ML19274D182

Responds to 781220 Request for Info Re Fire Protection Program.Forwards Answers to Questions Re Combined Fire & Security Emergency Plan,Fire Brigade Equipment,Shared Emergency Equipment & Operation,Testing,& Maintenance

ML19274D182
Person / Time
Site:	Crystal River
Issue date:	01/09/1979
From:	Stewart W FLORIDA POWER CORP.
To:	Reid R Office of Nuclear Reactor Regulation
References
3--3-A-3, 3-0-3-A-3, NUDOCS 7901150138
Download: ML19274D182 (19)

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09L W. P. STEWART, DIR ECTOR g{ POWER PRODUCTION 9 , ,

January 9, 1979 Mr. Robert W. Reid Chief, Operations Reactors Branch #4 Division of Operating Reactors U.S. Nuclear Regulatory Commission Washington, DC 20555

SUBJECT:

Crystal River Unit 3 Docket No. 50-302 Operating I,4 cense No. DPR-72

Dear Mr. Reid:

On December 26, 1978, Florida Power Corporation received your Request for Additional Information, dated December 20, 1978, concerning the CR#3 Fire Protection Progam. You stated that the concerns identified in Enclosures 2, 3 and 4 of your letter are a result of your staff's review of FPC's submittals, dated June 22, 1978 and May 30, 1978, from observations made during the NRC staff site visit, or from the review of information subsequent to the site visit. You also indicated that some of these questions were previously sent to FPC in h1C letters, dated November 14, 1978 and November 21, 1978.

Therefore, this letter is being submitted by Florida Power Corporation in response to the NRC's letters of November 14, 1978, November 21, 1978 and December 20, 1978. Our responses or schedule for response are contained in Enclosures 1 through 4 of this letter.

A schedule for completion, including 90 days for NRC review, for all modifications contemplated at CR#3 for the Fire Protection Program is currently being developed and will be submitted at a later date.

Should you or members of your staff wish to discuss our responses or schedule for response to these NRC concerns, please contact this office.

Very truly yours, FLORIDA POWER CORPORATION

- . R1.M W.P. Stewart File: 3-0-3-a-3 WPS/ECS/hicT01 (1/9/79D3) ]$d M8 O /3 General Office 3201 Thirty-fourth Street South e P O Box 14042. St. Petersburg. Ronda 33733 e 813-866-5151

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STATE OF FLORIDA COUNTY OF PINELLAS W.P. Stewart states that he is the Director, Power Production, of Florida Power Corporation; that he is authorized on the part of said company to sign and file with the Nealear Regulatory Commission the information attached hereto; and that all such statements made and matters set forth therein are true and correct to the best of his knowledge, information and belief.

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W.P. Stewart Subscribed and sworn to before me, a Notary Public in and for the State and County above named, thi.s 9th day of January,1979.

- W W Notarf Public Notary Public, State of Florida at Large, My Commission Expires: August 24, 1979

ENCLOSURE NO. 1

' FIRE PROTECTION STAFF REVIEW REQUEST FOR ADDITIONAL INFORMATION CONCERNING ADMINISTRATIVE CONTROLS (NRC letter dated November 21, 1978)

QUESTIONS RESPONSE SCHEDULE 72 parts (a) through (h) February 27th POSITION P-5 February 27tt.

Simpson (FireProt)

(1/8D9)

ENCLOSURE NO. 2 FIRE PROTECTION STAFF REVIEW REVISED LIST OF NRC QUESTIONS (NOVEMBER 14, 1978 NRC LETTER),

REQUEST FOR ADDITIONAL INFORMATION, NRC STAFF POSITIONS, AND REQUEST FOR DRAWINGS CRYSTAL RIVER 3 NUCLEAR STATION Docket No. 50-302 QUESTIONS RESPONSE SCHEDULE 1 Enclosed 2 February 27 3 February 27 4 February 13 9 Enclosed 10 Enclosed 11 Enclosed 12 Enclosed 17 February 13 21 February 13 23 January 29 24 February 13 25 February 27 26 March 29 29 February 27 30 January 29 31 February 13 32 Enclosed 33 February 27 37 February 27 38 February 27 46 Enclosed 55 March 29 56 January 29 57 February 27 58 Enclosed 66 February 13 68 January 29 69 February 13 71 January 29 72 February 27 73 January 29 Simpson (FireProt)

(1/8D9)

ENCLOSURE 2 QUESTION 1. Combined Fire and Security Emergency Describe the responsibilities of key plant personnel, in the event of a combined fire and security emergency.

