ML20207K946

Summary of 880830 Meeting W/Util in Rockville,Md Re Fire protection-related Issues.Draft Fire Protection Engineering Evaluation, Cables on Svc Bldg Outside Wall & List of Attendees Encl

ML20207K946
Person / Time
Site:	Millstone, Haddam Neck, 05000000
Issue date:	10/04/1988
From:	Wang A Office of Nuclear Reactor Regulation
To:	Office of Nuclear Reactor Regulation
References
NUDOCS 8810170091
Download: ML20207K946 (29)

Text

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N 0 i ;gg Cocket Nos:

50-213 50-245 n

50-336 LICENSEES:

Connecticut Yankee Atomic Power Company Northeast Utilities FACILITIES:

Haddam Neck Plant Millstene Units 2 and 3

SUBJECT:

MEETING

SUMMARY

OF AUGUST 30, 1988 REGARDING FIRE PROTECTION On Tuesday, August 30, 1988 a neeting was convened in Rockville, Maryland between the staff and representatives of Northeast Nuclear Energy Company (NNECO) to discuss several fire protection-related issues. A list of attendees is attached.

During the meeting a nunber of conditions associated with the design of fire protection features at the Haddam Neck Plant were discussed. Son.e of these pertain to the new switchgear building. These conditions do not literally conforts with staff fire protection requiren.ents and guidelines.

Connecticut Yankee Atomic Power Company's (CYAPCO) representatives presented sunnaries of engineering evaluations which justify these conditions.

The staff requested additional clarification on several issues but indicated, tentatively, that the conditions were acceptable. The staff noted, however, that in three locations these conditions impact existing exemptions from the technical requirenents of Aprendix R to 10 CFR Part 50.

It was agreed that revised exemption requests will be submitted for these areas.

NU's proposed fire barrier penetration seal re-validation program for Millstone Units 2 and 3 was discussed.

The staff expressed two concerns.

The first was that Northeast Utilities' (NU) approach would not implenent appropriate compensatory measures (i.e. fire watches) in a timely manner upon discovery that a fire seal (s) was not qualified by a representative fire test.

The staff used the analogy of existing technical specification surveillances to enphasize that fire watches should be implenented in a tinely manner. The staff suggested that other utilities approach to this issue would be a basis for resoluticn.

The second concern was that NU's reliance upon engineering evaluation to justify the adequacy of fire seals that are not fire rated per staff criteria wculd be difficult to implenent on a long tenn basis. However, this approach is sanctioned by guidance issued in Generic Letter 86-10, 8810170093 gggoo4 hDR ADOCK 05000213 PNU h

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2 Further discussions on the above issues are expected pending completion of NU's analysis.

Alan B. Wang, Project Parager Project Directorate I-4 Division of Reactor Projects I/II Attachtrents:

as stated

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Mr. Edward J. Mroczka

'onnecticut Yankee Atomic Power Company Haddam Neck Plant ec' Gerald Garfield, Esquire R. M. Kacich, Manager Day, Berry and Howard Generation Facilities Licensing Counselors at Law Northeast Utilities Service Company City Place Post Office Box 270 Hartford, Connecticut 06103-3499 Hartford, Connecticut 06141-0270 W. D. Rorberg, Vice President D. O. Nordquist Nuclear Operations Manager of Quality Assurance Northeast Utilities Service Company Northeast Nuclear Energy Company Post Office Box 270 Post Office Box 270 Hartford, Connecticut 06141-0270 Hartford, Connecticut 06141-0270 Kevin McCarthy, Director Regional Administrator Padiation Control Unit Region I Departrent of Environtrental Protection U. S. Nuclear Regulatory Comission j

State Office Building 475 Allendale Road l

Hartford, Connecticut 06106 King of Prussia Pennsylvania 19406 l

Bradford S. Chase, Under Secretary Board of Selectren Enargy Divisicn Town Hall office of Policy and Panagement Haddam, Connecticut 06103 80 Washington Street Hartford, Connecticut 06106 J. T. Shedlosky, Resident Inspector Hi.' dam Neck Plant D. B. Miller, Station Superintendent c,'o V. S. Nuclear Regulatory Comission Haddam Neck Plant Post Office Box 116 Connecticut Yankee Atomic Power Corrpany East Haddam Post Office I

