Oconee, Units 1, 2 & 3, License Amendments 64, 64 & 61 ... · -GII •(Ko•Y D0C•¶ET FILa Local...

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ORB#4 Rdg AUGUST 1 1 1978 VStello

Docket Nos.1 8 BKGrimes 50-2 Rlngram 50-270 S _2 RReid

and 50-287 UMFairtile OELD

Duke Power Company 0on&es(5)

ATTN: Mr. William 0. Parker, Jr. BScharf(15)

Vice President - Steam Production B~ch

Post Office Box 2178 JMcGough

422 South Church Street BHarless

Charlotte, NC 28242 DEisenhut ACRS(16)

Gentlemen: OPA(CMiles) TBAbernj

The Commission has issued the enclosed Aimienm Nos. 64,64 nd 61 to Facility Operating License Nos. DPR-38, DPR-47ad DPR-55 f he Oconee Nuclear Station, Unit Nos. 1, 2 and 3. r-mendments are in response to your submittals dated December 31, 1976, March 1, July 18, November 22, December 15, 1977; January 16, January 25, February 1, February 17, February 22, May 9, June 19, and July 19, 1978.

nan

These amendments add license conditions relating to the completion of facility modifications for fire protection.

Copies of the Safety Evaluation and Notice of Issuance are also enclosed.

Sincerely,

Oritinal 9jgned b!

Robert W. Reid, Chief Operating Reactors Branch #4 Division of Operating Reactors

Enclosures: 1. Amendment No. 64 to DPR-38 2. Amendment No. 64 to DPR-47 3. Amendment No. 61 to DPR55 4. Safety Evaluation 5. Notice of Issuance

cc w/enclosures: See next page

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AUGUST '. i 1978Duke Power Company - 2

cc: Mr. William L. Porter Duke Power Company P. 0. Box 2178 422 South Church Street Charlotte, NC 28242

J. Michael McGarry, III, Esquire DeBevoise & Liberman 700 Shoreham Building 806 - 15th Street, N. W. Washington, DC 20005

Oconee Public Library 201 South Spring Street Walhalla, SC 29691

Honorable James M. Phinney County Supervisor of Oconee County Walhalla, SC 29621

Chief, Energy Systems Analyses Branch (AW-459) Office of Radiation Programs U. S. Environmental Protection Agency Room 645, East Tower 401 M Street, S. W. Washington, DC 20460

U. S. Environmental Protection Agency Region IV Office ATTN: EIS. Coordinator 345 Courtland Street, N. E. Atlanta, GA 30308

Mr. Chrys Baggett State Clearinghouse Division of Policy Development 116 West Jones Street Raleigh, NC 27603

Docket

-• UNITED STATES

NUCLEAR REGULATORY COMMISSION VWASHINGTON, D. C. 20555

August 11, 1978

Nos. 50-269 50-270

and 50-287

Duke Power Company ATTN: Mr. William 0. Parker, Jr.

Vice President - Steam Production Post Office Box 2178 422 South Church Street Charlotte, NC 28242

Gentlemen:

The Commission has issued the enclosed Amendment Nos. 64, 64 and 61 to Facility Operating License Nos. DPR-38, DPR-47 and DPR-55 for the Oconee Nuclear Station, Unit Nos. 1, 2 and 3. The amendments are in response to

your submittals dated December 31, 1976, March 1, July 18, November 22, December 15, 1977; January 16, January 25, February 1, February 17, February 22, May 9, June 19, and July 19, 1978.

These amendments add license conditions relating to the completion of facility modifications for fire protection.

Copies of the Safety Evaluation and Notice of Issuance are also enclosed.

Sincerely,

iobert W. Reid, Chief Operating Reactors Branch #4 Division of Operating Reactors

Enclosures:. 1. Amendment No. 64 to DPR-38 2. Amendment No. 64 to DPR-47 3. Amendment No. 61 to DPR55 4. Safety Evaluation 5. Notice of Issuance

cc w/enclosures: See next page

August 11, 1978Duke Power Company

cc: Mr. William L. Porter Duke Power Company P. 0. Box 2178 422 South Church Street Charlotte, NC 28242

J. Michael McGarry,.III, Esquire DeBevoise & Liberman 700 Shoreham Building 806 - 15th Street, N. W. Washington, DC 20005

Oconee Public Library 201 South Spring Street Walhalla, SC 29691

Honorable James M. Phinney County Supervisor of Oconee County Walhalla, SC 29621

Chief, Energy Systems Analyses Branch (AW-459) Office of Radiation Programs U. S. Environmental Protection Agency Room 645, East Tower 401 M Street, S. W. Washington, DC 20460

U. S. Environmental Protection Agency Region IV Office ATTN: EIS Coordinator 345 Courtland Street, N. E. Atlanta, GA 30308

Mr. Chrys Baggett State Clearinghouse Division of Policy Development 116 West Jones Street Raleigh, NC 27603

-2 -

* UNITED STATES 0 1,• NUCLEAR REGULATORY COMMISSION

. .k , • ,•'WASHINGTON, D. C. 20555

DUKE POWER COMPANY

SIDOCKET NO. 50-269

Conrtol f DOU't OCONEE NUCLEAR STATION, UNIT NO. 1

_ PQOAT-Iý AMENDMENT TO FACILITY OPERATING LICENSE

Amendment No. 64

License No. DPR-38

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The facility will operate in conformity with the provisions of the Atomic Energy Act of 1954, as amended (the Act) and the rules and regulations of the Commission;

B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission;

C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations;

D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and

2. Accordingly, the license is amended by adding paragraph F to Facility License No. DPR-38 to read as follows:

F. The licensee is authorized to proceed with and is required to complete the modifications identified in Table 3.1 of the NRC's Fire Protection Safety Evaluation Report on the Oconee Nuclear Station dated August 11 , 1978. The modifications shall be completed on the schedule specified by Table 3.1. Detailed design information concerning

-2-

Section 3.1.14 must be submitted within 15 months from the time we approve the concept of the Oconee Safe Shutdown Facility. In the event these dates for submittal cannot be met, the licensee shall submit a report explaining the circumstances, together with a revised schedule.

3. This license amendment is effective on the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION S/ " /


Date of Issuance: August, 11, 1978

"I- ,UNITED STATES SNUCLEAR REGULATORY COMMISSION

WASHINGTON, D. C. 20555

DUKE POWER COMPANY

DOCKET NO. 50-270

OCONEE NUCLEAR STATION, UNIT NO. 2

AMENDMENT TO FACILITY OPERATING LICENSE

Amendment No. 64

License No. DPR-47




C. There is reasonable assurance (i) thdt the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations;




I

-2-

Section 3.1.14 must be submitted within 15 months from the time we approve the concept of the Oconee Safe Shutdown Facility. In the event these dates for submittal cannot be met, the licensee shall submit a report explaining the circumstances, together with a revised schedule.

3. This license amendment is effective on the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION


Date of Issuance: August 11, 1978

0 • "' UNITED STATES

NUCLEAR REGULATORY COMMISSION J:. ,• 00 WASHINGTON, D. C. 20555

DUKE POWER COMPANY

DOCKET NO. 50-287

OCONEE NUCLEAR STATION, UNIT NO.3

AMENDMENT TO FACILITY OPERATING LICENSE

Amendment No. 61 License No. DPR- 5 5




C. There is reasonable assurance (i) thaL the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations;




FIRE PROTECTION

SAFETY EVALUATION REPORT

BY THE

OFFICE OF NUCLEAR REACTOR REGULATION

U.S. NUCLEAR REGULATORY COMMISSION

IN THE MATTER OF

DUKE POWER COMPANY

OCONEE NUCLEAR STATION, UNITS 1, 2, & 3

DOCKET NOS. 50-269, -270, -287

AUGUST 11, 1978

TABLE OF CONTENTS

PAGE

1.0 INTRODUCTION ............................................................. 1-1

2.0 FIRE PROTECTION GUIDELINES .................................................. 2-1

2.1 Overall Objectives ..................................................... 2-1 2.2 General Design Criterion 3. - "Fire Protection" .......................... 2-1

3.0 SUMMARY OF MODIFICATIONS .................................................... 3-1

3.1 Modifications .......................................................... 3-1

3.1.1 Smoke Detectors ................................................. 3-1 3.1.2 Fire Header Piping .............................................. 3-1 3.1.3 Fire Barrier Penetrations ....................................... 3-1 3.1.4 Portable Handlights ............................................. 3-3 3.1.5 Water Flow Alarms ............................................... 3-3 3.1.6 Hose Stations ................................................... 3-3 3.1.7 Propane Tanks ................................................... 3-3 3.1.8 Portable Extinguishers .......................................... 3-3 3.1.9 Portable Smoke Exhausters ....................................... 3-3 3.1.10 Emergency Breathing Air Supply .................................. 3-3 3.1.11 Fire Hose Nozzles ............................................... 3-3 3.1.12 Oil Collection System ........................................... 3-3 3.1.13 Cable Penetration Fire Stop Test ................................ 3-4 3.1.14 Dedicated Safe Shutdown Facility ................................ 3-4 3.1.15 Administrative Controls ......................................... 3-4 3.1.16 Fixed Suppression Systems ....................................... 3-4 3.1.17 Interim Measures .............................................. 3-4 3.1.18 Reactor Building Communications ................................. 3-4

4.0 EVALUATION OF PLANT FEATURES ................................................ 4-1

4.1 Safe Shutdown Systems .................................................. 4-1 4.2 Fire Detection and Signaling Systems ................................... 4-1 4.3 Fire Control Systems ................................................... 4-2

4.3.1 Water Systems ................................................... 4-2

4.3.1.1 Water Supply ........................................... 4-2 4.3.1.2 Fire Pumps ............................................. 4-2 4.3.1.3 Fire Water Piping System ............................... 4-3 4.3.1.4 Interior Fire Hose Stations ............................ 4-3 4.3.1.5 Automatic Sprinkler Systems ............................ 4-4 4.3.1.6 Foam ................................................... 4-44.3.1.7 Effects of Suppression Systems on Safety Systems ....... 4-4

TABLE OF CONTENTS (Cont.)

4.3.2 Gas Fire Suppression Systems ............ 4.3.3 Portable Fire Extinguishers .............

4.4 Ventilation Systems and Breathing Equipment ....

4.4.1 4.4.2 4.4.3

Smoke Removal .......................... Filters ................................ Breathing Equipment ....................

Floor Drains ............................ Lighting Systems ........................ Communication Systems ................... Electrical Cable Combustibility ......... Fire Barrier Penetrations ...............

4.9.1 4.9.2 4.9.3

Electrical Cable, Conduit and Piping Penetrations .... Fire Doors and Hatches ............................... Ventilation Duct Penetrations ........................

Separation of Equipment; Safe Shutdown System. Fire Barriers ................................. Access and Egress ............................. Toxic and Corrosive Combustion Products ....... Nonsafety-Related Areas ....................... Instrument Air ................................

5.0 EVALUATION OF SPECIFIC PLANT AREAS - UNITS 1, 2 AND 3 ............

5.1 Reactor Building ............................................ 5.2 Control Room - Auxiliary Building Elevation 822 Feet ........