RESPONSE: There are independent entities for fire and security emergencies. Each performs it's primary assigned function by procedure until the emergency has subsided. Coordination between the Fire Brigade and Security in an emergency situation which involves both entities is governed by D4-211

" Duties of the Plant Guards."

The Fire Brigade is composed of operation and maintenance personnel. Their qualifications are defined in EM-101 " Fire Protection Plan." These are reviewed in Docket No. 50-302

" Fire Protection Program Review."

QUESTION 9. Fire Brigade Equipment Describe the equipment provided for the fire brigade.

Describe means that will be used to either override the locking mechanism, or breach a barrier to provide fire brigade access and personnel egress in the event of a locking mechanism failure. Describe the training and tools provided for this purpose.

RESPONSE: Personal equipment consists of Fire Service approved bunker gear, helmet, gloves and boots. Fire Service approved fire fighting equipment and tools are as follows:

(1) Self-contained breathing ;raratus (2) Hose (various types)

(3) Nozzles: Inplant, fog; plant exterior, fog and straight (4) Foam and eductors (5) Portable lights (6) Portable ventilators with flexible duct (7) Door and window braces (8) Pick-headed axes (9) Fire extinguishers, Classes A, B and C in various combinations and sizes, strategic to location (10) Various central extinguishing systems composed of water (standpipe and sprinklers), CO 2, and halon.

In the event of door locking mechanism failure, the door will be checked for hinge arrangement and lock type. Depending on the situation at hand, the most practible course of torcible entry will be executed in accordance with standard fire service techniques. Tools for forcible entry include pick headed axes and pry bars.

Simpson (FireProt)

(1/8D9)

QUESTION 10. Shared Emergency Equipment List the emergency equipment that is shared or proposed to be used by both the fire brigade and the security team. Provide the results of an analysis that demonstrctes the number of units available and unit (or system) design is adequate to support a combined fire-security emergency.

RESPONSE: There is no shared equipment between the Fire Brigade and any other group in the plant.

QUESTION 11. Operation, Maintenance, and Testing Procedures Provide a summary 'of the procedures established to control operation, maintenance and testing of fire protection (detect-ion and suppression) systems and components.

RESPONSE: Procedure No./ Title / Activity PM-115, Diesel Fire Pump Engine Inspection Describes the various tests and inspections to be per-formed on the diesel and motor-driven fire pumps.

SP-190, Channel Functional and Circuitry Operability of Fire Detection Instrumentation Demonstrates the operability of the fire detection in-strumentation by the performance of a channel func-tional test of the circuitry associated with the instrumentation.

SP-323, Evacuation and Fire Alarm Demonstration Demenstrates the operability of the audible evacuation and fire alarm systems.

SP-363, Fire Protection System Tests Verities the automatic start capability of the fire pumps, checks the fire service water system valve lineup, checks the CO2 system tank level, tank pres-sure, and valve lineup.

SP-364, Hose Station Inventory and Hydrant Operability Test Visually inspects hose reels and hose houses for equipment, checks the operability of the " post-indicator valves" and hydrant base valves, and checks position and integrity of seals.

SP-365, Fire Pump Operability Verifies the operability of each fire pump, inspec-tions of each valve in the flow path, and verification of the operability of fire pump diesel engines.

Simpson (Fire Prot)

(1/8D9)

QUESTION 11. (Continued)

SP'366,' Fire System Annual Valve Surveillance Demonstrates the operability of the fire suppression water system and deluge and sprinkler system.

