ML20004B265: Difference between revisions

From kanterella
Jump to navigation Jump to search
(StriderTol Bot change)
(StriderTol Bot change)
 
Line 17: Line 17:
=Text=
=Text=
{{#Wiki_filter:_
{{#Wiki_filter:_
LONG ISLAND LIGHT!NG COM PANY 7 FACO Jaaramass                     SHOREHAM NUCLEAR POWER STATION P.O. BOX 618, NORTH COUNTRY RfJAD e WADING RIVER, N.Y.11792 May 21, 1981                                                       g7         SNRC-572 C
LONG ISLAND LIGHT!NG COM PANY 7 FACO Jaaramass SHOREHAM NUCLEAR POWER STATION P.O. BOX 618, NORTH COUNTRY RfJAD e WADING RIVER, N.Y.11792 SNRC-572 May 21, 1981 g7 C
C'       41 ?             %
C' 41 ?
Mr. Harold R. Denton, Director                                   LU  l            I office of Nuclear Reactor Regulation              f'_] . ,,N ~o=g- 1981 ~!
LU l
* 1*_9 U.S. Nuclear Regulatory Commission                 ' C -'     ii 5
I Mr. Harold R. Denton, Director f'_].,,N o g 1981 * *_9 office of Nuclear Reactor Regulation 1
Washington, DC      20555                            .1 u.s. T'',l38, , A s
ii
                                                                %                  - 8 ','
~ = -
~!
U.S.
Nuclear Regulatory Commission
' C -'
.1 u.s. T'',l38,, A 5
Washington, DC 20555 s
s
s
                                                                    /
/
Shoreham Nuclear Power                     Tion - Unit 1 Docket No. 50-322
- 8 ','
Shoreham Nuclear Power Tion - Unit 1 Docket No. 50-322


==Dear Mr. Denton:==
==Dear Mr. Denton:==
Enclosed are six (6) copies of LILCO's position addressing Safety Evaluation Report (SER) Outstanding Issue 45, Fire Protection.
Enclosed are six (6) copies of LILCO's position addressing Safety Evaluation Report (SER) Outstanding Issue 45, Fire Protection.
Based on our review of the issue, we have concluded that the Shoreham design compares very favorably with Appendix R and the fire protection guidelines applicable to Shoreham.
Based on our review of the issue, we have concluded that the Shoreham design compares very favorably with Appendix R and the fire protection guidelines applicable to Shoreham.
If you have any questions, please contact us.
If you have any questions, please contact us.
fery    rul yours, g 7,MW
rul
          . P. N varro Project / Manager RAH /pd Enclosures l
: yours, fery g 7,MW P.
cc:   J. Higgins l
N varro Project / Manager RAH /pd Enclosures l
nV l
cc:
l Y '' \
J.
1 l   8195270462
Higgins l
l V
l n
Y ''
\\
1 l
8195270462


APPENDIX R - FIRE PROTECTION PROGRAM FOR NUCLEAR POWER FACILITIES SHOREHAM EVALUATION II. General Requirements II.A   Fire Protection Program The Shoreham Protection Program as required by Appendix R has been established under station procedure SP39.001.0. This procedure defines the levels of responsibility for the formu-lation, implementation, and assessment of the Fire Protection Program. In addition, it provides an overview of the adminis-trative procedures which constitute the basis of the program.
APPENDIX R - FIRE PROTECTION PROGRAM FOR NUCLEAR POWER FACILITIES SHOREHAM EVALUATION II.
General Requirements II.A Fire Protection Program The Shoreham Protection Program as required by Appendix R has been established under station procedure SP39.001.0.
This procedure defines the levels of responsibility for the formu-lation, implementation, and assessment of the Fire Protection Program.
In addition, it provides an overview of the adminis-trative procedures which constitute the basis of the program.
The Plant Manager has the direct responsibility for formulating, implementing, administrating, and periodically assessing the effectiveness of the Fire Protection Program including fire drills and fire training of the fire brigade and plant personnel.
The Plant Manager has the direct responsibility for formulating, implementing, administrating, and periodically assessing the effectiveness of the Fire Protection Program including fire drills and fire training of the fire brigade and plant personnel.
He is also directly responsible for the effective coordination of the fire protection program with the station emergency plan to assure that a single point of control and contact will exist for all fire contingencies.
He is also directly responsible for the effective coordination of the fire protection program with the station emergency plan to assure that a single point of control and contact will exist for all fire contingencies.
The Shoreham Fire Protection Program is designed to ensure the capability to shutdown the reactor, maintain it in a safe shutdown condition, and minimize radioactive releases to the environment in the event of a fire.
The Shoreham Fire Protection Program is designed to ensure the capability to shutdown the reactor, maintain it in a safe shutdown condition, and minimize radioactive releases to the environment in the event of a fire.
The overall fire protection, detection, and suppression systems for the plant were reviewed based upon an evaluation of potential fire hazards and their effect on structures, systems, and components important to safety.
The overall fire protection, detection, and suppression systems for the plant were reviewed based upon an evaluation of potential fire hazards and their effect on structures, systems, and components important to safety.
Total reliance for suppressing a fire is not placed on a single fire suppression system. Appropriate backup suppression capability is also provided.
Total reliance for suppressing a fire is not placed on a single fire suppression system.
Appropriate backup suppression capability is also provided.
Evaluations of fire loadings affecting all safety-related areas have been performed to ensure that walls, floors, ceiling /
Evaluations of fire loadings affecting all safety-related areas have been performed to ensure that walls, floors, ceiling /
floor assemblies, and doors are adequate to 1) prevent external fires from spreading into these areas and 2) prevent any internal fire from spreading to adjacent safety-related areas.
floor assemblies, and doors are adequate to 1) prevent external fires from spreading into these areas and 2) prevent any internal fire from spreading to adjacent safety-related areas.
This evaluation was also performed for all areas containing a significant inventory of radioactive materials.
This evaluation was also performed for all areas containing a significant inventory of radioactive materials.
                            .      .-..-.. -. . .. ~   . ---.
.. ~
9         -        -  m     9
9 m
9


II.B Fire Hazards Analysis The Fire Hazard Analysis Report (FHA 2) documents a comprehensive evaluation of potential fire hazards through-out the plant. Therein, the ability to safely shut down the plant considering fire hazards was analyzed. As concluded by this analysis, Shoreham Nuclear Power Station is adequately protected against postulated fires which could challenge the ability to perform a safe shutdown of the plant.
II.B Fire Hazards Analysis The Fire Hazard Analysis Report (FHA 2) documents a comprehensive evaluation of potential fire hazards through-out the plant.
In addition to assessing the impact on safe shutdown capability, fire hazards throughout the plant were reviewed with regard to the potential for a fire to cause an unaccept-able radioactive release. The review determined that there is no single postulated fire within the plant which could cause an unacceptable release of radioactivity. No release identified would e.<ceed a small fraction of the guidelines set forth in 10CFR100.
Therein, the ability to safely shut down the plant considering fire hazards was analyzed.
As concluded by this analysis, Shoreham Nuclear Power Station is adequately protected against postulated fires which could challenge the ability to perform a safe shutdown of the plant.
In addition to assessing the impact on safe shutdown capability, fire hazards throughout the plant were reviewed with regard to the potential for a fire to cause an unaccept-able radioactive release.
The review determined that there is no single postulated fire within the plant which could cause an unacceptable release of radioactivity.
No release identified would e.<ceed a small fraction of the guidelines set forth in 10CFR100.
It should also be noted that through the use of fire retard-ant materials, strict limits on combustibles, and a comprehensive fire plan, the overall plant design presents a very low fire l
It should also be noted that through the use of fire retard-ant materials, strict limits on combustibles, and a comprehensive fire plan, the overall plant design presents a very low fire l
hazard.
hazard.
In addition to the analysis reported in the FHAR, a study was conducted with respect to the Reactor Building which conservatively considered the effects of fire. The study demonstrated that sufficient separation exists between redundant systems and components such that,even if all cables and raceways in very large segments of the reactor building are destroyed due to fire, the capability remains to safely shut down the plant. The methodology and results of this study are reported in the Cable Separation Analysis Report l             submitted by letter SNRC-532 dated February 10, 1981.
In addition to the analysis reported in the FHAR, a study was conducted with respect to the Reactor Building which conservatively considered the effects of fire.
II.C   Fire Prevention Features Fire protection features are provided for all fire areas that contain or present a fire hazard to structures, systems, or components important to safety in accordance with the general requirements of this paragraph. The Shoreham design features for fire protection are described in FSAR Section 9.5.
The study demonstrated that sufficient separation exists between redundant systems and components such that,even if all cables and raceways in very large segments of the reactor building are destroyed due to fire, the capability remains to safely shut down the plant.
The requirements with respect to transient fire hazards will be covered by SNPS Station Procedure SP12.013.02     " Fire Prevention Watches,. Patrols and Permits" which will provide instructions on inspections, the use of fire prevention permits, the composition, function and deployment of fire equipment watches and patrols.
The methodology and results of this study are reported in the Cable Separation Analysis Report l
submitted by letter SNRC-532 dated February 10, 1981.
II.C Fire Prevention Features Fire protection features are provided for all fire areas that contain or present a fire hazard to structures, systems, or components important to safety in accordance with the general requirements of this paragraph.
The Shoreham design features for fire protection are described in FSAR Section 9.5.
The requirements with respect to transient fire hazards will be covered by SNPS Station Procedure SP12.013.02
" Fire Prevention Watches,. Patrols and Permits" which will provide instructions on inspections, the use of fire prevention permits, the composition, function and deployment of fire equipment watches and patrols. --


