ML20244D992
| ML20244D992 | |
| Person / Time | |
|---|---|
| Site: | Seabrook, 05000000 |
| Issue date: | 06/16/1986 |
| From: | Rossi C Office of Nuclear Reactor Regulation |
| To: | Nerses V Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20235T530 | List:
|
| References | |
| FOIA-87-51 GL-86-10, NUDOCS 8606240346 | |
| Download: ML20244D992 (21) | |
Text
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j Docket Nos.:
50 443/444 h
DISTRIBUTION l
Docket Filc 4 MEMORANDUM FOR: Victor Nerses, Senior Project Manager PSB Docket File PWR Project Directorate No. 5 PSB Reading File Division of PWR Licensing - A S. West T. Quay FROM:
Charles E. Rossi, Assistant Director J. Shapaker Division of PWR Licensing - A J. Milhoan C. Rossi
)
SUBJECT:
FIRE PROTECTION INPUT FOR SUPPLEMENT 5 TO THE SEABROOK STATION, UNITS 1 AND 2 SAFETY EVALUATION REPORT Applicant: Public Service Company of New Hampshire Plant Name: Seabrook Station, Units 1 and 2 Docket Numbers: 50 443/444 Licensing Stage: OL Responsible Directorate: PWR PD #5 Project Manager:
V. Nerses PSB Reviewer:
S. West Review Status: Complete Enclosed as Enclosure 1 is the Plant Systems Branch input for Section 9.5.1,
" Fire Protection," of Supplement 5 to the Seabrook Station, Units 1 and 2 Safety Evaluation Report (SSER 5).
The staff identified three unresolved fire protection items in Seabrook Station SSER 4 The applicant provided additional information concerning these three items.
In addition, by letter dated June 11, 1986, the applicant conmitted to incorporate the approved fire protection program into the FSAR and to implement procedures to replace the fire protection technical specifi-cations in accordance with Generic Letter 8610.
A table of SER errata is enclosed as Enclosure 2.
License conditions are enclosed as Enclosure 3.
SALP input is enclosed as Enclosure 4.
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Y bW 03(6 O 2 tpp q-y Charles E. Rossi, Assistant Director Division of PWR Licensing - A
Enclosures:
As stated cc:
T. Novak L. Hulman V. Noonan J. Wermiel S. Ebneter, RI R. Bosnak
- SEE PREVIOUS CONCURRENCE q 0FC
- P5B : PWR-A*
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DATE :06/ /86
- 06/ /86
- 06/ /86
- 06/) /86
- 06//[f/86 OFFICIAL RECORD COPY
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i Docket Nos.: 50-443/444 DISTRIBUTION I
Docket File MEMORANDUM FOR: Victor Nerses, Senior Project Manager PSB Docket File PWR Project Directorate No. 5 PSB Reading File l
Division of PWR Licensing - A S. West T. Quay FROM:
Charles E. Rossi, Assistant Director J. Shapaker l
3 Division of PWR Licensing - A J. Milhoan i
C. Rossi
SUBJECT:
FIRE PROTECTION INPUT FOR SUPPLEMENT 5 TO THE SEABROOK STATION, UNITS 1 AND 2 SAFETY EVALUATION REPORT Applicant:
Public Service Company of New Hampshire Plant Name: Seabrook Station, Units 1 and 2 Docket Numbers: 50-443/444 Licensing Stage: OL Responsible Directorate: PWR PD #5 Project Manager:
V. Nerses PSB Reviewer:
S. West Revi. w Status: Complete Enclosed as Enclosure 1 is the Plant Systems Branch input for Section 9.5.1,
" Fire Protection," of Supplement 5 to the Seabrook Station, Units 1 and 2 Safety Evaluation Report (SSER 5).
The staff identified three unresolved fire protection items in Seabrook Station SSER 4.
The applicant provided additional information concerning these three items.
In addition, by letter dated June 11, 1986, the applicant connitted to incorporate the approved fire protection program into the FSAR and to implement procedures to replace the fire protection technical specifi-l cations in accordance with Generic Letter 86-10.
A table of SER errata is enclosed as Enclosure 2.
The fire protection license condition is enclosed as Enclosure 3.