SP-404, Fire Deluge and Sprinkler System Surveillance Demonstrates the operability of the deluge and sprink-ler systems by inspection of the spray headers and a water flow test.

SP-407, Fire Barrier Penetration Seals A visual inspection of the fire carrier penetration fire seals.

SP-408, Fire System Flow Test Demonstrates the operability of the fire suppression water system by performing a flow test of the system.

SP-411, Fire Protection, Deluge and Sprinkler System Test Demonstrates the availability of an adequate supply of water to cll deluge and sprinkler alarm valves, veri-fies a clear flow path through all sprinkler systems, demonstrates that all deluge valves unlatch and open when activated, verifies all local and Control Center trouble, sees that fire alarms activate properly, and to show all fans and pumps interlocked to fire systems respond properly.

SP-413, Verification of Alarm Function and CO2 Flow to Protec-ted Areas Verifies the operation of the CO 2 "SP urt" pushbutton stations, pilot valves, CO2 nozzles, and the ability of at least one temperature sensor in each area to initiate the appropriate alarm.

SP-501, Halon System Functional Test Demonstrates the ejerability of the Halon system in Cable Spreading Ream.

SP-502, Fire Pump Diesel Batteries Weekly Check Demonstrates the operability of the fire pump diesel batteries by checking the overall battery voltage and cell electrolyte levels.

SP-503, Fire Pump Diesel Batteries Quarterly Check Demonstrates the operability of the fire pump diesel batteries by verifying that each connected cell's specific gravity meets its accepted criteria.

Simson (FireProt)

(1/8D9)

QUESTION 11. (Continued)

SP-504, Fire Pump Diesel Batteries 18 Month Battery Check Demonstrates the operability of the fire pump diesel batteries by verifying the battery racks, cell, and plates show no signs of deterioration and connections are clean, tight, and coated with anti-corrosion material.

SP-606, Diesel Fire Pump Engine Inspection and Maintenance Checks the diesel fire pump engine to insure it is in accordance with the manufacturer's recommendations.

SP-800, Monthly Portable Fire Extinguisher Inspection Inspects each portable fire extinguisher to determine if it is fully charged and opere' le.

SP-801, Poctable Fire Extinguisher Yearly Maintenance Inspection Inspects all portable fire extinguishers to give maximum assurance that they will operate effectively and safely. Where necessary, it includes repair, recharging, or replacement.

SP-802, Annual Fire Hose Hydro Test and Hose Reel Inspection Verifies that ali plant hoses will hold their hydro pressures for the required period of time and that they are free from physical danage, bubbles, leaks and no coupling creeps.

QUESTION 12. Removal from Service Procedure Provide a summary of the procedures established to control the disarming of any automatic or wo ually ;rcuated fire protection system. Identify the canagement position responsible for authorizing the disarsament and the means used to assure the system is returned to actmal.

RESPONSE: Disarmament of fire protection systems is governed by CP-115, "In Plant Equipment Clearance and Switching Orders."

Clearance for fire protection system disarmament is issued by the Shift Supervisor. Special documentation and chain of procedures are required for disarmament and restoration of fire systems as outlined in CP-115.

QUESTION 32. Pin-Type Hose Rack Verify that the pin-type rack, if used, is approved to store the rubber lined hose by the hose manufacturer.

Simpson (FireProt)

(1/8D9)

QUESTION 32. (Continued)

RESPONSE: Only linen hose (Office Building) is stored in pin-type racks (manufacturer-approved).

CONCERN 46. Resolve difference in separation of cable trays as noted on Page 5-44 as contrasted to those noted on pages 5-12, 5-13, and 14 (5-44).

RESPONSE: As discussed on page 5-12, parallel trays of a single safeguards or protective channel may be run together to form a cable tray system. Page 5-13, item 4 describes the minimum spacing between trays of a cable tray system. Page 5-13, item 3 describes the separation requirements between cable trays or cable tray systems of redundant channels, which is consistent with the information given on page 5-44.

