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| issue date = 12/06/1978
| issue date = 12/06/1978
| title = Discusses Fire Protection in Operating Nuclear Power Stations,In Particular Providing Analysis of Facilities' Ser.Proposed Fire Protection Mod Increases Level of Protection Against Fire Hazards
| title = Discusses Fire Protection in Operating Nuclear Power Stations,In Particular Providing Analysis of Facilities' Ser.Proposed Fire Protection Mod Increases Level of Protection Against Fire Hazards
| author name = HALL R E
| author name = Hall R
| author affiliation = BROOKHAVEN NATIONAL LABORATORY
| author affiliation = BROOKHAVEN NATIONAL LABORATORY
| addressee name = FERGUSON R L
| addressee name = Ferguson R
| addressee affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| addressee affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| docket = 05000250, 05000251
| docket = 05000250, 05000251
Line 17: Line 17:


=Text=
=Text=
{{#Wiki_filter:p p'O(p REGULATOR NFORMATION DOCKET NB 2 p RECIPIENT:
{{#Wiki_filter:p'O(p p                            REGULATOR       NFORMATION DISTRIBUTION                STEM DOCKET NB               2 p                                 DOC    DATE:
PERDU ON ORIGINATOR:
RECIPIENT:           PERDU ON                               ACCESSION NBR:
HAL DISTRIBUTION STEM DOC DATE: ACCESSION NBR: COPIES RECEIVED: COMPAN~-FL PWR&LI HT  
ORIGINATOR:           HAL                                   COPIES RECEIVED:
COMPAN~- FL         PWR & LI HT                           LTR                  'NCL


==SUBJECT:==
==SUBJECT:==
LTR SI ZE: 5+9'NCL Discusses fire rotec in o eratin nuc wr stations in articular rovidin an analysis of facils'ER.
SI ZE: 5+9 Discusses       fire rotec in   o eratin   nuc wr stations in articular rovidin     an analysis       of facils'ER.       Asserts that ro osed fire rotec mod re resents       n increase in level of protec against           fire hazards'.
Asserts that ro osed fire rotec mod re resents n increase in level of protec against fire hazards'.OISTRTBUT?ON CODE t A006 OISTR)RUT?ON TITLE l FTRE PROTECTION I~FARNATION (AFTER ISSU4NCE OF OL), NOTARI ZED NAPE 8 EG FTL I 8 E OELD AUXILT ARY SYS BR 40 FOR SYS 8, PRI)J PLANT SYSTEMS HR 8 A l4l 9 A C H R HURANAKA HANAUFR LPDR TERA NSIC ACRS ENCLV N/ll ENCL~/ENCL~/F hlCL lv/7 ENCL LTR ONLY'li/2 E NC L W/ENCL W/g tv/ENCL W/ENCL~/ENCL>/ENCL</ENCL W/ENCI'H/16 ENCL FOR ACTION~ORB//1 BC TOT A[NUHRER OF COPIES REAUIRF0 I LTR ENCL 3c)38 DEC Z3 197S A3)D BRINKMAN W/ENCL.
OISTRTBUT?ON CODE t             A006 OISTR)RUT?ON TITLE l                                                                 NOTARIZED FTRE PROTECTION I~FARNATION (AFTER ISSU4NCE OF                     OL),
K='BROOKHAVEN NATIONAL LABORATORY ASSOCIATED UNIVERSITIES, INC.'on, New York 11973 Department of Nuclear Energy (516)385-2144 6 December 1978 Division of Operating Reactors U.S.Nuclear Regulatory Commission Washington, D.C.'0555 Attention:
NAPE                             ENCLV                      FOR ACTION N/ll ENCL           ~ ORB//1 BC 8
Mr.Robert L.Ferguson Plant Systems Branch  
EG FTL                          ~/ENCL
                                        ~/F hlCL I  8    E                      lv/7 ENCL OELD                              LTR ONLY AUXILTARY SYS BR                  'li/2 E NC L 40 FOR SYS 8, PRI)J              W/ENCL PLANT SYSTEMS HR                  W/g 8 A l4l 9 A C H                  tv/ENCL R  HURANAKA                      W/ENCL HANAUFR                          ~/ENCL LPDR                              >/ENCL TERA                              </ENCL NSIC                              W/ENCI ACRS                              'H/16 ENCL TOT A[     NUHRER OF COPIES       REAUIRF0 I LTR           3c)
ENCL          38 DEC Z3 197S A3)D BRINKMAN W/ENCL.
 
