ML19289C976

Interim Rept Re Fire Protection in Operating Nuclear Power Stations.Provides Exceptions to Proposed Fire Protection in Ser.Discusses Valve Supervision,Hose Coupling Gaskets,Smoke Removal,Turbine Bldg.Proposed Mods Are Acceptable

ML19289C976
Person / Time
Site:	Indian Point
Issue date:	12/28/1978
From:	Randy Hall, Macdougall E BROOKHAVEN NATIONAL LABORATORY
To:	Ferguson R Office of Nuclear Reactor Regulation
References
CON-FIN-A-3107 NUDOCS 7901290066
Download: ML19289C976 (6)

Text

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BROOKHAVEN NATIONAL LABORATORY ASSOCIATED UNIVERSmES, INC.

Upton. New York 11073 Decartment of Nuc!ect Energy (516) 345- 2362 December 28, 1978 Division of Operating Reactors U.S. Nuclear Regulatory Comission Washington, D.C. 20555 .

Attention: Mr. Robert L. Ferguson Plant Systems Branch

Subject:

Fire Protection in Operating Nuclear Power Stations Indian Point Station, Unit 2 Safety Evaluation Reoort Review The Safety Evaluation Report, as developed jointly by the NRC staff and Brookhaven National Laboratory, (BNL), adequately reflects the concerns and recommendations of the consultants. Throughout the reevaluation of Indian Point Unit 2, 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 SER, will give reasonable assurance that the health and safety of the public is not endangered. The following exceptions represent a differing engineering point of view that should be evaluated by the NRC staff.

Valve Supervision SER Item 4.3.1.3 indicates that certain valves in the fire water piping system are electrically supervised such as the first gate valve upstream of control valves on water spray, sprinkler and foam systems, and suction and discharge valves at the fire pumps. Certain other valves are chained and locked in the open position. Electrical valve supervision should be pro-vided on sectionalizing valves and on all valves controlling fire water sys-tems. The present proposal of incorporating administrative controls and locks is unacceptable. See letter dated July 13, 1977 to Mr. R. L. Ferguson from Mr. R. E. Hall.

Hose Coupling Gaskets There is no provision in the Draft SER which satisfies the need to pro-vide two spare hose coupling gaskets in the sizes used at each hydrant hese cabinet, and all applicable hose stations of the plant. This is an important need, and particularly so in a plant using adapters to achieve hose thread compatibility with the local fire departments.

.NRC Researca anc Tec1nica 7 9 012 9 o o G N Assistance Report

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INTERIFl REPORT Accession No. 790 /6Ct croGC3

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Contract Program or Project

Title:

Fire Pr0Lection in Operating Nuclear Power Stations Subject of this Document: Indian Point Station, Unit 2 Safety Evaluation Report Review Type of Document: Letter Report Author (s): R. E. Hall and E. A. MacDougall Date of Document: December 28, 1978 Responsible NRC Individual Mr. Robert L. Ferguson and NRC Office or Division: Division of Operating Reactors Office of Nuclear Reactor Reg.

U.S. Nuclear Regulatory Commission

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Washington, D.C. 20555

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This document was prepared primarily for preliminary or internal use. It has not received full review and approval. Since there inay be substantive changes, this document should not be considered final.

Brookhaven National Laboratory Upton, NY 11973

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for the

. U.S. Department of Energy Prepared for U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Under Interagency Agreement EY-76-C-02-0016 NRC FIN No. A- 3107 INTERIFl REPORT

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Hose Stations SER Item 3.1.7 is vague and the word " AREAS" as used is too broad. It is imperative that the hose line must have sufficient length that an effective hose stream can be brought to bear on any spot or burning object wherever it may be in the area; merely " reaching to the door" of a room or compartment will not satisfy this requirement. Therefore, it is suggested that this alter-nate wording be used: " Manual hose stations shall be so located that an effective fire stream, when using an approved nozzle attached to not more than 100 feet of hose, can be brought to bear on any portion of any area containing safety-related equipment."

Smoke Removal SER Item 4.4.1 indicates that portable fans and ducts will be accepted as a means for removing smoke from many plant areas. Fires in electrical insula-tion can generate copious amounts of dense smoke which hamper fire control efforts by rendering the atmosphere toxic and reducing visibility in the area.

Properly used, self-contained breathing apparatus can minimize the problem of toxic atmosphere, but little can be done to improve visibility except to re-move the smoke from the building.

Massive changes will be required in most areas of this plant if effective permanent smoke removal systems are required, the design of which would also have to include consideration of radioactivity releases. While portable fans and ducts may be effective for smoke control in many instances, there is con-cern that they will not be sufficient for a major fire in some areas of the plant. It is recomended that this item be held open until better guidelines are developed for the evaluation of smoke generation potential and smoke re-moval system design.

