IR 05000410/1985034
| ML17055C080 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 02/26/1986 |
| From: | Haughey M Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8607240094 | |
| Download: ML17055C080 (40) | |
Text
Docket No. 50-410 February 26, 1986 APPLICANT:
Niagara Mohawk Power Corporation (NMPC)
FACILITY:
Nine Mile Point Nuclear Station, Unit 2 (NMP-2)
SUBJECT:
SUMMARY OF MEETING HELD WEDNESDAY, JANUARY 29, 1986, WITH NMPC TO DISCUSS FIRE PROTECTION FOR NMP-2 On January 29, 1985, the NRC staff met with representatives of NMPC and their consultants from Stone and Webster Engineering Corporation (SWEC)
and Compis Services (CS) to discuss fire protection for NMP-2.
This meeting was a follow-up to the Appendix R site audit of NMP-2 performed the week of October 21, 1985, and documented in Inspection Report No. 50-410/85-34.
Enclosure 1 to this meeting summary is a handout provided by NMPC discussing proposed responses to Appendix R Audit Unresolved Items.
Below is a summary of the discussion at the January 29, 1986, meeting relating to each of these items.
/
(1)
Hatch Area and 20 ft. Fire Break Zones Enclosure 1 indicates this activity will be "ready to support the fuel load."
NMPC was informed that this action would need to be completed a period of time before fuel load in order to allow the NRC staff to be able to inspect the completed action.
NMPC indicated this activity is expected to be complete by February 24, 1986.
(2)
Fire Proofing of Structural Steel NMPC is attempting to show that fire proofing of structural steel is not needed on the 'ba'sis that the effects of fire on structural members (i.e. deformation)
are acceptable.
NMPC stated that the building temperature would not follow a time-temperature curve because heat would "bleed-off" to the rest of the building.
The NRC staff staled that NMPC would be taking a risk that the fuel load schedule could be effected by trying to establish a new method this close to licensing.
The.NRC staff requested NMPC consider issuing an already accepted method for fire protection of structural steel if the analysis to be provided does not provide sufficient justification for not protecting structural steel.
The use of ASTM fire curves as a basis for determining damage to structural members in a fire would be acceptable to the NRC.
NMPC will use ASTM fire curves wherever possible.
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The NRC staff stated that a structural review of the proposed analysis may be required and as no structural reviewers were present the staff did not know what, if any, questions might be asked in the structural area.
(3)
Fire Seals NMPC needs to provide a letter of commitment that fire seals will be replaced with rated seals.
(4)
Fire Detectors NMPC needs to provide a letter of commitment on fire detectors.
(5)
Fire Dampers NMPC needs to amend the FSAR to include commitments on fire proofing of the HVAC duct penetrating the diesel generator fuel oil day tank enclosure.
(6)
NFPA Deviations (see enclosure 3)
(a)
NFPA 20 7.111, 7.6 - Kubicki will talk to John Stang (former NRC reviewer) about the fire pump.
(b)
NFPA 20 7.3.5 - (fuses)
NMPC needs to include the following in their justification:
i)
Why is this not a problem if there is no fire?
ii)
Why is this not a problem if there is a fire in the pump room?
(iii)
Why is it not a problem if there is a fire in any other area of the plant?
(c)
NFPA 72D 2.2.2 (non-UL listed controls)
NMPC needs to add the explanation non-UL listed controls are in UL listed cabinets etc.
(d)
/
More information needs to be provided.
Enclosure 2 to this meeting summary is a handout provided by NMPC discussing proposed responses to issues "raised during the Appendix R audit but not included in the.inspection rep'ort.
A summary of the discussion at the January 29, 1986, meeting relating to each. of these items is included below:
(1)
NMPC will be.sub'mi'tting,a letter to the NRC to discuss changes to the FSAR to justify removing fire protection technical specification ~ A j
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(6)
Bus du'ct penetrations are only located in exterior walls.
"Unapproved" penetrations and seals designates those not yet completed.
NMPC does not need to submit anything additional on this issue.
Fire dampers
- In-plant tests on fire dampers still need to be com-pleted.
Tests are expected to be completed by 2/24/86.