BROOKHAVEN NATIONAL LABORATORY ASSOCIATED UNIVERSITIES, INC.
K='
                                                                            'on, New York 11973 Department of Nuclear Energy                                               (516) 385- 2144 6 December 1978 Division of Operating Reactors U.S. Nuclear Regulatory Commission Washington, D.C. '0555 Attention:   Mr. Robert L. Ferguson Plant Systems Branch


==Dear Bob:==
==Dear Bob:==
~Sub ect: Fire Protection in 0 aretine Nuclear Power Stations-Turke Point Nuc ear Power P ant Safet Eva uatson Re ort Review The Safety Evaluation Report, as developed jointly by the NRC staff and Brookhaven National Laboratory (BNL), adequately reflects the concerns and re-commendations of the consultants.
 
Throughout the reevaluation of Turkey Point there has been general agreement between the NRC staff and the BNL consultants.
    ~Sub ect:   Fire Protection in 0 aretine Nuclear     Power Stations - Turke     Point Nuc ear Power P ant Safet     Eva uatson Re ort Review The Safety Evaluation Report, as developed jointly by the NRC staff and Brookhaven National Laboratory (BNL), adequately reflects the concerns and re-commendations of the consultants.       Throughout the reevaluation of Turkey Point there has been general agreement between the NRC staff and the BNL consultants.
Based on present data, the proposed fire protection, as set forth in the draft SER, will provide significant enhancement of the fire protection program at the Turkey Point Plants, and thus, represents significant progress towards a com-prehensive fire protection program.The following subjects represent the re-solutions of the items of concern as discussed in a letter dated September 21, 1978 from R.E.Hall (BNL)to R.L.Ferguson (NRC), see attached.The final SER has not yet been received, and therefore, this discussion is based on an NRC memorandum from G.C.Lainas to A.Schwencer dated August 15, 1978 containing the originally reviewed draft SER and numerous.discussions and meetings between the staff and BNL.~Water Su 1 for Fire Protection The adequacy of the dedicated fire protection water supply at the Turkey Point Units remains questionable.
Based on present data, the proposed fire protection, as set forth in the draft SER, will provide significant enhancement of the fire protection program at the Turkey Point Plants, and thus, represents significant progress towards a com-prehensive fire protection program. The following subjects represent the re-solutions of the items of concern as discussed in a letter dated September 21, 1978 from R.E. Hall (BNL) to R.L. Ferguson (NRC), see attached.           The final SER has not yet been received, and therefore, this discussion is based on an NRC memorandum from G.C. Lainas to A. Schwencer dated August 15, 1978 containing the originally reviewed draft SER and numerous. discussions and meetings between the staff and BNL.
The administrative control, to guarantee a minimum of 180,000 gallons cannot be endorsed since the required information to determine the plant's maximum demands has not been submitted by the licensee.In addition, administrative controls should not replace the required physical dedication.
    ~   Water Su   1 for Fire Protection The adequacy     of the dedicated fire protection   water supply at the Turkey Point Units remains questionable. The       administrative control, to guarantee a minimum   of 180,000 gallons cannot be     endorsed since the required information to determine the plant's maximum demands has not been submitted by the licensee.
This discussion is contained in the attached letter of September 21, 1978.At this time it is our understanding that the subject of an adequate water supply for fire protection will be an open item in the safety evaluation.
In addition, administrative controls should not replace the required physical dedication. This discussion is contained in the attached letter of September 21, 1978.
Upon the receipt of further information from the licensee, the evaluation will be completed.
At this time     it is our understanding that the subject of an adequate water supply for fire protection will be an open item in the safety evaluation. Upon the receipt of further information from the licensee, the evaluation will be completed.
Og~gP Mr.Robert L.Ferguson December 6, 1978 4 Redundanc in Mater Su 1 The requirements of Appendix A to the Branch Technical Position 9.5-1, dated August 23, 1976, are such that two separate water supplies be provided.The licensee, at this time, does not meet this criteria and proposes to make available a spool piece to allow the use of the screen wash pumps, salt water, as the secondary sour ce.Due to the unanswered questions regarding the maxi-mum water demand and the capabilities of the screen wash pump's, this item should also be held as an open item, reference attached letter of September 21, 1978.~Cable Protection
Og
-Area 58 Fire Area 58 contains a large volume of safety-related cables for both Units 3 and 4.In addition, this area is the main access hallway to the auxi-liary building and as such is exposed to numerous transient combustibles, see letter of September 21, 1978.The licensee proposal to administratively con-trol the flammable and combustible liquids in this area does not resolve the problem.The falme retardant cable coatings will retard flame propagation but this does not remove the possibility of a fire occurring that could affect both safety channels of Unit 3 as well as Unit 4.There is a need to determine if relative remote shutdown capabilities exist for this area for both units in the event ot a fire.Based on this information conclusions can be drawn as to the adequacy of the protection.
                                                                                                ~gP
o Cable Protection
 