SALP input is enclosed as Enclosure 4 Charles E. Rossi, Assistant Director Division of PWR Licensing - A
Enclosures:
As stated cc:
T. Novak L. Hulman V. Noonan J. Wermiel S. Ebneter, RI R. Bosnak FC :P5B:PWR-A
- P5B:PWR.A
- P5B:PW A
- PSB:PWR-A
- P5B:PWR-A 0_ _ _ :....... _ _ _.. :........ _ _.. :. 4 AME :SWest
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- 06/ /86
- 06/d/86
- 06/ /86
- 06/ /86 u
0FFICIAL RECORD COPY d
ENCLOSURE 1 1
PLANT SYSTEMS BRANCH (DPLA-A)
INPUT FOR SUPPLEMENT 5 TO SAFETY EVALUATION REPORT SEABROOK STATION, UNITS 1 AND 2 DOCKET N05. 50-443/444 1
4 9 AUXILIARY SYSTEMS S.5 Other Auxiliary Systems 9.5.1 Fire Protection In Supplement Number 4 to the Seabrook Station, Units 1 and 2 Safety Evaluation Report (SSER 4) the staff identified the following unresolved fire protection items:
4 Concerns raised during the staff's January 27 to 3 986 plant site audit.
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of the fire protection program for Seabrook Station, Unit 1.
Multiple high impendence faults concern.
Energency lighting deviations
[
By letter dated March 18, April 24, May 13, and June 13,1986, Public Service Company of New Hampshire (the applicant) addressed the staff's plant site audit and multiple high impedence faults concerns.
The staff has also com-pleted its review of the emergency lighting deviations requested by the appli-cant in their January 24, 1986 letter.
By letter dated June 11, 1986, the applicant submitted a proposed tinal Safety Analysis Report ()FSAR) amendment for staff review. The staff's resolution of these concerns is reported below.
~
9.5.1.1 Fire Protection Program Requirements By letter dated June 11, 1986, the applicant submitted a proposed revision to Section 9.5-1 of the Seabrook Station FSAR.
This revision will (1) incorporate the fire protection program that has been approved by the staff, including the fire hazards analysis and commitments that form the basis for the fire protec-tion program, into the FSAR by reference to specific previous submittals, and (2) include a commitment to establish limiting conditions for operation, action statements and surveillance requirements for the fire protection program within the Seabrook Station plant operating procedures.
The applicant stated that these procedures will provide an equivalent leval of protection to that pro-vided by the fire protection sections of the Westinghouse Standard Technical Specifications.
Furthermore, in the June 11, 1986 letter the applicant com-mitted to incorporate this revision to FSAR Section 9.5-1 into the Seabrook Station FSAR via a future amendment.
The revision to Section 9.5-1 of the Seabrook Station FSAR proposed by the applicant meets the guidance for operating license applications currently under review, as set forth in Generic Letter 86-10, dated April 24, 1986.
On this basis, and on the basis of the applicant's commitment, the staff finds the FSAR revision proposed by the applicant in its June 11, 1986 letter acceptable.
By letter dated March 18, 1986, the applicant identified seven deviations from the National Fire Protection Association (NFPA) standards. The deviation con-cerning the fire protection booster pur.ep is discussed in Section 9.5.1.5 of this report.
The remaining six deviations are not applicable to the nuclear indus-try, are consistent with staff fire protection guidelines, or, in the staff's opinion, do not decrease the level of fire protection safety. These six devia-tions from the NFPA standards are, therefore, acceptable.
I 9.5.1.4 General Plant Guidelines Building Design During the January 27 to 31,1986 audit of the applicant's fire protection pro-gram for Seabrook Station, the staff observed that composite gypsum board-tube 06/16/86 2
SEABROOK SSER 5 SEC 9.5
steel barriers were installed as fire barriers (walls) in several plant areas.
Fire test results were not available during the audit to substantiate the fire resistance rating of the barrier design.
By letter dated April 24, 1986, the applicant submitted fire test reports on the subject barriers for staff review.
The subject fire barriers consist of a structural steel support system support-ing four layers of type X gypsum wa11 board.
All vertical joints are staggered and are taped and covered with a layer of joint compound.
Steel sub girts are mechanically fastened to each face of the wallboard panels.
Interlocking steel siding panels are mechanically fastened to the sub girts. Butyl-based sealing gaskets are applied to all interlocking vertical joints between the siding panels on both faces of the wall assembly.
