ML20209F677

Forwards Staff Position on Fire Protection for Charcoal Filter Units.Applicant Should Conduct Detailed,Valid Fire Hazard Analysis for Each Area Containing Filter Unit

ML20209F677
Person / Time
Site:	Seabrook
Issue date:	09/08/1986
From:	Noonan V Office of Nuclear Reactor Regulation
To:	Harrison R PUBLIC SERVICE CO. OF NEW HAMPSHIRE
References
NUDOCS 8609120227
Download: ML20209F677 (7)

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, 0 8 SEP 193 Docket Nos.: 50-443 and 5 0-444 Mr. Robert J. Harrison President & Chief Executive Officer Public Service Company of New Hampshire P.O. Box 330 Manchester, NH 03105

Dear Mr. Harrison:

In several of our recent fire protection reetings and telecons with your staff, we have consistently stated our position concerning fire protection for the Seabrook Unit I charcoal filter units.

Information we have received from your staff intending to address and resolve our concerns regarding fire protection of the charcoal filter units continues to be insufficient. On this basis, we feel it appropriate to document (Enclosure) our concerns including our position on this issue.

, Ouestions or additional information regarding this matter should be directed to the Seabrook Project Manager, Mr. V. Nerses (301-492-8535).

, Vincent S. Noonan, Director PWR Project Directorate No. 5 Division of PWR I.icensing-A

Enclosure:

As stated l

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Docket Nos.: 50-443 and 50-444

Mr. Robert J. Harrison President & Chief Executive Officer Public Service Company of New Hampshire P.O. Box 330 Manchester, NH 03105

Dear Mr. Harrison:

In several of our recent fire protection meetings and telecons with your staff, we have consistently stated our position concerning fire protection for the Seabrook Unit I charcoal filter units.

Information we have received from your staff intending to address and resolve our concerns regarding fire protection of the charcoal filter units continues to be insufficient. On this basis, we feel it appropriate to document (Enclosure) our concerns including our position on this issue.

Questions or additional information regarding this matter should be directed to the Seabrook Project Manager, Mr. V. Nerses (301-492-8535).

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, nan, U1. rector WR Proj Directorate No. 5 Division f PWR t.icensing-A

Enclosure:

As stated cc: See next page I

. Enclorurs

, STAFF POSITION SEABROOK STATION FIRE PROTECTION PROGRAM CHARC0AL FILTER UNITS Staff Concerns In Section E.2, " Review Assumptions," of its report entitled "Seabrook Station Fire Protection Program - Evaluation and Comparison to BTP APCSB 9.5-1, Appendix A," the applicant for Seabrook Station states:

" Air cleaning units, which contain roughing filters, HEPA filters and charcoal filters, are contained in heavy metal casings and are not considered in the fire hazard analysis."

The applicant has not provided a sufficient technical basis relative to the NRC's guidelines and regulations to support this position. The staff believes that the applicant has not (1) adequately considered the potential fire hazards associated with the station's charcoal filter units or (2) determined the consequences of a fire in a charcoal filter unit on the ability to safely shutdown the reactor.

Licensing Basis (Fire Protection)

General Design Criterion 3 (GDC 3), " Fire Protection " of Appendix A to 10 CFR 50, requires that structures, systems, and components important to safety be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosives. GDC 3 also requires that fire detection and suppression systems of appropriate capacity and capability be provided and designed to minimize the adverse effects of fire on structures, systems, and components important to safety. The combination of the guidance contained in Appendix A to BTP APCSB 9.5-1 and the technical requirements set forth in Appendix R to 10 CFR 50 define the essential elements of an acceptable fire protection program at nuclear power plants docketed for a construction permit before July 1, 1976, for demonstration of compliance with GDC 3 of

Appendix A to 10 CFR 50. Therefore, the staff has used the technical require-

! ments of Appendix R to 10 CFR 50 and Appendix A to BTP APCSB 9.5-1 as guidelines in its evaluation of the applicant's fire protection program for Seabrook Station.

Section II.B. " Fire Hazards Analysis," of Appendix R to 10 CFR 50 states:

"A fire hazards analysis shall be perfonned by qualified fire protection and reactor systems engineers to (1) consider potential in situ and transient fire hazards; (2) determine the consequences of fire in any location in the plant on the ability to safely shutdown or on the ability to minimize and control the release of radioactivity to the environment; and (3) specify measures for fire prevention, fire detection, fire suppression, and fire containment and alternative shutdown capability, as required, for each fire area containing structures, systems, and components important to safety, in accordance with NRC guidelines and regulations."

