DUKE POWER COMPANY ri

422 SOCTs CHURCH STRZZT, CARLOTTZ, .. 2242

WILLIAM 0. PARKEP.JR.

'-ccI~ Pmoac¶I0ost

January 25, 1978cEIAP-ONC: APEA 7C4

Mr. Edson G. Case, Acting DirectorOffice of Nuclear Reactor RegulationU. S. Nuclear Regulatory CommissionWashington, D. C. 20555

Attention:

Reference:

Mr. A. Schwencer, ChiefOperating Reactors Branch #1

Oconee Nuclear StationDocket No. 50-269

Dear Sir:

During the week of October 3, 1977, representatives from the NuclearRegulatory Commission visited Oconee Nuclear Station for the puzrposeof observing station features pertinent to fire protection. Staffrequest3 for additional information on the Oconee fire protectionprogram were provided during that visit and subsequently transmittedby Mr. A. Schwencer's letter of November 10, 1977. An initial res-ponse to these requests was provided by my letter of November 22, 1977.On December 15, 1977, further requests for additional information werereceived with regard to fire protection and initially responded to onJanuary 16, 1978. Questions were also received from the staff onJanuary 16, 1978. The purpose of this letter is to supplement theinformation provided on November 22, 1977 and January 16, 1978 and torespond to the request received on Januaryiif6, 1978.

The attached refers to and is based in part on a proposed Safe ShutdownSystem for Oconee. This system was discussed with the staff on January18, 1978 and information concerning the system will be formally trans-mitted on February 1, 1978.

Very truly yours,

-d

William 0. Parker, Jr.

DCH:geAttachment

U

Requests 2, 3, and Position 4 for additional inform-ation concerning systems,equipment, and cable routing for safe shutdown were provided in part onJanuary 18, 1978, when Duke Power Company made a presentation to the NRCoutlining a concept for a safe shutdown facility.,

This safe shutdown facility provides a means to safely shutdown the plantindependent and diverse from existing plant equipment which could be affectedby a postulated fire.

To complete this response, a system description for the facility will beprovided by February 1, 1978, and the additional information on ReactorBuilding cable routing as requested in Item 3 is enclosed in this submittal.

The application of a fire retardant coating on redundant cable will be deletedfrom the December 3), 1976, Response to Branch Technical Position 9.5-1 dueto the separate safe shutdown facility.

EDB-i January 25, 1978

9

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3. Instrumentation and control cables located In the Reactor Building that are

assoclated.with hot shutdown are listed on attached Figure 012478. The phy-

sical routing of these cables Is shown on attached Drawings 0-875,0-884,0-885,0-886,

O-886A,0-886B and 0-887. The drawings employ a color coding scheme Identified.,,

In Figure 012478 for the Identification of the cables.

A review of the cable routing on the drawings shows that all hot shutdown

system instrumentation and control cables associated with Reactor Loop A

and pressurizer level terminate on penetrations :on the East side of the

building, and those cables associated with Loop B terminate on penetrations

on the West sideaof the building (see 0-875 and 0-886).

The minimum instrumentation and control cables required for

that are located in the Reactor Building are asvffollows:

1. One cable from Reactor Coolant Temperature Loop A or B.

2. One cable from Reactor Coolant Pressure A or B.

3. One cable from Pressurizer Level.

4. One cable from Steam Generator A Level.

5. One cable from Steam Generator B Level.

hot shutdown

In addition to the Instrumentation and control cables described above, power

cables to one group (126 KW) of pressurizer heaters are required for hot shut-

down. Drawings 0-875 and 0-885 are marked to show the routi.ag of all the

pressurizer heater cables with the Reactor Building and these cables all

terminate on penetrctions on the East side of the Reactor Building.

5. The attached drawings are marked to show the HVAC penetrations.

The penetrations are coded to denote those which are provided with dampersand those proposed for upgrading.