On one face of the wall assembly (exposed steel face), the metal siding panels are insulated with unfaced, fiberglass compression-fit insulation bolts.
A layer of regular type asphaltum painted diamond mesh is erected over the exposed portions of the structural steel sup-port system.
The mesh is covered with a 1-inch layer of an approved fire retar-dant material.
Both sides of the wall assembly were tested by a recognized testing laboratory in accordance with ASTM E-119-83, " Standard Methods of Fire Tests of Building Construction and Materials," in two separate tests.
Both the exposed steel face and the smooth face satisfactorily withstood the fire endurance portion of the test for the full 3-hour test period.
Immediately af ter the fire exposure, each test specimen was subjected to the standard hose stream test.
Only the smooth face successfully resisted the hose stream test without developing any openings.
The hose stream penetrated a small section of the exposed steel wall face between the vertical edge channel flashing and the concrete block of the test furnace through a fire retardant coating filled gap.
No other section of the wall assem-bly was penetrated by the hose stream. The details of the wall assembly that allowed direct passage of water have been modified by the applicant with Under-writers Laboratories (UL) approved flashing details.
On the basis of the subject fire test reports and the modified flashing details, the staff qoncludes that the composite tube steel gypsum wallboard fire barriers-(walls) enclosing certain Seabrook Station fire areas are 3-hour fire rated, 06/16/86 3
SEABROOK SSER 5 SEC 9.5
l I
meet Section C.5.a of Branch Technical Position (BTP) CMEB 9.5-1, and are, therefore, acceptable.
e During the audit, the staff also noted that a number of fire door assemblies in-stalled in fire barriers, for which deviations had not been approved, were not Fire test tested and approved by a nationally recognized testing laboratory.
i 1
results were not available during the audit to verify the fire rating of the door assemblies.
In the April 24, 1986, letter, the applicant also submitted a fire test report on a swinging steel door assembly.
The door assembly was tested by a nationally recognized laboratory in accordance with ASTM E-152-81, " Standard Methods of Fire Tests of Door Assemblies." The door assembly remained in place without undue warpage throughout a fire exposure period of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and during a standard hose stream exposure.
On the basis of the staff's review of the referenced fire test report, the staff concludes that the tested fire door assembly achieved a fire resistance rating The use of these doors in fire barriers meets Section C.S.a of of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.
BTP CMEB 9.5-1 and is, therefore, acceptable.
During the plant site audit, the staff also observed a number of fire barrier penetrations, i.e., bus duct penetrations and seismic gaps, that were not pro-tected by penetration seal designs qualified by fire test.
By letter dated March 18, 1986, the applicant requested a deviation from Sec-tion C.S.a of BTP CMEB 9.5-1 to the extent that it states that penetrations in fire rated barriers should be sealed to provide a fire resistance rating at least equal to that of the barrier itself for bus duct penetrations in the east wall of the nonessential switchgear room and the north wall of the turbine building.
Aluminum bus ducts penetrate the east 3-hour fire rated wall of the nonessen-tial switchgegr room (fire area CB-F-1A-A) to the turbine building (fire Fire rated seals are provided around the ducts where they pene-zone TB-F-1A g).
trate the f. ire wall. There are no internal fire seals in the bus ducts.
There -
is an areawide fire detection system in the nonessential switchgear room and an area sprinkler system on the turbine building side of the wall.
4 SEABROOK SSER 5 SEC 9.5 06/16/86
Alas,inum bus ducts also penetrate the north 3-hour fire rated exterior wall of the turbine building to the outside transformer yard area.
The walls are sealed around the bus ducts where they penetrate the fire wall. There are no seals inside the ducts.
There is an area sprinkler system on the turbine side of the wall.
Each of the transformers on the exterior side of the wall, which are lo-i cated about 28 feet from the wall, is equipped with a deluge system.
The staff was concerned that a fire in one of the subject fire areas would spread to the adjacent fire area through the unsealed bus duct penetration and adversely affect safe shutdown. However, the staff evaluated the fire hazards and fire proctection features provided on each side of each of the bus duct penetrations and found no unmitigated fire hazards in their proximity that present a threat to the safe shutdown capability.