RfD 1 Post Office Box 127E East Haddam, Connecticut C6423

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East Harpton, Connecticut 06424 I

G. H. Bouchard, tinit Superintendent Haddam Neck Flant RfD #1 Post Office Box 127E East Hampton, Connecticut 06424 G

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ATTENDANCE hE COMPANY PHONE NUMBiRS Alan Wang NRC/NRR 301-492-1313 Mike Ciccont Northeast Utilities / Licensing 203-665-5700 Dennis Kubicki NRC/NRR 301 492-0825 r

Jim Naylor Northeast Utilities / Fire 203-665-3795 Robert Andren Northeast Utilities /

203-444-5249 James Fountain Northeast Utilities 203-444-5304 Bohdan Pokora Northeast Utilities 203-665-5965 Mike Boyle NRC/NRR 301-492-1318 l

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DRAFT FIRE PROTECTION ENGINEERING EVALilATION CABLES ON SERVICE BtTILDING OLTTSIDE VALL Areas of Concern Redundant components (cabling) are located approximately 15 feet of each other.

Hovever, one set of cables are located outside the building. There is a vall which separates the cables from their redundant counterpart.

However, this vall is a nonrated, outside vall (floor to ceiling) constituted tif corrugated steel.

NRC Requirement l

Redundant cables / trains should be separated by a three hoitr fire barrier.

Evaluation 2

Inside Svitchgear Room o

Inside the Svitchgear Room the redundant component cabling is located vithin a MCC cabinet approximately 15 feet avay from the exterior vall.

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The Svitchgear Ron is protected by a total flooding Halon 1301 I

suppression system with a Priority Matrix detection smoke system.

o Combustibles are limited in the area of the exterior vall, Barrier Separation Area

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o The exterior vall consists of sheetmetal and insulation, f

o Extends floor to ceiling with no opening N

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outside Svitchgear Room, exposure harards are limited to structures and a vooden structure that is completely sprinklered.

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cables on outside of vall are located in conduit / cable trays.

Covers are provided on trays.

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s conclusion The physical separation, the shielding provided by the sheetmetal vall and 4

the fact that the cables are located outside the area (in conduit or covered cable trays) provides a reasonable amount of assurance that both j

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redundant components vill not be affected by the same fire.

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i In addition, the Halon system inside the room assures that fires inside the room are detected and extinguished in their earliest stage long before the l

integrity of the cabling outside is jeopardized.

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,y TURBINE BUILDING STRUCTURAL STEEL i

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o Area of Concern 7

Access to the steam hoggers must be maintained after a Turbine Bldg. fire.

Steam hoggers are located on the 37'-6" el. of the Turbine Bldg. and are required as an additional release path for steam during plant cool down.

To place the steam hoggers inservice, two valves must be manually operated.

The valves are located adjacent to the hoggers and can be operated with the i

loss of control air and pover.

NRC Requirement o

Cold shutdovn equipment must be repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

o Protection of structural steel such that building collapse does not occur.

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Hust enter fire area af ter fire is extinguished to manually operate steam hogger valve.

Evaluation i

o Steam hoggers are piping systems which ellov steam, from the steam W

generators, to be dumped to the condensor.

For this fire, steam j

hoggers vill be used as an additional steam removal path, i

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o Steam hoggers can be operated manually without assistance of electrical or control air systems.

o Operation of steam hoggers are not required for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> after the j!

event (fire)

starts, or 7 hou':s after the postulated fire is

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extinguished (vorst case App. R.)

o Most of the Turbine Building is protected by automatic suppression systems.

Hovever, there is one section adjacetit to the hoggers that is not protected.

For this area, there are no combuctibles present that could cause steel to collapse.

