ML20247N001
| ML20247N001 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 07/27/1989 |
| From: | Morris K OMAHA PUBLIC POWER DISTRICT |
| To: | |
| Shared Package | |
| ML20247M994 | List: |
| References | |
| NUDOCS 8908020261 | |
| Download: ML20247N001 (10) | |
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- t BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION I
In tae Matter of -)
Omaha Public Power District ) Docket No. 50-285 l (Fort Calhoun Station ) l Unit'No. 1). ) l l
l APPLICATION FOR AMENDMENT 0F i OPERATING LICENSE j i
Pursuant to Section 50.90 of the regulations of the U. S. Nuclear .;
Regulatory Commission ("the Commission"), Omaha Public Power District, !
holder of Facility Operating License No. DPR-40, herewith requests that Sections 4.9.1 and 4.14 of the Fire Protection SER (Technical Specification Amendment 40) be amended to delete the requirement for )
. turbine building fire water curtain installations.
i The proposed changes in the Fire Protection SER are shown in Attachment A to.this Application. A discussion, which demonstrates that the proposed changes do not involve significant hazards considerations, is provided in Attachment B. The proposed change in the SER would not authorize'any change in the types or any increase in the amounts of effluents or any change in the authorized power level of the facility. l l
WHEREFORE, Applicant respectfully requests that the license conditions in Sections 4.9.1 and 4.14 of the Fire Protection SER be j amended in the form attached hereto as Attachment A. l
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A copy of thir. Application, including its attachments, has been sub- .
mitted to the Director - Nebraska State Dhtaion of Radiological Health, as required by 10 0FR 50.91.
OMAHA PUBLIC POWER DISTRICT By [ '
bisionManager Nuclear Operations Subscribed and sworn to before me this AN day of July,1989.
GENEtk BMAbf ahate W M NAL
)k)jhr ms '""* M 4*
Notary Public
l L- UNITED STATES OF AMERICA 1 '
NUCLEAR REGULATORY COMMISSION In the Matter of )
)
Omaha Public Power District ) Docket No. 50-285 (Fort Calhoun Station )
Unit No. 1) )
AFFIDAVIT K. J. Morris, being duly sworn, hereby deposes and says that he is the Division Manager - Nuclear Operations of the Omaha Public Power District; that as such he is duly authorized to sign and file with the Nuclear Regulatory Commission the attached information concerning the Application for Amendment dated July 27, 1989, concerning fire water curtain commitments; that he is familiar with the content thereof; and that the matters set forth therein are true and correct to the be-t of.his knowledge, information, and belief.
/- '
K.(#. M6rfis Division Manager Nuclear Operations STATE OF NEBRASKA)
) ss COUNTY OF DOUGLAS)
Subscribed and sworn to before me, a Notary Public in and for the State of Nebraska on this '#1 day of July,1989.
() umaan amm-sw.m mene.
N - m,c N. ., N 4 A Notary Public
ATTACHMENT A Th2 GTC system consists of 77 handsets which ara wall distributed through-out the plant and also four jack stations in the containment. At each handset station there is local speaker amplification. This system has four channels consisting of one page line and three party lines. The GTC system is supplied from the 120-volt instrument AC power system.
The sound powered telephone system has two channels. Telephone jacks are .
distributed throughout the plant at the same locations as the GTC handsets.
Sia portable handsets and fcur portable headsets are provided for this system.
The sound-powered telephone system penetrates the containment at the personnel air-lock while the GTC system enters the containment through the electrical penetration area.
The licensee proposes to install fixtd repeaters to facilitate communica-tion by portable radios which will provide backup to the existing communi-cation system. Three portable radios will be provided to maintain -
emergency communication.
We find that, subject to implementation of the abova described nodifica-tions, the communication system will have necessary redundancy to coor-dinate fire fighting and plant operation, meets the objectives of Section 2.2 of this report and is, therefore, acceptable.
4.8 Electrical Cables The power cables are of the rubber and polyethylene type, the control cables are cross-linked polyethylene, and the instrumentation cables are silicone rubber and polyethylene types.
Although IEEE Standard 383 was not in existence at the time Fort Calhoun CEbling was purchased and installed, manufacturers which supplied most of ~
the caoles have subsequently certified that these cables are capable of pa's sing the test outlined in IEEE Standard 383-1974. In addition, the licensee has successfully conducted tests on control and power c9bles, generally following the provisions of the alternate test method described
.in lEEE Standard 383-1974.
