ML20079F439
| ML20079F439 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 05/17/1982 |
| From: | Benaroya V Office of Nuclear Reactor Regulation |
| To: | Miraglia F Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20079F427 | List:
|
| References | |
| FOIA-84-35 NUDOCS 8205270420 | |
| Download: ML20079F439 (7) | |
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NUCLE AR REGUL ATORY COMMISSION
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MAY 171982 MEMORANDUM FOR:
Frank Miraglia, Chief Licensing Branch No. 3 Division of Licensing FROM:
Victor Benaroya, Chief Chemical Engineering Branch Division of Engineering
SUBJECT:
FIRE PROTECTION REQUEST FOR INFORMATION FOR SHEAROM HARRIS UNITS 1-4 Plant Name:
Shearon Harris Nuclear Power Plant Units 1-4 Docket Hos.:
50-400-403 Milestone No. :
N/A Licensing Branch:
LB 13 Prcject Manager:
D. Ward
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CMEB Reviewer:
R. Eberly Requested Completion Date:
May 19,1982 Review Status:
Q-l's completed Enclosed is our request for the additional infonnation CMEB cnd ASB need on the fire protection program to complete our review.
The primary items of concern apply throughout the plant.
We will need the information by November 1,1982 to meet the schedule.
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Victor Benaroya, Chief
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Chemical Engineering Branch
'I Division of Engineering
Enclosure:
As stated
Contact:
R. Eberly Ext. 24565 cc:
R. Vollmer J. Tay1or D. Eisenhut S. Pawlicki W. Johnston T. Sullivan f~Etie'rlyT' Region I R. Tedesco S. EbW ter, R. Ferguson
- 0. Parr T. Conlon, Region 11 N. Wagner C. Norelius, Region III T. Wambach G. Madsen, Region IV
- 9. Kerd P. Sternberg, Region V 0
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i Chemical Engineering Branch Fire Protection Section Request for Information Shearon Harris Units 1-4 Docket Nos. 50-400-403 280.1 Your fire protection program willibe reviewed to the guidelines of BTP CMEB 9.5-1 (NUREG-0800), July 1981.
Provide a comparison 4
that shows conformance of the plant fire protection program to these guidelines.
Deviations from the guidelines should be
- specifically identified.
A technical basis shold be provided for each deviation.
280.2 Provide the qualifications of the fire protection engineer responsible for the formulation and implementation of the fire protection program.
280.3 Verify that a plant fire brigade will be provided in accordance with BTP CMEB 9.5-1 Section C.3.b.
280.4 Verify that the plant fire brigade will have the minimum equipment listed in BTP CMEB 9.5-1 Section C.3.c.
28'0.5 Verify that fire brigade drills will be performed at regular intervals in accordance with BTP CMEB 9.5-1 Section C.3.D.7.
280.6 Verify that all fire barriers have been tested and approved by-an independent laboratory.
280.7 Verify that all openings in rated fire barriers will be sealed to provide a fire resistance rating at least equal to that of 4
the barrier in conformance with BTP CMEB 9.5-1 Section C.S.a.
,i 280.10 Provide a design description of the types of penetration seals a,
used, including materials of-construction.
Verify that tests have been conducted to qualify the resistance of the seals in accordance with BTP CMEB 9.5-1 Section C.S.a.
Verify that the seals will be installed in accordance with the manufacturer's r
instructions.
-280.11 On page 9.5.1-9 of your FSAR you state that " fire dampers are not provided in safety-related ductwork".
It is our position that fire dampers be provided for all ventilation duct penetrations of fire barriers in conformance with BTP CMEB
- 9. 5-1 Section C.5. a. _ Verify that all fire barrier ductwork penetrations will be sealed by fire dampers having a fire resistance rating at least equal to that of the barrier.
Verify that such dampers have been tested and approved by a nationally recognized laboratory.
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2-280.12 Verify that door openings in fire barriers will be protected with equivalently rated doors, frames, and hardware.
Speci fy that a nationally recognized independent testing laboratory has tested and labelled this equipment in accordance with BTP CEB 9.5-1 Section C.5.a.
Verify that the closing of fire doors will be supervised by 280.13 one of the measures stated in BTP CMEB Section C.5.a.