CONCERN 58. Are the hose threads on yard hydrants and interior fire hose stations compatible with the local public iire departments (Page 5-25)?

RESPONSE: The hose threads on yard b"drants and interior fire hose stations at CR #3 are compatible with the local public fire departments.

Simpson (FireProt)

(1/8D9)

ENCLOSURE NO. 2 (cout'd)

FIRE PROTECTION STAFF REVIEW REQUEST FOR ADDITIONAL INFORMATION QUESTIONS 1 February 13 4 February 13 6 February 13 NRC STAFF POSITIONS POSITION RESPONSE SCHEDULE PF1 Enclosed DRAWINGS DRAWINGS 1 March 29 2 February 13 Simpson (FireProt)

(1/8D9)

NRC STAFF POSITION - PF1 There are several areas in the fire safety evaluation which

.ontain safety-related equipment or cable trays for which no fire detection is provided or proposed. Fire detection should be provided for such areas having significant combustibles, which appears to include:

A. Heating and ventilation MCC area (IB, 119, A/Z24)

B. Neutralizer Room (AB, 95, A/Z6)

C. Reactor coolant evaporator room (AB,95, A/Z14)

D. Waste transfer pump room (AB, 95, A/Z19 and 20)

E. Decant and slurry pump rooms (AB, 95, A/Z21, 22 and 23)

F. Waste gas rooms (AB, 95, A/Z24 and 25)

G. Waste and recycle pump rooms (AB, 95, A/Z26, 27 and 28)

H. Nuclear sampling room (AB, 95, A/Z34 and 35)

I. Seal return coolers and makeup tank rooms (AB, 119, A/Z11, 12 and 13)

J. Decontamination room (AB, 119, A/Z19)

K. Control rod drive cooling water filter room (AB,119, A/Z23)

RESPONSE: None of these areas contain rotating equipment (such as pumps) that are required for safe shutdown; none contains significant quantities of oil or liquid combustibles. Only two areas contain any significant amounts of solid combustibles (other than cable insulation) and the amounts contained therein are small. No release of radioactive materials would result from a fire in any of these areas.

An electrically-initiated cable fire is, therefore, the only credible fire in these areas which might be of concern. Most of these areas contain only one train of cables; where there are two trains, separation is maintained so the second train cannot be involved (Note that each train contains three trains or less). With or without detections, a detectable fire in these trays would affect operation of components on one train, but not the other. Therefore, it is concluded that fire detectors in these areas would not be of significant benefit.

Simpson (FireProt)

(1/8D9)

ENCLOSURE NO. 3 RESULTS OF STAFF CONCERNS SITE VISIT MEETINGS FIRE PROTECTION STAFF REVIEW POSITIONS (SRP)

WHICH THE LICENSEE AGREED TO IMPLEMENT CRYSTAL RIVER 3 NUCLEAR STATION Docket No. 50-302 STAFF REVIEW POSITIONS AND CONC, ERNS RESPONSE SCHEDULE 2 Enclosed 3 Enclosed 6

• 7 Enclosed 8 Enclosed 10 Enclosed 11 Enclosed 12 Enclosed 13 Enclosed 14 Enclosed 15 Enclosed 16 Enclosed 18 Enclosed 19

• 22 Enclosed 23 Enclosed 25 January 29 28 Enclosed 32 April 27 33 Enclosed 34 Enclosed 35 Enclosed

• Staff Position 6 & 19 concerning installation of a remote shutdown panel are presently being evaluated by FPC Engineering and our consultants. Cace the total work scope has been defined, a schedule for submitting the design change to the NRC for review and a schedirle for installation will be furnished.

Simpson (FireProt)

(1/8D9)

ENCLOSURE 3 SRP-2 Post Indicator Valves Traffic Guards Staff Concern Traffic guards should be provided for post indicator valves to eliminate possible vehicular damage to the post irdicator valves.

Staff Position Provide traffic guards for post indicator valves.

RESPONSE: Work Request #5959 issued 12/12/78. The estimated time of completion is 4/79.

