ML20205N975
| ML20205N975 | |
| Person / Time | |
|---|---|
| Site: | Byron, Braidwood, 05000000 |
| Issue date: | 10/13/1988 |
| From: | Grimsley D NRC |
| To: | Murphy M AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML20204J149 | List: |
| References | |
| FOIA-88-344, RTR-NUREG-0800, RTR-NUREG-0876, RTR-NUREG-1097, RTR-NUREG-800, RTR-NUREG-876 NUDOCS 8811070165 | |
| Download: ML20205N975 (6) | |
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Dast INFORMATION ACT (FOIA) REQUEST OCT 131988
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No ado,teral agency exosos sob ect to IP4 feowest have toen located Agency records ~. sect to ee 'comt that s'e centded e Acp/4s - $
are a9eads a adabe fo' OutAC especton and copyng e the NRC PWC Documeat Room ggStyt. N W. Washeg'oa. DC Ageacy 'eco*39 swbeect to *e 'ehest t* *t a*e dentded se Ac$e*4s. h_Y
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The nonewoo+4*ary.e s.on of t*e c+occWsi t"at vow ag*eed to accect sa e 'etephone conve<saten note a moetee of m staM e con te.ag mase s.adatdo for pwbhc irecec'oe '
and coveg et the NRC Pwt4 Dot.,rrent Room 1717 H Street. N W WasNegiom DC. e a 80ce' unde' the 80iA vca* and eoweste' man Enclosed e eformatom on how vowmay ot.tae access to and the (Pa ges for correg records placed in tre NRC Pwtec Qocumeat Rg
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PART 18 A-INFORMAtl0N WITHHILD FROM PUBLIC DISCLOSURt Costam efo<maton e the 'ecws ad exceda e beg *4thhe64 hom outu 6,wiess,e pwisweat to ee FOI A esempices deMrted e 46d for me teasoes stated e Pad N. sec-t ses S. C, and D Aey rreased portens of tFa documeets 90' #sch only part of t*e record 4 beeg withheid are tog maJW evadetde for putAC especten and copy *9 m w see th s FOt A n meen and eeowes'ee name g
the NRC PwtSc Cocwmeet ecom.1717 M St*eet. N W Washegton, DC e a towee e
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0811070165 001013 PDR FOIA MURPHYes-344 PDR
'e 0CT 1 s 1988 NIEEDOM CF INFO MATION ACT RESPONSE FOtA PsuMBERIS): Fole - Fb3W DAf t:
PART H 0- APPtlCABLE FOIA ExtMPitONS Records subpect to the request that are described in the enclosed Appendices _1 are being witNield in their entirety or in part under FOIA Esemptions and for the ressora set forth below pursuant to 5 U.S.C. 552(b) ar.d 10 CFR 9 $(s) of NRC Regulations.
- 1. The withheld information is propeW cfass. fed pursuant to Executive Order 12356 (DEMPTON 1)
- 2. The witnheid informate relates solely to the infomal personne4 rules and procedures of NRC. 4EXIVPTON 21
- 3. The wthheld information is specifcaey esempted from putAc declosure by statute inecated: (DEMPTON 31 Secte 141 145 of the Atomic Energy Act which prohents the declosure of Restncted Data.or Formerfy Restricted Data 142 U.S.C. 216121861.
Secten 147 of the Atomic Energy Act which prohtets the declosure of Unclassefed Safeguards Informaton 142 U.S C. 2167L
- 4. The wethheld information is a trade sec et ce commercial or fnencel eformaton that is becg mthheld for the reason (s) indicated: (ExtMPTON di I
The eformaton is conedered to be conf 4 ental buseess (proccetary) informaton.
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The mformaton is consadered to be propretary information pursuant to 10 CFR 2 7XhdH1).
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The informaton was submitted and receesed in conf 4ence from a fore.gn source pursuant to 10 CFR 2 790tdit21.
- 6. The withheld informate conersts of interagency or etraegency records that are not avalable through 4 scosery dunng htgaton. Osciosure of predecoonal eformaten would tend to inh 4dt the open and frere enchange of esas essental to the delteratswo process. More records are wthheid m toew entrety, the facts are mestricatar intertwred with the piedec.senal esformaton. There also are no reasonabit segregable f actual portens towse the release of the f acts would permet an inetect inquiry mto the predecessonal procesa of the egency. ItxtMPilON na I'
- 4. The withheld information e esempted f*om pwtAc declosure because sts declosvre would result m a cleady uPwarranted irwasson of personal prisscy. (DEMPTCN 6)
- 7. The wthheld informaton consists of investgatory records comp 3ed for law enforcement purposes and a teeg wittfeld for the reasorWst int sted. (DEMPTCN 71 Omelosure would interfere wth an enforcement proceedeg becawse d could reveal the scope. detecten, and focus of enforcernent eNotts. td thus could po6s.tify allow them to take acten to shead potentel wongdoeg or a W) late of NRC reowrements frem ewestgators (DEVPTCN 7t i Doctosure *owld coretetute an uewarranted insason of personal ornracy (DEMPTCN 7tCH l
The informaton consests of names of ed@ets and other rformaten the disclosvre of wNch woJd reveal deatstes of conf 4eetel sources. IDEMPTCN 7tOH PART 11 C.DENylNG OFFICIALS Pursuant to 10 CFR 9 9 and'or 9 t$ of tN U S. Nucient RegVatory Cemea on regwtatons, it has teen de+ermened N1 the eformaten wthNed is esecr# frwn production or escicev e.
r and that ses prodveten or declosure is contrary to N putec eterest. The persons resoorsese for the dener are those oews dentifed te+ow as derwg oMoe:s and *te D<ector.
Omsen of Rwies and Records. OMce of Adme.stration, for any den ais that may be appeased to the Enecutnre 0<ector for Operatoes'f oot DENYlNG OFFICJAL TITLE _OF FICE RECORD $ CEN-E0 APPELLAf t CFFiciAL h
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PART fl D-APPEAL R10 HTS _
We denial by each deaying official 6 dent <f.ed hi Part II.C may be appealed to the Appellate Off.cial ident, fed in that section. Any such appeal must be in writeg and must be rnade within 'O days of recespt of thes recponse. Appeals must be addressed as approprme to the Execuths Directot for Operations or to the Secretary of me Commission, U.S. Nuclear Regulatory Comrmssion, Washegton, DC 20566, and shou d clearty state on the envelope and in the letter a
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that it is an "Appeat from en initial FOIA Decison.
senc Foaw ass iPen r>
U.S. NUCLEAR REGULATORY COMMISSION c **
FOlA RESPONSE CONTINUATION 1
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F0! A-88-344
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APPEN0lX G
RECORDS MAINTAINED AMONG PDR FILES NUMBER DATE DESCRIPTION 1.
10-24-85 Memo from Martin Malsch to Chairman Palladino, Re:
Fire Area Boundaries.
(21 pages).
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4 Accession number 8606300366.
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FOIA 68-344 APPEN0!X H RECORDS MAINTAINED IN TK POR UNDER THE ABOVE REQUEST NUMBER NUMBER DA1E DESCRIPTION 1.
09/29/82 Memo W. V. Johnston to T. Novak re: Open Items in the Byron Station Safety Evaluation Report w/ enclosures 3
a.
Sunnary of Deviations from CMEB 9.5-1 in the Byron Fire Protection Program b.
Chemical Engineering Branch / Fire Protection Section Sunnary of Staff Requirements to Resolve Open items (7 pages) 2.
06/20/83 Memo W. V. Johnston to T. Novak re:
Fire Protection Draf t Safety Evaluation Report Braidwood Station, Units 1 & 2 w/ Chemical Engineering Branch / Fire ProtectionSection(20pages) 3.
07/26/83 Memo D. Xubicki to V. Benaroya re: Trip Report:
Fire Protection Site Audit - Byron Station, Unit I and 2, w/ Chemical Eng)ineering Branch / Fire Protection Section (11 pages 4.
10/31/83 Memo R. L. Ferguson to W. V. Johnston re: Potential Licensing Problems - Byron Station, Units 1 and 2 (2 pages) 5.
11/07/83 Ltr L. 01shan to Ceco re:
Summary of Meeting on Byron Fire Protection Program w/ Fire Protection Meeting Attendees (4 pages) 6.
03/22/84 Ltr B. J. Youngblood to D. L. Farrar re: Request for Additional Information - Fire Protection and Masonry Walls w/Pequest for Additional Information (4 pages) 7.
05/29/84 Memo from S.L. Trubatch to multiple addressees, subject:
n idance For imolementation Of Fire protection Reauirements u
For operatinn Deactors,10 C.r.P. 50, Aerendix R.
(7 pres).
10/19/84 T.
Memo W. Y. Johnstoh to T. H. Novak re: Fire Protection Supplemental Safety Evaluation Re Units 1 and 2 w/ report (26 pages) port - Byron Station,
Re:
FOI A.88-344 APPENDIX H
RECORDS MAINTAINED IN THE POR UNDER THE ABOVE REQUEST NUMBER NUMBER DATE DESCRIPTION 10/25/84 Memo W. V. Johnston to T. M. Novak re:
Fire Protection 9*
Supplemental Safety Evaluation Report - Byron Station, Units 1 and 2 w/ attachments a.
