ML020320491

Enclosure to Proposed Staff Guidance on Aging Management of Fire Protection Systems for License Renewal

ML020320491
Person / Time
Site:	PROJ0690
Issue date:	01/28/2002
From:	Charemagne Grimes Division of Regulatory Improvement Programs
To:	Lochbaum D, Alexis Nelson Nuclear Energy Institute, Union of Concerned Scientists
Strnisha J, NRR/DRIP, 415-1092
References
Download: ML020320491 (9)

Text

Enclosure 2 XI.M26 FIRE PROTECTION Program Description For operating plants, the fire protection aging management program (AMP) includes a fire barrier inspection program and a diesel-driven fire pump inspection program. The fire barrier inspection program requires periodic visual inspection of fire barrier penetration seals, fire barrier walls, ceilings, and floors, and periodic visual inspection and functional tests of fire rated doors to ensure that their operability is maintained. The diesel-driven fire pump inspection program requires that the pump be periodically tested to ensure that the fuel supply line can perform the intended function. The AMP also includes periodic inspection and test of halon/carbon dioxide fire suppression system.

Evaluation and Technical Basis

1. Scope of Program: For operating plants, the AMP manages the aging effects on the intended function of the penetration seals, fire barrier walls, ceilings, and floors, and all fire rated doors (automatic or manual) that perform a fire barrier function. It also manages the aging effects on the intended function of the fuel supply line. The AMP also includes management of the aging effects on the intended function of the halon/carbon dioxide fire suppression system.

2. Preventive Actions: For operating plants, the fire hazard analysis assesses the fire potential and fire hazard in all plant areas. It also specifies measures for fire prevention, fire detection, fire suppression, and fire containment and alternative shutdown capability for each fire area containing structures, systems, and components important to safety.

3. Parameters Monitored/Inspected: Visual inspection of 10% of each type of penetration seal is performed during walkdowns carried out at least once every refueling outage. These inspections examine any sign of degradation such as cracking, seal separation from walls and components, separation of layers of material, rupture and puncture of seals which are directly caused by increased hardness and shrinkage of seal material due to weathering. Visual inspection of the fire barrier walls, ceilings, and floors examines any sign of degradation such as cracking, spalling, and loss of material caused by freeze-thaw, chemical attack, and reaction with aggregates. Hollow metal fire doors are visually inspected at least once bi-monthly for holes in the skin of the door. Fire door clearances are also checked at least once bi-monthly as part of an inspection program. Function tests of fire doors are performed daily, weekly, or monthly (which may be plant specific) to verify the operability of automatic hold-open, release, closing mechanisms, and latches.

The diesel-driven fire pump is under observation during performance tests such as flow and discharge tests, sequential starting capability tests, and controller function tests for detecting any degradation of the fuel supply line.

Periodic visual inspection and function test at least once every six months examines the signs of degradation of the halon/carbon dioxide fire suppression system. The suppression agent charge pressure is monitored in the test. Material conditions that may affect the performance of the system, such as corrosion, mechanical damage, or damage to dampers, are observed during these tests. Inspections performed at least once every month verify that the extinguishing agent supply valves are open and the system is in automatic mode.

4. Detection of Aging Effects: Visual inspection of penetration seals detects cracking, seal separation from walls and components, and rupture and puncture of seals.

Visual inspection (VT-1 or equivalent) of 10% of each type of seal in walkdowns is performed at least once every refueling outage. If any sign of degradation is detected within that 10%, the scope of the inspection and frequency is expanded to ensure timely detection of increased hardness and shrinkage of the penetration seal before the loss of the component intended function. Visual inspection (VT-1 or equivalent) of the fire barrier walls, ceilings, and floors performed in walkdown at least once every refueling outage ensures timely detection for concrete cracking, spalling, and loss of material. Visual inspection (VT-3 or equivalent) detects any sign of degradation of the fire door such as wear and missing parts. Function tests promptly detect deficiencies in operational conditions. Periodic visual inspection and function tests detect degradation of the fire doors before there is a loss of intended function.

Periodic tests performed at least once every refueling outage, such as flow and discharge tests, sequential starting capability tests, and controller function tests performed on diesel-driven fire pump ensure fuel supply line performance. The performance tests detect degradation of the fuel supply lines before the loss of the component intended function.