Auxiliary Building Elevation 838 Feet .......... Auxiliary Building Elevation 796 Feet .......... Auxiliary Building Elevations 771 and 783 Feet. Auxiliary Building Elevation 758 Feet .......... Cable Spreading Room ........................... Battery Rooms .................................. Penetration Areas .............................. Turbine Building - Turbine Deck Level .......... Turbine Building - Mezzanine Level ............. Turbine Building - Basement Level .............. Yard Area ...................................... Block House .................................... Keowee Hydro Station ...........................

6.0 ADMINISTRATIVE CONTROLS .....................................................

PAGE

4.5 4.6 4.7 4.8 4.9

4-5 4-5

4-5

4-5 4-6 4-6

4-6 4-6 4-7 4-7 4-7

4-7 4-8 4-9

4.10 4.11 4.12 4.13 4.14 4.15

4-9 4-11 4-11 4-11 4-12 4-12

5-1

5.3 5.4 5.5 5.6 5.7 5.8 5.9 5.10 5.11 5.12 5.13 5.14 5.15

5-1 5-2 5-3 5-4 5-6 5-7 5-8 5-9 5-10 5-11 5-12 5-13 5-14 5-15 5-16

....... ....

...........

.............

.............

. ... ... ... . . .

.. ,.......°,..

. . .. . . . . . .. . .°

. . .. . . . . . . . . .

.............

.............

.............

.............

.............

.............

6-1


PAGE


PAGE

7.0 TECHNICAL SPECIFICATIONS .................................................... 7-i

8.0 CONCLUSIONS ................................................................. 8-i

9.0 CONSULTANT'S REPORT ......................................................... 9-1

APPENDIX A - CHRONOLOGY .......................................................... A-i

APPENDIX B - CONSULTANT'S REPORT ................................................. B-i

1.0 INTRODUCTION

Following a fire at the Browns Ferry Nuclear Station in March 1975, the Nuclear Regulatory Commission initiated an evaluation of the need for improving the fire protection programs at all licensed nuclear power plants. As part of this continuing evaluation the NRC, in February 1976, published a report by a special review group entitled, "Recommendations Related to Browns Ferry Fire," NUREG-0050. This report recommended that improvements in the areas of fire prevention and fire control be made in most existing facilities and that consideration be given to design features that would increase the ability of nuclear facilities to withstand fires without the loss of important functions. To implement the report's recommendations, the NRC initiated a program for reevaluation of the fire protection programs at all licensed nuclear power stations and for a comprehensive review of all new licensee applications.

The NRC issued new guidelines for fire protection programs in nuclear power plants which reflect the recommendations in NUREG-0050. These guidelines are contained in the following documents:

"Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," NUREG-75/087, Section 9.5.1, "Fire Protection," May 1976, which includes "Guidelines for Fire Protection for Nuclear Power Plants," (BTP APCSB 9.5-1), May 1, 1976.

.o "Guidelines for Fire Protection for Nuclear Power Plants" (Appendix A to BTP APCSB 9.5-1), August 23, 1976.

"Supplementary Guidance on Information Needed for Fire Protection Program Evaluation," September 30, 1976.

"Sample Technical Specifications," May 12, 1977.

"Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance," June 14, 1977.

All licensees were requested to: (1) compare their fire protection programs with the new guidelines; and (2) analyze the consequences of a postulated fire in each plant area.

We have reviewed the licensee's analyses and have visited the plant to examine the relationship of safety-related components, systems and structures with both combustibles and the associated fire detection and suppression systems. Our review was based on the fire protection review team's site visit of October 3-7, 1977 and the licensee's proposed program for fire protection as described in the following docketed information:

1-1

(1) The Oconee Final Safety Analysis Report;

(2) "Fire Hazards Analysis and Response to BTP 9.5-1" dated December 31, 1976;

(3) The licensee's responses to requests for additional information and staff positions, dated March 1, July 18, November 22 and December 15, 1977, January 16 and 25, February 1, 19 and 22, May 9, June 19 and July 19, 1978.

Our review has been limited to the aspects of fire protection related to the protection of the public from the standpoint of radiological health and safety. We have not considered aspects of fire protection associated with life safety of onsite personnel and with property protection, unless they impact the health and safety of the public due to the release of radioactive material.

The licensee's approach to fire protection for this plant is different from methods used by other licensees to meet the staff BTP or objectives outlined in Section 2.2 of this report. The difference is that the licensee has proposed to install a dedicated shutdown system which will enable the plant to be shut down even if other systems are adversely affected. For this reason, the staff has not required as heavy a reliance on the ability to promptly detect or suppress fires as we have requested in other plants. This option is addressed in BTP 9.5-1 as an acceptable alternative to meeting the specific fire protection measures prescribed by BTP 9.5-1. In other plants, the plant can be brought to safe shutdown but an independent system has not been proposed. Therefore, the ability to detect and suppress a fire has greater significance than in this case where we have the dedicated shutdown system.

This report summarizes the results of our evaluation of the fire protection program at Duke Power Company's Oconee Nuclear Station, Units 1, 2 and 3. The chronology of our evaluation is summarized in Appendix A of this report.

1-2

2.0 FIRE PROTECTION GUIDELINES

2.1 General Design Criterion 3 - "Fire Protection"

The Commission's basic criterion for fire protection is set forth in General Design Criterion 3, Appendix A to 10 CFR Part 50, which states:

"Structures, systems and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions.

"Noncombustible and heat resistant materials shall be used wherever practical throughout the unit, particularly in locations such as the containment and the control room.

"Fire detection and protection systems of appropriate capacity and capability shall be provided and designed to minimize the adverse effects of fires on structures, systems and components important to safety.

"Fire fighting systems shall be designed to assure that their rupture or inadvertent operation does not significantly impair the safety capability of these structures, systems and components."

2.2 Supplementary Guidance

Guidance on the implementation of GDC 3 for existing nuclear power plants has been provided by the NRC staff in "Appendix A" of Branch Technical Position 9.5-1, "Guidelines for Fire Protection for Nuclear Power Plants."

Appendix A provides for a comprehensive program assuring a substantial level of fire protection, beyond minimums that might be deemed to satisfy GDC-3.

The overall objectives of the fire protection program embodied in BTP 9.5-1 and Appendix A, are to:

(1) reduce the likelihood of occurrence of fires;

(2) promptly detect and extinguish fires if they occur;

(3) maintain the capability to safely shut down the plant if fires occur; and

(4) prevent the release of a significant amount of radioactive materials if fires occur.

2-1

We have used the guidance of Appendix A as appropriate in our review. We have evaluated alternatives proposed by the licensee to various specific aspects of Appendix A using the overall objectives outlined above to assure that these objectives are met for the actual relationship of combustibles, safety-related equipment and fire protection features of the facility.

2-2

3.0 SUMMARY OF MODIFICATIONS

3.1 Modifications

The licensee plans to make certain plant modifications to improve the fire protection program as a result of both his and the staff's evaluations. Such proposed modifications are summarized below. The sections of this report which discuss the modifications are noted in parentheses following each item. Further detail is contained in the licensee submittals. All modifications will be completed in accordance with the scheduled dates given in Table 3.1. Certain items listed below are marked with an asterisk to indicate that the NRC staff will require additional information in the form of design details to assure that the design is acceptable prior to actual implementation of these modifications. The balance of the other modifications have been described in an acceptable level of detail.

3.1.1 Smoke Detectors

Smoke detectors will be installed in the high pressure and low pressure injection pump areas (5.6); nonsafety-related laboratories, work rooms, and storage areas (5.3), (5.4), (5.5); Unit 3 battery room (5.8); electrical maintenance kitchen and computer rooms near the control room (5.2); below the ceiling panels and in cabinets and consoles in the control room (5.2); and in other areas of the plant so that detectors are located in all safe shutdown equipment areas.

3.1.2 Fire Header Piping

A connection between the hose station header at elevation 771 feet and the

hose station header at elevation 783 feet will be provided (5.5).

3.1.3 Fire Barrier Penetrations

Openings in fire barriers will be upgraded to the rating of the fire barrier in the equipment rooms (5.4) and cable spreading rooms (5.7).

Fire doors will be provided for doorways into the HVAC rooms from the cable

spreading rooms (5.7) and the equipment rooms (5.4).

Double leafed fire doors will be modified such that only one door may be normally opened. Similarly, double glass doors between the turbine building and auxiliary building will be modified so that only one door may be normally opened (4.9.2).

Unlabeled doors and frames are being replaced with labeled fire doors and frames, with the exception of the blast doors to the east penetration room and an instrument room door in the turbine building (4.9.2). Fire dampers are being located in ventilation duct penetrations of fire barriers (4.9.2).

3-1

TABLE 3.1

IMPLEMENTATION DATES FOR PROPOSED MODIFICATIONS

ITEM

3.1.1 Smoke Detectors

3.1.2 Fire Header Piping

3.1.3

3.1.4

3.1.5

3.1.6

3.1.7

3.1.8

3.1.9

3.1.10

3.1.11

.1.12

Fire Barrier Penetrations

Portable Handlight

Water Flow Alarms

Hose Stations

Propane Tanks

Portable Extinguishers

Portable Smoke Exhausters

Emergency Breathing Air Supply

Fire Hose Nozzles

Oil Collection System

3.1.13 Cable Penetration Fire Stop

3.1.14 Dedicated Safety Shutdown Facility

3.1.15 Administrative controls (except for Fire Fighting Procedures)

Fire Fighting Procedures

3.1.16 Fixed Suppression Systems

3.1.17

3.1.18

Interim Measures

Reactor Building Communications

DATE

**End of 2nd refueling outage for each unit.

**End of 2nd refueling outage for items inside containment for each unit.

July 1, 1979 for items outside containment.

July 1, 1979.

Completed. *End of 1st refueling outage.

**End of 2nd refueling outage for items inside containment for each unit.

July 1, 1979 for items outside containment.

*End of 1st refueling outage.

Completed.

Completed. *End of 1st refueling outage.

Completed. **End of 2nd refueling outage for each

unit.

December 31, 1978.

30 months after NRC approval of concept. *End of Ist refueing outage

September 1, 1979

**End of 2nd refueling unit.

Complete.

**End of 2nd refueling unit.

outage for each

outage for each

*End of Ist refueling outage for any unit which occurs after 6 months from the date of issuance of this Safety Evaluation.

**End of 2nd refueling ouage from date of issuance of this Safety Evaluation.

3-2

3.1.4 Portable Hand Lights

Portable hand lights will be provided for fire brigade use (4.6).

3.1.5 Water Flow Alarms

The alarm system will be modified so that automatic sprinkler and deluge systems provide a water flow alarm to the control room upon system actuation (4.3.1.5).

3.1.6 Hose Stations

Additional hose stations will be provided so that all safety-related areas and large fire hazard areas in the auxiliary and turbine buildings and the Keowee hydro facility can be reached with a maximum of 100 feet of fire hose (4.3.1.4).

Hose stations connected to the low pressure service water system will be

provided inside the reactor building (5.1).

3.1.7 Propane Tanks

Propane tanks located outside of the turbine building will be anchored and provided with excess flow valves (5.13).

3.1.8 Portable Extinguisher

Portable Halon type 1211 fire extinguishers will be provided in each control room (5.2).

S3.1.9 Portable Smoke Exhausters

Portable smoke purge fans and portable ductwork will be provided (4.4.1).