Based on past PLC Steel Ar.alysis I

i experience (lack of combustibles, no trays within 5' of steel), no j

steel damage vould occur based on fuel loading.

o There is at least two vays to get to the steam hogger.

I conclusion i

o Limited combustibles.

o Majot hazards protected by suppression system.

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Turbino Building Structurcl Stcel Pago 2 o

Building is protected by suppression syste:n.

o Steam hoggers do not require control air or electric systems to

operate, o

At least two means of access exist.

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1 DRAFT FIRE PROTECTION ENGINEERING EVALUATION h T' #

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9J"9 Area of Concern Gas fire, suppression system has been provided for the nev $vitchgear Room P lieu of the NRC recommended water suppression system for area of cable cone'ntration.

1 NRC Criteria i

NUREG-0800 Requirement 5.3.2. "... vater suppression for cable concentration areas should be provided."

Technical Justification i

There are several areas with concentrations of safety-related cables in the nev Svitchgear Building.

Two of the areas are cable shafts (approximately 30" x 30") each of which have several cable trays.

The suppression system in these shafts is described in the attached description of the cable shafts.

The nov Svitchgear Room vill have a total flooding halon 1301 j

suppression system in lieu of a vater suppression system.

In a Svitchgear

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Room environment, a halon system provides an acceptable alternate to a 1

sprinkler system for the following reasons:

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o Most fires vill origina.e as smokey fires f rom the cable insulation.

The smoke detectors vill actuate the halon system much faster than the 4

heat buildup vould actuate a sprinkler head.

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A fire in a svitchgear enclosure vould be shielded from the waterspray i

of a sprinkler head.

The halon gas vill enter the enclosure and extinguish the fire in its early stages of development.

o The Electrical and Operations Departments are more comfortable vith j

halon around high voltage equipment.

o Halon in svitchgear rooms is standard in the nuclear industry and has l

been found to be acceptable by the NRC in pass installation similar to i

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Inadvertent operation of the halon system should* hava no impact on i

plant operation / safety compared to inadvertent operations of a

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sprinkler system in any area of sensitive electrical equipment such as i

switchgear.

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DRAFT Summary Considering the above fire protection features, it is NUSCO's position that en ef fective fire suppression system vill be provided for the nature of the hazards involved.

JVNided 8/8/88 4

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DRAFT

.-9 FIRE PROTECTION g pvdg <; 4 o,

l ENGINEERING EVALUATION MENS' LOCKER ROOM SERVICE VATER CABLES Areas of Concern All four service water pump power cables come together in a duct bank i

located in the floor of the mens' locker room.

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NRC Requirement J

o Cables of redundant components required for hot shutdovn sust be

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protected such that one safety train vill be available for plant shut-dovn during and after a fire.

1 Evaluation i

o Service vater pump cable (Pump D) vill be run in a nev duct bank from the nev Svitchgear Building to an existing duct bank located belov the south vall of the mens' locker room.

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o The D pump cable must enter the existing duct bank at this point so that the cable can make its vay to the intake structure.

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o The cables vill join in a nev concrete junction box located belov the I

floor within manhole #3.

In this junction box a new service water pump I

l cable vill be spliced on to the existing "D" service water pump and i

travel out tn the intake structure in its own conduit (in the duct j

bank).

The only separation at this point to the intake strue'ure vill be the conduits in a cement duct bank which is considered a nev i

junction box (the new cable / conduit, at the bend into the junction box, l

j vill be the only exposed section of cables. The others vill be covered by existing concrete).

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No combustibles exist other than cables themselves.

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Area above duct bank and.' unction box u fully sprinklered.

o Locker room shovers, etc. in area, no reason to postulate transient combustible such as oil, etc. being in. area.

i Justification 1

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o Junction box is enclosed by concrete on three sides, t

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Area above junction box has full sprinkler protection.

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No combustibles, except. the one exposed cable, exist in ihe junction

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box.

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Transient combustible can not accumulate.

