ML20198G304

Notifies That Util Has Not Provided Sufficient Info to Review Fire Protection Program Evaluation Submitted in Amend 38 to Psar.Three Deficient Areas in Proposed Fire Protection Design Listed

ML20198G304
Person / Time
Site:	Satsop
Issue date:	07/18/1977
From:	Tedesco R Office of Nuclear Reactor Regulation
To:	Vassallo D Office of Nuclear Reactor Regulation
References
CON-WNP-1296 NUDOCS 8605290451
Download: ML20198G304 (15)

Text

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_/ JUL 1 8 87 Docket Nos. 50 508 50-509 l MEMORANDUM FOR: D. B. Vassallo, Assistant Director for Light Water Reactors, DPM ,

FROM: R. L. Tedesco, Assistant ' Director for Plant Systems, DSS

SUBJECT:

FIRE PROTECTION QUESTIONS FOR WPPSS NUCLEAR PROJECTS NO. 3 AND N0. 5 Plant Narne: WPPSS Nuclear Projects No. 3 and.5 Licensing Stage: CP Docket Numbers: 50-508/509 Milestone Number: NA Responsible Branen LWR 3 6nd Project Manager: A. Bournia Requested Completion Date: NA '

Review Status: Awaiting Infonnation The Auxiliary Systems Branch has reviewed the WPPSS Nuclear Projects

~ No. 3 and No. 5 Fire Protection Program Evaluation submitted in Amendment No. 38 to the PSAR. Our review was based on the guidelines set forth in Appendix A to Branch Technical Position 9.5-1 "Guldelines for Fire Protection for Huclear Power Plants Docketed Prior to July 1,1976."

The Washington Public Power Supply System has not provided sufficient information to allow us to complete the review. Enclosed is a request for additional information and statements of our positions pertaining to plant fire protection. Our concerns on Administrative Controls, Quality Assurance, and electrical and control systems will be forwarded to you at a later date. , ,

We are particularly concerned with regard to three deficient areas in the proposed WPPSS 3 and 5 fire protection design. We will require resolution of these items before the Construction Permit is issued.

The three major deficient areas are as follows:

Contact:

C. Liang Ext. 27763

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JUL 1 8 577 D. B. Vassallo 2

1. - Fire Barrier Rating - (request no. 9)

The applicant stistes in Amendcent He. 3B that floors, walls and ceilings enclosing separate firs areas will have a fire rating connensurata with or exceeding fire hazards in the area. It is our po:ition that the applicant comit that all floors, w311s, ceilings, and associated penetrations enclostr.g separate safsty related fire areas have a minim 9m fire rating of three hours.

2. Fire Protection System far SSE - (request no. M The applicant indicates ic traendment No. 33 that they take exceptico to the guidelines set forth in our BTP 9.5-1 Appendix A with regard to manual fire protection provision:, following an SSE for equipment r6-quired for plant safe shutdown. It is our position that WPPSS 3 and 5 should meet the guideline 1 in Section E.3(d) of our BTP 9.5-1 Appendix A,

3. Dgel Day Tanks - (request no. 371 The applicant indicates in Amendment No. 33 that the day tanks are sized to 2200 gallons capacity and will be located inside the diesel er>gine rcom. It is our position that the day tank should have a maximum capacity of 1100 gallons and these tanks shoJid be located in a separate enclosure with a mi.nimum fire rating of three hours and protected by an automatic fire suppression system.

YdFJh.m Robert L. Tedesco, Assistant Director for Plant Systems Division of Systems Safety

Enclosure:

As stated cc: S. Hanauer P. Matthens R. Boyd D. Fischer R. Mattson J. Glynn W. Mcdonald W. Butler

0. Parr C. Long .

A. Bournia D. Notley V. Benaroya C. Liang FILE: WPPSS 3 & 5 i - _

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ENCLOSURE Fire Protection Ouestions for Wr>PSS Nuclear Projects Nos. 3 & 5

1. (General)

Your Fire Hazard Analysis (FHA) is deficient in the areas listed be low. Expand the FHA to include the following additional information:

a. Provide a quantitative fire loading and its basis for each plant area described in the FRA.

b. Where an automatic fire suppression system is installed, an analysis should be made to demonstrate that the plant can achieve its safe shutdown during a fire assuming malfunction of the fixed automatic fire suppression system in the area.

