ML18054B063
| ML18054B063 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/26/1989 |
| From: | Cooper H CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-86-10, GL-88-12, TAC-73819, NUDOCS 8911020283 | |
| Download: ML18054B063 (97) | |
Text
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consumers Power PDWERIN&
NllCHl&ANYS PROGRESS General Offices: 1945 West Parnall Road, Jackson,' Ml 49201 * (517) 788-0550 October 26, 1989 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
FIRE PROTECTION PROGRAM REPORT - ADDITIONAL INFORMATION (TAC NO. 73819)
On July 31, 1989 Consumers Power Company submitted a proposed License and Technical Specification Change Request to comply with Generic Letters 86-10 and 88-12.
That submittal included the Fire Protection Program Report which will become part of the FSAR once approval is received.
Since that July 31, 1989 submittal, we have found that a portion of our Fire Protection Program Report was omitted.
After discussion with NRR and Regional NRC staff members, we have determined that this information should be included as part of the Fire Protection Program Report.
The information to be included is entitled "Response to Appendix A guidelines of Branch Technical Position APCSB 9.5-1, Regulatory Guide 1.78 and Regulatory guide 1.101," and was originally submitted on March 31, 1977 as part of a report titled "Fire Protection Evaluation for Palisades Plant."
In the years between 1977 and the present many modifications and improvements have been made, thus the information has been revised and has been added as section V to Volume 1 of the Proposed Fire Protection Program Report.
Attachment I to this letter is a revised Table of Contents for the Fire Protection Program Report.
Attachment II is the added Section V which contains the updated information.
H F Cooper Licensing Consultant CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachments OC1089-0005-NL02 8911020283 891026 PDR ADOCK 05000255 F
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A CMS ENERGY COMPANY
OC1089-0005-NL02 ATTACHMENT 1 Consumers Power Company Palisades Plant Docket 50-255 REVISED TABLE OF CONTENT FIRE PROTECTION PROGRAM REPORT October 26, 1989 1 Page
PALISADES NUCLEAR PLANT FIRE PROTECTION PROGRAM REPORT (FPPR)
TABLE OF CONTENTS VOLUME 1 FIRE PROTECTION PROGRAM I. INTRODUCTION II. FIRE PROTECTION PLAN 1.0 Scope 2.0 References 3.0 Organization 4.0 Implementation 5.0 Fire Protection Equipment 6.0 Training 7.0 Fire Prevention Activities 8.0 Quality Assurance 9.0 Program Review 10.0 Documented Instruction 11.0 Commitments and Modifications 12.0 Emergency Procedures 13.0 Records 14.0 Attachments III. FIRE HAZARDS ANALYSIS (FHA)
IV. SAFE SHUTDOWN ANALYSIS V. RESPONSE TO BRP. APCSB 9.5-1 & REG GUIDES 1.78 & 1.101 VI. REFERENCES VOLUME 2 LICENSING VII. EXEMPTIONS FROM THE REQUIREMENTS OF 10CFR50.48 AND APPENDIX R VIII. FIRE PROTECTION SAFETY EVALUATION REPORT VOLUME 3 ENGINEERING ANALYSIS I IX. FIRE EQUIPMENT & MATERIAL CONDITION ANALYSES VOLUME-4 ENGINEERING ANALYSES-II X. SYSTEM ANALYSES OC1089-0005-NL02 I
I I
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OC1089-0005-NL02 ATTACHMENT 2 Consumers Power Company Palisades Plant Docket 50-255 LIST OF CHANGES AND RESPONSE TO APPENDIX A TO BRANCH TECHNICAL POSITION APCSB 9.5-1 AND REGULATORY GUIDE 1.78 AND 1.101 REVISION 1 October 26, 1989 2 Pages
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1 2
3 4
5 7
8 9
10 11 12 13 14 15 19 19 20 21 23 26 27 28 29 29 30 31 32 32 33 34 37 38 38 39 40 41 41 Paragraph A.1. a A.1.b A.1. b. (2)
A.4 A, 5 & A. 6 B.1 B.2 B.3, (a)
B.3.(c)
B.4 B,5 B. 5. (b)
B.6 B.7 D.1.(a).1 D.2 D.1. (b)
D.1.(d)
D.l.(f)
D.1.(i)
D.1.(j)
D.2.(a)
D.2. (b) _
D. 2. (b). 3 D,2,(c)
D.2.(d)
D.3. (c)
D.3. (c)
D,3, (d)
D.3.(e)
D.4.(a)
D.4.(c)
D,4. (d)
D.4. (f)
D.4.(g)
D.4,(h)
D.4. (i)
MI0989-0012-NL02
-Change Title change Title changes, responsibility change Added "Modification and specification changes to" Added an exception which are mitigated by contingency measures Deleted specific references to FHA Changed tense, added reference to FPIP's Changed to describe current requirements and procedure Added description of hot work permit program Added reference to NML standards Added training for Covert F.D.
Added reference to FPIP's Word change and reference to unannounced fire drill and fire department participation Added security force Added "applicable" Added reference to alternate shutdown panel Deleted reference to "Appendix 1" Describes Design Input Checklist Added "roofs" Added reference to FPIP's Deleted "Appendix 1" Deleted reference to "Appendix 1" Deleted reference to "Appendix 1" Describes hydrogen source Adds an exception Adds reference to FPIP's Adds reference to FPIP's Revised to accurately state conditions Deleted reference to "Appendix 1" Refers to "original" FHA and silicone seals Adds reference to IEEE 383 standard Removed references to Section III of Appendix 1 adds description of dampers and smoke ejectors Adds description of manual reopening of dumpers Adds charcoal filter protection description Revises door resistance, deletes reference to Appendix 1 Deletes reference to Appendix 1 Updates numbers, adds an air compressor Describes a "new" Halon system
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44,
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42 42 42 43 43 45 47 48 49 52 53 54 54 55 56 57 58 60 61 63 64 65 66 67 67 68 69 71 72 73 74 75 75 78 79 80 80 82 84 87 Paragraph D.5. (a)
D. 5. (b)
D.5. (d)
E.1.(a)
E.1. (b)
E.2.(a)
E.2.(c)
E.2. (d)
E.2. (e)
E.3, (a)
E, 2. (b)
E,3. (d)
E.3. (e)
E.4 E.6 F.1. (a)
F. 1. (a)
F.1 F.1. (b)
F.2 F,2 F.3(a)(l)
F,3(a)(3)
F.3(a)(4)
F.3(a)(5)
F. 3 (b)(2)
F.3(b)
F.5 F.5 F.6 F. 7 F.8 F.9 F.11 F.12 F.13 F.14 F.18 G.3 MI0989-0012-NL02
- Change*
Added description of self contained emergency lights Added control room Added security officer radios References an analysis Describes fire detection system Added description of fuel pool cooling system cross tie Added description of radiant energy shield Added description of 30-inch pipe Adds description of largest deluge system Adds "globe" valve, adds recent exception Adds tamperproof seals Adds description of hose reels in containment Adds "suitable for *.* "
Adds description of "recent" Halon system Adds reference to exceptions Deletes irrelevant paragraph Adds description of detection system in containment Add description of hose reels in containment Describes use of SCBA's Changed tense of sentence, seals are described as 3-hour Changed "will be" to "are" Added "other fire retardent material" Changed "two" to "three", deleted "Appendix 1" Added "and one from the turbine building" Changed "will be" to "is" and describes mounting Adds reference to IEEE 383 Refers to alternate shutdown panel, deletes irrelevant paragraphs.
Refers to 3-hour barrier, describes fire protection in rooms.
Adds "other fire resistant material" Changed "will be" to "are" Changes "two" to "three", refers to FHA Adds exception Describes upgraded protection Describes automatic detection and protection Describes current protection Adds smoke detectors Describes automatic protection in area Changes location of records storage area Deletes Appendix 3, changes tense of sentence Adds Halon System
RESPONSES TO APPENDIX A TO.BRANCH TECHNICAL POSITION APCSB 9.5-1 AND REGULATORY GUIDES 1.78 AND 1.101 - REVISION 1 REGULATORY POSITION IV.
Fire Protection BTP, APCSB 9.5-1, Appendix A A.
Overall Requirements of Nuclear Plant Fire Protection Program
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Personnel - Responsibility for the overall fire protection program should be assigned to a desig-nated person in the upper level of management.
This person should retain ultimate responsibility even though formulation and assurance of program imple-mentation is delegated.
Such delegation of author-ity should be to staff personnel prepared by training and experience in fire protection and nuclear plant safety to provide a balanced approach in directing the fire protection programs for nuclear power plants.
MI1188-0170A-TP11-TP15
RESPONSE
Palisades Plant - Docket No 50-255 A. l.a
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Personnel - The overall responsibility for fire protection programs is assigned to the Vice Presi-dent of Nuclear Operations.
The Plant General Manager shall be responsible for fire protection and nuclear safety of the plant.
The Plant Property Protection DeP.artment is responsible for providing functional supervision of fire protection* operations with assistance from the Asset Protection Section's fully qualified fire protection engineer.
REGULATORY POSITION IV.
Fire Protection BTP, APCSB 9.5-1, Appendix A A.
Overall Requirements of Nuclear Plant Fire Piotection Program
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Personnel - Responsibility for the overall fire protection program should be assigned to a desig-nated person in the upper level of management.
This person should retain ultimate responsibility even though formulation and assurance of program imple-mentation is delegated.
Such delegation of author-ity should be to staff personnel prepared by training and experience in fire protection and nuclear plant safety to provide a balanced approach in directing the fire protection programs for nuclear power plants.
HI1188-0l70A-TP11-TP15 1
RESPONSE
Palisades Plant - Docket No 50-255 A.l.a
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Personnel - The overall responsibility for fire protection programs is assigned to the Vice Presi-dent of Nuclear Operations.
The Plant General Manager shall be responsible for fire protection and nuclear safety of the plant.
The Plant Property Protection Department is responsible for providing functional supervision of *fire protection' operations with assistance from the Asset Protection Section's fully qualified fire protection engineer.
REGULATORY POSITION A.l (Contd) - The qualification requirements for the fire protection engineer or consultant who will assist in the design and selection of equipment, inspect and test the completed physical aspects of the system, develop the fire protection program, and assist in the fire fighting training for the operat-ing plant should be stated.
Subsequently, the FSAR should discuss the training and the updating provisions such as fire drills provided for maintaining the competence of the station fire fighting and operating crew, including personnel responsible for maintaining and inspecting the fire protection equipment.
The fire protection staff should be responsible for:
- a.
Coordination of building layout and systems design with the fire area requirements, including consideration of potential hazards associated with postulated design basis fires MI1188-0170A-TP11-TP15
RESPONSE
A. (Contd)
A.l.b - Qualification requirements for the fire protection engineer (Fire Control Engineer) include the following:
BS in Engineering - Professional Registration status is desirable.
Miscellaneous engineering experience throughout the Company.
Development and presenta-tion of policies, procedures and loss prevention programs.
Engineering design review and construc-tion followup of buildings and plant projects for compliance with codes and regulations.
Full member status in the Society of Fire Protection Engineers is desirable.
A revision to the Palisades FSAR has been prepared to discuss the training and updating provisions of the fire protection program such as:
(1)
Providing fire drills to maintain competence of the station fire fighting and *operating crews (2)
Providing responsible personnel to maintain and inspect fire protection equipment Palisades Property Protection personnel, with assistance from the Corporate Fire Control Engineer, are responsible for:
(1)
Coordination for building layout and systems design with fire area requirements, including consideration of potential hazards associated with postulated design basis fires
REGULATORY POSITION A.l (Contd)
(b)
Design and maintenance of fire detection, suppression, and extinguishing systems (c)
Fire prevention activities (d)
Training and manual fire fighting activities of plant personnel and the fire brigade NOTE:
NFPA 6 - Recommendations for Organization of lndust'rial Fire Loss Prevention, contains useful guidance for organization and operation of the entire fire loss prevention program.
- 2.
Design Basis - The overall fire protection program should be based upon evaluation of potential fire hazards throughout the plant and the effect of postulated design basis fires relative to maintain-ing ability to perform safe shutdown functions and minimize radioactive releases to the environment.
MI1188-0170A-TP11-TP15
RESPONSE
A. l (Co~td)
(2)
Design, maintenance, modification and specifi-cation changes to fire detection, suppression, and extinguishing systems (3)
Fire prevention activities (4)
Training and manual fire fighting activities of plant personnel and the fire brigade (5)
Unannounced inspections (6)
Fire drills
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A fire hazard analysis has been performed at Palisades Plant and a list of these credible fires has been developed.
An evaluation of these fires and their impact on plant systems with respect to maintaining the ability to safely shutdown and cooldown the plant and control or mitigate the release of radioactivity to the environment has been made.
REGULATORY POSITION A.2 (Contd)
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Backup - Total reliance should not be placed on a single automatic fire suppression system.
Appro-priate backup fire suppression capability should be provided.
NOTE:
Per telecon V Benaroya, NRC and H Pielage, NSC, November 26, 1976, the phrase "appropriate backup fire suppression capability" is not intended to mean backup automatic suppression systems but rather means manual hose stations and portable extinguishers.
- 4.
Single Failure Criterion - A single failure in the fire suppression system should not impair both the primary and backup fire suppression capabili-ties.
For example, redundant firewater pumps with independent power supplies and controls should be provided.