In the junction box there vill be cement between the conduits with only j

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the 'D" cable / conduit exposed.

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Mens' Locker Rotm Sorvico Vater Cables P:ge 2 9

Conclusion The protection afforded by the concrete, sprinklers, and conduit assure that at least one service water pump power cable vould survive any postulated fire.

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DRAFT J

i FIRE PROTECTION l

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ENGINEERING EVAL 11 TION Area of Concern k

i Unlabeled fire daor3r Iinstalled within the barriers separating the nev Svitchgear Room fro _m adjacent areas of the plant.

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NRC Criteria I

NUREG-0800 Requirement 5.a.5, "Door penetrations in fire barriers must have j

listed door assemblies rated the same as the barrier."

Technical Justification l

l This deviation addresses tvo tornado doors in the Svitchgear Room which do not have a U.L. 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> label.

These doors are located in the Svitchgear 1

Room leading to stairvells. The lack of a three U.L. label is mitigated by j

the folloving factors, and therefore vill provide adequate fire separation.

l The Svitchgear room is protected by an automatic total flooding halon i

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1301 system vhich vill prevent fire exposure to the door on one side.

Both of the doors letd to enclosed stairvells which normally have no j

combustibles that could threaten the door.

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The doors, by virtue of their ability to vithstand a tornado exposare.

are of heavy steel construction.

These doors are sinillar to vater 4

tight doors which have been found by the NRC to provide adequate fire j

separation in similar installations.

1 The general vicinity around the door on both sides vill be kept free of l

combustibles. Therefore, even if the door surface heats beyond that of l

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a standard fire door, there vill be nothing to ignite.

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I Suasary i

i Based on the construction details of the doors their location and the lack k

j of combustible loading in the general vicinity of doors, it is NUSCO's I

J position that the doors vill satisfy their intended funetton of providing i

adequate separation betveen fire area as well as prevent the spread of fire j

from Sne area to snother.

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e DRAFT FIRE PROTECTION ENGINEERING EVALUATION A M" W

Area of Cr>ncern Lack of floor drain in the Svitchgear and Battery Rooms.

NRC Criteria NI?.EG-0000 Requirement, 5.a.14 "Floor drains must be sized to remove expected firefighting (and fire suppression system) vater."

Technical Justification This deviation addresscs the lack of floor drains in the entire nev Svitchgear Bulloing.

In lieu of floor drains, a sump system has been installed in the basement (lov point) of the building.

Current plans call for directing vater from fire suppression ectivities it.to the stairvell so the vater can flov dovn to the sump.

The lack of floor drains vill not have a detrimental effect on firefightitg act;<ities or safety-related corponents for the following res:vns:

The Svitchgear Room is to be provided with an automatic total flooding halon 1301 system.

This type of system is de.ilgned to ef fectively extinguish a fire while it is still in an incipient stage.

The only firefighting vater that may be necessary is minor quantities for overhaul activities.

The cable shafts (tvo) have au omatic sp:inklers, hovever, the acumu, lation of vater in the bottom o' the shafts vill not affect the cables.

The water vill be removed via a drainage opening through the vall at the floor level.

See the attached description of the cable shafts.

The remainder of the building vill be provided with automatic sprinklers.

tiovever, none of these areas vill contain safety-related components which could be damaged by vater accumulation.

The sprinkler systee.s vill actually reduce the potential amcunt of water necessary for fire extinguishment as compared to the use of manual hose streams.

The Fire Brigade Pre-Fire Plan _ Strateries vill be vrit ten to refleet the lack of drains and provide the necessary instructions and' precautin"-

Summary Based on the above factors, the lack of floor trains in the nov Svitchgear Room vill not affeet safety-related (and/or safe shutdovn components) nor unduly hamper fire fighting activities.

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DRAFT FIRE PROTECTION E_NGINEERING IVALUATION i

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j Area of Concern i

Lack of a seismically deslaned standnina avstem in the nov Svitchgear j

Sullding.