Stratification NMPC needs to provide a letter commitment on the 3 areas discussed (RB Refueling Floor, RB and Service Water Pump Bay)
NMPC also needs to discuss why other areas are acceptable.
Halon and C02 Suppression Systems-NMPC to provide a list of concerns.
Appendix R boundaries NMPC needs to review which walls need to be under surveillance.
Sealing criteria around vertical cable trays is addressed in Amendment 23.
(s)
Flood troughs - additional sprinkler heads are to be provided.
Commit-ment needs to be added to the FSAR.
In addition to the items discussed above the following items were discussed.
Pull-stretch tests on fire hose (2)
(3)
NMPC needs to state the hydraulic calculations have also been completed.
Cable tray suppression NMPC needs to provide a discussion of what is in the plant (plant criteria), what does not meet plant criteria, and why it is okay to load fuel with the exceptions to plant criteria.
Plant status -
NRC needs to know ASAP what will not be completed before fuel load.
A copy of the meeting attendees is included as enclosure 4.
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MHaughey/hmc 2//i!!/86 y F. Haughey, Project Manager BWR Project Directorate No.
Division of BWR Licensing
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Mr. B.
G. Hooten Niagara Mohawk Power Corporation Nine Mile Point Nuclear Station Unit 2 CC:
Mr.'roy B. Conner, Jr.,
Esq.
Conner 5 Wetterhahn Suite 1050 1747 Pennsylvania Avenue, N.W.
Washington, D.C.
20006 Richard Goldsmith Syracuse University College of Law
'.
I. White Hall Campus Syracuse, New York 12223 Ezra I. Bialik Assistant Attorney General Environmental Protection Bureau New York State Department of Law 2 World Trade Center New York, New York 10047 Resident Inspector Nine Mile Point Nuclear Power Station P. 0.
Box 99 Lycoming, New York 13093 Mr. John-W.
Keib, Esq.
Niagara Mohawk Power Corporation 300 Erie Boulevard West Syracuse, New York 13202 P
Mr. James Linville U. S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, Pennsylvania 19406 Norman Rademacher, Licensing Niagara Mohawk Power Corporation 300 Erie Boulevard West Syracuse, New York 13202 Regional Administrator, Region I U.S. Nuclear Regulatory.'Commission 631 Park Avenue King of Prussia, Pennsylvania 19406 Mr. Paul D.
Eddy New York State Public Service Coranission Nine Mile Point Nuclear Station,-
Unit II Post Office Box 63 Lycoming, New York 13093 Don Hill Niagara Mohawk Power Corporation Suite 550 4520 East West HighWay; Bethesda, Maryland 20814
~
EiVCLOSURH I APPENDIX R AUDITUNRESOLVED IT MS ITEiM LICENSEE'S DISPOSITION HATCH AREA AND 20 FT. FIRE BREAK ZONES (20'FBZ)
(MK.-2)
Area suppression coverage and open hatches protec-tion is being added in the 20 Ft fire break zone areas of the reactor building. The proposed design calls for the physical expansion of the two existing nor th and south systems, requiring no electrical changes to implement it.
The capacity of each system will-be sized for the in-creased demand of the Reactor Building 20 Ft. Fire Break Zone as well as 300 G.P..'ii. t'or future storage areas.
. It is expected that this ongoing activity will be ready to support the fuel load. See Attachement 1.
(EEcDCR No. 71422).
(Unresolved Item No.50-410/S5-3~-01).
FIRE PROOFING OF Based upon NRC discussions on January 10, 1986, it STRUCTURAL STEEL was indicated that a four phase approach to fire (RAS-2)
proofing structural steel was necessary. As a result. we have completed a review of the Reactor Building steel and its associated fire loading. By addressing struct-ural failure under fire conditions, the following con-clusions have been reached as a result of '.he review of the applicable areas.
1. Equipment required to provide Safe Shutdown capability is adequatelv located on each hall of the Reactor Building separated by a 20 Ft. Fire Break Zone.
Z. Early warning detection is provided thoughout all N'ea5 coataiaiag eafcty retatod aquicrcnant ar cable trays in the Reactor Building.
Page
5. Credit taken for protection ol fire hazards by automatic suppression systems has substantia!!y reduced fire loadings in the Reactor Bui!din" in a majority of cases to less than ten t10! minutes dur ation.