Fire doors have labels or are being replacediJwith doors provided with labelsexcept for the East Penetration Room Doors an'd an Instrument Room Door inthe Turbine Building.

The Penetration Room doors are blast doors and considered adequate. TheInstrument Room contains negligible combustibles and no contact withunit shutdown; there!'ore, no fire door should be required.

EDB-i January 25, 1978

-9

6. Attached is the analysis of the Radiological Consequences of Fires in

'Radwaste Areas.

Fire protection is provided by local hose stations.

I

ED8-i January 25, 1978

Analysis of Radiological Consequences of Fires in Radwaste Areas

Approximate DoseRate To

Room Number Component SourceSource Fl refinhters

51 RC Bleed Evaporation Lijuid from RC Bleed Evaporation Feed Tank (400Feed Pump ft. Tank Vol). Dose rate in room would be pre-

dominately from evaporator bottoms stored in theevaporator.

Spent Resin Sluice Resln/Slulce water. Dose rate due mostly toPumps source In the punpsSpent Resin Trans-fer Pumps

Miscellaneous Waste Miscellaneous Liquid lRadwaste. Dose rate duePumps mostly to source in the pumps.

50-200 mr/hr

10-150 mr/hr

10-50 mr/hr

5-40 mr/hr

50-200 mr/hr

2-20 mr/hr

106, 124,166

122

304

Concentrated BoricAcid Transfer Pumps

Miscellaneous WasteEvaporation FeedPump

Low Level DrummingStorage Area

Low activity liquid - concentrated boric acid.Dose rate due entirely from concentrated boricacid storage tanks (3000 ft 3 Tank Vol).

Liquid from Hisce laneous Waste EvaporationFeed Tank (400 ftl Tank Vol). Dose rate Inroom would be predominately from evaporatorbottoms stored in the evaporator.

Low activity solids - rags, clothing, etc.

EDO-I January 25, 1978

-------------------------------------------------------------------------------~ -.

'a

10. The analysis of the information concerning regular and emergency light-Ing to areas providing access to a fire in safety-related areas providedNovember 22, 1976, demonstrates that a fire in a safety-related area of.the plant will not cause the loss of lighting to areas providing accessto the fire.

ED8-1 January 25, 1978

7 7

* &

11.> As illustrated In attached Figure 021578, the Reactor Coolant Pump Motor'Drain and Overflow System will be modified to include housings and leak

- collection provisions around the'upper and lower bearing oil level devicesand the upper bearing oil cooler.

With this modification, all potential oil leaks of motor bearing oil willbe collected and drained to the collector tank in-the Reactor CoolantPump Motor Drain and Overflow System.

¾?

a

EDB-i January 25, 1978

4

OIL BEARING COOLER

NEW HCUSING AROUNDCOOLER S PIPING

MOTOR HOUSING.

LOWER SEARING OIL-LEVEL DEVICE

TO MOTOR DRAIN & OVER FLOWSYSTEM COLLECTION TANK

FIGURE 012578

The Data/Sheet for Standard Armstrong Armaflex Sheetattached.

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13. Insulation is

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EDB-i January 25, 1978

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Standard ArmaflexKSheet Insulation':

*Surface Burning Characteristicsof Building Materials.** Averagemaximum specific optical smokedensity has been measured byNational Bureau of Standards (NBS)Smoke Chamber Method.

These numerical flame-spread-ratings alone do not define thehazards presented by this materialunder actual fire conditions.These numerical flame-spreadratings are intended onlyto provide guidelines forregulatory authorities.

Flame.Spreed

Thickness Ctass..aficai141orIes" 30 or.wasVorIes" 75 oriless

AM* MiazSpecific optielSmoke. Oufladi

Thkictwe 0,, (corr.)