10/17/84 memo L. S. Rubenstein to W. V. Johnston re: Supplemental Safety Evaluation Report input for SRP Section 9.5.1, Positions C.S.b and C.S.c -
Byron Station, Unit I b.
Report (9pages) 10.
11/26/84 Memo 0. G. Eisenhut to R. L. Spessard re: Response to Request for NRR Assistance Regarding Byron Fire Protection Issues (TIA 84-31) (1 page) 02/08/85 Memo W. V. Johnston to T. M. Novak re:
Fire Protection Ij-Supplemental Safety Evaluation Report - Byron Station, Unit I w/ attachments a.
Report b.
Byron Fire Protection License Condition c.
Byron 1 input to SALP (7 pages) 1 l
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Re: F0IA. 88-344-APPENDIX I
RECORDS TOTALLY WITHHELD NUMBER DATE DESCRIPTION & EXEMPTION i
1.
10-9 Memo from 5. Trubatch to multiple addressees, subject: Nuclear Utility Fire Protection Groups Coments On Proposed Interpretation Of Fire Protection Requirements in 10 CFR, Part 50, Appendix R.
(6 pages).
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MEMORANDUM FOR:
Thorcs Novak, Assistant Director kM ink for Licensing 3
ritt,gy Division of Licensing it l
FROM:
William V. Johnston, Assistant Director M^"7 Materials & Qualifications Engineering W' ' ' O Division of Engineering
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SUBJECT:
OPEN ITEMS IN THE BYRON STATION
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SAFETY EVALUATION REPORT Plant Name:
Byron Station Units 1 and 2 A,c_ -
Docket Hos.:
50-454/455
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Responsible Branch:
LB#1 Project Manager:
S. Chestnut Q~
Chemical Eng w ering Branch Reviewer:
D. J. Kubicki Requested Completion Date:
ASAP Review Status:
7 open items Our Byron Safety Evaluation Report identified 7 open items pertaining
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Since we issued the SER, we made several attempts, to fire protection.
including a meeting and telephone conversations, to resolve these issues. The following is the current status of the open itams.
1.
VI.B Safe Shutdown capabil_ity.
The licensee's safe shutdown 14, 1982 and answers to staff questions are report of June under review. We will report on this item in an upcoming SSER.
2.
VI.C Alternate Shutdown Capability.
Per item 1, we will report on this issue in an upcoming 55ER.
VI.D Control of Combustibles._ The applicant has not agreed to
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3.
conform to Section C.5 d(2) of BTP CHEB 9.5-1 as it relates to the routing of hydrogen piping.
Primary Containment._ By letter dated May 5, 1982, the VIII.A 4.
applicant submitted additional information concerning the needWe for an oil collection system for the reactor coolant pumps.
We asked the will report on this item in an upcoming SSER.
appllCant to provide us With the cost of installing the ColleC-tion system at Zion and to provide us with the exposure of changingthemechanIcalsealbeforeandaftertheoilcollection system was installed.
Lighting and Comunication. The applicant has not agreed VI.G 5.
to protect the radio repeaters from fire damage in accordance with Section C.S.g of BTP CHEB 9.5-1 and has not provided justi-fication for a deviation from the guidelines, g
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Thomas Novak 2
e VIII.C Cable Spreadino Room. The applicant has not agreed to 6.
provide a fixed, water-based fire suppression system in accord-ance with Section C.7.c of BTP CHEB 9.5-1 and has not provided sufficient justification for a deviation from the guidelines.
7.
IX.
Summary of Deviations from CHEB 9.5-1.
The applicant has not committed o meeting the guidelines of BTP CMEB 9.5-1 and has not justified these deviations.
Our consultant, Gege-Babcock and Associates, (GBA) as part of their review, identified a number of. deviations from BTP CMEB 9.5-1.
These deviations were the subject of a conference call with the licensee on Septer.ber 8, 1982.
The licensee stated that several of these deviations.were adequately addressed or eliminated in the revi: ion to the Byron /Braidwood Fire Protection Report, dated August 16, 1982 which we received after the telephone conference was scheduled.
This information is under review and vill be reported on in an upcoming SSER.
The licensee verbally committed to study further the remaining deviations identified by GBA and to provide additional information at a later date.
These deviations are listed in Enclosure 1.
In light of the amount of time already expended without successful resolution of the open items, we suggest that a meeting be arranged with the appropriate representatives of the applicant to resolve The applicant should be informed of the need to the open issues.
conform with the guidelines of BTP CHEB 9.5-1, and to identify and justify devistions. contains a summary of our position with regard to the fire protection for these areas.
W L }on, &~.
6 Assistant Director William V. John Materials & Qualifications Engineering Division of Engineering
Contact:
D. J. Kubicki X24564 cc:. R. Vollmer S. Pawlicki D. Eisenhut T. Sullivan V. Benaroya J. Taylor A. Schwencer D. Kubicki F.' Rosa S. Ebneter, Region I
- 0. Parr T. Conlon, Region II j
M. Srinivasan C. Norelius, Region III v R. Ferguson G. Madsen, Region V
- 5. Chestnut P. Sternberg, Region V K. Kiper R. Barnes (Gage-Babcock) e----
Enc 1csure 1 Summary cf Deviations from CMES 9.5-1 In the Byron Fire Protection Program Our consultant, Gage-Babcock and Associates, identified a number of deviations from CHEB 9.5-1 in the Byron fire protection program.
Thase deviations were the subject of a conference call between the; applicant and the staff on September 8, 1982.
The applicant stated that several of the deviations were addressed or eliminated in the revision to the Byron /Braidwood Fire Protection Report dated August 16, 1982, which was received after the telephone conference had been scheduled.
We are reviewing this information and will report on them in an upcoming SSEk.
The applicant verbally committed to study further the remaining deviations, listed below, and provide us with addi-tional inforsation at a later date:
1.
The applicant's :ubmittals do not indicate if any self-contained positive press 1re air masks are reserved only for fire brigade use as stipulated by Section C.3 of CHES 9.5-1.
In addition, the applicant has not committed to provide an on-site, 6-hour supply of reserve air and extra air bottles for fire brigade breathing apparatus.
Fire pump alarms indicating pump running and driser availability 2.
are provided in the control room for the motor-driven fire pump.
The diesel fire pump alares for these conditions indicate only as a trouble alarm in the control room.
"Failure to start" alanas not provided as stipulated by Section C.6.a of CHEB 9.5-1.
Separate alarms should be provided in the control room to indicate pump running, driver aeailability and failure to start for each pump.
In addition, low fire main pressure should also be alarsed in the control room.
,. 7....
y The applicant has not supplied sufficient information to provide 3.
reasonable assurance of the reliability of the fire protection water supply (Section C.6.b).
Specifically, the applicant proposes to use the bcsin of the cooling tower as a source of water for fire protection. We need to know if the required quantity of water (336,000 gallons) will always be available from the basin during all modes of plant operation.
The valve arrangement at the fire pumps is such as to prevent pumping capability by the diesel pump during testing of the motor driven pump.
This must be changed to assure that one pump is available at all times to supply the required fire flow.
The applicant has provided cross-connections between the fire protection and ESW systems to provide water to stanc' pipe hose stations in the event of a SSE.
The applicant needs to verify that the ESW system can supply at least the two most hydrauli-In cally remote hose stations with adequcte flow and pressure.
addition, check valves should be provided in the cross-connections to prevent using fire protection water for any other purpose.
i The design of the standpipe system does not conform to Section 4.
C.6.c of CHEB 9.5-1.
Specifically, the following plant areas are not providet with adequate hose stream protection:
Zc3e 3.1-1, Unit 1 Electrical Cable Tunnel d
Zone 3.4A-1, Unit 1 Cable Riser Area Zone 4.1-1, Unit 1 Computer Room Zone 9.2-1, Diesel Generator Room 1A Zone 9.4-1, Diesel Generator Day Tank Room IB Zone 10.1-1, Diesel Fuel Oil Storage Room IB Z'me 10.2-1, Diesel Fuel Oil Storage Room 1A Zone 11.6A-0, Laboratory HVAC Equipment Roon P
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In addition, lengthy runs of 1 inch pipe will be used to supply select hose stations.
Hydraulic calculation will have to be provided to verify that an adequate quantity of water at sufficient pressure will be available at the hose nozzles.
5.
The applicant has not committed to provide water-type portable l
fire extinguishers for the control room in conformance with l
Section C.7.b of CHEB 9.5-1.
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6.
The applicant has not committed to provide smoke detectors in all panels (including unventilated panels) in the control room l
that contain safe shutdown related circuitry (Section C.7.b) 7.
The applicant has not connitted to provide curbs at the entrance to each diesel generator room in conformance with Sc. tion C.7.j of CME 8 9.5-1.
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Chemical Engineering Branch / Fire Protection Section Summary of Staff Requirements to Resolve Open Items Byron Station Units 1 & 2 Docket Nos. 50-454/455 VI.G Lichting and Communication In the Fire Protection SER, our concern was that the two repeaters for the portable radio communications units are exposed to fire damage, which would result in the loss of the emergency communication system.
The two repeaters are located adjacent to one another on the roof of the instrument shop, on the turbine floor adjacent to the control room.
