ML19242B412
| ML19242B412 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck, Millstone File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 07/31/1979 |
| From: | Counsil W NORTHEAST UTILITIES |
| To: | Ziemann D Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7908080476 | |
| Download: ML19242B412 (33) | |
Text
t l'10lfi'HI!JL!iT UTII.ITII!!i N
N P O BOX 270 1
- 1ARTFORD CONNECTICUT 06101 (203# fie-0911 July 31, 1979 Docket Nos. 50-213 50-245 50-336 Director of Nuclear Reactor Regulation Attn
Mr. D. L.
Ziemann, Chief Operating Reactors Branch #2 Mr.
R.
Reid, Chief Operating Reactors Branch #4 U.
S. Nuclear Regulatory Commission Washington, D. C.
20555
References:
(1)
D. L.
Ziemann letter to W. G. Counsil dated October 3, 1978.
(2)
D. L. Ziemann letter to W. G. Counsil dated September 26, 1978.
(3)
R.
Reid letter to W. G. Counsil dated September 19, 1978.
(4)
W. G. Counsil letter to D. L. Ziemann and R. Reid oated July 19,197 9.
Gentlemen:
Haddam Neck Plant Millstone Nuclear Power Station, Unit Nos. 1 and 2 Fir e Protection In References (1), ( 2), a nd (3), the NRC Staf f issued License Amendments and associated Saf ety Evaluation Reports regarding Fire Protection for the Haddam Neck Plant, Millstone Unit No. 1, and Millstone Unit No. 2, respectively.
In Section 3 of each of the above Ref erences, a schedule of license submittals on various aspects of fire protection madifications was provided.
In the majority of cases, the scheduled submittal date was July 1,1979.
In Reference (4 ), information previously provided verbally to the NRC Staff regarding revised submittal dates was formally documented.
It was anticipated that one submittal, addressing the topics included in Table 3.2 of Reference (1),
Table 3.1 of Reference (2), and Table 3.1 of Reference (3) wauld be prov id ed on or about July 31, 1979. Accordingly, additional information with regard to the above topics is hereby provided in Attachments 1, 2, and 3 to this letter for the Haddam Neck Plant, Millstone Unit No. 1, and Millstone Unit No.
2.
306 0Si 7 90808 0 y'76 i
. As noted in Ref erence (4), the majority of the material being provided at this time has been the subject of telephone discussions between our respective Staffs.
It is our current understanding that resolution has been achieved regarding these topics.
Connecticut Yankee Atomic Power Company (CYAPCO) and Northeast Nuclear Energy Company (NNECO) truat that this information fulfills the commitments or Ref erences (1), (2), and (3).
Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY NORTHEAST NUCLEAR ENERGY COMPANY
)ll I*l('71aG
/)
'l
/0 / l 4
W. ' G. Cutisil Vice President At tacinent s 506 052
DOCKET NO. 50-213 ATTACIB1ENT 1 HADDAM NECK PLAhT ADDITIONAL INFORMAT10N FIRE PROTECTION 506 053 JULY, 1979
NRC - SER ITEM 3.2.1 ALTERNATE SIIUTDOWN CAPABILITY
_NRC CONCERN An alternate means of saf e shutdown should be provided which is independent of systems which could be damaged by fires in the following areas: a) Control Room, b) Switchgear Room, c) Cable Spreading Area, d) PAB, e) Cable Vault, f) Containment.
RESPONSE
As noted in the W. G.
Counsil letter to D. L. Ziemann dated August 29, 1978:
CYAPCO believes that most of the important design criteria and methods used for the alternate shutdown system will be agreed upon during the Systematic Evaluation Program (SEP). at that time, it was expected that the last of these areas of agreement will be fiaalized in late spring of 1980.
The subsequent evaluation, its results, and modifications deemed necessary could take up to three year _ from that point.
Thus, we.. auld expect that any modifications would be implemented by late 1983. CYAPCO wishes to note that conceptual design of the system has commenced. The overall schedule for the system will be periodically reassessed at various points during the SEP so as to consider the progress in determination of design criteria.
506 054
NRC - SER ITE}! 3.2.2 SMOKE DUTECTION SYSTEM TESTS NRC CONCERN The licensee is evaluating a nethod to conduc t ir-situ tests with a suitable smoke generation F 2vice to verif y that a fire would be promptly detected by installed smoke detectors and that ventilation air flow patterns in the area do not significantly reduce or pr event detection response.
lienc h t e s t s will be cor%cted to verif y that smoke detectors will provide p. rom p t response and have acequate sensitivity to the products of combustion for the combuatibles in the area where smoke detectors are installed.
If any fire detection systems are f ound to be inadequate, appropriate modifications will be made to provide adequate performance (4. 2).
RESPONSE
CYAPCO has been actively invclved in researching and investigating a method of in-situ testing for the 11addam Leck Plant. Various concepts have been reviewed /
analyzed and it appears that N"TECli has developed an in-situ testing technique which merits further investigation.