-Cable S readin Room Upon reviewing the licensee submittal and visiting the site of Turkey Point Units 3 and 4, conclusions cannot be drawn as to the ability of the units to remotely shut down.This assumes the loss of the cable spreading room.Based on discussion with the NRC staff, we recommend that the licensee reevaluate this capability while investigating the same situation in Fire Area 58.Upon receipt of this reevaluation, a conclusion can be drawn as to the required fire protec-tion in, the cable spreading room.~Yd II d Our letter of September 21, 1978 recommended the installation of a 2-1/2" gate valve on each 2-1/2" hydrant outlet in place of only one throttling valve per unit.Upon reevaluation, with new information supplied to BNL by the hy-drant manufacturer, we conclude that the single valve should be acceptable.
Mr. Robert L. Ferguson                                                     December 6, 1978 4   Redundanc     in Mater   Su   1 The requirements of Appendix A to the Branch Technical Position 9.5-1, dated August 23, 1976, are such that two separate water supplies be provided.
Mhile the second valve would still aid the fire fighters in throttling and ad-ding hose line, it has been determined that our concern about undermining the hydrant by throttling it has been resolved.At this time we recommend approval of the licensee position.
The licensee, at this time, does not meet this criteria and proposes to make available a spool piece to allow the use of the screen wash pumps, salt water, as the secondary sour ce.         Due to the unanswered questions regarding the maxi-mum water demand and the capabilities of the screen wash pump's, this item should also be held as an open item, reference attached letter of September 21, 1978.
Mr.Robert L.Ferguson December 6, 1978 o Smoke Ventin E ui ment The concept of utilizing two 5,000 CFM or greater smoke ejectors in place of the BNL recormended three unit scheme, reference letter of September 21, 1978, is marginally acceptable.
~   Cable Protection     - Area 58 Fire Area   58 contains a large volume of safety-related cables for both Units 3 and   4. In addition, this area is the main access hallway to the auxi-liary building and as such is exposed to numerous transient combustibles, con-            see letter of September 21, 1978. The licensee proposal to administratively trol the flammable and combustible liquids in this area does not resolve the problem. The falme retardant cable coatings will retard flame propagation but this does not remove the possibility of a fire occurring that could affect both safety channels of Unit 3 as well as Unit 4.
Although the two units do not allow for as versatile a smoke moving capability, if sized correctl they should prove adequate.In addition, the problem of utilization of the third unit in the event of an ejector failure can be resolved by a proper maintenance and testing program.We there-fore recommend at this time, the acceptance of the licensee program.~Turbine Buildin Subsequent to the September 21 letter, concerns have developed regarding the adequacy of the fire protection for cable systems in the turbine building.We recommend that the licensee perform a more, realistic evaluation of the po-tential for safety-related cable damage given an oil fire in this location.~Valve Su ervision Electrical valve supervision should be provided on all valves controlling fire water systems and sectionalizing valves.The present proposal of adminis-trative controls or locks is unacceptable.
There is   a need   to determine       if relative remote shutdown capabilities exist ot a fire. Based on this information for this area   for both   units     in the   event conclusions can     be drawn   as   to   the adequacy   of the protection.
See letter dated July 13, 1977 to Mr.R.L.Ferguson from Mr.R.E.Hall.The preceding statements are a result of a detailed evaluation of the fire protection program as implemented by the Florida Power and Light Company at the Turkey Point Nuclear Power Station.The analysis covered a review of the fire prevention, detection and suppression capabilities of Units 3 and 4 of this plant as interfaced with the nuclear systems requirements.
o   Cable Protection     - Cable     S readin     Room Upon reviewing the licensee submittal and visiting the site of Turkey Point Units 3 and 4, conclusions cannot be drawn as to the ability of the units to remotely shut down. This assumes the loss of the cable spreading room. Based on discussion with the NRC staff, we recommend that the licensee reevaluate this capability while investigating the same situation in Fire Area 58. Upon receipt of this reevaluation, a conclusion can be drawn as to the required fire protec-tion in, the cable spreading room.
This was accomplished by utilizing a review team concept with members from Brookhaven National Labora-tory (BNL)and the Nuclear Regulatory Commission Division of Operating Reactors staff.The fire protection evaluation for Turkey Point is based on an analysis of documents submitted by the Florida Power and Light Company to the Nuclear Regu-latory Coranission and a site visit.The site visit was conducted by Mr.T.Dunning and Mr.L.Derderian of the NRC;Mr.M.Antonetti of Gage-Babcock and Associates, Inc., under contract to BNL;and Mr.John Townley, consultant to BNL.Mr.J.Townley was under contract to BNL to review the manual fire fight-ing capabilities of the station along with administrative controls.This review has been conducted under the direction of Mr.E.MacDougall and myself of the Reactor Engineering Analysis Group at BNL.We have reviewed the Turkey Point Nuclear Power Plant (the licensee)analy-ses and have visited the facility to examine the relationship of safety-related components, systems and structures with both combustibles and the associated fire detection and suppression systems.Our review has been limited to the as-pects of fire protection related to the protection of the public from the stand-point of radiological health and safety.We have not considered aspects of fire Mr.Robert L.Ferguson December 6, 1978 protection associated with life safety of onsite personnel and with property protection, unless they impact the health and safety of the public due to the release of radioactive material.It is our conclusion that the proposed fire protection modification, as discussed in the SER and as might be implemented by the items discussed above, represents an increase in the level of protection against serious fire asso-ciated hazards.obert E.Hall, Group Leader Reactor Safety Analysis REH:yo Attachment DISTRIBUTION H.Antonetti I.Asp V.Benaroya E.Blackwood!l.Butler R.Cerbone D.Eisenhut R.Feit R.Ferguson R.Hall S.Hanauer P.Herman E.Imbro!l.Kato J.Kievan G.Lainas C.Long E.t)ac0ougall J.Riooelle V.Stello T.Telford H.Todosow J.Townley PDR}}
    ~Yd   II d Our   letter of   September       21, 1978 recommended the installation of a 2-1/2" gate valve on each     2-1/2"     hydrant     outlet in place of only one throttling valve per unit. Upon     reevaluation,       with   new information supplied to BNL by the hy-drant manufacturer,     we   conclude       that the single valve should be acceptable.
Mhile the second valve would still aid the fire fighters in throttling and ad-ding hose line,     it has been determined that our concern about undermining the hydrant by throttling       it has been resolved.         At this time we recommend approval of the licensee position.
 