Refer to Summary Fire Loading Tables P2R and P3. The Reactor Building steel is primarily comprised of heavy unprotected framed steel members (%27,W36). Potential impacts on a steel member, given the loading willproduce. at best, localized deformation in the immediate fire area. Failure of members impacting redundant equipment across a fire barrier or fire break zone is not considered a credible scenario.
Some assumptions made in performing the PLC struc-tural steel evaluation are not applicable to the layout of structures at Nine blile Point Unit 2. Therefore. the results of the analysis may not provide practical out-puts in view of the ezisting conditions. Some namoies include:
I. Fire ~alls separate all redundant equipment.
Z. A distinct localized volume exists for each analyzed area.
3. Any protected or unprotected cable tray located within three (3) feet of steel causes steel member failure.
In view of the existing conditions and current protec-tion provided. the structural failure of stee! members in the Reactor Building is not expected 10 impact re-dundant Safe Shutdown equipment based on the in-fo'ation identified.
(Unresolved Item No. 50-4 l 0/85-34-02'!.
FIRE SEALS IN CONSTRUCT ION
~OINTS (az-4B)
The requirement to revise design of non-rated con-struction joints to allow installation in rated walls is proceeding per the attached schedule. See Attach-ment 2. (ERDCR No. Z-71443A).
!Unres'olved Item No. 50-410/85-34-05!.
Page 2 FIRE DETECTORS IN Allsafetv related ar ea which contain sa!'eiy relat-SAFETY RELATED ed equipment have been or will be provided a;ith AREAS (AIK-32)
fire detectors as required.
Areas, or small rooms.
without safety related equipment, will not be provided with fire detectors.
(Unresolved Item No. 50-410/85-34 04).
FIRE DAMPERS DG FUEL OIL DAY'ANI'OOhl A HVAC duct which penetrates the fire rated en-closure around the diesel generator (DG) fuel oil day tank willbe enclosed with a 3-HR. fire v rap. This rated barrier is being provided in place of a fire damper.
See Attachements 3A and 3B. (E6DCR's No.
Z-711422B and 71423).
(Unresolved Item No. 50-40/85-34-05)
NFPA DEVIA-TIONS iEY-I J NFPA deviations, clarifications and justifications have been identified and willbe included in table 9.5-3 of the FSAR. {See attachement 4 for deviations. clarifications and justifications).
'Unresolved Item No. 50-410/85-34-06).
EMERGEi tCY BATTERY PACK LIGHT-ING Emeregency battery pack lighting is scheduled to be
"
installed to support the fuel load for those areas needed, for the safe operation of the shutdown equipment, as well as, the access and egress routes thereto, including the areas required to support the control room evacua-tion procedure for remote shutdown. See Attachement 5.
(EfcDCR No. 39602B).
{Unresolved Item No. 50-410/85-34-07).
Page 3
ITEMS ENCLOSURE 2 NON-AUDITFIRE PROTECTION ITEibIS a
LICENSEE'S DISPOSITION REMOVALFIRE Ve are removing all fire related items from the Techni-PROTKTION cal Specifications. They willbe decscribed in detail in.
PROGRAM FROM the FSAR subject to NRC approvaL This ammend'ment TECH. SPECS. TO willbe submitted later.
THE FSAR PENETRATIOYS
. There is a program scheduled to complete all of the AND SEALS safety related penetrations and seals by fuel load.
(MK-4A)'on-safety related penetrations and seals willbe
. completed after fuel load. Eleven (ll) tests reports covering approximately twenty eight (28) unapproved configurations willbe provided. See Attachement 6 for test report. (E&DCR No. 71443A)
FIRE DAiWIPERS At Nine Mile Point Unit 2, most of the fire dampers were (AK-I)
tested at the factory under fullflow conditions prior to shipment. Twenty three (25) dampers manufactured by Pacific Air Products Company (PAPCO'! remain to be tested that, potentially would not close under full air flow conditions. It was noted. however, that these dampers would partially close restricting air flow within the system.
Page l As a result of the restricted air flow. low-flow switches associated with these fans for the HVAC systems can be calibrated to trip out the fan on low flow. With the fan tripoed, air flowwould cease and the dampers willclose.
