ML20215G682
| ML20215G682 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 10/10/1986 |
| From: | Bailey J SOUTHERN COMPANY SERVICES, INC. |
| To: | Youngblood B Office of Nuclear Reactor Regulation |
| References | |
| GN-1108, NUDOCS 8610210060 | |
| Download: ML20215G682 (9) | |
Text
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Southem Ccmpany Servces. Inc.
Post offca Box 282 W:ynesboro, Georgia 30830 Te:aphone 404 7221543 I
404 722 3943 Vogtle Project October 10, 1986 Director of Nuclear Reactor Regulation File: X3BL01 Attention:
B. J. Youngblood Iog: GN-1108 Licensing Branch #4 Division of Licensing U. S. Nuclear Regulatory Comission Washington, D. C. 20555 NRC DOCKET NUMBERS 50-424 AfD 50-425 CONSI'RUCTION PERMIT NUMBERS CPPR-108 AND CPPR-109 VCOTLE ELECTRIC GENERATING PLAIE - UNITS 1 AND 2 FIRE PROI'ECTION
Dear Mr. Dentor:
Confirm 11ng our conversations-with your staff on October 6 thru 10,-1986, Georgia Power Compsny is planning to revise the PSAR to address certain fire protection issues.
Attachment A to this letter is a description of the upcoming changes.
Should you require additional infomation, please let me know.
Sincerely, J. A. Bailey Project Licensing ihnager JAB /adg Attachments
.xc w/att.:
R. E. Conway R. A. '1homas B. W. Churchill, Esq.
J. E. Joiner, Esq.
M. A. Miller L. T. Gucwa G. Bockhold, Jr.
B. Jones Esq.
O. Batum R. W. McManus D. Feig NRC Regional Adminstrator NRC Resident Inspector 8610210060 861010 PDR ADOCK 05000424 I \\
F PDR
10-0CT-86 ATTACID Eff A CHARCOAL FII1TER PROTECTION The FSAR states (Appendix 9B, page 9B-68 and Section 9.5.1, page 9.5.1-8). that-the Vogtle Electric Generating Plant (VEGP) charcoal filters are equipped with an automatic heat detection system with a manually initiated deluge system. The FSAR will be revised to reflect the modification of the water supply to the-filter to install either a blind flange with a spool of pipe removed or the installation of a spectacle flange.
These modifications effectively block flow to the filter.
This modification was made to ensure that an inadvertent initiation of the water spray cannot occur.
In the event of an alarm indicating a possible ' fire in the charcoal bed an operator will investigate.
If the investigation confims the presence of a fire, the airflow through the filter will be shut off, thus starving the. fire and stopping the combustion process.. Maintenance personnel will then install the spool pieces or reverse the spectacle flange using tools normally available for maintenance work. After spool piece installation or spectacle flange reversal, 1
the block valve can be opened from the control room to permit water flow into the filter.
The presence of other fire suppression in the general area of the filter (hose, sprinklers or both), will assure that the filter housing can be cooled to assure that any internal fire does not spread to other materials in the fire zone and to assure that the operator is not exposed to excessive heat in the installation of the spool pieces.
DIESEL DAY TANK HA'ICH The FSAR states in Appendix 9B (Pages 9B-94, and 9B-95) that the VEGP diesel generator day tanks meet the criteria of both paragraphs (1) and (2) under CMEB Section C.7.1.
This will be revised to indicate that the diesel day tank meets the paragraph (2) criteria for diked enclosures and meets paragraph (1) except for a non-rated hatch cover.
'Ihe hatch cover is a fire door installed in an untested horizontal configuration rather than the tested vertical configuration.
In addition, a sprinkler system is installed in the day tank enclosure and in the diesel generator room above the hatch.
'1his does not constitute an additional deviation from CMEB 9.5-1 because the installed configuration complies with paragraph (2); however, FSAR Appendix 9A will be revised to reflect that the fire area boundary (tank room ceiling) between the diesel generator room and the day tank room is not a rated barrier. !
10-0CT-86 SAFEN-RELATED PUMP SPRINKLERS The FSAR states in Appendix 9B (Page 9B-95) that automatic suppression has been provided for all rooms containing safety-related pumps. 7his will be amended to indicate that automatic suppression has been provided for all but three safe shutdown related pump sets.
In the cases where no autcriatic suppression is supplied, the redundant safe shutdown pumps are separated by 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire barriers. This change does not constitute an additional deviation fecri CMEB 9.5-1 since the fire hazards analysis demonstrates separation from redundant equignent.
COMMUNICATIONS FSAR Appendix 9B (Page 9B-69) lists the CMEB 9.5-1 criteria for portable radio comunications. No VEGP position in currently stated. The FSAR will be revised to note that the fire team will be equipped with radios, but that the repeater power supplies are not backed by an onsite power source.
The plant comunication systems are discussed in FSAR section 9.5.2.
These systems will be utilized for comunication under fire conditions.
It is highly unlikely one fire could destroy all ccuriunication system in or around the operation action location. To ensure that the sound powered phone circuit is available when required for alternative shutdown (for a control room fire) 1' solation switches will be installed outside the control room.