Mr. Robert L. Ferguson                                   December 6, 1978 o   Smoke Ventin   E ui ment The concept of utilizing two 5,000 CFM or greater smoke ejectors in place of the BNL recormended three unit scheme, reference letter of September 21, 1978, is marginally acceptable. Although the two units do not allow for as versatile a smoke moving capability, if sized correctl       they should prove adequate. In addition, the problem of   utilization   of the third unit in the event of an ejector failure can be resolved by a proper maintenance and testing program. We there-fore recommend at this time, the acceptance of the licensee program.
~   Turbine Buildin Subsequent   to the September 21 letter, concerns have developed regarding the adequacy of the   fire protection for cable systems in the turbine building.
We recommend that the licensee perform a more, realistic evaluation of the po-tential for safety-related cable damage given an oil fire in this location.
~   Valve Su ervision Electrical valve supervision should be provided on all valves controlling fire water systems and sectionalizing valves. The present proposal of adminis-trative controls or locks is unacceptable. See letter dated July 13, 1977 to Mr. R.L. Ferguson from Mr. R.E. Hall.
The preceding statements are a result of a detailed evaluation of the fire protection program   as implemented by the Florida Power and Light Company at the Turkey Point Nuclear Power Station. The analysis covered a review of the fire prevention, detection and suppression capabilities of Units 3 and 4 of this plant as interfaced with the nuclear systems requirements. This was accomplished by utilizing a review team concept with members from Brookhaven National Labora-tory (BNL) and the Nuclear Regulatory Commission Division of Operating Reactors staff.
The fire protection evaluation for Turkey Point is based on an analysis of documents submitted by the Florida Power and Light Company to the Nuclear Regu-latory Coranission and a site visit. The site visit was conducted by Mr. T.
Dunning and Mr. L. Derderian of the NRC; Mr. M. Antonetti of Gage-Babcock and Associates, Inc., under contract to BNL; and Mr. John Townley, consultant to BNL. Mr. J. Townley was under contract to BNL to review the manual fire fight-ing capabilities of the station along with administrative controls. This review has been conducted under the direction of Mr. E. MacDougall and myself of the Reactor Engineering Analysis Group at BNL.
We have reviewed the Turkey Point Nuclear Power Plant (the licensee)     analy-ses and have visited the   facility to examine the relationship of safety-related components, systems and structures with both combustibles and the associated fire detection and suppression systems. Our review has been limited to the as-pects of fire protection related to the protection of the public from the stand-point of radiological health and safety. We have not considered aspects of fire
 