11 orles 400

m Test Methd~OAST14 E84ASTM 584

NBTest MethodBSSmoke ChAn'beD'

Nes Smofte Chamber

DESCRIPTIONStandard Armaflex Sheet Insulationis a flexible. elastomeric thermalinsulation, black in color, suppliedas flat sheets 36" x 48", inthicknesses t'Al through 1" in •"increments (except %"). It Isfurnished with a smooth skin oneside which forms the outer,exposed insulation surface. Theexpanded, closed-cell structure ofArmaflex Sheet makes it anefficient Insulation. and becauseof its low water vapor permeance,It is considered to be a vaporbarter In itself.

Standard Armaflex Insulations havebeen evaluated for typical flame-spread classification by ASTM E34(NFPA 255) Method of Test for

*Averag of smolderIM AMd MSflaVm MoOs

USESStandard Armaflex Sheet is usedfor all applicabons that cannot teaccomplished by the preformedtubular insulation also available.It is particularly adaptable forInsulating ductworl, large piping,tanks, and vessels. Its flexibilityallows applicarion to curved andirregular surfaces. Armaflex Sheetis very adaptable to making all.types of fitting cover insulations.

The recommended temperatureusage range for Armaflex Sheetis -40 F to +220 F according tomethod of application. With fulladhesive coverage attachment.the surface to wnich it is appliedmay operate to a limit of 180 F.When used for pipe insulation withadhesive adhering seams andjoints only, Armaflex Sheet can beapplied to lines that will operateto a limit of 220 F.

For use on cold surfaces.

Armaflex Sheet thicknesses havebeen calculated to preventcondensation on the insulationsurface, as shown in the table ofthickness recommendations.

APPLICATIONStandard Armaflex Sheet is installedusing Armstrong 520 Adhesive. aheat-resistant and water-vapor-resistant contact adhesive. Forapplication to large flat or curvedmetal surfaces such as ducts, verylarge pipes, tanks, and vessels.full adhesive coverage attachmentis used. For application as pipeinsulation and fitting covers, onlythe seams and joints are adheredwith adhesive. 520 Adhesive is acontact adhesive: therefore, in allcases, both surfaces to be joinedare coated with adhesive.

Indoors, no protective finish isrequired but may be desirable.Outdoors, a weather-cesistantprotective finish is to be applied.The recommended protectivefinish is Armstrong ArmaflexFinish: however, other compatiblefinish systems are not ruled out.

SPECIFICATIONCOMPLIANCEStandard Armatlex Sheet can besupplied upon request to meet:

ASTM C534, Type IIASTM D1056 SBE 41-42MIL-C-3133B (MIL STO 6708),

Grade SBE 3HH-1-5738, Class S

The Plant Facilities and EquipmentStaff of USDA APHIS has noobjection to the use of StandardArmaflex Insulations in processing,transporting, or storage areas formeat and poultry prepared underFederal inspection, provided theinsulation is covered or coated withan acceptable material. The JacKetor coating material used Shouldprovide a surface that is smooth,impervious. and cleanable and beapproved by USDA APHIS.

A "dl,-'di

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COW Wd It. ArWOV" Cws COOM~ LN41WU. ft

POO ME

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Industry Products Division, Lancaster. Pa. 17604

Standard Armaflex Sheet Insulation:Aymqae physical propertiese

Test Mo~wod (Soe roto 3)Density. lb/¢u It 5.7 XTTM 0-1622

Thermal conductivityBtuih sq ft (F Coglin.)75 F mean temo 0.27 ASTIM C17790 F mean temo 0.276 or C518

Upper use limit. og F: (See note 11 220Lower use limit. cog F (See note 2) -40Thermal staoility. % shnnkage

7 days. 200 F 3 ASTM C543..7 0ay^ 220 F 5

Water vapor pwrrneaOlty, 0.1 ASTM 355wet cuo, perm-4n.

