of breathing air, j only units approved for breathing air shall be used; compressors shall be operable 1 assuming a loss of offsite power." 10CFR50, App. R, Paragraph III.H. states in part:
"At least 10 (self-contained breathing apparatus) masks shall be available for fire brigade personnel."
" Service or rated operating life shall be a minimum of one half hour for the self contained units."
"At least a 1 hour supply of breathing air shall be located on the plant site for each self-contained breathing unit."
"In addition, an onsite 6 hour supply of reserve air should be provided and arranged to permit quick and complete replenishment of exhausted supply air
- bottles as they are returned. If compressors are used as a source of breathing air, only units approved for breathing air shall be used and the compressors shall be operable assuming a loss of offsite power."
3 01/28/97 P00*3Ded OdN 01 1833 NDIS30 009dd 140dd CC:8 16. 9 833
~. . - . - . . . -. _ . - .. - - . ~- .. - - -
. * * . GOO *3DOd 16101 **
i PRESENT AP600 SSAR STATEMENT: AP600 SSAR Table 9.5.1-1, Fire Protection Program Compliance with BTP CMEB 9.5-1, Item 33 states in part: i "A breathing air compressor is provided in the compressed and instrument air
- system (CAS) to replenish the exhausted air supply bottles used by the fire brigade."
4 i PRESENT AP600 POSITION: After reviewing the requirements of BTP 9.51 paragraph C.3.c and 10CFR50, App. R, paragraph !!!.H. AP600 considers that we are in compliance with these requirements. I AP600 goes beyond the minimum requirement which specifies "~an onsite 6-hour supply of reserve air should be provided..." and notes that there is ne requirement that t the 6-hour supply of reserve air be located in a place where a fire cannot occur. ' AP600 provides a breathing-air compressor and an air receiver in the turbine building in order to replenish exhausted SCBA air bottles in the event of a fire. This design should be acceptable as it is capable of providing far more ak than the required 6-hour supply. However, in order to minimize concerns relative to a large turbine building fire i damaging the ~6-hour supply of reserve air"(i.e. the breathing-air compressor and an , air receiver), AP600 proposes to utilize the self-contained compressed breathable air bottles stored inside the MCR pressure boundary to provide up to six additional hours ) of breathable air for up to eleven people. - See SSAR 6.4, section 5.4.2 Breathing Apparatus relative to control room habitability. PROPOSED AP600 SSAR STATEMENT: AP600 SSAR Table 9.5.11, Fire Protection Program Compliance with BTP CMER 9.51, item 33 states in part:
"A breathing air compressor and receiver is provided in the compressed and instrument air system (CAS) to replenish the exhausted air supply bottles used by the fire brigade. Additionally, an equivalent 6-hour supply of reserve air will be mainsained in an area located outside of the turbine building. (e.g. the 6-hours of compressed breashalde air bottles stored inside the MCR pressure boundary for up to 11 people.)
1 4 01/28 S 7 S00*3DOd 3dN 01 1d33 NDIS30 009db WOdd PC:8 46. 9 833
WESTINGHOSUE/NRC AP600 MEETING ,
- FIRE PROTECTION
! MARCH 7, 1997 4 1 l i jgg ORGANIZATION ! ' JEFF HOLMES NRR/DSSA/SPLB DIANE JACKSON NRR/DRPM/PDST ~ TAD MARSM* NRR/DSSA/SPLB ' STEVE W ST NRR/DSSA/SPLB ED CUMMINS WESTINGHOUSE j DON HUTCHINGS WESTINGHOUSE ! JIM WINTERS WESTINGHOUSE ARIE G0 BECHTEL/ WESTINGHOUSE { CONSULTANT ' DONALD CHUNG NUS/ MEMBER OF PUBLIC
*PART-TIME 1
1 l l Attachment 6
- m.
