ML14099A367

Preliminary Draft First Round Questions on Fire Protection

ML14099A367
Person / Time
Site:	San Onofre
Issue date:	05/29/1979
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML13303A707	List: ML13303A706 ML14099A367
References
NUDOCS 7907120485
Download: ML14099A367 (13)

Text

{{#Wiki_filter:ENCLOSURE 2 A 17 San Onofre Units 2 and 3 pre mnarT Questions 1.. Page 1-3, Item A.5. Although transient fire loads are difficult to assess for fire loading purposes, they must be considered as the source of a possible exposure fire, particularly in areas containing redundant safe shutdown equipment or cable. Revise your fire hazards analysis to consider such exposure fires in all areas containing safety-related equipment or cable. Such a review should not take credit for "oxygen depletion" based on closure of doors or dampers.

2. Page 1-3, Item B. In this item you state that the fuel loading in "power plants" consists "mostly=of plastic-and-oil,"-yet-i-n your submittal you have not identified any plastics other than battery cases.

Identify any areas of the plant where plastics are used, and indicate the amount of plastic used. Also analyze the effect on safe shutdown of fires in these areas considering the combustible loading and effects of the various products of combustion.

3. Page 1-8, Item 7. Your methods used to determine and define non combustible materials is not in complete agreement with NFPA 220.

Revise your definitions to agree with those in NFPA 220 for non combustible and limited combustible material, and verify that all wrap, insulation, and interior finish material comply (see specifi cally Sections 2-3 and 2-6 of NFPA 220, 1975 Edition).

4. Page 1-20, Item F and prage 111-41.

a.

The fire suppression systems located in containment are isolated from the fire main by a-normally closed containment i.solation "7907120 ft? b'iiL!iIJf/ALi 1WA valve which is manually op rated from the control room via a re mote manu'al switch. Explain the reasons for using manually acti rather than automatically actiavated valves vated valvesAor a wet syand incude information o how a fire situation is verified before the manual valves are activated. Also analyze the effect of any time delay introduced on the postu lated fires in the containment; consider possible effects on the exposed steel structural members as well as safe shutdown systems.

b. Analyze the operating features of the specific deluge valves installed in containment to determine if any adverse effects can be expected due to operation of the release mechanism without static water-prcssure on the-supply-side of the valve-- Also analyze the effect of the pressure surge on both the valve and piping.

5.

Page 1-21, Item G', and page 111-22. Verify that your flooding analysis considered combined sprinkler and hose water runoff for the design flows and duration and also the effects on safety re lated equipment on other elevations -of water runoff through doors and unsealed floor openings.

6. Page I-21, Iten H.

Your fire hazards analysis indicates that many of the barriers (v.ills, floors, ceilings, dampers,

doors, etc.) enclosing safety-related rooms and areas are of 1 or 2 hr.

construction. Your analysis also indicates that the fire loading permnent ly loteod in or exposing some of these areas could pro duce a fire severiLy in excess of the fire barrier ratings. It is our position that all rooms and areas containing safe--shutdown related cable or equipment be provided with minimum 3 hr. rated

walls, floors, ceilings, and penetration seals. Analyze each such area at San Onofre, aud state how compliance will he a tained, or justify your. intentions -to maintain noncompliance.

7. Pages 1-23, 24, Item M and pages 111-32 through 36.

a. Where automatic sprinklers or water spray systems are in stalled, provide the basis for using such systems and include the criteria and rationale to determine the density and spacing.

In clude hydraulic design data for the largest system flow and pres sure to verify that the fire pumps can provide this flow plus 750 gpm for hose streams with the largest pump out of service. bedar - r an d a sp .ite---hepr S s-u__p-e--r .9. Verify that the fire pumps and their controllers are either UL listed or FM approved for fire pump service. Indicate the location of the controllers. d Provide information which demonstrates that the fire pumps and their controllers meet or exceed the requirements of NFPA 20 for such equipment. if. Explain the procedures used to test the fire

pumps, and provide details of pump accetance tests, including flaVis and pressures, for all three pumps.

• [4-1PD1 LI NABEY MAY2 1979

.~4-Eovide-a-detzailed-an alys--o f-the-f i re-pmp-tart-tP n rangement-.

8. Page 1-25, Item N.

It is our position that a second supply be provided for the fire protection systems in containment so that a single failure will not result in the loss of all fire protection water inside containment.

9. Page III-2, Item A.l. Provide the qualifications of the fire protection engineer referred to as required by Appendix A.

10.

Page 111-5, Item A.4 and page 111-37. Describe how water is provided to standpipe hose stations in the event of a Safe Shut down Earthquake.

11.

Page III-11, and page 111-54, Item G.l. Page III-11 states that open flame permits are required only when such operations are performed in the vicinity of flammable materials, while page 111-54 implies-that a permit will always be required to utilize welding or cutting type equipment. Explain the discrepancy.

12.