We-find that the electrical cables adequately comply with IEEE Standard 383-1974 and raeets BTP 9.5-1.
4.9 Fire Barrier Penetrations .
4.9.1 Doorways
' Fire barriers are penetrsted ay doorways, ven'tilation ducts, electrical rraceways, piping and cer.duits. Many doorway penetrations are not provided
'With three-hour rated fireAll cocrs. The licensee will replace these with tthree-hour rated doors. fire doors will be electrically supervised with time delayed alarm in a constantly manned area, or locked closed.
iWate~ettH.5 ins .cill be-4milcd to rei-f orc: protection by three-Nwe 44 re-dooefr-a tdoorway-opek,99-oewee&t-he-twMr.: and-t4eap4Mery-l 4tti-Id i ng';.
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sealed; access is provided through an interlocked double-door air-lock.
Special procederes. oust be followed to gain access, increasing the response time of the fire brigade.
The licensee has agreed to establish and clearly nark all escape and access routes and to develop and practice a prefire plan by drills for operating and fire brigade personnel.
1 Access to and' egress from the controlled area in the basement level is currently provided by a single open stairway. The ifcensee will provide I
an additional . ioorway into, the electrical penetration area in the same l level to serve as the alternate access and egress.
The cable spreading room is reasonably accessible. Ilowever, the arrange-l-
' ment of cable trays in the room is such that fire fighters may have to crawl under trays approximately three feet above the floor to get to many parts of the room. The licensee has agreed to provide protection as outlined in section 5 of this report (5.25).
We find that, subject to implementation of above modifications, access and egress will be adequate to each fire area in the plant, meets BTP 9.5-1 and are, therefore, acceptable.
l 4.13' Teric ar.d Corresive Combustion Prodects 1
The products of ccabestion of many polymers are toxic to humans and corro-sive to metals. Proept fire detection and Means extinguishment are relied upon of smoke removal, as to reduce the cuantity of such products.
discussed in Secticr. 4.4, are previded as an aid i.n fire fighting access.
Mez ers of the fire brigade will be provideo with, and trained in the use of, emergency breathing apparatus for fighting fires involving such materials. .
We find that, subject to implementati.on of the modifications described elsewhere in this report, the precautions taken to reduce the effects of toxic and corrosive products satisfy the cbjectives identified in Sec-tien 2.2 af this report ano are, therefore, acceptable.
4 I4 Nonsafety-Related Areas The licensee has analyzed the potential fire hazard in the turbine building and will provide a fire barrier nd - ctcr curtai, between the turbine building and the auxiliary building. The turbine room is also protected by automatic i
water suppression syntems. Separation of turbine building from safety-related areas meets BTP 9.5-1 and is, therefnre, acceptable.
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ATTACHMENT B DISCUSSION, JUSTIFICATION, AND NO SIGNIFICANT HAZARDS CONSIDERATION ANALYSIS l.
Discussion Omaha Public Power District (0 PPD) in Reference 2 proposed to delete a commitment from the Fire Protection SER (Reference 3) requiring the installation of fire water curtains as additional protection at doorway openings between the turbine and auxiliary buildings. These water curtains are presently installed and will not be removed. However, the deletion of this requirement from the SER is necessary to correct the subject deviation of fire protection commitments as described in Reference 2.
OPPD committed in Reference 4 to install fire water curtains at doorway openings between the turbine building and auxiliary building as an additional fire protection measure. Subsequently, on August 23, 1978, Fort Calhoun Station Unit No. I was issued Technical Specification Amendment 40 which incorporated a license condition related to the completion and implementation of fire protection modifications.
SER Section 4.9.1 for this Technical Specification Amendment described a commitment by OPPD to install water curtains to " reinforce protection of three hour fire doors at doorway openings between the Turbine and Auxiliary Buildings." It should be noted that these water curtains are not required in the Technical Specifications, thus a Technical Specification Amendment is not relevant to pursue. SER Section 4.14 describes the water curtain installation as providing separation of the Turbine Building from safety-related areas to l meet the criteria of Branch Technical Position (BTP) 9.5-1. However, in the discussion of the Turbine Building in SER Section 5.29, no mention is made of the water curtains and it simply states: "The NRC has reviewed fire barriers separating this area from safety-related areas and found it is adequate to prevent a fire in this area from exposing safety-related systems / components."