NUTECll's concept of in-situ testing was demonstrated and discussed with the NRC Staff in a meeting in liet hesda on June 21, 1979.
CYAPCO has evaluated NUTECll's concept of in-situ testing and concludes that althout;h NUTECll's concepts have advanced the state-of-the-art, more testing or qualification is appropriate to provide assurance cf an acceptable test.
Several utilities and NUTECll are now considering sponsoring a prototype test program to qualif y NUTECll's technique. The results of this testing would be useful in determining the acceptability of NUTECll's concept / technique.
CYAPCO will continue to evaluate taethods of conducting a usef ul, acceptable in-situ test of existing detection systems.
In the interim, it reru ins CYAPCO's position that a demonstrated, reliable method of conduc ting in-situ tests of smoke detectors is not currently available. The completed or in-progress fire protection modifications includ ing; extensive fire detection and suppression provide adequate assurance that postulated fires would be dealt with prompt 1/.
This assurance is enhanc ed by the consideration siven to fire loadings, produc ts of ecmbustion, and ventilation paths in the installation of fire detection equipment.
.r-P*
5au
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NRC - SER I T EM 3. _'_. 3 CABLE FIRE BARRIER PENETRATIONS TEST DATA NRC CONCERN fest data will be provided to d e:no n s t ra t e the adequacy of electrical catale fire barrier penetrations.
RESP 0NSE All cable penetrations sealed at the lladdam Neck Plant have been sealed using Dow Co r ning Q3-65'+6 med ium density S ilicone RTV Foam.
Tne penetratica seal installer, Insulation Consultant and Management Service, Incorporated (ICMS),
cert i t ies the mat er ials used to the ASTM El19-73 Fire Endurance test.
i'h i s
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tet i
retlect raceway type, percent obs t: uc t i on, anJ
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.o. 2 6 5 '+ 1 U+ o l 0 ) da t ed Oc tobor 28, 1975 and t h<
iow Corninc and ICM.
ttst, Factor-lutual :,o t)Roy l AM (4610) dated
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IS, l'377, 506 056
mem new product L _;
informat.on DOW CORNlt4Ge 03-6548 SILICONE RTV F0AM (MEDIUM DENSITY)
(Black, reversion resistant, non-corrosive, improved fire resistant, closed cell).
Dow Corning % Q3-6548 Silicone RTV Foam is a two-part product supplied as A and B liquid components.
The A component is black and the B component is off white for easy identification a r. d inspection for completeness o( mix.
When ths A and B thoroughlf mixed in a one to one ratio by componenes are either weight or volume the product will expand, and cure to a fmmed elastomer at room temperature.
Only a mild exotherm (20 C maximum internal temperature rise) is exhibited during the curing reaction.
CIs t ' T ION :
During and shortly after the foam expansion period, a small quantity of hydrogen gas is evolved from the foam product, and appropriate caution should be exercised.
Keep away from sparks and flame.
Adequate ventilation should be provided to prevent localized build-up of gas.
(See section on gas evolution).
Dow Corningt Q3-6548 Silicone RTV Foam is specially formulated to have improved fire resistant properties.
As a result of these unique properties, this material has been used to prepare f;re stops and penetration seals.
The suitability of Dow Corninga Q3-6548 Silicone RTV Foam for applications of this type is evidenced by the resul
'fter testing according to the ASTM E 119-73 Fire Endurance 'l c, where five hours of fire exposure were successfully maintained according to the 506 057
~._ __ _,. _._, _,,....,
conde satisf ac tory performance before Commercalu.fiort $wggest_S Of uses should rmt be taken es erlducements to erheQ4 Ony pe(16Cular P4 tent DOW CORNING CORPORATION, MIDLAND, MICHIGAN 48840 TELEPHONE 517-g W]
496-4000
severe parameters of this test.
This test was conducted at the National Gypsum Company and witnessed by a representative of the Factory Mutual Research Corporation.
A formal report is available by requesting the Factory Mutual Serial No. 24963.
It should be specifically noted that not all silicone foams have improved fire resistant properties.
The use of the generic term " Silicone Foam" should be avoided when referenc-ing this product or data.
This test data is valid only to this product by its specific name and number designation, namely, Dow Corning @ 03-6548 Silicone RTV Foam.
Dow Corning @ 03-6548 Silicone RTV Foam has demonstrated utility in a variety of other applications that require sealability, improved fire resistance (see test methods and data on Page 4),
l insulation against heat and cold, and low toxicity It is particularly useful where stability at higher and lower temperatures is required.
The following is a list of application requirements and the related pertinent properties for which data is or will be available on Dow Corning @ 03-6548 Silicone RTV Foam.