= - 412 374 5535 03/20/97 THU 14:16 FAI 413 374 5535 AP600 ..3 ! h Westinghouse FAX COVER SHEET l D l l I l RECIPIENT INFORMATION SENDER INFORMATION l l OATE: /Fletc# 20./997 NAME: %@m i TO: LOCATION: ENERGY CENTER - ! b hE ,_ Ace:as4 EAST l PHONE: FACStMILE: PHONE: Omce gg.y?g T2SO COMPANY: Facsimile: win: 264 4887 (,) f gg ( outside: (412)374 48')7 LOCATION: gpf 4/p gpg i Cover + Pages 1+IQ . The following pages are being sent from the Westinghouse Energy Center, East Tower, Monroeville, PA. If any problems occur during this transmission, please call: WIN: 284 5125 (Janice) or outside: (412)374 5125. COMMENTS: Daar , ke'l9 s.s MfawnAT1w ed 17/E ITP>u wr voor A.s A c71ws FAos ooR 3hh7 M unut.() Men w; M f% Va , ri sasr> , air taiet L -A *in w r 1ws e yo A L ETTE.kt. - - 97mn onK W C MAdf COMALGWO ALL Ar@eM OAl ftd f pe.wr,w f 'i ec: #crundra D M2bb u m inna qIUT194tAJU
/,rusets.ej __
DJ8A/7DfJ
.. Attachment 7
. _- _. .~____.____.._-.___ _ _ _.._ _ _ _. . _ _ _ _ . _ . _ . . _ _ . .
. 03/40/97 THU 14:17 FAI 412 374 ss3s AP600' @ 002 1
01 306. NRC's concerns regarding AP600 safe shutdown capabilities during and/or after a design basis fire. I I 1
- 1. AP600 Compliance with Renulations for Passive ALWRs l l
A. Compliance with BTP CMEB 9.5-1 l l l SSAR Table 9.5.1-1, note the following: Item 16 AP600 uses two levels of damage limits: ssfe shutdown and design basis accidents (in contrast to three in App. R: hot shutdown, cold 1 l shutdown, and DBAs). Safe shutdown capability is protected from ) l damage caused by a single fire. (AP600 " safe shutdown" is deemed equivalent to cold shutdown. In SECY-94 084, it is recognized that Passive ALWR designs are limited by the inherent ability of the . passive heat removal processes. EPRI's position is that safe stable shutdown condition is at 420 'F, and that passive safety systems need not be capable of achieving cold shutdown, based on the belief that the passive decay heat removal systems have inherently high long-term reliability. The NRC Staff position is that an RHR system be able to bring the plant to cold shutdown conditions (with reference to GDC 34 and RG l.139) was established to enable the licensee to perform inspection vi v pir at the plant. The Staff believes that other plant conditions may constitute a safe shuttlown state as long as reactor - suberiticality, decay heat removal, and radioactive materials containment are properly maintained for the long term. The Staff recorrunends that the Commission anorove the EPRTs oroposed 420 dearees F or below, rather than the cold shutdown condition reauired by R_G 1.139. as a safe stable condition which the cassive decay heat removal systems must be canable of achieving and maintainine followinn non-LOCA events. This ; o recommendation is orMicatM on an acceptable osssive safety system performance and I an accentable resolution of the issue of reaulatory treatment of non. safety systems.) The Commission has made determinations on the Staff's recommendations (SECY-94-084) regarding Safe Shutdown Requirements (item C)in the memorandum of June 30,1994 from John C. Hoyle to James M. Taylor. t i l l l
! ,. 03/30/97 11IU 14:17 FAI 412 374 5535 AP600 goos l l Item 25 Safe shutdown systems are protected such that reliance on alternative or dedicated shutdown capability is not necessary (in contrast with App. R allowed Alternative or Dedicated Shutdown). (AP600 safe shutdown capabilities include methods for using safety related systems l only, safety related and nonsafety-related systems, or nonsafety-related systems only. The safe shutdown capabilities using safety related systems are fully protected to ensure that at least one safe shutdown capability is available in the event of a single fire, without taking any credit for repairs or operator actions in the fire affected area, and all equipment within the fire area is rendered inoperable by the fire. AP600 does not rely on an alternative or dedicated shutdown capability.) O O 2 A
03/20/97 T8t' 14:17 FAI 412 374 5535 AP600 3 004 1 .- i 1 1 i B. SECY-90-016 Evolutionary LWR Certification Issues Gan. 12.1990)
- (re iterated in $ECY-93-087) 1 4
- "D. Fire Protection"
- The evolutionary ALWR desinners must ensure that AP600 complies. At least
- safe shutdown can be achieved. assuming that all one of safe shutdown
- eautoment in any one fire area will be rendered capability using safety-l inonerable by the fire and that re-entry into the fire related systems (SSAR area for repairs and onerator actions is not oossible. 7.4.1.1) is available in the The control room is excluded from this acoroach. event of a single fire,
! orovided an indeoendent alternative shutdown without requiring repairs } goability that is physically and electrically or operator actions in the i independent of the control room is included in the fire-affected area. M Evolutionary ALWRs must orovide fire protection for AP600 complies. SS AR i redundant shutdown systems in the reactor containment 9A.3.1.1 provides the i building that will ensure, to the extent cracticable. that FHA and Safe. Shutdown i one shutdown division will be free of fire damane. Analysis. l Addinona11v. the evolutionary ALWK oesteners must AFoVU comphes. hre-
- ensure that smoke. hot eases, or the fire suooressant smoke dampers are
+ will not migrate into other fire areas to the extent that utilized to minimize they could adverselv affect safe shutdown capabilities. migration of the effects of including operator action fire through the shared HVAC. (See attached sketch and respons to 01-323 located elsewhere in this letter.) C. April 26,1990 Staff Letter to the Commission, Re. Evolutionary LWR Certification Issues and Their Relationship to Current Regulatory Requirements "6. Fire Protection"
~ Proposed enhancements that represent a significant AP600 complies. Fire-improvement in physical separation requirements and smoke dampers are in the need to consider the effects of smoke, heat, and utilized to minimize fire suppressant migration into other areas. In migration of the effects of particular, redundant train separation is likely to be the fire through the shared most significant feature leading to reduced fire risk. HVAC.