Moreover, in the staff's o inion, the bus ducts are capable of confining the effect of a fire to the o origin until the j
fire brigade arr;ves and extinguishes the fire.
On these bases, the staff con-
~
cludes that the installation of fire rated seals inside the subject bus ducts would not significantly increase the level of fire safety. The lack of such m.
seals is, therefore, an acceptable deviation from Section C.S.a of BTP CMEB 9.5-1.
By letter dated April 24, 1986, the applicant also provided additional informa-tion on the seismic gaps.
The seismic gaps were originally sealed with a nonfire rated sealant material. This material has been removed and replaced with a fire 3
retardant silicone foam sealant material to a depth of 7-1/2 inches, as detailed in the applicant's letter. The seismic gap seal design used by the applicant has not been tested in accordance with the ASTM E-119 fire test standard, and, there-fere, does not have a fire resistance rating.
However, ASTM E-119 fire tests on this silicone foam material in other configurations demonstrate that 7-1/2 inches of the sealant material can achieve a fire resistance rating of up to 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.
Based on this testing, a review of the applicant's submittal, and an evaluation of the fire hazards proximate to the seismic gaps, the staff concludes that the silicone foam seismic gap seals installed at Seabrook Station will, for antici-pated fires, prevent the spread of the fire and its products through the seismic gaps.
The seismic gap seals arc, therefore, acceptable.
By letter dated March 18, 1986, the applicant informed the staff that a teflon coating has been applied to the blade guide flanges of the fire damper 06/16/86 5
SEABROOK SSER 5 SEC 9.5
i I.
as semblies installed at Seabrook Station.
This deviates from the UL tested con-figuration in that the damper assemblies were not tested with the teflon coating.
T e purpose of the teflon coating is to improve the closure characteristics of tne dampers under air flow conditions.
Section 5 of UL Standard 555, " Standard for Fire Dampers and Ceiling Dampers,"
allows the use of epoxy or alkyd-resin type or other outdoor paint on steel parts
)
used in the damper assembly.
The staff concurs with the applicant that the tef-lon coating used is sufficiently similar to a paint coating that its use would not adversely affect the ire. ability of the dampers to prevent fire spread and coes not affect the ratin of the fire damper assemblies. The use of the teflon coating is, therefore, acceptable.
Safe Shutdown Capability Osring the audit of the applicant's fire protection program for Seabrook Station, p..
the staff observed that structural steel supporting a number of fire barriers was not protected to provide fire resistance equivalent to that required of the barrier in accordance with Section C.5.b of BTP CMEB 9.5-1.
l Ey letter dated April 24, 1986, the applicant informed the staff that it had e.aluated fire barriers supported by unprotected structural steel to determine whether or not they are capable of withstanding anticipated fire exposures.
On June 12,1986, the staff met with the applicant to discuss the evaluation.
By i
letter dated June 9,1986, the applicant provided additional information.
The applicant's structural steel evaluation consisted of three parts.
- First, the potential fire area and localized fire exposure temperatures were deter-sined for the various fires that could occur in each fire area, and second, the effects of these temperatures on the structural steel members present in each fire area were assessed. Where the calculations indicated that the steel temperatures would exceed 1100 F, the structural member was assumed to fail.
Where the unprotected steel temperature did not reach 1100*F, the structural sembsr is considered acce'ptable and protection is not deemed necessary.
The methodology employed in these first two parts of the applicant's three part analysis is the s'ime as that used by Philadelphia Electric Company for Limerick 06/16/86 6
SEABROOK SSER 5 SEC 9.5
Ge erating Station, Units 1 and 2.
The staff's evaluation and acceptance of this methodology is reported in Supplement 2 to the Limerick Generating Station, Units 1 and 2 Safety Evaluation Report (NUREG-0991), dated October 1984.
The third part of the applicant's analysis consisted of a structural integrity
'I re.iew.
For the fire areas where the aforementioned calculations indicated that j
structural members could f ail as a result of fire exposure, a structural integ-rity review was conducted on the fire area.
For each fire area in question, it was assumed that those steel members that could potentially be lost, were lost, and the structural integrity of the remaining structure was analyzed. Where it was determined that the structural integrity of the fire area would not be com-promised by f ailure of the structural elements, the steel was not protected.
(
Those structural steel members t w re determined to be required to ensure K
the structural integrity of the area have been protected in accordance with Section C.S.b of BTP CMEB 9.5-1.