Application Requirement Related Property
- Sealability Closed cell structure Expansion ratio during cure
- Insulation against hot and cold Termal conductivity K Factor
- Iiigher temperature stability Thermal aging Reversion resistance 1 The hazardous decomposition products due to extreme heat or burning of this product are SiO2, CO2 and traces of incompletely burned carbon products.
ggg
- Jdo, UJv
- Lower temperature stability Stiffening temperature
- Flame retardancy (cured foam)
Vertical Burn Limiting oxygen index
- Flammability of liquid com-Flash point ponents Fire point
- Toxicity Toxicity of by-products Toxicity of product
- Nuclear applications Radiation resistance Halogen content Testing of Dow Corninge Q3-6548 Silicone RTV Foam is continuing with respect to the above specific material properties and related applications.
Toxicologic properties of this material have not been thoroughly studied. Toxicity data on similar silicone materials indicate this product should pose no hazard to health.
Additional data will be supplied upon request as it becomes available.
TYPICAL PROPERTIES (Not intended for use in preparing specifications)
As Supplied Part A Dow Corning Corporation Test Method ASTM Property-Physical CTM 0176 Appearance Black liquid CTM 0044 D 70 Specific Gravity 1.05 CTM 0050 D 1084 Viscosity, poise 50 (Brookfield Model HAF spindle No. 3 at 10 rpms)
Shelf Life, Months 6
506 0b9 7
CTM 0006 D92 Flash Point, F
470 CTM 0006 D92 Fire Point, F
Greater than 650 CTM 0787 Sulfur None detected, less than 2 ppm Chlorine None detected, less than 4 ppm Bromine None detected, less than 5 ppm Iodine None detected, less than 6 ppm Test Method ASTM Property-Electrical (50 mils Liquid)
CTM 0114 D877 Dielectric Strength, volts / mil 680 CTM 0210 D924 Dielectric Constant, 100 Hz 3.08 CTM 0210 D924 Dissipation Factor, 100 Hz 0.00103 CTM 0272 D169 Volume Resistivity, 500 volts 12 DC, ohm-cm 3.23 x 10 As Supplied Part B Dow Corning Corporation Test Method ASTM Property-Physical CTM 0176 Appearance off White Liquid CTM 0044 D70 Specific Gravity 1.05 CTM 0050 D1084 Viscosity, poise 60 (Brookfield Model HAF Spindle No. 3 at 10 rpms)
Shelf T. ife, Months 6 CTM 0006 D92 Flash Point, F
270 CTM 0006 D92 Fire Point, F
390 CTM 0787 Sulfur None detected, less than 2 ppm Chlorine None detected, less than 4 ppm 506 060 1
Bromine None detected, less than 5 ppm Iodine None detected, less than 6 ppm Test Method ASTM Property-Electrical '50 mils Liquid)
CTM 0114 D877 Dielectric Strength, volts / mil 900 CTM 0210 D924 Dielectric Constant, 100 Hz 3.29 CTM 0210 D924 Dissipation Factor, 100 Hz 0.0034 CTM 0272 D169 Volume Resistivity, 500 volts 12 DC, ohm-cm 3.38 x 10 PROPERTIES OF CURED FOAM (THOROUGHLY MIXED ONE PART OF A WITH ONE PART OF B AND CURED AT 23 C.FCm A MINIMUM OF 24 HOURS Test Method Property-Physical CTM 0176 Appearance Dark Gray-Black Elastomeric Foam CTM 0812 Density (power mixed for 30 seconds and cured in non-3 confined condition) lbs/ft 17 CTM 0826 Cell structure, percent closed cell (breathability method) 95 CTM 0224 Thermal conductivity 1.8x10-4 (cenco fitch method)
Cal cm/sec sq cm deg C CTM 092A Snap Time (time to non-pour condition.
Also time to begin foam rise), minutes 1.5 CTM 0316A Flammability (vertical burn)
Average Time to Average parcent Time in Flame Flame-& Glow-out Weight Loss 15 seconds 7.2 seconds 1.3 60 seconds 15.6 seconds 13.5 CTM 0780 Limiting Oxygen Index (L.O.I. Rating) 35 o/i
'O d3i The above listed tests, claims, representations and descriptions regarding the flammability of the product described are based on standard small scale laboratory tests and as such are not reliable for determining, evaluating, predict-ing or describing the flammability or burning characteristics of this product under actual fire conditions, whether said product is used alone or in combi-nation with other products.
Property-Electrical (cured foam Test Method ASTM sample thickness - 125 mils)
CTM 0014 D877 Dielectric Strength, volts / mil 165 CTM 0112 D150 Dielectric Constant, 100 Hz 1.95 CTM 0112 D150 Dissipation Factor, 100 Hz 0.00505 15 CTM 0249 D257 Volume Resistivity, ohm-cm 2.24 x 10 Test Method Property - Radiation Resistance Modulus at 10%
CTM 0525 Exposure, megarads compression, PSI O
0.628 6
0.672 22 0.92 49 2.00 124 2.32 Still Resilient MIXING On standing some filler may settle to the bottom of the A and B component containers.
To ensure a uniform product mix, the material in the A and B containers should be thoroughly mixed just prior to use.
500 062
To properly catalyze Dow Corning @ Q3-6548 Silicone RTV Foam add an equal quantity of Part A with an equal quantity of Part B by either weight or volume.