Postulated fires or fire protection system failures need not be considered concurrent with other plant accidents or the most severe natural phenomena.
The effects of lightning strikes should be included in the overall plant fire protection program.
MI1188-0170A-TP11-TP15
RESPONSE
A.2 (Contd)
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Backup - Manual hose stations and portable extinguishers are provided throughout the plant as backup to the automatic systems.
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Single Failure Criterion -
An evaluation of the single failure criterion has been made and is presented in Appendix 2 of this report.
The fire-water system conforms to the single failure crite-rion.
One ex~eption is the charging pump room where a single failure will cause the loss of both primary and backup water supplies. 'contingency measures will be placed into effect should this occur.
The containment building has lightning rods and the plant has a complete grounding system.
All struc-tures and equipment are tied into the grid grounding systems.
REGULATORY POSITION A. (Contd)
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Fire Suppression Systems - Failure or inadver-tent operation of the fire suppressi6n system should not incapacitate safety-related systems or compo-nents.
Fire suppression systems that are pressur-ized during normal plant operation should meet the guidelines specified in APCSB Branch Technical Position 3-1, Protection Against Postulated Piping Failures in Fluid Systems Outside Containment.
- 6.
Fuel Storage Areas - Schedule for implementation of modifications, if any, will be established on a case-by-case basis.
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Fuel Loading - Schedule for implementation of modifications, if any, will be established on a case-by-case basis.
- 8. Multiple Reactor Sites On multiple reactor sites where there are operating reactors and con-struction of remaining units is being completed, the fire protection program should provide continuing evaluation and include additional fire barriers, fire protection capability, and administrative controls necessary to protect the operating units from construction fire hazards.
The superintendent of the operating plant should have the lead respon-sibility for site fire protection.
MI1188-0170A-TP11-TP15 5
RESPONSE
A. (Contd)
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Fire Suppression Systems - Failure or inadver-tent operation of the fire suppression system should not incapacitate safety-related systems or components.
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Fuel Storage Areas - These areas are covered in detail in Lhe Fire Hazards Analysis.
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Fuel Loading - The only fuel load activities to be undertaken at the Palisades Plant will be normal refueling operations.
No modifications are required in conjunction with those operations.
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Multiple Reactor Sites - The Palisades Plant is a single reactor site; thus, this requirement is not applicable.
REGULATORY POSITION A. (Contd)
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Simultaneous Fires - Simultaneous fires in more than one reactor need not be postulated, where separation requirements are met.
A fire involving more than one reactor unit need not be postulated except for facilities shared between units.
MI1188-0170A-TP11-TP15
RESPONSE
A. (Contd)
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Simultaneous Fires - Not applicable to the Palisades Power Plant since it is on a single reactor site.
REGULATORY POSITION B.
Administrative Procedures, Controls and Fire Brigade
- 1.
Administrative procedures consistent with the need for maintaining the performance of the fire protection system and personnel in nuclear power plants should be provided.
The following publications are cited for guidance; NFPA 4, 4A, 6, 7, 8 and 27.
MI1188-0170A-TP11-TP15
RESPONSE
B, Ad~inistrative Procedures, Controls and Fire Brigade 7
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Administrative procedures have been developed consistent with the need for maintaining the perfor-mance of the {ire protection system and personnel 1n the Palisades Plant based on the Nuclear Mutual Limited (NML) Property Loss Prevention Standards.
These procedures are contained in the Palisades Plant Fire Protection Implementing Procedures.
REGULATORY POSITION B. (Contd)
- 2.
Effe~tive administrative measures should be implemented to prohibit bulk storage of combustible materials inside or adjacent to safety-related buildings or systems during operation or maintenance periods.
Regulatory Guide 1.39, "Housekeeping Requirements for Water-Cooled Nuclear Power Plants,
provides guidance on housekeeping, including the disposal of combustible materials.
Mlll88-0170A-TP11-TP15
RESPONSE
B. (Contd)
- 2.
Housekeeping requirements are found in the Palisades Plant Fire Protection Implementing Proce-dure Number 7 (FPIP).
These procedures have been developed and implemented which prohibit bulk storage of combustible materials inside or adjacent to safety-related buildings or systems during operation or maintenance periods.
8
REGULATORY POSITION B. (Contd)
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Normal and abnormal conditions or other antici-pated operations such as modifications (eg, breaking fire stops, impairment of fire detection and sup-pression systems) and refueling activities should be reviewed by appropriate levels of management and appropriate special actions and procedures such as fire watches or temporary fire barriers implemented to assure adequate fire protection and reactor safety.
In particular:
(a)
Work involving ignition sources such as welding and flame cutting should be done under closely controlled conditions.
Procedures governing such work shou~d be reviewed and approved by persons trained and experienced in fire protection.
Persons performing and directly assisting in such work should be trained and equipped to prevent and combat fires.
If this is not possible, a person qualified in fire protection should directly monitor the work and function as a fire watch.
MI1188-0170A-TP11-TP15 9
RESPONSE
B. (Contd)
- 3.
Administrative procedures that ensure the appropriate levels of management and staff review of all normal and abnormal conditions or other antici-pated operations have been implemented.
(a)
All maintenance work orders have a check-off and comment section for fire hazards.
Each work order is revi~wed by the maintenance supervisor and the maintenance man before beginning the job.
A hot work permit is required for all cutting or welding jobs.
This hot work permit is completed by an experienced supervisor and authorized by a Plant Shift Supervisor.
For all jobs inside the plant, a fire watch is established and fire extinguishing equipment is assigned to the job's location.
Plant Property Protection personnel review all hot work permits upon authorization and closeout.
All plant modifications are coordinated by a plant engineer.
Contractors performing major modifica-tions at Palisades Plant are required to provide a resident safety officer at the jobsite.
Modifica-
- tion reviews are conducted by the Plant Property Protection Department for fire protection impact and by a supervising engineer for impact against Appen-dix R criteria per Administrative Procedures 9.03 and 9.04.
REGULATORY POSITION B.3 (Contd)
(b)
Leak testing, and similar procedures such as air flow determination, should use one of the commercially available aerosol techniques.
Open flames or combustion generated smoke should not be permitted.
(c)
Use of combustible material; eg, HEPA and charcoal filters, dry ion exchange resins or other combustible supplies, in safety-related areas should be controlled.
Use of wood inside buildings con-taining safety-related systems or equipment should be permitted only when suitable noncombustible substitutes are not available.
If wood must be used, only fire retardant treated wood (scaffolding, lay down blocks) should be permitted.
Such mate-rials should be allowed into safety-related areas only when they are to be used immediately.
Their possible and probable use should be considered in the Fire Hazard Analysis to determine the adequacy of the installed fire protection systems.
MI1188-0170A-TP11-TP15
RESPONSE
B.3 (Contd)
(b)
Open flame or combustion generated smoke will not be used in leak testing or air flow determination.
(c)
The use of wood and other combustibles with safety-related buildings or system areas is mini-mized in accordance with NML standards.
10 The resins storage is addressed in Sections G.2 and G.4.
The HEPA filters are addressed in Section G.4.
REGULATORY POSITION B. (Contd)
- 4.
Nuclear power plants are frequently located in remote areas, at some distance from public fire departments.
Also, first response fire departments are often volunteer.
Public fire department re-sponse should be considered in the overall fire protection program.
However, the plant should be designed to be self-sufficient with respect to fire fighting activities and rely on the public response only for supplemental or backup capability.
MI1188-0170A-TP11-TP15 11
RESPONSE
B. (Contd)
- 4.
The fire plan for the Palisades Plant includes provisions for maintaining self-sufficiency with respect to fire fighting activities and also allows for outside assfstance from the Covert Fire Depart-ment, if necessary, for supplemental or backup capability.
Periodic training is provided by the plant for the Covert Township Fire Department as well as joint.drills with the plant fire brigade.
REGULATORY POSITION B. (Contd)
- 5.
The need for good organization, training and equipping of fire brigades at nuclear power plant sites requires effective measures be implemented to assure proper discharge of these functions.
The guidance in Regulatory Guide 1.101, "Emergency Planning for Nuclear Power Plants," should be followed as applicable.
(a)
Successful fire fighting requires testing and maintenance of the fire protection equipment, emergency lighting and communication, as well as practice as brigades for the people who must utilize the equipment.
A test plan that l.ists the individ-uals and their responsibilities in connection with routine tests and inspections of the fire detection and protection systems should be developed.
The test plan should contain the types, frequency and detailed procedures for testing.
Procedures should also contain instructions on maintaining fire protection during those periods when the fire protection system is impaired or during periods of plant maintenance; eg, fire watches or temporary hose connections to water systems.
MI1188-0170A-TP11-TP15 12
RESPONSE
B. (Contd)
- 5.
The intent of Regulatory Guide 1.101 with respect to fire protection emergency planning is implemented by following the administrative controls provided in the Palisades Fire Protection Implement-ing Procedures and the NML Property Loss Prevention Standards.
(a)
Fire pro~ection equipment is maintained and tested in accordance with the manufacturer's recom-mendations, the applicable NFPA Standards and the NML Property Loss Prevention Standards and Appen-dices listed below.
A.6 Private Fire Brigade - Operating Plant A.7 Fire Prevention Surveillance - Completed Plant A.10 Fire Pumps and Controllers A.11 Hydrants and Hose Equipment Stations
REGULATORY POSITION B. (Contd)
(b)
Basic training is a necessary element in effective fire fighting operation.
In order for a fire brigade to operate effectively, it must operate as a team.
All members must know what their indi-vidual duties are.
They must be familiar with layout of the plant and equipment location and operation in order to permit effective fire fighting operations during times when a particular area is filled with smoke or is insufficiently lighted.
Such training can only be accomplished by conducting drills several times a year (at least quarterly) so that all members of the fire brigade have had the opportunity to train as a team, testing itself in the major areas of the plant.
The drills should include the simulated use of equipment in each area and should be preplanned and post-critiqued to establish the training objective of the drills and determine how well these objectives have been met.
These drills should periodically (at least annually) include local fire department participation where possible.
Such drills also permit supervising personnel to evaluate the effectiveness of communi-cations within the fire brigade and with the on-scene fire team leader, the reactor operator in the control room, and the offsite command post.
MI1188-0170A-TP11-TP15
RESPONSE
B. (Contd)
(b)
See B.5 above.
Hands-on fire fighting tra1n1ng is conducted annu-ally including the local fire department.
Fire brigade drills are held so as to fulfill the requirements of this section.
13 At least one unannounced fire drill is held annually for each shift brigade.
The offsite fire department participates in at least one combined fire drill per year.
REGULATORY POSITION B. (Contd)
- 6.
To have proper coverage during all phases of operation, members of each shift crew.should be trained in fire protection.
Training of the plant fire brigade should be coordinated with the local fire department so that responsibilities and duties are delineated in advance.
This coordination should be part of the training course and implemented into the training of the local fire department staff.
Local fire departments should be made aware of the need for radioactive protection of personnel and the special hazards associated with a nuclear power plant site.
MI1188-0l70A-TP11-TP15
RESPONSE
B. (Contd)
- 6.
In accordance with the Palisades Plant Fire Plan, members of each shift crew and the security force are members of the fire brigade and are trained in fire protection.
Training between the plant and the local fire department has been established and will be continued.
14 The responsibilities and duties of each organiza-tion, the fire brigades, local fire departments and each individual are established.
The Covert Fire Department is made aware of the need for radioactive protection of personnel and special hazards associated with the Palisades Plant.
REGULATORY POSITION B. (Contd)
- 7.
NFPA 27, "Private Fire Brigade" should be followed in organization, training, and fire drills.
This standard also is applicable for the inspection and maintenance of fire fighting equipment.
Along with the standards referenced in this document, the following should be utilized:
NFPA 194, "Standard for Screw Threads and Gaskets for Fire Hose Couplings," NFPA 196, "Standard for Fire Hose,"
NFPA 197, "Training Standard on Initial Fire Attacks," NFPA 601, "Recommended Manual of Instruc-tions and Duties for the Plant Watchman on Guard."
NFPA booklets and pamphlets listed on Page 27-11 of Volume 8, 1971-72 are also applicable for good training references.
In addition, courses in fire prevention and fire suppression which are recognized and/or sponsored by the fire protection industry should be utilized.
MI1188-0170A-TP11-TP15
RESPONSE
B. (Contd)
- 7.
Fire brigade organization, training and drills follow the NHL Loss Prevention Standards which are based on applicable NFPA Standards.
15
REGULATORY POSITION C.
Quality Assurance Program - Quality assurance (QA) programs of applicants and contractors should be developed and implemented to assure that the requirements for design, procurement, installation, and testing and administrative controls for the fire protection program for safety-related areas as defined in this Branch Position are satisfied.
The program should be under the management control of the QA organization.
The QA program criteria that apply to the fire protection program should include the following:
- 1.
Design Control and Procurement Document Control - Measures should be established to assure that all design related guidelines of the Branch Technical Position are included in design and procurement documents and that deviations therefrom are controlled.
- 2.
Instructions, Procedures and Drawings - Inspec-tions, tests, administrative controls, fire drills and training that govern the fire protection program should be prescribed by documented instructions, procedures or drawings and should be accomplished in accordance with these documents.
- 3.
Control of Purchased Material, Eguipment and Services - Measures should be established to assure that purchased material, equipment and services conform to the procurement documents.