2. (Table 9.5-5)

Table 9.5-5 indicates that dry bose stations will serve as primary fire suppression systems for RAB switchgear rooms, new fuel storage area and the spent fuel pool area. Provide additional information to indicate the location of these hose stationsfor the above areas. If these hose stations for the RAB switchgear rooms and the new fuel storage area are lodated outside these areas, wet hose stations should -

be provided. The hose stations for the spent fuel pool area should be the wet type also.

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3. (SectionA.4)

Describe the provisions taken to preveat lightning from initiating fires which could damage safety related equipment. Also describe the provisions which show that the fire protection systems are

' afforded Ifghtning protection.  ;

4. (SectionA.7)

Confirm that the fire protection program for an entire reactor unit will be fully operational prior to initial fuel loading in that . reactor unit.

5. (Section C.1.(a))

You state that redundant systems necessary for safe shutdown are

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separated such that both trains are not subject to the same fire hazard. Identify all the redudant systems necessary for safe shut-down which are separated only by distance. Describe the fire detec-r tion system, the primary and backup suppression system provided for these systems. Provide the results of an analysis to demonstrate that for a postulated fire, including an exposure fire and failure of the primary fire suppression system, that safe shutdown can still be accomplished. 'For any cases where, safe shutdown cannot be assured, describe what additional measures will be taken.

6. (Section D.l.(c))

You state that where cable trays serving redundant trains of safe shutdown equipment are exposed to the same fire hazard, the cables will be separated by fire barriers. Identify the areas where the above situation exists and discuss the fire protection provided for

these areas.

7. (SectionD.l(d))

(RSP)

Your response to Section 0.1(d) of BTP 9.5-1 Appendix A indicates that the thernal insulation, radiation shielding and sound-proofing materials used may be combustible. It is our position that the above materials used for WPPSS 3 & 5 should be non-combustible.

8. (Section D.1.(f))

Identify all safety related cables and wiring installed above sus-pended ceilings. Describe the detection and fire extinguishing system to be provided in those areas.

9. (Section D.1.5 and 15.2.12)

(RSP)

Throughout the fire hazard analysis, reference is made to the fact that floors, walls and ceilingsenclosing separate fire areas will have a fire rating commensurate with or exceeding fire hazards in the area. It is our position tnat you clearly state in the PSAR that all walls, ceilings and associated penetrations enclosing separate safety related fire areas will have a minimum fire rating of three ,

hours.

10. (Section D.1.(5))

Substantiate the fire resistance capacity of the following items by verifying that their construction is in accordance with a particular design that has been fire tested.

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a. rated fire barriers

b. fire barrier penetration seals c., fire stops in cable trays

d. fire dampers / fire doors, as well as how they are installed in the ventilation..ddcts that penetr. ate rated ' fire barriers of safety related areas.

Also identify the desig6, and the test method used and acceptance criteria. _

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11. (Section D.l.(j)

List locations where mechanical piping penetrations through fire i

barriers are anchored at walls. Confirm that these fire barriers test have taken into account the mechanical loading of the pipe.

, 12. (Section D.1.(j)j (RSP)

You state "where ventilation ducts penetrating fire barriers the ducts will be coated with materials having a fire rating equal to that of the barrier; the duct will be considered to be a physical extension of the fire area. Fire dampers will not necessary be provided in'such ducts at the barrier penetrations". This is not acceptable. It is our position that fire dampers should be provided in all duct penetrations through fire barriers. _

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13. (SectionD.2.(b))

List locations, amount and type of flamable gases in relation to any safety related areas or equipment. Include in your fire hazard analysis any flannable gas storage areas that could threaten safety related equipment.

14. (Section D.3.(c))

Provide design criteria and bases used in providing automatic sprinklers for congested runs of cable trays including cable densities, spacing, arrangement, amount of cable and divisional separation.

15. (Section D.3.(J)

Identify'any cables which will be installed in floor trenches or culverts in the control room and describe the protection provided in these areas.

16. (Section D.4.(a))

Discuss the operating mode of the ventilation system used for smoke removal in the fire areas addressed in your fire hazard analysis.