Station Procedure SP39.001.02     " Fire Brigade Organization, Response and Drills" defines the composition and function of the station fire brigade, and its reponse in a fire emergency. It also addresses the fire drills which shall assess the brigade's performance as a team, the status of associated emergency equipment, and the station performance, including outstde assistance. This. procedure is consistant vith the detailed requirements of Appendix R.
Station Procedure SP39.001.02
" Fire Brigade Organization, Response and Drills" defines the composition and function of the station fire brigade, and its reponse in a fire emergency.
It also addresses the fire drills which shall assess the brigade's performance as a team, the status of associated emergency equipment, and the station performance, including outstde assistance.
This. procedure is consistant vith the detailed requirements of Appendix R.
SNPS Fire Suppression Systems are designed in conformance with National Fire Protection Association (NFPA) standards and meet the requirements of the American Nuclear Insurers (ANI).
SNPS Fire Suppression Systems are designed in conformance with National Fire Protection Association (NFPA) standards and meet the requirements of the American Nuclear Insurers (ANI).
Personnel who maintain and test fire detection and suppression systems shall be properly qualified by training or experience, or both as appropriate.
Personnel who maintain and test fire detection and suppression systems shall be properly qualified by training or experience, or both as appropriate.
Procedures are being established to ensure that fire barriers and fire suppression systems and components are operable in accordance with Appendix R.
Procedures are being established to ensure that fire barriers and fire suppression systems and components are operable in accordance with Appendix R.
II.D Alternative or Dedicated Shutdown Capability The Shoreham position with respect to alternative or dedicated shutdown capability is discussed in paragraph III.L.
II.D Alternative or Dedicated Shutdown Capability The Shoreham position with respect to alternative or dedicated shutdown capability is discussed in paragraph III.L.
III. Specific Requirements III.A Water Supplies for Fire Suppression Systems The Shoreham design is in full compliance with the requirements of this paragraph. The water supply system is discussed in FSAR Section 9.5.1.2.
III.
III.B Section Isolation Valves
Specific Requirements III.A Water Supplies for Fire Suppression Systems The Shoreham design is in full compliance with the requirements of this paragraph.
!        The Shoreham design is'in full compliance with the requirements of this paragraph. Refer to FSAR Section 9.5.1.2.
The water supply system is discussed in FSAR Section 9.5.1.2.
I III.C Hydrant Isolation Valves The Shereham design is in full compliance with the requirements of this paragraph. Refer to FSAR Section 9.3.1.2.
III.B Section Isolation Valves The Shoreham design is'in full compliance with the requirements of this paragraph.
III.D Manual Fire Suppression l         The Shoreham design is in full compliance with the requirements l         of this paragraph. Refer to FSAR Section 9.5.1.2.
Refer to FSAR Section 9.5.1.2.
i A maintainability study is being performed at Shoreham to insure walkway access is provided for all floors and elevation; l         of the station where systems or componencs are important to l         safety.
I III.C Hydrant Isolation Valves The Shereham design is in full compliance with the requirements of this paragraph.
Refer to FSAR Section 9.3.1.2.
III.D Manual Fire Suppression l
The Shoreham design is in full compliance with the requirements l
of this paragraph.
Refer to FSAR Section 9.5.1.2.
i A maintainability study is being performed at Shoreham to insure walkway access is provided for all floors and elevation; l
of the station where systems or componencs are important to l
safety.
l l
l l


III.E Hydrostatic Hose Tests The Shoreham hydrostatic hose tests will comply with the requirements of this paragraph.
III.E Hydrostatic Hose Tests The Shoreham hydrostatic hose tests will comply with the requirements of this paragraph.
III.F Automatic Fire Detection The Shoreham decign is in full compliance with the requirements of this paragraph. Refer to FSAR Section 9.5.1.2.
III.F Automatic Fire Detection The Shoreham decign is in full compliance with the requirements of this paragraph.
III.G Fire Protection of Safe Shutdown. Capability Fire protection of safe shutdown capability is p2cvided by maintaining free of fire damage, one train of systems necessary to achieve and maintain shutdown conditions. This is accomplished from either the Main Control Room or the Remote Shutdown Panel. There is no single fire that can affect both the Main Control Room and the Remote Shutdown Panel. See paragraph III.L for a discussion of the independence of the Remote Shutdown Panel.
Refer to FSAR Section 9.5.1.2.
In addition, there are numerous plant features which assure fire protection of safe shutdown capability.         In that regard, some of the more important areas of the plant are discussed below.
III.G Fire Protection of Safe Shutdown. Capability Fire protection of safe shutdown capability is p2cvided by maintaining free of fire damage, one train of systems necessary to achieve and maintain shutdown conditions.
The electrical separation criteria for the Relay Room and cable spreading area are also described in Section 2 of the FRAR. It is recognized that a sustained fire must be l         precluded in this area. Therefore, this room is equipped with highly sensitive smoke and temperature detectors and a total flooding CO2 system as described in the FRAR. In addition to the use of low combustible materials, strict controls are maintained on the introduction and use of transient combustibles. In the unlikely event of a fire in the Relay Room, it will be quickly detected and automatically extinguished by the CO2 system, thus limiting the spread of fire from reaching significant levels. Therefore, any damage sustained would be quite local due to the quick response of the fire suppression system and the fire retardent nature of the
This is accomplished from either the Main Control Room or the Remote Shutdown Panel.
          .aaterials.     Under these conditions, sufficient capability will be available in the Main Control Room to safely shut the plant down should it be desirable or necessary to do so.
There is no single fire that can affect both the Main Control Room and the Remote Shutdown Panel.
Furthermore, control of sufficient shutdown systems is provided on the Remote Shutdown Panel located in the Raactor Building. The Remote Shutdown Panel is protected by a 3 hr j
See paragraph III.L for a discussion of the independence of the Remote Shutdown Panel.
rated concrete wall and stael door which completely enclose l         the panel.     Within the enclosure, the panel is further j         protected by smoke detectors and an automatic halon fire l         suppression system. The controls and instrumentation located
In addition, there are numerous plant features which assure fire protection of safe shutdown capability.
!          in this panel are provided with transfer capability such thar they are isolated from the Relay Room and Main Control Room equipment when they are in service. Transfer / control i
In that regard, some of the more important areas of the plant are discussed below.
capability is also provided in the Diesel Generator and
The electrical separation criteria for the Relay Room and cable spreading area are also described in Section 2 of the FRAR.
It is recognized that a sustained fire must be l
precluded in this area.
Therefore, this room is equipped with highly sensitive smoke and temperature detectors and a total flooding CO2 system as described in the FRAR.
In addition to the use of low combustible materials, strict controls are maintained on the introduction and use of transient combustibles.
In the unlikely event of a fire in the Relay Room, it will be quickly detected and automatically extinguished by the CO2 system, thus limiting the spread of fire from reaching significant levels.
Therefore, any damage sustained would be quite local due to the quick response of the fire suppression system and the fire retardent nature of the
.aaterials.
Under these conditions, sufficient capability will be available in the Main Control Room to safely shut the plant down should it be desirable or necessary to do so.
Furthermore, control of sufficient shutdown systems is provided on the Remote Shutdown Panel located in the Raactor Building.
The Remote Shutdown Panel is protected by a 3 hr rated concrete wall and stael door which completely enclose j
l the panel.
Within the enclosure, the panel is further j
protected by smoke detectors and an automatic halon fire l
suppression system.
The controls and instrumentation located in this panel are provided with transfer capability such thar they are isolated from the Relay Room and Main Control Room i
equipment when they are in service.
Transfer / control capability is also provided in the Diesel Generator and _