System low-flowinterlocks willbe operational during testing and credit will be taken for them to activate.
allowing the dampers to close. Allof the dampers at 5:ilP Linit 2 willbe mechanically cycled to verily mechanical closure. The results of this mechanical cycling willbe documented by Start-Up, and the results of the P <<PCO air flow test, willbe available for NRC revie STRATIFICA-TION (iKIV-20)
Three plant areas exhibit the potential for stratification and are resolved as follows:
1. The Reactor Building Refueling Floor. elev. 357-0" The Safe Shutdown capability in this area willnot be affected by a fire. The HVACSystem is designed such that normal floor-to-ceiling movement of air willassist smoke to reach ceiling mounted detectors with sufficient time to alert the control room operator and fire brigade.
{DSI'-13)
2. Reactor Building. Elevation 196'-0's steel grating:
At elev. 195'-0" additional smoke and heat col!ectors are to be installed above safety related equiptment specilica!ly to address the potential problem of stratification and does not represent an installation designed to meets require-ments of NFPA 72E. Since these areas have two levels of detection, including the elevation 215'-0" which is installed to meet the requirements of NFPA 72E, they will promptly alert the control room operator and fire brigade.
See Attachement 7.(EE DCR No. 71403D).
3. Service Pater Pump Bay. Elev. 224'-0" Two levels of detection willbe provided: one at the ceiling, elev. 276'-0" and the other above the safety related equipment at elev. 232'/239'-0". It is not intended that this insta!lation meet the requirements of NFPA 72E. The two levels of detection are being added sole!y to resolve the potential problem of stratification as weH as to provide detectors in areas with safety related equipment.
This arrangement willprovide prompt notification to the control room operators and fire brigade personel. See Attachment 8.( E6 DCRs No,71401 6 71403E).
HALON AND C02 SUPPRES-SION SYSTEM IS The concentration tests for these systems willbe complet-ed prior to fuel load and the results willbe supplied for review as requested.
APPENDIX R BOUNDARIES REQUIRED FOR SAFE SHH DOWN (EY-1j The minimum Appendix R boundaries have been!dent!l !-
ed and the FSAR drawings willbe changed to reflect these required boundaries.
Page 2
SEALING CRITERIA AROUND VERTICAL CABLE TRAYS IN THE REACT-OR BLDG.
(iVK-22)
This criteria is being changed as shown in amendment
of the FSAR, Subsection 9A.3.1.2.5.10, to reflect its intent of providing additional good pratices.
FLOOD TROUGH To resolve this case of competing criterias of flood control REACTOR BLDG. vs. penetration sealing.
additional sprinkler heads will ELEV. 175'-0" be added at these openings to provide protection.
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l/28/86
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Nine Mile Point Unit 2 FSAR Table 9.5-3 Deviations from NFPA Standards NPFA Standard Section Deviation Justification NFPA 10 3 ~ 1 ~ 2 ~ 1 Deviation:
Complete protection of buildings with Class A extinguishers not provided.
Justification:
Class A units are provided where Class A
materials are present; balance of stations covered by B.-C.
units.
Entire station is covered by hose stations.
NFPA 13 (also applies to NFPA 14 g 15/
16 and 24)
NFPA 13 2 ~ 7 ~ 1 3.14.2.1 Deviation:
Fire department connections are not provided at Nine Mile 2.
Justification:
Backup for site pumps is provided by interconnection with Nine Mile 1.
City supply provides limited capability.
150 psi pump pressures are sufficient.
Deviation:
Non-listed steel bodied valves are used on the interior fire main loop.
Justification:
The interior fire main loop is of welded steel construction for reli-ability.
Steel valves are consistent with this design.
NFPA 13 (also applies to NFPA 15 and 16)
3.17.6 Deviation:
The normal solenoid valve used on the listed Viking deluge valves have been replaced with dual motor operated valves.
Justification:
There was con-cern for accidental system operation or premature shutdown in the event of loss of power to the valves.
Dual MOVs powered by separated circuitry were therefore employe a
"2 NFPA 13 4.3.4.1 Deviation:
Sprinklers in parts of the Reacter Building 20 ft. zone and the Condensate Storage Tank Building are located up to 22" below the floor slab.
