ML20204D162

Interim Rept on SER Review Re Fire Protection Program. Inadequately Covered Items:Lube Oil Fire in Turbine Bldg, Control Valves Subj to Human Failure,Effect of Seismic Damage,Smoke Removal by Ducts & Wiring in Signaling Sys

ML20204D162
Person / Time
Site:	Palisades
Issue date:	08/30/1978
From:	Randy Hall, Mcdougall E BROOKHAVEN NATIONAL LABORATORY
To:	Ferguson R Office of Nuclear Reactor Regulation
References
TR-780830, NUDOCS 7812110293
Download: ML20204D162 (5)

Text

. __ _ _ . . . _

INTERIM REPORT' .

Accession No.

e

. Contract Program er Project

Title:

Fire Protection-in Operating Nuclear Power Stations: >

Subject of this' Document: Palisades Safety Evaluation Report Review l 1

Type of Document: Letter. Report Author (s): R.E. Hall and E.A. MacDougall Date of Document: August 1978 .

~

Responsible NRC Individual Mr. Robert L. Ferguson and NRC Office or Division: Division of Operating Reactors ,

Office of Nuclear Reactor Reg.

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 This document was prepared primarily for preliminary or internal use. It has not received full review and approval. Since there >

may be substantive changes, this document should not be considered final.

b Brookhaven National Laboratory Upton, NY 11973 Associated Universities, Inc.

I for the U.S. Department of Energy Prepared for  !

U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Under Interagency Agreement EY-76-C-02-0016 NRC FIN No. A-3107 INTERIM REPORT t

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. o Y kmI 60g BROOKHAVEN NATIONAL LABORATORY , l 7E[9

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ASSOCIATED UNIVERSITIES, INC.

Upton, New York 11973 Department of Nuclear Energy (516) 345-2144 August 30, 1978 Division of Operating Reactors U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Mr. Robert, L. Ferguson Plant Systems Branch

SUBJECT:

Fire Protection in Operating Nuclear Power Stations - Palisades Safety Evaluation Report Review The Safety Evaluation Report, dated July 21, 1978, as developed jointly by the NRC staff and Brookhaven National Laboratory (BNL), adequately reflects the concerns and recommendations of the consultants. Throughout the r.eeval-uation'of Palisades, there has been general agreement between the NRC staff and the BNL consultants. Based on present data, the proposed fire protection, as set forth in the SER, will give reasonable assurance that the health and '

l safety of the public is not endangered. The following exception represents a differing engineering point of view that should be evaluated by the NRC staff.

1. Turbine Building SER Item 5-15 concludes that fire protection in the turbine building is acceptable. However, the licensee's fire hazard analysis does not adequately address the consequences of an unsuppressed lube oil  !

fire in the turbine building (see October 24, 1977 letter from l L.P. Herman to R.E. Hall on this subject.)

2. Control Valves SER Item 4.3.1.3 indicates that the position of fire protection system valves will be controlled by locks or seals with periodic  ;

inspections. Locking or sealing programs depend upon ongoing administrative controls that are subject to human failure. Locks ,

can also prevent prompt water shutoff if piping ruptures. It is i valves for fire protection systems protecting areas containing or exposing safeh'-related equipment.

11C ,lesearci anc' Teclnical Assistance Report

'rs u n o 213

3. Seismic Damage The SER does not consider the effect of seismic damage on primary and back-up fire protection systems, although Branch Technical Position 9.5-1 addresses this item for new plants. It is recommended that the potential that a seismic event could cause both a fire and damage to the protective features provided to cope with the fire be further evaluated. This should include fires started in nonseismi-cally qualified systems or areas that spread to safety-related sys-tems because protective systems are damaged.

4. Smoke Removal SER Item 4.4.1 indicates that portable fans and ducts will be accepted as a means for removing smoke from many plant areas. Fires in elec-trical insulation can generate copious amounts of dense smoke which hamper fire control efforts by rendering the atmosphere toxic and reducing visibility in the area. Properly used, self-contained breathing apparatus can minimize the problem of toxic atmosphere, but little can be done to improve visibility except to remove the smoke from the building.