Fire protection for this area I
consists of portable fire extinguishers and manual hose stations.
This protection is insufficient to preclude loss of both repeaters due to a single fire and does not conform with Section C.5.g of BTP CHEB 9.5-1.
To conform to this guideline, the applicant should either provide a fixed, automatic fire suppression system to prevent a fire from eff erting both repeaters or should separate the repeaters a
i by means of an ac eptable five 'arrier or relocate one repeater to c
another fire area.
i VIII.C Cable Spreading Roy In the SER, our concern was that the protection for the cable i
spreading rooms was insufficient to prevent fire damage.
The f
j applicant has proposed gaseous fire suppression systems to protect these areas. The protection alone is insufficient to provide reasonable assurance that no fire damage will occur and does not j
conform with Section C.7.c of BTP CHEB 9.5-1 which stipulates l
that in the primary fire suppression system in cable spreading rooms be a water-based system.
A water based system offers the advantages of being: proven effective, less complicated in design, j
more dependable, able to discharge the fire suppression agent cont-inuously and for long periods of time.
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A gaseous fire suppression system is less effective on cable fires; more complex in design and more prone to failure; is subject to the inability to maintain the design concentration of gas by virture of unprotected room openings; and has a limited, finite amount of fire surpressing agent.
To conform to the above guideline, the applicant should provide either an automatic water system such as closed-head sprinklers, open-head deluge system, or a directional water spray system, o=
the opplicant should provide a canually activ&ted water suppression system as a supplement to the proposed gaseous fire suppression systems.
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JUN 2 01983 x,y vi crw se D6 4L
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MEMORANDUM FOR:
Thomas Novak, Assistant Director O'
Fiti fg f
for Licensing 1
3 Division of Licensing 4,
FROM:
William V. Johnston, Assistant Director p
Materials, Chemical & Environmental Technology A% ~v Division of Engineering
SUBJECT:
FIRE PROTECTION DRAFT SAFETY EVALUATION REPORT-liRAIDWOOD STATION. UNITS 1 & 2 Plant Name:
Braidwood Stations Units 1 and 2 Docket Numbers:
50-456/457 Licensing Stage:
OL Responsible Branch:
LB #1 Project manager:
J. Stevens CHEB Reviewer:
D. Kubicki Requested Completion Date: June 15, 1983 Review Status:
Hine Open Items Enclosed is the Fire Protection Draft Safety Evaluation Report.
The Chemical Engineering Branch reviewed the Fire Protection Program for conformance with NUREG-0800, Standard Review Plan, Section 9.5-1, dated July 1981.
This document incorporates the guidelines of BTP ASB 9.5-1 and Appendix R to 10 CFR 50.
The applicant has compared his program to both NUREG-0800 and Appendix R to 10 CFR 50.
Since Braidwood Station is identical to Bryon Station Units 1 & 2, except where noted, our DSER conforms with the Byron SER (NUREG-0876) and references specific sections of NUREG 08/6 were our evaluation of the respective fire protection programs
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is the same.
We have not yet made a fire protection review site visit because the construction of the plant'has not progressed to the point where such a visit would be' meaningful. We expect to have our site visit when approximately 90% of the cable has been installed in the plant.
We have the following open items:
1.
Fire stop/ penetration seal material (Section 9.5.1.4) 2.
Fire protection for redundant shutdown divisions (Section 9.5.1.'4)
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Alternate shutdown capability (Section 9.5.1.4) 4.
Routing of hydrogen lines (Section 9.5.1.4) 5.
Lighting and communication (Section 9.5.1.4) 6.
Fire detectors in safety related areas (Section 9.5.1.4) 7.
Supervision of fire detection circuits (Section 9.5.1.4) 8.
Oil collection system for reactor coolant pump (Seccion 9.5.1.5) 9.
Sprinklers in the cable spreading rooms (Section 9.5.1.5)
Fozn.tt 3W JUN 23 $83 I
S'3d?@Sp 3 9 9 " M A" Xk
,w Thomas Novak -
Several areas of the fire protection program are being reviewed by other branches and will be reported in other sections of the SER, as follows:
Branch Item Section '
EPLB Offsite Emergency Planning 13.3 LQB Fire Brigade Training Program 13.22 LQB Fire Protection Organization 13.1 LQB Fire Protection Plant Procedures 13.5 QAB Fire Protection QA Program 17.0 LQB Technical Specifications 16.0 This report includes the evaluation of Safe Shutdown Capability and Alternate Shutdown Capability from ASB.
Our consultant, Gage Babcock & Associates participated in the preparation of this DSER.
William V. Johnston, Assistant Director Materials, Chemical & Environmental Technology Division of Engineering
Contact:
D. J. Kubicki X27743
Enclosure:
As stated cc:
R. Vollmer J. Youngblood
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D. Eisenhut J. Stevens W. Johnston L. 01shan V. Benaroya F. Rosa
" R. Ferguson M. Srinivasan T.,Wambach R. Eberly S. Pawlicki T. Sullivan
- 0. Farr V. Panciera J. Taylor J. Stang D. Kubicki F. Nolan S. Ebneter, Region I T. Conlon, Region II C. Morelius, Region III G. Madsen, Region IV P. Sternberg, Region V
t Chemical Engineering Branch / Fire Protection Section i
Fire Protection. Review Braidwood Station Units 1 and 2 Docket Nos. 50-456/457 9.5 Other Auxiliary Systems r
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9.5.1 Fire Protection Program t
c 9.5.1.1 General 1
The staff has reviewed the fire protection program for conformance with SRP Section 9.5-1, Fire Protection.
The SRP contains, in BTP CMEB 9.5-1, l
the technical requirements of Appendix A to BTP AS8 9.5-1 and Appendix R f
i to 10 CFR 50.
j The applicant's Fire Protection Report, transmitted by letter dated l
j April'31, 1977, was in response to the staff's request that he evaluate l
his fire protection program against the guidelines of Appendix A to BTP l
AS8 9.5-1, "Guidelines for Fire Protection for Nuclear Power Plarits.
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By letter dated August 16, 1982, the applicant revised the Fire Protection f
f Report to include an evaluation against the guidelines of SRP 9.5-1 and the requirements of Appendix R to 10 CFR 50.
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l As part of its review, the staff will visit the plant site to examine the t
relationship of safety-related components, systems, and structures in l
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specific plant areas to both combustible materials and to associated j
fire detection and suppression systems.
j The staff review included an evaluation of the automatic and manually J
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operated water and gas' fire suppression systems, the fire detection f
j systems, fire barriers, fire doors and dampers, fire protection admini-l strative controls, and the fire brigade Tize and training.
Theobjective of this review is to ensure that in the event of a fire, personnel and l
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plant equipment would be adequate to safely shut down the reactor, to maintain the plant in a safe shutdown condition, and to minimize the release of radioa'ctive material to the environment.
Because Units 1 and 2 a're of the same design except as noted, the comments made in this report apply to both units.
9.5.1.2 Fire Protection Program Requirements Fire Protection Program The fire protection program establishes policy for the protection cf structures, systems and components important to safety.
By letter dated August 16, 1982, the applicant has committed to conform to the technical requirements for fire protection program in Appendix R to 10 CFR 50, Section II.A (BTP CNEB 9.5-1, Section C.1).
The staff finds that, with 4
this commitment, the fire protection program meets the guidelines of BTP CMEB 9.5-1, Section C.1, and is, therefore, acceptable.
Fire Hazard Analysis The applicant provided a fire hazard analysis with the Fire Protection Report.
The analyses specified the combustible materials present in fire areas, identified safety 'related equipment, determined the consequences of a fire on safe shutdown capability, and summarized available fire protection in accordance with BTP CMEB 9.5-1, Item C.1.b.
The staff's evaluation of the identified fire hazards is contained in the balance il
,of this report.
c Alternative Shutdown Alternate shutdr. capability has been provided for the control rooe.
this capability is addressed under Section 9.5.1.4 in this report.
1 i
3 Implementation of Fire Protection Procram The fire protection program for both units should be operation.;1 before initial fuel loading.
9.5.1.3 Administrative Controls l
s The administrative controls for fire protection consist of the fire protec-t l
tion organization, the controls over combustibles and ignition sources, and the prefire plans and procedures for fighting fires.
In'the August 16,
[
1982 revision to the Fire Protection report, the applicant committed to conform with the requirements for administrative controls delineated in Appendix' R to 10 CFR 50, Section III.K (BTP CMEB 9.5-1, Section C.2) except as explained in the Fire Protection Report concerning fire fighting strategies.
i The applicant has committed in the August 16, 1982 revision to the Fire
[
i Protection Report to develop generic strategies for fiahting fires in _
l 1
"all safety related areas and areas presentina a hazard to safety related_
l equipment._ Based on this commitment, the staff finds that ';ne adn' int-l strative controls conform to BTP CHEB 9.5-1, Section C.2, and are, there-(
)
l fore, acceptable.
I
(
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L Fire Briande and Fire Briaade Trainino q'
In the August 16, 1982 revision to the Fire Protection Report, the
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f i
i applicant committed to a fire brigade th;*. meets the requirements of j
Appendix R to 10 CFR 50, Section III.H (BTP CMEB 9.5-1, Section C.3),
except for the performance standard af the annum 1 nhysical examination and f
the nveber_of air bottles from the reserve air suonly.