For fires outside the control room, no comunications are required for safe shutdown because the necessary operator actions do not require coordination with the control room. '1hese operator actions do not require comunication because the action taken is an on/off operation (i.e., no controlling function), additional parameters are available in the control room to determine if action has been performed or the actions are required for a cold shutdown (i.e., RHR operation).
CONI'ROL ROOM LIGHTING The FSAR currently states'(page 9B-69) that VEGP confo ms with the CMEB 9.5-1 requirement that 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> sealed beam lights be provided for all areas which must be manned for safe shutdown. This is true for all areas except the main control board. The control board lighting is described in FSAR Section 9.5.3.2.3.
7he circuits for the power to the lights have been analyzed as safe shutdown circuits. It has been detemined that the circuits are separated such that any fire outside th? control roca complex will not disable both trains of lighting.
Thus for fires for which shutdown is accomplished for the control room the existing emergency lighting will assure that adequate lighting is maintained.
Fires inside the control room complex may disable both trains of essential lighting power.
In this event, the existing ~ battery backup (1 1/2 hours) is adequate to ensure an orderly transfer of control to the alternative' shutdown panels. _.
10-OCT-86 The PSAR will be revised to indicate that VEGP does not conform with CEB 9.5-1 at the main control b6ard but for the above reasons is adequate. Reference to the sealed beam lighting at the main control board will also be deleted from Section 9.5.3.2.3.
PLASTIC USAGE The use of plastic materials is currently addressed on page 9B-60 of the FSAR.
The list of items which contain plastics' (including PVC) will be modified to include a small amount of PVC drain piping.
This addition is being made for clarification only and does not constitute an additional request for deviation approval.
EARLY-WARNING'PIRE DETTECTORS Appendix 9A contains a detailed listing of fire detector types installed in each fire zone. To avoid confusion, these detailed listing will be replaced with the term "early warning fire detector".
This change does not constitute an additional deviation from CMEB 9.5-1 since the criteria address " detection" rather than specific types of detection.
OUTDOOR EMERGENCY LIGHTING Appendix 9B of the FSAR does not address the placement of 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> emergency lighting for outdoor access routes.
This will be revised to state that VEGP does not provide 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> battery powered emergency lights for outdoor areas. The outdoor areas will be lighted by the security lights which are powered from the independent security diesel generator.
Additionally, a set of battery powered hand lights (flashlights) will be maintained for operator and fire team use in these areas.
MODIFIED POST INDICATOR VALVE The FSAR states in Appendix 9B (Page 9B-73) that approved visual indicating sectional control valves have been provided for isolation of the portions of the fire main. Certain post indicator valves have been modified to remove the valve posts from the security intrusion detection field. These " cut-off" valves have
'been equipped with indicators that show the valve status; however, the indicators are not approved for fire service.
The FSAR will be modified to reflect this change.
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10-0CT-86 CONCEALED SPACFE The FSAR states in Appendix 9B (Page 9B-47) that all concealed spaces are devoid of combustibles. The following description of the concealed space combustibles will be added by amendment:
Concealed spaces are devoid of combustible materials to the extent practicable.
Electrical cables in conduit are not considered as. combustible material. 'Ihe existence of combustible material above the main control room dropped ceiling and below the raised floor areas are discussed in Appendix 9B Section c.7.b.
The space below the control room raised floor section does not contain detection or suppression systems. The Technical Support Center has raised floors with exposed electrical cables in the computer, CRT display and the comunication roons as do the plant computer rooms.
These rooms and their raised floor sections are provided with fire detection systems and are protected by automatic halon fire suppression systems. Some of the rooms on levels 1 and 2 of the control building have combustible material 1.ocated above the suspended' ceilings.
In many cases the combustible material is minimal (HVAC damper operators, small fans, electrical heaters) and the damage potential presented is relatively insignificant. When the concealed combustibles are electrical cables in cable trays, the cable trays are encloaed (solid metal bottom, and covers) to ensure that a fire, should one occur, is ventilation controlled. 'Iherefore, a low combustion rate and fire intensity will make fire fighting in the concealed space easier. Where combustible material is present in a concealed space, fire detectors are provided to alert the plant operators of a fire should a fire occur. Where the electrical cables are safety related, only one safety division is present. Fire detection annunciation is provided at each local detection panel and the control room by zones.
FIRE PROI'ECTION TECHNICAL SPECIFICATIONS
'Ihe fire protection criteria have been deleted from the VEGP Technical Specifications. A new table ~ 9.5.1-10 will be submitted in the upcoming FSAR amendment. This table will contain the requirements which have been included in the fire protection technical specifications in the past. 'Ihese provisions will be based upon the standard Technical Specifications as customized for VEGP.
SEISMIC GAP FIRE DAMPERS The PSAR states that fire dampers are installed in ventilation penetrations of rated fire area boundary barriers.