Page 111-12. It is t-ed-that the fire brigade for each shift consists of 3 It is our position that a minimum.of 4 -7on duty be maintained for fire brigade operations. This may require additional f ve brigade members to fill in for sick time and vacations so that a minimum of Qrfire brigade members are on duty at all times.

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13.

Page 111-20. Redundant safe shutdown system cable separation in accordance with Rult o-ry ui dc .75 i u not 'n::i'erce .ampro protection from the effects of exposure fires, such as fires in transient combustibles. It is our position that an automatic water suppression system be installed in all areas where redundant safe shutdown equipment or cable is not separated by 3 hr. fire rated barriers. In addition, where such equipment or cable is separated by less than T feet, ee trainsof safe shutdown equip 30 ment or cable must be enclosed with at least a F4 minute fire rated barrier.

14. -- Page--41I -Indicate-the --loc-at ion -and--orientation- -of th1e bulk gas storage tanks with regard to the various structures.

15.

Page 111-25. Verify that flammable liquids are not stored in rooms or areas containing saety related equipment or cable.

16.

Page III-23, 25 and 26., and page 1-23, Items J and K. Substantiate the fire resistance capability of the following items as they pertain to safety-related areas or areas exposing safety related areas or high hazard areas by verifying that their con struction is in accordance with.a particular design that has-been fire tested, and identify the design, the test method used and the acceptance criteria: (1) Rated fire Barriers, including floor and ceiling con struction and their supports; (2) Fire dampers/fire doors, as well as how they are instal led in the venti1-ation ducLs that penetrate rated fire barriers of safety-related areas; LLJUULUd MAY 2 9 1979 (3) Fire barrier penetration seals around ducts, pipes, cables, cable trays and in other openings. Verify that all seals are of the thickness specified in the tests, and that cables and rable trays are supported in a manner similar to supporting arrange ments used in any tests.

17.

Page 111-27, Item 4. Ventilation.

a. Describe the procedure employed for heat and smoke removal using fixed or portable equipment in areas that house safety-related systems or components. Describe how these areas can be ventilated for manual firefighting purposes. Consider that control or power cabling for normal ventilation may not be functional in these areas.

Include a discussion regarding control access to the equipment as well as the ability to handle high temperature gases and particulates.

b.

In each area, verify that products of combustion exhausted from an area will not be exhausted to other safety-related areas of the plant.

c. Analyze the need to monitor products of combustion from areas outside the containment for radioactivity prior to release to the atmosphere.

d.

In this item you state "there are no special 'smoke re moval systems'" while in Item 3(i) on the same page you state that the "cable spreading room and the cable tunnels are provided with automatic smoke venting." Explainlite aC4s-e

a -7 AY2 91979

18.

Page 111-29. Sjf f{Ct.iir4A 1 (i+/- a.Analyze 4 -aeu~ fnrVdil /--hr-., -- serv oe1ife fs various functions, and state the locations where these units are stored. 19 P age I II30,"-1teff-5 (A)? It -i- --&ur iOositio1Y that a-fixed' emergency lighting system consisting of sealed beam units with individual 8 hr. battery power supplies be installed in all areas required for safe shutdown operations, including access and egress routes. 20.- Page III-30,.Item 5(c). It is our position that fixed emer gency communications using voice powered head sets should be pro vided at pre-selected stations. Battery powered (PAX) dial tele phones are not an acceptable alternate.

21.

Page 111-30, Item 5(d). Verify that the fire brigade will be supplied with portable radios for emergency communications.

22.

Page 111-31, Item E.l. Fire Detection

a. Provide an analysis, supported where necessary by test data, which substantiates that the sensitivity of fire detection devices and the number and placement of detectors are sufficient

[L~kiUbd AY 91979 to provide detector response in time to prevent loss of safety related systems or components. The analysis should include both fire detection devices used to notify personnel and those used to activate fire protection systems.

b. Provide sufficient data to show that the complete fire.

alarm system, including waterflow and valve supervision, conforms to applicable quidance in NFPA 72D for Class A systems and in NFPA 70 for Class I 'circuits or identify and justify any s3eviation. Include a discussion of the primary and secondary power supplies for the alarm system, and indicate how power is transferred to the secondary supply.

c. You state that the plant public address system is used to announce fires plant wide.

Describe how the fire announcement is distinctive and unique so as not be be confused with other announcements.

d.

It is our position that all fire detection and actuation systems be connected to the plant emergency power supply.

23.

Page 111-35. It is our position that the lateral to each hydrant on the fire main should be provided with a shutoff valve to eliminate the need to shut off portions of the fire main loop to repair hydrants.

-~9- &J L 3LJMY AY BI / Page III-3 9,- Item 4. Halon Suppression ystem. Povide Ihe design criteria, including concentration and soaking.time, for the total flooding systems installed in the computer rooms. 25 U. Page III-42. It is our position that portable fire extinguishers be permanently installed at strategic locations throughout contain ment. Z1. Pages III-43, 44, Item 2. Control Room.

a.

