ML19256D667

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Forwards Request for Addl Info Re Fire Protection Program
ML19256D667
Person / Time
Site: Crane 
Issue date: 04/06/1978
From: Butler W
Office of Nuclear Reactor Regulation
To: Stello V
Office of Nuclear Reactor Regulation
References
NUDOCS 7910220581
Download: ML19256D667 (15)


Text

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8 UNITED STATES NUCLEAR REGULATORY COMMISSION 3 :.I yh[);'.j p1 4

WASHINGTON, D. C. 20555

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%..v f April 6,1978 MEMORANDUM FOR:

V. Stello, Jr.

Acting Assistant Director for Ooeratina Reactors Division of Operating Reactors FROM:

W. Butler, Chief Plant Systems Branch Division of Operating Reactors

SUBJECT:

FIRE PROTECTION REVIEW - THREE MILE ISLAND NUCLEAR STAT ON, UNIT 1 Facility:

Three Mile Island Nuclear Station, Unit 1 Docket Number:

50-289 Licensee:

Metropolitan Edison Company Responsible Branch:

ORB #4 Reviewing Branch:

Plant Systems Branch Status of Review:

Ongoing; additional information is required Additional information is required to complete our evaluation of the fire protection program.

The specific information required is identified in Enclosures 1 and 2.

As a result of our initial review, we have taken several positions to resolve outstanding issues. The specific positions are specified in.

We reque3t your assistance to assure a timely response by the licensee, d

u.-

Walter R. Butler, Chief Plant Systems Branch Division of Operating Reactors

Contact:

T. Lee X28077 1452 304

Enclosures:

As stated cc w/ enclosures:

Listed on page 2 7910220 M /

/

a

. April 6,1978 V. Stello cc w/ enclosures:

D. Eisenhut W. Butler R. Reid G. Zwetzig T. Wambach R. Ferguson T. Lee E. MacDougall J. Klevan M. Virgilio T. Lee 1452 305

ENCLOSURE 1 THREE MILE ISLAND NUCLEAP. PLANT, UNIT i DOCKET NO. 50-289 REQUEST FOR ADDITIONAL INFORMATION 1.

Combined Fire and Security Emergency 2.

Instrument Air System 3.

Failure Analysis 4.

Lightning Effects 5.

Effects of Extinguishing Agents 6.

Safety-Related Systems Interlocked with Fire Fighting Systems 7.

Fire Barrier 8.

Steel Structures 9.

Safety Areas Witb3ut Fire Protection 10.

Drains 11.

Pipe and Ventilation Duct Penetrations 12.

Piping Containing Combustibles 13.

Laboratories and Sorage Areas 14.

Combustible Fluid Reservoirs and Storage 15.

Interface Between Safety and Non-Safety Equipment 16.

Cable Insulation Materials 17.

Method of Heat and Smoke Venting 18.

Prevention of Fire and Smoke Spread 19.

Ventilation System Power and Control 20.

Automatic Operation of Fire Dampers / Doors 21.

Proximity of Regular and Emergency Lighting Wiring 22.

Requirements for Manual Hose Stations 23.

Fire Hazard at the Containment Cable Penetration 24.

Portat.le Extinguisher Rating 25.

Fire Hazards Associated with the Plant Computer 26.

Remote Shutdown Panels 27.

Radiological Consequences of a Fire 28.

Diesel Fuel Transfer Shut-off 29 - Plant Specific Concerns 1452 306

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I, 1.

Combined Fire and Security Emergency Describe the responsibilities of key personnel in the event of a

..l combined fire and security emergency.

I 2.

Instrument Air System Verify that the effects of a fire on the instrument air system will not cause a transient more severe than those already analyzed in the FSAR, or prevent safe shutdown.

,, l 3.

Failure Analysis y

'i Provide a failure analysis which verifies that a single failure does not simultaneously impair the primary and backup fire suppression capabilities. The analysis should include consideration of failures

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s 11 in the suppression system, the fire detection system or the power M

i scurces for such systems.

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4.

Lightning Effects 4

Describe the means provided to prevent lightning from initiating fires

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which could damage safety-related equipment.

Describe the means pro-

.g vided to prevent lightning from damaging the fire protection system.

5e 5.

Effects of Extinguishing Agents Provide the results of an analysis which shows that rupture or inad-

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vertent operation of a fire fighting system will not subsequently cause 1.

damage or failure of safety-related equipment required for safe shutdown.

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a 6.

Safety-Related Systems Interlocked with Fire Fighting Systems Identify any safety-related systems or their auxiliaries which are interlocked to and could be disabled by operation of a fire fighting system.

7.

Fire Barrier

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- 4 For all barriers, describe the fire resistance rating of the associated RX foors, ventilation dampers and seals for cable, pipe and ventilation 1

duct penetrations.

Identify the fire barriers, enclosing separate fire areas, that do not have minimum fire rating of three hours.

~ f 8.

Steel Structures a

Describe the type of fire protection, if any, applied to steel struc-j tures.

Evaluate the possibility of fire damage to protected and unprotected steel structures and the effect of such damage on the safe plant shutdown capability.

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9.

Safety Areas Without Fire Protection Identify all areas that contain safety-related equipment and/or cables in open cable trays that are not provided with eithe-fire detection or automatic fire suppression.

Justify the lack of either of the above.

10.

Drains (1)

Provide the results of an analysis which shows that drains have sufficient capacity, and/or equipment pedestals have sufficient height to prevent standing water from sprinklers and fire hoses from damaging safety-related equipment or supporting systems necessary for safe shutdown of the plant.