The fire brigade l
~
l consists of five members on each shift.
The applicant committed to f
furnish at least two extra air bottles.for_each mask. The staff finds j
l this acceptable.
The applicant committed to perform fire brigade drill i
training such that the brigade drills once per quarter so that each fire f
j The staff l
i brigade member participates in at least two drills per year.
l finds this acceptable, i
a d
5
i
. [
1 Based on these commitments, the staff finds that the applicant's fire brigade and fire brigade training program conforms to the requirements of BTP CHEB 9.5-1, Section C.3, and is, therefore, acceptable.
Quality Assurance Program The applicant has classified the fire protection systenj s reliability
'related and has committed to have its Quality Assurance Department N
audit fire protection activities._ The staff finds the descript*on of the fire protection Quality Assurance Progras acceptable.
9.5.1.4 General Plant Guidelines Building De,s_ign Fire areas are defined by walls and floor / ceiling assemblies.
Walls that separate buildings and walls between rooms containing safe shutdown systems are 3-hour-fire-rated assemblies.
Floor / ceiling assemblies are either 2-or 3.-hour-rated assemblies.
In cases where the fire rating is 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, the staff has evaluated the fuel loading and fire protection provided l
l and found the 2-hour fire rating to be acceptable.
l l
s I
, Fire stop/ penetration seal material _ used in the plant _is a mineral fibre semi-rigid felt. Iht annlicant states that this material _aghityes__
h l
4 3-hour fire resistance rating based on results_of fire tests on similar.
l I
l assemblies.
The applica d has not provided lustifications for the _
l deviations from the standard ASTM E-119 test _for__in planLeonf.10utations.
l We will rGquire that the applicant demonstrate, by comparative analysis a r l
i actual tests that the fire stop material, as installed in the_ plant, will,
withstand a 3-hour fire exposure as defined by ASTM E-119, as stipulated in Section C.5.a(3) of BTP CMEB 9.5-1.
l l.
I f
Door openings in fire rated barriers are, for the most part, equipped with labeled fire doors.
In the August 16, 1982 revision to the Fire Protection Report, the applicant identified a number of door openings that were provided with unlabeled doors.
Pressure doors as well as bullet and missile resistant doors are located l
in some fire boundaries.
T,hese doors have been fabricated in accordance withUnderwritersLaboratoriesapprovedproceduresfor3-hourfiredoor".
l Certificates from the manufacturers are on file which verify the_
construction of the doors.
They are not labe' led because modifications necessary to satisfy leakage rates, bullet resistance and pressure loadings are not incorporated in U.L. procedures.
However, it is the staffs opi_nion that these doors will provide an equivalent level of fire protection to labeled fire doors.
The sta'f finds that the use of unlabeled fire doors in the above referenced areas to be an accep-table deviation from Item C.S.a (5) of BTP CHEB 9.5-1.
Small amounts of comb 0stibles are used as architectural finishes.
These
}inisheshaveflamespread, smoke,andfuelcontributionratingsof25_
or less in their end use configuration as determined by the test method of ASTM E-84.
The applicant has, however, stated that these materials do not
~
significantly contribute to fire loading in the plant and do not expose safety-related systems to undue risks, The staff finds this acceptable.
Metal deck roof construction is not used at Byron.
The applicant has stated that he complies with the guidelines of BTP CMEB i
9.5-1, Section C.5.a(12) and C.5.a(13), concerning transformers installed inside building and outdoor oil-filled transformers containing safety-related systems, closer than 50 ft to such buildings. __The applic. ant has also stated that he complies with Section C.5.a(14) of BTP CHEB 9.5-1 The g concerning floor drains sized to remove fire fighting water f1w.
staff finds this acceptable.
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Safe Shutdown Capability In the revised Fire Protection Report submitted by letter dated August 16, 1982, the applicant provided information concerning fire protection for the safe shutdown capability in accordance with the criteria of Appendix R.
The applicant's safe shutdown analysis states that systems needed for hot shutdown and cold shutdown consist of redundant trains and that one of the redundant trains needed for safe shutdown would be free of fire damage by providing seoaration, fire barriers, and/or alternative shutdown capability.
For hot shutdowa, at least one train of the following shutdown systems would be available:
(1) the auxiliary feedwater system, (2) the steam generator atmospheric _rel(ef valves, (3) the charging system and (4) the pressurizer PORVs and heaters.
For cold shutdewn, at least
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olie train of the residual teat removal system would_ be available.
The safe shutdown analysis consider & qmponents, cabling and support equipment for systems identified above which are needed to achieve shut'down.
The support equipment included the diesel generators, essential service water
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system, component cooling water system, and necessary ventilation systems.
The applicant performed an essential cabling separation study as part
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of the safe shutdown analysis in order to ensure that at least one train of the above equipment and essential instrtmentation is available in the event of a fire in areas which might affect these cuponents.
Essential 4
cables associated with this equipment and instrumentation were idsntified The comouter_
and traced throuch the olant by use of a comouter program. _
program provides a cable ' tabulation reoort which indicates the exact routingpathofeacheg1_e.
This information was transferred to electrical installation drawings by maddDg_the_ci e locations. These drawings also bl identified individual fire areas / zones to pirait verification of adequate, separation of redundant trains or an ayAlgation of cable separation where
redundant shutdown equipment trains are located in the same fire zone.
Mo_difications were made as necessary to assure proper separation and/or barriers, or alternate shutdown capability.
The applicant also considered associated circuits by verifyina that fire-induced failure in cabling for equipment not, required for achieving safe shutdown does not cause a condition which would prevent safe shutdown doesd not cause a condlign, which would prevent safe shutdown.
The applicant examined those non-shutdown circuits sharing a common power source or common enclosure with shutdown circuits, or whose fire induced spurious operation could affect.
jafeshutdown, Adequate coordinated short circuit protection and the l
capability for_ manual corrective acticn is provided.
The staff has reviewed the applicant's cable separation method.
In several areas of the plant, identified in Section 2.3 of the August 16, 1982 revision to the applicant's Fire Protection Report, separation of red'undant k safe shutdown divisions is le11__tban 20 feet. The staff is concerned that a single fire of significant magnitude will damage systems from both divisions and prevent the achieve?ent and maintenance of safe shutdown conditions.
The staff will require that the applicant completely protect one shutdown division with a 1-hour fire rated Urrier,wheneverredundantdivisionsarelocatedlessthan20 feel from one another.
The staff will also require that whenever redundant _
shutdown divuions are located within the same fire area, i.e. not_
separated by a 3-hour fire barrier or a justified fire barrier of lejj fire resistance, a fixed fire suppression system be installed in the___
area in accordance with Section 5.b.(2) of BTP CMEB 9.5-1.
These areas are identified in Section 2.3 of the applicant's Fire Protection Report.
The applicant's analysis indicated that alternative shutdown measures were required for the' control room in order to assure the availability of the safe shutdown sjstem.
In the event that fire disables the control room, the h mote shutdown panel (three panels) and other local
,4 8-instrumentation and controls located in separate fire protected areas in the auxiliary building provide an alternate to providing fire orotection separation (refer to Section 7.4.1.2 of the SER).
The con-trol functions and indications provided at. the remote shutdown panel --
g51ch are necessary for shutdown are electrically isolated or othenvise
~
separate and independent from the control room.
Alternative Shutdown Capability The design objective of the remote shutdown panels (three panels) is to provide a central point to control and monitor plant shutdown independent of ;he control room in the event of an evacuation of the control room.
The design of the panels includes the capability to electrically isolate the instrumentation indications and control functions g, the shutdown systems from the control room.. The auxiliary feedwater system, main steam atmospheric relief valves, and chemical and volti.e control systes k (charging pump and letdown line) can be manually conti311ed from the panels to achieve and maintain hot shutdown independert of the control l
rop loitie. tion of the residual heat removal system for achieving cold, shutdown is Derformed at local locations.
Support system functions are initiated either at the remote shutdown panels or at local locations.
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i Installation of temporary cabling is required as a repair to certato
% equipment required for cold shutdown following fires in some plant arta_s.
i
~Further, installation of a small boric ccjd transfer pump is reouired N following a fire in an area of the auxiliary building.
The applicant, I
however, has not committed to provide repair procedures covering _the specific repairs required following fires in these plant areas.
It is the 2
staff position that the applicant provides these procedures for plant
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g herators, and assure that the necessary material including the spare boric acid transfer pump is available on site.
e
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The design of the remote shutdown panel was reviewed to determine compliance with the performance goals outlined in the requirements of Section III.L Appendix R.
Reactivity control is accomplished by a manual _
scram before the coerator leaves the control room _and boron addit {on vi_a,
Shechemicalandvolumecontrolsystem(chargingpumps).
Reactor coolaa L makeup is also provided by the charging portion of the chemical and volume control sysism._. Roactor decay heat removal in hot shutdown is provided throughthesteamientratorby__theauxiliaryfeedwatersy_stemandmMa steam atmospheric relief valves, and in cold shutdown by_the residual heat removal _ system, comprnent cooling water system, and essential service water system.