Turbine Building SER Item 5.9 concludes that fire protection in the turbine building is acceptable. However, the licensee's fire hazard analysis does not adequately address the consequences of an unsuppressed lube oil fire in the turbine building (see October 24, 1977 letter from L. P. Herman to R. E. Hall on this subject). At this plant the turbine building is particularly critical, as compared to most other nuclear power plants, in that major portions of the building containing the lube oil piping system are not protected by automatic sprinklers.

The preceding statements are based on a detailed reevaluation of the fire protection program as implemented by the Consolidated Edison Company at the Indian Point Station - Unit 2. The analysis covered a review of the fire pre-vention, detection and suppression capabilities of the Indian Point Station -

Unit 2 as interfaced with the nuclear systems requirements. This was accom-a review team concept with members from Brookhaven plished Nationalby utilizing (BNL) and the Nuclear Regulatory Commission Division of Laboratory Operating Reactors staff.

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2. " Review of the Indian Point Station Fire Protection Program," dated December,1976 and Revisicn 1 dated April,1977 by Consolidated Edison Company of New York and Power Authority of the State of New York.

3. Consolidated Edison Company responses to Staff Positions and Requests for Additional Information dated May 17, 1978, May 26, 1978, September 18, 1978, November 16, 1978 and December 12, 1978.

4. Various engineering drawings prc/ided by Consolidated Edison Company including drawings: A-201030 Rev. 7; 155702-0; SK No. 2678, 2679, 2680, 2681, 2682, 2683; A200866.

5. December 5, 1978 draft Safety Evaluation Report.

The Indian Point - Unit 2 review has been conducted under the direction of M". E.A. MacDougall and myself of Reactor Engineering Analysis Group at BNL.

We have reviewed the analyses submitted by the licensee 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 aspects of fire protection related to the protection of the public from the standpoint of radiological health and safety. We have not considered aspects of fire pro-tection 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. The proposed modifications represent a significant increase in the level of protection against serious fire associated hazards.

Respectfully yours, ,

obert E. Hall, Group Leader Reactor Engineering Analysis REH:EAM:sd

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The fire protection evaluation for the Indian Point Station - Unit 2 is

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based on an analysis of documents submitted by the Consolidated Edison Company to the Nuclear Regulatory Commission and a site visit. The site visit was conducted by Mr. H. George and Mr. J. Knight of the NRC; Mr. P. Herman of Rolf Jensen and Associates, Inc., under contract to Brookhaven National Labor-atory; and Mr. J. Riopelle consultant to BNL. Mr. Riopelle was under contract to BNL to review the manual fire fighting capabilities of the station along with administrative controls.

Milestone Dates

1. The Con Ed " Review of the Indian Point Station Fire Protection Program" was transmitted to NRC on December 15, 1976; a complete revision of this document was transmitted to NRC on April 15, 1977.

2. By letter of March 3, 1978,' Consolidated Edison Company was provided with NRC requests for additional information and staff positions pertaining to fire protection at the Indian Point Station, Unit 2 facility.

3. On May 17 and 26, 1978, Consolidated Edison Company provided a sub-mittal responding to NRC requests for additior:al information and staff positions of March 3, 1978.

4 On June 13-16, 1978, the D0R fire protection revieu team visited the Indian Point Station, Unit 2.

5. On July 18, 1978 and August 31, 1978 the review team identified addi-tional staff positions and requested additional information based on the site visit.

6. By letter of September 18, 1978, Consolidated Edison Company provided a submittal responding to a portion of the Staff Positions and Re-quests for Additional Information of July 18, 1978 and August 31, 1978.

7. On November 2,1978 the review team identified additional staff posi-tions and requested additional information.

8. By letter of November 16, 1978 and December 12, 1978 Consolidated Edison Company provided a submittal responding to a portion of the Staff Positions and Requests for Additional Information.

9. On December 5, 1978, the draft Safety Evaluation Report was trans-mitted from Plant Systems Branch to the Operating Reactors Branch No. 1.

Review Documents The following documents were used in the Indian Point Station, Unit 2 Fire Protection Reevaluation:

1. NRC Branch Technical Position AFCSB 9.5-1, Appendix A, dated August 23, 1976.

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DISTRIBUTICN M. Antonetti 1 I. Asp 1 V. Benaroya 1 E. Blackwood 1 W. Butler 1

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R. Cerbone 1

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D. Eisenhut 1 R. Feit 1 R. Ferguson 5 R. Hall 1 S. Hanauer 1 P. Herman 1 E. Imbro 1 W. Kato 1 J. Klevan 1 G. Lainas 1 C. Long 1 E. MacDougall 1 J. Riopelle 1 V. Stello 1 T. Telford 1 H. Todosow 2 J. Townley 1

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PDR 2