Emergency Switchgear Rooms to snable the emergency diesel
Emergency Switchgear Rooms to snable the emergency diesel generators to be started, connected to the emergency buses, and connected to emergency loads, independent of the control The plant is designed for orderly shutdown of the room.
<        generators to be started, connected to the emergency buses, and connected to emergency loads, independent of the control room. The plant is designed for orderly shutdown of the reactor from outside the Main Control rcom.
reactor from outside the Main Control rcom.
For the Control Room, ionization detectors are installed in the supply and return air ducts and all safety-related panels and consoles.     All safety-related (Class lE) panels in the Control and Relay Rooms will be equipped with ionization type smoke detectors.             Most non-Class lE panels in thse areas also have the ionization smoke detectors installed.
For the Control Room, ionization detectors are installed in the supply and return air ducts and all safety-related panels and consoles.
These detectors     alarm on the station security consoles in the Security Building and the Main Control Room.                     There is one detector located in each enclosed section of the panel. For large panels, multiple detectors are located to provide effective coverage.
All safety-related (Class lE) panels in the Control and Relay Rooms will be equipped with ionization type smoke detectors.
Most non-Class lE panels in thse areas also have the ionization smoke detectors installed.
These detectors alarm on the station security consoles in the Security Building and the Main Control Room.
There is one detector located in each enclosed section of the panel.
For large panels, multiple detectors are located to provide effective coverage.
Fire detectors will sound an alarm in the event of a fire.
Fire detectors will sound an alarm in the event of a fire.
Fire protection for the Control Room consists primarily of portable hand extinguishers located both inside and outside the area with CO2 hose reels as backup. One CO2 hose reel is located in the north stairwell and one CO2 hose reel in the HVAC Equipment Room. Both areas are immediately adjacent to the Main Control Room. Minimal quantitites of combustible materials within panels prevent the occurrence of a fire of sufficient severity to cause propagation to adjacent panels or adjacent sections of the same panel.                 Wires are flame retardant and self-extinguishing.
Fire protection for the Control Room consists primarily of portable hand extinguishers located both inside and outside the area with CO2 hose reels as backup.
One CO2 hose reel is located in the north stairwell and one CO2 hose reel in the HVAC Equipment Room.
Both areas are immediately adjacent to the Main Control Room.
Minimal quantitites of combustible materials within panels prevent the occurrence of a fire of sufficient severity to cause propagation to adjacent panels or adjacent sections of the same panel.
Wires are flame retardant and self-extinguishing.
In those areas of Class 1E panels where adjacent controls /
In those areas of Class 1E panels where adjacent controls /
instruments from two redundant safety divisions cannot be located in separate panels,             separation is maintained by distance, by steel barrier or by enclosing one of the devices in a steel enclosure and by running the associated wiring in conduit to terminal blocks in the appropriate divisional area of the panel. Consequently, safe shutdown capability is not lost.
instruments from two redundant safety divisions cannot be located in separate panels, separation is maintained by distance, by steel barrier or by enclosing one of the devices in a steel enclosure and by running the associated wiring in conduit to terminal blocks in the appropriate divisional area of the panel.
In areas of the plant, such as Emergency Switchgear Rooms, Battery Rooms, Diesel Generator Rooms, 3 hr rated walls exist between equipment and cable of each train. The Remote Shutdown panel Room including 3 hr fire barrier walls and door is protected by smoke detectors and automatic halon fire suppression system.
Consequently, safe shutdown capability is not lost.
For the Reactor Building a study was performed to consider the effects of fire. Conservatively sized plant segments were selected and all the safety related cables and components located in the segment were assumed lost due to fire.                     The segments are overlapping 45 degree areas in the secondary containment and overlapping 60 degree areas in the primary containment.     The study concluded that sufficient separation exists between redundant systems and components that even if all the cables and raceways and components in thesc segments
In areas of the plant, such as Emergency Switchgear Rooms, Battery Rooms, Diesel Generator Rooms, 3 hr rated walls exist between equipment and cable of each train.
The Remote Shutdown panel Room including 3 hr fire barrier walls and door is protected by smoke detectors and automatic halon fire suppression system.
For the Reactor Building a study was performed to consider the effects of fire.
Conservatively sized plant segments were selected and all the safety related cables and components located in the segment were assumed lost due to fire.
The segments are overlapping 45 degree areas in the secondary containment and overlapping 60 degree areas in the primary containment.
The study concluded that sufficient separation exists between redundant systems and components that even if all the cables and raceways and components in thesc segments..


were lost due to fire, the capability remains to safely shut down the plant. Furthermore, the primary containment will be inerted.
were lost due to fire, the capability remains to safely shut down the plant.
Furthermore, the primary containment will be inerted.
III.E Fire Brigade The Shoreham fire brigade will comply with the requirments of this paragraph.
III.E Fire Brigade The Shoreham fire brigade will comply with the requirments of this paragraph.
III.I Fire Brigade Training The Shoreham fire brigade training will comply with the require-ments of this paragraph.
III.I Fire Brigade Training The Shoreham fire brigade training will comply with the require-ments of this paragraph.
III.J Emergency Lighting Areas needed for operation of safe shutdown equipment and in access and egress routes thereto will be identified and 8 hr battery powered units installed to meet this requirement.
III.J Emergency Lighting Areas needed for operation of safe shutdown equipment and in access and egress routes thereto will be identified and 8 hr battery powered units installed to meet this requirement.
III.K Administrative Controls The Shoreham administrative controls will comply with the requirements of this paragraph.
III.K Administrative Controls The Shoreham administrative controls will comply with the requirements of this paragraph.
III.L Alternative or Dedicated Shutdown Capability Alternative or dedicated shutdown capability is* required only where the protection of systems whose function is required for hot shutdown does not satisfy the requirement of paragraph G, (Fire Protection of Safe Shutdown Capability) . It is our position as discussed in paragraph G above, that the Shoreham design provides adequate fire protection of safe shutdown capability. Therefore, special consideration for an alternative or dedicated shutdown capability is not required by Appendix R.
III.L Alternative or Dedicated Shutdown Capability Alternative or dedicated shutdown capability is* required only where the protection of systems whose function is required for hot shutdown does not satisfy the requirement of paragraph G, (Fire Protection of Safe Shutdown Capability).
It is our position as discussed in paragraph G above, that the Shoreham design provides adequate fire protection of safe shutdown capability.
Therefore, special consideration for an alternative or dedicated shutdown capability is not required by Appendix R.
Nevertheless, the Shoreham design provides for an independent shutdown capability at the Remote Shutdown Panel.
Nevertheless, the Shoreham design provides for an independent shutdown capability at the Remote Shutdown Panel.
l The Remote Shutdown Panel (RSP) provides remote control for the essential reactor systems needed to carry out the shutdown function from outside the Main Control Room to bring the reactor to cold shutdown in an orderly fashion.       It is in an alternate location from the normal control system used in the Main Control Rcoc     Shutdown of the Reactor can be l
l The Remote Shutdown Panel (RSP) provides remote control for the essential reactor systems needed to carry out the shutdown function from outside the Main Control Room to bring the reactor to cold shutdown in an orderly fashion.
6            accomplished from the RSv if feedwater is not available and the normal heat sinks, i.e., turbine and condenser, are l
It is in an alternate location from the normal control system used in the Main Control Rcoc Shutdown of the Reactor can be l
accomplished from the RSv if feedwater is not available 6
and the normal heat sinks, i.e., turbine and condenser, are l
lost.
lost.
Transfer switches are provided in the RSP for the purpose of
{-
{-            transferring control from the Main Control Room to the RSP for all the functions en the RSP. When the transfer is completed the RSP functions inlapendant of the Control Room and the Relay Rccm. Therefore, one train of equipment necessary to achie;e shutdown is maintained free of damage from an exposure fire in either the Relay Room or Control Room.
Transfer switches are provided in the RSP for the purpose of transferring control from the Main Control Room to the RSP for all the functions en the RSP.
l 1
When the transfer is completed the RSP functions inlapendant of the Control Room and the Relay Rccm.
Therefore, one train of equipment necessary to achie;e shutdown is maintained free of damage from an exposure fire in either the Relay Room or Control Room. l 1