Cold shutdown can be achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> followino a fire in any piant area, The following direct reading of process variables is provided at the remote shutdown panel:
p.
Auxiliary feedwater flow; pf'.
Steam generator wide range level;
/
Steam generator pressure; g.
Reactor coolant system hot leg and cold leg temperature; je5.
Pressurizer pressure; g,6.
Pressurizer level; and p
Source range neutron count rate
~
However,' the source range neutron monitor located at the remote shutdown panels is Et electrically isolable from the control room and thus an independent means to nonitor reactivity is not available.
Section III.L requiresthecapabilityfordirectreadingsofprocessvariablesnecessary to perform and control the reactivity control functions, the reactor coolant makeup functions and the reactor heat removal functions.
There-fore, it is our positiori that the applicant provide a source rtDSt neutron flux monitor _as part of the safe shutdown instrumentati m independent of the control room and available in the event of a control room fire.
10 -
Systems Intercction The applicant has designed components required for hot shutdown so that rupture or inadvertent operation of fire suppression systems will not adversely affect the operability of these components. Where necessary, appropriate protection is provided to prevent impincoment of s ter shayoncomponentsrequiredforhotshutdown.
Redundant trains of components that are susceptible to damage from water spray are physically separated so that manual fire suppression activities will not adversely affect the operability of components not involved in the postulated fire.
The staff finds this acceptable.
2 1
Control of Combustibles In the August 16, 1982 revision to the Fire Protection Report, the applicant stated that the hydroaan storans area is in a senarate buildina and that hydrogen piping is not routed throygh any areas _containina safe shutdowa equipment o p ahling.
Thus, a fire or explosion associated with the m
hydrogen system will not affeet the safe shutdown capability.
- However, the hydrogen piping is routed in areas containing safe'ty-related equipment.
To meet staff guidelines in 8TP CME 8 9.5-1, Section C.5.d(2), hydeggan.
lines in safety-related areas should be either destaned to seismic Category I requirements, or sleeved so that the water pipe is direct]y vented to the outside, or equipped with excess-flow valves so that in case of a line break, the hydrogen concentration in the affected areas will not exceed 2 percentm The staff will require the applicant to meet the guidelines of 8TP CME 8 9.5-1, Section C.5.d(2).
The applicant has stated in his fire hazard analysis that safety-related systems have been isolated or separated from combustible mateslais to the extent possible, that the use of plastic materials has been minimized,
'and that storage of flaanable materials complies with the requirements of NFPA 30. The staff finds this acceptable.
d QctricalCableConstruction.CableTrays,andPenetrations.
c Refer to Section 9.5.1.4 of NUREG-0876.
Ventilation t
i Refer to Section 9.5.1.
of NUREG-0476 Lighting and Communication Refer to Section 9.5.1.4 of NUREG-0876 Fire Detection and Suppression l
Fire Detection Separate fire detectio. systems are provided for Units 1 and 2.
The i
system for each unit consists of ionization and ultraviold detectors F_lre detectors y i
located in specific fire zones throughout the plant.
i ngoinstalled in all plant area's that contain safety related equipment.
l Some of these locations, such as the cable riser area on elevation 451_
l
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j feet, 0 inches, contain a high fire loadina.
The staff will require
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that fire detectors be installed in such areas in accordance with Section C.6.a.(1) of BTP CMEB 9.5-1. __
4 l
The design of the fire detection system meets the provisions for a Class l
B proprietary protective signaling system as defined in NFPA 720-1975.
Both audible and visual alares are provided in the main control room for each zone of the fire detection system.
The system is electrically super-vised in accordance with the provisions of NFPA 720 and is connected _.
to the plant emeraer":y power supply ara backed up by a battery source.
Fire _ detectors are installed in accordance with the provistens of NFPA
)
72E.
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l
- 12
- The staff was concerned that the Class B systems provided would not include provisions for emergency operation during a single break or a single ground fault of the signaling line circuit.
By letter dated _
January 14, 1982, the applicant committed to provide either Class A supervised circuits or their equivalent for those fire detecti_on circuits associated with automatic fire suppression systems gop tting areas which contain equipment or cables wh_ich__Re g ra m afety-related function.
In the August 16, 1982 revision of the Fire Protection Report, the cpplicant states that Class B supervision, coupled with manual _3ystem activ3 tion,3i11 be relied upon durina single break or ground fault
,co311.tions.
The staff concludes that manual system activatiortiLrtot, equivalent __to_ Automatic system acti_yAtion that would be available with Class A supervis h The staff will require that fire detection elec-trical circuits associated with automatic fire suppression systems be capable of fuictioning during single break or ground fault conditions.
Fire Protection Water Supply System The water supply system consists of two fire pumps separately connected to an underground 14 in, water main loop around the plant.
System pressure ismaintainedbytwojockeypumps.
Each jockey pump is rated at 100 gpm at 145 psi.
Whenever system pressure drops, the electric-motor-driven fire
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pump will automatically start.
If the motor-driven fire pump does not staet or is unable to satisfy the demands of the system, then the diesel-engine-driven fire pump will automatically start.
The diesel-driven pump does not require any power other than its own batteries to start.
Eae.h fire pump 1; rated at 2500J pa g 68 y_sj.
The fire pumps and controllers are UL listed and are installed in accordance with NFPA 20.
The fire pumps are located in the circulating water pump house and are separated by 150 ft.
The diesel-engine-driven fire pumpMtiosed_with its 650-aaLLLe1 tan _k.
Tlie enclosure has a 3-hr fire rating.
An 8-in.-high curb is provided within the enclosure t.o contain any oil in the tank location in the event of an oil tank rupture, t
a-
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The fire pumps take suction from.the forebay of the Lake Screen House.
The source of water is much larger than 300,000 gal recommended by the guide-lines; therefore, the staff finds this acceptable.
Electrical supervision is provided for control valves t_o individual fixed
[extinauishinasystems.
These circuits alarm in the control room.
Interi>r and exterior sectional control valves are not electrically supervised.
Their positions are administratively controlled.
The staff finds this acceptable.
/ The greatest _ water demand for the fixed fire suppassion systems is J
2'285 gpm, and, coupled with 500 opm for hose streams, creates a total water demand of 2785 gpA The water supply system can deliver 2700 com 7
F fp with one pump out of service but with both jockey pumps operating.
The I
staff finds this acceptable.
Based on its review, the staff concludes that the fire water supply system meets the guide'ines of BTP CMEB 9.5-1, Section C.6.b and is, therefore, acceptable.
l Water Suppression and Hose Standpipe Systems
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Water suppression systems and hose stations standpipe systems are separately connected to the yard main or to headers within buildings fed from each end I
of the building; therefore, a single failure cannot impair both water suppression systems and hose stations.
Fixed water spray systems and sprinkler systems are designed according to the provisions of NffA l
Standard 13 "Standard for Installation of Sprinkler Systems," and NFPA Standard 15 "Standard for Water Spray Fixed System." Manual ho1L sG tions are located throughout the plant to ensure that an effective hose stream can be directed to any sefety-related area in the plant.
The standpipes used have a varying diameter of 2-1/2 inches to 4 inches.
Portions of the Fire Protection System that service safety-related e-
,,- -- ---,...-.._,.,.~ _.._,.
.s -
,e equipment.or run through areas where safety-related equipment is housed use Seismic Category I piping.
The system is designed according to_the provisions of NFPA Standard 14. "Standpipe and Hose Systems." Areas equipped with water suppressica systems are as list'ed in the Fire Protection Report, Table 2.2. Several areas are protected with fsam suppression systems as listed in the Fire Protection Report, Table 2.2-3.
These systems are designed in accord-ance with NFPA 11.
The staff has reviewed the design criteria and bases for the water suppression systems and concludes that these systems meet the guidelines of BTP CEM8 9.5-1, Section C.6.c and are, therefore, acceptable. [
[.
Halon Suppression Sys,tems Refer to Section 9.5.1.4 of NUREG-0876 l
-(.
Carbon Dioxide Suppression Systems Refer to Section 9.5.1.4 of NUREG-0876.
Portable Extinguisher Refer to Section 9.5.1.4 of NUREG-0876.
- 9. 5.1. 5 Fire Protection for Specific Plant Areas Primary Containment i
Refer to Section 9.5.1.5 of HUREG-0876.
Control Room Complex The control room complex consists of the control room, record storage With the exception of 2 unlabeled fire doors,
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rooms, and toilet room.
i 1
l protection for this area-to be in accordance with the guidelines of BTP CMEB 9.1-1, Section C.5.b, and is, therefore, acceptable.
$4fetV-Related Battery Rooms i
Refer to Section 9.5.1.5 of W REG-0876.
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P Oiesel Generator Areas The diesel generators are located in difforent fire areas separated by
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3-hour-fire-rated barriers.
l i
i The diesel fuel oil day tank rooms are also separated from other plant l
areas by 3-hour-fire-rated barriers.
Eaci 500-gal diesel fuel cil day tank is contained by 24-in, dike around the tank with drainage to a safe location.