Four penetrations have been identified in which the fire area boundary consists of two adjacent building walls separated by a seismic gap with a fire damper installed in only one wall. Two fire area boundary interfaces are involved. These instances will be detailed in Appendix 9A as follows:
10-0CT-86 Fire Area 1-AB-LD-A No fire dampers are installed in the two ventilation duct penetrations in the north auxiliary building wall of this fire area between column lines A14 and A16 at elevation 215 feet (approximately).
'Ihis wall is a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated fire area boundary barrier which separates this fire area from the seismic gap between the auxiliary building and the fuel handling building. 'Ihis deviation is acceptable because:
a.
Fire dampers are installed in these ventilation ducting penetrations in the south wall of the fuel handling building wnich will isolate fire area 1-FB-LC-A (adjoining fire area) from the seismic gap and from this fire area.
b.
'Ihe interconnecting ducting between the fuel handling building fire damper sleeve and the ventilation ducting penetration through the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated fire barrier of this area are non-combustible flexible material or sheet metal ducting, c.
'Ihere is no combustible material in the immediate vicinity of the ventilation penetrations within this fire area.
d.
While the seismic gap does contain some combustible material (exposed electrical cable insulation) it is a small quantity (relative) and an exposure fire within this area is not considered credible as the area is not accessible (seismic gap is approximately 5 1/2 inches wide),
e.
Safe shutdown capability is not jeopardized. Only train B safety related cables exist inside the seismic gap and train B safe shutdown cables and equipment exist in fire area 1-AB-LD-A.
Modifications of the plant to provide rated fire dampers in these ventilation penetrations would not significantly increase the level of protection provided by the existing design.
10-ocT-86 A
i Fire Area 1-CB-L4-A-i No fire damper in a rated fire area boundary barrier:
i No fire. dampers are installed in two ventilation ducting penetrations in the south control building wall of-this fire area near column lines, C13 and 010 (one near each) at elevation 281 feet.
his wall is a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> ~ rated fire
' area boundary barrier which separates. this fire. area from the seismic gap between the control building and the fuel handling building. Bis deviation is acceptable because:
i a.
Fire dampers are installed in these ventilation ducting l
penetrations in the north wall of the fuel handling building which will isolate fire area 1-FB-L3-A and 1-AB-LD-B (adjoining fire area) from the seismic gap and from this fire area.
i b.
%e interconnecting ducting between the fuel handling building fire damper sleeve and the ventilation ducting penetration through the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated fire barrier.of this area is noncombustible flexible material or sheet metal ducting.
c.
Were is no combustible material in.the imediate vicinity of the ventilation penetrations within this fire area.
d.
While the seismic gap does contain some combustible material (exposed electrical cable insulation) it is a 4
small quantity (relative) and an exposure fire within i
this area is not considered credible as the area is not accessible (seismic gap is approximately 5 1/2 inches wide).
e.
Safe shutdown capability is not jeopardized as the safety-related cables inside the seismic gap are Train B and fire area 1-CB-L4-A does not contain any safe shutdown equipnent or cables.
Modification of the plant to provide. rated fire dampers in these ventilation penetrations would not significantly increase the level of protection provided by the existing design.
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m 10-0CT CONPROL ROOM CEILIMI
-Appendix 9B of the PSAR describes the control room fire detection system (Page 9B-89). A clarification will be added to the. description to note that no smoke detectors are to be installed below the modular ceiling in the main control board area. '1he modular ceiling is the ventilation supply for the control board work space. '1he air movement pattern in the vicinity of the ceiling would.
prevent smoke detection in that area.
his is not a deviation from the NFPA
' code and is presented as a clarification only.
OVERSIZED PENFJfRATION SFAIS An issue was discussed with the NRC concerning the presence of subdivided sealed fire barrier penetrations. '1his issue will be addressed by a future letter.
SPRINKLER SYSTEMS
'Ihe VEOP Safety Evaluation Report (SER) states (Page 9-52) that " wet pipe" sprinkler systems meet appropriate fire code. The sprinkler systems at VEGP are generally preaction systems. The words " wet pipe" should be deleted from the SER. This infomation is forwarded for clarity.only and does not constitute a deviation report.
WATER SPRAY SYSTEMS (NFPA-15)
The FSAR addresses compliance with NFPA-15 in Table 9.5.1-9 and Appendix 9B (Page 9B-79). '1he FSAR will be revised to note that the protection of cable trays is accomplished by utilizing the guidance of NFPA 15; but with closed directional spray nozzles rather than the NFPA 15 open spray nozzles. '1his is done to minimize the possible effect of' water spray onto safety-related equipment.
10-0CT-86 SPRINKLER SYSTEM DESIGN 1
FSAR Appendix 98 and Table 9.5.1-9 address the VEGP compliance with NFPA 13 for sprinkler system design.
Due to the complexity of the plant, the determination of compliance with NFPA 13 is based in part upon the professional judgment of qualified fire protection engineers.
In recognition of this, the description in the FSAR will be revised to indicate that VEGP is in compliance with the. codes or will be evaluated by a registered fire protection engineer to provido an acceptable level of protection.
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