3 4
. _ _ _ _ . . _ _ - - . _ - .- - - - - ~ - -. -- -
03/20/97 THU 14:18 FAI 412 374 5535 AP600 @ 005 l
~
D. Additionally, in the NRC Request for Additional Information, RAI 280.12, it was stated th'at .........." based on its review of Section 7.4, the staff has detennined that safe shutdown as defir.:d above can be achieved within 36 hours following a fire event using only safety related equipment and can be maintained long term (i.e., beyond 36 hours after it has been achieved) provided: (1) the safety-related passive systems used for safe shutdown perform their intended function; (2) nonsafety-related equipment are available for long-term maintenance of safe. shutdown; and (3) all staffs concerns identified in the following sections are resolved. For the above reasons, consistent with SECY-94-084 (approved by Commission, see SRMs dated June 30,1994 and June 28 1995) position on safe shutdown requirements for passive plant designs, the staff accepts safe shutdown as defined above as a safe stable condition for AP600, subject to an acceptable passive system performance and an acceptable resolution of the issue of regulatory treatment of non-safety systems (RTNSS).
" Response- '
Westinghouse concurs with the definition of safe shutdown presented in this Request for Additional Information." 1 I l l 4
-.- ~-.-. -.. - - -.-.-.-.-. ..~ -. .. ._..--.-....-.~. -- _ -.
03/iO/97 THU 14:18 FAI 418 374 ss3s AP600 @ 006 ! i ! For discussion ourposes unty. the followine AP600 comparison with Ann. R and ! other remaNions/muidelines for LWRs is presented. No renulations reauire such i comparison as Ann. R is not anolicable to AP600. ! i A. AP600 short term safe shutdown capability (to be initiated following a design l ! basis fire-event, when using safety-related systems only) includes maintaining l 1 the reactor subcritical, the reactor coolant average temperature less than or equal to no load temperature, and adequate coolant inventory and core cooling. l 1 The long-term safe shutdown conditions are the same as the short-term safe i shutdown conditions except that the coolant temperature shall be less than i 420 *F. This long-term condition must be achieved (using safety related l- equipment) within 36 hours and maintained indefinitely. (SSAR 7.4) ;
- Based on the above
l l (1) AP600 long-term safe shutdown condition shall be deemed equivalent to cold shutdown discussed in Appendix R of 10CFR50. SECY-94-084 confirms this equivalency. I i l (2) App.R W.G.I.b. " Systems necessary to achieve and maintain cold ! shutdown from either the control room or emergency control station (s)
- can be repaired within 72 hours"is not applicable to AP600.