In the test of the halon/carbon dioxide fire suppression system, the suppression agent charge pressure is verified to be within in the normal band. Visual inspections of the halon/carbon dioxide fire suppression system detects any sign of degradation, such as corrosion, mechanical damage, or damage to dampers. The periodic function test and inspection performed at least once every six months detects degradation of the halon/carbon dioxide fire suppression system before the loss of the component intended function. The monthly inspection ensures that the extinguishing agent supply valves are open and the system is in automatic mode.

5. Monitoring and Trending: The aging effects of weathering on fire barrier penetration seals are detectable by visual inspection and, based on operating experience, visual inspections performed at least once every refueling outage to detect any sign of degradation of fire barrier penetration seals prior to loss of the intended function.

Concrete cracking, spalling, and loss of material are detectable by visual inspection and, based on operating experience, visual inspection performed at least once every refueling outage detects any sign of degradation of the fire barrier walls, ceilings, and floors before there is a loss of the intended function. Wear, missing parts, or holes in the fire door are detectable by visual inspection and, based on operating experience, the visual inspection and function test performed bi-monthly which detects degradation of the fire doors prior to loss of the intended function.

The performance of the fire pump is monitored during the periodic test to detect any degradation in the fuel supply lines. Periodic testing provides data (e.g., pressure) for trending necessary.

The performance of the halon/carbon dioxide fire suppression system is monitored during the periodic test to detect any degradation in the system. These periodic tests provide data necessary for trending.

6. Acceptance Criteria: Inspection results are acceptable if there are no visual indications of cracking, separation of seals from walls and components, separation of layers of material, or ruptures or punctures of seals, no visual indications of concrete cracking, spalling and loss of material of fire barrier walls, ceilings, and floors, no visual indications of missing parts, holes, and wear and no deficiencies in the functional tests of fire doors. No corrosion is acceptable in the fuel supply line for the diesel-driven fire pump. Also, any signs of corrosion and mechanical damage of the halon/carbon dioxide fire suppression system are not acceptable.

7. Corrective Actions: For fire protection structures and components identified within scope that are subject to an aging management review for license renewal, the applicant is to expand the scope of the 10 CFR Part 50, Appendix B, program to include these in-scope structures and components to address corrective actions, confirmation process, and administrative controls for aging management during the period of extended operation. This commitment is documented in the final safety analysis report (FSAR) supplement in accordance with 10 CFR 54.21(d). As discussed in the appendix to this report, the staff finds the requirements of 10 CFR Part 50, Appendix B, acceptable to address corrective actions, confirmation process, and administrative controls.

8. Confirmation Process: See Item 7, above.

9. Administrative Controls: See Item 7, above.

10. Operating Experience: Silicone foam fire barrier penetration seals have experienced splits, shrinkage, voids, lack of fill, and other failure modes (IN 88-56, IN 94-28, and IN 97-70). Degradation of electrical racing way fire barrier such as small holes, cracking, and unfilled seals are found on routine walkdown (IN 91-47 and GL 92-08). Fire doors have experienced wear of the hinges and handles. Operating experience with the use of this AMP has shown that no corrosion-related problem has been reported for the fuel supply line, pump casing of the diesel-driven fire pump, and the halon/carbon dioxide suppression system. No significant aging related problems have been reported of fire protection systems, emergency breathing and auxiliary equipment, and communication equipment.

References NRC Generic Letter 92-08, Thermo-Lag 330-1 Fire Barrier, December 17, 1992.

NRC Information Notice 88-56, Potential Problems with Silicone Foam Fire Barrier Penetration Seals, August 14, 1988.

NRC Information Notice 91-47, Failure of Thermo-Lag Fire Barrier Material to Pass Fire Endurance Test, August 6, 1991.

NRC Information Notice 94-28, Potential problems with Fire-Barrier Penetration Seals, April 5, 1994.

NRC Information Notice 97-70, Potential problems with Fire Barrier Penetration Seals, September 19, 1997.

XI.M27 FIRE WATER SYSTEM Program Description This aging management program applies to water-based fire protection systems that consist of sprinklers, nozzles, fittings, valves, hydrants, hose stations, standpipes, water storage tanks, and aboveground and underground piping and components that are tested in accordance with the applicable National Fire Protection Association (NFPA) codes and standards. Such testing assures the minimum functionality of the systems.