For batch mixing by hand or power et-vigorously and thorough mixing should be main-tained for 30 to 60 seconds.
The mixed product should then be quickly transferred and poured into the desired application site.
For larger volume applications the use of suitable automatic mixing, metering, and dispensing equipment is recommended.
The type or degree of mixing can significantly affect the cell structure and density of the final foam oroduct.
The intro-duction of air during the mixing ac, tion is desirable to obtain a more uniform cell structure and maximum expansion ratio and volume efficiency.
Typical batch hand mixing will generally 3
result in a foam density of about 20 lbs/ft Batch power 3
mixing will generally result in a density of about 17 lbs/ft Automatic mixing, metering and dispensing equipment with intro-duction of auxiliary air into the mix, can result in foam 3
densities as low as 15 lbs/ft Likewise, the expansion ratios of foam volume to liquid volume can vary from 2.5/1 to 4/1 depending on the type and degree of mixing.
When cured under significant confinement and restriction, foam densities packed 3
as high as 28 to 29 lbs/ft can result.
CURE RATE As supplied and properly mixed, Dov Corning 1 Q3-6548 Silicone RTV Foam has a snap time or working time of between 1 and 3 minutes at room temperature, where a typical snap time would be about 1.5 minutes.
The cure rate or snap time is very dependant upon the temperature of the A and B components after they are mixed.
506 063 9 Q3-6548 SILICONE RTV FOAM SNAP TIME VS TEMPERATURE DOW CORNING AFTER MIXING PART A WITH PART B 13 -
e TEMPERATURE ( F) SNAP TIME -MINUTES 12 32 (O C) 13.2 11 -
43 (60C) 6.7 72 (230C) 1.5 100 (370C) 0.3 10 122 (500C) 0.25 SNAP TIME MINUTES 9
8 o,
C 6
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Os 4
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0 20 40 60 80 100 120 TEMPERATURE - F
As shown in the graph and table below, temperatures lower than 23 C (72 F) will result in significantly longer cure rates, while temperatures higher than 23 C (72 F) will result in significantly shorter cure rates.
Snap times faster than 1 minute and longer than 3 minutes can result in a less uniform foam cell structure and a lower expansion ratio.
REPAIRABILITY Once cured in place, Dow Corning @ Q3-6548 Silicone RTV Foam can be removed with relative ease, repairs or changes made, and the Since repaired area re-foamed in place with additional product.
this product develops good adhesion to itself, the repaired region will become an integral part of the original foam.
ADHESION dpon curing, Dow Corningo Q3-6548 Silicone RTV Foam exhibits good adhesion to most common substrates.
Substrates to which good adhesion is not normally obtained would include Teflone, polyethylene, polypropylene and related materials.
Adhesion to most substrates can be improved with the use of Dow Corninge 1200 Primer.(2)
Good adhesion cannot be expected to substrates known to inhibit the cure of Dow Cornings Q3-6548 Silicone RTV Foam as listed in the following section.
(2) CAUTION:
Dow Corning @ 1200 primer is flammable.
Keep away from heat and open flame.
Use only with adequate ventilation.
INHIBITION OF CURE Certain materials, chemicals, curing agents, and plasticizers can inhibit the cure of Dow Corninge Q3-6548 Silicone RTV Foam.
Most notable of these are:
- Organo-tin and other organo-metallic compcunds
- Silicone rubber containing organo-tin catalyst
_3_
- Amines, urethanes, or amine containing materials
- Unsaturated hydrocarbon plasticizers If a substrate or material is questionable with respect to potentially causing inhibition of cure, it is recommended that a small scale compatibility test be run to ascertain suitability _ in a given application.
The presence of liquid or uncured product at the interface between the questionable substrate and the cured Dow Corning @ 03-6548 Silicone RTV Foam would indicate incompatibility and inhibition of cure.
GAS EVOLUTION Immediately upon mixing the A and B components of Dow CorningE C3-6548 Silicone RTV Foam, a cure rea'ction takes place that results in the evolution of hydrogen gas (see caution on page 1).
The product then cures to an elastomer in the presence of the evolved gas resulting in a solid, flexible, elastomeric foam.
Since the foam is greater than 90% closed cell, the gas is not immediately released to the surrounding atmosphere, but instead is released over a time period by diffusion.
The total volume of gas is essentially generated during the first three minutes after the A and B components are mixed together.
Since the foam has a closed cell structure, the gas is initially retained and then released as shown by the graph and table listed below.
This data shows that one part by weight or volume of Part A mixed with one part by weight or volume of Part B will release 8.7 parts by volume of hydrogen gas at S.T.P.
during the first 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
More than one half of the total gas evolution is released from the foam during the first hour subsequent to mixing the A and B components.