S RP-3 Fire Pump House Protective Curbing Staff Concern Curbing should be provided in the fire pump house floor drains system to separate the floor drains from the diesel fire pumps in case of diesel fuel oil tank or line break.

Staff Position Provide curbing across fire pump house for postulated break in diesel fuel oil line.

RESPONSE: Work Request #5961 issued 12/12/78. The estimated time of completion is 4/79.

SRP-7 Fire Emergency Radio Communication Staff Concern Two-way voice communication is vital to rafe shutdown and emergency response in the event of fire.

Staff Position Two portable radios should be readily available for fire emergency situations.

RESPONSE: To be resolved as part of the overall Security Plan now under review. The radio communication is currently being reviewed by Engineering.

Simpson (FireProt)

(1/8D9)

SRP-8 Control Room Chart Storage Staff Concern Paper chart storage in the SE corner of the control room is in a safety-related area and presents an unprotected fire hazard.

Staff Position Chart storage area in the SE corner of control room should be moved to an appropriate non-safety related area and/or properly sprinkled storage area.

RESPONSE: Purchase Req. #740-4587 dated 12/11/78 was issued and completion date is estimated as 4/79.

SRP-10 Computer Printout Storage Staff Concern Computer printout data paper is stored in the control room in a safety-related area and presents an unprotected fire hazard.

Staff Position Utilize enclosed metal cabinets for storage of compur--

printout data.

RESPONSE: Cabinets ordered by Purchase Req. #740-4609 dated 12/19/78.

The delivery estimated as 3/79.

SRP-11 Computer Tape Storage Staff Concern Computer tape storage in the control room is in a safety-related area and presents an unprotected fire hazard.

Staff Position Relocate computer tape storage from behind control panel to an appropriate non-safety related area.

RESPONSE: Work Request #5960 issued 12/19/78. The estimated completion date is 4/79.

SRP-12 Non-Smoking Requirements Staff Concern Smoking in safety-related areas should be eliminated to preclude the possibilities of a fire in safety-related areas.

Simpeon (FireProt)

(1/8D9)

SRP-12 (Continued)

Staff Pos'ition Enforce non-smoking requirements in s.ifety-related areas. Of particular concern was the evidence of smoking found inside main control panels, etc.

RES PONSE: No smoking enforcement letter initiated 12/4/78, file code 3-0-3-a by Operations Supt. Signs were posted on each door (2).

SRP-13 Trash Containers Staff Concern Approved metal trash containers with self-closing metal lids should be utilized throughout the plant in carety-relatud areas.

Staff Position Replace plastic trash containers with approved metal trash containers.

RESPONSE: Replaced plastic trash cans with metal in MU pump rooms.

Additional cans on order. Balance of approved metal trash containers to be supplied and in use by 2/79.

SRP-14 Fire Door Mechanisms Staff Concern Fire doors should be operable with sutomatic closures and; functional door latching mechanisms.

Staff Position

• Insure that all fire door mechanisms are operable.

RESPONSE: The normal Surveillance Procedure SP-805 of 12/1/78 pointed up some problems and a REI will be written requesting Engineering review and recommendations.

SRP-15 Control Room Door Staff Concern The door between the control room and hallway should be equipped with a closure device which will close the door on actuation of the fire detection system and/or control room ventilation recirculation.

Simpson (FireProt)

(1/8D9)

SRP-15 (Continued)

Staff Position If it is necessary to leave the door i en between control room and hallway, provide a device to hold uoor open which will close the door automatically on actuation of fire detection and/or ventilation recirculation. Utilization of a security guard for this purpose is satisfactory until an automatic closing, security / fire door has been installed.

RESPONSE: General Orders issued to al? guards as per 1.etter dated 12/6/78, File 3-0-12, initiated by Officer of the Guard.

SRP-16 Control Room Fire Extinguishers Staff Concern The present fire suppression in the control room may not be adequate for combating small deep-seated fires.

Staff Position Provide 2 water and/or Halon 1211 extinguishers at doorways at main control cabinets.