Each diesel fuel oil day tank room, and each diesel generator room is protected by automatic total flooding carbon dioxide f
Heat detectors actuate the carbon gaseous extinguishing systems. '
l dIoxidesystems.
t Based on its evaluation, the staff concludes that the fire protection l
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I for the diesel generator rooms meets the guidelines of BTP CMER 9.5-1, Section C.7.1, and,is, therefore, acceptable, l
Other Areas Refer to Section 9.5.1.5 of W REG-0876 f
9.5.1.6 Deviations From BTP CMEB 9.5-1 f
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f f
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15 -
the control room is separated from other plant areas by walls, ceilings t
and floor assemblies, and doors with fire ratings of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.
The unlabeled fire doors _are evaluated in Section 9.5.1.4 and the staff finds them acceptable.
All ventilation penetrations are located in the ceiling slab and is eouioned with two curtain-type, 1-1/2-hr. horizonta_1 4
fire dampers in series per penetration. __ The staff finds this acceptable.
Ionization detectors are located above the drop ega_ crate _ ceiling that aiaraandannunciateloca111 In addition, ionization detectors in th_e exhaust ductwork from the control panels and in the air intake ducts will alare in the control room.
Thestafffindsthisacceptable.'[
An alternative shutdown capability is provided for the control rooms.
This capability is evaluated in Section 9.5.1.4.
The staff finds the fire protection for this area to be in accordance with BTP CHE8 9.5-1, Section C.7.b, and is, therefore, acceptable.
Cable Spreadina Rooms Refer to Section 9.5.1.5 of NUREG-0876.
Switchgear Rooms Refer to Section 9.5.1.5 of NUREG-0876.
i Remote Safety-Related Panels Tiie remote shutdown panels are housed in an area separated from the remainder of the plant by ceiling / floor assemblies, walls and doors with fire ratings of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.
The paneitof Unit 1__and _ Unit 2_are separated by moreJhan_S0_fL Ionization detectors are located at various points in the room._ The panels are electrically and physically j
isolated from the control room such that a fire ir. either area will not
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affect shutdown capability in the other area.
The staff finds the fire 9
+
On February 19, 1981, the Commission approved a rule concerning fire protection. The technical requirements cet forth in Appendix R are being used as guidelines in the licensing of plants after January 1,1979.
On April 27,_1981, the Commission required that Operatina Licenses issued
'after January 1,1979, contain a condition reouirino compliance with comitments made by an applicant and agreed to by the staff af ter diff-erences between the applicant's program and the guidelines set forth in Appendix A to BTP 9.5-1 and Appendix R to 10 CFR 50 (BTP CHEB 9.5-1) have been identified and evaluated.
The technical requirements of Appendix R to 10 CFR 50 and Appendix A to BTP ASB 9.5-1 have been included in 8TP CME 8 9.5-1.
The applicant has identified one deviation from the staff guidelines that the staff has approved: namely, unlabeled fire door tidentified in Section 2.3 of th L AIgust 16, 1982 revit,lon to the applicant's Fire Protection Report._
9.5.1.7 Conclusion As discu'ssed in the previous sections, the following itees of the appli-cant's fire protection program are unresolved (the number in parentheses indicates the section of this report in which the ites is addressed):
~
_Firestop/penetrationsealmaterial(Section9.5.1.41, Fire Protection for redundant shutdown division (Section 9.5.1.4)
Alternate Shutdown Capability (Section 9.5.1.4)
, Routing of hydrogen lines (Section 9.5.1._4)
Lighting and communication (Section_9u5al h EFiredetectorsinsafetyrelatedareaslSection9.5.1.4)
, Supervision of fire detection circuits (Section 9.5.1.4) 011 collection system for reactor coolant pump (Section 9.5.1.5)
Sprinklers in the cable spreading rooms (Section 9.5.1.5)
3,.
The applicant has been infonned of the necessity of the resolution of all open items so that all fire protection features can be implemented prior to fuel loading. We will report our review of these unresolved items in a subsequent safety evaluation report.
e=
0
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UNITED STMES f
NUCLEAR REGULATORY COMMIS$10N WAaHHeeTON.D C.30005 o
5 JR.18 M MEMORANDUM FOR: Victor Benaroya, Chief Chemical Engineering Branch Division of Engineering THRU:'
Robert Fervuson, Section Leader Chemical Engineering Branch Division of Engineering FROM:
Dennis Kubicki i
Chemical Engdeering Branch Division of E.'.gtneering
SUBJECT:
TRIP REPORT: FIRE PROTECTION SITE AUDIT - BYRON STATION UNITS 1 AND 2 Plant Name:
Byron Station Units 1 and 2 Dockat Numbers: 50-454 and 50-45,\\
Licensing Stage: OL Responsible Branch:
LB -1; L. 015han, PM Chemical Engineering Branch Reviewec:
D. J. Kubicki Between July 12 and 15,1983, we contiucted our fire protection site audit at the Byron Station, Units 1 and 2.
A representative of our con-l sultant, Gage Babcok & Associates, participated.
As a rciult of the audit, we reached several agreements re0arding the adequacy of the fire protection program.
In addition, we expressed a number of concerns / questions pertaining to previous applicant commitments; L
the justification for particular fire protection designs; and the degree of compliance with our fire protection criteria. A summary of these issues is enclosed.
The applicant agreed to respond to our concerns.
$s iM Dennis Kubicki Chemical Engineering Branch Division of Engineering t
Enclosure:
As stated
Contact:
D. Kubicki j
cc:
See next page
[d7.4 1ri' M Y i
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79 D
E W y 1
o Vic 'r senaroya '
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cc:
R. Vo11aer W. Johnston R. Ferguson T. Wambach R. Eberly
- 5. Pawlicki T. Sullivan t
O. Parr J. Werefel I
J. Taylor l
C. Morelius, Region I!!
C. Eisenhut T. Novak
- 5. J. Youngblood L. 01shan F. Rosa I
N. Srinivasan l
R. Wessaan R.'Barnes(G8A)
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m 1
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o Enclosure Chemical Engineering Branch / Fire Protection Section Syren Station, Units 1 and 2 Docket Nos. 50 454 and 50-455 Introduction Between July 12 and 15, 1983, we conducted our fire protection site audit at the Byron Station, Units 1 and 2.
A representative of our consultaat.
Gage Babcock and Associates participated.
As a result of the audit, we reached a number of agreements regarding the adequacy of the fire protection program.
In addition, we expressed a number of concerns pertaining to previous appitcant comettaents; the justification for particular fire prctection designs; and the degree, of compliance with our fire protection criteria.,The agreements and con-cerns can be summarized as follows:
Aareements 1.
The applicant has designed those components required for hot shut-down so that rupture or inadvertent operation of fire suppression systees will not adversely affect the operability of these compo-nonts. Where necessary, appropriate protection is provided te pre-vent impingement of water spray en components required for het shut-down. Redundant trains of components that are susceptible te damage free water spray are physically separated so that annual fire sup-pression activities will not adversely affect the operability of components not involved in the postulated fire.
2.
The installation of a third fixed reposter for emergency comeu-nications on the roof of the elevator eachine room in the Turblee Building provides reasonable assurance that a single fire could not interrupt emergency communications in the plant. This modification complies with Section C.5.g of BTP CME 8 9.5.1.
s o
.g.
3.
Because of the complete, area wide, automatic fire detection and suppression systems; the steel pipe construction and the insulation for the cooling water pipes in the diesel generator rooms, a fire in Room 15 will not damage cooling water pipes for both deisel gen-erators before being detected and extinguished. Therefore, the routing of cooling water lines for diesel generator 1A through the room containing diesel generator 18 is an acceptable deviation from the technical requirements of Section III.G of Appendix R.
4.
With the tixception of the two doors identified in ites 16 (below),
the non-U.L. labeled doors, identified in Section 2-3 of the app 11-cant's.
Fire Protection Report, will achieve an equivalent level t
of safety to labeled fire doors and is, therefore, an acceptable deviation from the technical requirements of Section C.5.a of BTP CMEB 9.5.1.
I Concerns The following is a list of fire protection concerns raiseu during the audit.
1.
In the August 16, 1982 revision to the Fire Protection Report, the applicant coenitted to seal fire barrier penetrations with saterial l
having a fire resistance rating comparable to the ratings of fire walls and floor / ceiling assemblies. This ner.essitates that seal-
[
ant satorial be installed to an appropriate. depth consistant with its U.L. listing. We observed that RTV rilicon sealant material g nstalled in the plant in thicknessjs greater than the depth _
of the concrete floor slab. This conf,lauratina does not ap u to' l
[beconsistentwiththelistingofthysaterial. We are concerned th.t this sealant saterial will not be able to withstand anticipated fire exposures. The applicant shculd verify that penetration seals featuring silicon foam, as insta' led in the plant, are equivalent I
to the rating of the structural assembly.
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3 2.
The following features of the fire protection program were observed to be incomplete:
The installation of penetration seals H fire walls and fire rated floor / ceiling assemblies.
The provision of seismic supports for the hydrogen supply piping routed through the Aux. Building.
The installation of fire proofing for steal structural elements.
The installa; ion of fire hose nozzles, hose houses and hose-house fire fighting equipment, g - The third reptater for the plant emergency comunications network.
The 0.5. Y-type sectional control valve at the discharge outlet for
<e fire pumps to avoid the necessity of shutting off one fire
.mp in order to test the other.
The applicant should verify that these features of the fire protection
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program will be completed by fuel load.