AVAI LABI LITY 900 lb kits 100 lb kits 506 066 r
DOW CORNING Q3-6548 SILICONE RTV FOAM HYDROGEN GAS VOLUME / RATE 8
EVOLUTION AFTER MIXING PART A WITH PART B IN A 1 TO 1 RATIO BY EITHER WElGHT OR VOLUME e
8 RESULTS AFTER MIXING 1 PART Q3-6548A 7
WITH 1 PART Q3 6548B BY EITHER WElGHT OR VOLUME.
TIM F - MINUTES PARTS BY VOLUME H2 GAS EVOLVED AT S.T.P.
6 1
0.9 PARTS BY 5
1.2 VOLUME OF 0
1.4 HYDROGEN 5
20 2.0 i
GAS 95 3
120 6.7 S T P-4 200 7.5 240 7.8 270 8.0 tr 3
340 8.4 C-400 B.5
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500 8.7 2
o 1
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I O
100 200 300 400 500 TIME - MINUTES
DOC KET NO. 50-245 ATTACIDIENT 2 MILLSTONE NUCLEAJ. POWER STATION, UNIT NO. 1 ADDITIONAL INFORMATION FIRE PROTECTION 506 063 JULY, 1979
NRC - SER IT EM 3. 2.1 SMOKE DETECTION SYSTEM TESTS NRC CONCERN The licensee is evaluating a method to conduct in-situ tests with a suitable smoke generation device to verify that a fire would be promptly detected by installed smoke detectors and that ventilation air flow patterns in the area do not significantly reduce or prevent detection response.
Bench tests will be conducted to verif y that smoke detectors will provide prompt response and have adequase sensitivity to the products of combustion for the combustibles in the area where smoke detectors are installed.
If any fire detection systems are found to be inadequate, appropriate modifications will be made to provide adequate performance (4. 2 ).
RESPONSE
NNECO has been actively involved in researching and investigating a method of in-situ testing for the operating plants. Various concepts have been reviewed / analyzed and it appears that htTECH has developed an in-situ testing tecimique which merits further investigation.
NUTECH's concept of in-situ testing was demonstrated and discussed with the NRC Staf f in a meeting in Bethesda on June 21, 1979.
NNECO has evaluated NUTECH's concept of
- -situ testing and concludes that although some of NUTECH's concepts have advanced the state-of-the-art, more testing or qualification is appropriate to provide assurance of an acceptable test.
Several utilities and NUTECH are now considering sponsoring a prototype test program to qualif y NUTECH's technique. The results of this testing would be useful in determining the acceptability of NUTECH's concept / technique.
NNECO will continue to evaluate methods of conducting a useful, acceptable in-situ cest of existing detection systems.
In the interim, it remains NNECO's position tlut a demonstrated, reliable method of conduc ting in-situ tests of smoke detectors is not currently available. The completed or in-progress fire protection modifications including extensive fire detection and suppression ptovide adequate assurance t hat postulated fires would be dealt with promptly.
This assurance is enhanced by the consideration given to fire loadings, products of combustion, and ventilation paths in the installation of fire detection equipment.
500 069
NRC - SER ITEM 3.2.2 FIRE HOSE STATION EVALU1 TION NRC CONCERN Hose stations will be verified to be capable of supp ing a pressure of 1
65 psig at the nozzle under flowing conditions.
Larger pipe sizes will be provided if required to provide a hose nozzle pressure to ensure adequate hose stream throw (4. 3.1.d ) (5. 3 ).
RESPONSE
An evaluation of Millstone Unit No. I hose sta tions was conduc ted :o determine if NRC Staf f's minimum requirements of 65 psig is available at the hose sta tion nozzle under flowing conditions.
The hose stations selected for this evaluation were H.S-44 and H.S-45 as shown on attached sketch.
Please not<_ that the location of the hese stations selected is the 108'6" level of the reactor building. The reason for this selection is that the 108' level represents the most sever cond it ion s from a pressure consideration.
Hose station #43 is also tocated at this level but was not pressure tested. This hose station is being relocated on the stairwell area for better coverage and, therefore, new pipe size and length will be provided to exceed the required pressure.
The actual pressure test performed for the noted hose stations was conducted as follows:
(1) The Millstone Unit No. 2 electric pump was manually started.
(2)
Static pressure was recorded at both hose stations.
(3)
Residual pressure was recorded with gage at hose station.
(4 )
Residual pressure was recorded with gage at nozzle oatlet.
(5)
Sath hose stations contained 100' of 1-1/2" rubber-lined hose.
(6)
Spray nozzles were adjustable fog spray nozzles as specified by NRC.
(7)
Pipe lengths and number / type of fittings from stnnd pipe riser to hose station was recorded.
The results of the hose station pressure test were as follows.
b/l
NRC - SER Item 3.2.2 Fire Hose Station Evaluation Page 2 1
Static Residual Pres. l Residual Pres.
Pipe Length No. of Pressure Gage at li. S.
Gage at Nozzle to Riser Fittings 6
ll. S. #44 92 psig 78 psig 72 psig 32 ft.
7-90 elbows, 1
I I
elbowsf 132 ft.