Also, these systems are normally maintained at required operating pressure and monitored such that loss of system pressure is immediately detected and corrective actions initiated. In addition to NFPA codes and standards, which do not currently contain programs to manage aging, portions of the fire protection sprinkler system, which are not routinely subjected to flow, are to be subjected to full flow tests at the maximum design flow and pressure before the period of extended operation (and at not more than 5-year intervals thereafter). In addition, a sample of sprinkler heads is to be inspected by using the guidance of NFPA 25, Section 2.3.3.1. This NFPA section states that where sprinklers have been in place for 50 years, they shall be replaced or representative samples from one or more sample areas shall be submitted to a recognized testing laboratory for field service testing. It also contains guidance to perform this sampling every 10 years after the initial field service testing. In addition to NFPA codes and standards, which do not currently contain programs to manage aging, portions of the fire protection sprinkler system that are not routinely subjected to flow are to be subjected to full flow tests at the maximum design flow and pressure before the period of extended operation (and at not more than 5-year intervals thereafter). Finally, portions of fire protection suppression piping located aboveground and that are exposed to water areshall be disassembled and visually inspected internally once every refueling outage non-intrusively inspected (e.g., ultrasonic testing) to ensure that corrosion aging effects are managed and that wall thickness is within acceptable limits. These inspections are performed before the end of the current operating term, after the 50-year sprinkler head testing, and at 10-year intervals thereafter during the extended period of operation. The purpose of the full flow testing and internal visual inspections is to ensure that corrosion, microbiological influenced corrosion (MIC), or biofouling aging effects are managed such that the system function is maintained.

Evaluation and Technical Basis

1. Scope of Program: The aging management program focuses on managing loss of material due to corrosion, MIC, or biofouling of carbon steel and cast-iron components in fire protection systems exposed to water. Hose stations and standpipes are considered as piping in the AMP.

2. Preventive Actions: To ensure no significant corrosion, MIC, or biofouling has occurred in water-based fire protection systems, periodic flushing, system performance testing, and inspections are conducted.

3. Parameters Monitored/Inspected: Loss of material due to corrosion and biofouling could reduce wall thickness of the fire protection piping system and result in system failure. Therefore, the parameters monitored are the systems ability to maintain pressure and internal system corrosion conditions. The NRC GL 89-13 recommends periodic flow testing of infrequently used loops of the fire water system at the maximum design flow to ensure that the system maintains its intended function.

4. Detection of Aging Effects: Fire protection system testing is performed to assure required pressures. Internal iInspections of aboveground fire protection piping and the smaller diameter fire suppression piping are performed on system components using non-intrusive techniques (e.g., ultrasonic testing) (when they are disassembled) to identify evidence of loss of material due to corrosion. These inspections are performed before the end of the current operating term, after the 50-year sprinkler head testing, and at 10 year intervals thereafter during the period of extended operation. As an alternative to non-intrusive testing, the work control process may include a visual inspection of the internal surface of the fire protection piping upon each entry to the system for routine or corrective maintenance, as long as it can demonstrated that inspections are performed (based on past maintenance history) on a representative number of locations on a reasonable basis. These inspections must be cable of measuring (1) wall thickness to ensure against catastrophic failure and (2) the inner diameter of the piping as it applies to the flow requirements of the fire protection system. If the environmental and material conditions that exist on the interior surface of the below grade fire protection piping are similar to the conditions that exist within the above grade fire protection piping, the results of the inspections of the above grade fire protection piping can be extrapolated to evaluate the condition of below grade fire protection piping. If not, additional inspection activities are needed to ensure that the intended function of below grade fire protection piping will be maintained consistent with the current licensing basis for the period of extended operation. Repair and replacement actions are initiated as necessary. Continuous system pressure monitoring, periodic system flow testing performed, and internal inspections of aboveground piping are effective means to ensure that corrosion and biofouling are not occurring and the systems intended function is maintained. In addition, general requirements of existing fire protection programs include testing and maintenance of fire detection and suppression systems and surveillance procedures to ensure that fire detectors, as well as fire suppression systems and components, are operable.