1 NRC Criteria a

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NUREG-0800 Requirement 6.c.4.. "Standpipes should be capable of supplying f

j vater after a safe rhutdovn earthquake."

Technical Justiffeation

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i The standpipes in the nov Svitchgear Building are not to be seismically l

supported, for the folloving reasons:

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Due to the requirements in effect at the time the plant was built, the j

underground was not required to be seismic at that time.

1 The standpipe is not located over any safety related/ safe shutdovn j

components that falling pipes or flooding could affect.

6 Other means of manual fire suppressior (fire extinguishers) are readily 1

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available to support fire extinguishment in the area based on tre postulated fire for the area.

J Summary

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Loss of the standpipe system due to a seismic event veuld not totally impact the fire brigades' capability to ef fectively extinguish a fire in the safety related areas of the nev svitchgear building, j

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DRAFT M

FIRE PROTECTION i

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3 ENGINEERING EVALUATION Area of. Concern 14ck of fire detection in the new Svitchgear Building cable shaf ts which contain safety related cabling.

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i NRC Criteria NUREG 0800 Requirement 6.9.1, "Detection is necesssary in all areas containing or exposing safety related/ safe shutdown components."

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Technical Justification i

The svo cable shafts, which each contain two cable trays with safety-i related/ safe shutdown components, are not provided with smoke detection.

j Heat detection is provided in the form of 165'T sprinkler heads (part of 4

vet pipe sprinkler system) vith a flov alarm svitch installed at the base of the riser.

The alare is to be annunciated to the Control Room.

This 1

detection configuration provides adequate protection for the folloving reasons:

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Sprinkler heads are actually very reliable fixed temperature heat detectors (165'T in thin case).

I The flov svitch provides an alarm to the Control Room via a supervised

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circuit.

The flov svitch is tested as part of the inspector's test surveillance.

The sprinkler heads are to be located at the top of the shaft for fast response. The shalt sire. 30" x 30", is so small that the sprinkler l

f head should respond quickly to any type of fire in its early stages.

Due to the configuration of the shaft, a smoke detector vould be l

difficult to test.

The fire seals vould have to be removed.

This vould result in the eventual degradation of the seal.

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The proposed design (165'T flusible link sprinkler heads) vill provide both j

early detection as well as suppression capability in the two shaft areas.

Therefore, it can be concluded that this de' sign vill satisfy the intent of 4

providing early varning of a fire condition in safety related areas.

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DRAF1 FIM PROTECTION f

ENGINEEMNG EVALUATION 1ACK OF DETECTION IN VDB PASSAGEVAT I

e6 Areas of Concern i

i A section of the Vaste Disposal Building passagevay contains 1 division of RHR and charging pump cables.

This area is not provided with automatic

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detection systems.

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NRC Requirement i

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BTP 9.5.1 Section C.5.a requires...

"Area fire detection systems should be provided for all areas 4

l that contain, or present potential fire exposure to, safety-1 related equipment."

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Evaluation o

One division of RHR and Charging system cable pass in this area.

j Alternate divisions exist in other areas.

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o Cables in question are installed in conduit.

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No exposad cables / cable trays, etc. in immediate area.

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Cembustible loading is negligible. There are no fire exposure l

concerns.

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o Due to laddered entrance, area not subject to transient combustibles.

o Radiation control Area. activity is limited.

o Area is surrounded by concrete construction.

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o llo/lov fire loading.

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o Transient combustible eliminated from area.

o opposite division of componsnts exist in separate fire area.

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bRAFT FIRE PROTECTION k af ENGINEERING EVALUATION USE OF MI CABLE Areas of Concern In order to provide fire separation inside CY's Containment Cable Vault, fire rated HI cable is proposed for certain Appendix R cables.

NRC Requirement Use of MI cable as a substitute for ont hour vrap requires an exemption.

t Evaluation The folloving describes the planned use of Mineral Insulated (MI) Tire Cable in the Connecticut Yankee (CY) Cable Vault (CV). This description is provided as the bases of an exemption request to approve the use of this cable to meet Appendix R requirements in the CV.