7-90 II.S. #45 92 psig 70 psig 65 psig
{
1-45 elbow !
i Based on the actual test data documented above, Millstone Unit No. 1 concludes tha t their stand pipe hose station system complies with NRC's minimum require-ments of 65 psig at hose station nozzle under flowing conditions.
506 071
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DOCKET NO. 50-136 ATTACletENT 3 MILLSTONE NUCLEAR POWER STATION, UNIT NO. 2 ADD IT IO NAL INFORMATION FIRE PROTECTION S ri e
'3 s
au'v. 1979 m
NRC - SER ITEM 3.2.1 CABLE SPREADING AREA NRC CONC ERN The licensee will conduct an evaluation to determine a suitable method to provide isolation, separation, or protection of redundant safety-related cables in the cable spreading area (4.1 ), (5.2).
RESPONSE
An evaluation of the Millstone Unit No. 2 cable spreading area has been completed and corrective action will be implemented a s de fined below.
The intent of the evaluation was to :
(1) Determine the extent of existing physical separation between redundant cables of saf ety-related f acilities.
(2)
Determine the adequacy of existing saiety-related cable separation based upon comparisons between all of the following :
(a ) Original plant design cable separation criteria.
(b) The extent of accessibility into the var ious areas of the cable vaelt for manual fire fighting and personnel safety.
(c )
Existing methods of supp ession and detection.
(d ) Cable raceway separation and density combinations known to be acceptable to NRC as a result of their recent fire protection inspections of the Millstone Unit No. 2 cable vault.
(e) Cable type - IEEE 383, thermoset jacket, etc.
(3)
Recommend correc tive actions where necessary to assure t ha t a fire would not involve redundant saf ety-related systems.
In order to accurately evaluate the Millstone Unit No. 2 cable spreading area, the area was sectionalized to account for varying degrees of cable raceway densit ies.
The following represents our findings and recommendations on a sec t ion-by-sec t ion ba sis.
(1)
Section:
Column 15, 16/A, E5 Cable Vault, Turbine Area Elevation 25' Design Features This section contains the west entrance to the cable vault, risers to upper switchgear room cable vaults, and a 12" thick floor to ceiling reinforced block fire wall separating Z1 and Z2 f acilities. Accessibility for manual fire fight ing is adequa te.
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I]f\\hbo O/M
NRC - SER ltem 3.2.1 Cable Spreading Area Page 2 This area contains Z1 conduits Z17930-1 and Z17383-1 routed along colume E3 just above f acility Z2 cable trays containing redundant HVAC cables.
Recommendation Fire retardant barriers will be lastalled to separate the two tacilities.
(2)
Section:
Column 15,18.9/ E5, F8 Cable Vault Area 6 and West Penetration Area Elevation 25' Design Features This section contains light to moderate cable raceway density and is accessible through the west cable vault entrance.
There are three locations where Z1 facility conduits or trays crossover Z2 cable trays.
In each case, the degree of physical separation is in accordance with the original plant design separation criteria which is 4 ft. vertical, or enclosed raceway and 18" horizontal.
In addition, all the cables within these trays love been inventoried and there are no redundant cables in the trays involved in the crossover.
Recommendation None.
(3)
Section:
Column 15, 17.2/FS, L5 Cable Vault Arla 7, Elevation 25' lesign Features i
This section of the Millstone Unit No. 2 cable vault is located just beneath the main control panels and contains the plant's largest concentration of cable raceways. Approximately 94% ot the 1,350 safety-related cables located in this area are control and instrument cables serving the vital plant equipment normally controlled from the control room.
The remaining 6% is LV power cable that primarily supplies control room f u nc t io n s. Access into this area is via the east entrance to the cable vault.
There are extremely high cable concentrations combined with r.carly total inaccessibility (stacks of cable trays obstructing east entrance to this area) thus requiring an absolute reliance on early detection and operation of the fixed manual deluge system to mitigate fire.
The location, quantity, and cable type involved in crossovers wit hin this area is presently being researched.
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NRC - SER Item 3.2.1 Cable Spreading Area Page 3 Recommendation A wet pipe automat ic sprinkler system will be installed to protect this entire 90 ft. x 60 ft. area.
(Represents 38% of cable vault.)
The system design will Inve branch lines extending down from the ceiling and spray perpendicular to the tray edges.
This new system should be independent of the existing cable vault deluge system header.
Inherently, it will provide an additional measurc of detection and alarm through fusible links and water flow alarm.
Fire retardant barriers will be installed if and where required to separate redundant facilities.
This would be an additional measuce used in conjunction with the proposed sprinkler system which in itself provides pro tection against loss of redundant cabling within this area.
(4 )
Section:
Column 15. 9, 18. 9/ L S, M7 Cable Vault Area 7 and East Penetration Area Design Features This section contains primarily 21, Z3 and facility 1 raceways.
There are no redundant f ac ility crossovers in this area, and this area is readily accessible via the east entrance to the cable vault.
Recommendation None.