3.1.10 Emergency Breathing Air Supply

Two spare air bottles and an additional air supply will be provi.ded for each air mask (4.4.3).

3.1.11 Fire Hose Nozzles

Nozzles on fire hose stations located near electrical equipment will be provided with spray stream nozzles or nozzles modified to prevent a straight stream flow (4.3.1.4).

3.1.12 Oil Collection System

The reactor coolant pump motor drain and overflow system will be modified to include housings and leak collection provisions around upper and lower bearing oil level devices and the upper bearing oil cooler (5.1).

3-3

"*3.1.13 Cable Penetration Fire Stop Test

Cable penetration fire stops will be tested to demonstrate the adequacy of the design to seal penetrations of fire barriers (4.9.1). The licensee has committed to upgrade cable penetration fire stops, where required, to designs found acceptable by testing.

"*3.1.14 Dedicated Safe Shutdown Facility

A dedicated safe shutdown facility will be installed to provide capability for continued safe shutdown of all three units independent of existing shutdown systems (4.10).

3.1.15 Administrative Controls

Administrative controls will be developed as identified in Section 6.0 of this report (6.0).

3.1.16 Fixed Suppression Systems

Each cable spreading room, equipment room and cable shaft will be provided with a manually actuated fog type open head spray system (5.4) (5.7).

3.1.17 Interim Measures

Spare dedicated cables will be provided for use with the low pressure injection pumps, low pressure service water pumps and the high pressure injection pumps (4.10).

3.1.18 Reactor Building Communications

The licensee has committed to provide an analysis to show that the existing communications system is sufficiently separated to insure that a reactor building fire will not cause loss of communications between the reactor building and control room. If the adequacy of the existing system cannot be demonstrated, modifications will be made to provide an acceptable alternative (4.7).

3-4

4.0 EVALUATION OF PLANT FEATURES

4.1 Safe Shutdown Systems

There are several arrangements of safe shutdown systems which are capable of shutting down the reactor and cooling the core during and subsequent to a fire. The exact arrangement available in a fire situation will depend upon the effects of the fire on such systems, their power supplies and control stations. To preclude a single event from affecting redundant systems, these systems are separated into two safety divisions, either of which would be capable of achieving safe shutdown.

During or subsequent to a fire, safe shutdown could be achieved using equipment such as: the reactor trip system; high pressure injection system, low pressure injection system, low pressure service water system, emergency feedwater system, pressurizer heaters, and certain instrumentation. Supporting systems and equipment such as the Keowee Hydro station for emergency A.C. power and the engineered safety features batteries would also be required. Due to separation problems in various areas, the licensee has proposed a dedicated safe shutdown system independent of the above systems which could also be used to achieve safe shutdown. This system is further discussed in Section 4.10 of this report.

We have evaluated the separation between the various systems which can be used for safe shutdown to determine that they are either adequately separated or that adequate fire-protection is provided such that a fire will not cause the loss of capability to perform the safe shutdown function. The adequacy of separation of safe shutdown equipment is discussed in other sections of this report.

4.2 Fire Detection and Signaling Systems

The plant has a protective signaling system which transmits alarms from fire detectors and water spray system actuation to the control room. Water flow on wet pipe sprinkler systems does not alarm in the control room. In general, the system complies with those provisions of NFPA 72D which are considered essential for the facility, including requirements for emergency power supply and circuit supervision. There is no distinct audible fire alarm signal provided in the control room.

The licensee has proposed to provide water flow alarms in the control room for all wet pipe sprinkler systems, and a unique audible signal in the control room for fire alarm notification of the operators.

Smoke detectors in some areas of the plant containing electrical cable insulation are located lower than ceiling level and, therefore, may not respond as rapidly as they would if located at the ceiling. However, since fires in cable insulation generate heavy quantities of smoke, reasonably prompt detection can be expected. Ionization type smoke

4-1

detectors are used throughout the plant. In some tests, ionization type detectors have not responded as rapidly to fire involving PVC as they do to fire involving other types of combustibles. Tests have shown that they are, however, adequate to detect first in their early stages. To assure that fires in safe shutdown areas of the plant are detected, the licensee has proposed, in addition to the existing detection system, to provide detectors in all areas containing safe shutdown equipment and combustibles. In addition, the licensee has proposed to provide a dedicated safe shutdown system which would be unaffected by fires involving existing equipment such that the plant can be safety shut down in the event of a fire in any location of the plant.

We find that, subject to implementation of the proposed modifications, the fire detection and signaling system in conjunction with the safe shutdown system satisfies the objectives of Section 2.2 of this report and is, therefore, acceptable.

4.3 Fire Control Systems 4.3.1 Water Systems 4.3.1.1 Water Supply

The fire protection water supply is provided by the high-pressure service water (HPSW) pumps which take suction from separate circulating cooling water (CCW) system headers. The CCW system is supplied from Lake Keowee by pumps at the intake structure; the lake water would still be available on loss of power to the intake pumps because the system can be operated as a siphon. The lake water supply has over 390,000 acre-feet of water available.

In addition to the HPSW pumps, a 100,000 gallon elevated storage tank floats on the HPSW system providing a backup fire protection water supply.

The HPSW pumps are located in the turbine building, each in a small masonry room enclosing the pump and motor. The power supply to each pump extends from the blockhouse via cables which are embedded in the turbine building floor. The suction and discharge piping and valving for the pumps are inside the turbine building and could be exposed to damage by a major fire in this structure. However, oil hazards in this area are provided with automatic water suppression systems to protect against fires in these hazards. In addition, the licensee has proposed to provide a dedicated safe shutdown system which will be unaffected by a turbine building fire and from which safe shutdown of the plant can be accomplished (see Section 4.10).

We find that the basic water supply system satisfies the provisions of Appendix A to BTP 9.5-1 and is, therefore, acceptable.

4.3.1.2 Fire Pu-:

hea-e tw. KCCO gpm HPSW pumps and one 500 gpm jockey pump, all rated at "' .n .'L-wsure. The two large pumps are considered redundant, e A, a - . c suP1pying the largest design fire flows plus other

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simultaneous demands on the HPSW system. The pumps are electric motor driven, receiving power from separate Unit No. 1 buses. These buses are interconnected to the other two units and are also connected to the Keowee hydro- station.

The HPSW pumps are operated automatically, based on the water level maintained in the elevated storage tank. The pumps can also be started manually from the control room or at the pump switchgear located in the blockhouse.

We find that the fire pumps meet the objectives outlined in Section 2.2 of this report and are, therefore, acceptable.

4.3.1.3 Fire Water Piping System

Each HPSW pump has a separate discharge line into the HPSW system. Valving is arranged so that a single break in the discharge piping will not remove both pumps from service.

All yard fire hydrants, fixed water suppression systems, and interior hose lines are supplied by the HPSW system through underground yard mains and headers inside buildings. Sectionalizing valves are provided to allow isolation of various sections of the system for maintenance; however, there are locations in the turbine building where a single piping break could affect both automatic water suppression systems and manual hose stations protecting the same area. The licensee has proposed to cross-connect the ends of two auxiliary building headers to provide dual feed for hose stations in this area.

The licensee has proposed to establish a program to seal and lock required fire protection control valves in the open position, and verify that the valves remain open with periodic inspections.

Yard fire hydrants have been provided at approximately 300 ft. intervals around the exterior of the plant. Auxiliary gate valves are not provided on the hydrant laterals, with the result that a portion of the fire water headers would have to be removed from service if a fire hydrant has to be isolated for maintenance.

Hose houses have been provided at seven of the yard hydrants, each equipped with at least 200 ft. of 2-1/2 inch hose, 200 ft. of 1-1/2 inch hose and other manual fire fighting tools.

Upon completion of the dedicated safe shutdown system, a major fire in the turbine building would not prevent safe shutdown of the three units. We conclude that, upon implementation of the modifications described above, the fire water piping system meets the objectives contained in Section 2.2 of this report and is, therefore, acceptable.

4.3.1.4 Interior Hose Stations

Interior hose stations equipped with 1-1/2 inch fire hose have been provided throughout the plant except in containment. Some areas are too far away from a hose station for effective fire fighting. The licensee has proposed

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to provide additional hose stations so that all areas containing or exposing safety-related systems will be within effective fire fighting range of at least one hose station using not more than 100 ft. of 1-1/2 inch fire hose, and to provide hose stations inside containment supplied by the LPSW system.

The nozzles on the interior hose lines are of several types. The licensee has proposed to provide nozzles capable of only a spray pattern for hose stations near electrical equipment.

Upon completion of the proposed modifications, we find that the interior hose stations meet the requirements of Appendix A of BTP 9.5-1 and are, therefore, acceptable.

4.3.1.5 Automatic Sprinkler Systems

Wet pipe automatic sprinklers provide area coverage over those portions of the turbine building basement and mezzanine levels which contain the turbine oil piping systems.

Automatic water spray systems are installed on the turbine oil headers and reservoirs, feed water pumps, and hydrogen seal oil units in the turbine building; and on oil-filled transformers and reactors in the yard area. The water spray systems are actuated by pilot-head type detection systems.

Sprinkler and water spray systems are designed according to applicable NFPA Standards.

We find that the sprinkler systems meet the requirements of Appendix A of BTP 9.5-1 and are, therefore, acceptable.

4.3.1.6 Foam

The plant has no fire fighting foam equipment or systems. Adequate suppression capability is provided by other means as described in other sections of this report. Use of foam is not required by Appendix A of BTP 9.5-1.

4.3.1.7 Effects of Suppression Systems on Safety Systems

In areas protected by sprinklers and water spray systems, floor drains have been sized to remove fire protection water. In most other areas, water should drain outdoors or through grating to lower elevations so that standing water should not affect safety-related equipment. In addition, valves are available to isolate sections of the fire water piping inside buildings to preclude the buildup of water and thus prevent equipment from being incapacitated due to flooding.

The effects of water spraying from suppression system discharge or pipe breaks has been analyzed by the licensee and reviewed by the staff and it has been determined that it will have no adverse effect on safety-related equipment.

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We conclude that the potential for actuation or failure of fire protection systems to prevent safe shutdown is minimal and meets the objectives of Section 2.2 of this report and is, therefore, acceptable.

'4.3.2 Gas Fire Suppression Systems

This plant has no gas fire suppression systems. Adequate suppression capability is provided by other means as described in other sections of this report. Use of gas fire suppression systems is not required by Appendix A of BTP 9.5-1.

4.3.3 Portable Fire Extinguishers

Portable fire extinguishers have been distributed throughout the plant in accordance with NFPA guidelines. The licensee has proposed to provide Halon 1211 extinguishers in the control room.

Upon implementation of this modification, we find the portable fire extinguishers will conform to the provisions of Appendix A of BTP 9.5-1, and accordingly is acceptable.

4.4 Ventilation Systems and Breathing Equipment 4.4.1 Smoke Removal

The plant does not have fixed exhaust systems designed specifically for smoke removal. The normal air handling systems in most areas might be used for smoke removal; however, their effectiveness will be limited by several factors. The capacity and configuration of the normal air handling systems may be unsuitable for effective smoke removal. The fans and other equipment in the air handling systems are not designed to withstand high temperatures, and can be rendered inoperative by the heat from a significant fire. Heat-operated dampers in fire barriers may close automatically, precluding smoke removal.