It is our position that the walls separating the control room from the cable risers be upgraded to provide a 3 hr. fire rated barrier. Describe how this will be accomplished.

b.

It is our position that other rooms in the control room area which are not separated from the control room by 3 hr. fire barriers should be separated by walls extending from floor slab to floor slab with a minimum 1 hr. fire resistance rating, and all such rooms should-be provided with an automatic extinguishing system.. Describe how this will be accomplished at San Onofre.

c.

It is our position,that fire detection capability be provided within the cabinets and consoles in the control room. Describe how this will be accomplished. 27

27.

Pages 111-45 through 47, Item 3. Cable Spreading Room.

a. It is our position that the 1 and 2 hr. fire barriers (including floor and ceiling) presently enclosing and separating the cable spreading rooms be upgraded to provide at least a 3 hr.

UUUL~~UUUUUUL13UU~A'~2 9 1979 fire rated barrier enclosing each cable spreading room. Describe how this will be accomplished.

b. With regard to Item 3.b.2 on page 111-46, see question

1. 13.

perfrm unctonsroquiedforsafe plant utdw V 2 3-. Page 111-48, Item 5. Switchgear Rooms. It is our position that all safety-related switchgear rooms be separated-from-each-other and-from other -areas by minimum -3hr. rated fire barriers. Describe how the present 1 and 2 hr. rated barriers will be upgraded to provide 3 hr. rated barriers.

21.

Page 111-48, Item 7. Station Battery Rooms.

a. Question #30 applies equally to the station battery rooms.

b. -It is our position that the battery room ventilation sys tems be monitored so that a loss of ventilation flow in any battery V.

room is alarmed in the control room.

30.

Page 111-52, Item 12. New Fuel Area. ear-o 4-ftrn -that th storage cnfiytOnfOir tiftioen l-'y h.mi~~Jelc~a t rcue rtclL 4 1 Lt e deAity-tr---a t-oC-- VCA'4 +k' tht 4sqw-l t'efa.Oo-re-2&3

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b.

it is our position that-local standpipe hose stations be provided within reach of this area. Describe where such a hose station will be located. 3 P 13 Spent Fuel Pool Area. pp-Page III-52, Item 13*tto ortenwFe The position for a local standpipe hose station for Area also applies to this area. Fire Hazards Analysis A. Containment Structure Two Steam Generator Rooms - Zone 1P Describe how the oil from a rupture in the reactor coolant oi lne wl be pr evented fromexposing the other reactor cooln pumpsi or lsafe rnel ated equipment should the oil become ignited. PUMPS or ote 9s-0"televation ako urbs at thegoolevain Consider the floor openings, lack of c and lack of an oil containment and collection system. B., C., &.D. Penetration Areas piping Penetration Area - Zones 45, 28 and 10. Appendix A you state, on page III-36

a. In your response too that "interior manual hose installations are capable of reaching any location with at least one effective hose stream."

In your analysis of these areas, you have not indicated the presence of any standpipe hose stations for Zones 45 and 28 and a single hose station for Zone 10 which is inadequate for the entire area It is our position that standpipe hose stations be provided in com pliance with the requirements of Appendix A and NFPA 14.

12

b. Your diagrams indicate inadequate coverage by hand portable fire extinguishers in Zones 45 and 28.

It is our position that such extinguishers be installed in accordance with NFPA 10, including travel distance. L. Auxiliary Building, Radwaste Area

34.

Low Radioactive Waste Storage Area - Zone 24. It is our position that automatic sprinklers be installed in this area as required by Appendix A. This also applies to the High Radioactive Waste Storage Area - Zone 25 if it is intended for storage of com bustible material. U. Underground Electrical Tunnels

3.

Describe the oil containment, drainage, and collection sys tems for the transformers which are located over portions of the electrical tunnels. Consider the seals provided for any cable which enters the tunnels from the-transformers, and analyze the possibility of oil from a transformer oil spill or accident entering the cable tunnels. General

6.

a. Describe the procedures necessary to bring the reactor(s) to a cold shutdown if a fire were to cause evacuation of the con trol room or were to destroy all cable and equipment in any of the following areas:

-~~13-J UJ i J PAY 2 q 1 (1) Control room (2) Cable spreading room (3) Cable riser galleries (4) Cable tunnels (5) Any other areas containing redundant safe shutdown equipment or cables. Consider the number of personnel required and available at projected minimum staffing periods to provide needed shutdown operations. What provisions have been made for emergency lighting at any remote areas required for safe shutdown operations, and how would communi cations be established between these areas, as well as other vital operations areas (i.e. fire brigade)?

b. Describe the procedures necessary to transfer control to

-any remote shutdown panels, and verify that all control functions from the remote shutdown panels are electrically independent of any circuits in the affected areas, including power supply.}}