280.14
' Verify that all indoor transfomers are of the dry type as 4
required by BTP CMEB 9.5-1 Section C.S.a.
280.15 Verify that fire protection has been provided for safe shutdown so that one train of systems necessary to achieve and maintain hot shutdown conditions from either the control room or emergency control station (s) is free of fire damage and that system necessary to achieve and maintain cold shutdown from either the control room or the emergency control station (s) can be repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Provide an analysis which shows that one redundant train of equipment structures, systems, and cables necessary for safe shutdown can be maintained free of fire damage by either:
a)
Separa' tion of cables and equipment and associated circuits of redundant trains by a fire barrier having a 3-hour rating.
Structural steel foming a part of or supporting such fire barrigrs should be protected to provide fire resistance equivalent to that required of the barrier; b)
Separation of cables and equipment and associated circuits 4
of redundant trains by a horizontal distance of more than 20 feet with no interventing combustible or fire hazards.
In addition, fire detectors and an automatic fire suppression system should be installed in the fire area; or c)
Enclosure of cable and equipment and associated circuits of one redundant train in a fire barrier having a 1-hour rating.
In addition, fire detectors and an automatic fire suppression system should be installed in the fire area.
280.16 Identify those areas of the plant that will not meet the guidelines of Section C.5.b of BTP CMEB 9.5-1 and, thus alternative shutdown will be provided.
Additionally provide a statement that all other areas of the plant will be in compliance with Section C.5.b of BTP CMEB 9.5-1.
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J 3 For each of those fire areas of the plant requiring an alternative shutdown system (s) provide a complete set of responses to the following requests for each fire area:
a) List the system (s) or portions thereof used to provide the shutdown capability with the loss of offsite power.
b) For those systems identified in "a".for which alternative or dedicated shutdown capability must be provided, list the equipment and components of the nomal shutdown system in the fire area and identify the functions of the circuits of the normal shutdown system in the fire area (power to what equipment, control of what components and instrumentation).
Describe the system (s) or portions s
thereof used to provide the alternative shutdown capability for the fire area and provide a table that lists the. equipment and con'ponents of the alternative shutdown system for the fire area.
For each alternative system identify the function of the new circuits being
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provided.
Identify the location (fire zone) of the alternative shutdcwn equipment and/or circuits that bypass the fire area and verify that the alternative shutdown equipment and/or circuits are separated from the fire area in accordance with Section III.G.C.
c) Provide drawings of the alternative shutdown sr ts) which highlight any connections to the nomal shutdown i
systems (P& ids fcr piping and components, elementary I
wiring diagrams of electrical cabling).
Show the electrical location of all breakers for power cables,-
and isolation devices for control and instrumentation, circuits for the alternative shutdown systems for tha't
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fire area.
d). Verify that procedures have been or will be developed which describe tasks to be performed to effect the shutdown method.
Provide a summary of these procedures outlining operator actions.
e) Verify that the manpower required to perfom the shutdown functions using the procedures of e) as well as to provide fire brigade members to fight the fire is available as required by the fire brigade technical specifications.
f) Provide a commitment to perfom adequate acceptance tests of the alternative shutdown capability.
These tests should verify that:
equipment operates from the local control
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. station when the transfer or isolation switch is placed in the " local" position and that the equipment cannot be operated from tiie control room; and that equipment operates i
from the control but cannot be operated at the local control station when the transfer isolation switch is in the " remote" position.
g)
Verify that repair procedures for cold shutdown systems are developed and material for repairs is maintained on si te.
Provide a summary of these procedures and a list of the material needed for repairs.
280.17 Verify that in the event of a fire involving alternate shutdown equipment which causes a hot short in the transfer switches, hot and cold shutdown can still be achieved.
Also show that in the s
event of fire involving alternate shutdown equipment without hot shorts in transfer switches, safe shutdown can be a?fected.
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280.18 Verify that procedures will be developed for maintaining the primary system pressure during hot shutdown in the event the pressurizer heaters become inoperable due to fire damage.
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Verify that the design of alternate shutdown equipment will 280.19 not permit' a single failure to cause 1oss of redundant safety system; e.g. you may not permit control circuits for both RHR systems to pass through one transfer switch, thus allowing a loss of redundant safety systems by a single failure.