The equipment rooms, cable spreading rooms and Unit No. 3 control room have exhaust fans that could be used to remove smoke from these areas. However, the fans discharge into other building areas rather than directly outside, and as a result the smoke could be spread to areas providing access for fire fighting. For this reason, as well as those cited previously, the effectiveness of these exhaust fans for smoke removal is very limited. To aid in manual smoke removal, the licensee has proposed to provide portable smoke ejectors and portable ductwork of a type used in public fire fighting and which we find acceptable for nuclear power facilities.

Upon completion of this modification, we find that smoke removal capability satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

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4.4.2 Filters

No fire detection or automatic fire suppression is provided on the charcoal filters. Filters have been provided with instrumentation and control room alarms to detect loss of cooling air flow, and adequate time is available after loss of air flow to take corrective action. The filter units are enclosed in substantial metal housing and thus do not present a significant fire exposure to safety-related equipment. In addition, with the provision of the dedicated safe shutdown system, a fire in a charcoal filter would not prevent safe shutdown of the reactors. We conclude that the objectives identified in Section 2.2 of this area are met and the installation is, therefore, acceptable.

4.4.3 Breathing Equipment

Six self-contained breathing appliances have been provided, along with a cascade system to replenish empty air bottles. The licensee has proposed to provide sufficient air masks for fire brigade personnel and operators along with two spare air bottles for each mask and a 6-hour air bottle refill capability.

We find that, subject to implementation of the described modification, the portable breathing equipment conforms to the provisions of Appendix A of BTP 9.5-1 and is, therefore, acceptable.

4.5 Floor Drains

Floor drains are provided in areas protected by fixed water suppression systems. There are no devices in the turbine building drain system to prevent fires involving flammable liquids from spreading via the drain system. However, the oil hazards at the lower levels of the turbine building are provided with automatic suppression systems and the likelihood of any flashback through the drains causing fire in other areas is remote. In addition, with the provision of the dedicated safe shutdown system, the complete loss of the turbine building could be sustained without the loss of safe shutdown capability. We therefore find that modifications to the turbine building drain system are unnecessary and that adequate protection against deleterious effects due to the drain system is provided. Therefore, we find that the floor drain system meets the objectives of Section 2.2 of this report and is, therefore, acceptable.

4.6 Lighting Systems

In addition to the normal AC lighting, there are separate DC and AC emergency lighting systems provided in certain areas of the plant. An analysis by the licensee indicates that a fire would not cause loss of both normal and emergency lighting in areas providing access to fight fires in safetyrelated areas. We have reviewed this analysis and agree with its conclusions.

In addition, the licensee has proposed to provide additional portable hand lights for fire brigade personnel.

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We find that, subject to implementation of the above described modification, the lighting conforms to the provisions of Appendix A of BTP 9.5-1 and is, therefore, acceptable.

S 4.7 Communication Systems

Normal communications within the plant are provided by a telephone and paging system. An additional communication method is provided by a soundpowered phone system with jacks at various key locations throughout the plant. These wired systems may be damaged in a fire. However, portable radios are available at the control room and security office for use by fire brigade personnel. These may be used in all areas of the plant with the exception of the reactor building. The licensee has proposed to provide an analysis to show that the existing communications system is sufficiently separated to insure that a reactor building fire will not cause loss of communications between the reactor building and control room. If the adequacy of the existing system cannot be demonstrated, modifications will be made to provide an acceptable alternative.

We find that, subject to implementation of either of the above described actions, the communications systems conform to the provisions of Appendix A to BTP 9.5-1 and are, therefore, acceptable.

4.8 Electrical Cable Combustibility

The cable insulation used in the plant consists of armored ethylene propylene rubber (EPR) of 5-8 KV cables with a polyvinyl chloride (PVC) jacket, armored EPR with hypalon or neoprene jacket for control cables, and armored PVC insulation with PVC jacket outside containment and armored EPR with hypalon jacket, some with a PVC jacket overall, for inside containment. The majority of cables in Oconee are of the metallic armored type. The IEEE 383 standard was not in effect at the time the plant was constructed and therefore the cables were not required to meet IEEE 383. The licensee has stated, however, that the same cable construction has since been used at a later plant where the IEEE 383-1971 criteria were imposed and the cable was acceptable. We find that retest to the IEEE 383 procedures and criteria is unnecessary and would not provide information that would alter our recommendations or conclusions. Accordingly, we find the electrical cables used at the Oconee Nuclear Station acceptable.

4.9 Fire Barrier Penetrations

Fire barriers are penetrated by doorways, ventilation ducts, electrical cables, conduit and piping. The means of preventing a fire from crossing a fire barrier through these various penetrations is discussed below.

4.9.1 Electrical Cable, Conduit and Piping Penetrations

Seals using cementitious plaster, which have a minimum thickness of 4 inches, have been installed at locations where electrical cable trays and conduit pass through fire barriers. Some of the seals have been constructed with a "Armaflex" sheet insulation on the outside surface; others use a polyester

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board. Certain piping penetrations are sealed with the "Armaflex" sheet insulation only. The seal designs have not been subjected to tests to establish their fire resistant characteristics. The licensee has proposed to test the electrical cable penetration fire stop design and submit the results of the tests conducted according to the NRC modified ASTM E-119 test. The licensee has committed to upgrade cable penetration fire stops, where required, to designs found acceptable by testing. Piping penetration seals in required fire barriers that are sealed with the Armaflex sheet insulation are sufficiently remote (50 feet) from safe shutdown cables that a fire at the penetration would not affect the safe shutdown cables. Additionally, the proposed dedicated safe shutdown system described in Section 4.10 will be independent of these areas.

The licensee has proposed to properly seal the flexible conduit penetrations in the floor between the cable spreading room and the control room, and around the bus duct in the wall between the blockhouse transformer and switchgear rooms.

We find that upon implementation of the above described modifications and successful performance of the proposed tests, cable, conduit, and piping penetrations will satisfy the objectives of Section 2.2 of this report and is, therefore, acceptable.

4.9.2 Fire Doors and Hatches

The licensee has proposed to make the following modifications on doors and hatches in fire barriers:

(1) Replace unlabeled fire doors and frames in fire barriers with properly labeled doors and frames.

(2) Modify double-leaf fire doors to normally keep one door closed to assure proper closure.

(3) Modify the door arrangement of openings between the turbine building and auxiliary building to prevent glass doors from obstructing automatic fire door closure.

(4) Upgrade metal hatch plates in the floor between the cable spreading room and the control room to provide a 3-hour fire rated barrier.

The licensee has stated that doors separating redundant safe shutdown equipment or protecting safe shutdown equipment from large hazards are alarmed to the control room and provided with automatic closure devices.

Upon completion of these modifications, the doorway and hatch penetrations of fire barriers will conform to the provisions of Appendix A to BTP 9.5-1 and are, therefore, acceptable.

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4.9.3 Ventilation Duct Penetrations

Fire dampers have been provided at some locations where ventilation ducts penetrate fire barriers. The licensee has proposed to upgrade ventilation duct penetrations with dampers having fire ratings equivalent to that required of fire barriers.

We find that, subject to implementation of the above modifications, ventilation duct penetrations will satisfy the objectives identified in Section 2.2 of this report and are, therefore, acceptable.

4.10 Separation of Equipment; Safe Shutdown System

The licensee has stated in the FSAR that electrical equipment and cable separation is in accordance with the following criteria:

(1) Auxiliary transformers, startup transformers, and the 100 kV transformer are located out of doors and physically separated from each other. The 13.8 kV transformer CT4, fed from the on-site Keowee Hydro Station is physically separated from the other transformers and located in a Class I enclosure.

(2) The 6900 volt switchgear, 4160 volt switchgear, and 600 volt load center are located in areas to minimize exposure to mechanical, fire, and water damage. This equipment is coordinated electrically to permit safe operation of the equipment under normal and short circuit conditions. Metal clad construction is used throughout for personnel and equipment protection.

(3) The 4160 volt main feeder buses, switchgear sections, and standby power buses switchgear sections are located in a Class I enclosure. The redundant engineered safeguards 4160 volt switchgear bus sections and their associated 600 volt switchgear bus sections, motor control centers, etc. are located within the turbine building and auxiliary building below the operating floor level. They are located in areas with separation and protection to minimize exposure to mechanical, fire, and water damage. This equipment is coordinated electrically to permit safe operation under normal and short circuit conditions. The engineered safeguards system is of Class I seismic design.

(4) The 600 volt motor control centers are located in the areas of electrical load concentration. Those associated with the turbinegenerator auxiliary system in general are located below the turbinegenerator operating flood level. Those associated with the nuclear steam supply system are located in the auxiliary building. Motor control centers are located in areas with separation and protection to minimize their exposure to mechanical, fire, and water damage.

(5) The 125 volt DC instrumentation and control power system batteries are physically separated in separate enclosures to minimize their exposure to any damage. The battery chargers and associated DC bus sections and switchgear are located in three separate rooms in the

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auxiliary building and physical separation is maintained between redundant equipment.

(6) Metal-enclosed buses are used for all major bus runs where large blocks of current are to be carried. They are also routed to minimize exposure to mechanical, fire, and water damage.

(7) Early cable tray requirements were based on types of cable which had been used in the past which were primarily not armored. Armored cable was used at Oconee to achieve better mechanical protection and fire retardance. This caused the trays to fill faster than anticipated and in several locations the fill became excessive. Steps have also been taken to insure that no additional cables are routed through trays which are already overfilled.

(8) Where overfill situations exist in Unit 1 between vertically adjacent cable trays to the extent that the top cable in the lower tray is within three (3) inches of the bottom cable in the tray immediately above, a 1/8" fire retardant fiberglass reinforced polyester barrier will be placed between the trays. These barriers will be attached to the bottom of the upper tray and fitted around cables which may pass through the barrier.

(9) The criteria for routing cables requires that mutually redundant safety-related cables be run in separate trays. Trays are spaced vertically in the cable room a minimum of 10 inches apart and in some cases redundant cables are in vertically adjacent trays. It should be pointed out that the cable armors used provide excellent mechanical and fire protection which would not be provided with conventional, unarmored cable systems. An early warning fire detection system has also been provided in this area.

(10) Control, instrumentation, and power cables are applied and routed to minimize their vulnerability to damage from any source. All cables are selected using conservative margins with respect to their current carrying capacities, insulation properties, and mechanical construction. Cable insulations in the Reactor Building are selected to minimize the effects of radiation, heat, and humidity. Appropriate instrumentation cables are shielded to minimize induced voltage and magnetic interference. Wire and cables related to engineered safeguards and reactor protective systems are routed and installed to maintain the integrity of their respective redundant channels and protect them from physical damage. Power and control cables for redundant auxiliaries or services are run by different routes to reduce any probability of an accident disabling more than one piece of redundant equipment. Floor sleeves will be filled with a fire retardant material.