l III.M   Fire Barrier Cable Penetration Seal Oualification
III.M Fire Barrier Cable Penetration Seal Oualification
                -The Shoreham design is in full compliance with the require-i              ments of this paragrapn.             Refer to FSAR Section 9.5.1.2.
-The Shoreham design is in full compliance with the require-ments of this paragrapn.
III.N   Fire Doors The shoreham design is in full compliance with the requirements of this paragraph. Refer to FSAR Section 9.5.1.2.
Refer to FSAR Section 9.5.1.2.
Inspection requirements will be covered through Station Procedures SP12.016.01             " Surveillance Program" and SP12.01S.01. " Preventive Maintenance Program".
i III.N Fire Doors The shoreham design is in full compliance with the requirements of this paragraph.
Access to keys will be provided to the Shoreham Fire Brigade Chief through Station Procedure SP91.005.01               " Lock and Key Control System".
Refer to FSAR Section 9.5.1.2.
An oil collection System for Reactor Coolant Pump I               An oil collection system for the recirculation pump is not required since the primary containment is inerted during normal operation. When the plant is not operating, normal fire protection is available in accordance with BTP 9.5-1.
Inspection requirements will be covered through Station Procedures SP12.016.01
" Surveillance Program" and SP12.01S.01.
" Preventive Maintenance Program".
Access to keys will be provided to the Shoreham Fire Brigade Chief through Station Procedure SP91.005.01
" Lock and Key Control System".
An oil collection System for Reactor Coolant Pump I
An oil collection system for the recirculation pump is not required since the primary containment is inerted during normal operation.
When the plant is not operating, normal fire protection is available in accordance with BTP 9.5-1.
i I
i I
l l
l l
l f
l
i
! f i


NRC FHAR FOLLOW-UP QUESTIONS TO   -
NRC FHAR FOLLOW-UP QUESTIONS TO OUR DECCC3:2 1973 RESPONSES Question No. 2 It is our position that an oil collection system be provided for the HPCI turbine pump and RCIC turbine pump.
OUR DECCC3:2 1973 RESPONSES Question No. 2 It is our position that an oil collection system be provided for the HPCI turbine pump and RCIC turbine pump. This would resolve our concerns for questions Nos. 2, 12, and 13.
This would resolve our concerns for questions Nos. 2, 12, and 13.


===Response===
===Response===
HPCI and RCIC turbine pumps located at el 4 ft-0 in. of the Reactor Building are provided with a forced pressure lubrication system. The HPCI and PCIC pumps are not normally operative; therefore, the lubricatio1 system is not under pressure. Any leakage is contained in the immediate vicinity of the respective pump due to the partial wall between the pumps and the curbs provided for this purpose. Each curbed area is drained by the floor drain system to respective underground sumps.
HPCI and RCIC turbine pumps located at el 4 ft-0 in. of the Reactor Building are provided with a forced pressure lubrication system.
Moreover, due to the complexity of the lubrication system piping of the HPIC and RCIC turbines, it is impracticable to design and install a seismically supported and effective oil collection system around the pipes. Also, as mentioned in the last paragraph of response to this question:   loss of both HPCI and RCIC does not impair the safe shutdown capability of the plant. Therefore, the system design as provided, including early warning detection, fire suppression, and the installed oil collection system is adequate.
The HPCI and PCIC pumps are not normally operative; therefore, the lubricatio1 system is not under pressure.
Any leakage is contained in the immediate vicinity of the respective pump due to the partial wall between the pumps and the curbs provided for this purpose.
Each curbed area is drained by the floor drain system to respective underground sumps.
Moreover, due to the complexity of the lubrication system piping of the HPIC and RCIC turbines, it is impracticable to design and install a seismically supported and effective oil collection system around the pipes.
Also, as mentioned in the last paragraph of response to this question:
loss of both HPCI and RCIC does not impair the safe shutdown capability of the plant.
Therefore, the system design as provided, including early warning detection, fire suppression, and the installed oil collection system is adequate.
We state below our revised posicion on a previous response t6 question No. 12, where provision for 3-hr fire barrier is found not to be compatible with the as-built conditions.
We state below our revised posicion on a previous response t6 question No. 12, where provision for 3-hr fire barrier is found not to be compatible with the as-built conditions.
A review of as-buiit conditions, with respect to incorporating a 3-hr rated fire barrier between vertical cable tray risers (at 1380 and 2230 azimuth) and adjacent pumps (HPCI and RCIC), has been completed. Various interferences such as seismic pipe supports, cable trays, cable tray supports, conduits, and electrical junction boxes, limit the ability to provide a 3-hr fire barrier from el 8 ft-0 in. to el 40 ft-0 in. A partial height barrier of 3-hr rated construction extending 9 ft high is being installed between the vertical cable trays and the adjacent RCIC pump. The barrier will not encompass the trays entirely. However, the fire loading at el 8 ft-0 in. of the Reactor Building as provided in Table 1 of the FHAR is less than one hour.
A review of as-buiit conditions, with respect to incorporating a 3-hr rated fire barrier between vertical cable tray risers (at 1380 and 2230 azimuth) and adjacent pumps (HPCI and RCIC), has been completed.
Each individual riser in the banks contain only Red, Orange or Blue division cables. The distance between the two cable tray risers is 85 ft. The HPCI turbine-pump set is located appro::imately   .
Various interferences such as seismic pipe supports, cable trays, cable tray supports, conduits, and electrical junction boxes, limit the ability to provide a 3-hr fire barrier from el 8 ft-0 in. to el 40 ft-0 in.
30 ft. away due northwest from the vertical cable tray risers (138 0),
A partial height barrier of 3-hr rated construction extending 9 ft high is being installed between the vertical cable trays and the adjacent RCIC pump.
The barrier will not encompass the trays entirely.
However, the fire loading at el 8 ft-0 in. of the Reactor Building as provided in Table 1 of the FHAR is less than one hour.
Each individual riser in the banks contain only Red, Orange or Blue division cables.
The distance between the two cable tray risers is 85 ft.
The HPCI turbine-pump set is located appro::imately 0),
30 ft. away due northwest from the vertical cable tray risers (138 thus providing physical separation and the RCIC turbine-pump set is located 25 ft southeast of the HPCI pump set.
The distance between the two cable tray risers is 85 ft.
The HPC: turbine-pt e sct is locat2d approximately 30 ft. away due northwes from :ne vertical cable tray risers (138
),
thus providing physical separation and the RCIC turbine-pump set is located 25 ft southeast of the HPCI pump set.
thus providing physical separation and the RCIC turbine-pump set is located 25 ft southeast of the HPCI pump set.
The distance between the two cable tray risers is 85 ft. The HPC: turbine-pt e sct is locat2d approximately 30 ft. away due northwes from :ne vertical cable tray risers (138 ), thus providing physical separation and the RCIC turbine-pump set is located 25 ft southeast of the HPCI pump set.


Fixed manual spray fire suppression system, together with an early warning fire detection system and lube oil l'c.kage detection system are provided for both HPCI and RCIC pump areas. In addition, portable and fire hose stations are provided as backup fire suppression systemt.
Fixed manual spray fire suppression system, together with an early warning fire detection system and lube oil l'c.kage detection system are provided for both HPCI and RCIC pump areas.
In addition, portable and fire hose stations are provided as backup fire suppression systemt.
The above features ensur'e that fire cannot spread to adjacent areas.
The above features ensur'e that fire cannot spread to adjacent areas.
Loss of any one of ' the vertical cable tray risers will not impair both divisions of safety systen.s. Also, we have demonstrated, by analysis, that loss of all electrical cables (including HPCI and RCIC) in the designated 450 zones of the Rea?cror Building does not impair the safe shutdown capabilities of the plant.
Loss of any one of ' the vertical cable tray risers will not impair both divisions of safety systen.s.
Also, we have demonstrated, by analysis, that loss of all electrical cables (including HPCI and RCIC) in the designated 450 zones of the Rea?cror Building does not impair the safe shutdown capabilities of the plant.
Question No. 3 The licensee should provide the penetration seal test reports or ANI approval sheets for all seals.
Question No. 3 The licensee should provide the penetration seal test reports or ANI approval sheets for all seals.
It is our position that all dampers, including motorized dampers, be UL listed.
It is our position that all dampers, including motorized dampers, be UL listed.