506 076
NRC - S E R IT EM 3. 2. 2 PROTECTION OF REDUNDANT CABLE TRAYS NRC CONCERN 1he consequences of fire damage to systems required for safe shutdown will be determined where the physical separation of cables in the auxiliary building cny not preclade damage to redundant safety-related systems.
Fire retardant coatings, automatic sp r inkle r, suitable fire barriers, or early warning detection will be provided to assure that fire damage does not result in a loss of shutdown capability where prompt action is not taken to suppress fires in these areas (5.2), (5.8).
RESPONSE
An evaluation of the Millstone Unit No. 2 auxiliary building has been completed and corrective action will be implemented as defined below.
The intent of the evaluation was to :
(1) Determine the degree of existing physical separation between redundant cables of safety-related divisions.
(2) Determine the adequacy of existing cable separations (Paragraph 1 above) based upon original plant cable separation criteria and what is now known to be acceptable to NRC as a result of their recent fire protection inspection of Millstone Unit No. 2.
(3)
Recommend corrective measures where necessary to assure that a fire would not involve redundant safety-related systems.
This evalua+. ion was conducted in fire zo ne s A-1 A, A-1B, A-14, A-24, A-2 7 B,
and A-27D.
The following represents our findings and recommendations on a zone-by-zone basis.
(1)
Elevat ion 45 ', Zone 1 A, Column F.8/ll.2 and 16.6/17/2 Stack of three Z1 and three Z2 trays containing IlPSI, LPSI, and other safety-related cables involved in crossover.
Recommend at io n Ionization detec tors placed just above the crossover as part of the general area detection system already proposed for this elevation plus the installa-tion of an original plant design barrier to separate the two tray f ac ilit ies.
(2)
Elevation 45 ', Zone A-1A, Column F.8/il2 and 17.2/18.4 The same trays described in Paragraph 1 above running parallel to one another with three foot horizontal separat ion in accordance with IEEE-384.
506 077
NRC - SER Item 3.2.2 Protection of Redundant Cable Trays Page 2 Recommendat ion Ionization detectors placed above tray stacks as part of the general area detection system already proposed for this elevation.
(3)
Elevation 25 ', Zone A-9, Charging Pump Area Stack of thr ee Z1 trays containing charging pump cabling traversing entire zone.
Recommendation Cable density is light, approximately five percent tray fill.
The general area detection system recently proposed for this zone will provide adequate sup erv isio n.
(4 )
Elevation 5 ', Zone A-18, Column F.3/ F.8 and 18.9/19. 6, Pipe Penetration Room lips I, LPS I, and other safety-related Z2 facility conduits involved in crossover with Z1 f acility trays.
Recommendation Lonization detectors, possibly f rom Zone A25, will be installed above the Z1 trays at each of four Z2 conduit crossovers.
In addition, original design barriers will be installed between Z1 tray and Z2 conduits at crossovers.
(5)
Elevation 5', Zone A-14, Column F.8/II.2 and 18.1 Stack of three Z1 and four Z2 trays involved in crossover.
Trays contain redundant co n tainment spray stop MOV cables and other safety-related cables.
Recommendation Ionization detectors, from proposed area detection system, will be installed at crossover plus original design barrier will be provided above Z14FK10.
(6)
Elevation 5',
Zone A-14, Column L.5/M.4 and 17.7 Stack of two 21 and Z2 trays containing RWST cable and other safety-related cables involved in crossover.
Recommenda tion Same as Paragraph 5 above.
Barrier installed between Z14FL10 and Z26EE10 trays.
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SRC - SER ltem 3.2.2 Protection of Redundant Cable Trays Page 3 (7)
Elevation 5 ', Zone A-14, Column M.4 and 17.8 Five Z1 conduits involved in crossover with two Z2 trays.
Conduit ZlA488-1 and tray Z24FN10 contain redundant RWST cables.
Recommenda t ion Same as Paragraph 5.
Barr ier installed between upper tray and conduits.
(8)
Elevation 14 '6", Zone A-27D, Column M.7 and 18.9/20.0 Tray Z25BR20 crossing between trays Z14LB10 and Z15GA20 containing redundant enclosure building filtration cables and other safety-related cables.
Reco mmenda t io n Provide general ar a ionization detection system with additional detectors located at tray crossover.
Also, barrier installed separating the Z2 tray f rom both Z1 trays similar to barrier detail in Paragraph 5.
(9)
Eleva t ion +14 ' 6", Zone A-24, Column 11. 2 /11.4 and 17.1/17. 5 Stack of five trays (three Z1 and two f acilit y) running parallel with and then crossing over a stack of facility Z2 trays containing redundant enclosure building and other vital area cooling fens Recommendation Install general area detection syster for Zone A-24 with detectors located at tray crossovers and where the two tray stacks run parallel with one anothor.
Install original design barrier at crossovers.
(10)
Elevat ion - 14 '6", Zone A-24, Column F.8/ll.2 and 17.4 Tray Z12PC10 containing diesel generator feed to bus 24C involved in c;ossover with stack of Z2 trays.