HI1188-0170A-TP11-TP15
RESPONSE
C.
The Consumers Power Company Quality Assurance Program Manual for Nuclear Power Plant applies to fire protection systems classified as safety-related.
16
- 1.
The Quality Assurance Program Manual for Nuclear Power Plants is used.
- 2.
Same as C.1
- 3.
Same as C.1
REGULATORY POSITION C. (Contd)
- 4.
Inspection - A program for independent inspec-tion of activities affecting fire protection should be established and executed by, or for, the organi-zation and executed by, or for, the organization performing the activity to verify conformance with documented*installation drawings and test procedures for accomplishing the activities.
- 5.
Test and Test Control - A test program should be established and implemented to assure that testing is performed and verified by inspection and audit to demonstrate conformance with design and system readi-ness requirements.
The tests should be performed in accordance with written test procedures; test results should be properly evaluated and acted on.
- 6.
Inspection, Test and Operating Status - Measures should be established to provide for the identifica-tion of items that have satisfactorily passed required tests and inspections.
- 7.
Nonconforming Items - Measures should be estab-lished to control items that do not conform to specified requirements to prevent inadvertent use of installation.
- 8.
Corrective Action - Measures should be estab-lished to assure that conditions adverse to fire protection, such as failures, malfunctions, defi-ciencies, deviations, defective components, uncon-trolled combustible material and nonconformances are promptly identified, reported and corrected.
MI1188-0170A-TP11-TP15 17
RESPONSE
C. (Contd)
- 4.
Same as C.l and also the semiannual NHL inspec-tion program is used as an additional cross-check.
- 5.
Same as C.l
- 6.
Same as C.l
- 7.
Same as C.l
- 8.
Same as C.l
REGULATORY POSITION C. (Contd)
- 9.
Reco~ds - Records should be prepared and main-tained to furnish evidence that the criteria enumer-ated above are being met for activities affecting the fire protection program.
- 10.
Audits - Audits should be conducted and docu-mented to verify compliance with the fire protection program including design and procurement documents, instructions, procedures, drawings and inspection and test activities.
MI1188-0170A-TP11-TP15 18
RESPONSE
C. (Contd)
- 9.
Same as C.l
- 10.
Same as C.1
REGULATORY POSITION D.
General Guidelines For Plant Protection
- 1.
Building Design (a)
Plant layouts should be arranged to:
(1)
Isolate safety-related systems from unaccept-able fire hazards, and (2) Alternatives:
(a)
Redundant safety-related systems that are subject to damage from a single fire hazard should be protected by a combination of fire retardant coatings and fire detection and suppression systems, or (b)
A separate system to perform the safety func-tion should be provided.
MI1188-0170A-TP11-TP15 19
RESPONSE
D.l.(a)l - The Palisades Plant has been designed with physical separation to prevent the spread of a fire in safety-related equipment areas such that the function of redundant engineered safety features is not impaired.
This separation is maintained by compartment isolation of plant safety systems and by employing redundant equipment, piping, controls and power supplies.
In the event any single system is disabled, the redundant system and the protection afforded by compartment structural boundaries will ensure that the system safety function is not jeopardized.
An alternate shutdown panel is available.
- 2.
A detailed study has been made of the systems required for safe shutdown of the plant.
This study was used during the Fire Hazards Analysis.
REGULATORY POSITION D. (Contd)
D.l.(b) Fire Hazard Analyses - In order to accom-plish l.(a) above, safety-related systems and fire hazards should be identified throughout the plant.
Therefore, a detailed Fire Hazard Analysis should be made.
The Fire Hazards Analysis should be reviewed and updated as necessary.
Additional Fire Hazards Analysis should be done after any plant modification.
(c)
Cable Spreading - Alternative guidance for constructed plants is shown in Section F.3, "Cable Spreading Room."
HI1188-0170A-TP11-TP15 20
RESPONSE
D. (Contd)
D.l.(b) - A Fire Hazards Analysis evaluation has been conducted in order to determine the extent to which safety equipment may be affected, the most appropriate protection to be provided and the need for additional fire detection/suppression equipment or safety features.
The results of this Fire Hazards Analysis is re-ported separately.
The Design Input Checklist has a section that deals with fire protection.
Before specific design details are made, fire protection requirements are reviewed.
Applicable fire safety requirements are added to the project from the start.
REGULATORY POSITION D. (Contd)
(d)
Construction Materials - Interior wall and structural components, thermal insulation materials and radiation shielding materials and soundproofing should be noncombustible.
Interior finishes should be noncombustible or listed by a nationally recog-nized testing laboratory, such as Factory Mutual or Underwriters' Laboratory, Inc for flame spread, smoke and fuel contribution of 25 or less in its use configuration (ASTM E-84 Test, "Surface Burning Characteristics of Building Materials").
MI1188-0170A-TP11-TP15
RESPONSE
D. (Contd)
(d) - Interior plant walls, floors and roofs are constructed of noncombustible materials.
21
REGULATORY POSITION D. (Contd)
(e)
Roof Materials - Metal deck roof construction should be noncombustible (see the building materials directory of the Underwriters Laboratory, Inc) or listed as Class I by Factory Mutual System Approval Guide.
Where combustible material is used in metal deck roofing design, acceptable alternatives are (i) replace combustibles with noncombustible mate~
rials, (ii) provide an automatic sprinkler system, or (iii) provide ability to cover roof exterior and interior with adequate water volume and pressure.
MI1188-0170A-TP11-TP15 22
RESPONSE
D. (Contd)
(e)
Roof Materials - The metal deck roof construc-tion is Class 1 roof.
REGULATORY POSITION D. (Contd)
(f)
Suspended Ceilings - Suspended ceilings and their supports should be of noncombustible construc-tion.
Concealed spaces should be devoid of combus-tibles.
Adequate fire detection and suppression systems should be provided where full implementation is not practicable.
MI1188-0170A-TP11-TP15 23
RESPONSE
D. (Contd)
(f) - The suspended ceiling used in the Control Room area is of metal construction.
The suspended ceilings in the engineering office area are of noncombustible construction.
The concealed spaces such as cable tunnels, manholes, culverts and spaces above false ceilings inspected as part of the Fire Hazards Analysis, are devoid of combustibles.
Plant
.1*
Fire Protecti~n Implementing Procedures prohi~it combustibles in nondesignated areas.
REGULATORY POSITION D. (Contd)
(g)
Transformers - High voltage - high amperage transformers installed inside buildings containing safety-related systems should be of the dry type or insulated and cooled with noncombustible liquid.
Safety-related systems that are exposed to flammable oil filled transformers should be protected from the effects of a fire by:
(1)
Replacing with dry transformers or transformers that are insulated and cooled with noncombustible liquid; or (2)
Enclosing the transformer with a three-hour fire barrier and installing automatic water spray protection.
MI1188-0170A-TP11-TP15 24
RESPONSE
D. (Contd)
~
- All high voltage power transformers located within the plant safety-related areas are dry type.
REGULATORY POSITION D. (Contd)*
(h)
Transformer Fires - Bu1ldings containing safety-related systems, having openings in exterior walls closer-than 50 feet to flammable oil filled transformers should be protected from the effects of a fire by:
(i) Closing of the opening to have fire resistance equal to three hours (ii) Constructing a three-hour fire barrier between the transformers and the wall ope.nings; or (iii) Closing the opening and providing the capa-bility to maintain a water curtain in case of a fire MI1188-0170A-TP11-TP15 25
RESPONSE
D. (Contd)
(h) -* The main transformer, auxi 1 iary transformers and start-up transformers ar~ located south of the containment vessel and east of the turbine building.
The transformers are within 50 feet of the contain-ment building.
However, there are no openings in the exterior walls of containment within 50 feet of the transformers and the fire resistance of these walls is in excess of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.
All oil filled transformers are outdoors and are protected by an automatic water deluge system.
REGULATORY POSITION D. (Contd)
(i)
Water Removal - Floor drains, sized to remove expected fire fighting water flow, should be pro-vided in those areas where fixed water fire suppres-sion systems are installed.
Drains should also be provided in other areas where hand hose lines may be used if such fire fighting water could cause unac-ceptable damage to equipment in the area.
Equipment should be installed on pedestals, or curbs should be provided as required to contain water and direct it to floor drains.
(See NFPA 92M, "Waterproofing and Draining of Floors.")
Drains in areas containing combustible liquids should have provisions for preventing the spread of the fire throughout the drain system.
Water drainage from areas which may contain radioactivity should be sampled and analyzed before discharge to the environment.
In operating plants or plants under construction, if accumulation of water from the operation of new fire suppression systems does not create unacceptable consequences, drains need not be installed.
MI1188-0170A-TP11-TP1S 26
RESPONSE
D. (Contd)
(i) - Floor drains for water removal are provided in all sprinklered areas.
Many areas have alternate drainage via equipment sumps, door access ways or stairwells to sump areas.
Transformers and 480-volt vital load centers are mounted on pedestals.
Switchgear are floor mounted but floor drains are provided since these areas are sprinklered.
All safety-related diesel day tanks have high curbs around the tanks or the tanks are enclosed in separate fuel oil rooms with doors elevated well above floor level.
All drains located in poten-tially contaminated areas are connected to the low level radwaste systems.
Thus, any firewater col-lected would be analyzed in a normal manner prior to discharge to the environment.
Additional informa-tion is provided in the Fire Hazards Analysis.
REGULATORY POSITION D. (Contd)
(j) Compartmentation - Floors, walls and ceilings enclosing separate fire areas should have m1n1mum fire rating of three hours.
Penetrations in these fire barriers, including conduits and piping, should be sealed or closed to provide a fire resistance rating at least equal to that of the fire barrier itself.
Door openings should be protect~d with equivalent rated doors, frames and hardware that have been tested and approved by a nationally recognized laboratory.
Such doors should be nor-mally closed and locked or alarmed with alarm and annunciation in the control room.
Penetrations for ventilation system should be protected by a standard "fire door damper" where required.
(Refer to NFPA 80, "Fire Doors and Windows.")
The fire hazard in each area should be evaluated to determine barrier requirements.
If barrier fire resistance cannot be made adequate, fire detection and suppression should be provided, such as:
(i) Water curtain in case of fire (ii) Flame retardant coatings (iii) Additional fire barriers MI1188-0170A-TP11-TP15
RESPONSE
D. (Contd) ii2. - See the Fire Hazard Analysis which discusses each area and its fire barriers in detail.
27
REGULATORY POSITION D. (Contd)
D.2 Cont~ol of Combustibles (a) Safety-related systems should be isolated or separated from combustible materials.
When this is not possible because of the nature of the safety system or the combustible materials, special protec-tion should be provided to prevent a fire from defeating the safety system function.
Such protec-tion may involve a combination of automatic fire suppression, and construction capable of withstand-ing and containing a fire that consumes all combus-tibles present.
Examples of such combustible materials that may not be separable from the remain-der of its system are:
(1)
Emergency diesel generator fuel oil day tanks (2)
Turbine-generator oil and hydraulic control fluid systems (3)
Reactor coolant pump lube oil system MI1188-0170A-TP11-TP15
RESPONSE
D. (Contd)
D.2.a - See the Fire Hazards Analysis which dis-cusses the quantities of combustible materials located in the plant.
28
REGULATORY POSITION D. (Contd)
(b)
Bulk gas storage (either compressed or cryo-genic), should not be permitted inside structures housing safety-related equipment.
St.orage of flammable gas such as hydrogen, should be located outdoors or in separate detached buildings so that a fire or explosion will not adversely affect any safety-related systems or equipment.
(Refer to NFPA 50A, "Gaseous Hydrogen Systems.")
Care should be taken to locate high-pressure gas storage containers with the long axis parallel to building walls.
This will minimize the possibility of wall penetration in the event of a container failure.
Use of compressed gases (especially flammable and fuel gases) inside buildings should be controlled.
(Refer to NFPA 6, "Industrial Fire Loss Prevention.")
MI1188-0170A-TP11-TP15 29
RESPONSE
D. (Contd)
(b) - Bulk storage of combustible gases inside the plant safety-related areas is not permitted.
Only necessary amounts of flammable gases are used inside plant buildings.
This includes the hydrogen sup-plies to the main turbine generator.
Storage of this supply is outside the turbine building in large volume, high-pressure cylinders which are built in accordance wi~h NFPA 50A.
A small source of hydro-gen is also supplied in a one-inch line from the area to the auxiliary building for the volume control system.
Only a small inventory is kept in the auxiliary building for reactor chemistry control purposes and gas analyzing systems.
Other com-pressed gas storage tanks are located outside, this includes:
(1)
Propane storage for heating boilers and labora-tory supplies (2)
Methane storage for counting gas (3)
Acetylene and*nitrous oxide for hot chemical laboratories All high-pressure gas bottles are stored with the long axis parallel to building walls.
One exception is the propane tank located outside, behind the plant boiler rooms.
i*
REGULATORY POSITION D. (Contd)
(c)
The use of plastic materials should be m1n1-mized.
In particular, haloginated plastics such as polyvinyl chloride*(PVC) and neoprene should be used only when substitute noncombustible materials are not available.
All plastic materials, including flame and fire retardant materials, will burn with an intensity and Btu production in a range similar to that of ordinary hydrocarbons.
When burning, they produce heavy smoke that obscures visibility and can plug air filters, especially charcoal and HEPA.