NFPA 13 7.1.1.2 Justification:
Some floor supports employ 20" steel beams closely spaced.
A 22" slab clearance permits proper floor coverage without employ-ing an excessive number of sprinklers.
Deviation:
On some cable tray nozzle drops, short 1/2" nipples no more than 6" long or close 1/2" nipples were used.
Justification:
To correct misinstalled cable tray sprinklers located in excess of 8" from trays, short nipples or 1/2" nipples increased to 1" pipe (per section 3.8.4)
were used.
The increase in friction loss is negligible.
NFPA 13 3.16 '.2 Deviation:
1/4" orifice fused nozzles are used for cable tray sprinkler systems.
Justification:
Small orifice nozzles were required to meet the application criteria of NFPA 15 with reasonable water rates.
Scale buildup is mini-mized since drops supplying nozzles are normally water filled. All such systems are provided with individual system strainers.
NFPA 14 3.2.1 Deviation:
Portions of some buildings are not within 30'f a nozzle attached to 100'f 1 1/2" hose.
Justification:
Xt is proposed to temporarily correct the condition by mounting
additional hose where required at the existing hose stations.
A permanent solution will involve installation of six additional hose stations plus requesting a permanent vari-ance for 150'f hose at 13 of the plant hose stations.
See attached prints for clarification.
NFPA 14 7'.1 Deviation:
Installed pressure gauges are not provided at the top of each standpipe with the exception of the four standpipes in the Reactor Building.
Justification:
Pressure readings on all standpipe risers can be taken with a portable gauge.
This arrangement has been accepted by Mr. Krasopoulos of Region
(12/11/85).
NFPA 15 (also applies to NFPA 13)
4.4.1.4 Deviation:
The cable tray sprinkler system employs design elements of NFPA 13 and 15.
NFPA 16 1'.1 Justification:
NFPA 15 spec-fies coverage requirements for cable trays using open nozzles.
NFPA 13 deals with area protection using fused sprinklers or nozzles.
Elements of both standards were employed for design as they applied.
Fused nozzles were chosen to limit potential water damage to equipment.
Deviation:
The foam-water sprinkler systems protecting the turbo-generator area are designed for automatic actua-tion of water and.manual injection of foam.
Justification:
Accidental foam operation can present a
problem in the radwaste system.
Automatic operation
of water employs a 0.2 gpm/ft2 density (0.16 required).
The fire department or the Control Room can actuate the foam pumps if required.
This is in general accord with Section 1.4.1
~
NFPA 20 7.111 7.6 Deviation:
The electric fire pump is powered by a 4KV motor which is controlled by an unlisted, circuit breaker.
Justification:
NFPA 20 permits use of high voltage motor starters, none of which are U.L. listed.
The starter used was evaluated by a U.L.
engineer to assure compliance with the requirements of NFPA 20.
This procedure was acceptable to Mr. John Stang of NRR.
NFPA 20 NFPA 20 NFPA 20 9.5.2.7 7.5.2.4 9.5.2.4 7.3.5 Deviation:
The diesel driven fire pump is not equipped with a weekly program timer.
Justification:
Station pro-cedure recpxires a 30-minute operating test of the pump weekly.
Deviation:
Timing devices to prevent simultaneous start are not provided on the electric and diesel pump controllers.
Justif ication:
Cranking time of a diesel engine will produce a 5-10 second delay in coming up to speed when compared with an electric motor driven pump.
Hence, timer devices merely compli-cate the control circuitry.
Deviation:
Control circuits in the motor starter are fused.
Justification:
This is a deviation from Standard 20 and is so listed in the J NFPA 24 8.1.1 report.
Fuse failure will cause a trouble alarm to be transmitted to the Control Room.
Justification for the presence of fuses will be supplied.
Deviation:
In a few cases, the depth of cover of the underground fire mains is less than 1 foot in excess of the frost line.
Justification:
In all cases, the cover exceeds the worst-case frost line for the area.
NFPA 24 NFPA 30 8.6.2.8 2.4.2 Deviation:
Restraining devices and fasteners for portions of the underground piping were not coated with a corrosion retarding material.