Water absoro•ton. % by eignt 8 ASTM 01056Ozone resistance GOOdor NEGLIGIBLE

IWhen AnvWfie Shoet is Mistaed y edfentWtutl points and seamr onfy. the uooer emoer-two hint is 220 F usAV• 520 A,6esie. Anna.ftx Shev adhered with comowife achsivecover•ge on flat or curwve met surfaces maybe ablmed to surfaces that *id ooerate a h,.rna 180 F usg 520 Adhesmve.

IAI - 20 F. ftlxmte Armnalex insttorntsbecome hard and. as temo*vatures crod oelow- 20 F. wA be rcreessingy bttle: rhowever.Mes mriervrig criaracter'snc does mot aztecWeW efencwy and resatance to water

veow permeackwty. Aoplicatofl Deo -40 F isa1 Uer's *$cretion.

IASTU meMod. in some case* may be moo.Wle Sngtr to make resutts mrorsriemanirigtui

for eron-ise a•ppcation. if detuls we requvecLcom Anewo c C arn l...

dArmerwe ShMein WI V fttcknearw not lfe

*Averng v•sle we ne to be weed forWdln matwtl spoeriafUens. CantaggArmeurn for aecIlicadon ranles.

Thicknes inchee (See note 4)* Wo

(~incroemet)J

Thickness recommendations

BASED ON NORMAL DESIGN CONDITIONSArmaflex in trio thicKnes3es noted amn withinthe socifled temoorature ranges will controlkwulation surface sreating indOors underinrmal design conditions. a maximum seve".of 93 F and 70% RH. Armstrong rvsearcn andfleid experience indicate that indoor conditionsanywhere in the United States seldom exceedthe degree of seventy.BASED ON MILD DESIGN CONDITIONSArmattex in the tIMcirnessea noted and within

tA speciftled temoerature ranges will controlinsulation surface sweating indooirs under

0ild design condittons.a maximum seventyof 60 F and 50% RH. Typical of tresecon itions are most air-conditioned somicssand arid climates.

BASED ON SEVERE DESIGN CONDITmONSArmaflex in the tr'icxnesses noted and withintie specified tmooeraturo ranges will controi

itmlation surface wematin indoors underarseir design conditons, a maximumseventy of 90P and 0% RH.ATycal of -vww condtions are indoor arias inwtuch excessive moisture in introducedor in poorly ventilated confined areas where911 temperature may oe depressed oelowSnbwnt.

Duetis-Tarnks-Vesmis---EutpmentMeU64 ae Temperature

5OF 3SF OF

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OFFICESCHARLOTTE. NC 28217P.O. Box 7089Textard & Arrowood Boulevards704/588-3770

CHICAGO. IL422 Northwest HighwayPark Ridge. IL 60068312/6%6-3130

CINCINNATI OH 452414100 Executive Patr% Drove513/563-4160

NEW YORK. NYPari 80 Plaza West-OneGarden State Plrxway at Interstate 80Saddle Brook. NJ 076622011843-0300

ST. LOUIS, MO 63106222 South Meramet Avenue314/863-7979

SAN FRANCISCO. CA3190 Clearview waySan Mateo. CA 94402415/574.4133

Ci4.. 1'kt

t muffe 181ayer

.1- IP.716.277Y

P1iftad I, $am 01n kis e

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14. ,The oilV-fired boiler conforms to NFPA 85,."Oil-and-Gas Fired Water TubeFurnaces", One Boiler, '73," except that:

a. Upon loss of control air, the Oconee boiler will drop to minimalflow and not create an unsafe condition.

b. The boiler will start the purge fan prior to proof of valve closure.The boiler Is not auto-recycle; therefore, no unsafe condition shouldbe created.

The Auxiliary Boiler meets the intent of NFPA 85.

S

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EDB-i January 25, 1978

now

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providedrhere are no backflow devicessystem.