Throughout most of the plant there is good separation between redundant divisions such that a fire would not cause loss of redundant safe shutdown equipment. During the site visit, it was determined that in a number of locations, redundant safe shutdown cables could be jeopardized due to a

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lack of sufficient separation. The separation criteria used in the installation did not preclude the routing of redundant cables vertically over one another in adjacent trays. In view of this situation, the licensee has proposed to provide a separate and independent capability to safely shut down the units from a location isolated from existing systems such that a fire will not cause the loss of safe shutdown capability. The proposed capability will not be dependent upon existing AC or DC power supplies, but will have its own diesel generator and battery power sources. The control station, diesel generator and battery will be located in a separate building to be built for this system. As a result of this commitment, we find that the provision of additional separation or barriers is not required between existing systems. We find that the proposed safe shutdown facility is acceptable from the standpoint of fire protection. Our approval here does not include acceptance for either flooding of the turbine building or security aspects which will be addressed separately. Included as part of the modificatons listed in Section 3.1 of this report, the licensee has proposed to implement the following interim measures until the safe shutdown facility is completed.

(1) Provide a dedicated cable for the low pressure injection pumps (necessary for cold shutdown) in the event of fire damage to these cables.

(2) Provide a dedicated cable for the low pressure service water pumps (necessary for cold shutdown) in the event of fire damage to these cables.

(3) Provide a dedicated cable for the high pressure injection pumps (may be necessary for hot shutdown) in the event of fire damage to these cables.

Items 1 and 2 will continue in force after the safe shutdown facility is completed. Each of the safety-related areas is discussed i'n more detail in Section 5.0 of this report.

Subject to implementation of the modifications described above, separation of equipment will be sufficient to meet the objectives of Section 2.2 of this report.

4.11 Fire Barriers

Fire barriers have been provided to separate the turbine building from the auxiliary building, and to cut off the equipment rooms, cable spreading rooms, control rooms, penetration areas and blockhouses from surrounding areas. Based on the type and quantity of combustibles present, the basic fire resistance of the barriers would prevent the spread of fire between fire areas.

Upon completion of the dedicated safe shutdown system, the facility will be able to sustain a fire in any fire area and still achieve safe shutdown of the three units. We conclude that, upon completion of the dedicated shutdown system, the fire barriers meet the objectives of Section 2.2 of this report and are, therefore, acceptable.

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4.12 Access and Egress

Most safety-related areas are reasonably accessible for manual fire fighting. However, the cable spreading room can only be reached by stairwells from adjacent floors, presenting access difficulty in fighting a hot, smokey fire. Such situations are not likely to develop due to installed smoke detection capability to detect fires in their early stages when smoke and heat would not be a problem. Should a larger fire occur, manual fire fighting techniques would have to be employed, such as cooling the area with water sprayed from hoses, utilizing portable smoke removal equipment and self contained breathing apparatus to facilitate access. In view of this capability we find that additional entrances to the room are not required, and existing access and egress capability is acceptable.

4.13 Toxic and Corrosive Combustion Products

The products of combustion of many polymers are toxic to humans and corrosive to metals. Fire detection and extinguishment is relied upon to reduce the generation of such products. Additionally, proposals have been made for portable smoke removal equipment and training of the fire brigade in the use of this equipment and in the use of emergency breathing appliances. We find that, subject to implementation of the proposed modifications described in this report, the measures taken to control toxic and corrosive combustion products satisfy the objectives in Section 2.2 of this report and are, therefore, acceptable.

4.14 Nonsafety-Related Areas

We have evaluated the separation by distance or by fire barriers of safe shutdown systems from nonsafety-related areas to determine that fires in such areas will not adversely affect the ability to safely shut down the plant. Nonsafety-related areas which potentially pose a fire hazard to safe shutdown equipment are addressed in Section 5.0 of this report.

The licensee has evaluated the effects of fires in radwaste areas as to the potential releases to the environment. We have reviewed the licensee's evaluation and find that the releases resulting from fire in these areas are acceptably low.

On this basis we find the fire protection provided for radwaste areas

acceptable.

4.15 Instrument Air

Loss of function of the instrument air system will not prevent safe shutdown of the plant.

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5.0 EVALUATION OF SPECIFIC PLANT AREAS

The licensee has performed a fire hazards analysis of the facility to determine the fire loading of various plant areas, to identify the consequences of fires in safety-related and adjoining nonsafety-related areas, and to evaluate the adequacy of existing and proposed fire protection systems. The results of the fire hazards analysis, other docketed information and site visit observations were used in the staff's evaluation of specific plant areas. The staff's evaluation of specific areas is discussed in the following sections.

5.1 Reactor Building 5.1.1 Safety-Related Equipment

Safety-related equipment includes: primary coolant piping, reactor vessel, instrumentation, containment air coolers, valves, and related cabling.

5.1.2 Combustibles

Significant combustibles in the reactor building include a small quantity of electrical cable jacketing, and approximately 240 gallons of lube oil in each of four reactor coolant pump motors. Most of the cables are metal armored cables that do not have exposed plastic insulation or covering.

5.1.3 Consequences if no Fire Suppression

An unmitigated fire involving oil from a reactor coolant pump would probably result in damage to one pump. Experience with an actual reactor coolant pump fire at this facility which consumed all the lube oil in one pump indicates that a lube oil fire would probably not affect the ability of systems to function which would be required to achieve safe shutdown.

Fires in those few cables that have exposed plastic PVC jackets may affect redundant cables required for safe shutdown due to minimal physical separation in some areas.

5.1.4 Fire Protection Systems

An oil collection system is provided for the reactor coolant pump lube oil system and around the lift pump. However, leaks in parts of the lube oil system are not protected against by the present oil collection system.

Fire detection devices are provided above the penetrations, above the reactor coolant pumps, and near air flow streams for the reactor building cooling units.

Portable extinguishers are provided within the reactor building.

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5.1.5 Adequacy of Fire Protection

The oil collection system would not be adequate to collect certain oil spills which may occur.

Portable extinguishers would not be adequate to suppress lube oil fires or those fires which occur in electrical cable jacketing.

5.1.6 Modifications and Recommendations

The licensee has proposed to: (1) extend the coverage of the oil collection system to include housings and leak collection provisions around the upper and lower bearing oil level indicator devices and the upper bearing oil cooler; (2) provide manual hose stations inside of the reactor building; (3) provide a dedicated safe-shutdown system that is independent of existing systems (see Section 4.10); and (4) implement interim measures as identified in Section 4.10 of this report.

We find that, subject to implementation of the above described modifications and interim measures, fire protection for the reactor building conforms to the provisions of Appendix A to BTP 9.5-1 and is, therefore, acceptable.

5.2 Control Room - Auxiliary Building Elevation 822 Feet 5.2.1 Safety-Related Equipment

The facility includes two control rooms: one for Units 1 and 2, and a separate one for Unit 3. These rooms contain safety-related control cabinets and consoles, certain of which would currently be required for safe shutdown of the reactor from the control room.

5.2.2 Combustibles

The combustibles in the area consist mainly of electrical cable insulation, electrical components in panels and consoles, and a small amount of Class A combustibles such as log books, drawings, etc. The electrical cables enter through the bottom of the cabinets and consoles directly from the cable spreading room. There is a very limited amount of cabling in the cabinets. Cables from redundant divisions are kept in separate bundles and physically separated. Many of the cables have a mineral fiber jacket.

The control complex is separated from other areas by three-hour fire-rated floors, walls, and ceilings with the exception of doors leading to stairways which have 1-1/2 hour ratings. The only other area opening into this stairwell is the cable spreading room which has a three-hour fire-rated door.


Due to the rigorous separation of redundant cabling in the cabinets and the limited amount of combustibles, it is unlikely that a fire in the cabinets would cause loss of redundant safe shutdown equipment. A fire in the

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cabinets may causeloss of control of certain equi-prTent in one safety

division, and may cause generation of smoke that would impede shutdown of

the affected unit.

5.2.4 Fire Protection System

Fire detection is currently provided by detectors located above ceiling

panels. Fire suppression capability is provided by portable CO2 extinguish

ers in the room and by hose stations within reach of the area.


The detectors located above the hung ceiling would be ineffective in detecting

fires in the cabinets or in the control room area. Hose stations provide

an adequate means of suppression to promptly extinguish fires; however, the

CO extinguishers are an unacceptable means for extinguishing fires in

electrical cables or Class A combustibles. In the unlikely event that a

fire should become large, the extinguishing protection may not be adequate

to prevent involvement of redundant circuits.


The licensee has proposed to: (1) lower the smoke detectors from above the

ceiling panels to expose them to the room environment, and to place smoke

detectors in cabinets and consoles; (2) locate smoke detectors in electrical

maintenance, kitchen, and computer rooms which are adjacent to the control

room; (3) seal unprotected openings between the control room and cable

spreading room, including flexible "green-field" conduit penetrations, and

openings covered by a steel plate; (4) provide portable water or halon-1211

type extinguishers in the control room; (5) provide a dedicated safe shutdown

system independent of the control room and other areas as discussed in

Section 4.10 of this report; and (6) implement interim measures as identi

fied in Section 4.10 of this report.

We find that, subject to implementation of the above described modifica

tions and interim measures, fire protection for the control room conforms

to the provisions of Appendix A to BTP 9.5-1 and is, therefore, acceptable.

5.3 Auxiliary Building - Elevation 838 Feet 5.3.1 Safety-Related Equipment

The safety-related equipment at elevation 838 feet in the Auxiliary Building

includes the spent fuel pools and associated fuel handling equipment.

5.3.2 Combustibles

Significant combustibles include cable jacketing on a small number of power

and control cables for ventilation systems which serve the auxiliary build

ing, charcoal filters in certain ventilation systems, and combustibles

introduced during refueling operations such as plastic sheeting and protec

tive clothing.

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Consequence if no Fire Suppression

An unmitigated fire at this elevation may cause loss of nonsafety-related ventilation systems for the auxiliary building. These systems would not be required for safe shutdown.


Fire suppression capability is provided by portable extinguishers. Hose stations could reach this area only by adding extra lengths to reach from hose stations at lower elevations.


Existing fire protection would not be adequate to promptly suppress fires in this area, due to the lack of adequate hose coverage.


The licensee has proposed to provide fire detectors in storage and protective clothing areas and to add hose stations so that all areas can be reached with the 100 feet of hose located at the hose stations.

We find that, subject to implementation of the modifications detailed above, fire protection for this elevation of the auxiliary building conforms to the provisions of Appendix A to BTP 9.5-1 and is, therefore, acceptable.

5.4 Auxiliary Building - Elevation 796 Feet 5.4.1 Safety-Related Equipment

The equipment rooms for each unit are located at this elevation, which each contain redundant cabling that may be required for safe shutdown. The 480 volt switchgear for both divisions is also located in the rooms. Other areas of this elevation contain some safety-related cabling which may be required for safe shutdown but is generally well separated.

5.4.2 Combustibles

The major source of combustibles in the equipment rooms is a high concentration of cable insulation. Other areas of this elevation contain oil, clothing and cable as combustibles.

5.4.3 Consequences if no Suppression

A postulated fire in the equipment rooms may cause loss of redundant safe shutdown cables. Due to the fire rating of the enclosure of the rooms, the fire would be confined to the room. Fires in other areas of this elevation are not likely to affect redundant equipment for safe shutdown.


A large number of hand and cart-type portable extinguishers are located throughout the building at this elevation. Smoke detectors are installed

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5.3.3

in the equipment rooms. Fire hose could be provided to this area by adding extra lengths of hose to stations located at elevation 783 of the auxiliary building, or from the turbine building.

"-5.4.5 Adequacy of Fire Protection

The use of portable extinguishers is not adequate to extinguish fires in the equipment rooms due to the large concentration of combustible cable.