The SER goes on to state, "No modification is necessary." In Section 3.0 of the same SER, the installation of the Turbine Building water curtains is not listed among the required modifications or incomplete items. In 1979, the Turbine Building water curtains were installed under a design change request, DCR-77-26/GSE task 77-10B. Subsequent to thit , several additional SER's were issued as the modifications and incomplete items were completed. None of the later SER's describe the corrpletion of or acceptability of the Turbine Building water curtain installation. In an Inspection Report dated April 31, 1989 (IER 89-09), OPPD was cited for a deviation for failure to test the Turbine Building water curtain actuation valves in accordance with USAR requirements. In discussions held with the Senior Resident Inspector, OPPD decided to pursue removing the requirement for the Turbine Building water curtains from the fire protection SER since the available analysis shows that they are not required to preserve the safe shutdown function or protect safety-related components and that testing beyond the current weekly visual inspection was impractical from a personnel and equipment safety perspective.
Justification OPPD requests to remove the requirement for the Turbine Building water curtains as stated in Sections 4.9.1 and 4.14 (pages 4-12 and 4-15, respectively) of the fire protection SER based on the following justification:
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M The water curtains are not required to provide separation between the turbine building and safety-related areas of the plant due to the adequacy of installed fire barriers and other fire suppression systems (e.g., manual hose stations, portable extinguishers, wet-pipe sprinkler system) which function to protect the safety-related areas.
The basis for the justification is provided in the following fire area by fire area analyses for those safety-related areas of the Auxiliary Building that are provided with openings to the Turbine Building currently protected by water curtains. This analysis has been summarized from the Fort Calhoun Fire Hazards Analysis, Revision 3, dated September 29, 1988.
Fire Area 32 Comoressor Area Fire Area 32 is provided with two openings (1011-1 and 1011-11) to the Turbine Building on the 1011 ft elevation. All safety-related cabling and equipment in this area is located several feet below the elevation and is separated by at least 20 feet horizontally from the openings. The area is provided with an area-wide detection and automatic preaction water suppression system. An exposure fire in the Turbine Building would be prevented from spreading by the three-hour rated fire door installed in opening 1011-1 and the unrated steel access hatch installed in opening 1011-11. The quantity of combustibles in the vicinity of either opening is limited and consists primarily of IEEE-383 rated cable insulation. The Turbine Building is provided with manual hose stations, portable extinguishers, and also a wet-pipe sprinkler system below the 1011 f t elevation to suppress lube oil fires. Based on the limited combustibles, adequacy of barriers, and other available suppression systems, the water i curtains provided at the openings to this fire area are not required to protect safety-related equipment from an exposure fire in the Turbine Building.
Fire Area 36A East Switchaear Area Fire Area 36A is provided with two openings (1011-3 and 1011-4) to the Turbine Building on the 1011 ft elevation. The area is provided with an area-wide detection and automatic total flooding Halon 1301 suppression system. An exposure fire in the Turbine Building would be prevented from spreading by the three hour rated fire doors installed in each opening. The quantity of combustibles in the vicinity of each opening is limited and consists primarily .
of IEEE-383 rated cable insulatior,. The Turbine Building is provided with I
- manual hose stations, portable extinguishers, and also a wet-pipe sprinkler system below the 1011 ft elevation to suppress lube oil fires. Based on the limited combustibles, adequacy of barriers, and other available suppression systems, the water curtains provided at the openings to this fire area are not l required to protect safety-related equipment from an exposure fire in the Turbine Building.
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Fire Area 37 Battery Room 1 1
Fire Area 37 is provided with one opening (1011-2) to the Turbine Building on the 1011 ft elevation. An exposure fire in the Turbine Building m ld be prevented from spreading by the three hour rated fire door installed in the opening. The quantity of combustibles in the vicinity of the opening is ,
limited and consists primarily of liquid filled plastic battery casings. The :
Turbine Building is provided with a wet-pipe sprinkler system below the 1011 ft I elevation to suppress lube oil fires as well as manual hose stations and 1 portable extinguishers. Based on the limited combustibles, adequacy of barriers, and other available suppression systems, the water curtain provided at the opening to this fire area is not required to protect safety-related equipment from an exposure fire in the Turbine Building.