On the basis of both this evaluation and the aforementioned Limerick evaluation, the staff concludes that the absence of fire protection for the structural steel elements identified in the applicant's April 24, 1986 letter is an acceptable deviation from Section C.S.b of BTP CMEB 9.5-1.
In SSER 4 the staff expressed a concern that fire-induced, multiple high-icpedance faults could result in the loss of the necessary power supply for safe shutdown equipment.
By letter dated May 13, 1986, the applicant provided additional information.
Maltiple high-impedance faults can occur when several cables from a common bus are located in the same fire area. When a fire occurs in such an area, the re-sulting fire damage could cause electrical faults in the cables, but the faults may not trip the individual circuit breakers. However, the sum of the faults may be sufficient to trip the main breaker which protects the power supply bus.
If safe shutdown equipment is energized from the same bus, once the main breaker trips, this equipment will have lost its power source.
The applicart stated that, for such a condition to occur, each branch circuit cable would have to fail along its length so as to result in a unique insulation resistance. This unique resistance would produce a leakage current to ground or conductor to con-06/16/86 7
SEABROOK SSER 5 SEC 9.5 1
l
d.ctor which, when added to the conductor load, would result in a current just below the protective device rating. Thus, an improbable combination of tempor-a y leakage currents would have to occur at once to produce a trip of the main b-eaker.
The applu.- t committed to add a general note to the safe shutdown and cooldown procedt.: ' to alert plant personnel to clear nonessential loads from a tripped bus before reclosing the bus feeder breaker, should the bus l
feeder breaker trip.
The staff finds the applicant's provision of the note to drop the nonessential i
loads before reclosing a tripped breaker acceptable in that it resolves the prob-lem of a breaker trip because of high impedance faults.
Ventilation In the Seabrook Station SER, the staff reported that charcoal filters have been provided with low-flow air bleed systems in accordance with Regulatory Guide 1.52.
During the audit of the applicant's fire protection program for Seabrook Station, Unit 1, the staff observed that the station's charcoal filters are not protected in accordance with the guidelines of Regulatory Guide 1.52.
By letter dated March 18,1986 the applicant requested a deviation from installing fire sup-pression systems to protect the charcoal filters.
The applicant indicated that an analysis was conducted which showed that the temperature for adsorber auto-ignition or desorption would not occur even without air flow across the adsor-bers.
Previously,theSafetyAnalysisReportindicatedthatalow-flowgir bleed velocity of 0.2 ft per minute was require [to mainthn the adsorber temperature below the autoignition or desorption point. SW MsN55 '* 5 EM b o.ppbeat ens.cerUn th w c h ses md 645 %cd ur bin use w phr.is ws.t 65 tequ.re k eA%v c y.sA T % a &.
sed m 4 The applicant.must provide an analysis which justifies the lack of any fire pee-at-5.ppressem y tutka system for the charcoal adsorbers if the staff is to consider approval j
of the deviation. Therefore, the staff proposes that, as a licensee condition, 9tu.M9 w
.,s h. ' h o n LMd-the applicant not operate above a 5% power level without th:5 N ="...'
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th; d.:,try The basis for staff approval of operation up to 5%
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power without low flow air bleed is that there is a slow buildup of fission 06/16/86 8
SEABROOK SSER 5 SEC 9.5
products when operating up to 5% power and the low probability of an accident occurring during this mode of operation.
I Lighting and Communication In the Seabrook Station SER, the staff reported that the applicant committed i
to install 8-hour battery powered emergency lighting units in all areas of the plant that may need to be staffed for safe shutdown operations, and in access and egress routes to and from all such areas, in accordance with Section C.5.g of BTP CMEB 9.5-1.
By letter dated January 24, 1986, the applicant requested deviations from Sec-tion C.S.g of BTP CMEB 9.5-1 in the control room, switchgear room A, and switch-
]
gear room B.
In SSER 4 the staff reported that its review of these deviation i
requests was ongoing.
Following is the staff's evaluation of these deviations.
In the control room (fire area CB-F-3A-A) diesel generator powered lighting is provided to illuminate the face of the main control board and the control switches
)
used to achieve safe shutdown.
This lighting is powered from both diesel gen-erators in an "A and/or B" logic such that lighting is provided by either train.