Mr. Robert L. Ferguson                                 December 6, 1978 protection associated with life safety of onsite personnel and with property protection, unless they impact the health and safety of the public due to the release of radioactive material.
It is our conclusion that the proposed fire protection modification, as discussed in the SER and as might be implemented by the items discussed above, represents an increase in the level of protection against serious fire asso-ciated hazards.
obert E. Hall, Group Leader Reactor Safety Analysis REH:yo Attachment
 
DISTRIBUTION H. Antonetti I. Asp V. Benaroya E. Blackwood
!l. Butler R. Cerbone D. Eisenhut R. Feit R. Ferguson R. Hall S. Hanauer P. Herman E. Imbro
!l. Kato J. Kievan G. Lainas C. Long E. t)ac0ougall J. Riooelle V. Stello T. Telford H. Todosow J. Townley PDR}}

Latest revision as of 11:47, 22 October 2019

Discusses Fire Protection in Operating Nuclear Power Stations,In Particular Providing Analysis of Facilities' Ser.Proposed Fire Protection Mod Increases Level of Protection Against Fire Hazards
ML17338A344
Person / Time
Site: Turkey Point  NextEra Energy icon.png
Issue date: 12/06/1978
From: Randy Hall
BROOKHAVEN NATIONAL LABORATORY
To: Ferguson R
Office of Nuclear Reactor Regulation
Shared Package
ML17338A345 List:
References
NUDOCS 7812120119
Download: ML17338A344 (6)


Text

p'O(p p REGULATOR NFORMATION DISTRIBUTION STEM DOCKET NB 2 p DOC DATE:

RECIPIENT: PERDU ON ACCESSION NBR:

ORIGINATOR: HAL COPIES RECEIVED:

COMPAN~- FL PWR & LI HT LTR 'NCL

SUBJECT:

SI ZE: 5+9 Discusses fire rotec in o eratin nuc wr stations in articular rovidin an analysis of facils'ER. Asserts that ro osed fire rotec mod re resents n increase in level of protec against fire hazards'.