Since detection in other areas of this elevation is not provided, safetyrelated cables could be lost, some of which may be related to safe shutdown.

Adding extra lengths of hose to existing hose is not an adequate method of using fire hose.


The licensee proposes the following modifications for this area:

(a) Provide smoke detectors in the following areas:

(1) work areas 300, 347, 376; (2) laundry storage areas 337, 338, 339; (3) janitor/towel storage areas 313, 314, 357, 365; (4) protective clothing areas 322, 366; and (5) laboratory areas 329, 330, 333, 334, 335, 369A, B, C.

(b) Modify equipment rooms 310, 311, 354 by:

(1) closing the opening in cable shaft with fire barrier to separate from equipment room; and

(2) replacing the door to HVAC equipment room with three-hour rated door.

(c) To assure that fires at this elevation will not cause loss of safe shutdown capability, provide a dedicated safe shutdown system as discussed in Section 4.10 of this report.

(d) Provide hose stations with not greater than 100 ft. of hose to reach all safety-related areas;

(e) Smoke detectors in all safe shutdown areas containing combustibles.

(f) To provide a manually actuated open head fog-type water spray system in each equipment room.

(g) To implement interim measures as identified in Section 4.10 of this report.

We find that, subject to implementation of the above described modifications and interim measures, fire protection for this area satisfies the objectives of Section 2.2 of this report and is, therefore, acceptable.

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5.5 Auxiliary Building - Elevations 771 and 783 Feet 5.5.1 Safety-Related Equipment

Redundant safety-related cables which are required for safe shutdown pass through these elevations of the auxiliary building.

5.5.2 Combustibles

The major source of combustible is cable jacketing, with a lesser amount of oil. The fire load is generally low.


Fire in some areas may affect redundant safe shutdown cables. This is unlikely, however, due to the light fire loading in most areas.


Hand and cart type portable extinguishers are provided throughout these elevations. Smoke detectors are provided for only two rooms. Hose stations are provided in the hallways.


Fire protection for these elevations is not adequate to detect and extinguish fires and prevent involvement of redundant safety-related cables which may be required for safe shutdown. Hose stations may not be adequate to reach all safety-related areas.


The licensee has proposed the following modifications for these areas:

(a) Provide hose stations to reach all safety-related areas with not greater than 100 feet of hose.

(b) Smoke detectors will be provided in storage areas 204, 224 and 264. (Detection is sufficient since storage areas are not in vicinity of safe shutdown equipment.)

(c) Provide smoke detectors for all safe shutdown equipment areas.

(d) Provide a dedicated safe shutdown capability independent of these areas to assure safe shutdown for fires in these areas (see Section 4.10 of this report for more detail).

(e) Implement interim measures as identified in Section 4.10 of this report.

We find that, subject to implementation of the above-described modifications and interim measures, the fire protection for these areas meets the objectives of Section 2.2 of this report and is, therefore, acceptable.

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5.6' Auxiliary Building - Elevation 758 Feet 5.6.1 Safety-Related Equipment

Safety-related equipment at this elevation include three high pressure and three low pressure injection pumps for each unit, reactor building spray pumps, and associated power and control cables. For the injection pumps, one of the pumps is separated by a masonry wall partition from the other two counterpart pumps.

5.6.2 Combustibles

Significant combustibles at this elevation include lube oil for each of the safety-related pumps, as well as lube oil for various nonsafety-related pumps, and a moderate amount of electrical cable jacketing.


An unsuppressed lube oil fire may affect two of the three high pressure or low pressure injection pumps, but would not likely affect the three pumps associated with shutdown of one unit. A postulated cable fire may affect redundant divisions; but, the potential for affecting redundant safe shutdown systems is unknown since the licensee's fire hazards analysis did not address the adequacy of separation of cables required for safe shutdown.


No smoke detection devices or automatic suppression systems are provided at this elevation. Hoses can only reach the area by connecting additional hose lengths together and routing hose down the stairwell from elevation 771 feet.

"-6. 6.5 Adequacy of Fire Protection

The fire protection provided would not be adequate to promptly detect and suppress fires at this elevation, or to prevent involvement of redundant safety divisions.


The licensee has proposed to:

(1) provide smoke detectors in the high pressure and low pressure injection pump areas;

(2) add hose stations so that coverage of all safe shutdown areas is provided; and

(3) Provide a dedicated safe shutdown system independent of elevation 758 feet of the auxiliary building.

(4) Implement interim measures as identified in Section 4.10 of this report.

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We find that, subject to implementation of these proposed modifications and interim measures, fire protection for elevation 758 feet of the auxiliary building conforms to the provisions of Appendix A to BTP 9.5-1 and is, therefore, acceptable.

5.7 Cable Spreading Room •5.7.1 Safety-Related Equipment

There are three cable spreading rooms, one for each unit. Each cable spreading room contains redundant safety-related cables required for safe shutdown of one unit. Some safety-related equipment for the respective unit is also located in each of these areas.

5.7.2 Combustibles

A large quantity of cable jacketing is located in these areas. Cable trays are stacked as much as 10 deep.

5.7.3 Consequence if no Fire Suppression

An unmitigated fire in one of the cable spreading rooms could affect redundant equipment required for safe shutdown of one unit. The affected unit could be maintained in a safe condition by using equipment from the other units through piping inter-ties.


The cable spreading rooms are provided with ionization type smoke detectors. Portable extinguishers are provided within the room and outside within access. Fire hose could reach into the area from the turbine building, although additional lengths of hose may be required to reach all points.

'-J5.7.5 Adequacy of Fire Protection

The manual extinguishers are not adequate to extinguish fires in these areas. Stringing extra lengths of hose is not an adequate method of using fire hose.


The licensee has proposed to make the following modifications to the fire protection for the cable spreading rooms:

(a) Provide hose stations within access of all safety-related areas, which would include the cable spreading rooms.

(b) Close the opening in the cable shaft with a fire barrier to separate the cable spreading room from the equipment room.

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(c) To assure that fires in these areas will not cause loss of safe shutdown capability, a dedicated safe shutdown system will be provided, as discussed in Section 4.10 of this report.

(d) To provide a manually actuated open head fog-type water spray system in each cable spreading room.

(e) To implement interim measures as identified in Section 4.10 of this report.

We find that, subject to implementation of the above described modifications and interim measures, fire protection for the cable spreading rooms conforms to the provisions of Appendix A to BTP 9.5-1 and is, therefore, acceptable.

5.8 Battery Rooms 5.8.1 Safety-Related Equipment

The battery rooms, one for each unit, each contains both redundant safety

related batteries for the respective unit.

5.8.2 Combustibles

The combustibles consist of a small amount of plastic jacketing on the battery cables and the plastic battery cases. There is little possibility for a hydrogen buildup problem due to the type of battery used (Pb-Ca) which has a low generation rate. Ventilation systems are also designed to maintain the concentration at a very low level.


Loss of redundant safety-related batteries could occur for a battery room fire. This would not affect safe shutdown since the batteries from the other units are tied in to feed the loads for the affected units.


Portable extinguishers are provided to fight fires in these rooms. Smoke detectors are provided in each room.


Portable extinguishers are not adequate to extinguish fires in these rooms; however, their loss would not affect safe shutdown.


The licensee has proposed to provide hose stations to reach the battery rooms to fight fires in these areas. In addition, the dedicated safe shutdown system proposed by the licensee will have its own battery (see Section 4.10 of this report for details).

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We find that, subject to implementation of the above described modifications, the fire protection for these rooms conforms to the provisions of BTP 9.5-1, Appendix A and is, therefore, acceptable.

5.9 Penetration Areas 5.9.1 Safety-Related Equipment

For each unit, the penetration areas are located on opposite sides of the containment. Penetration areas contain safety-related cables required for safe shutdown. At least one penetration for each of the units contains redundant safe shutdown instrumentation cables.

5.9.2 Combustibles

The only combustible of any significance in the penetration areas is the cable jacketing.


An unmitigated fire in the containment penetration areas could cause loss of redundant safe shutdown instrumentation though this is unlikely due to the armor on the cable.


Portable extinguishers provide the means of suppressing fires in these areas. Detection devices are provided in each penetration area.


Due to the lack of manual hose stations, some redundant safe shutdown instrumentation may be lost due to a fire in one of the penetration areas for each unit. In the other penetration areas, at least one division of safe shutdown instrumentation could be affected by a fire.


The licensee has proposed the following modifications:

(a) Provide hose stations to reach all safe shutdown areas,

(b) Provide a dedicated safe shutdown system with separate cable routing independent of this area (see Section 4.10 of this report for more details).

(c) Implement interim measures as identified in Section 4.10 of this report.

We find that, subject to implementation of the above described modifications and interim measures, fire protection for these areas meets the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

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5.10 Turbine Building - Turbine Deck Level 5.10.1 Safety-Related Equipment

This level of the turbine building contains the remote shutdown panels for all three reactors.

5.10.2 Combustibles

The significant combustibles at this elevation are turbine oil and hydrogen. There is also combustible insulation in a limited amount of electrical equipment and on electrical cables.


A major break in the turbine oil system or a hydrogen fire/explosion could result in damage to the unprotected steel building structure and roof deck. Burning oil could flow into areas below this level which contain safetyrelated systems through numerous floor openings. Depending upon the quantity of oil released, a fire could prevent safe shutdown of all three units; however, with the completion of the dedicated safe shutdown system this potential will be eliminated.


Automatic fire detectors are provided above the bearing lift pumps and high pressure turbine bearings. There are no automatic suppression systems at this level. Manual hose stations and portable fire extinguishers are provided.

).10.5 Adequacy of Fire Protection

The existing manual fire suppression equipment used by properly trained personnel would be able to control most fires on this level before safetyrelated equipment on the lower levels is affected. Manual fire suppression may not be effective for all potential fires, depending upon the quantity of fuel involved and the nature of the fire development.


The licensee has proposed to provide a safe shutdown system independent of this area.

In addition to these proposed modifications, the licensee has proposed to implement interim measures as identified in Section 4.10 of this report.

We find that, subject to implementation of this modification and interim measures, the fire protection for this area satisfies the objectives in Section 2.2 of this report and is, therefore, acceptable.

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5.1.1 Turbine Building - Mezzanine Level 5.11.1 Safety-Related Equipment

This level of the turbine building contains the 4160 volt bus ducts feeding the 4160 volt engineered safety features switchgear (ESF) and the 4160 volt ESF switchgear. This equipment is required for safe shutdown.

5.11,2 Combustibles

The major sources of combustibles at this elevation are the electrical cable jacketing and turbine lube oil in tanks and piping. Cables are in open trays stacked 6 to 8 high.


An unsuppressed cable or lube oil fire at the mezzanine level may cause loss of redundant cables required for safe shutdown of the plant due to a fire impact on the redundant electrical equipment.


The turbine lube oil tanks and the oil distribution system are protected by deluge systems actuated by smoke detectors.

The protection for cables is provided by portable extinguishers, hose stations and detection devices.


The protection is adequate to extinguish oil fires but may not be adequate to prevent spread of fire between redundant divisions due to interposing combustible paths (cable jacketing) between divisions.


The licensee has proposed to provide smoke detectors to detect fires in the area of safe shutdown cables. In addition, a dedicated safe shutdown capability will be provided completely independent of cables or equipment located in the turbine building from which all three units can be safely shut down (see Section 4.10 for more detail). Interim measures will also be taken until the dedicated shutdown system is operational.

