ML20244E229

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Forwards Position Paper Concluding That Util Needs to Revise Fire Hazards Analysis to Include Charcoal Filter Units & Provide Protection If Dictated by Revised Fire Hazards Analysis
ML20244E229
Person / Time
Site: Seabrook, 05000000
Issue date: 08/26/1986
From: Rossi C
Office of Nuclear Reactor Regulation
To: Nerses V
Office of Nuclear Reactor Regulation
Shared Package
ML20235T530 List: ... further results
References
FOIA-87-51 NUDOCS 8608280299
Download: ML20244E229 (5)
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1 Docket No.: 50-443/444 @G 2 g g MEMORANDUM FOR: Victor Nerses, Senior Project Manager Project Directorate No. 5 Division of PWR Licensing . A FROM: Charles E. Rossi, Assistant Director c Division of PWR Licensing - A 4

SUBJECT:

FIRE HAZARDS ANALYSES FOR CHARCOAL l FILTER UNITS - SEABROOK STATION, UNITS 1 AND 2 )

As you know, we have had several meetings and numerous telecons over the past two months with various representatives of the applicant for Seabrook Station concerning fire protection for the Station's charcoal filter units.

On August 19, 1986, we received a draft copy of a letter (undated / unsigned) from the applicant that was intended to address and resolve our concerns. 1 We have reviewed this draft letter and have discovered that the applicant i has fallen far short of its intent. On this basis we feel it is now  !

appropriate to document this issue, including our concerns and position, for the record.

Our "pesition paper", which is enclosed, is consistent with the position we have taken with and expressed to the applicant's representatives during i each of the aforementioned meetings and telecons. l l

In short, the applicant needs to (1) revise its fire hazards analysis to include the charcoal filter units, and (2) provide additional fire protection if dictated by the revised fire hazards analysis.

If you need additional information to achieve resolution of this issue, please advise.

gicind clPSM Charles E. Rossi, Assistant Director Division of PWR Licensing - A

Enclosure:

As stated cc: T. Novak Distribution _:

V. Noonan Docket FileC. JMilhoan J. Calvo PSB Read File JShapaker L. Hulman PSB Docket File SWest S Long AD Read File I

  • See previous concurrence 0FC :PWR-A:PSB :PWR-A:PSB :PWR.A:PSB :PWR-A:AD  :  :  :

NAME :SWest: art * :JShapaker* :JMilhoan -

DATE :8/25/86 :8/25/86 :8/25/86  : /86  :  :  :

0FFICIAL RECORD COPY [y+ N L Y bO8N #1 ((_] Sp

Docket No.: 50-443/444 MEMORANDUM FOR: Victor Nerses, Senior Project Manager Project Directorate No. 5 Division of PWR Licensing . A FROM: James L. Milhoan, Chief Plant ~ Systems Branch Division of PWR Licensing . A

SUBJECT:

FIRE HAZARDS ANALYSES FOR CHARCOAL FILTER UNITS - SEABROOK STATION, UNITS 1 AND 2 As you know, we have had several meetings and numerous telecons ver the past two months with various representatives of the applicant or Seabrook Station concerning fire protection for the Station's charco filter units.

On August 19, 1986, we received a draft copy of a letter ( dated / unsigned) from the applicant that was intended to address and reso ve our concerns.

We have reviewed this draft letter and have discovered at the applicant has fallen far short of its intent. On this basis we eel it is now appropriate to document this issue, including our c cerns and position, for the record.

Our " position paper", which is attached, is co istent with the position we have taken with and expressed to the applican s representatives during each of the aforementioned meetings and tele ons.

In short, the applicant needs to (1) revi e its fire hazards analysis to include the charcoal filter units, and ) provide additional fire protection if dictated by the revised fire hazard analysis.

If you need additional information achieve resolution of this issue, please advise.

James L..Milhoan, Chief Plant Systems Branch Division of PWR Licensing . A cc: T. Novak Distribution:

C. Rossi Docket File JMilhoan V. Noonan PSB Read File JShapaker  !

S. Long PSB Docket File SWest  !

AD Read File l i

I i

0F0 :P5B:PWR  : )5

C:PSB:PWR-A :  :  :  :

NAME :SWe e :JMilhoan  :  :  :  : j

. . . . . : . . . . f. . . . . . .i. . ...p .r

, DATE :8/ 23 /86 :8/f47 /86 :8/ /86  :  :  :  : )

0FFICIAL RECORD COPY

i STAFF POSITION J

SEABROOK STATION FIRE PROTECTION PROGRAM l 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 i 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 NttC'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 Frotection," of Appendix A to 10 CFR j 50, requires that structures, systems, and components important to safety be i 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 APCEB 9.5-1 as guidelines in its evaluation of the applicant's fire protection program for Seabrook Station. i Section II.B. " Fire Hazards Analysis," of Appendix R to 10 CFR 50 states: ,

"A fire hazards anblysis 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 I area containing structures, systems, and components important to safety, in accordance with NRC guidelines and regulations."

i

- - - - - - - - - - - . - - - _ - - - . - - - - - - a

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

"The overall fire protection program should be based upon evaluation of

! potential fire hazards throughout the plant and the effect of postulated l 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- 1 should be separately identified in the fire hazards analysis. The staff  !

would exnect the applicant to conduct a detailed evaluation for each fire 1 area ir wich 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 i 1

- walls, floor, and ceiling construction {

- ceiling height j 4

- room volume l - ventilation k l - congestion ]

B. Safe Shutdown Capability

- number of redundant systems in area

- whether or not system or equipment is required for het shutdown

- type of equipnent/ cables involved

- repair time for cold shutdown equipment within this area l

- separation between redundant components and in situ concentration of combustibles

- alternative shutdewn capability l

C. Fire Hazards

- 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 l D. Fire Protection Existing or Comnitted

- fire detection system

- fire extinguishing systems

- hose staticn/ extinguisher

- radiant heat shields

. . . . 3 Because establishment of specific design basis fires for individual fire areas is a prerequisite to performance of a valid fire hazards analysis, the sta'f 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 I

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 priur knowledge of the presence {

of the filter units. Knowledge of the presence of these filters would have i 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 comitment from the applicant to complete the modifications i by a specified date, not to extend beyond 5 percent of full rated power, and condition the operating license accordingly.

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