Recommendation Same as Paragraph 9.
Install barrier just below Z12PC10 and 11CA10 and above Z25BB20.
506 079
NRC - SER ITEM 3. 2. 3 SMOKE DETECTION SYSTEM TESTS NRC CONCERN The l ic ensee is evaluating a uethod to conduct in-situ tests with a suitable smoke generation device to verify that a fire would be promptly detected by installed smoke detectors and that ventilation air flow patterns in the area do not significantly reduce or prevent detection response.
Bench tests will be conducted to verify that smoke detectors will provide prompt response and have adequate sensitivity to the products of combustion fo.
the combustibles in the crea where smoke detectors are installed.
If rny fire detection systems are found to be inadequate, appropriate modifications will be made to provide adequate performance (4.2 ).
RESPONSE
NNECO has been actively involved in researching and investigating a method of in-situ testing for the operating plants. Various concepts have been reviewed / analyzed and it appears that NUTECH has developed an in-situ testing technique which merits further investigation.
NUTECH's concept of in-situ testing was demonstrated and discussed with the NRC Staff in a meeting in Bethesda on June 21, 1979.
NNECO has evaluated NUTECH's concept of in-situ testing and concludes that although some of NUTECH's concepts have advanced the state-of-the-art, more testing or qualification is appropriate to provide assurance of an acceptable test.
Several utilities and NUTECH are now considering sponsoring a prototype test program to qualify NUTECH's technique.
The results of this testing would be usef ul in determining the acceptability of NUTECH's concept / technique.
NNECO will continue to evaluate methods of conducting a useful, acceptable in-situ test of existing detection systems.
In the interim, it remains NNECO's position that a demonstrated, reliable method of conducting in-situ tests of smoke detectors is not currently available. The completed or in-progress fire protection modifications including extensive fire detection and suppression provide adequate assurance that postulated fires riould be dealt with promptly.
This assurance is enhanced by the consideration given to fire loadings, products of combustion, and ventilation paths in the installation of fire detection equipment.
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NRC - SER ITEM 3.2.4 CABLE FIRE BARRlER PENETRATIONS TEST DATA NRC CONCERN Test data will be provided to demonstrate the adequacy of electrical cable fire barrier penetrations.
RESPONSE
All cable penetrations sealed at Millstone Unit No. 2 have been sealed using Dow Corning Q3-6548 medium density Silicone RTV Foam.
The penetration and installer, Insulation Consultant & Management Services, Incorporated (ICMS),
certifies the materials used to the ASTM E119-73 Fire Ensurance Test.
This test is described in the Dow Corning "New Product Information" document transmit ted in Attac hment (1).
Actual fill depths reflect raceway t ype,
percent obstruction, and area served.
There have been several ether subsequently completed nSTM E119 tests using the Dow Corning penetration seal material among which are the Dow Corning and Cheatrol test, Factory Mutual No. 26543 (4610) dated October 28, 1975 and the Dow Corning and ICMS test, Factory Mutual No. OROQ3 AM (4610) dated May 18, 1977.
506 US1
NRC - SER ITEM 3.2.5 PRIMARY COOLANT PUMP LUBE OIL FIRE IL\\ZARD NRC CONCERN The licensee is evaluating a method of oil collection or routing to prevent the spread of oil or the use of alternative types of lubricants to reduce the fire hazards associated with tne reactor coolant pump lube oil systems (5.10).
RES PONSE An evaluation was performed to determine a method of R J lube oil collection and/or rerouting or the use of synthetic fire retardant oil to minimize ftre exposure inside containment. The results of this evaluation ind ica ted tl'a t the use of fire retardant lubricating oil is not considered practical at this time.
The type of oil collection and/or rerouting of RCP lube oil will consist of a main drip pan arrangement with a supplemental lift pump / oil cooler drip pan.
The primary purpose of the drip pan system is to collect oil from all exterior leakage points (i.e., mechanical connections) around the RCP and route it to an acceptable tank storage area which will be located at the base of the RCP supports.
The RCP oil collection system will be handled as a field design and installation rather than a predesigned unit.
The following general design / installation guidelines will be used.
(1) A drip pan with a 3" lip (minimum) will be installed around the base of the RCP motor top hat area.
The drip pan will extend radially to the exterior location of potential leakage points such as the uppur oil cooler lower reservoir oil level transmitter, and the high pressure lube oil system.
(2) A deflection box / shield will be installed around the high pressure lube oil system to direct high pressure leakage to the drip pan.
(3j Two one-nalf inch holes will be provided at either the bottom of the lip or in the base plate at the lowest elevation of the drip pan.
One-half inen tubing will be run from the drain holes to the storage tank.
(4 ) The one-half inch drain lines to the tank storage area will be tested after field installation to ensure that they are not clogged with debris.
An isometric sketch (SK-REB-531) is provided which illustrates the conceptual design for the system.
This drawing is preliminary and final design will be established at time of installation.
Installation.is scheduled for the 1980 refueling outage.
506 0 8 ^.
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