. In addition, Section A.2, " Design Bases," of Appendix A to BTP APCSB 9.5-1 states:

"The overall fire protection program should be based upon evaluation of potential fire hazards throughout the plant and the effect of postulated design basis fires relative to maintaining ability to perform safety shut-down functions and minimize radioactive releases to the environment".

Fire Hazards Analysis In the staff's opinion, charcoal filter units represent in situ fire hazards that should be separately identified in the fire hazards analysis. The staff would expect the applicant to conduct a detailed evaluation for each fire area in which a charcoal filter unit is located. As a minimum, the staff considers the following baseline parameters during its evaluations and, therefore, expects that the applicant would address each of the parameters in its fire hazards analysis / fire area evaluation:

A. Area Description

- walls, floor, and ceiling construction

- ceiling height

- room volume ventilation

- congestion B. Safe Shutdown Capability

- number of redundant systems in area whether or not system or equipment is required for hot shutdown

- type of equipment / cables involved

- repair time for cold shutdown equipment within this area separation between redundant components and in situ concentration of combustibles alternative shutdown capability C. Fire Hazards i -

type and configuration of combustibles in area

- quantity of combustibles

- ease of ignition and propagation

- heat release rate potential

- transient and installed combustibles

- suppression damage to equipment

- whether the area is continuously manned

- traffic through the area

- accessibility of the area D. Fire Protection Existing or Committed

- fire detection system

- fire extinguishing systems hose station / extinguisher

- radiant heat shields

Because establishment of specific design basis fires for individual fire areas is a prerequisite to performance of a valid fire hazards analysis, the staff would expect the applicant to postulate a fire in each charcoal filter unit and determine the effects of the postulated fire on maintaining the ability to perform safe shutdown functions to meet Section II.B of Appendix R to 10 CFR 50 and Section A.2 of Appendix A to BTP APCSB 9.5-1. The staff would also expect the applicant to provide appropriate protection in those areas where safe shutdown-related losses can occur. The fire hazards analysis should clearly demonstrate what fire protective features should be provided in each fire area to mitigate the consequences of a fire in that area.

In the staff's judgement, the applicant's fire hazards analysis does not accomplish this for those areas that house charcoal filter units and safe shutdown-related systems. Therefore, the staff does not have reasonable assurance that a charcoal filter fire at Seabrook Station will not adversely affect the facility's safe shutdown capability.

Additional guidance is available to the applicant in Generic Letter 81-12

" Fire Protection Rule," dated February 20, 1981, and Generic Letter 86-10

" Implementation of Fire Protection Requirements," dated April 24, 1986.

Previous Staff Approvals It appears that the staff approved deviations from providing area automatic fire suppression systems in areas that contain both charcoal filter units and redundant safe shutdown systems without prior knowledge of the presence of the filter units. Knowledge of the presence of these filters would have been considered in the staff's evaluation and could have affected the conclusions reached by the staff.

Conclusion To resolve the staff's concern, the applicant should (1) conduct a detailed, valid fire hazards analysis for each fire area that contains a charcoal filter unit in accordance with Section II.B of Appendix R to 10 CFR 50 and

, Section A.2 of Appendix A to BTP APCSB 9.5-1, and (2) provide additional appropriate fire protective features in those areas, if any, where the fire hazards analysis does not clearly demonstrate that the currently available fire protection features are adequate to protect against safe shutdown related losses in the event of a charcoal filter unit fire. Alternatively, the applicant could technically justify its position that the charcoal filters need not be considered in the fire hazards analysis. However, based on its many discussions with the applicant, the staff does not believe the applicant will be able to do so.

The absence of any resolution of this matter as discussed above will require the staff to reopen its review of the deviations previously approved; which entail not providing area suppression in those fire areas that contain char-coal filter units.

In the staff's opinion this issue should be resolved prior to the issuance of a low power license. However, should modifications be required, the staff would entertain a commitment from the applicant to complete the modifications by a specified date, not to extend beyond 5 percent of full rated power, and condition the operating license accordingly.

. Mr. Robert J. Harrison

', Public Service Company of New Hampshire Seabrook Nuclear Power Station cc:

Thomas Dignan Esq. E. Tupper Kinder, Esq.

John A. Ritscher, Esq. G. Dana Bisbee, Esq.