t l (3) App.R m.G.3 that provides "Altemate or dedicated shutdown
- capability"is also not needed for AP600, because on AP600 none of the j following App.R conditions exist
- a) protection of systems whose
- function is required for hot shutdown does not satisfy the requirement j of III.G.2, and b) where redundant trains of systems required for hot
- shutdown located in the same fire area may be subject to damage from j fire suppression activities or from the rupture or inadvertent operation of
! fu suppression systems. However, the App.R requirement of "In l addition, fu detection and a fixed fire suppression system shall be i installed in the area, room, or zone under consideration" has been
- implemented for AP600 Containment fu area. Fire detectors and
! standpipe and hose coverage are provided. } See also AP600 SSAR Table 9.5.1-1 (Comparison with B'IP CMEB 9.51 Guidelines) Item 25. Remarks: " Safe shutdown systems are protected such that reliance on alternative or dedicated shutdowii , capability is not necessary". j i GL 86-10 that provides interpretations of App. R regarding the l Alternative or Dedicated Shutdown is also not applicable on AP600. l And the interpretation of App. R " free of fire damage" is not applicable, because on AP600, all equipment within the fa area are rendered
~
inoperable by the fire,in compliance vith SECY-90-016. l
.~. - .. - , . - . - _ . - . ~ - _ . - - . _ . . - - - . - - - - . - - - . - -
. 03/40/97 THU 14:19 FAI 412 374 Ss35 AP900 @ 007 i
App.R.T!!.L. detailing the requirements of Altemative and dedicated (4) i shutdown capability provided for a specific fire area is not applicable to AP600 item (3) above confirms that AP600 does not require an l Alternative or dedicated shutdown capability. i B. App.R Fire Damage Limits for hot shutdown safety function is "One train of equipment necessary to achieve hot shutdown from either the control room or j emergency control station (s) must be maintained free of fire damage by a . single fire, including an exposure fire", and for cold shutdown is "Both trains I of equipment necessary to achieve cold shutdown may be damaged by a single fire, including an exposure fire, but damage must be limited so that at least one train can be repaired or made operable within 72 hours using onsite capability".
- AP600 complies with the fire damage limits for hot shutdown safety function,
- and even better for cold shutdown function, because AP600 safe shutdown
- systems (using safety-related systems) are fully protected such that reliance on repairs of fire-damaged equipment within 72 hours is not necessary. See also AP600 SSAR Table 9.5.1-1 (Comparison with BTP CMEB 9.51 Guidelines)
, item 16 Remarks: "AP600 uses two levels of damage limits: safe shutdown 5 and design basis accidents. Safe shutdown capability is protected from damage caused by a single fire." t 4 Also, GL 86-10 that provides interp etations of App. R regarding the allowed I repair of cold shutdown equipment is also not applicable on AP600. i l C. Based on the discussions above, a major fire involving the Turbine Building with its potential consquences of loss of the nonsafety related RHR systems should not be a nuclear safety issue on AP600. It may be4ome a property loss i prevention issue, especially from the plant underwriter's perspective. However, l AP600 turbine building fire protection is consistent with the current industry standards, such as, NFPA 803,804,850 and EPRI NP-4144 (July 1985). l 1 6 4
. 03s20/97 THh14:20FAI4123745535- _ _ _ . AP600 _________._.___________.._...__
i .
@ 008 e
01 314. AP600 Fire Detection and Alarm System $ 1. Compliance with BTP CMEB 9.51 (see SSAR Table 9.5.1 1) I 112. Fire detection systems should be AP600 complies.
, provided for areas that contain or present j a fire exposure to safety-related
- equipment.
113. Fire detection systems should AP600 complies, no exception to Nt PA j comply with the requirements of Class A 70 & 72D is identified. l systems as defined in NFPA 72D and Class I circuits as defined in NFPA 70. I14. Fire detectors should be selected and AP600 complies, no exception to NFPA : installed in accordance with NFPA 72E. 72 is identified. I15. Testing of pulsed line-type heat AP600 complies. detectors should demonstrate that the frequencies used will not affect the actuation of protective relays in other . plant systems. I16. Fire detection systems should give AP600 complies. audible and visual alarm and annunciation in the main control room. l 117. Where zoned detection systems are AP600 complies. used in a given area, local means should { be provided to identify which zone has actuated. { 118. Local audible alarms should sound AP600 complies. in the fire area. I19. Fire alarms should be distinctive and AP600 complies. i unique so they will not be confused with any other plant system alarms. 120. Prunary and secondary power AP600 complies, no exception to NFPA i supplies, which satisfy the provisions of 72D is identified. section 2220 of NFPA 72D, should be provided for the fire detection system and for electrically operated control valves for automatic suppression systems. 7
. e
. 03/20197 THtt 14:20 FAI 412 374 5535 AP600 @ 009
- 2. Disposition of NRC concerns
- 1. Fire detection in safety related areas is AP600 does not intend to have a seismically qualified. seismically qualified fire detection i I
system. There is no requirement to make the fire detection system to withstand design basis earthquake, or to remain 4 functional following a seismic event. However, with microprocessor-based equipment and components the fire
, detection system can be expected to be 4
unaffected by earthquakes, and the i potential of spurious actuation should be minimal. 4 I ! 1 l 1 f a 1 i i i 1 4 5 4 8 8
0340/97 'llitt 14:20 FAI 412 374 5535 AP600 gogo 1 ) i i 01321. AP600 Fire Pumps 1
- 1. Compliance with BTP CMEll 9.51 (see SSAR Table 9.5.1 1) 1 728. A sufficient numter of pumps AP600 complies, one electnc motor- l j should be provided so that 100 percent driven and one diesel-driven fue pump, i capacity will be available assuming 100% capacity each, are provided.