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

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5. Protective Signaling System i Portions of the protective si )naling system utilize unsupervised d wiring. NRC has required an increased frequency of testing for this system. It is reconmended that supervised circuits be re-quired instead.

6. Yard Hydrant Eouipment - Section 3.1.2 This section as written appears' too " general" and brief, in that it does not require certain essential tools and equipment; i.e.

hydrant wrenches, hose spanner wrenches, spare hose gaskets. See JHR Report par. 8.0, page 15; and Sec. 5-6.1 NFPA No. 24 - 1977.

7. Non-Safety Related Hydrants It is recommended that hydrant no. 6 be barricaded against possible vehicle damage.

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The. preceding. statements-are based on a detailed reevaluation of the Lfire protection program as implemented by the Consumers Power Company at the Palisades Nuclear Power Station. The-analysis covered a review of the fire prevention, detection and_ suppression capabilities of the Palisades unit as interfaced.with the nuclear systems requirements. This was accomplished by utilizing a review team concept with members from BNL and the Nuclear Reg-ulatory Commission Division of Operating Reactors staff.

The fire protection evaluation .for Palisades is based on an analysis of documents submitted by the Consumers Power Company to the Nuclear Regulatory Commission and a site visit. The site visit was conducted by Mr. J.E. Knight and Mr. H.J. George of the NRC; Mr. L. Paul Herman of Rolf Jensen and Asso-ciates, Inc. , under contract to BNL; and Mr. J. Riopelle was under contract' to BNL to review the manual-fire fighting capabilities of the station along with administrative controls.

The Palisades review has been conducted under the direction of Mr. E. MacDougall and myself of the Reactor Engineering Analysis Group at BNL, and has had the following major milestone dates.

1. The CPC " Fire Protection Program Evaluation" was transmitted to NRC on March 31,-1977.

2. On September 29,-1977, CPC transmitted a supplement to their original evaluation for the reactor containment building.

3. On January 30, 1978, NRC transniitted a Staff Position and Requests for Additional Information based on an initial review of the CPC submi ttals. ,

4. The site visit was conducted on May 8-12, 1978. The ' primary Review Team consisted of James E. Knight and Henry J. George of the NRC staff, James H. Riopelle, private consultant, and L. Paul Herman of Rolf Jensen- and Associates, Inc. Mr. Knight served as 4 team leader and spokesman. $

5. On May 15, 1978, CPC transmitited responses to the initial NRC Pas-ition and Requests for Additional Information

6. On May 24, 1978, NRC transmitted further staff Positions and Requests for Additional Information based on the site visit.

7. On June 30, 1978, CPC transmitted responses to the site visit Pos -

itions and Requests for Additional Information.

8. The SER draft' associated with this report is attached to a memo.

from G.C. Lainas to D. Ziemann, dated July 21, 1978.

9. Certain modifications to the SER draft identifiad above were con-tained in a mema from Hank George to Dick Silver dated August 2, 1978.

-4 i

This. review process has resulted in identifying areas of the plant in

- which a-fire could have undesirable' effects. on safe shutdown of the reactor and on release of- radioactivity to the environment. . The Utility's proposed modifications are'significant steps in reducing the undesirable effects of ,

-i a fire in this plant.

. Respectfully yours, ,

// fc r

[Mh obert E.. Hall,. Group Leader

- Reactor Enqineering Analysis  ;

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DISTRIBUTION M. Antonetti 1

1. Asp 1 V. Benaroya 1 E. Blackwood I W. Butler 1 R. Cerbone 1 D. Eisenhut 1 R. Feit 1 R. Ferguson 5 R. Hall 1 S. Hanauer 1

. P'. Herman 1

. E. Imbro 1 W. Kato 1 J. Klevan I G. Lainas 1 C. Long 1 E. MacDougall 1 J. Riopelle 1 V. Stello 1 T. Telford 1 H. Todosow 2 J. Townley 1 PDR- 2

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