The haloginated plastics also release free chlorine and hydrogen chloride when burning which are toxic to humans and corrosive to equipment.
MI1188-0170A-TP11-TP15
RESPONSE
D. (Contd)
(c) - The use of plastic materials has been m1n1-mized at Palisades Plant.
Plant Fire Protection Implementing Procedures limit the use of plastic materials.
30
REGULATORY POSITION D. (Contd)
(d)
Storage of flammable liquids should, as a minimum, comply with the requirements of NFPA 30, "Flammable and Combustible Liquids Code. 11 MI1188-0170A-TP11-TP15 31
RESPONSE
D. (Contd)
(d) - Flammable and combustible liquid storage inside the plant safety-related areas will be minimized to those quantities essential to plant operation and stored in accordance with the applica-ble sections of NFPA 30.
Flammable and combustible liquids are controlled by the Plant Fire Protection Implementing Procedures.
REGULATORY POSITION D. (Contd)
D.3 Electric Cable Construction, Cable Trays and Cable Penetrations (a)
Only noncombustible materials should be used for cable tray construction.
(b)
See Section F.3 for fire protection guidelines for cable spreading rooms.
(c)
Automatic water sprinkler systems should be provided for cable trays outside the cable spreading room.
Cables should be designed to allow wetting down with deluge water without electrical faulting.
Manual hose stations and portable hand extinguishers should be provided as backup.
Safety-related equipment in the vicinity of such cable trays, that*
does not itself require water fire protection, but is subject to unacceptable damage from sprinkler water discharge, should be protected from sprinkler system operation or malfunction.
When safety-related cables do not satisfy the provisions of Regulatory Guide 1.75, all exposed cables should be covered with an approved fire retardant coating and a fixed automatic water fire suppression system should be provided.
MI1188-0l70A-TP11-TP15 32
RESPONSE
D. (Contd)
D.3(a)
Cable trays are of the open top ladder type made of galvanized steel with galvanized steel or painted channel or unistrut type supports.
(b)
See Paragraph F.3.
(c)
Automatic sprinklers are provided in dense areas of cabl~s. Less dense areas are not provided with sprinklers.
Manual hose stations and portable extinguishers are provided as ba~kup.
Cables have been designed to allow wetting down with deluge water without electrical faulting.
The safety-related equipment in the vicinity of automatic sprinklers, have all had the top cable entry points in the cabinets sealed to prevent water ingress.
The rooms in which this equipment is mounted are provided with floor drains to prevent flooding during sprinkler operation.
The safety-related cables do not fully meet the requirements of Regulatory Guide 1.75 since the plant was designed and constructed before the Guide was established.
See the Fire Hazards Analysis for details.
REGULATORY POSITION D.3 (Contd)
(d)
Cable and cable tray penetration of fire barriers (vertical and horizontal) should be sealed to give protection at least equivalent to that fire barrier.
The design of fire barriers for horizontal and vertical cable trays should, as a minimum, meet the requirements of ASTM E-119, "Fire Test of Building Construction and Materials," including the hose stream test.
Where installed penetration seals are deficient with respect to fire resistance, these seals may be protected by covering both side with an approved fire retardant material.
The adequacy of using such material should be demonstrated by suitable testing.
MI1188-0l70A-TP11-TP15 33
RESPONSE
D.3 (Contd)
(d)
Cable tray penetrations in safety-related areas of the plant have been packed with Kaowool, (a ceramic fire packing) sealed with Marinite board and covered with a fire retardant coating (Flamemastic).
Additional penetration seals, where required as a result of the original Fire Hazards Analysis have been installed.
Silicone foam -penetration seals have also been installed in various fire walls.
REGULATORY POSITION D.3 (Contd)
(e)
Fire breaks should be provided as deemed necessary by the Fire Hazards Analysis*.
Flame or flame retardant coatings may be used. as a fire break for grouped electrical cables to limit spread of fire in cable ventings.
(Possible cable derating owing to use of such coating materials must be considered during design.)
(f) Electric cable constructions should as a minimum pass the current IEEE No 383 flame test.
(This does not imply that cables passing this test will not require additional fire protection.)
For cable installation in operating plants and plants under construction that do not meet the IEEE No 383 flame test requirements, all cables must be covered with an approved flame retardant coating and prop-erly derated.
(g)
To the extend practical, cable construction that does not give off corrosive gases while burning should be used.
Applicable to new cable.
installations MI1188-0170A-TP11-TP15
RESPONSE
D.3 (Contd)
(e) Fire breaks required by the Fire Hazards Analysis will be installed.
34 (f)
The cables were specified to meet the vertical flame-resisting test in accordance with IPCEA Standards S-19-81 and is considered satisfactory.
New cables meet the IEEE 383 standard.
(g)
New cable installations will utilize to the extent practical~ cable construction that does not give off corrosive gases while burning.
REGULATORY POSITION D.3 (Contd)
(h)
Cable trays, raceways, conduit, trenches, or culverts should be used only for cables.
Miscella-neous storage should not be permitted, nor should piping for flammable or combustible liquids or gases be installed in these areas.
Installed equipment in cable tunnels or culverts need not be removed if they present no hazard to the cable runs as deter-mined by the Fire Hazards Analysis.
HI1188-0l70A-TP11-TP15 35
RESPONSE
D.3 (Contd)
(h)
Plant inspections conducted during the Fire Hazards Analysis evaluations shows that cable trays, raceways, conduit, trenches, or culverts are used only for cables, and that no miscellaneous storage was present.
No piping for flammable or combustible liquids or gases was installed in these areas.
REGULATORY POSITION D.3 (Contd)
(i)
The design of cable tunnels, culverts and spreading rooms should provide for automatic or manual smoke venting as required to facilitate manual fire fighting capability.
(j)
Cables in the control room should be kept to the m1n1mum necessary for operation of the control room.
All cables entering the control room should terminate there.
Cables should not be installed in floor trenches or culverts in the control room.
Existing cabling installed in concealed floor and ceiling spaces should be protected with an automatic total flooding Halon system.
MI1188-0l70A-TP11-TP15 36
RESPONSE
D.3 (Contd)
(i)
The tunnel from the north penetration area to the switchgear Room 1-D and the cable spreading room can be vented with the HVAC system or manually vented with the door to the switchgear room from the outside.
Also the tunnel can be vented with the door from the outside leading into the north pene-tration room.
(j) All cables entering the control room pass through penetration seals ~nd are terminated in the control room cabinets.
There are no floor trenches or culverts in the control room.
REGULATORY POSITION D.4 Ventilation (a)
The products of combustion that need to be removed from a specific fire area should be evalu-ated to determine how they will be controlled.
Smoke and corrosive gases should generally be automatically discharged directly outside to a safe location.
Smoke and gases containing radi.oact i ve materials should be monitored in the fire area to determine if release to the environment is within the permissible limits of the plant technical specifications.
The products of combustion which need to be removed from a specific fire area should be evaluated to determine how they will be controlled.
(b)
Any ventilation system designed to exhaust smoke or corrosive gases should be evaluated to ensure that inadvertent operation or single failures will not violate the controlled areas of the plant design.
This requirement includes containment functions for protection of the public and maintain-ing habitability for operations personnel.
MI1188-0170A-TP11-TP15 37
RESPONSE
D.4(a)
Emergency exhaust direct to the outside is provided for the cable spreading room and switchgear rooms.
The HVAC system can be configured to exhaust smoke directly outside in the control room/office area and the viewing gallery office area; this can also be used as a backup to the emergency exhaust system.
The diesel generator rooms have natural ventilation for smoke control.
The radwaste area can be ventilated through the normal HVAC system exhaust.
Thi~ must pass through the high-efficiency filter system and the normal radiation monitoring before release.
(b)
The emergency exhaust system can be backed up by the normal HVAC system for the cable spreading room and the 607' switchgear room.
Both these can be readily ventilated by portable fans.
The rad-waste exhaust system has two fans so if one should fail, the other will be available.
A fire that closes fire dampers will be contained within the area as will the smoke.
This necessi-tates the manual reopening of the dampers to vent the smoke after the fire is extinguished.
Portable smoke ejectors are also available.
REGULATORY POSITION D.4 (Contd)
(c)
The,power supply and controls for mechanical ventilation systems should be run outside the fire area served by the system.
(d)
Fire suppression systems should be installed to protect charcoal filters in accordance with Regula-tory Guide 1.52, "Design Testing and Maintenance Criteria for Atmospheric Cleanup Air Filtration."
(e)
The fresh air supply intakes to areas contain-ing safety-related equipment or systems should be located remote from the exhaust air outlets and smoke vents of other fire areas to minimize the possibility of contaminating the intake air with the products of combustion.
MI1188-0170A-TP11-TP15 38
RESPONSE
D.4 (Contd)
(c)
The power supply and controls for the ventila-tion systems are run outside the fire area served by the system with the exception of the cable spreading room and the two safety-related switchgear rooms.
The normal exhaust fan for the cable spreading room and the two switchgear rooms is mounted in the cable spreading room.
The emergency exhaust fan that serves the three above-mentioned rooms is mounted in switchgear Room 1-D.
Both of these areas can also be readily vented with portable blowers.
Any dampers that close due to the fire wall have to be manually opened to vent the smoke.
(d)
Charcoal filters are protected by a manual deluge system.
(e)
All intakes are remote from locations where smoke could be exhausted.
REGULATORY POSITION D.4 (Contd)
(f) Stairwells should be designed to minimize smoke infiltration during a fire.
Staircases should serve as escape routes and access routes for fire fight-ing.
Fire exit routes should be clearly marked.
Stairwells, elevators and chutes should be enclosed in masonry towers with minimum fire rating of three hours and automatic fire doors at least equal to the enclosure constructions, at each opening into the building.
Elevators should not be used during fire emergencies.
Where stairwells or elevators cannot be enclosed in three-hour fire rated barrier with equivalent fire doors, escape and access routes should be estab-lished by prefire plan and practiced in drills by operating and fire brigade personnel.
MI1188-0l70A-TP11-TP15 39
RESPONSE
D.4 (Contd)
(f)
Main ~entral stairway is enclosed with a three-hour enclosure.
Doors are Class B or the equivalent in protection.
The elevator and stairway are in the same enclosure.
The enclosure is compro-mised by penetration of two HVAC ducts although there are no openings in these ducts within the stairway enclosure.
Elevators will not be used during fire e~ergencies.
The stairway from the viewing gallery down to the 607' switchgear room is not enclosed; however, it is separated from the viewing gallery at the top by a wall and door with fire resistance of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.
Based on the Fire Hazards Analysis, this protection is adequate.
REGULATORY POSITION D.4 (Contd)
(g)
Smoke and heat vents may be useful in specific areas such as cable spreading rooms and diesel fuel oil storage areas and switchgear rooms.
When natural-convection ventilation is used, a m1n1mum ratio of 1 sq foot of venting area per 200 sq feet of floor area should be provided.
If forced-convection ventilation is used, 300 cfm should be provided for every 200 sq feet of floor area.
See NFPA No 204 for additional guidance on smoke control.
(h)
Self-contained breathing apparatus, using full face positive pressure masks, approved by NIOSH (National Institute for Occupational Safety and Health - approval formerly given by the US Bureau of Hines) should be provided for fire brigade, damage control and control room personnel.
Control room personnel may be furnished breathing air by a manifold system piped from a storage reservoir if practical.
Service or operating life should be a minimum of one-half hour for the self-contained units.
HI1188-0170A-TP11-TP15 40
RESPONSE
D.4 (Contd)
(g)
The cable spreading room and two switchgear rooms have both normal and emergency exhaust systems which exceed this criteria.
The diesel generator rooms have 3.2 ft 2 of natural ventilation per 100 ft 2*
Diesel day tank rooms are enclosed 'SO that there would not be enough air to support combustion.
All other locations, except the engineered safe-guards rooms ~t the 570 ft level have exhaust ventilation which exceeds these criteria.
Based on the Fire Hazards Analysis, this ventilation is judged adequate.
(h)
Approved self-contained breathing apparatus is provided.
REGULATORY POSITION (h) (Contd) - At least two extra air bottles should be located onsite for each self-contained breathing unit.
In addition, an onsite six-hour supply of reserve air should be provided and arranged to permit quick and complete replenishment of exhausted supply air bottles as they are returned.
If com-pressors are used as a source of breathing air, only units approved for breathing air should be used.
Special care must be taken tQ locate the compressor in areas free of dust and contaminants.
(i) Where total flooding gas extinguishing systems are used, area intake and exhaust ventilation dampers should close upon initiation of gas flow to maintain necessary gas concentration.
(See NFPA 12, "Carbon Dioxide Systems," and NFPA 12A, "Halon 1301 Systems.")
MI1188-0170A-TP11-TP15 41
RESPONSE
(h) (Contd) - A minimum of twelve self-contained breathing units are available throughout the plant.
The majority are located at the access control area near the health physics office.
There are 54 extra air bottles.
There is a cascade fill system that has the capacity to refill 70 bottles.
This is enough capacity for 5 masks to operate 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
There are no air compressors for breathing air.
A compressor for refilling air bottles is provided onsite.
(i) A total flooding gas fire suppression system 1s installed in a self-contained room with no intake or exhaust dampers.
The Halon system has been installed in accordance with NFPA 12A.