- failure of the largest pump or loss of j offsite power.
i 129. Individual nre pump connections to Areco complies. Fac pump discharge
- the yard fire main loop should be lines are re-arranged so (ney are
- l. separated with sectionalizing valves individual connections to the yard fire ,
j between connections. main, with sectionalizing valves between ' j connections. ! 130. Each pump and its driver and AP600 complies. l controls should be separated from the Each fire pump and its controller are i ! remaining fire pumps by a 3-hour rated located in a room enclosed by 3-hour fire i fire wall. barrier. f 131. The fuel for the diesel fire pump AP600 complies. ! i should be separated so that it does not Fuel oil day tank is in the diesel engine- ! provide a fire source exposing safety- driven fire pump room that is enclosed by l related equipment. 3 hour fire barrier. "Ihe fuel oil storage i tank is located outdoor. 1 { 732. Alamis indicatmg pump running. AP600 complies. l driver availability, failure to start, and Refer to P&ID FPS M6-001. i Iow fire main pressure shoald be provided in the main control room.
- 133. The fire pump installation should AP000 compues. No excepuon to
! conform to NFPA 20. NFPA20 is identified. (See Ta$le 9.5.1-3.) t 4 1 ! 9 i 3 a J
_ ,03620/97 THU 14:81 FAI 412 S74 5535 AP600 goli l i
- 2. Disposition of NRC concerns
- 1. Can the yard fire main be supplied by Yes. The fire pumps can sull supply the the fire pumps if there is fire damage to yard main and the yard main extension the yard main extension inside the can be isolated if it is damaged by the Turbine Building? fire.
2.Will the air intake of the diesel fire No. The fire pump diesel-engine driver pump be affected by the turbine building outside air intake is located at the same fire? side of the building with the other HVAC outside air intakes, remote from the discharge points including smoke relief l through the roof. Additionally, the intake l is located within the envelope of the fire pump fire area. {
- 3. Will the power supply of the electrical Fire pump motor supply is designed and motor driven fire pump survive a fire in routed in conformance with NFPA 20 and the Turbine Building? NFPA 70. .
l Since routing from the non-diesel bus is I less susceptible to a turbine building fire and a diesel back fire pump is not required if a diesel fire pump is installed, the present SSAR 9.5.1.2.3 wording "The motor-driven fire pump is supplied with power from the diesel backed non-Class 1E switchgear", will be revised in SSAR Rev.12 tp indicate the motor-driven fire pump is not <A the plant diesels.
- 4. Are the fire tanks too close to the 4. As nog 3%meenngs with the NKC, Turbine Building? Could they be this is not a licensing issue but an damaged by a turbine building fire? insurance issue. Westinghouse is l presently reviewing its design in this area to determine its insurance liabilites.
10
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g 43/'.'0/97 THU 14:2 Q AI 412 394 5535 AP600 @012 b - i OI.322. AP600 Basis for Selecting NFPA 14, Class II, Standpipe and Hose l; Stations j l BTP 9.5-1 guidelines recommend installation of standpipe and hose stations that meets l the requirements of NFPA 14, however, it does not call for a specific class of standpipe system per NFPA 14 to be provided. NFPA 14 provides three classes for a
- standpipe system based on its intended use (for the manual firefighting efforts), ,
! however, it too does not specify specific applications, buildings or facilities where
]
l such classes of standpipe systems should be provided. ,
; 1 a
i As stated in SSAR 9.5.1.2.1.5, the AP600 fire protection standpipe and hose systems
! are provided for each building, for Class Il service in accordance with NFPA 14, i.e.,
primarily intended for use primarily by the building occupants or by the fire
; department (plant fire brigade) during initial response. Each hose reel or rack contains
- up to 100 ft. of 1-1/2 in. fire hose.