OISTRTBUT?ON CODE t A006 OISTR)RUT?ON TITLE l NOTARIZED FTRE PROTECTION I~FARNATION (AFTER ISSU4NCE OF OL),

NAPE ENCLV FOR ACTION N/ll ENCL ~ ORB//1 BC 8

EG FTL ~/ENCL

~/F hlCL I 8 E lv/7 ENCL OELD LTR ONLY AUXILTARY SYS BR 'li/2 E NC L 40 FOR SYS 8, PRI)J W/ENCL PLANT SYSTEMS HR W/g 8 A l4l 9 A C H tv/ENCL R HURANAKA W/ENCL HANAUFR ~/ENCL LPDR >/ENCL TERA </ENCL NSIC W/ENCI ACRS 'H/16 ENCL TOT A[ NUHRER OF COPIES REAUIRF0 I LTR 3c)

ENCL 38 DEC Z3 197S A3)D BRINKMAN W/ENCL.

BROOKHAVEN NATIONAL LABORATORY ASSOCIATED UNIVERSITIES, INC.

K='

'on, New York 11973 Department of Nuclear Energy (516) 385- 2144 6 December 1978 Division of Operating Reactors U.S. Nuclear Regulatory Commission Washington, D.C. '0555 Attention: Mr. Robert L. Ferguson Plant Systems Branch

Dear Bob:

~Sub ect: Fire Protection in 0 aretine Nuclear Power Stations - Turke Point Nuc ear Power P ant Safet Eva uatson Re ort Review The Safety Evaluation Report, as developed jointly by the NRC staff and Brookhaven National Laboratory (BNL), adequately reflects the concerns and re-commendations of the consultants. Throughout the reevaluation of Turkey Point there has been general agreement between the NRC staff and the BNL consultants.

Based on present data, the proposed fire protection, as set forth in the draft SER, will provide significant enhancement of the fire protection program at the Turkey Point Plants, and thus, represents significant progress towards a com-prehensive fire protection program. The following subjects represent the re-solutions of the items of concern as discussed in a letter dated September 21, 1978 from R.E. Hall (BNL) to R.L. Ferguson (NRC), see attached. The final SER has not yet been received, and therefore, this discussion is based on an NRC memorandum from G.C. Lainas to A. Schwencer dated August 15, 1978 containing the originally reviewed draft SER and numerous. discussions and meetings between the staff and BNL.

~ Water Su 1 for Fire Protection The adequacy of the dedicated fire protection water supply at the Turkey Point Units remains questionable. The administrative control, to guarantee a minimum of 180,000 gallons cannot be endorsed since the required information to determine the plant's maximum demands has not been submitted by the licensee.

In addition, administrative controls should not replace the required physical dedication. This discussion is contained in the attached letter of September 21, 1978.

At this time it is our understanding that the subject of an adequate water supply for fire protection will be an open item in the safety evaluation. Upon the receipt of further information from the licensee, the evaluation will be completed.

Og

~gP

Mr. Robert L. Ferguson December 6, 1978 4 Redundanc in Mater Su 1 The requirements of Appendix A to the Branch Technical Position 9.5-1, dated August 23, 1976, are such that two separate water supplies be provided.

The licensee, at this time, does not meet this criteria and proposes to make available a spool piece to allow the use of the screen wash pumps, salt water, as the secondary sour ce. Due to the unanswered questions regarding the maxi-mum water demand and the capabilities of the screen wash pump's, this item should also be held as an open item, reference attached letter of September 21, 1978.

~ Cable Protection - Area 58 Fire Area 58 contains a large volume of safety-related cables for both Units 3 and 4. In addition, this area is the main access hallway to the auxi-liary building and as such is exposed to numerous transient combustibles, con- see letter of September 21, 1978. The licensee proposal to administratively trol the flammable and combustible liquids in this area does not resolve the problem. The falme retardant cable coatings will retard flame propagation but this does not remove the possibility of a fire occurring that could affect both safety channels of Unit 3 as well as Unit 4.