In the Turbine Building drain

4

EDB-i ,January 25, 1978

20 'The Turb ne Building roof deck was constructed in accordance with Koppers

Company's SpecifIcation No 17:

i II' I II i111111'i lilIlll

F A'•.• i ,•,.,; -,..• "•

I. Strip.mop steel deck with steep roof asphalt..and apply 1-5/16" of

Owens-Corning Fiberglas roof insulation, mop solid with coal-tar

pitch and apply one 43 lb coated base sheet and mop solid with coal-

tar pitch.

.2 Install 3 plies of 15 lb tarred felt, each ply lapped 24-2/3" with

coal-tar pitch.

.3 Embed 400 lb gravel or 300 lb slag per square into not less than

75 lb per square of hot coal-tar pitch.

Therefore, construction Is considered to be in accordance with FM Class I,

but installation documentation is not available.

EDB-i January 25, 1978-

24,

• . <' ,.. .. .. ' " ' • " ; " . .. , . ;' . , , " .

The HPSW System provides water for fire protection. Flowpiping layout drawings are attached.

If wa ter flow is lost to sections of the Turbine BuildingMezzanine and Operating Floor hose stations'are also lost

vertical risers feeding them..

".:,.

diagrams

Basementdue to

and

t, thethe

Automatic suppression systems are fed from theon the attached drawings.

Refer to Tables I and Ii for a synopsis.

EDB-i January 25, 1978

"B"r line header as shown

. TABLE I

BreakLocation

IsolationRequired Area of Loss of Fire Protection

I

2

3

HPSW- 111IIPSW-33IIPSW-75

2 HPSW-312 HPSW-332 HPSW-75

HPSW-332 HPSW-31

HPSW-20IPSW-11

HPSW-20HPSW-21

HPSW- 1032 IIPSW-33

Turbine Building Auto Systems - Units 1 & 2 FWP Turbine and Turbine Oil TankMulsifier System; Unit I & 2 Seal Oil Tank Mulsifier System; Unit I Main TurbOil Tank, turb bearing and oil piping Mulsifier System; Unit 1 Emergency F. W.Turb & Turb System and Sprinkler System to Trans CT 1. IT, Main #1 and CT 4.Turbine Building Manual Systems - 33% of Unit I area hose racks. Loss of allfire protection in service building, shop and administration building.

t ,

Turbine Building Auto SystemsOil Piping Mulsflier System.area hose racks.

- Unit 2 Main Turb Oil Tank, Turb Bearing andTurbine Building Manual System - 20% of Unit 2

)T

4

5

6

Turbine Building Auto Systems - Unit 2 emergency FWi turb and Turb Oil TankMulsifier System; Sprinkler System to Trans 2T, Unit 2 Main and CT 2; Basementand mezzanine area 3 sprinkler system. Turb Building Manual Systems - 17% ofUnit 1 area hose racks.

Loss of Fire Protection Jockey PumpsTurbine Building Manual Systems - 50% of Unit I area hose racks; 80% of Unit 2area hose racks; 78% of. Unit 3 area hose racks.

Auxiliary Building-Manual Systems - Loss--.f Call auxiliary building area hoseo:-,:.:racks.

Turbine Building Auto Systems - Unit 3 Emergency FW Turb and Turb Oil TankMulsifier System; Unit 3 Main Turb Oil Tank. Turb Bearing and Oil PipingMulsifier System, Unit 3 FlP Turb and Turb Oil Tank Mulsifier System; Sprinkler i

System to Trans. CT 3 3T and Mains 3A, 30, 3C and 3D; Basement and mezzaninearea 4 sprinkler system. Turbine Building Manual Systems - 12% of Unit 3 areahose racks.

7 IIPSW- 104 230 Hv and 500 Kv Switch Yard . Loss of all auto systems.FH-12, 13a 14, 15, 16, 17s 18, 19, 20, 21, 32 and 33.

Loss of Fire Hydrants -

24.