3.
To comply with Section C.6.a of BTP CME 8 9.5.1, electrical circuits associated with automatic fire suppression systems, including fire detection circuits, are required to be Class "A" supervised such that systes activation is possible automatically under a single break or ground fault condition.
Information was unavailable during the audit to completely verify this design feature in the plant. With the exception of the recundant fire detection systems in the cable spreading rooms (where activation of either system initiates fire suppression system discharge), the applicant should verify that all circuits associated with automatic fire suppression systems are class "A",
including those circuits from the local fire alare panels to the suppression system actuating mechanism.
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4 4.
In the August 16, 1982 revision to the Fire Protection Report, the applicant coanitted to comply with Section C.5.d of STP CMES 9,5.1 and with*!ection C.7 b. with the exception that an automatic fire surpression system will not be installed in "offices" in the control
_ e obsevered that the ccaputer related, storane area W
room complex.
adjacen'. to the control room is not equipped with an automactic _
je suppression system which is not consistent with these commit-ments.
5.
To comply with Section C 6.c of STP CME 8 9.5.1, interior sanual hose ststions should be installed so as to be able to reach any location that contains, or could present a fire exposure ha:ard to safety related equipment with at least one effective hose stream.
We observed that_because of the present location of manual hose j
stations, it say not be possible to reach all areas of W computer room and cable riser area on elevation 451 feet. The applicant should conduct a hose stretch test to verify the adequacy of the existing design.
We also observed that because of congested conditions in certain p1 ant areas, such as the cable spreading rooms, it may not be pos-sible to utilize existing manual hose stations because of the in _
In such arets, a[ilitytofullydeploythewoven-jacketedfirehose.
tu comply with Section C.6.c of STP CMER 9.5.1, it will be necessary to replace the woven-jacketed hose with a hard rubber thpe.
- 6. In the August 16. 1982 revision to the fire Protection Report, the _
applicant committed to seal fire barrier penetrations with material having a fire resistance rating comparable to the rating of fire-_
l walls and floor / ceiling assemblies.
Inforsation was unavailable l
during the audit to verify that bus duct onnatrations d fire rated assemblies have been sealed internally with an anorcoriate firA.
rated material The applicant should confirs that such penetrations Tresealedtomaintaintheintegrityofthebarrier.
In additon,
5 we observed that fire dampers were installed in a "ganged" configu-
"ration in several larae vantilation openings in fire barriers. such_
as the diesel generator room exhaust vents. _This arrangement does ~
not appear to be consistent with the listing of the darper. The applicant should verify that the installation of the dampers in a ganged configuration will achieve a fire rating equivalent to that of the barriers in which they are installed.
7.
In the Aucast 16, 1982 ruvision to the Fire Protection Report, the applicant committed to comply with NFPA Standards 13 and 15 in the design and installation of fixed water extinguishing systems. We observedthatmanualdischargevalvesforthewaterdelugefirI suppression systems protecting charcoal filters would be inaccessible during a fire because of their closeness to the filters and the
' limited access in the area. This condition appears contrary to the c655Tuent.
8.
To corply with Section C.Lb of BTP CHEB 9.5.1 and Section III.G of Appendix R, structural steel forsing a part of or supporting fire barriers should be_ protected to provide fire resistance equivalent to that required of the barrier. We observed that in
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the upper and lower cable penetration areas and in the Auxilla g Butiding General Floor _ area, on elevations 346 feet through 426_
feet, the structural steel supporting the floors was unprotected.
We are concerned that a fire could cause the collapse of such elements and effect components / cables of redundant shutdown divisions located within the same floor elevation or on vertically adjoining elevations.
The tpplicant should provide protection for such structural steel commensurate with the fire exposure and the degree of separation between redundant shutdown divisions (see concern in item 18 below).
4
. We are also concerned that openings in non-fire rated _ barriers._
such as equipment hatches, removable concrete slabs, and unprotec-ted stairway cuenings in the Auxiliary Building General Floor areas would subject redundant shutdown divisions, which are located
,on different_ elevations, to loss from a single fire. The applicant should pro)ide fire protection connensurata with the hazard and in accordance with Section C.5.b of our fire protection guidelines or demonstrato that at least one shutdown division would remain free of damage from a vertically propagating fire.
9.
We observed coveral discrepancies in the (escriotion of fire protection features in the applicant's Fire Protection Report from '
what was observed in the plant.
Such discrepancies include the description of fire proofing for structural steel, the extent of g/\\
fire detection in safety related plant areas, the nature of fire doors and the lack _of a fire hazard's analysis and fire protection for the Med-Chem" area on eleva+.f on 401 feet.
10.
In our Safety Evaluation Report, we stated that an oil collection system for each reactor coolant pump was required in accordance with Section C.7.a of BTP CMEB 9.5.1.
Based on observations of conditions in containment as they pertain to the fire hazard posed by the reactor coolant cumps. our conclusion regardino the need for
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an RCP oil collection system remains unchanced.__
11.
In the August 16, 1982 revision to the Fire Protection Report, the applicant coamitted to comply with NFPA Standard No. 20 regarding the installation of fire pumps. We observed that an unlisted controller has been installed for the electric motor driven fire _
pump which is not consistent with that cossaitment.
7 12.
In the August 16, 1982 revision to the Fire Protection Report, the applicant committed to comply with Section C.5.d(1), "control of Combustibles" of BTP CME 8 9.5.1..In the diesel generator rooms and at the Auxiliary Fuel Pump Room, we observed that curtis were not provided at doomays into these areas and therefore, a potential existed for a diesel fuel fire to propagate through the doorway r
into adjoining areas. The applicant should provide curbs at these i
doonvays to be consistent with their comuniteent.
13.
In the Fire Protection Report, the applicant committed to comply i
with NFPA Standard No.13 in the design of automatic sprinkler systems. We observed that the ceiling levet sprnklers over the_
lube oil drain tank were obstructed, which is contrary to that commitment.
- 14. To comply with Section C.5.g(1) of STP CME 8 9.5.1, fixed self-contained lighting consisting of flourescent or sealed beam units with individual 8-hour minimum battery power supp1tes should be providea in all plant areas that need to be manned for safe shutdown and all routes to these areas. We observed that the Essential Safety Features Switchgear Roos has not been provided i
All i
% with 8-hour battery powered eeergency Itchtino as required.
other areas of the plant that are accessed for safe shutdown have -,
been provided with emergency lighting off of individual battery units or the station batteries. The use of station batteries represents a deviation from our fire protection guidelines.
To be considered acceptable, the applicant would have to demonstrate that a fire in an area containing eneroency lighting off of the station batteries would not af f act battery powered emergency 51ghting in all other plant areas.
6
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- 15. The August 16, 1982 revision to the Fire Protecton Report identifies equipment located within the Control Room Refrigeration Equfpment
~ Rooms being necessary for safe shutdown, We observed that components and cables from both shutdown division are vulnerable to damage from a fire in this room and therefore do not meet _
the guidelines of Section C.5.b of BTP CHEB 9.5.1.
16.
Libeled fire doors were not provided at the Auxiliary Fuel Pump, Room and at the doomay in the fire wall at Column L-11 on elevation d
401 feet, as committed to in the Fire Protection Report.
- 17. We observed that, because of the absence of an automatic fire suppression system and the lack of a fire wall between redundant _
divisions, both RHR pumps and related cabling are vul_nerable to a _
fire located in the containment spray pumo area, To settsfy the guidelines in Section C.5.b of BTP CMEB 9.5.1, the unprotected I
openings in the wall separatina the Division 11 RHR Dump room from the containment spray pump area should be erotadQ
[revent the passage of smoke and heat.
2
- 18. We observed that, because of the absence of automatic fire suppfat-l sioa systems. area-wide smoke detection systems and/or physical separation between redundant divisions, both trains of shutdown _
f glated cabling and components are vulnerable to damage from a _
l single fire in the following olant arame -
l 7 Non segregated bus duct area v Aux. electrical equipment roon
/ Aux. building general area Elevation 346 feet f
f Aux. buildiq; general area, Elevation 364 feet I
V Aux. building general area. Elevation 401 feet g Aux. building general area Elevation 426 feet y Containment.
a 1
.g.
The fire protection for these areas is not in accordance with the guidelines in BTP CMEB 9.5.1 or Section !!!.G of Appendix R.
Out-side containment, the applicant should completely protect one shut-down division with a one-hour fire rated barrier wherever redundant divisions are located within 20 feet of one another or located more than 20 feet apart but the intervening space contains combustible saterial.
In addition, complete area-wide fire detection and automatic fire suppression are required.
Inside containment, the fire protection guidelines _of Section C 7.a of BTP CMEB 9.5.1 apply. To facilitate our evaluation of any deviation from our guidelines and to evaluate the adequacy of the applicant's response to Item 8 (above), the aoolicant should providtcolor coded drawings showing the relative location of redundant shutdown related cables for all fire areas.
NOTE 5ecause no safe shutdown analysis was provided for Unit 2, g our evaluation applies only to Unit 1.