AP600 fire hazard and protection analyses (SSAR section 9A) showed that in the nuclear island the postulated fires are primarily fires involving electrical equipment and cables or ordinary class A combustibles such as paper or trash. There'are no insitu
- flammable liquids or gases expected to be present within the nuclear island. Consistent l with the postulated fire characteristics and manual extinguishing techniques, plus the l AP600 fire areas compartmentalization and configurations, a Class H standpipe with
! l-1/2" hoses is deemed most practical as it can be safely used by the plant fire brigade i without undue damages to nonfire affected facilities and equipment. i In the Turbine Building, recognir.ing that the postulated fires may involve flammable 4 liquids or gases, such as, lubricating fluid, hydraulic fluid, hydrogen, etc., the hose ' i stations are provided with a 2-1/2 in. angle valve. A 2-1/2 to 1-1/2 hose coupling is installed at the hose rack, together with the up to 100 ft. of I-12 in. fire hose. Hence
- the fire brigade has the option to breakaway the hose coupling, ard attached their portable 2-1/2 in hoseline in order to obtain a greater flow rate.
l In either case, the fire brigads can also supplement the interior hosestreams by using the additional 2-1/2 inch hoses that are connected to the nearest hydrant (s), should it i become necessary. 1 i o
.03/20/97 THU 14:23 FAI 412_374 5535 AP600 gog3 ~
01 323. AP600 Protection from Smoke Spread I. Compliance with BTP CME 8 9.51 (see SSAR Table 9.5.1 1)
- 99. Smoke and corTosive gases should be AP600 complies, smoke exhaust outlets discharged directly outside to an area that are located remote from outside air intake will not affect safety-related plant areas. openings to preclude recirculation of smoke into the buildings.
100. To facilitate manual firefighting, AP600 complies, smoke and beat venting separate smoke and heat vents should be capability is provided as described in provided in certain areas. App.9A. Fire Protection Analysis. 101. Release of smoke and gases AP600 compues. containing radioactive materials to the envirorunent should be monitored.
- 2. Compliance with SECY-90-16, Evolutionary LWR Certification issues (Jan.12,1990)
Additionally, the evolutionary ALWR AP600 complies. Fire-smoke dampers are designers must ensure that smoke, hot utilized to minimize migration of the cases. or the fire suooressant will not effects of fire (smoke and hot gases) mirrate into other fire areas to the extent through the shared HVAC ductwork that that they could adverselv affect safe- serves a single train of safety-related l shutdown capabilities. includinc operator equipment rooms (Div. A&C, or ' aq112n_t Div. B&D). i I 12
c'
- 1f3/10/97 _THU 14:22 FAI 412 374 5535 AP600 3 014 1
4 i
- 3. Disposition of NRC concerns 1 .
! 1.. Define the detector to smoke damper Opening and closing of the combination ! logic. fue/ smoke dampers will be controlled by , the fire detection system that comprises
- of area detectors and in duct detectors.
, De area smoke detectors will initiate the. ] closing of the fire / smoke dampers. A high
- temperature override will close the l damper when the in-duct secondary high temperature sensor senses a temperature ,
! higher than the fire damper's fusible link rating.
- 2. Denne the location of smoke detectors Area smoke detectors will be used for l used for damper control. controlling the opening / closing of the
- combination fire / smoke dampers. The
! concept is to close the smoke damper and to isolate the fire-affected room at the i carly stage of the fire, and as soon as i smoke is developed and detected by the j area detector (s), while allowing the { HVAC system to continue running and i providing pressurization of the non. ', affected rooms.
- 3. Descnbe overall smoke control Smoke control logic will be integrated
- philosophy, logic and implementation. with the corresponding HVAC control
- logic.
Upon detection of smoke in a room, that ) room will be immediately isolated by i using the combination fire / smoke 4 dampers. Meanwhile, the HVAC is designed to continue running to serve the other non affected rooms and to provide ambient pressurization that will help confine smoke and hot gases within the fire-affected room. For post fire recovery the fire / smoke damper will be reopened and smoke removal will be accomplished by running the HVAC system in a once-through mode. 13
93/a0/97 TH M 4:23 FAI 412 374 5535 AP600 @ 015 0
- 4. Describe in details the re-opening of Reopening the combination fire / smoke ;
fire and smoke dampers. dampers can be accomplished from a remote location, i.e. from the fire alarm I and control panel (s), However, when the damper is closed due to high temperature, resetting the high temperature sensor needs to be made at the damper.
'Iherefore, on AP600 the damper actuators and controller will be located outside of the fire-affected areas, either in the corridor ceiling or in the mechanical ;
equipment room ; l i I
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