Visual inspection of yard fire hydrants performed once every six months ensures timely detection of signs of degradation, such as corrosion. Fire hydrant hose hydrostatic tests, gasket inspections, and fire hydrant flow tests, performed annually, ensure that fire hydrants can perform their intended function and provide opportunities for degradation to be detected before a loss of intended function can occur.

Sprinkler systems are inspected before the end of the current operating term, after the 50-year sprinkler head testing, and at 10-year intervals thereafter during the extended period of operationonce every refueling outage to ensure that signs of degradation, such as corrosion, are detected in a timely manner.

5. Monitoring and Trending: System discharge pressure is monitored continuously.

Results of system performance testing are monitored and trended as specified by the NFPA codes and standards. Degradation identified by non-intrusive or internal inspection is evaluated.

6. Acceptance Criteria: The acceptance criteria are (a) the ability of a fire protection system to maintain required pressure, (b) no unacceptable signs of degradation observed during non-intrusive or visual assessment of internal system conditions, and (c) that no biofouling exists in the sprinkler systems that could cause corrosion in the sprinkler heads.

7. Corrective Actions: For fire water systems and components identified within scope that are subject to an aging management review for license renewal, the applicant is to expand the scope of the 10 CFR Part 50, Appendix B, program to include these in-scope systems and components to address corrective actions, confirmation process, and administrative controls for aging management during the period of extended operation. As discussed in the appendix to this report, the staff finds the requirements of 10 CFR Part 50, Appendix B, acceptable to address corrective actions, confirmation process, and administrative controls.

8. Confirmation Process: See Item 7, above.

9. Administrative Controls: See Item 7, above.

10. Operating Experience: Water-based fire protection systems designed, inspected, tested and maintained in accordance with the NFPA minimum standards have demonstrated reliable performance.

References NFPA 25: Inspection, Testing and Maintenance of Water-Based Fire Protection Systems, 1998 Edition.

NRC Generic Letter 89-13, Service Water System Problems Affecting Safety-Related Equipment, July 18, 1989 Table 3.3-2. FSAR Supplement for Aging Management of Auxiliary Systems (continued)

Program Description of Program Implementation Schedule*

Compressed air monitoring (BWR/PWR)

The program consists of inspection, monitoring, and testing of the entire system, including (1) frequent leak testing valves, piping, and other system components, especially those made of carbon steel; and (2) preventive monitoring that checks air quality at various locations in the system to ensure that oil, water, rust, dirt, and other contaminants are kept within the specified limits. This program is in response to NRC GL 88-14 and INPOs Significant Operating Experience Report (SOER) 88-01. It also relies on the ASME OM Guide Part 17, and ISA-S7.0.1-1996 as guidance for testing and monitoring air quality and moisture.

Existing program Fire protection (BWR/PWR)

The program includes a fire barrier inspection program and a diesel-driven fire pump inspection program. The fire barrier inspection program requires periodic visual inspection of fire barrier penetration seals, fire barrier walls, ceilings, and floors, and periodic visual inspection and functional tests of fire rated doors to ensure that their operability is maintained.

The diesel-driven fire pump inspection program requires that the pump be periodically tested to ensure that the fuel supply line can perform the intended function. The AMP also includes periodic inspection and test of halon/carbon dioxide fire suppression system.

Existing program Fire water system (BWR/PWR)

To ensure no fouling has occurred in the fire protection system, periodic full flow flush test and system performance test are conducted to prevent corrosion from biofouling of components. Also, the system is normally maintained at required operating pressure and is monitored such that loss of system pressure is immediately detected and corrective actions initiated. The AMP relies on testing of water based fire protection system piping and components in accordance with applicable NFPA commitments. In addition, this program will be modified to included (1) portions of the fire protection sprinkler system that are subjected to full flow tests prior to the period of extended operation and (2) portions of the fire protection system exposed to water are internally visually or ultrasonically inspected.

Program should be modified before the period of extended operation Fuel oil chemistry (BWR/PWR)

The AMP relies on a combination of surveillance and maintenance procedures. Monitoring and controlling fuel oil contamination in accordance with the guidelines of ASTM Standards D1796, D2276, D2709, and D4057, maintains the fuel oil quality. Exposure to fuel oil contaminants such as water and microbiological organisms is minimized by periodic cleaning/draining of tanks and by verifying the quality of new oil before its introduction into the storage tanks.

Existing program