We find that, upon implementation of the above described modifications and interim measures, fire protection for the turbine building-mezzanine level conforms to the provisions of Appendix A to BTP 9.5-1 and is, therefore, acceptable.

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5.12 Turbine Building - Basement Level 5.12.1 Safety-Related Equipment

Safety-related equipment at this level consists of the auxiliary feedwater and low pressure service water pumps for each unit as well as associated valves, piping, and power and control cables.

In addition the redundant high pressure service water pumps are located at this elevation of the turbine building with each in a separate enclosure.

5.12.2 Combustibles

Significant combustibles include: a moderate amount of electrical cable jacketing; turbine lube oil transfer tank and piping; the auxiliary boiler and its fuel oil; and lube oil for main feedwater pumps.


An unsuppressed lube oil or cable fire may cause loss of safe shutdown capability due to loss of redundant auxiliary feedwater systems or redundant low pressure service water pumps.


Fire protection at this elevation of the turbine building includes the following:

(1) Detection devices which alarm in the control room;

(2) Automatic water spray protection on the auxiliary feedwater pumps and hydrogen seal oil unit;

(3) Automatic sprinkler coverage of major lube oil hazards;

(4) Guard piping over lube oil piping;

(5) Hose stations within reach of all large hazards and safety-related equipment;

(6) Portable fire extinguishers.


The protection provided would be adequate to suppress lube oil fires, but may not be adequate to protect redundant electrical cabling from oil hazards or cable fires. The licensee's fire hazards analysis did not evaluate the adequacy of cable separation for redundant safe shutdown systems.


The licensee has proposed to provide a dedicated safe shutdown system independent of the turbine building for each unit. These systems would

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be capable of safely shutting down the plant, as further discussed in Section 4.10 of this report. In addition, the licensee has proposed to implement certain interim measures as identified in Section 4.10 of this report.

We find that, subject to implementation of the above described modification and interim measures, fire protection for the turbine building basement level conforms to the provisions of Appendix A to BTP 9.5-1 and is, therefore, acceptable.

5.13 Yard Area 5.13.1 Safety-Related Equipment

The yard area contains the condensate storage tanks, and the transformers

and buses associated with the AC power supply system.

5.13.2 Combustibles

The combustibles which were considered for their potential exposure to safety-related systems are several oil-filled transformers and reactors, and portable propane tanks adjacent to the turbine building for igniting the auxiliary boiler. There are no significant combustibles exposing the condensate storage tanks.


In general, safety-related equipment is adequately separated from fire hazards in the yard area by distance and/or substantial fire barriers. An unsuppressed fire in an oil-filled transformer could damage some but not all bus ducts supplying AC power to all three units.


The oil-filled transformers are protected by automatic water spray systems. Yard'hydrants and hose lines stored in hose houses are available for manual fire suppression.


An analysis by the licensee of the potential effects of a transformer fire on the AC power system indicates that such a fire would not prevent safe shutdown with the systems normally utilized. Completion of the dedicated safe shutdown system will provide additional defense in depth, eliminating any potential that a yard area fire could prevent safe shutdown.


The licensee has proposed to anchor the portable propane tanks in the yard and provide them with excess flow valves. We find that fire protection in the yard area satisfies the objectives detailed in Section 2.2 of this report and is, therefore, acceptable.

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5.14 Block Houses 5.14.1 Safety-Related Equipment

The two block house structures contain switchgear for all 4160 volt AC power to ESF systems. The unit 1 and 2 blockhouse contains the switchgear for the HPSW pumps. The unit 1 and 2 blockhouse also contains, in a separate room, the stepdown transformer which receives 13,800 volt power directly from the Keowee hydro-station via underground cables.

5.14.2 Combustibles

The combustibles in the block houses consist of electrical insulation in the switchgear and associated cabling. The stepdown transformer is oil-filled.


An unsuppressed fire in the switchgear areas could result in loss of all 4160 volt AC power to ESF systems and the HPSW pumps. With the completion of the dedicated safe shutdown system, such a fire would not prevent safe shutdown of all three units.

An unsuppressed fire at the stepdown transformer would result in loss of the underground power supply from the Keowee hydro-station; however, the overhead line coming from the hydro-station would not be affected.


Automatic smoke detectors are provided in the switchgear rooms and transformer room. The oilfilled transformer is protected by an automatic water spray system.


Manual fire fighting may not be effective in preventing damage to the safety-related equipment in the switchgear areas.

The automatic water suppression system and fire barrier would prevent a transformer fire from affecting the switchgear area in the unit 1 and 2 block house, except that the fire barrier between the stepdown transformer and switchgear room has an inadequately protected electrical bus duct penetration.


The licensee has proposed to upgrade the bus duct penetration in the fire barrier between the transformer and the switchgear rooms in the unit 1 and 2 block house.

Upon completion of this modification and recommendation, fire protection in the block houses will satisfy the objectives detailed in Section 2.2 of this report and is, therefore, acceptable.

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5.15 Keowee Hydro-Station 5.15.1 Safety-Related Equipment

The hydro-station, which has two water-driven turbine generators, provides the primary source of emergency AC power for all three units.

5.15.2 Combustibles

The significant combustibles in the hydro-station are lubricating oil for the turbine generators, insulation and cable jacketing for electrical cables and equipment, and hydrogen from storage batteries. There is an oil-filled transformer in the yard area adjacent to this plant.


An unsuppressed fire in a single turbine generator involving lube oil or electrical insulation would not result in the loss of more than the unit initially involved because of the distance and barriers between units. An unsuppressed fire in the electrical cable trays in the basement or in the battery room could result in the loss of generating capability from both turbine generators. This would not prevent safe shutdown of the plant due to the availability of the Lee station gas driven turbine.


An automatic carbon dioxide system is provided for the generators. Automatic water spray systems are provided on the oil pumps in the basement and on the outside oil-filled transformer. Automatic smoke detectors have been installed in the battery room and basement area. Fire hose stations with 1-1/2 inch hose are provided on the first floor and first basement level.


The lack of fire detectors in some areas of the hydro-unit could delay personnel response for manual fire fighting. A fire in the electrical cable trays in the basement area and battery room could be difficult to control manually because of limited access and the poor visibility caused by smoke.

Existing fire hose stations may not be sufficient to reach all areas containing combustible materials.


The licensee has proposed to provide additional hose stations to reach all safety-related areas with 100 feet of 1-1/2" fire hose.

In addition, the dedicated safe shutdown system proposed by the licensee will have its own power source (see Section 4.10 of this report). We find, subject to implementation of the above described modifications, the fire protection for the Keowee hydrostation satisfies the objectives of Section 2.2 of this report and is, therefore, acceptable.

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6.0 ADMINISTRATIVE CONTROLS

6.1 General

The administrative controls for fire protection consist of the fire protection organization, the fire brigade's training, the controls over combustibles and ignition sources, the prefire plans and procedures for fighting fires, and the quality assurance provisions for fire protection. By letter dated January 6, 1978, the licensee provided a description of the elements of his administrative controls for fire protection, as detailed in the following sections. Various improvements needed in his administrative controls are also detailed in the following sections.

6.2 Organization

The licensee's present fire protection organization description contains the functional responsibilities and the lines of communication between all positions involved in the fire protection program.

The fire protection organization contains positions extending from the Vice-President, Steam Production Department down to the Station Manager and the Safety Supervisor. These management and staff positions are responsible for formulation, implementation, and assessment of the fire protection program. The organizational responsibilities are delineated for design, selection, installation, testing, maintenance, modification, and review of fire protection systems and for fire brigade training. Qualification requirements have been established for the training instructors, and the positions responsible for formulating and implementing the fire protection program.

We find that the fire protection organization conforms to the provisions

of Appendix A to BTP 9.5-1 and is, therefore, acceptable.

6.3 Fire Brigade Training

The fire brigade training program consists of classroom instructions, fire drills, and practice in fire fighting.

The fire brigade training program contains the following essential elements: use of fire fighting equipment, fire fighting principles and techniques, use of fire fighting procedures, periodic practices in actual fire fighting and periodic fire drills to assess brigade effectiveness. These drills also provide practice in the use of equipment, fire fighting procedures, and brigade leadership. Records of fire brigade members training and drills are maintained and available for review.

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We find that the fire brigade training program conforms to the provisions

of Appendix A to BTP 9.5-1 and is, therefore, acceptable.

6.4 Control of Combustibles

The licensee has identified the facility procedures which implement the

controls to minimize the amount of combustibles that a safety-related area

may be exposed to. These procedures include provisions to: limit the use

and storage of combustibles in safety-related areas; establish work controls

and required additional fire protection where transient fire loads are

introduced; assure the removal of waste, debris and scrap materials following

work activities; and provide for periodic housekeeping inspections.

We find that the control of combustibles conforms to the provisions of

Appendix A to BTP 9.5-1 and is, therefore, acceptable.

6.5 Control of Ignition Sources

The control of ignition sources minimizes the potential for fire resulting

from work involving ignition sources such as welding, cutting, grinding, and open flame work or smoking. The controls on ignition sources require:

use of a work permit authorized by a qualified individual prior to performing

cutting, welding, grinding, or other flame work; removal of moveable combus

tible material; use of trained and equipped fire watches; provisions for

protection by curtains or covers when cutting, welding, grinding, or other

flame work; and restrictions on smoking in safety-related areas. Use of

open flames or combustion generated smoke for leak detection in safetyrelated areas has been prohibited.

We find that the control of ignition sources conforms to the provisions of

Appendix A to BTP 9.5-1 and is, therefore, acceptable.

6.6 Fire Fighting Procedures

The licensee has provided a description of the current fire fighting procedure and the procedural elements to be changed in the near future. The fire fighting procedures identify the actions to be taken by the individual discovering the fire, action to be taken by the control room operators, the fire brigade actions, and the necessary strategies for fighting fires in safety-related areas and areas presenting a

hazard to safety-related equipment.

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We find that the fire fighting procedures conform to the provisions of Appendix A to BTP 9.5-1 and is, therefore acceptable.

6.7 Quality Assurance

The licensee has elected to meet NRC's fire protection QA criteria by applying their existing QA program under 10 CFR Part 50, Appendix B, to fire protection. This QA program was approved July 30, 1975, and should adequately cover the quality assurance provisions for fire protection in safety-related areas such as the control of the design, procurement, installation, testing and maintenance of fire protection equipment. These provisions include fire protection requirements; establishment of procedures to implement the fire protection program; evaluation of potential suppliers and inspection of equipment on receipt; inspection and testing of fire protection equipment following maintenance and modification; installation and periodic inspection of penetration seals and fire retardant coatings; periodic testing of fire protection equipment; identification and evaluation of nonconforming fire protection equipment; corrective action for failures, deviations, and defective materials; records of fire protection activities; and audits to verify proper implementation of the fire protection program.

We find that the licensee's commitment to implement the NRC's fire protection QA criteria as part of their existing approved QA program under 10 CFR Part 50, Appendix B, conforms to the guidelines of Appendix A to BTP 9.5-1 and is, therefore, acceptable.