, ,,:~3< ,K .'~' , ~ >

JABLE I ~ 2

ISOLATION FOR MAINTENANCE OF FIRE HYDRANTS

Isolation Valves Closed Hydrants Affected Other Are

- ..1,, .'~,,*-' . - -.3333~$$ 3$

33'

as AffectedIII

HPSW 79

HPSW-77, HPSW-76,HPSW-81, & 2HPSW-80

HPSW-73 & 223

HPSW-187

FH-5, 4, 3, 2, 1

3 FH 34 &35 .

FH-8, 9, 10, 11

FH-24

None

None

HPSW-183 4

HPSW-27

HPSW-219 22 & 109

HPSW-23 & 106

HPSW-107

HPSW-104 & 106HPSW-81 & 103HPSW-223

FH-23

FH-25

FH-29 & 22

FH-28 & 27

FH-26

FH-12, 13, 14,15, 16, 17, 18,19, 20, 21, 30,31, 32 & 33

None

None

Mulsifier System.Trans. CT-5

FH-24, FH-23 andMulsifler System.Trans. CT-5

None

CCW Pump F1ireProtection and

CCW Pump FireProtection

220 and 500 Kv S,Yard AutoFire Protection

toU

to.

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33~I3

DEX/h1/12/78

11,

... .• , 7"

SReference the January 16, 1978, submi'ttal. These radios will bemade available to the fire brigade as, necessary*

14.

q

EDB- I January 25, 1978

V.'A.

S 2. Refer to esponse5. Fire doors have labels'except forPenetration Rooms which are equipped with blas.t doors..

the East

47

I: +

5'

EDB-i January 25, 1978

*9.

Positions

Hose statlons will be provided as shown on drawings submitted Novenmer,'.

22, 1976, and will reach safety-related.areas in the Auxiliary and

Turbine Buildings with 100 fthoses,.,

Detectors will be provided In areas described in previous submittals.

Installation of smoke detectors"in all locations containing safety-relatedequipment is considered unnecessary based on construction of the safeshut-.

down facility.

11. The Equipment Rooms contain redundant cables andthe Control Room.

doors are alarmed to

The details for the safe shutdownlater date.

12. Portable smoke purge fans with atprovided.

facility doors will be provided at a

least 3700 CFM capacity will be

14 Twenty-flve dedual-circuit sound powered phone'stations are located In theReactor Building along with a separate sound poered phone circuit in the

refueling area of the Reactor Building. In addition, telephone and public

address system.communication facilities are available Inside the Reactor

Building. .

All the systems described above provide communication between the ReactorBuilding and areas of the Auxiliary Buildlng.. .Jncluding the Control Room..

Because of,.the high level of duplication of diverse communication systemswithin the Reactor Building, we do not feel. the installation of fixedrepeaters in the Reactor Building is warranted.

'I

EDB-i January 25, 1978

'S. .

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17. Th shedulea fo the-testing of able penetratior fire stops for Oconee..

Is 'ias .fol lows:1. Performance .of- tests -Week of February 13, 1978

2. Preliminary Report to be given orally to NRC Staff - Week of

" February 27, 1978

3. Submittal of Final Test Reports - April 1, 1978

WJF/kss

.1/25/78

• ''I.

-Additional

2. ) "Included In th

4• Provided at Janus

InformationwRequired For'The Oconee E, 2, aFire Protection Revision

.Telecopled January 16, '1978

i•s submittal.

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rid 3

"I-."""1' "4'

iry 18i 1978, meeting.

5.))6. )

) Included in this submittal.

7. ))8. )

9. Provided at January 18, 1978, meeting.

10. There will be 8 - 7.5 volt sealed beamli'ghts and 9 - flashlights provided

for the. fire brigade..

11. Included in this response.

12. The fire hazard analysis did consider the affect of water spray on safety-

related systems.

13'. Hose racks, connected to the LPSW System, will be provided in the

Buildings,. Details for the systems will be provided as design. isReactor

completed.

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EOB-I January 25, 1978

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4.