Include in your discussion, a) the equipment used, b) operator actions required for this operation, c) the control excess to the equipment and d) the ability of the equipment to handle high temperatures gases and particles.

17. (SectionD.4(d)) -

Confirm that the air circulating system for charcoal filters will meet the single failure criteria per Regulatory Guide 1.52. Also confirm that there will be no exposure fire hazards that could ignite the charcoal filters.

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18. (Section D.4.(h))

(RSP)

Your response to Section D.4.[h) of BTP 9.5-1 Appendix A is not acceptable. It is our position that at least two extra air bottles should be located onsite for each self-contained breathing unit.

In addition, an onsite 6-hour supply of reserve air per breathing unit or compressors should be provided and arranged to permit quick and complete replen'shment of exhausted supply air bottles as they are returned. Modify your design to meet the above position.

19. (Section D.5)

(RSP)

Your response to Section D.5 of BTP 9.5-1 appendix A is not acceptable.

It is our position that fixed self-contained lighting, consisting of fluorescent or sealed beam units with individual 8-hour minimum .

battery power supplies should be provided in areas which must be manned for safe shutdown and for access and egress routes to all fire areas. Safe shutdown areas include those required to be manned if the control room must be evacuated. Also, a portable radio communications systems should be provided for use by the fire brigade and other operations personnel required to achieve safe plant shutdown.

20. (Secti,onE.1)

Verify that the fire alarm system which is designed according to NFPA 72-D is a class A system with Class I circuits per National .

Electrical Code.

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21. (Section E.1(b))

Clarify your response to Section E.l(b)'of BTP 9.5-1 Appendix A to confirm that the fire detection systems will give annunciation in addition' to audible and visual alarm in the control room.

$2. (Section E.2.(b))

Verify that the fire pumps and their associated controllers will be U.L. and/or F.M. approved per NFPA-20. Also confirm that individual trouble alams will be provided for each fire pump in.

the control room.

23. (Section E.2(e))

Clarify your response to section E.2.(e) of BTP 9.5-1 Appendix A to confim that the fire water supply of 300,000 gallor.s per tank is greater than the demands of three hose streams plus all sprinkler heads opened within the largest fire area irrespective of whether the sprinkler system is hydraulically designed or not.

24. (Section E.3.(a))

Identify safety related areas where hydraulically calculated ,

automatic sprinkler systemsare used. Provide a discussion of the criteria and bases to determine the density and spacing of equipment.'

25. (Section E.3.(b)) .

Confirm that all fire protection system control and divisional 2

valves provided with monitor switches are connected to electrically supervised circuits.

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26. (Section E.3.(d))

Confirm that the placement of hose stations in the safety related areas will reach any location with one effective hose stream, consideration should be given to situations where the access to a single hose station may be blocked by a fire; in such cases an alternative hose station should be provided.

27. (Section E.3.(d)) ,

Verify that your hose and sprinkler standpipe design criteria will provide for an alann in the control room when there is flow in a standpipe per NFPA 14.

28. (SectionE.3.(d))

Justify that 3-inch diameter standpipes rather than 4-inch diameter standpipes as stated in BTP 9.5-1 appendix A are of sufficient size to supply the necessary flows.

29. (Section E.3.(d))

(RSP)

Your response to Section E.3.(d) of BTP 9.5-1 Appendix A is not acceptable. It is our position that provisions be made to supply water at least to standpipes and hose connections for manual fire fighting following an SSE in areas within hose reach of equipment required for safe shutdown. The standpipe system serving such hose stations should be analyzed for SSE loading and should be provided with supports to assure system pressure integrity. The piping and valves for the portion of hose standpipe system af.~ected by this functional requirement should at least satisfy ANSI Standard l

B 31.1, " Power Piping". The water supply for this condition should l

I be obtained from a normal seismic Category I water system.

30. (Section F.1, Figure 9.5-la) l Your fire protection design criteria and bases for the areas inside primary containment do not meet our guidelines. . Submit a fire hazard' analysis for the areas inside containment. Analyze the con-sequences of a fire due to an oil leak in reactor coolant pumps or a fire in safety related cables inside containment in your FHA. Figure 9.5-la indicates a single fire water line penetrates containment and supply water for hose stations inside containment. Confirm that sufficient water for fire protection inside the containment can be supplied though the single line assuning a moderate pipe leak on the line; also confirm that the piping penetrating containment boundary upto and including the isolation valves will be designed to quality group B and seismic Category I requirements.