Ropes and Gray Assistant Attorney General 225 Franklin Street Office of Attorney General Boston, Massachusetts 02110 708 State Hosue Annex Concord, New Hampshire 03301 Mr. Bruce B. Beckley, Project Manager Public Service Company of New Hampshire Resident Inspector Post Office Box 330 Seabrook Nuclear Power Station Manchester, New Hampshire 03105 c/o US Nuclear, Regulatory Commission Post Office Box 700 Dr. Mauray Tye, President Seabrook, New Hampshire 03874 Sun Valley Association 209 Sumer Street Mr. John DeVincentis, Director Haverhill, Massachusetts 01839 Engineering and I.icensing Yankee Atomic Electric Company Robert A. Backus Esq. 1671 Worchester Road O'Neil, Backus and Spielman Framingham, Massachusetts 01701 116 1.owell Street Manchester, New Hampshire 03105 Mr. A. M. Ebner, Project Manager United Engineers & Constructors William S. Jordan, !!! 30 South 17th Street Diane Curran Post Office Box 8223 Hamon, Weiss & Jordan Philadelphia, Pennsylvania 19101 20001 S Street, NW Suite 430 Washington, D.C. 20009 Mr. Philip Ahrens, Esq.

Assistant Attorney General State House, Station #6 Augusta, Maine 04333 Jo Ann Shotwell, Esq.

Office of the Assistant Attorney General Environmental Protection Division i Mr. Warren Hall One Ashburton Place Public Service Company of Boston, Massachusetts 02108 New Hampshire Post Office Box 330 D. Pierre G. Cameron, Jr. , Esq.

Seabrook, New Hampshire 03874 General Counsel Public Service Company of New Hampshire Seacoast Anti-Pollution t.eague Post Office Box 330 Ms. Jane Doughty Manchester, New Hampshire 03105 5 Market Street Portsmouth, New Hampshire 03801 Regional Administrator, Region !

U.S. Nuclear Regulatory Commission Mr. Diana P. Randall 631 Park Avenue i 70 Collins Street King of Prussia, Pennsylvania 19406 Seabrook, New Hampshire 03874 j Richard Hampe Esq.

l New Hampshire Civil Defense Agency 107 Pleasant Street Concord, New Hampshire 03301

L Public Service Company of Seabrook Nuclear Power Station

. New Hampshire cc:

Mr. Calvin A. Canney, City Manager Mr. Alfred V. Sargent, ,

City Hall Chairman }

126 Daniel Street Board of Selectmen '

Portsmouth, New Hampshire 03801 Town of Salisbury, MA 01950 Ms. I.etty Hett Senator Gordon J. Humphrey Town of Brentwood ATTN: Tom Burack '

RFD Dalton Road U.S. Senate Brentwood, New Hampshire 03833 Washington, D.C. 20510 Ms. Roberta C. Pevear Mr. Owen B. Durgin, Chairman Town of Hampton Falls, New Hampshire Durham Board of Selectmen Drinkwater Road Town of Durham Hampton Falls, New Hampshire 03844 Durham, New Hampshire 03824 l

Ms. Sandra Gavutis Charles Cross, Esq.

Town of Kensington, New Hampshire Shaines, Mardrigan and RDF 1 McEaschern East Kingston, New Hampshire 03827 25 Maplewood Avenue Post Office Box 366 Chairman, Board of Selectmen RFD 2 South Hampton, New Hampshire 03827 Mr. Guy Chichester, Chaiman Rye Nuclear Intervention Mr. Angie Machiros. Chairman Committee Board of Selectmen c/o Rye Town Hall for the Town of Newbury 10 Central Road Newbury, Massachusetts 01950 Rye, New Hampshire 03870 Ms. Cashman, Chairman Jane Spector Board of Selectmen Federal Energy Regulatory Town of Amesbury Comission Town Hall 825 North Capital Street, NE Amesbury, Massachusetts 01913 Room 8105 Honorable Peter J. Matthews Mayor, City of Newburyport Mr. R. Sweeney Office of the Mayor New Hampshire Yankee Division City Hall Public Service of New Hampshire Newburyport, Massachusetts 01950 Company 7910 Woodmont Avenue Mr. Donald E. Chick, Town Manager Bethesda, Maryland 20814 Town of Exeter 10 Front Street Mr. William B. Derrickson Exeter, New Hampshire 03823 Senior Vice President Public Service Company of New Hampshire Post Office Box 700, Route 1 Seabrook, New Hampshire 03874 l

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