There is a need to determine if relative remote shutdown capabilities exist ot a fire. Based on this information for this area for both units in the event conclusions can be drawn as to the adequacy of the protection.

o Cable Protection - Cable S readin Room Upon reviewing the licensee submittal and visiting the site of Turkey Point Units 3 and 4, conclusions cannot be drawn as to the ability of the units to remotely shut down. This assumes the loss of the cable spreading room. Based on discussion with the NRC staff, we recommend that the licensee reevaluate this capability while investigating the same situation in Fire Area 58. Upon receipt of this reevaluation, a conclusion can be drawn as to the required fire protec-tion in, the cable spreading room.

~Yd II d Our letter of September 21, 1978 recommended the installation of a 2-1/2" gate valve on each 2-1/2" hydrant outlet in place of only one throttling valve per unit. Upon reevaluation, with new information supplied to BNL by the hy-drant manufacturer, we conclude that the single valve should be acceptable.

Mhile the second valve would still aid the fire fighters in throttling and ad-ding hose line, it has been determined that our concern about undermining the hydrant by throttling it has been resolved. At this time we recommend approval of the licensee position.

Mr. Robert L. Ferguson December 6, 1978 o Smoke Ventin E ui ment The concept of utilizing two 5,000 CFM or greater smoke ejectors in place of the BNL recormended three unit scheme, reference letter of September 21, 1978, is marginally acceptable. Although the two units do not allow for as versatile a smoke moving capability, if sized correctl they should prove adequate. In addition, the problem of utilization of the third unit in the event of an ejector failure can be resolved by a proper maintenance and testing program. We there-fore recommend at this time, the acceptance of the licensee program.

~ Turbine Buildin Subsequent to the September 21 letter, concerns have developed regarding the adequacy of the fire protection for cable systems in the turbine building.

We recommend that the licensee perform a more, realistic evaluation of the po-tential for safety-related cable damage given an oil fire in this location.

~ Valve Su ervision Electrical valve supervision should be provided on all valves controlling fire water systems and sectionalizing valves. The present proposal of adminis-trative controls or locks is unacceptable. See letter dated July 13, 1977 to Mr. R.L. Ferguson from Mr. R.E. Hall.

The preceding statements are a result of a detailed evaluation of the fire protection program as implemented by the Florida Power and Light Company at the Turkey Point Nuclear Power Station. The analysis covered a review of the fire prevention, detection and suppression capabilities of Units 3 and 4 of this plant as interfaced with the nuclear systems requirements. This was accomplished by utilizing a review team concept with members from Brookhaven National Labora-tory (BNL) and the Nuclear Regulatory Commission Division of Operating Reactors staff.

The fire protection evaluation for Turkey Point is based on an analysis of documents submitted by the Florida Power and Light Company to the Nuclear Regu-latory Coranission and a site visit. The site visit was conducted by Mr. T.

Dunning and Mr. L. Derderian of the NRC; Mr. M. Antonetti of Gage-Babcock and Associates, Inc., under contract to BNL; and Mr. John Townley, consultant to BNL. Mr. J. Townley was under contract to BNL to review the manual fire fight-ing capabilities of the station along with administrative controls. This review has been conducted under the direction of Mr. E. MacDougall and myself of the Reactor Engineering Analysis Group at BNL.

We have reviewed the Turkey Point Nuclear Power Plant (the licensee) analy-ses and have visited the facility to examine the relationship of safety-related components, systems and structures with both combustibles and the associated fire detection and suppression systems. Our review has been limited to the as-pects of fire protection related to the protection of the public from the stand-point of radiological health and safety. We have not considered aspects of fire

Mr. Robert L. Ferguson December 6, 1978 protection associated with life safety of onsite personnel and with property protection, unless they impact the health and safety of the public due to the release of radioactive material.

It is our conclusion that the proposed fire protection modification, as discussed in the SER and as might be implemented by the items discussed above, represents an increase in the level of protection against serious fire asso-ciated hazards.

obert E. Hall, Group Leader Reactor Safety Analysis REH:yo Attachment

DISTRIBUTION H. Antonetti I. Asp V. Benaroya E. Blackwood

!l. Butler R. Cerbone D. Eisenhut R. Feit R. Ferguson R. Hall S. Hanauer P. Herman E. Imbro

!l. Kato J. Kievan G. Lainas C. Long E. t)ac0ougall J. Riooelle V. Stello T. Telford H. Todosow J. Townley PDR