===Response===
===Response===
Penetration seal test reports and ANI (American Nuclear Insureres) acceptance sheets will be available for all seals utilized at Shoreham. These are required to be furnished by the fire stop and seals contractor as part of the Specification SH1-459.
Penetration seal test reports and ANI (American Nuclear Insureres) acceptance sheets will be available for all seals utilized at Shoreham.
Fire dampers without motors are UL listed with fusible links and are labeled.                                                     -
These are required to be furnished by the fire stop and seals contractor as part of the Specification SH1-459.
Fire dampers with motors ara certified UL construction with fusible links but are not labeled. At the time these motorized fire dampers were purchased, UL listing for the motorized dampers as a unit was i   not available, therefore, the unit was not labeled. The motor does not affect the closure during a fire. Melting of the UL listed fusible link allows the damper to close on high temperature.
Fire dampers without motors are UL listed with fusible links and are labeled.
Fire dampers with motors ara certified UL construction with fusible links but are not labeled.
At the time these motorized fire dampers were purchased, UL listing for the motorized dampers as a unit was i
not available, therefore, the unit was not labeled.
The motor does not affect the closure during a fire.
Melting of the UL listed fusible link allows the damper to close on high temperature.
Question No. 5 It is our position that fire stops be insta]1ed in the vertical runs of the Reactor Building.
Question No. 5 It is our position that fire stops be insta]1ed in the vertical runs of the Reactor Building.


===Response===
===Response===
All vertical cable tray runs in the Reactor Building are provided with approved fire stops where they penetrate any floor level.
All vertical cable tray runs in the Reactor Building are provided with approved fire stops where they penetrate any floor level.
Fire stops are also provided in cable trays at their midpoints when the distance between Reactor Building floor levels exceeds 25 ft. This is in accordance with Specification SH1-459.
Fire stops are also provided in cable trays at their midpoints when the distance between Reactor Building floor levels exceeds 25 ft.
I t
This is in accordance with Specification SH1-459.
I t _


W e
W e
vuestion No. 9 It is our position that the fire detection system be separated from the rest of the relay room by a 2-hr fire barrier so that a fire in the relay room will not cause the loss of e.9 tire fire det+.'ction system.
vuestion No. 9 It is our position that the fire detection system be separated from the rest of the relay room by a 2-hr fire barrier so that a fire in the relay room will not cause the loss of e.9 tire fire det+.'ction system.
It is our position that fire detection system wiring be Class "A" from the fire control panels within the relay room to the control room.
It is our position that fire detection system wiring be Class "A"
from the fire control panels within the relay room to the control room.
We would like to discuss the fire detection system during site visit to resolve concerns.
We would like to discuss the fire detection system during site visit to resolve concerns.


===Response===
===Response===
The arrangament of the fire detection system wiring conforms to NFPA 72D for Class "A" circuits from the local detectors to the switching panel located within the relay room. Class "A" circuits consist of 2 pairs of wires with switching capability to utilize either pair if a problem occurs. From the switching panel to the fire zone modules and the console, each located in the control room, the circuits are continuously electronically supervised so that a loss of any circuit is alarmed. Power supply equipment, such as the inverter, fire detection panels, and distribution panel are located in various parts cf the relay room. It is not practicable to incorporate a 2-hr fire barrier within the relay room to achieve separation. This would also impose additional requirements of ventilation, fire detection, and protection of the areas thus created.
The arrangament of the fire detection system wiring conforms to NFPA 72D for Class "A" circuits from the local detectors to the switching panel located within the relay room.
Class "A" circuits consist of 2 pairs of wires with switching capability to utilize either pair if a problem occurs.
From the switching panel to the fire zone modules and the console, each located in the control room, the circuits are continuously electronically supervised so that a loss of any circuit is alarmed.
Power supply equipment, such as the inverter, fire detection panels, and distribution panel are located in various parts cf the relay room.
It is not practicable to incorporate a 2-hr fire barrier within the relay room to achieve separation.
This would also impose additional requirements of ventilation, fire detection, and protection of the areas thus created.
All cabling must run through the relay room to reacn the control room.
All cabling must run through the relay room to reacn the control room.
The relay room is equipped with fire detection devices and fire suppression equipment for fire protection.     Automatic total flooding CO fire suppression system provided for the relay room is adequate.
The relay room is equipped with fire detection devices and fire suppression equipment for fire protection.
Automatic total flooding CO fire suppression system provided for the relay room is adequate.
2 1
2 1
Question No. 11           2 It is our position that a permanent second feed be provided for l
Question No. 11 2
the Reactor Building fire water systems.
It is our position that a permanent second feed be provided for the Reactor Building fire water systems.
Verify that in the event cf an SSE, water is still available for fire suppression use in the Reactor Building.
l Verify that in the event cf an SSE, water is still available for fire suppression use in the Reactor Building.
Response                                                         ,
 
!  A permanent second feed will be provided for the Reactor Building l
===Response===
A permanent second feed will be provided for the Reactor Building l
fire water system from the yard fire loop and will be connected into the Reactor Building seismically supported fire protection system.
fire water system from the yard fire loop and will be connected into the Reactor Building seismically supported fire protection system.
l l   The fire protection system was not designed to Seismic Category I l
l l
Cri:2ria and, tharafcre, may not be a>cilable for fire suppression l   cse in the Reactor Building in the event of a SSE.
The fire protection system was not designed to Seismic Category I l
P
Cri:2ria and, tharafcre, may not be a>cilable for fire suppression l
                                  - -    -  .-v -              .
cse in the Reactor Building in the event of a SSE.
P !
.-v


However, the portions of the system located in safety-related areas are supported such that failure during a seismic event cannot significantly impair the capability of any safety-related equipment.
However, the portions of the system located in safety-related areas are supported such that failure during a seismic event cannot significantly impair the capability of any safety-related equipment.
However, a seismic Category I safety-related service water line inside the Reactor Building has been provided.with a spare connection available tor manual hook-up to the fire suppression system. This alternate connection ensures that fire suppression system is available following a SSE.
However, a seismic Category I safety-related service water line inside the Reactor Building has been provided.with a spare connection available tor manual hook-up to the fire suppression system.
This alternate connection ensures that fire suppression system is available following a SSE.
Question No. 14 It is our position that a fixed automatic water sprinkler system be provided in the table spreading room (relay room).
Question No. 14 It is our position that a fixed automatic water sprinkler system be provided in the table spreading room (relay room).


===Response===
===Response===
The relay room is protected by a low pressure total flooding CO2 fire suppression system.     This system is actuated automatically by heat detectors or it can be actuated manually.             The area and panels are also monitored by early warning ionization smoke detectors which in combination with heat detectors, for the actuation circuit of the CO2 system, provide constant and sensitive surveillance for detection of any fire in its incipient stages.           The CO2 system is designed to provide two successive total flooding CO2 discharges.
The relay room is protected by a low pressure total flooding CO2 fire suppression system.
In addition, a manual water suppression system (standpipe hose stations) has been provided for the cable spreading room (relay room) in the event that a deep-seated fire in a fully loaded cable tray is not permanently suppressed by the CO2 system. The manual cap &bility is preferred because it provides ror selective application of water in the relay room and would limit the consequences of water damage.
This system is actuated automatically by heat detectors or it can be actuated manually.
The area and panels are also monitored by early warning ionization smoke detectors which in combination with heat detectors, for the actuation circuit of the CO2 system, provide constant and sensitive surveillance for detection of any fire in its incipient stages.
The CO2 system is designed to provide two successive total flooding CO2 discharges.
In addition, a manual water suppression system (standpipe hose stations) has been provided for the cable spreading room (relay room) in the event that a deep-seated fire in a fully loaded cable tray is not permanently suppressed by the CO2 system.
The manual cap &bility is preferred because it provides ror selective application of water in the relay room and would limit the consequences of water damage.
Prompt fire detection and actuation of the fixed CO2 system will l
Prompt fire detection and actuation of the fixed CO2 system will l
prevent a fire from becoming established.     Backup suppression capability is provided with standpipe water hose station, CO2 hose reels, and portable extinguishers.
prevent a fire from becoming established.
l l   Provisions to protect the relay room as described above are l   compatible with the components within the room and are adequate.
Backup suppression capability is provided with standpipe water hose station, CO2 hose reels, and portable extinguishers.
l l
Provisions to protect the relay room as described above are l
compatible with the components within the room and are adequate.
Question No. 16 It is our position that a hose station be provided in the screenwell pump house.
Question No. 16 It is our position that a hose station be provided in the screenwell pump house.
l