REGULATORY POSITION D.5 Lighting and Co11111unication - Lighting and two-way voice communication are vital to safe shutdown and emergency response in t~e event of fire.
Suitable fixed and portable emergency light-ing and communication devices should ~e provided to satisfy the following requirements:
(a)
Fixed emergency lighting should consist of sealed beam units with individual eight-hour minimum battery power supplies.
(b)
Suitable sealed beam battery powered portable hand lights should be provided for emergency use.
(c)
Fixed emergency communication should use voice powered headsets at preselected stations.
(d)
Fixed repeaters installed to permit use of portable radio communication units should be pro-tected from exposure fire damage.
MI1188-0170A-TP11-TP15 42
RESPONSE
D.5(a)
Emergency lighting for the plant consists of permanently installed lighting fixtures powered from the two (2) redundant battery banks.
These emer-gency lighting fixtures are permanently located throughout the plant.
The battery chargers are powered by the diesel busses.
In addition, self-contained emergency lighting units have been in-stalled on possible routes leading to emergency control stations.
These lights are rated at eight hours.
(b)
Portable sealed beam battery powered hand lights are contained within emergency kits which are located throughout the plant and in the control room area.
(c)
Voice powered headsets are not used at the plant for emergency communications.
The plant uses a Gaitronics communications system with stations located within each area of the plant.
This system provides telephone communication between areas as well as a page and command signal within each area.
This system is used for communications with the plant under emergency conditions.
(d)
Portable radio transmitter receivers are provided in each emergency kit located throughout the plant and at equipment locations within the various areas of the plant.
The radios provide communication throughout the plant and operations personnel are knowledgeable of their locations.
Security officers all carry portable radios at all times during normal operations.
REGULATORY POSITION E.
Fire Detection and Suppression
- l. Fire Detection (a) Fire detection systems should, as a minimum, comply with NFPA 72D, "Standard for the Installa-tion, Maintenance and Use of Proprietary Protective Signaling Systems.
Deviations from the require-ments of NFPA 72D should be identified and justified.
(b)
Fire detection system should give audible and visual alarm and annunciation in the control room.
Local audible alarms should also sound at the location of the fire.
MI1188-0170A-TP11-TP15
RESPONSE
E.l.(a)
An analysis has been written discussing variations from NFPA 72D.
(b)
The fire detection system provides both an audible and visual alarm and annunciation in the control room.
Local audible alarms also sound at the location of the fire.
43 I
REGULATORY POSITION E.l (Contd)
(c) Fire alarms should be distinctive and unique.
They should not be capable of being confused with any other plant system alarms.
(d) Fire detection and actuation systems should be connected to the plant emergency power supply.
MI1188-0170A-TP11-TP15
RESPONSE
E.l (Contd)
(c)
A distinctive audible fire alarm is provided.
(d)
The fire alarm system and actuation system is powered from the plant emergency power supply.
44
REGULATORY POSITION E.2 Fire Protection Water Supply Systems (a)
An underground yard fire main loop should be installed to furnish anticipated firewater require-ments.
NFPA 24, Standard for Outside Protection, gives necessary guidance for such installation. It references other design codes and standards devel-oped by such organizations as the American National Standards Institute (ANSI) and the American Water Works Association (AWWA).
Lined steel or cast iron pipe should be used to reduce internal tubercula-tion.
Such tuberculation deposits in an unlined pipe over a period of years can significantly reduce water flow through the combination of increased friction and reduced pipe diameter.
Means for treating and flushing the systems should be pro-vided.
Approved visually indicating sectional control valves, such as Post Indicator Valves, should be provided to isolate portions of the main for maintenance or repair without shutting off the entire system.
The fire main system piping should be separate from service or sanitary water system piping *. For operating plants fire main system piping that can be isolated from service or sanitary water system piping is acceptable.
Visible location marking signs for underground valves is acceptable.
Alternative valve position indicators should also be provided.
MI1188-0170A-TP11-TP15 45
RESPONSE
E.2(a)
The yard is furnished with a 10-inch dia-meter main firewater loop surrounding the plant.
Firewater system design is in accordance with NFPA requirements, American Insurance Association, NELPIA and local codes and standards.
The firewater system is flushed annually when the pumps are tested.
Maintenance on the firewater system is performed under administrative controls.
The discharge system and underground lines are lined cast iron and the aboveground p~ping is carboti steel rated at 125 psig and 100°F.
The firewate*r system is separated and isolated from the service water system, the sanitary water system, the feedwater system, and fuel pool cooling system.
However, crossties to the service water and auxiliary feedwater pumps and the fuel pool cooling system via the installation of a spool piece are available for emergency situations.
REGULATORY POSITION E.2 (Contd)
(b)
A common yard fire main loop may service multi-unit nuclear power plant sites, if cross-connected between units.
Sectional control valves should permit maintaining independence of the individual loop around each unit.
For such instal-lations, common water supplies may also be utilized.
The water supply should be sized for the largest single expected flow.
For multiple reactor sites with widely separated plants (approaching one mile or more), separate yard fire main loops should be used.
Sectionalized systems are acceptable.
MI1188-0170A-TP11-TP15
RESPONSE
E.2 (Contd)
(b)
Not applicable.
Palisades is a single unit site.
- l 46
REGULATORY POSITION E.2 (Contd)
(c) If pumps are required to meet system pressure or flow requirements, a sufficient number of pumps should be provided so that 100% capacity will be available with one pump inactive (eg, three 50%
pumps or two 100% pumps).
The connection to the yard fire main loop from each fire pump should be widely separated, preferably located on opposite sides of the plant.
Each pump should have its own driver with independent power supplies and control.
At least one pump (if not powered from the emergency diesels) should be driven by nonelectrical means, preferably diesel engine.
Pumps and drivers should be located in rooms separated from the remaining pumps and equipment by a minimum three-hour fire wall.
Alarms indicating pump running, driver availability, or failure to start should be provided in the control room.
MI1188-0170A-TP11-TP15 47
RESPONSE
E.2 (Contd)
(c)
The 100% electric fire pump is considered the primary pump.
It is backed up by two 100% diesel driven fire pumps.
The electric fire pump is started when system pressure drops below 90 psig and the diesel fire pumps are automatically started sequentially as the system pressure drops.
Each of the three pumps is capable of delivering 100% flow to the firewater system.
All three pumps are connected to the firewater discharge header in the service water pump structure.
Each diesel driven pump has its own diesel engine, starting circuit, fuel oil day tank gravity feed line and lube oil supply.
Separate rooms for the firewater pumps are not provided; however, the pumps are spatially separated from each other by distance and a radiant energy shield is provided between P-41 and the other pumps.
At the present time the only source of combustible material in this room is the diesel fuel oil day tanks and lube oil.
Only a minimal amount of power cabling exists in this area.
Based on the Fire Hazards Analysis, and the completed modifications, this is acceptable.
Pump operation and system pressure are indicated in the control room by a pump running alarm and low pressure alarm.
REGULATORY POSITION E.2 (Contd)
(d)
Two separate reliable water supplies should be provided.
If tanks are used, two 100% (minimum of 300,000 gallons each) system capacity tanks should be installed.
They should be so interconnected that pumps can take suction from either or both.
How-ever, a leak in one tank or its piping should not cause both tanks to drain.
The main plant firewater supply capacity should be capable of refilling either tank in a minimum of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
Common tanks are permitted for fire and sanitary or service water storage.
When this is done; however, minimum firewater storage requirements should be dedicated by means of vertical standpipe for other water services.
(e)
The firewater supply (total capacity and flow rate) should be calculated on the basis of the largest expected flow rate for a period of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, but not less than 300,000 gallons.
This flow rate should be based (conservatively) on 1,000 gpm for manual hose streams plus the greater of:
(1)
All sprinkler heads opened and flowing in the largest designed fire area; or (2)
The largest open head deluge system(s) operating MI1188-0170A-TP11-TP15 48
RESPONSE
E.2 (Contd)
(d}
The firewater pumps suction basin receives its water supply from Lake Michigan.
If for any reason water cannot reach the suction basin through the traveling screen, the basin may be supplied with water from the lake by using the warm water recircu-lation pump.
Water can be supplied by this pump through a 30-inch pipe.
(e)
Each of the 3 water pumps is capable of deliv-ering 1,500 gpm at 125 psig.
This would allow them to deliver approximately 2,250 gpm each at 89 psig.
Thus, with one pump out of service, a total flow rate of 4,500 gpm at 89 psig is available.
(1)
The largest number of sprinkler heads in a fire area is around the turbine island in the operating floor fire area and consists of 133 heads.
Analysis of a possible fire, that is a turbine lube oil pipe failure with flash fire, indicates a reasonable maximum of 1/3 of the sprinklers might open.
If 1/3 of the sprinklers were activated, a total flow of 1,185 gpm at 52 psig would be required.
REGULATORY POSITION MI1188-0170A-TP11-TP15
RESPONSE
E.2 (e) (Contd) - The largest number of heads in a vital fire area are located in the cable spreading room and include 27 heads rated for 731 gpm at 52 psig with all heads flowing.
49 Both of these systems are closed head systems using fusible links for each head.
The largest deluge system protects the main transformer and station power transformers.
Flow rate is approximately 1,400 gpm.
(2)
The firewater supply (Lake Michigan) is more than adequate to support the maximum flows for more than two hours.
REGULATORY POSITION E.2 (Contd)
(f)
Lakes or fresh water ponds of sufficient size may quaiify as sole source of water for fire protec-tion, but require at least two intakes to the pump supply.
When a common water supply is permitted for fire protection and the ultimate heat sink, the following conditions should also be satisfied:
(1)
The additional fire protection water require-ments are designed into the total storage capacity; and (2)
Failure of the fire protection system should not degrade the function of the ultimate heat sink.
MI1188-0170A-TP11-TP15
RESPONSE
E.2 (Contd)
(f)
Only a single intake structure is provided at the plant.
However, each pump has its own intake from the suction basin.
50.
Lake Michigan also serves as the ultimate heat sink and has more than adequate capacity for all systems simultaneously.
REGULATORY POSITION E.2 (Contd)
(g)
Outside manual hose installation should be sufficient to reach any location with an effective hose stream.
To accomplish this, hy~rants should be installed approximately every 250 feet on the yard main system.
The lateral to each hydrant from the yard main should be controlled by a visually indi-cating or key operated (curb) valve.
A hose house, equipped with hose and combination nozzle, and other auxiliary equipment recommended in NFPA 24, "Outside Protection," should be provided as needed but at least every 1,000 feet.
Threads compatible with those used by local fire departments should be provided on all hydrants, hose couplings and standpipe risers.
MI1188-0170A-TP11-TP15 51
RESPONSE
E.2 (Contd)
(g)
Fire hydrants are located at appropriate site locations outside of the buildings with six-inch risers at seven yard positions.
Hose houses are available in the yard with hose couplings and adapters that have threads which are compatible with the local fire department.
Hydrant spacipg outside Reactor/Turbine/Auxiliary building complex is 250 feet or less.
Valves are not provided between the yard main and the hydrants and are not considered necessary with the number of isolating valves installed.
REGULATORY POSITION E.3 Water Sprinklers and Hose Standpipe Systems (a)
Each automatic sprinkler system and manual hose stations standpipe should have an independent connection to the plant underground water main.
Headers fed from each end are permitted inside buildings to supply multiple sprinkler*and standpipe systems.
When provided, such headers are considered an extension of the yard main system.
The header arrangement should be such that no single failure can impair both the primary and backup for protec-tion systems.
Each sprinkler and standpipe system should be equipped with OS&Y (outside crew and yoke) gate valve, or other approved shutoff valve, and water flow alarm.
Safety-related equipment that does not itself require sprinkler water fire protection, but is subject to unacceptable damage if wetted by sprinkler water discharge should be protected by water shields or baffles.
MI1188-0l70A-TP11-TP15 52
RESPONSE
E.3(a)
The plant is connected to the firewater yard loop via 8-inch and 10-inch lines which penetrate the auxiliary building and turbine building.
Several headers are supplied to accommodate sprink-ler systems in the various fire zones.
The yard loop is connected to the fire pump discharge headers via 12-inch and 14-inch lines located in the turbine building.
A single failure of either a pump or a valve in the system would not impair the supply of firewater.
Each sprinkler and standpipe system is provided with either an OS&Y shutoff valve or globe valve located on the supply headers.
The top cable entry openings of the cabinets of safety-related equipment have been sealed closed to prevent water ingress.
Separ~te lines from the fire main loop serve sprink-lers and fire hose stations.
A break in either line can be isolated by shutoff valves so both.sprinklers and standpipes would not be out of service.
One exception is the water supply to the charging pump room sprinklers.
A single break can cause the loss of both primary and backup water.
Adequate contin-gency procedures can be implemented to supply water.
REGULATORY POSITION E.3 (Contd)
(b)
All valves in the firewater systems should be electrically supervised.
The electrical supervision signal should indicate in the control room and other appropriate command locations in the plant (see NFPA 26, "Supervision of Valves").
When electrical supervision of fire protection valves is not practi-cable, an adequate management supervision program should be provided.
Such a program should include locking valves open with strict key control, tamper-proof seals and periodic, visual check of all valves.
(c) Automatic sprinkler systems should, as a minimum, conform to requirements of appropriate standards such as NFPA 13, "Standard for the Instal-lation of Sprinkler Systems," and NFPA 15, "Standard for Water Spray Fixed Systems."