280.20 Verify that'a fire involving any high-low pressure interfaces which use redundant electrically controlled devices to isclate the primary coolant boundary will not challenge the integrity of the primary pressure boundary (GDC 11 and GDC 31).
1 250.21 Describe how communications will' be achieved between the personnel ' performing cold shutdown.
Verify that you have adequate manpower to complete all necessary cctions.
280.22 Verify that the following instrumentation necessary for safe shutdown will be accessible to operators following a fire in the control room or alternate shutdown equipment:
pressurizer pressure and level; reactor coolant hot leg temperature and either cold leg temperature or TAVG; steam generator pressure and level (wide range);
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.. source range flux monitor; actual flow measurements for all pumps used; and level indication for all tanks used.
280.23 Discuss the steps necessary to assure satisfactory control of plant reactivity when proceeding to hot shutdown and then to cold shutdown.
Verify that a control room fUe will not cause spurious 280.24 signals resulting in undersirable operation of any safe shutdown equipment controlled from the alternate shutdown panel.
280.25 Verify that all associated circuits of concerr whose fire-induced failure could affect safe shutdown have been adequately protected.
280,26 On page 9.5.1-21 of your FSAR, you state that emergency D.C.
lighting feed from the 125 volt station batteries will provide emergency lighting for the control room.
It is our postion that' self-contained 8-hour minimum capacity, battery powered emergency lighting units be installed in conformance with BTP CMEB 9.5-1 Section C.S.g.
4 280.27 Verify that a fire detection system has been provided in accordance with BTP CMEB 9.5_-1. Section C.6.a to protect all areas that contain or present a fire exposure to safety related equipment and cables.
280.28 Verify that hydrant isolation valves will be provided in the fire main in confomance with BTP CMEB 9.5-1 Section C.6.b.
280.29 Verify that the fire pumps, motors, and controllers will be listed by an independent testing laboratory for the senrice intended.
280.30 Verify that all control and sectionalizing valves in the fire protection water system will be supervised in confomance with the guidelines of BTP CMEB 9.5-1 Section C.6.c.
280.31 Identify all areas of the plant where Halon 1301 or carbon dioxide systems are installed.
Verify that the Halon systems neet the guidelines in BTP CMEB 9.5-1 Section C.6.d and the carbon dioxide systems BTP CMEB 9.5-1 Section C.6.e.
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4 280.32 It is our position that the reactor coolant pumps be equipped with an oil collection system in conformance with Section C.7.a of BTP CMEB 9.5-1.
Provide the
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design description of this system.
280.33 One control room is provided for both units.
In the event of a fire in the control room equipment for both units could be damaged and both units would have to be shutdown from outside the control room.
Verify that both units can be safely shutdown in the event of such a fire in the control room.
Show that there is the necessary manpower available to perform all necessary l
actions.
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280.34 Verify that all cables in the control room meet the separation criteria and fire protection criteria detailed s
in BTP CMEB 9.5-1 Section C.7.b.
l 280.35 Describe how ' hydrogen concentrations in the battery room l
will be maintained below 2 volume % in conformance with BTP CMEB Section C.7.g.
Verify that the loss of ventilation is alarmed in the control room.
j 280.'36 It is our position that water sprinkler systems for the protection of the diesel generators be designed in accordance with NFPA Std.13 or 15.
The NFPA standards i
j do not cover multi-cycle sprinkler systems.
Justify that the design basis used for the multi-cycle sprinkler system is equivalent to that provided by the NFPA design.
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280.37 On page 9.5-35 of your FSAR, you state that 3000-ga11on capacity day tanks are provided for each diesel generator.
It is our position that day tank capacity should not exce'ed 1100 gallons in accordance with BTP CMEB 9.5-1 Section C.7.1, or the fire protection provided for the tanks should meet the guidelines in BTP CMEB 9.5-1, Section C.7.j.
280.38 On page 9.5.1-37 of your FSAR, you state that a Halon 1301 system is provided for the record storage facility.
The i
system has been designed for a 10 percent concentration of halon within 30 seconds of discharge.
This is not consistent with NFPA standard 12A.
It is our position that the system be designed in accordance with NFPA standard 12A according to our guidelines in BTP CMEB 9.5-1 Section C.6.d.
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