31. (Section F.2)

(RSP)

You state that only portable Halon extinguishers are provided inside the control room. It is our position that Class A hand portable fire extinguishers be provided in accordance with NFPA 10, to provide the ability to extinguish small deep seated fires inside the control room.

32. (Section F.2)

Identify those safey related control room cabinets that contain cables from both divisions. Provide results of an analysis of the consequences of a fire in each cabinet. The analysis should take

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. 1 into account the damage to wiring and instrumentation in adjoining safety related cabinets due to heat and corrosive vapors. Describe i

any additional measures necessary to assure plant safe shutdown under the above conditions. ,

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33. (Section F.3) ,

Confinn that location of sprinhler heads or spray nozzles 'inside the cable spreading rooms will be arranged considering cable tray sizing and arrangments to assure adequate water coverage for electrically initiated fires and/or exposure fires.

34. (Section F.4) -

Identify the location of plant computer room relative to control room and other safety related areas. Describe the fire protection measures provided to prevent fire and smoke damage to safety related equipment.

35. (Section F.5)

In your response to Section F.5 of BTp 9.5-1 Appendix A, you indicate' that cabling passing through the switchgear rooms serving the UHS dry cooling towers will be minimized. Describe the type and quanti.ty of cabling passing through the UbS switchgear rooms. Confirm that the automatic Halon fire protection system provided in this area is adequate for the type of fire hazard present.

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36. (SectionF.8)

In the event of a fire in the turbine building which might cause the turbine butiding roof to collapse, demonstrate that safe shut-down can be accomplished.

. 37. (Section F.9)

(RSP)

Your response to Section F.9 of BTP 9.5-1 Appendix A is not acceptable.

It is our position that the day tanks should be a maximum capacity of '

1100 gallons and located in the diesel generator area under the following conditions: (a) the day tank should be located in a separate enclosure, with a minimum fire rating of three hours, including doors and penetrations. The enclosure should be ventilated to avoid accumulation of oil fumes, (b) the enclosure should be protected by automatic fire suppression systems such as AFFF or sprinklers.

38. (Section F.11)

(RSP)

Your design criteria for fire protection in safety related pump areas deviate from the guidelines in BTP 9.5-1 Appendix A. It is our position that you modify your design to meet these Appendix A guide-lines in providing fire barriers with minimum three-hour rating around each safety related pump and automatic sprinklers inside each safety related pump room. Otherwise, detailed analyses should be provided to demonstrate that without protection of fire barriers and auto- _

matic sprinklers, a postulated internal or exposure fire in a safety related pump area will not impair capability of plant safe shutdown.

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39. (Section F.12, F.13)

(RSP)

You state that fire detectors will not be provided in new fuel area and spent fuel pool area. This is not acceptable. It is our position that you provide automatic fire detection in the new fuel area and spent fuel pool area. The automatic fire detection should alarm and annunciate in the control room and alarm locally.

40. (Section F.14)

(RSP)

Your fire hazard analysis does not demonstrate that the radwaste.

equipment located in the reactor auxiliary building is not in need of fire resistive construction and automatic fire ~ detection. It is our position that you modify the design to the radwaste building from other areas of the plant by fire barriers having at least three-hour ratings and provide automatic fire detection in the radwaste building to alarm and annunciate in the control room and alarm locally.

41. (Section F.15)

Your responses to section F.15 of BTP 9.5-1 Appendix A is not complete.

Provide additional information to demonstrate that WPPSS 3 and 5 meet the Appendix A guidelines in the decontamination areas.

42. (SectionG.3) ,

Confirm that hazardous chemicals will not be stored in areas containing or exposed to safety related equipment.

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43. (Section 15.2.12.2.f)

You indicate in Section 15.2.12.2.f of the PSAR that the electrical penetration area has no fire barrier to separate the areas housing redundant trains of equipment. The protection of redundant trains will be dependent on the 40-foot space separation. Since a 40- foot distance is very marginal for adequate protection from an exposure fire in the area, we require that you provide additional measures in this area to assure that a common exposure fire will not damage both redundant trains of safety related equipment inside the electrical penetration area.

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