MI1188-0170A-TP11-TP15 53
RESPONSE
E.3 (Contd)
(b)
Control of all fire protection system valves and their maintenance is controlled administra-tively.
Key fire protection valves, crosstie valves and valve positions are controlled by keylock or are sealed in their proper position with tamperproof seals.
Periodic inspection and checking is per-formed in accordance with the fire surveillance check sheet.
(c)
The design and installation of the sprinkler system was specified to be in accordance with the applicable sections of NFPA 13 and NFPA 15 in force at the time of plant construction.
REGULATORY POSITION E.3 (Contd)
(d)
Interior manual hose installation should be able to reach any location with at least 1 effective hose steam.
To accomplish this, standpipes with hose connection equipped with a maximum of 75 feet of 1-1/2 inch woven jacket lined fire hose and suitable nozzles should be provided in all build-ings, including containment, on all floors and should be spaced at not more than 100-f oot inter-vals.
Individual standpipes should be of at least 4-inch diameter for multiple hose connections and 2-1/2-inch diameter for single hose connections.
These* systems should follow the requirements of NFPA No 14 for sizing, spacing and pipe support require-ments (NELPIA).
Hose stations should be located outside entrances to normally unoccupied areas and inside normally occupied areas.
Standpipes serving hose stations in areas housing safety-related equipment should have shutoff valves and pressure reducing devices (if applicable) outside the area.
(e)
The proper type of hose nozzles to be supplied to each area should be based on the Fire Hazard Analysis.
The usual combination spray/straight stream nozzle may cause unacceptable mechanical damage (for example, the delicate electronic equip-ment in the control room) and be unsuitable.
Electrically safe nozzles should be provided at locations where electrical equipment or *cabling is located.
HI1188-0170A-TP11-TP15 54
RESPONSE
E.3 (Contd)
(d)
The interior of the plant is provided with hose racks and reel-mounted hoses with fog-type nozzles.
Hose stations are located so that all areas in the turbine and auxiliary building are within 95 feet or less of a hose reel or rack.
Hose stations identi-fied during the Fire Hazards Analysis that contained less than 75 feet of hose will be replaced with 75 feet.
Also, a spare 50-foot roll of hose will be stored in the control room for use anywhere in the plant that it might be needed.
The individual standp.ipes are 3 inches or 4 inches in diameter.
The hose stations and their shutoff valves for safety-related areas are located outside these areas.
There are two continuous flow one-inch hose reels inside the containment building.
(e}
The only nozzle type used inside the plant are electrically safe fog spray nozzles suitable for the hazards located in the areas they protect,
REGULATORY POSITION E.3 (Contd)
(f) Certain fires such as those involving flammable liquids ~espond well to foam suppression.
Consider-ation should be given to use of any of the available foams for such specialized protection application.
These include the more common chemical and mechani-cal low expansion foams, high expansion foam and the relatively new aqueous film forming foam (AFFF).
E.4 Halon Suppression Systems The use of Halon fire extinguishing agents should, as a minimum, comply with the requirements of NFPA 12A and 12B, "Halogenated Fire Extinguishing Agent Systems - Halon 1301 and Halon 1211." Only UL or FM approved agents should be used.
In addition to the guidelines of NFPA 12A and 12B, preventative maintenance and testing of the systems, including check weighing of the Halon cylinders should be done at least quarterly.
Particular consideration should also be given to:
(a) Minimum required Halon concentration and soak time (b)
Toxicity of Halon (c) Toxicity and corrosive characteristics of thermal decomposition products of Halon MI1188-0170A-TP11-TP15 SS
RESPONSE
E.3 (Contd)
(f)
Foam extinguishing agents are not used at the plant.
Portable units employ carbon dioxide or dry chemical.
E.4 - A total flooding Halon system has been in-stalled in the nonsafety-related CFMS trailer.
The system has been designed according to NFPA 12A.
REGULATORY POSITION E.5 Carbon Dioxide Suppression Systems - The use of carbon dioxide extinguishing systems should, as a minimum, comply with the requirements of NFPA 12, "carbon Dioxide Extinguishing Systems."
Particular consideration should also* be given to:
(a)
Minimum required C02 concentration and soak time (b) Toxicity of C02 (c) Possibility of secondary thermal shock (cooling) damage (d) Offsetting requirements for venting during C02 injection to prevent overpressurization versus sealing to prevent loss of agent E.6 Portable Extinguishers - Fire extinguishers should be provided in accordance with guidelines of NFPA 10 and lOA, "Portable Fire Extinguishers, Maintenance and Use."
Dry chemical extinguishers should be installed with due consideration given to clean-up problems after use and possible adverse effects on equipment installed in the area.
HI1188-0170A-TP11-TP15
RESPONSE
E.5 Carbon dioxide extinguishing systems are not used at Palisades.
56 E.6 Portable fire extinguishers are provided for use inside the plant in accordance with the applica-ble sections of NFPA 10.
Exceptions to NFPA 10 have been analyzed.
The analysis can be found in the fire protection file.
REGULATORY POSITION F.
Guidelines for Specific Plant Areas
- 1.
Primary and Secondary Containment (a)
Normal Operation - Fire protection requirements for the primary and secondary co.ntainment areas should be provided on the basis of specific identi-fied hazards.
For example:
"Lubricating oil or hydraulic fluid system for the primary coolant pumps "Cable tray arrangements and cable penetrations "Charcoal filters Fire suppression systems should be provided based on the Fire Hazards Analysis.
MI1188-0l70A-TP11-TP15 51
RESPONSE
F.l.(a)
The containment building can be isolated to contain any fire source and the containment boundary will prevent any outside fire from entering the containment.
There are no charcoal filters inside the containment building.
REGULATORY POSITION F.l.(a) (Contd) - Fixed fire suppression capability should be provided for hazards that could jeopardize safe plant shutdown.
Automatic sprinklers are preferred.
An acceptable alternate is automatic gas (Halon or C02) for hazards identified as requiring fixed suppression protection.
An enclosure may be required to confine the agent if a gas system is used.
Such enclosures should not adversely affect safe shutdown, or other operating equipment in containment.
Operation of fire protection systems should not compromise integrity of the containment or the other safety-related systems.
Fire protection act1v1t1es in the containment areas should function in conjunc-tion with total containment requirements such as control of contaminated liquid and gaseous release and ventilation.
Fire detection systems should alarm and annunciate in the control room.
The type of detection used and the location of the detectors should be most suit-able to the particular type of fire that could be expected from the identified hazard.
MI1188-0170A-TP11-TP15 58
RESPONSE
F.l.(a) (Contd) - Automatic fire suppression systems are not provided inside the containment building.
Fire detection systems have been provided inside the containment cable penetration areas and in the air room.
REGULATORY POSITION F.l.(a) (Contd) - AutoJDatic fire suppression capa-bility need not be provided in the primary contain-ment atmospheres that are inerted during normal operation.
However, special fire protection re-quirements during refueling and maintenance opera-tions should be satisfied as provided below.
A primary containment general area fire detection capability should be provided as backup for the above-described hazard detection.
To accomplish this, suitable smoke detection (eg; visual obscura-tion, light scattering and particle counting) should be installed in the air recirculation system ahead of any filters.
MI1188-0170A~TP11-TP15 59
RESPONSE
F.l.(a) (Contd) - The Palisades containment building is not inerted.
REGULATORY POSITION F.l (Contd)
(b)
Ref~eling and maintenance operations in con-tainment may introduce additional hazards such as contamination control materials, decontamination supplies, wood planking, temporary wiring, welding and flame cutting (with portable compressed fuel gas supply).
Possible fires would not necessarily be in the vicinity of fixed detection and suppression systems.
Management procedures and controls necessary to assure adequate fire protection are discussed in Section 3a.
In addition, manual fire fighting capability should be permanently installed in containment.
Standpipes with hose stations, and portable fire extinguishers, should be installed at strategic locations through-out containment for any required manual fire fight-ing operation.
Equivalent protection from portable systems should be provided if it is impractical to install stand-pipes with hose stations.
MI1188-0170A-TP11-TP15
RESPONSE
F.l (Contd)
(b)
Maintenance activities inside the containment during refueling are subject to procedural control via maintenance work orders.
60 Portable fire extinguishers are available inside the containment in the event of any light combustibles fire.
During refueling, access is readily available to aid in extinguishing any postulated fires.
Two continuous flow one-inch hose reels have been installed in the containment.
Requirements for boric acid concentrations in the sump would take priority.
REGULATORY POSITION F.l.(b) (Contd) - Adequate self-contained breathing apparatus should be provided near the containment entrances for fire fighting and damage control personnel.
These units should be independent of any breathing apparatus or air supply systems provided for general plant activities.
MI1188-0170A-TP11-TP15 61
RESPONSE
F.l.(b) (Contd) - Breathing apparatus units are available near the containment entrance in the radiation protection offices and in the control room.
These units are entirely self-contained with extra air cylinders available.
These units can be used for fire fighting or for general use.
Dedi-cated fire fighting SCBA will be brought to the area by the fire brigade.
REGULATORY POSITION F.2 Control Room - The control room is essential to safe reactor operation. It must be protected against disabling fire damage and should be sepa-rated from other areas of the plant by floors, walls and roofs having minimum fire resistance ratings of three hours.
Control room cabinets and consoles are subject to damage from two distinct fire hazards:
(a) Fire originating within a cabinet or console; and (b)
Exposure fire involving combustibles in the general room area Manual fire fighting capability should be, provided for both hazards.
Hose stations and portable water and Halon extinguishers should be located in the control room to eliminate the need for operators to leave the control room.
An additional hose piping shutoff valve and pressure reducing device should be installed outside ihe control room.
Hose stations adjacent to*the control room with portable extinguishers in the control room are acceptable.
Nozzles that are compatible with the hazards and equipment in the control room should be provided for the manual hose station.
The nozzles chosen should satisfy actual fire fighting needs, satisfy electri-cal safety and minimize physical damage to electri-cal equipment from hose steam impingement.
MI1188-0170A-TP11-TP15 62
RESPONSE
F.2 - The control room is provided with two C02 fire extinguishers.
Outside the control room door in the office space hallway is a water extinguisher and fire hose station.
The hose station is provided with an electrically safe nozzle.
A description of the control room and its fire resistance ratings are discussed in the Fire Hazards Analysis.
REGULATORY POSITION F.2 (Contd) - Fire detection in the control room cabinets and consoles should be provided by smoke and heat detectors in each fire area.
Alarm and annunciation should be provided in the control room.
Fire alarms in other parts of the plant should also be alarmed and annunciated in the control room.
Breathing apparatus for control room operators should be readily available.
Control room floors, ceiling, supporting structures, and walls, including penetrations and doors, should be designed to a minimum fire rating of three hours.
All penetration seals should be airtight.
MI1188-0l70A-TP11-TP15 63
RESPONSE
F.2 (Contd) - Smoke detectors are installed in the walk-in cabinet enclosures and on the ceiling in the control room.
Smoke detectors will not be installed in the main control consoles since they are designed with outlet ventilation openings at the top which will allow the control room operators to observe any smoke present from a fire.
The smoke detector system is alarmed locally and annunciated i~ the control room.
See the Fire Hazards Analysis.
Ther.e is a self-contained emergency breathing apparatus and spare bottles for the two operators in the control room.
The control room and adjacent office areas and fire barriers are described in the Fire Hazards Analysis.
All cable penetrations into the control room have been sealed with three-hour rated seals.
REGULATORY POSITION F.2 (Contd) - The control room ventilation intake should be provided with smoke detection capability to automatically alarm locally and isolate the control room.
Manually operated venting of the control room should be available so that operators have the option of venting for visibility.
Cables should not be located in concealed floor and ceiling spaces.
All cables that enter the control room should terminate in the control room.
That is, no cabling should be simply routed through the control room from one area to another.
MI1188-0170A-TP11-TP15
RESPONSE
F.2 (Contd) - Smoke detectors are installed in the control room.
64 The control room ventilation system can be con-trolled manually by the control room operator which will allow him to shut off the fans if smoke was observed entering the control room.
Manual opera-tion of the ventilation system for venting the control r.oom is available to the operators.
There are no concealed floor or ceiling spaces that contain cables in the control room.
The control room is not used as a cable right-of-way.
REGULATORY POSITION F.3 Cable Spreading Room (a) The preferred acceptable methods are:
(1)
Automatic water system such as closed head sprinklers, open head deluge, or open directional spray nozzles.
Deluge and open spray systems should have provisions for manual operation at a remote station; however, there should also be provisions to preclude inadvertent operation.
Location of sprink-ler heads or spray nozzles should consider cable tray sizing and arrangements to assure adequate water coverage.
Cables should be designed to allow wetting down with deluge water without electrical faulting.
Open head deluge and open directional spray systems should be zoned so that a single failure will not deprive the entire area of auto-matic fire suppression capability.
The use of foam is acceptable, provided it is of a type capable of being delivered by a sprinkler or deluge system, such as an Aqueous Film Forming Foam (AFFF).
(2)
Manual hoses and portable extinguishers should be provided as backup.
MI1188-0170A-TP11-TP15 65
RESPONSE
F.3.(a)(l)
The cable spreading room has closed head sprinklers installed above the open cable trays.
There is a manual isolation valve that can be closed for the sprinkler system in case of inadvertent operation.