===Response===
===Response===
l Each of the redundant safety-related service water pump rooms in the screenwell pump house has a low fire loading of 30,000 Btu /ft                   ,
Each of the redundant safety-related service water pump rooms in the screenwell pump house has a low fire loading of 30,000 Btu /ft less than the equivalent fira severity of 1/2 hr.
less than the equivalent fira severity of 1/2 hr.
1 l l
1 l
w
l w         - - + '
- - + '
T t' "  "    " " ' '  T             e ''F ~-*-
T t'
                                                                                            'T '' - ' '7?E '
T e
''F
~-*-
'T
- ' '7?E


Previous response to question No. 16, indicated two yard fire hydrants are provided with hoses for double stream coverage in addition to portable fire entinguishers.
Previous response to question No. 16, indicated two yard fire hydrants are provided with hoses for double stream coverage in addition to portable fire entinguishers.
The 3-hr rated fire door between the pump rooms is monitored for closure and alarmed in the control room. In ad e,ition, each of the rooms is provided with two area detectors and tue duct detector for early warning.
The 3-hr rated fire door between the pump rooms is monitored for closure and alarmed in the control room.
Provisions as described above for protection of each of the redundant screenwell pump rooms are adequate.                     A hose station for each room is not required.
In ad e,ition, each of the rooms is provided with two area detectors and tue duct detector for early warning.
Provisions as described above for protection of each of the redundant screenwell pump rooms are adequate.
A hose station for each room is not required.
Question No. 19 Provide justification for use of 1 1/2 hr dampers.
Question No. 19 Provide justification for use of 1 1/2 hr dampers.


===Response===
===Response===
The 1 1/2 hr fire dampers provided are equal to or better than the fire loading of the ad J acent areas.                   The structural design requirements of the walls results in the fire rating of the barrier exceeding the require =ent of the fire dampers.
The 1 1/2 hr fire dampers provided are equal to or better than the fire loading of the ad acent areas.
The structural design J
requirements of the walls results in the fire rating of the barrier exceeding the require =ent of the fire dampers.
Question No. 26 Appendix R hr battery packs.
Question No. 26 Appendix R hr battery packs.


===Response===
===Response===
Areas needed for operation of safe shutdown equipment and for access and egress routes thereto will be identified and 8-hr battery powered units installed.
Areas needed for operation of safe shutdown equipment and for access and egress routes thereto will be identified and 8-hr battery powered units installed. - - -, - _
                                                                - - - , - _ - -- __ --    _ . _ . . _ . , _              ,,. . _  . _.}}
_.}}

Latest revision as of 11:43, 23 December 2024

Forwards Util Position on SER Outstanding Issue 45 Re Fire Protection.Facility Design Compares Favorably W/App R & Applicable Fire Protection Guidelines
ML20004B265
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 05/21/1981
From: Novarro J
LONG ISLAND LIGHTING CO.
To: Harold Denton
Office of Nuclear Reactor Regulation
References
SNRC-572, NUDOCS 8105270462
Download: ML20004B265 (13)
v • d • e


Text

_

LONG ISLAND LIGHT!NG COM PANY 7 FACO Jaaramass SHOREHAM NUCLEAR POWER STATION P.O. BOX 618, NORTH COUNTRY RfJAD e WADING RIVER, N.Y.11792 SNRC-572 May 21, 1981 g7 C

C' 41 ?

LU l

I Mr. Harold R. Denton, Director f'_].,,N o g 1981 * *_9 office of Nuclear Reactor Regulation 1

ii

~ = -

~!

U.S.

Nuclear Regulatory Commission

' C -'

.1 u.s. T,l38,, A 5

Washington, DC 20555 s

s

/

- 8 ','

Shoreham Nuclear Power Tion - Unit 1 Docket No. 50-322

Dear Mr. Denton:

Enclosed are six (6) copies of LILCO's position addressing Safety Evaluation Report (SER) Outstanding Issue 45, Fire Protection.

Based on our review of the issue, we have concluded that the Shoreham design compares very favorably with Appendix R and the fire protection guidelines applicable to Shoreham.

If you have any questions, please contact us.

rul

yours, fery g 7,MW P.

N varro Project / Manager RAH /pd Enclosures l

cc:

J.

Higgins l

l V

l n

Y

\\

1 l

8195270462

APPENDIX R - FIRE PROTECTION PROGRAM FOR NUCLEAR POWER FACILITIES SHOREHAM EVALUATION II.

General Requirements II.A Fire Protection Program The Shoreham Protection Program as required by Appendix R has been established under station procedure SP39.001.0.

This procedure defines the levels of responsibility for the formu-lation, implementation, and assessment of the Fire Protection Program.

In addition, it provides an overview of the adminis-trative procedures which constitute the basis of the program.

The Plant Manager has the direct responsibility for formulating, implementing, administrating, and periodically assessing the effectiveness of the Fire Protection Program including fire drills and fire training of the fire brigade and plant personnel.

He is also directly responsible for the effective coordination of the fire protection program with the station emergency plan to assure that a single point of control and contact will exist for all fire contingencies.

The Shoreham Fire Protection Program is designed to ensure the capability to shutdown the reactor, maintain it in a safe shutdown condition, and minimize radioactive releases to the environment in the event of a fire.

The overall fire protection, detection, and suppression systems for the plant were reviewed based upon an evaluation of potential fire hazards and their effect on structures, systems, and components important to safety.

Total reliance for suppressing a fire is not placed on a single fire suppression system.

Appropriate backup suppression capability is also provided.

Evaluations of fire loadings affecting all safety-related areas have been performed to ensure that walls, floors, ceiling /

floor assemblies, and doors are adequate to 1) prevent external fires from spreading into these areas and 2) prevent any internal fire from spreading to adjacent safety-related areas.

This evaluation was also performed for all areas containing a significant inventory of radioactive materials.

.. ~

9 m

9

II.B Fire Hazards Analysis The Fire Hazard Analysis Report (FHA 2) documents a comprehensive evaluation of potential fire hazards through-out the plant.

Therein, the ability to safely shut down the plant considering fire hazards was analyzed.

As concluded by this analysis, Shoreham Nuclear Power Station is adequately protected against postulated fires which could challenge the ability to perform a safe shutdown of the plant.

In addition to assessing the impact on safe shutdown capability, fire hazards throughout the plant were reviewed with regard to the potential for a fire to cause an unaccept-able radioactive release.

The review determined that there is no single postulated fire within the plant which could cause an unacceptable release of radioactivity.

No release identified would e.<ceed a small fraction of the guidelines set forth in 10CFR100.

It should also be noted that through the use of fire retard-ant materials, strict limits on combustibles, and a comprehensive fire plan, the overall plant design presents a very low fire l

hazard.

In addition to the analysis reported in the FHAR, a study was conducted with respect to the Reactor Building which conservatively considered the effects of fire.

The study demonstrated that sufficient separation exists between redundant systems and components such that,even if all cables and raceways in very large segments of the reactor building are destroyed due to fire, the capability remains to safely shut down the plant.

The methodology and results of this study are reported in the Cable Separation Analysis Report l

submitted by letter SNRC-532 dated February 10, 1981.

II.C Fire Prevention Features Fire protection features are provided for all fire areas that contain or present a fire hazard to structures, systems, or components important to safety in accordance with the general requirements of this paragraph.

The Shoreham design features for fire protection are described in FSAR Section 9.5.

The requirements with respect to transient fire hazards will be covered by SNPS Station Procedure SP12.013.02

" Fire Prevention Watches,. Patrols and Permits" which will provide instructions on inspections, the use of fire prevention permits, the composition, function and deployment of fire equipment watches and patrols. --

Station Procedure SP39.001.02

" Fire Brigade Organization, Response and Drills" defines the composition and function of the station fire brigade, and its reponse in a fire emergency.

It also addresses the fire drills which shall assess the brigade's performance as a team, the status of associated emergency equipment, and the station performance, including outstde assistance.

This. procedure is consistant vith the detailed requirements of Appendix R.

SNPS Fire Suppression Systems are designed in conformance with National Fire Protection Association (NFPA) standards and meet the requirements of the American Nuclear Insurers (ANI).

Personnel who maintain and test fire detection and suppression systems shall be properly qualified by training or experience, or both as appropriate.

Procedures are being established to ensure that fire barriers and fire suppression systems and components are operable in accordance with Appendix R.