Fire Area 41 Cable Spreadino Room i Fire Area 41 is provided with one opening (1025 4) to the Turbine Building on the 1025 ft elevation. The area is provided with an area-wide detection and i automatic total flooding Halon 1301 suppression system. An exposure fire in the Turbine Building would be prevented from spreading by the UL Class IV bullet resistant door installed in the opening which provides an equivalent three hour fire rating. The quantity of combustibles in the vicinity of the door is limited and consists almost entirely of IEEE-383 rated cable insulation. The Turbine Building is provided with manual hose stations, portable extinguishers, and also a wet-pipe sprinkler system below the 1011 ft elevation to suppress lube oil fires. Based on the limited combustibles, adequacy of barriers, and other available suppression systems, the water curtain provided at the opening to this fire area is not required to protect safety-related equipment from an exposure fire in the Turbine Building.
Fire Area 42 Control Room Fire Area 42 is provided with two openings (1036-1 and 1036-2) to the Turbine Building on the 1036 ft elevation. Area wide detection is provided as is an autocatic total flooding Halon 1301 suppression system for the main walk-in control cabinet. An exposure fire in the Turbine Building would be prevented from spreading by the two UL Class IV bullet resistant doors installed in the openings which provide an equivalent three hour rating. The quantity of combustibles in the vicinity of the openings is limited. The Turbine Building is provided with manual hose stations, portable extinguishers, and also a rot-pipe sprinkler system below the 1011 ft elevation to suppress lube oil fires. Based on the limited combustibles, adequacy of barriers, and other available suppression systems, the water curtains provided at the openings to this fire area are not required to protect safety-related equipment from an exposure fire in the Turbine Building.
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Fire Area 43 Service and Condensate Tank Area Fire Area 43 is provided with one opening (1036-11) to the Turbine Building on the 1036 ft elevation. An exposure fire in the Turbine Building would be prevented from spreading by the three hour rated fire door installed in the opening. The quantity of combustibles in the vicinity of the opening is limited. The Turbine Building is provided with manual hose stations, portable -
extinguishers, and also a wet-pipe sprinkler system below the 1011 ft elevation .
to suppress lube oil fires. Based on the limited combustibles, adequacy of barriers, and other available suppression systems, the water curtain provided '
at the opening to this fire area is not required to protect safety-related .
equipment from an exposure fire in the Turbine Building. )
i Fire Area 44 (Fire Zone 46.1) Turbine Buildina Mechanical Eouipment Room .{
It should be noted that the Turbine Building Mechanical Equipment Room, also referred to as the fan coom, is actually located in the auxiliary building.
Fire Area 44 is provided with one large opening to the Turbine Building on the 1036 ft elevation. No safety-relateo equipment is located in this area. The water curtain provided at the opening to this fire area is, therefore, not required to protect safety-related equipment from an exposure fire in the Turbine Building.
Significant Hazards Consideration Analysis 10CFR 50.91(a)(1) requires that licensees requesting an Amendment provide an analysis addressing the significant hazards criteria of 10CFR 50.92.
Accordingly, the following is provided:
Based upon the discussion and justification noted above, the proposed change does not involve a significant hazards consideration because operation of Fort Calhoun Station in accordance with this change would not:
- 1. Involve a significant increase in the probability or consequences of an accident previously evaluated. This amendment will not result in l any physical plant changes. The intent of this change is to rectify a discrepancy of fire water curtain testing requirements as described in the Fort Calhoun USAR for Fire Protection Equipment described in the SER for Technical Specification Amendment 40. There will not be an increase in the probability or consequences of any accident since failure of the Turbine Suilding fire water suppression systems has been previously evaluated.
- 2. Create the possibility of a new or different type of accident than previously evaluated. These changes do not alter the manner in which equipment is operated or introduce new modes of operation. Therefore, this change does not create the possibility of a new or different type of accident.
- 3. Involve a significant reduction in the margin of safety. As no surveillance frequencies are being altered and no physical plant changes are being made, the proposed changes will not reduce the margin of plant safety.
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1 The water curtain installations are not required to protect safety-related l equipment from an exposure fire in the Turbine Building due to the adequacy of l other installed fire protection features, most notably the three hour rated fire doors or their equivalent. The deletion of this water curtain requirement ,
will not affect the ability of Fort Calhoun Station to safely shutdown following a fire as required by 10 CFR 50 Appendix R, Sections III.G and III.L. OPPD is therefore requesting removal of the requirement for the turbine building water curtains from the SER, towever, the actual physical installation will remain as an additional level of protection for the balance of plant fire suppression activities. OPPD will continue to treat the Turbine Building water curtain actuation valves as special hazard fusible-link sprinkler heads. The frequency of surveillance for the water curtain installations will not be altered. No procedures or programs will be affected by this deletion.
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