Wetting down with sprinkler water should not cause electrical faulting.
There are no splices in the cable trays and cable penetrations into the switchgear and cabinets are sealed with Flamemastic or other fire retardent material.
(2) room.
There is a portable extinguisher mounted in the Fire hose-stations with electrical safe nozzles are right building and from viewing area down outside the door to the turbine the upstairs hallway in the through the 1-D switchgear room.
1
REGULATORY POSITION F.3.(a) (Contd)
(3)
Each cable spreading room of each unit should have divisional cable separation, and be separated from the other and the rest of the plant by a minimum three-hour rated fire wall (refer.to NFPA 251 or ASTM E-119 for fire test resistance rating).
MI1188-0170A-TP11-TP15 66
RESPONSE
F.3.(a) (Contd)
(3)
There is only one unit at Palisades and one cable spreading room.
The design is for two divi-sion separation, but the design does not meet all of the requirements of the Regulatory Guide 1.75, since Palisades was designed and constructed before the Guide was established.
The wall to t~e turbine building is at least a three-hour wall and to the adjacent switchgear room is at least a three-hour wall.
The floors and ceilings have a three-hour fire resistance.
The ventilation ducts leading to the turbine building and into the battery rooms have fusible link fire dampers installed.
See the Fire Hazards Analysis.
REGULATORY POSITION F.3.(a) (Contd)
(4)
At least two remote and separate entrances are provided to the room for access by fire brigade personnel; and (5)
Aisle separation provided between*tray stacks should be at least three feet wide and eight feet high.
MI1188-0170A-TP11-TP15 67
RESPONSE
F.3.(a) (Contd)
(4)
There are two remote and separate entrances into the cable spreading room, one from the adjacent switchgear room and one from the turbine building.
(5)
The cable trays are all installed above the floor-mounted switchgear cabinets starting about seven feet high and extending to the ceiling except for the verti~al cable runs at the south side of the room.
There are four-foot aisles between floor-mounted equipment for ladders or fire fighting equipment.
There is a six-foot step ladder mounted for this room and tamperproof seals have been installed between the ladder and its mounting bracket to assure that the ladder is dedicated to this room.
With the ladder, access can be gained to any postulated cable tray fire with a portable extinguisher or fire hose.
REGULATORY POSITION F.3 (Contd)
(b)
For cable spreading rooms that do not provide divisional cable separation of a.(3),.in addition to meeting a.(l), (2), (4), and (5) above, the follow-ing should also be provided:
(1)
Divisional cable separation should meet the guidelines of Regulatory Guide 1.75, "Physical Independence of Electric Systems."
(2)
All cabeling should be covered with a suitable fire retardant coating.
(3)
As an alternate to a.(l) above, automatically initiated gas systems (Halon or C02) may be used for primary fire suppression, provided a fixed water system is used as backup.
HI1188-0170A-TP11-TP15 68
RESPONSE
F.3 (Contd)
(b)(l)
The Palisades Plant does not fully meet the requirements of Regulatory Guide 1.75.
The plant was designed and constructed before the guide was established.
See the Fire Hazards Analysis for amplification.
(2)
All cables were purchased to meet the vertical flame-resisting test of IPCEA Standard S-19-81 as part of the cable procurement specifications.
New cables meet the IEEE 383 standard.
(3)
The sprinkler system is the primary automatic fire suppression system with hose stations and fire extinguishers serving as backup.
REGULATORY POSITION F.3.(b) (Contd)
(4)
Plants that cannot meet the guidelines of Regulatory Guide 1.75, in addition to meeting a.(l),
(2), (4), and (5) above, an auxiliary shutdown system with all cabling independent of the cable spreading room should be provided.
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RESPONSE
F.3.-(b) (Contd) - Hot shutdown can be achieved by manual operation of the steam-driven auxiliary feed pump in the event there is a plant blackout or that cable spreading room equipment is not available.
If either 2,400-volt safety-related Bus 1-C or 1-D is available, then cold shutdown can be achieved independent of any cable spreading room equipment by locally operating circuit breakers and valves.
A safe shutdo~ analysis has been made.
An alternate shutdown panel has been installed and is capable of safely shutting down the plant in the event of a fire.
REGULATORY POSITION F.4 Plant Computer RoQm - Safety-related computers should be separated from other areas of the plant by barriers having a minimum three-hour fire resistant rating. 'Automatic fire detection should be provided to alarm and annunciate in the control room and alarm locally. Manual hose stations and portable water and Halon fire extinguishers should be provided.
MI1188-0170A-TP11-TP15
RESPONSE
F.4 - There are no safety-related computers at the Palisades Plant.
70
REGULATORY POSITION F.5 Switchgear Rooms -
Sw~tchgear rooms should be separated from the remainder of the plant by minimum three-hour rated fire barriers to the extent practi-cable.
Automatic fire detection should alarm and annunciate in the control room and alarm locally.
Fire hose stations and portable extinguishers should be readily available.
MI1188-0170A-TP11-TP15
RESPONSE
F.S - The switchgear room for Bus 1-D, elevation 607 feet, has a three-hour barrier to the cable spreading room.
Floors and ceilings have a three-hour fire barrier.
There is a cableway from the switchgear room to the north penetration room without any barriers.
71 The switchgear room for Bus 1-C, elevation 590 feet, has a three-hour fire barrier to the diesel genera-tor room and ~o the turbine building.
Smoke detectors are installed in both rooms to provide automatic fire detection.
Fire dampers are installed in the ventilation ducts.
Fire hose stations and portable extinguishers are available for both rooms.
Automatic sprinklers are installed in both switchgear rooms.
REGULATORY POSITION F.5 (Contd) - Acceptable protection for cables that pass through switchgear room is automatic water or gas agent suppression.
Such automatic suppression must consider preventing unacceptable damage to electrical equipment and possible necessary contain-ment of agent following discharge.
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RESPONSE
F.5 (Contd) - Both switchgear rooms are used as cable right-of-ways.
Both rooms have closed head sprinkler systems to protect the cables.
All switchgear top cable penetrations are sealed with Flamemastic or other fire-resistant material.
The switchgear enclosures are louvered to limit water sprays from entering the enclosures.
72
REGULATORY POSITION F.6 Remote Safety-Related Panels - The general area housing remote safety-related panels should be provided with automatic fire detectors that alarm locally and alarm and annunicate in the control room.
Combustible materials should be controlled and limited to those required for operation.
Portable extinguishers and manual hose stations should be provided.
MI1188-0170A-TP11-TP15 73
RESPONSE
F.6 - The engineered safeguards panel is located next to the radiation waste control panel.
There is a portable fire extinguisher in the room and a hose station in the corridor outside the room.
Smoke detectors are installed in the room to provide automatic fire detection.
There is a black plant hot shutdown procedure that would not req~ire the use of this room if a postu-lated fire were to occur.
REGULATORY POSITION F.7 Station Battery Rooms - Battery rooms should be protected against fire explosions.
Battery rooms should be separated from each other and other areas of the plant by barriers having a minimum fire rating of three hours inclusive of all penetrations and openings.
(See NFPA 69, "Standard on Explosion Prevention Systems.") Ventilation systems in the battery rooms should be capable of maintaining the hydrogen concentration well below 2 vol % hydrogen concentration.
Standpipe, hose and portable extin-guishers should be provided.
Alternatives:
(a)
Provide a total fire rated barrier enclosure of the battery room complex that exceeds the fire load contained in the room.
(b)
Reduce the fire load to be within the fire barrier capability of 1-1/2 hours.
or (c)
Provide a remote manual actuated sprinkler system in each room and provide the 1-1/2 hour fire barrier separation.
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RESPONSE
F.7 - There are two separate battery rooms.
They have a three-hour fire barrier from the cable spreading room and from each other.
Each room has a pressurized air intake from the cable spreading room with fusible link dampers installed.
The battery rooms ventilation exhausts to the outside.
A fire extinguisher is located right outside the battery rooms in the cable spreading room.
A hose station is av~ilable right outside the cable spread-ing room door to the turbine building.
The batteries are checked once a day and with the pressurized ventilation system the hydrogen concen-tration is maintained well below 2 vol % hydrogen concentration.
The fire barriers are considered adequate in rela-tion to the fire loading.
Refer to the Fire Hazard Analysis for further details.
REGULATORY POSITION F.8 Turbine Lubrication and Control Oil Storage and Storage and Use Areas - A blank fire wall having a minimum ~esistance rating of three hours should separate all areas containing safety-related systems and equipment from the turbine oil system.
When a blank wall is not present, open head deluge protec-tion should be provided for the turbine oil hazards and automatic open head water curtain protection should be provided for wall openings.
F.9 Diesel Generator Areas - Diesel generators should be separated from each other and other areas of the plant by fire barriers having a minimum fire resistance rating of three hours.
Automatic fire suppression such as AFFF foam or sprinklers should be installed to combat any diesel generator or lubricating oil fires.
Automatic fire detection should be provided to alarm and annunciate in the control room and alarm locally.
Drainage for fire fighting water and means for local manual venting of smoke should be provided.
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RESPONSE
F.8 - The turbine lube oil storage area lS com-pletely separated in an interior structure inside the turbine building.
The room is sprinklered and enclosed by three-hour fire walls except the west wall.
The room has a recessed floor to contain the entire lube oil storage inventory without leakage.
F.9 - The two station diesels, their respective 2,700-gallon day tanks and 600-gallon engine reser-voir tanks ar~ contained in separate diesel engine rooms which are separated by three-hour fire doors from a vestibule access.
Automatic detection is provided by the water flow alarm from the existing fused link-type sprinkler system.
Floor drains are provided in both rooms.
Manual venting of smoke is provided by exhaust dampers mounted in the ceiling to the outside and by a door to the outside from the vestibule.
There ls insufficient air available in the day tank rooms to support any significant combustion.
I I
REGULATORY POSITION F.9 (Contd) - Day tanks with total capacity up to 1,100 gallons are permitted in the diesel generator area under the following conditions:
(a)
The day tank is located in a separate enclo-sure, with a minimum fire resistance.rating of three hours, including doors or penetrations.
These enclosures should be capable of containing the entire contents of the day tanks.
The enclosure should be ventilated to avoid accumulation of oil fumes.
(B)
The enclosure should be protected by automatic fire suppression sy~tems such as AFFF or sprinklers.
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RESPONSE
F.9 (Contd)
(a)
The 2,700-gallon day tanks are each enclosed in a nonventilated cubicle adjacent to the diesel room serviced.
A large floor dike is provided to contain the complete day tank inventory and a 3-hour fire door is the only opening to the cubicle.
The tank is vented to the outside through a 211 pipe.
(b)
The day ~ank cubicles are not provided with sprinkler systems.
Portable fire extinguishers and hose stations serving the diesel generator rooms are available in case of a postulated fire in the day tank cubicles.
The day tank rooms do not have sufficient air to support combustion.
REGULATORY POSITION F.10 Diesel Fuel Oil Storage Areas - Diesel fuel oil tanks with a capacity greater than 1,100 gallons should not be located inside the buildings contain-ing safety-related equipment.
They should be located at least 50 feet from any building contain-ing safety-related equipment, or if located within 50 feet, they should be housed in a separate build-ing with construction having a minimum fire resis-tance ratting of three nours.
Buried tanks are considered as meeting the 3-hour fire resistance requirements.
See NFPA 30, "Flammable and Combusti-ble Liquids Code," for additional guidance.
When located in a separate building, the tank should be protected by an automatic fire suppression system such as AFFF or sprinklers.
Tanks, unless buried, should not be located directly above or below safety-related systems or equipment regardless of the fire rating of_separating floors or ceilings.
In operating plants where tanks are located directly above or below the diesel generators and cannot reasonably be moved, separating floors and main structural members should, as a minimum, have fire resistance rating of three hours.
Floors should be liquid tight to prevent leaking of possible oil spills from one level to another.
Drains should be provided to remove possible oil spills and fire fighting water to a safe location.
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RESPONSE
F.10 - The 30,000 diesel fuel oil storage tank is located outside and underground away from the auxiliary building and safety-related equipment.
77
REGULATORY POSITION F.10 (Contd) - One of the following acceptable methods of fire protection should also be provided:
(a) Automatic open head deluge or open head spray nozzle system(s)
(b)
Automatic closed head sprinklers; or (c) Automatic AFFF that is delivered by a sprinkler system or spray system F.11 Safety-Related Pumps - Pump houses and rooms housing safety-related pumps should be protected by automatic sprinkler protection unless a Fire Hazards Analysis can demonstrate that a fire will not endanger other safety-related equipment required for safe plant shutdown.
Early warning fire detection should be installed with alarm and annunciation locally and in the control room.
Local hose sta-tions and portable extinguishers should also be provided.
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RESPONSE
F.11 - The charging pump area in the auxiliary building does have automatic sprinkler protection.
In addition, a smoke detection system is installed.
However, these pumps are backed up by the high-pressure injection pumps located in the auxiliary building on the next lower level.
Portable extin-guishers are available in both areas.
The component cooling pump area in the auxiliary building does. not have automatic sprinkler protec-tion.
The 3 pumps are located 12 ft apart and the power supply cables for each motor are run in conduit.
Only a light combustible inventory of electric c~ble insulation and lubricants is present.
No single postulated pump or motor fire should affect the other pumps and only 1 of the 3 pumps is required for cold shutdown of the plant.