The diesel generator engine rooms are separated from each other by 3-hour fire rated barriers.
Power from each diesel generator is routed to separate switch-gear rooms (A and B), which are separated from each other and from the diesel t
generator rooms hy 3-hour fire rated barriers.
Power from each switchgear room is routed via embedded conduit, on opposite sides of the control building to train A and train B essential lighting panels within the control room complex computer room. Therefore, in the staff's opinion, at least one train of power will be available for control room emergency lighting for any postulated fire outside the control room complex.
In the event of a computer room fire, both essential lighting panels could be damaged. However, in the event of such a fire, the control room will be evacu-ated and the remote shutdown system (RSS) control panels will be used to achieve shutdown.. Emergency lighting for access and egress routes from the control room-to the the RSS facilities is provided by 8-hour battery powered lights in accor-dance with Section C.S.g of BTP CMEB 9.5-1.
06/16/86 9
SEABROOK SSER 5 SEC 9.5 N
l Eight-hour battery powered emergency lighting units are provided in switchgear room A for all RSS control locations and access / egress routes thereto, with the j
exception EDE-MCC-512, EDE-MCC-515, and EDE-MCC-521.
These panels (MCCs) are illuminated by fluorescent light fixtures powered by the train B diesel genera-tor.
The power feeds to these light fixtures is confined to switchgear rooms A and B, which are separated from each other and from each diesel generator room by 3-hour fire rated barriers.
Therefore, the lighting in switchgear room A will not be disabled by a fire outside of the switchgear rooms and the diesel generator rooms. Moreover, access to these MCCs is not required for a fire in either switchgear room or diesel generator room.
Eight-hour battery powered emergency lighting units are provided in switchgear room B for all RSS control locations and access / egress routes thereto, with the exception of EDE-MCC-612, EDE-MCC-621, and EDE-MCC-622, which are illuminated by fluorescent lighting fixtures powered by the train B diesel generator.
The power feeds to these fixtures are confined to switchgear room B which is sepa-
~
rated from diesel generator B by 3-hour fire rated barriers.
Therefore, the lighting in switchgear room B will not be disabled by a fire outside switch-gear room B or diesel generator room B.
Access to these MCCs is not required for a postulated fire within either switchgear room B or diesel generator room B.
On the basis of this review, the staff concludes that the installation of 8-hour battery powered lighting units in the control room, and the installation of additional 8-hour battery powered lighting units in switchgear room A and switchgear room B would not significantly increase the level of fire safety.
The staff further concludes that the lack of 8-hour battery powered lights in these areas is an acceptable deviation from Section C.5.g of BTP CMEB 9.5-1.
9.5.1.5 Fire Detection and Suppression Fire Detection In the Seabrook Stations SER and in SSER 4, the staff evaluated and approved deviations -from Section C.6.a of BTP CMEB 9.5-1 to the extent it states that fire detectors should be installed in all safety related areas. By letter 06/16/86 10 SEABROOK SSER 5 SEC 9.5 i
dated March 18, 1986, the applicant requested a deviation from Section C.6.a of BTP CMEB 9.5-1 for the space above the control room suspended ceiling.
Sr.oke detectors are installed in the control room at ceiling level and in the main control room console.
Smoke detectors are not installed in the space above the control room suspended ceiling.
The ceiling space is devoid of com-bustible materials and does not contain any safety-related equipment.
Further-more, the control room is continuously manned.
Because the ceiling space is devoid of combustibles, the staff does not expect a fire to occur in this space.
In the unlikely event that a fire does occur, it would be detected by the control room operators or by the existing ceiling level smoke detection system.
Because the ceiling space does not contain any safety-related equipment and is scparated by the safety related equipment in-stalled in the control room by the noncombustible suspended ceiling, the staff does not expect any postulated fire in the ceiling space to damage safety-
'Z
/0 related components before tM '% is detected and extinguished.
In the un-likely event a fire above the control room suspended ceiling results in-the loss of redundant safety-related or safe shutdown related components, safe plant shutdown can be achieved and maintained from the remote shutdown stations.
On these bases, the staff concludes in the control room ceiling space is an accept-able deviation from Section C.6.a of BTP CMEB 9.5-1.