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UNITED sf AT E s
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! '..., / y NUCL E AR CEGULATCRY COMMISSION PRIN0lPAL STAf[
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OCT 311983 aA ss en, L
JC Rq (f) 5CS i3A ML h-i William V. Johnston, Assistant Director Ei3 Flie lHEfDRANDUMFOR:
Haterials, Chemical & Environmental Technology g Idh Division of Engineering b*-
f THRU:
Victor Benaroya, Chief Q
7 F.$b Chemical Engineering Branch Division of Engineering
.M 4 #. 9 44 FROM:
Robert L. Ferguson, Section Leader
' k#d Fire Protection Section 4
Chemical Engineering Branch Division of Engineering
SUBJECT:
POTENTIAL LICENSING PROBLEHS - BYRON STATION UNITS 1 & 2 (50-454/455)
During our site audit, on July 12 to 15,1983, we identified several concerns with the applicant's implementation of our fire protection Two of these, the orotection for safe chuttinwn capability guidelines.
in certain areas and the orotection of structural steel associated with ire barriers may not be res%ed promptly and the needed modifications may not be implemented prior to f uel load, or even 51; power.
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Bv letter dated September 20, 1983, the applicant indicated that it did not share ouFconcern on thue two issues.
Subsequently, we held a reeting on October 28, 1983.
At this meeting, the app 1tcant presented general arguments for his positions.
The applicant stated tnt tns cable used at Byron had passed the IEEE-383 test, met the separatil.n crite'ta of Reg. Guide 1.75, and with the administrative procedures in e 'fect, are not expected to burn.
Therefore, the lack of separatio', and the absence of a suppression system as required tecause in the acolleant's by Appendix R would ' sot pose a safety problem.
evel of fire protection as reoutred by cur ngide. lines, opinion an eeutvaleat 'T ant".ed not asked and was nbt plannina en a Hng_
were provided the apo1 t Tor approval of these dev1ations h a cur __o m G nal. ~Ihe acolicant also, 11ated that theyJd_nat_hne _a_ cottnigte IInt of all areas _which doEL et our guidelineh ey ations would have to be req 9ested for each fire area that does not meet our guidelines; however, based on the site audit, we were of the opinion that the areas visited were not acceptable without some modifications.
Two approaches to resolve these issues are being considered by the applicant (1) technical meetings with the reviewer to work out acceptable fire protection and (2) appeal to higher level.managment.
The appitcant said that we will be inforsed by Nover.ber 4,1983 as to the approach they will take.
Fot A f t
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!!illia: Y. Johnston '
We believe that it will take a considerable effort on the annlicant's pa_rt ln ident' fv all the areas t.tiich do not reet eur guidelin25. develop on a
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[cecertabic level of fire protection for each of those areas anCinst.1 nocessary ecul p ent by fue) lohd scheduled for February 7E(.
To date 6 have not hat Aw frill coorerat' on of the app 11 cent _to imp'ement a fire _
iirotection prooram consistent with_out aufdelines. We recomend high "evel manage:nent involvement now.
Robert L. Ferguson, Section Leader Fire Protection Section Chemical Engineering tranch Division of Engineering cc:
R. Yollmer R. Ferguson T. !!ambach R. Eberly S. Paw 11cki T. Sullivan
- 0. Parr J. Werutel J. Taylor C. Norelius, Region !!!
D. Eisenhut V. Benaroya T. Novak B. J. Youngblood i
L. 01shan F. Rosa M. Srinivasan l
R. Wessman R. Barnes (GSA) l t
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NUCLE AR REGULATC'W COMMISSION W A5HiNGf DN. o. C. 20558
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Decket Noss: STN 50-454
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and STN 50-455 APPLICANT: Comonwealth Edison Company FACILITY:
BYRON STATION, UNITS 1 and 2
SUBJECT:
SUMMARY
OF MEETING ON BYRON FIRE PROTECTION PROGRAM 28,1983,(the NRC staff met with Comonwealth Edison (CECO)
On October S&L) to discuss the Byron Fire Protection Program.
and Sargent & Lundy
' Enclosure 1 is a list of the meeting attendees.
During, July 1983 the NRC and its consultant conducted its Fire Protection Site Audit of Byron and documented its findings in an August 3,1983 letter to CECO. The CECO response, dated September 20, 1983, did not satisfactorily t
' address the staff's concerns in several instances.
In conference calls of September 27, 1933 and October 21, 1983, CECO comitted to alter its response in r.any areas. CECO agreed to nake several plant modifications, including ins allation_of,a reattor_coolent_purp oil eolleet_ ton systerudti h compl3es 11cn_111J_of_ Append iLR1n s t a ) f ait ion a curbs in the diesel-generator w
room and Jnstallatf ortoL8-hour. battery-powertd. emergency _11shtWg IiEther
- Tsscntial Safety Featurellwltchgekr Room Pending receipt of a CECO letttr
' documenting 7ts comitments, all but two concerns are considered resolved.
j The primary purpose of the meeting was to discuss the two ynresolved concerns:
3e_psiec.ted 3tructuralitetLLConcern 4 R 1n the itaf.f'1_ August _3mit83tter) a i
un jsiu.iptint3Concer1LMom] A)_
gnogg.its_gtgyrgnH ] [t] h tygnpg }ggggg,ttntgt'yt3}
steel. CECO cited _.1bt low _ccebu111ble load 3ss. in the areas, the administrative ifontrols over transient combustib O he conductive heat transfer properties of the steel which tend to distribute the heat, and the unlike11 hood of the steel reaching a sufficient terperature for a sufficient' time, to collapse.
CEC 0's arguments in defending its existing configuration of separation of redundant safe shutdown cabling and equipment included:
(1)availabletest data on the combustibility of cables do not apply to the Byron design because most of propagation in the tests was in the vertical direction and the Byron i
configuration would require mostly horizontal propagations (2) Byron has EPR l
hyper 1on cabling and solid bottom trays. (3) CECO believes it has instituted
. g effective administrative controls over transient combustibles.
The NRC staff did not accept CEC 0's arguments and urged CECO to implement rodification's to satisfy the, staff's concerns. The staff re-emphasized that I
resolution of their concerns regarding 'the protection of safe shutdown systems-fs1h Tt* H Y,
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- '* *e3 231; Aim 4y
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2 wo61d enta 0 f at+2114aa M'+^matic H ra sentaction syttem and/or providing Thour fire rated barriert ai aund one imidown divis' om. In those instances 1
where the specific requirement of !vetion !!!.G.2 of Aspendix R are not met l
CECO would have to provide a detailed description of tie deviation, j
The applicant is considering either appealing to higher management or proposing.
and implementing fir 6 protection modifications that are acceptable to the staff.
However, the staff indicated that it could issue a license for fuel load i
without the modifications being completed if CEC 0 would provide adequate justification for this approach, but it is unlikely that the plant would be i
allowed to go above 5% power with the current configuration.
I 1
h-L. 01shan, Pro,iect Manager l
Licensing Branch No. 1 i
Division of Licensing
Enclosure:
I As stated cc: See next page f
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i i
ENCLO5URE 1 y
FIRE PROTECTION MEETING i
,0CTOBER 28, 1983 t
, MEETING ATTENDEE $
l I
l Comonwealth-Edison 3
i L
K. A. Ainger T. R. Tram J. T. Westermeier l
l Sarnent & Lundy t
E. R. Crass L. Cypranowski K. J. Green W. B. Paschal
[
J. D. Regan j
s NRC i
t V. Ben &roya i
R. L. Ferguson
.D. J. KubLcki L. N. 01shan i
Gene-Babcock (NRC Consvitant) i R. Barnes i
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I
l t-Mr. Dennis L. Ferrar i
i Director of Nuclear Licensing Cohconwealth Edison Company Post Office Box 767 Chicago, Illinois 60690
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cc Mr. William Kortier Ms. Diane Chavez
.I Atomic Power Distribution 326 N. Avon Street Westinghouse Electric Corporation Rockford, Illinois 61103 Post Office Box 355 l
Pittsburgh, Pennsylvania 15230 Mr. James 8. Keppler l
U. 5. Nuclear Regulatory Cornission Michael Miller Region !!!
-l Isham Lincoln & Seale 799 Roosevelt Roew One First National Plaza Glen Ellyn. Illinois 60137 42nd Floor Chicago. Illinois 60603 Joseph Gallo Esq.
l
! sham LincoIn 4 Seale t
Mrs. Phillip B. Johnson suite 840 1907 Stratford Lane 1120 Con ~necticut Avenue, N. W.
Rockford, Illinois 61107 Washington, D. C. 20036 l
Dr. Bruce von Zellen Doug Cassel, Esq.
Department of Biological $ctences Jane Whicker, Esq.
Northern Illinois University 109 N. Dearborn Street l
'8 DeKalb Illinois 61107 Chicago, 11Tinois 60602
[
Mr. Edward R. Crass Ms. Pat Morrison i
Nuclear Safegurrds & Licensing 5568 Thunderidge Drive 3 argent & Lundy Engineers Rockford. Illinois 61107
$5 fast Monroe Street t
Chicago.111tnois 60603 David C. Thomas, Esq.
77 5. Wacker Drive Mr. Julian Hinds Chicago, Illinois 60601 U. 5. Nuclear Regulatory Commission I
lyron/ Resident Inspectors Offices 4448 German Church Road Byron. !)11nois 61010 p
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