ML14191B262
| ML14191B262 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 07/10/2014 |
| From: | Nuclear Energy Institute |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| FAQ 14-0070 | |
| Download: ML14191B262 (3) | |
Text
FAQ Number 14-0070 FAQ Revision 0b FAQ Title Use of Non-Fire Treated Wood Plant: Harris Date: May 1, 2014
Contact:
Alan Holder Phone: (919) 546-3372 Email: Alan.Holder@Duke-Energy.com Distribution: (NEI Internal Use) 805 TF FPWG RATF RIRWG BWROG PWROG Purpose of FAQ:
FAQ provides clarification for the Control of Combustible Materials (specifically non-fire treated wood) as applied to Fundamental Fire Protection Program and Design Elements Transition Review (NFPA 805, Chapter 3).
Is this Interpretation of guidance? Yes / No Proposed new guidance not in NEI 04-02? Yes / No Details:
NEI 04-02 guidance needing interpretation (include section, paragraph, and line numbers as applicable):
NEI 04-02, Section 4.3.1, Fundamental Fire Protection Program and Design Elements Transition Review, and Appendix K, "NFPA 805 Chapter 3 Clarifications".
3.3.1.2* Control of Combustible Materials. Procedures for the control of general housekeeping practices and the control of transient combustibles shall be developed and implemented. These procedures shall include but not be limited to the following program elements:
(1)* Wood used within the power block shall be listed pressure-impregnated or coated with a listed fire-retardant application.
Exception: Cribbing timbers 6 in. by 6 in. (15.2 cm by 15.2 cm) or larger shall not be required to be fire-retardant treated.
FAQ Number 14-0070 FAQ Revision 0b FAQ Title Use of Non-Fire Treated Wood Circumstances requiring guidance interpretation or new guidance:
Clarification of the NFPA 805 Chapter 3 requirement of Section 3.3.1.2(1), which requires "Wood used within the power block shall be listed pressure-impregnated or coated with a listed fire-retardant application."
Detail contentious points if licensee and NRC have not reached consensus on the facts and circumstances:
None Potentially relevant existing FAQ numbers:
None Response Section:
Proposed resolution of FAQ and the basis for the proposal:
Section 3.3.1.2(1) of NFPA 805 has the following requirement:
3.3.1.2* Control of Combustible Materials. Procedures for the control of general housekeeping practices and the control of transient combustibles shall be developed and implemented. These procedures shall include but not be limited to the following program elements:
(1)* Wood used within the power block shall be listed pressure-impregnated or coated with a listed fire-retardant application.
Exception: Cribbing timbers 6 in. by 6 in. (15.2 cm by 15.2 cm) or larger shall not be required to be fire-retardant treated.
In order to provide clarity for the language above regarding Wood used within the Power Block shall be listed pressure-impregnated or coated with a listed fire-retardant application. this statement should be expanded upon for those cases when untreated wood (i.e., shipping and packing materials) is necessary for short-term (generally less than a shift) use, where administratively controlled, or while constantly attended. Also included would be the presence of small quantities of non-treated wood used in commercially finished products such as hand tools and office furnishings, which contain wooden components such as handles, picture frames and such, and does not affect nuclear safety. The small quantities of wood do not contribute significantly to the combustible loading of a given area, and therefore only a small contribution to fire size is anticipated. There is essentially no impact on the Nuclear Safety Performance Criteria (NSPC).
FAQ Number 14-0070 FAQ Revision 0b FAQ Title Use of Non-Fire Treated Wood If appropriate, provide proposed rewording of guidance for inclusion in the next Revision:
Modify Appendix K to add the following clarification:
======================================================
K.X NFPA 805 Section 3.3.1.2(1) (FAQ 14-XXXX)
Specific clarification for NFPA 805 section 3.3.1.2(1), from FAQ 14-0072; To comply with the term Wood used within the power block shall be listed pressure-impregnated or coated with a listed fire-retardant application., where used in section 3.3.1.2(1), one acceptable method is as follows:
Use of wood inside the Power Block should be permitted only when suitable noncombustible substitutes are not available. All wood smaller than 152 millimeters (mm)x152 mm (6 inch (in.)x6 in.)(nominal) used in plant areas important to safety during maintenance, modification, or refueling operations (such as lay-down blocks or scaffolding) shall be treated with a fire-retardant application. Non-fire retardant treated wood shall be allowed into the Power Block only when it is to be used immediately, and is constantly attended. Equipment or supplies shipped in untreated combustible packing containers (crates, boxes, pallets, cable spools, etc.) may be unpacked in Power Block areas if, required for valid operating reasons (fuel shipping containers, manufacturer specific packaging, etc.). However, all combustible materials shall be removed from the area immediately following the unpacking. Such transient combustible material, unless stored in approved containers, shall not be left unattended during lunch breaks, shift changes, or other similar periods. Loose combustible packing material such as wood shall be placed in metal containers with tight-fitting self-closing metal covers. In addition, the use of commercially available products (e.g., tools, janitorial supplies, special fixtures, and office type furnishings) which contain small quantities of untreated wood as an integral part of a finished product would be allowed.
These finished product items would not be subject to additional fire prevention administrative controls. Designated storage areas that have been evaluated by fire protection engineering are acceptable if it does not adversely impact the Approved Fire Protection Program.