O N/acI M d.2$c554/
Fire Protection Water Supply System A backup to the normal fire protection system has been provided for the stand-pipes servicing safety equipment in the event of safe shutdown earthquake
'kC (SSE) in accordance with Section C.I.c of
- 9. 5-1.
A permanent connection between one train of service water and the safety-related area standpipe is provided with a booster pump to supply the required flow and pressure. By letter dated March 18, 1986, the applicant informed the staff that this booster pump does not meet NFPA 20, " Standard for the Installation of Centrifugal Fire Pumps." The fire protection booster pump is a stainless steel pump that is neither UL Listed nor Factory Mutual (FM) approved.
The pump includes a local on-off push button with status indication. There is a gate valve and a pressure gauge in both the suction and discharge lines of the pump.
06/16/86 11 SEABROOK SSER 5 SEC 9.5
l.
A orifice plate is installed in a test line connecting the suction and dis-ctarge of the pump so that pump flow may be tested.
A persanent flow meter is nct provided, but there are connections for a portable flow meter for testing.
NFPA 20 states that fire pumps shall be listed for fire protection.
Although the subject booster pump is not UL Listed or FM approved (UL/FM), it has similar flow characteristics to a UL/FM pump.
The applicant stated that UL/FM pumps are typically made of cast iron which cannot be seismically qualified.
The stain-7
~
less steel booster pump however, is seismically qualified.
NFPt. 20 also states that fire pumps shall have an automatic controller, remote status indication, and remote alarm and signal devices at a point of constant attendance.
NFPA 20 also requires that the interior of the suction pipe be galvanized or painted to prevent tuberculation.
Tne subject booster pump is not the main fire pump.
It is a small (150 gom) backup fire pump which only supplies the standpipe systems in certain plant areas in the event that a SSE damages the normal fire protection water supply.
In such an event, plant operators will be dispatched to start the pump.
Therefore, an automatic controller is not necessary.
Moreover, the remote status indication and alarms required by NFPA 20 are not necessary because the operators will remain at the pump, in addition, because of the expected limited use of the pum tuberculation is not considered a problem.
On these bases, the staff concludes that the su ject booster pump installation, with the identified NFPA 20 deviations, is accer table.
NtjY Y Sprinkler and Standpipe Systems In the Seabrook Station SER, the staff stated that hose stations are installed so that all areas of the plant can be reached with an effective hose stream with a maximum of 100 ft of hose, in accordance with Section C.6.c of BTP CMEB 9.5-1.
By letter dated March 18, 1986, the applicant requested a deviation from Sec-tion C.6.c of BTP CMEB 9.5-1 for the cooling tower, east main steam and feed-06/16/86 12 SEABROOK SSER 5 SEC 9.5
water enclosure, service water pumphouse, and the intake and discharge struc-tures, to the extent that it states that standpipe and hose systems shall be installed so that at least one effective hose stream will be able to reach any location that contains or presents an exposure fire hazard to structures, systems, or components important to safety.
The primary means of manual fire fighting for the subject areas is portable lire extinguishers.
In lieu of standpipe and hose systems, the applicant proposes to use the fire hoses from the hose houses provided at the fire hydrants near these areas as a secondary means of manual fire fighting.
In the staff's opinion, reliance on the hydrant
)
hose houses instead 'of a standpipe system could delay the application of en ef fective hose stream on a fire.
However, because of the limited fire hazards present in the subject areas and the separation and protection of the safety related components in accordance with the staff fire protection guidelines as reported in the Seabrook Station SER and its supplements, the staff does not expect this delty to adversely impact the level of fire safety.
The substitu-tion of fire hoses from the fire hydrant hose houses for standpipe system hose
~
r-is, therefore, sn acceptable deviation from Section C.6.c of BTP CMEB 9.5-1.
9.5.1.8 Summary of Approved Deviations from BTP CMEB 9.5-1 The following deviations from BTP CMEB 9.5-1 were approved in the Seabrook i
Station SER and SSER 4:
3 carpet in the control room (SER and SSER 4) lack of an automatic fire suppression system and 20-foot separation j
between redundant safety-related equipment required for safe shutdown in I
certain fire areas.
(SER and SSER 4) 1 drains in the switchgear rooms (SEP.)