RESPONSE: Two (2) water-type extinguishers are on order (Purchese Req. #740-4614, dated 12/19/78. These will be hung at the doorways (2) of main control cabinets. Signs are to be posted directing the use of these extinguishers.

SRP-18 Control of Combustibles Staff Concern Unnecessary combustibles were observed in several areas of the plant. The conditions observed constituted an unnecessary and unevaluated fire loading which could impact on safety-related

< systems.

Staff Position All waste, debris, scrap, rags, oil spills, or other unnecessary combustibles resulting from work activity in safety-related areas should be removed following completion of the activity or at the end of the work shift (whichever is sooner). Administrative procedures should be established to control combustibles in safety-related areas. The unnecessary combustibles in the following areas should be removed:

- Diesel Generator Room

- Control Complex Ventilation Room

- 4160 B Switch Gear Room

- Main Exhaust Filter Room

- Spent Fuel Cooler Room Simpson (FireProt)

(1/8D9)

SRP-18 (Continued)

RESPONSE: Building Bervices clean-up is complete. A revision of AI-600 is in process of being written concerning the enforcement of clean-up after and during work.

SRP-22 Cable Spreading Room Fire Barrier Insulation Staff Concern The metal plates which serve as fire barrier penetration in the ceiling of the cable spreading room may not be sufficient to prevent the spread of a postulated fire between safety-related areas.

Staff Position Provide fire barrier insulation on underside of metal plates located in cable spreading room ceiling.

RESPONSE: Work Request #5957 was issued 12/12/78. The estimated time of cenpletion is 4/79.

SRP-23 Diesel Generator Rooms Protective Curbing Staff Concern A diesel fuel oil spill fire could spread from the diesel gea-erator rooms into the diesel generator control rooms and the diesel generator air handling rooms which could cause fire damage and/or render them inaccessible.

Staff Position Provide curbing at the two doors leading from diesel generator rooms to diecel generator control rooms and between the diesel generators air handling rocas.

RESPONSE: Work Request #5958 sas' issued 12/12/78. The estimated time of completion is 4/79.

SRP-28 Low-Level Waste Storage Staff Concern Fire Hose reels should be maintained to have free access at all times in cases of fire emergency.

Staff Position Relocate low-level waste storage at the drumming station to permit free access to hose reel.

RESPONSE: Work Request #04420 was issued 12/19/78. The estimated time for relocating the vaste drumming station is 2/79.

Signs posted to keep area clear 12/28/78.

Simpson (Fire Prot)

(1/8D9)

SRP-33 Fire Retardant Wood Staff Concern Unr.ecessary combustible fire loading was found to be stored and/or scattered inside and outside the plant which may impact on safety-related equipment or components in the area.

Staff Position All untreated lumber and wood items in safety-related areas should be 'oved. All lumber / wood required to be used in such areas should be treated fire retardant lumber and should be limited to temporary use, to be removed when no longer needed. Large wooden timbers may be coated with a U.L. listed fire retardant compound having a flame spread rating of 25 or less.

RESPONSE: Cost survey in progress (cost of treated wood at retail vs.

Building Services treating wood). However, treated fire retardant lumber should be available by 4/79.

SRP-34 Piping and Conduit Pentrations Staff Concern Fire stops should be provided for piping and cable penatrations to negate the possibility of fire propagation between areas.

Staff Position Piping and conduit penetrations between turbine building and safety-related areas should be upgraded to three hours, for example, the penetrations found on elevation 117 feet.

RESPONSE: This is under evaluation by maintenance. An REI will be written to Engineering if procedures do not fully address the situation.

FRP-35 Gas Cylinder Storage Staff Concern Potential missile damage to safety-related equipment or components from improperly stored cylinders.

Staff Position Gas cylinders should be stored in racks designated for that purpose. Storage should be in the approved manner.

RESPONSE: Modification Approval Request #770639 is in effect and completion is estimated as 4/79.

Simpson (FireProt)

(1/8D9)

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