Justification:
An engineering analysis
.,was conducted to establish that possible degradation of piping hardware would not adversely affect the fire system for the expected life of the plant.
Deviation:
The day tanks for the emergency diesel genera-tors are provided with emer-gency vents to the day tank rooms.
NFPA 72D 2.2 '
Justification:
The day tanks are provided with adequate outside vents for normal operation.
The emergency vents are equipped with oil filled loop seals.
These vents would function only if the normal vents were damaged by tornado action.
The operability of the generators is thereby assured.
Deviation:
The Control Room and local fire panels are not U.L. liste Justification:
The panels were constructed te meet the specific needs of the station; the components employed are properly listed; and they meet the intent of U.L. Standard 864 "Control Units for Fire Protective Signalling Systems."
NFPA 72D
~ 3 ~ 1 Deviation:
Manual pull fire alarm boxes are not used in station.
Justification:
The Nine Mile 2 Gaitronics two-way public address system in designed and installed to provide fire reporting capability in accordance with the intent of NFPA 72D.
NFPA 72D 2.2.2 Deviation:
Position switches used on steel body fire line valves are not listed for fire system use.
Justification:
Because of the difference in body size and shape of steel valves compared with U.L. listed iron body valves, listed position switches cannot be satisfacto-rily mounted.
High grade commercial limit switches were therefore used on steel valves.
NFPA 72E 4.3.7 Deviation:
For structural conditions involving beams in excess of 18" deep and spaced less than 8'part, smoke detectors are mounted on the bottom flange of alternate beams.
Justification:
NFPA 72E is silent on the acceptable coverage under the structural configuration noted.
The chosen arrangement was re-viewed with the 72E Chapter
Subcommittee Chairman, justification submitted in
C
answer to DSER 96, and was found acceptable by Mr.John Stang on 8/1/84.
NFPA 80 1.6.1 Deviation:
Non-listed 'fire doors are used at Nine Mile 2.
Justification:
For doors with multiple requirements including missle protected, pressure-tight, and radiation shielding, non-listed doors are employed and analyses are provided to demonstrate their capability of performing satisfactorily as fire doors at the locations where installed.
NFPA 90A 2. 1.4. 1 Deviation:
Service openings not provided adjacent to duct installed smoke detectors.
Justification:
Duct-type smoke detectors used can be serviced from the outside of the duct.
NFPA 90A 2.1.4.3 Deviation:
Service openings are not provided at 20'ntervals along the duct and at the base of vertical risers.
Justification:
Service openings are provided where required for system maintenance.
NFPA 90A 3.3 ' '
'
Deviation:
Fire dampers are installed in a manner similar to but not exactly in accord with manufacturers'ecommendations.
Justification:
In some instances, fire damper installations are modified to facilitate HYAC system construction.
Requested modifications received prior review and approval of the engineers'ire protection specialist.
These approvals
are documented and maintained on file.
NFPA 90A 9.3 Deviation:
HVAC system fans are not arranged to shut down automatically on fire detector operation.
Justification:
The Nine Mile 2 systems are incorporate low flow shutoffs.
For a fire in most areas, fire damper operation would cause the low flow shutoff to function.
This arrangement also is employed to guarantee total damper closure and is so teste LIST OF ATTENDEES FOR MEETING HELD JANUARY 29, 1986 NAME Mary Haughey Dennis Kubicki Don Sutton Richard Schulman Robert W. Hammelmann Elden E. York John L. Ford John R. Corcoran Norm Rademacher ORGANIZATION NRC - Licensing Project Manager NRC - Fire Protection Engineer SWEC - Fire Protection Coordinator NMPC - Associate Project Engineer NMPC - Lead Project Engineer - Mechanical Compis Services
- Licensing Consultant Compis Services
- Licensing Consultant NMPC - Supervisor - Fire Protection NMPC - Licensing
MEETING SUMMARY DISTRIBUTION cket No(s):
50-410 NRC PDR Local PDR BWD ¹3 r/f J. Partlow (Emergency Preparedness only)
E.
Adensam Attorney, OELD E. Jordan B. Grimes ACRS (10)
Project Manager E. Hylton NRC PARTICIPANTS M. Haughey D. Kubicki bcc:
Applicant 5 Service List
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