The redundant train of safs shutdovn instrumentation must be capable of withstanding a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> fire with suppression and detection (per Appendix R. section II.G.2.c).

• MI cable vill be used to transmit one set (Train B) of Appendix R safe shutdovn parameters through the CY cable vault.

This set of fire shutdovn parameters vill be utilized during CV fires.

The MI cable has been successfully UL tested in accordance with ASTM Standard E119 for a three

(*. hour fire rating.

The cable vill be provided by Combustion Engineering and is the same type used for the CY in-containment fire protected safe shutdovn instrumentation (train A).

This MI cable ves previously approved by the URC for outside of containment, Appendix R use at our Millstone I plant.

The transitiun from containment to the CV vill be made

,a special velded penetrations which incorporate the fire qualified MI cabla.

The MI cable vill be routed from the penetration, up the CV containment vall, across the CV ceiling, and dovn the facing vall to the nov duct bank.

MI cable vill also be routed from the Auxiliary Feed Pump room through the CV ceiling through approved fire stops to the new duct, bank.

The routing of the cable vill be such that falling debt resulting f rom the CV fire vill niet affect the integrity of the MI cable.

'.he MI cabli vill be fastened to the cable vault surfaces using unistrut and tubing clips. This fastening method has been qualified as part of the MI cable fire qualification, o

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Uso of MI Cablo pHM N.'6MV* \\N "UI O "

j Page 2 the transition from MI cable to organic cable vill take place within a tre

_ protected enclosure covering the ducts which vill carry the Appendix l

Traan a signa 4s n om Inw sv.

T.... udosure vill be fira 3 otected to reet Appendix R, section II.G.2.c. using accepted fire prot.ction methods. This enclosure vill also be protected as necessary from fellfug debris resulting from a CV fire.

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The attached sketch is provided to illustrate this scheme.

l In addition the inheterent fire protection feature of the cable, the area

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has an automatie total flooding CO, system which provides early varning and 3

fire suppression capabilities.

t conclusion l

The use of HI cable in the cable vault provides equivalent protection to 4.

that which vould be provided by one hour cable vrap.

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CY o Anoendix R Effort Cable Vault MI Cable Routina Scheme

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DRAFT FIRE PROTECTION EEGINEERING EVALUATION ELIMINATION OF 'IS REQUIREMENT FOR FIPS VALL BE"TVEEN THE STATION BATTERIES Area of Co'cern Presently, CY's Fire Protection License Condition requires the vall (shield vall) between batteries A & B, in the Svitchgear Room, be controlled as a TS fire barrier.

Vith the removal of battery A to the "new" Switchgear Room, the vall no longer needs to be controlled.

NRC Requirement Section 3.1.15 of CY's Appendix A SER requires a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> fire vall (shield vall) be installed and maintained between the two station batteries in the Svitchgear Room.

Evaluation o

In 1980, the imC requested a fire vall be installed between the two station batteries, such that if one battery became involved in fire, the second would be protected from the effects.

o As part of the new svitchgear project the following changes vill occurs a) Battery A vill be physically removed from the existing Svitchgear Room.

b) Battery B vill remain in its present location and be renamed as Battery 1A.

c) Battery C (non safety related), which is presently located in the old Svitchgear Room vill be energized and used for non-essential loads.

d) A new battery bank vill be installed in the new Svitchgear Building Battery Room and vill be identified as 1B.

o Due to the fact that Battery A vill be removed from the area and Battery C doesn't present an exposure concern to Battery B or the svitchgear equipment, the need to' retain the subject vall is eliminated.

o The area (old svitchgear room) has a nev automatic total flood Halon system which vill detect and suppress a svitchgear room fire in its j

earliest stages.

Conclusion Once battery A is removed from the old svitchgear room, protection /

separation of redundant batteries vill be satisfied.

There vill a no need to maintain the shield vall as a T.S. fire barrier.

AWP/JWNided 8/25/88 Icl.21)

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