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7.0 TECHNICAL SPECIFICATIONS

The Technical Specifications were modified on February 13, 1978 to incorporate interim Technical Specifications which include limiting conditions for operation and surveillance requirements for existing fire protection systems and administrative controls. Following the implementation of the modifications of fire protection systems and administrative controls resulting from this review, the Technical Specifications will be similarly modified to incorporate the limiting conditions for operation and surveillance requirements for these modifications.

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8.0 CONCLUSIONS

The licensee has performed a fire hazards analysis and has proposed certain modifications to improve the fire protection program. Additional modifications have been proposed by the licensee during the course of our review of the fire hazards analysis and our onsite evaluation of the fire protection program. These proposed modifications are summarized in Section 3.

In summary, significant steps are being taken to assure that safe shutdown can be accomplished and the plant maintained in a safe condition during and following potential fire situations. Upon implementation of the licensee's proposed modifications summarized in Section 3, we find that the provisions of Section 2.0 are satisfied and that:

(1) Combustibles in safety-related areas are limited to the extent practicable;

(2) Fire detection and suppression systems will minimize consistent with other safety requirements the effects of fire on safety-related systems and will not in themselves significantly impair the capability of safety-related systems.

(3) Redundant safe shutdown systems are separated from each other and, where practicable, from significant combustibles by barriers or distances, or are adequately protected by fire suppression systems, such that a fire in any fire area will not prevent safe shutdown of the plant;

(4) A fire in any fire zone will not damage safety-related structures such that they cannot perform their safety function;

(5) The fire protection organization has the professional qualifications to implement the fire protection program, and administrative controls are adequate to maintain control of combustibles, ignition sources, and the fire protection organization; and

(6) A fire in any fire zone will not cause the release of amounts of radioactive material in excess of those considered in previous safety eval uations.

We find that the licensee's proposed modifications described herein are acceptable both with respect to the improvements in the fire protection program that they provide and with respect to continued safe operation of the facility.

In the report of the Special Review Group on the Browns Ferry Fire (NUREG-0050) dated February 1976, consideration of the safety of operation

8-1

of all operating nuclear power plants pending the completion of our detailed fire protection evaluation was presented. The following quotations from the report summarize the basis for our conclusion that the continued operation of the facility, pending implementation of all facility modifications, does not present an undue risk to the health and safety of the public.

"A probability assessment of public safety or risk in quantitative terms is given in the Reactor Safety Study (WASH-1400). As the result of the calculation based on the Browns Ferry fire, the study concludes that the potential for a significant release of radioactivity from such a fire is about 20% of that calculated from all other causes analyzed. This indicates that predicted potential accident risks from all causes were not greatly affected by consideration of the Browns Ferry fire. This is one of the reasons that urgent action in regard to reducing risks due to potential fires is not required. The study (WASH-1400) also points out that 'rather straightforward measures, such as may already exist at other nuclear plants, can significantly reduce the likelihood of a potential core melt accident that might result from a large fire.'

"Fires occur rather frequently; however, fires involving equipment unavailability comparable to the Browns Ferry fire are quite infrequent (see Section 3.3 of [NUREG-0050]). The Review Group believes that steps already taken since March 1975 (see Section 3.3.2) have reduced this frequency significantly.

"Based on its review of the events transpiring before, during and after the Browns Ferry fire, the Review Group concludes that the probability of disruptive fires of the magnitude of the Browns Ferry event is small, and that there is no need to restrict operation of nuclear power plants for public safety. However, it is clear that much can and should be done to reduce even further the likelihood of disabling fires and to improve assurance of rapid extinguishment of fires that occur. Consideration should be given also to features that would increase further the ability of nuclear facilities to withstand large fires without loss of important functions should such fires occur."

We have determined that the license amendment does not authorize a change in effluent types or total amounts nor an increase in power level and will not result in any significant environmental impact. Having made this determination, we have further concluded that the amendment involves an action which is insignificant from the standpoint of environmental impact and pursuant to 10 CFR 51.5(d)(4) that an environmental statement, or negative declaration and environmental impact appraisal, need not be prepared in connection with the issuance of this amendment.

We have concluded, based on the considerations discussed above, that: (1) because the amendment does not involve a significant increase in the probability or consequences of accidents previously considered and does not involve a significant decrease in a safety margin, the amendment does

8-2

not involve a significant hazards consideration, (2) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (3) such activities will be conducted in compliance with the Commission's regulations and the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.

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9.0 CONSULTANT'S REPORT

Under contract to Nuclear Regulatory Commission, Brookhaven Natiohal Laboratory has provided the services of fire protection consultants who participated in the evaluation of the licensee's fire protection program and in the preparation of this report. Their letter, Fire Protection in Operating Nuclear Power Stations - Oconee Nuclear Station, Units I and 2, dated February 22, 1978, discusses several matters which have been addressed in this report. These elements of the consultants recommendations which we have not adopted are identified in Appendix B along with our bases therefor.

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APPENDIX A

CHRONOLOGY

In February 1976, the report by the NRC Special Review Group was issued as NUREG-0050, "Recommendations Related to the Browns Ferry Fire."

On May 1, 1976, Standard Review Plan 9.5.1, "Fire Protection," was issued, incorporating the various recommendations contained in NUREG-0050.

By letter dated May 11, 1976, Duke Power Company was requested to compare the existing fire protection provisions at their facilities with new NRC guidelines as set forth in Standard Review Plan 9.5.1, "Fire Protection," dated May 1, 1976 and to describe (1) the implementation of the guidelines met, (2) the modifications or changes underway to meet the guidelines that will be met in the near future, and (3) the guidelines that will not be met and the basis therefor.

By letter of September 28, 1976, Duke Power Company was requested to provide the results of a fire hazards analysis and propose Technical Specifications pertaining to fire protection. Duke Power Company was also provided a copy of Appendix A which includes acceptable alternatives to the guidelines of Standard Review Plan 9.5.1.

By letter of December 1, 1976, we provided model Technical Specifications and requested submittal of fire protection Technical Specifications.

On December 31, 1976, Duke Power Company provided a submittal responding to our requests of May 11, 1976 and September 27, 1976. On July 7, 1977, Duke Power Company provided proposed Technical Specifications for fire protection.

On October 3 to 7, 1977, the DOR fire protection review team visited the Oconee facility. On October 7, 1977 a meeting was held at the Oconee facility at which the review team presented positions and requests for additional information.

On March 1, July 18, November 22 and December 15, 1977, and January 16, 1978, the licensee submitted responses to staff requests for additional information and positions.

On January 18, 1978, a meeting was held at Bethesda, Maryland, at which Duke Power Company presented a preliminary description of the proposed dedicated safe shutdown system.

On January 25 and February 1, 1978, the licensee provided additional information including information on the safe shutdown facility.

A-1

On February 13, 1978, an amendment was issued approving interim fire protection Technical Specifications.

On February 22, May 9, June 19 and July 19, 1978, the licensee provided additional information.

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APPENDIX B

DISCUSSION OF CONSULTANT'S REPORT

Under Contract to Nuclear Regulatory Commission, Brookhaven National Laboratory has provided the services of fire protection consultants who participated in the evaluation of the licensee's fire protection program and in the preparation of the Safety Evaluation Report (SER). Their letter, "Fire Protection in Operating Nuclear Power Stations - Oconee Nuclear Station," dated February 22, 1978, discusses several matters which have been addressed in the SER. The consultant's report contains recommendations which have, for the most part, been implemented during our evaluation. The consultant's recommendations which we have not adopted, along with our basis therefor, are identified herein.

1. Consultant's Comment: Damage Limits

"SER Item 8.0(2) concludes that fire detection and suppression will minimize the effects of fire on safety-related systems. The consultant does not concur in this conclusion. There are usually several protective approaches that can be utilized for a given fire hazard, with each approach offering certain advantages and disadvantages in terms of limiting the fire extent, damage due to the fire suppression agents employed, reliability, and cost effectiveness. In most cases, it is technically possible to reduce the damage potential to a very low level, but cost penalties often become severe. The fire protection systems that are being provided and recommended are to assure safe shutdown capability and will not necessarily minimize fire damage to all safety-related systems."

Staff Response:

The fire protection systems that are being provided and recommended are to assure safe shutdown capability and will not necessarily minimize fire damage to all safety-related systems in the strict sense of the meaning. The term "minimize" is used by the staff in the context of GDC 3 as interpreted in Appendix A to BTP 9.5-1. The staff agrees that the effects of fires have not been literally "minimized."

2. Consultant's Comment: 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 recommended that electrical supervision be required on all control valves for fire protection systems protecting areas containing or exposing safety-related equipment."

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Staff Response:

The guidelines of Appendix A to BTP 9.5-1 allow electrical supervision. locking, or sealing with tamper proof seals with periodic inspection as means of assuring that valves in the fire protection water system are in the incorrect position. Valves on other systems in the plant are presently under administrative control. A review by the staff of Licensee Event Reports indicates that valves being in the correct position has not been a problem. Additionally an analysis by the licensee has shown that standing water as a result of failure of suppression system piping will not damage safety-related equipment due to curbs, drains, mounting of equipment above floor level, grating, and doorways. The licensee has also proposed to provide shields or other protection where water spray may result from cracks in suppression system piping. On this basis, a significant increase in plant safety would not result from the use of electrical supervision of all valves in the fire protection water systems.

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UNITED STATES NUCLEAR REGULATORY COMMISSION

DOCKET NOS. 50-269, 50-270 AND 50-287

DUKE POWER COMPANY

NOTICE OF ISSUANCE OF AMENDMENT TO FACILITY OPERATING LICENSE

The U. S. Nuclear Regulatory Commission (the Commission) has issued

Amendment Nos. 64, 64 and 61 to Facility Operating Licenses Nos. DPR-38,

DPR-47 and DPR-55, respectively, issued to Duke Power Company which

revised the license for operation of the Oconee Nuclear Station Unit

Nos. 1, 2 and 3, located in Oconee County, South Carolina. The

amendments are effective as of the date of issuance.

These amendments add license conditions relating to the completion

of facility modifications for fire protection.

The Commission has made appropriate findings as required by the Act and

the Commission's rules and regulations in 10 CFR Chapter I, which are set

forth in the license amendments. Prior public notice of these amendments

was not required since the amendments do not involve a significant hazards

consideration.

The Commission has determined that the issuance of these amendments

will not result in any significant environmental impact and that pursuant

to 10 CFR §51.5(d)(4) an environmental impact statement, negative declaration,

or environmental impact appraisal need not be prepared in connection with

issuance of these amendments.

-2-

For further details with respect to this action, see (1) the

licensee's submittals dated December 31, 1976, March 1, July 18,

November 22, December 15, 1977, January 16, January 25, February 1,

February 22, May 9, June 19 and July 19 1978, (2) Amendment Nos. 64,

64 and 61 to License Nos. DPR-38, DPR-47 and DPR-55, respectively,

and (3) the Commission's related Safety Evaluation. All of these

items are available for public inspection at the Commission's Public

Document Room, 1717 H Street, NW, Washington, DC 20555 and at the

Oconee County Library, 201 South Spring, Walhalla, South Carolina

29691. A copy of items (2) and (3) may be obtained upon request

addressed to the U. S. Nuclear Regulatory Commission, Washington, DC

20555, Attention: Director, Division of Operating Reactors.

Dated at Bethesda, Maryland, this llth Day of August 1978.

FOR THE NUCLEAR REGULATORY COMMISSION


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