A portable extinguisher is provided in the room and a fire hose station is located outside the door.
A smoke detection system has been installed in the lower level of the CCW room.
REGULATORY POSITION F.12 New Fuel Area - Hand portable extinguishers should be located within this area.
Also, local hose stations should be located outside but within hose reach of this area.
Automatic fire detection should alarm and annunciate in the control room and alarm locally.
Combustibles should be limited to a minimum in the new fuel area.
The storage area should be provided with a drainage system to pre-clude accumulation of water.
The storage configura-tion of new fuel should always be so maintained as to preclude criticality for any water density that might occur during firewater application.
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RESPONSE
F.12 - Dry chemical portable extinguishers are available in the new fuel area on the 649-ft eleva-tion.
A hose station is provided on the north side of the spent fuel pool.
Combustible materials stored in adjacent areas are being removed and no further storage of combustible material will be permitted in these areas.
New fuel racks are stored in a pit which is open to a pipe way an~ basement pump area at elevation 590 ft.
This pit will be closed with a noncombustible barrier.
Smoke detectors have been installed 1n the north end of the area.
The safety analysis of new fuel racks with respect to possible accidental criticality of stored new fuel has been done and is addressed in Facility Change No 278, modification of new fuel racks.
REGULATORY POSITION F.13 Spent Fuel Pool Area - Protection for the spent fuel pool area should be provided by local hose sta~ions and portable extinguishers.
Automatic fire detection should be provided to alarm and annunciate in the control room and to alarm locally.
F.14 Radwaste Building - The radwaste building should be separated from other areas of the plant by fire barriers having at least three-hour ratings.
Automatic sprinklers should be used in all areas where combustible materials are located.
Automatic fire detection should be provided to annunciate and alarm in the control room and alarm locally.
During a fire, the ventilation systems in these areas should be capable of being isolated.
Water should drain to liquid radwaste building sumps.
Acceptable alternative fire "protection is automatic fire detection to alarm and annunciate in the control room, in addition to manual hose stations and portable extinguishers consisting of hand held and large wheeled units.
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RESPONSE
F.13 - Portable fire extinguishers and a hose station are provided for the spent fuel pool area.
Smoke detectors have been installed in the north end.
80 F.14 - The radwaste areas are contained within the auxiliary building on several floor levels.
Auto-matic sprinklers are not provided in the radwaste areas.
Only light combustible material inventories exist in these areas.
Ventilation systems for these areas are automati-cally isolated and shut down on high radiation detected in the filter plenums.
Al1 floor and equipment drain sumps are collected for processing or storage in radwaste tanks prior to discharge.
Ma~ual hose station and portable extinguishers provide the primary fire protection in these areas.
Portions of the VRS building and the track alley are protected by an automatic dry pipe sprinkler system.
Portable extinguishers and hose stations are also provided.
REGULATORY POSITION F.15 Decontamination Areas - The decontamination areas should be protected by automatic sprinklers if flammable liquids are stored.
Automatic fire detection should be provided to annunciate and alarm in the control room and alarm locally.
The ventila-tion system should be capable of befng isolated.
Local hose stations and hand portable extinguishers should be provided as backup to the sprinkler system.
F.16 Safety-Related Water Tanks - Storage tanks that supply water for safe shutdown should be protected from the effects of fire.
Local hose stations and portable extinguishers should be provided.
Portable extinguishers should be located in nearby hose houses.
Combustible materials should not be stored next to outdoor tanks.
A minimum of 50 feet of separation should be provided,between outdoor tanks and combustible materials where feasible.
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RESPONSE
F.15 - Decontamination areas of the plant are an integral portion of the auxiliary building.
Fire protection is provided by the existing firewater system.
Radwaste ventilation systems serving the decontamination areas are automatically isolated and shut down on high radiation detected in the filter plenums.
F.16 - Storage tanks are located in separate build-ing spaces of the plant or outside.
The boric acid tanks are located in the auxiliary building inside a separate concrete compartment.
The Safety Injection Tank (SIRW) is located on the auxiliary building roof and the condensate storage tanks are located outside and protected by the yard firewater loop and hose houses.
REGULATORY POSITION F.17 Cooling Towers - Cooling towers should be of noncombustible construction or so loca.ted that a fire will not adversely affect any safety-related systems or equipment.
Cooling towers should be of noncombustible construction when the basins are used for the ultimate heat sink or for the fire protec-tion water supply.
Cooling towers of combustible construction, so located that a fire in them could adversely affect safety-related systems or equipment should be protected with an open head deluge system installation with hydrants and hose houses strategi-
. cally located.
F.18 Miscellaneous Areas - Miscellaneous areas such as records storage areas, shops, warehouses, and auxiliary boiler rooms should be* so located that a fire or effects of a fire, including smoke, will not adversely affect any safety-related systems or equipment.
Fuel oil tanks for auxiliary boilers should be buried or provided with dikes to contain the entire tank contents.
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RESPONSE
F.17 - The cooling towers are not fire resistant.
However, the cooling towers are located approxi-mately 400 feet to 600 feet from the plant and serve no safety function.
The loss of the cooling towers would not jeopardize* the safety of the plant or impair any safe shutdown function.
F.18 - Other storage areas, fuel oil tanks for auxiliary boilers and heating system auxiliaries are located in th~ turbine building or separate compart-ments away from safety-related structures, equipment and systems.
The records storage area 1s located on the third level of the support building away from safety-related areas.
REGULATORY POSITION G.
Special Protection Guidelines
- 1.
Welding and Cutting, Acetylene-Oxygen Fuel Gas Systems - This equipment is used in various areas throughout the plant.
Storage locations should be chosen to permit fire protection by automatic sprinkler systems.
Local hose equipment should be provided as backup.
The requirements of NFPA 51 and 51B are applicable to these hazards.
A permit system should be required to utilize this equipment.
(Also refer to 2.f, herein.)
- 2.
Storage Areas for Dry Iron Exchange Resins - Dry ion exchange resins should not be stored near essential safety-related systems.
Dry unused resins should be protected by automatic wet pipe sprinkler installations.
Detection by smoke and heat detec-tors should alarm and annunciate in the control room and alarm locally.
Local hose stations and portable extinguishers should provide backup for these areas.
Storage areas of dry resin should have curbs and drains.
(Refer to NFPA 92M, "Waterproofing and Draining of Floors.")
MI1188-0170A-TP11-TP15 83
RESPONSE
G.l - Spare acetylene-oxygen bottles are stored in
~ks outside the machine shop next to the ware-house.
Automatic sprinklers are not provided; however, there are hose stations and portable fire extinguishers nearby.
Based on the Fire Hazards Analysis, this is considered adequate.
The use of this equipment is administratively controlled.
- 2.
The resins are stored in the new radwaste building storage area until required for use.
The storage area is away from safety-related areas.
Hose stations and a fire extinguisher are nearby.
The "Resin Drum Storage" area shown on Drawing M-4 near the electrical penetration area is not used as a storage area for ion exchange resins.
REGULATORY POSITION G. (Contd)
- 3.
Hazardous Chemicals - Hazardous chemicals should be stored and protected in accordance with the reconunendations of NFPA 49, "Hazardous Chemicals Data."
Chemicals storage areas should be well ventilated and protected against flooding conditions since some chemicals may react with water to produce ignition.
- 4.
Materials Containing Radioactivity - Materials that collect and contain radioactivity such as spent ion exchange resins, charcoal filters, and HEPA filters should be stored in closed metal tanks or containers that are located in areas free from ignition sources or combustibles.
These materials should be protected from exposure to fires in adjacent areas as well.
Consideration should be given to requirements for removal of isotopic decay heat from entrained radioactive materials.
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RESPONSE
G. (Contd)
- 3.
All of the chemicals stored onsite were reviewed against NFPA 49 and a listing of those that were found in NFPA 49 was developed.
This list has been used to evaluate the actual storage conditions at the site.
- 4.
Spent ion exchange resins that are radioactive are routed to.the spent resins storage tank, T-69 and T-100, for storage and decay before offsite shipment in sealed shipping casks.
Charcoal and HEPA filters used in the plant have only minor radioactivity and are generally stored in their original containers in a controlled area outside the plant.
REGULATORY POSITION V.
Regulatory Guide 1.78*
B.
Discussion - The control room of a nuclear power plant should be appropriately protected from hazard-ous chemicals that may be discharged as a result of equipment failures, operator errors, or events and conditions outside the control of the nuclear power plant.
The purpose of this guide is to identify those chemicals which, if present in sufficient quanti-ties, could results in the control room becoming uninhabitable.
The general design considerations that are used in assessing the capability of the control room, as designed, to withstand hazardous chemical releases, occurring either on the site or within the surrounding area are presented.
Some of the chemicals specifically identified, such as helium and nitrogen, should generally not present a pr-oblem except when very large quantities are stored on the site. Asphyxiating chemicals such as these need not be considered unless a significant fraction of the control room air could be displaced as a result of their release.
Fire fighting equipment used for fighting chemical and electrical fires should be considered as a potential sources of hazardous chemicals.
- As related to habitable areas such as the control room and the use of specific fire extinguishing systems.
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RESPONSE
Palisades Plant - Docket No 50-255 V.B - There are no large amounts of asphyxiating chemicals located onsite.
Small amounts of nitrogen are stored onsite in high-pressure bottles.
C02 extinguishers are provided in the control room.
Self-contained breathing apparatus are available in the control room in the unlikely event that the C02 level becomes-too high during fire fighting attempts.
REGULATORY POSITION C.
Regulatory Position - In evaluating the habit-ability of a nuclear power plant control room during a postulated hazardous chemical release, the follow-ing assumptions should be made:
- 1. If major depots or storage tanks of hazardous chemicals such as carbon dioxide and Halon are known or projected to be present within a five-mile radius of the reactor facility, these chemicals should be considered in the evaluation of control room habitability.
- 4.
The toxicity limits should be taken from appro-priate authoritative sources such as those listed in the reference section.
For each chemical consid-ered, the values of importance are the human detec-tion threshold and the maximum concentration that can be tolerated for two minutes without physical incapacitation of an average human (ie, severe coughing, eye burn, or severe skin irritation).
The latter concentration is considered the "toxicity limit." Table C-1 gives the toxicity limits (in ppm by volume and mg/m*) for the chemicals listed.
Where these data are not available a determination of the values to be used will be made on a case-by-case basis.
- WASH-1238, "Environmental Survey of Transportation of Radioactive Materials To and From Nuclear Power Plants," December 1972.
Copies may be obtained from National Technical Information Service, 5285 Port Road, Springfield, Virginia 22151.
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RESPONSE
C. - There are no large amounts of hazardous chemi-cals stored within a five-mile radius of the plant.
REGULATORY POSITION TABLE C-1 SOME HAZARDOUS CHEMICALS POTENTIALLY INVOLVED IN ACCIDENTAL RELEASES FROM STATIONARY AND MOBILE SOURCESa Taxi city Limit Chemical mg/m3d Carbon dioxide 1,840 Halon 8 This list is not all-inclusive but indicates the hazardous chemicals most commonly encountered.
cParts of vapor or gas per million parts of air by volume at 25°C and 760 torr (standard temperature and pressure) dApproximate milligrams of particulate per cubic meter of air, at standard temperature and pressure, based on listed ppm values.
ePercent by volume MI1188-0170A-TP11-TP15
RESPONSE
There is one Halon system used onsite.
A Cardox System is used for the main generator purge system and does not present a hazard to the control room personnel.
87
REGULATORY POSITION HABITABILITY EVALUATION Chemical
- 1.
Name of hazardous chemical
- 2.
Type of source (stationary, mobile, or onsite)
- 3.
Human detection threshold, ppm
- 4.
Maximum allowable two-minute concentration (toxicity li~it as defined in Regulatory Position 4, ppm and mg/m )
- 5.
Maximum quantity of hazardous chemical involved in incident
- 6.
Maximum continuous release rate of hazardous chemical
- 7.
Vapor pressure, torr, of hazardous chemical (at maximum ambient plant temperature)
- 8.
Fraction of chemical flashed and rate of boiloff when spilling occurs
- 9.
Distance of source from control room, miles
- 10.
Five percentile meteorological dilution factor between release point and control room for instanta-neous and continuous releases MI1188-0170A-TP11-TP15
(
88
RESPONSE
REGULATORY POSITION HABITABILITY EVALUATION (Contd)
.Control Room
- 1.
Volume of control room, including the volume of all other areas supplied by §he control room emer-gency ventilation system, ft *
- 2.
Normal flow rates for volume defined above, cfm*:
Unfiltered inleakage or makeup air Filtered makeup air Filtered recirculated air
- 3.
Emergency flow rates for volume defined above, cfm* (as in Item 2, above)
- 4.
Time required to isolate the control room, sec
- "Filtered air" refers to the air filtered through filters whose removal capability for the particular chemical being considered has been established.
MI1188-0170A-TP11-TP15 89
RESPONSE
REGULATORY POSITION VI.
Regulatory Guide 1.101*
Regulatory Guide 1.101 - Emergency Planning for Nuclear Power Plants
- As related to fire protection emergency planning HI1188-0170A-TP11-TP15
RESPONSE
Palisades Plant - Docket No 50-255 The applicable sections. related to fire protection are discussed in Section D, Paragraph B.5 of this report.
90