II.D Alternative or Dedicated Shutdown Capability The Shoreham position with respect to alternative or dedicated shutdown capability is discussed in paragraph III.L.

III.

Specific Requirements III.A Water Supplies for Fire Suppression Systems The Shoreham design is in full compliance with the requirements of this paragraph.

The water supply system is discussed in FSAR Section 9.5.1.2.

III.B Section Isolation Valves The Shoreham design is'in full compliance with the requirements of this paragraph.

Refer to FSAR Section 9.5.1.2.

I III.C Hydrant Isolation Valves The Shereham design is in full compliance with the requirements of this paragraph.

Refer to FSAR Section 9.3.1.2.

III.D Manual Fire Suppression l

The Shoreham design is in full compliance with the requirements l

of this paragraph.

Refer to FSAR Section 9.5.1.2.

i A maintainability study is being performed at Shoreham to insure walkway access is provided for all floors and elevation; l

of the station where systems or componencs are important to l

safety.

l l

III.E Hydrostatic Hose Tests The Shoreham hydrostatic hose tests will comply with the requirements of this paragraph.

III.F Automatic Fire Detection The Shoreham decign is in full compliance with the requirements of this paragraph.

Refer to FSAR Section 9.5.1.2.

III.G Fire Protection of Safe Shutdown. Capability Fire protection of safe shutdown capability is p2cvided by maintaining free of fire damage, one train of systems necessary to achieve and maintain shutdown conditions.

This is accomplished from either the Main Control Room or the Remote Shutdown Panel.

There is no single fire that can affect both the Main Control Room and the Remote Shutdown Panel.

See paragraph III.L for a discussion of the independence of the Remote Shutdown Panel.

In addition, there are numerous plant features which assure fire protection of safe shutdown capability.

In that regard, some of the more important areas of the plant are discussed below.

The electrical separation criteria for the Relay Room and cable spreading area are also described in Section 2 of the FRAR.

It is recognized that a sustained fire must be l

precluded in this area.

Therefore, this room is equipped with highly sensitive smoke and temperature detectors and a total flooding CO2 system as described in the FRAR.

In addition to the use of low combustible materials, strict controls are maintained on the introduction and use of transient combustibles.

In the unlikely event of a fire in the Relay Room, it will be quickly detected and automatically extinguished by the CO2 system, thus limiting the spread of fire from reaching significant levels.

Therefore, any damage sustained would be quite local due to the quick response of the fire suppression system and the fire retardent nature of the

.aaterials.

Under these conditions, sufficient capability will be available in the Main Control Room to safely shut the plant down should it be desirable or necessary to do so.

Furthermore, control of sufficient shutdown systems is provided on the Remote Shutdown Panel located in the Raactor Building.

The Remote Shutdown Panel is protected by a 3 hr rated concrete wall and stael door which completely enclose j

l the panel.

Within the enclosure, the panel is further j

protected by smoke detectors and an automatic halon fire l

suppression system.

The controls and instrumentation located in this panel are provided with transfer capability such thar they are isolated from the Relay Room and Main Control Room i

equipment when they are in service.

Transfer / control capability is also provided in the Diesel Generator and _

Emergency Switchgear Rooms to snable the emergency diesel generators to be started, connected to the emergency buses, and connected to emergency loads, independent of the control The plant is designed for orderly shutdown of the room.

reactor from outside the Main Control rcom.

For the Control Room, ionization detectors are installed in the supply and return air ducts and all safety-related panels and consoles.

All safety-related (Class lE) panels in the Control and Relay Rooms will be equipped with ionization type smoke detectors.

Most non-Class lE panels in thse areas also have the ionization smoke detectors installed.

These detectors alarm on the station security consoles in the Security Building and the Main Control Room.

There is one detector located in each enclosed section of the panel.

For large panels, multiple detectors are located to provide effective coverage.

Fire detectors will sound an alarm in the event of a fire.

Fire protection for the Control Room consists primarily of portable hand extinguishers located both inside and outside the area with CO2 hose reels as backup.

One CO2 hose reel is located in the north stairwell and one CO2 hose reel in the HVAC Equipment Room.

Both areas are immediately adjacent to the Main Control Room.

Minimal quantitites of combustible materials within panels prevent the occurrence of a fire of sufficient severity to cause propagation to adjacent panels or adjacent sections of the same panel.

Wires are flame retardant and self-extinguishing.

In those areas of Class 1E panels where adjacent controls /

instruments from two redundant safety divisions cannot be located in separate panels, separation is maintained by distance, by steel barrier or by enclosing one of the devices in a steel enclosure and by running the associated wiring in conduit to terminal blocks in the appropriate divisional area of the panel.

Consequently, safe shutdown capability is not lost.

In areas of the plant, such as Emergency Switchgear Rooms, Battery Rooms, Diesel Generator Rooms, 3 hr rated walls exist between equipment and cable of each train.

The Remote Shutdown panel Room including 3 hr fire barrier walls and door is protected by smoke detectors and automatic halon fire suppression system.

For the Reactor Building a study was performed to consider the effects of fire.

Conservatively sized plant segments were selected and all the safety related cables and components located in the segment were assumed lost due to fire.

The segments are overlapping 45 degree areas in the secondary containment and overlapping 60 degree areas in the primary containment.

The study concluded that sufficient separation exists between redundant systems and components that even if all the cables and raceways and components in thesc segments..

were lost due to fire, the capability remains to safely shut down the plant.

Furthermore, the primary containment will be inerted.

III.E Fire Brigade The Shoreham fire brigade will comply with the requirments of this paragraph.

III.I Fire Brigade Training The Shoreham fire brigade training will comply with the require-ments of this paragraph.

III.J Emergency Lighting Areas needed for operation of safe shutdown equipment and in access and egress routes thereto will be identified and 8 hr battery powered units installed to meet this requirement.

III.K Administrative Controls The Shoreham administrative controls will comply with the requirements of this paragraph.

III.L Alternative or Dedicated Shutdown Capability Alternative or dedicated shutdown capability is* required only where the protection of systems whose function is required for hot shutdown does not satisfy the requirement of paragraph G, (Fire Protection of Safe Shutdown Capability).

It is our position as discussed in paragraph G above, that the Shoreham design provides adequate fire protection of safe shutdown capability.

Therefore, special consideration for an alternative or dedicated shutdown capability is not required by Appendix R.

Nevertheless, the Shoreham design provides for an independent shutdown capability at the Remote Shutdown Panel.

l The Remote Shutdown Panel (RSP) provides remote control for the essential reactor systems needed to carry out the shutdown function from outside the Main Control Room to bring the reactor to cold shutdown in an orderly fashion.

It is in an alternate location from the normal control system used in the Main Control Rcoc Shutdown of the Reactor can be l

accomplished from the RSv if feedwater is not available 6

and the normal heat sinks, i.e., turbine and condenser, are l

lost.

{-

Transfer switches are provided in the RSP for the purpose of transferring control from the Main Control Room to the RSP for all the functions en the RSP.

When the transfer is completed the RSP functions inlapendant of the Control Room and the Relay Rccm.

Therefore, one train of equipment necessary to achie;e shutdown is maintained free of damage from an exposure fire in either the Relay Room or Control Room. l 1

III.M Fire Barrier Cable Penetration Seal Oualification

-The Shoreham design is in full compliance with the require-ments of this paragrapn.

Refer to FSAR Section 9.5.1.2.

i III.N Fire Doors The shoreham design is in full compliance with the requirements of this paragraph.

Refer to FSAR Section 9.5.1.2.

Inspection requirements will be covered through Station Procedures SP12.016.01

" Surveillance Program" and SP12.01S.01.

" Preventive Maintenance Program".

Access to keys will be provided to the Shoreham Fire Brigade Chief through Station Procedure SP91.005.01

" Lock and Key Control System".

An oil collection System for Reactor Coolant Pump I

An oil collection system for the recirculation pump is not required since the primary containment is inerted during normal operation.

When the plant is not operating, normal fire protection is available in accordance with BTP 9.5-1.

i I

l l

l

! f i

NRC FHAR FOLLOW-UP QUESTIONS TO OUR DECCC3:2 1973 RESPONSES Question No. 2 It is our position that an oil collection system be provided for the HPCI turbine pump and RCIC turbine pump.

This would resolve our concerns for questions Nos. 2, 12, and 13.

Response

HPCI and RCIC turbine pumps located at el 4 ft-0 in. of the Reactor Building are provided with a forced pressure lubrication system.