1500-gallon diesel fuel day tanks (SER) lack af independence for the alternate shutdown capability from certain fire areas (SSER 4) 06/16/86 13 SEABROOK SSER 5 SEC 9.5
c non-fire-rated wall (SSER 4) l l
lack of fire dampers in certain HVAC ducts (SSER 4) 1 1
non-UL-labeled dampers in certain fire areas (SSER 4) lack of areawide fire detection in certain fire areas (SER and SSER 4) fire protection water supply tanks' capacity less than 300,000 gallens (SSER 4) 1 non-UL-listed water supply valves (SSER 4)
Or. the basis of the above-evaluation, the staff concludes that the following additional deviations are acceptable:
Deviations from NFPA standards (Section 9.5.1.1) 4 Non-fire rated bus duct penetrations (9.5.1.4)
Unprotected structural steel members in certain fire areas (9.5.1.4)
Lack of 8-hour battery powered emergency lighting units in the control room and certain locations in switchgear rooms A and B. (9.5.1.4)
Lack of smoke detectors above the control room suspended ceiling (9.5.1.5)
Certain details of the SSE fire protection booster pump deviate from NFPA 20 (9.5.1.5)
Use of fire hydrant hose houses in lieu of standpipe hose houses for certain fire areas (9.5.1.5).
9.5.1.5 Conclusions On the basis of its review, the staff concludes that, with the exception of the l
protection of the charcoal filter units, the applicant's fire protection program for Seabrook Station, with approved deviations, meets the' staff fire protection guidelines of BTP CMEB 9.5-1 and satisfies General Design Criterion 3.
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I knadditiontothelice, condition concerning the char
.1 filter units, the staff will condition the operating license to require that the applicant imple-ment and maintain in effect all provisions of the approved fire protection program.
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i 06/16/86 14 SEABROOK SSER 5 SEC 9.5 w--_____-_____________-_-___--
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Seabrook Station, Units 1 and 2 SER Errata Section 9.5.1, " Fire Protection" P_ age Line Change l
9-47 3, 4 Delete "or they are manually started by the operator in the control room" e
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l' 06/16/86 15 SEABROOK SSER 5 SEC 9.5
ENLOSURE 3 SEABROOK STATION, UNIT 1 FIREPROTECTIONLICENSECONDITION$
,)(
1.
The licensee shail implement and maintain in effect all provisions of the approved fire protection program as Cescribed in the Final Safety Analysis Report for the facility and letter dated June 11, 1986, and as approved in the Seabrook station SER dated March 1983 and SER Supplements dated subject to the following provision:
The licensee may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve ar,d maintain safe shutdown in the event of a fire.
Prior to exec;edingi' of ragdgg epthe licensee shall submit an ac;;pt-2.
m.,
eMe-analysis which jus.tifies the exclusion of any fire 9 nection system 3
ypessm for charcoal adsorbers.
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06/16/86 16 SEABROOK SSER 5 SEC 9.5
ENLOSURE 4 SEABROOK STATION, UNITS 1 AND 2 Input to the SALP Pr::ess A.
Functional Area: Fire Protection (1) Management involvement in assuring quality The applicant's activities generally exhibited evidence of prior assignment of priorities to fire protection safety.
However, the issues anc commitment changes resolved by the staff during this period sh:.1d have been addressed by the applicent much earlier in the revie. process.
Inaddition9fincomplete submittals indicate 2(s that manactment involvement could be improved.
Rating Categor) 3 (2) Approach t: resolution of technical issues During the various meetings and telecons, and in the documents sub-mitted, tti applicant's representatives did not always display clear understan:'ng of the specific fire protection principles involved with the resolution of technical issues nor a consistently conserva-(;,
tive apprca:hd$oward providing an adequate level of safety.
Staff efforts te resolve open items and deviation requests required a num-ber of meetings and submittals before acceptable resolution was achieved.
Rating Category 3 (3) Responsiveness to NRC initiatives With few exceptions, the applicant provided timely responses to the staff's rt;uest for information.
However, in some cases, the appli-cant's initial response did not resolve staff concerns.
Therefore, 06/16/86 17 SEABROOK SSER 5 SEC 9.5
staf f efforts to resolve some issues required a number of submittals before acceptable resolution was achieved.
Rating Category 2 9
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06/16/86 18 SEABROOK SSER 5 SEC 9.5
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