The HPCI and PCIC pumps are not normally operative; therefore, the lubricatio1 system is not under pressure.

Any leakage is contained in the immediate vicinity of the respective pump due to the partial wall between the pumps and the curbs provided for this purpose.

Each curbed area is drained by the floor drain system to respective underground sumps.

Moreover, due to the complexity of the lubrication system piping of the HPIC and RCIC turbines, it is impracticable to design and install a seismically supported and effective oil collection system around the pipes.

Also, as mentioned in the last paragraph of response to this question:

loss of both HPCI and RCIC does not impair the safe shutdown capability of the plant.

Therefore, the system design as provided, including early warning detection, fire suppression, and the installed oil collection system is adequate.

We state below our revised posicion on a previous response t6 question No. 12, where provision for 3-hr fire barrier is found not to be compatible with the as-built conditions.

A review of as-buiit conditions, with respect to incorporating a 3-hr rated fire barrier between vertical cable tray risers (at 1380 and 2230 azimuth) and adjacent pumps (HPCI and RCIC), has been completed.

Various interferences such as seismic pipe supports, cable trays, cable tray supports, conduits, and electrical junction boxes, limit the ability to provide a 3-hr fire barrier from el 8 ft-0 in. to el 40 ft-0 in.

A partial height barrier of 3-hr rated construction extending 9 ft high is being installed between the vertical cable trays and the adjacent RCIC pump.

The barrier will not encompass the trays entirely.

However, the fire loading at el 8 ft-0 in. of the Reactor Building as provided in Table 1 of the FHAR is less than one hour.

Each individual riser in the banks contain only Red, Orange or Blue division cables.

The distance between the two cable tray risers is 85 ft.

The HPCI turbine-pump set is located appro::imately 0),

30 ft. away due northwest from the vertical cable tray risers (138 thus providing physical separation and the RCIC turbine-pump set is located 25 ft southeast of the HPCI pump set.

The distance between the two cable tray risers is 85 ft.

The HPC: turbine-pt e sct is locat2d approximately 30 ft. away due northwes from :ne vertical cable tray risers (138

),

thus providing physical separation and the RCIC turbine-pump set is located 25 ft southeast of the HPCI pump set.

Fixed manual spray fire suppression system, together with an early warning fire detection system and lube oil l'c.kage detection system are provided for both HPCI and RCIC pump areas.

In addition, portable and fire hose stations are provided as backup fire suppression systemt.

The above features ensur'e that fire cannot spread to adjacent areas.

Loss of any one of ' the vertical cable tray risers will not impair both divisions of safety systen.s.

Also, we have demonstrated, by analysis, that loss of all electrical cables (including HPCI and RCIC) in the designated 450 zones of the Rea?cror Building does not impair the safe shutdown capabilities of the plant.

Question No. 3 The licensee should provide the penetration seal test reports or ANI approval sheets for all seals.

It is our position that all dampers, including motorized dampers, be UL listed.

Response

Penetration seal test reports and ANI (American Nuclear Insureres) acceptance sheets will be available for all seals utilized at Shoreham.

These are required to be furnished by the fire stop and seals contractor as part of the Specification SH1-459.

Fire dampers without motors are UL listed with fusible links and are labeled.

Fire dampers with motors ara certified UL construction with fusible links but are not labeled.

At the time these motorized fire dampers were purchased, UL listing for the motorized dampers as a unit was i

not available, therefore, the unit was not labeled.

The motor does not affect the closure during a fire.

Melting of the UL listed fusible link allows the damper to close on high temperature.

Question No. 5 It is our position that fire stops be insta]1ed in the vertical runs of the Reactor Building.

Response

All vertical cable tray runs in the Reactor Building are provided with approved fire stops where they penetrate any floor level.

Fire stops are also provided in cable trays at their midpoints when the distance between Reactor Building floor levels exceeds 25 ft.

This is in accordance with Specification SH1-459.

I t _

W e

vuestion No. 9 It is our position that the fire detection system be separated from the rest of the relay room by a 2-hr fire barrier so that a fire in the relay room will not cause the loss of e.9 tire fire det+.'ction system.

It is our position that fire detection system wiring be Class "A"

from the fire control panels within the relay room to the control room.

We would like to discuss the fire detection system during site visit to resolve concerns.

Response

The arrangament of the fire detection system wiring conforms to NFPA 72D for Class "A" circuits from the local detectors to the switching panel located within the relay room.

Class "A" circuits consist of 2 pairs of wires with switching capability to utilize either pair if a problem occurs.

From the switching panel to the fire zone modules and the console, each located in the control room, the circuits are continuously electronically supervised so that a loss of any circuit is alarmed.

Power supply equipment, such as the inverter, fire detection panels, and distribution panel are located in various parts cf the relay room.

It is not practicable to incorporate a 2-hr fire barrier within the relay room to achieve separation.

This would also impose additional requirements of ventilation, fire detection, and protection of the areas thus created.

All cabling must run through the relay room to reacn the control room.

The relay room is equipped with fire detection devices and fire suppression equipment for fire protection.

Automatic total flooding CO fire suppression system provided for the relay room is adequate.

2 1

Question No. 11 2

It is our position that a permanent second feed be provided for the Reactor Building fire water systems.

l Verify that in the event cf an SSE, water is still available for fire suppression use in the Reactor Building.

Response

A permanent second feed will be provided for the Reactor Building l

fire water system from the yard fire loop and will be connected into the Reactor Building seismically supported fire protection system.

l l

The fire protection system was not designed to Seismic Category I l

Cri:2ria and, tharafcre, may not be a>cilable for fire suppression l

cse in the Reactor Building in the event of a SSE.

P !

.-v

However, the portions of the system located in safety-related areas are supported such that failure during a seismic event cannot significantly impair the capability of any safety-related equipment.

However, a seismic Category I safety-related service water line inside the Reactor Building has been provided.with a spare connection available tor manual hook-up to the fire suppression system.

This alternate connection ensures that fire suppression system is available following a SSE.

Question No. 14 It is our position that a fixed automatic water sprinkler system be provided in the table spreading room (relay room).

Response

The relay room is protected by a low pressure total flooding CO2 fire suppression system.

This system is actuated automatically by heat detectors or it can be actuated manually.

The area and panels are also monitored by early warning ionization smoke detectors which in combination with heat detectors, for the actuation circuit of the CO2 system, provide constant and sensitive surveillance for detection of any fire in its incipient stages.

The CO2 system is designed to provide two successive total flooding CO2 discharges.

In addition, a manual water suppression system (standpipe hose stations) has been provided for the cable spreading room (relay room) in the event that a deep-seated fire in a fully loaded cable tray is not permanently suppressed by the CO2 system.

The manual cap &bility is preferred because it provides ror selective application of water in the relay room and would limit the consequences of water damage.

Prompt fire detection and actuation of the fixed CO2 system will l

prevent a fire from becoming established.

Backup suppression capability is provided with standpipe water hose station, CO2 hose reels, and portable extinguishers.

l l

Provisions to protect the relay room as described above are l

compatible with the components within the room and are adequate.

Question No. 16 It is our position that a hose station be provided in the screenwell pump house.

l

Response

Each of the redundant safety-related service water pump rooms in the screenwell pump house has a low fire loading of 30,000 Btu /ft less than the equivalent fira severity of 1/2 hr.

1 l l

w

- - + '

T t'

T e

F

~-*-

'T

- ' '7?E

Previous response to question No. 16, indicated two yard fire hydrants are provided with hoses for double stream coverage in addition to portable fire entinguishers.

The 3-hr rated fire door between the pump rooms is monitored for closure and alarmed in the control room.

In ad e,ition, each of the rooms is provided with two area detectors and tue duct detector for early warning.

Provisions as described above for protection of each of the redundant screenwell pump rooms are adequate.

A hose station for each room is not required.

Question No. 19 Provide justification for use of 1 1/2 hr dampers.

Response

The 1 1/2 hr fire dampers provided are equal to or better than the fire loading of the ad acent areas.

The structural design J

requirements of the walls results in the fire rating of the barrier exceeding the require =ent of the fire dampers.

Question No. 26 Appendix R hr battery packs.

Response

Areas needed for operation of safe shutdown equipment and for access and egress routes thereto will be identified and 8-hr battery powered units installed. - - -, - _

_.

Retrieved from "https://kanterella.com/w/index.php?title=ML20004B265&oldid=4674855"