(2)

Identify the areas containing safe shutdawn equipment that are not provided with floor drains.

Describe the drainage path for those areas without drains.

(3)

Identify the areas containing combustible liquids that are not provided with floor drains.

Describe the drainage path and provisions for containing or diverting the combustible liquids in those areas without drains.

Where applicable, provide the results of an analysis that shows that curbed areas surrounding combustible liquid tanks have sufficient capacity to contain the full contents of the tanks plus the quantity of water required for extinguishment of a fire involving the combustible liquid.

In those areas with drains, state tne capacity and location of the drain reservoirs ar.d describe the provisions to prevent the spread of flammable liquid fires via the drain system to areas which may jeopardize safety-related equipment.

11.

Pipe and Ventilation Duct Penetrations Provide the results of an analysis that shows that the fire barrier penetration seals far pipe penetrations and ventilation ducts are adequate to prevent the spread of smoke and fire through the barrier considering the fire hazard and possible air pressure differential.

12.

Piping Containing Combustibles Identify all piping containing flammable or combustible gas or liquid which is routed through areas containing safety-related equipment, safety-related cables or through which personnel must pass to reach safety-related equipment for local operation.

Provide an analysis to 1452 308 show that a fire involving the liquid or gas will not prevent safe shutcown or result.in the loss of function of a safety-related system.

13.

Laboratories and Storage Areas Identify ail hazardous materials located in the laboratories and chemical storage areas.

Previde the results of an analysis of the consequences of a fire or explosion involving these hazards on safety-related equipment.

14.

Combustible Fluid Reservoirs and Storage Provide a listing of all fixed tanks and pumps which contain oil or other flammable or combustible fluid and indicate the location of the container and quantity and name of fluid contained.

Describe the fire protection provisions associated with each such location.

15.

Interface Between Safety and Non-Safety Equipment Certain cables electrically connected to equipment necessary for safe shutdown may be used for functions designated as non-safety-related and, therefore, classified as non-safety-related.

Examples of these might be remote indicating lights for valves, breakers, etc.

Ocscribe whether such cables are kept with the safety division to which they were originally connected and if not, describe the effects on the safe shutdown equipment due to shorts to these cables as a result of fire.

16.

Cable Insulation Materials Identify all types and quantities of cable used in all arehs of the cable tray sysem.

For each type of cable, id entify the mitterials used for insulating and jacket 1ng.

17. Method of Heat and Smoke Venting Describe the methods which would be used for heat and smole removal using either fixed or portable air handling equipment.

If the plant HVAC systems are proposed for such service, provide design data to show that these systems are rated for the conditions (tem)erature and capacity) required when used for this service.

18.

Prevention of Fire and Smoke Spread e

Describe the manner in which fire and smoke are prevented from spread-ing from area to area via the normal and emergency venti' ation systems in all parts of the plant areas.

Describe the location, actuation method and all fire rating of dampers used for fire and imoke control 1452 309 in both air supply and return air systems.

Describe the details of interlocks for ventilation system shutdown or mcde change that can be utilized for fire and smoke control.

Describe the reliability of such systems and the consequences of system failure.

19.

Ventilation System Power and Control Identify areas where power and control cables of ventilation systems are routed through the fire area they serve.

Provide the basis for leaving ventilation systems power and control cables within the area they serve.

20.

Automatic Operation of Fire Dampers / Doors Discuss the provisions for automatic closure of ventilation fire dampers and fire' doors in all areas protected by total flooding gas suppression systems and provisions for re-opening the fire dampers remotely for post fire smo'<e venting.

21.

Proximity of Regular and Emergency Lighting Wiring Provide the results of an evaluation of the potential for a fire to cause damage to electrical wiring which would result in the loss of both regular and emergency lighting to areas needed for safe shutdown and other areas providing access to safe shutdown equipment or the fire area. Verify that AC emergency lights that are used in lieu of 8-hour sealed beam DC units are supplied from vital AC buses.

22.

Requirements for Manual Hose Stations Demonstrate that all points of safety-related areas and other areas with major fire hazard can be reached with tne hose line stored at the manual hose stations.

23.

Fire Hazard at the Containment, Cable Penetration Identify the consequences on safe shutdown of a fire at the cable penetration area on either side of containment.

24.

Portable Extinguisher Rating Verify that at least one portable extinguisher in the control room has a Class A rating.

1452 310 25.

Fire hazards Associated with the Plant Computer Provide the results of an analysis which demonstrates that a fire within the computer area will neither expose any safety-related equip-ment nor affect the safe plant shutdown.

Verify that the barrier around the area is compatible with the combustible loading in the area.

26.

Remote Shutdown Panels Identify the location of all remote shutdown panels and provide the results of analysis to demonstrate that no fire which could impair the control from the co.itrol room could also prevent the control from these areas.

27.

Radiological Conseo Jences of a Fire Evaluate the radiological consequences of a fire in radwaste areas and areas containing contaminated material such as filter cartridge, spent resin, etc.

28.

Diesel Fuel Transfer Shut-off Describe the means provided to automatically and/or manually stop the transfer of diesel oil from the bunker tanks to the diesel generator day tanks in the event of a fire in the area housing the day tank, or through which the fuel oil transfer piping is routed.

(Referenced page(s) in TMI-l's submittal are indicated in the parenthesis following the question.)

29.

Fire Detection System Design Provide design data for the automatic fire detection system in each fire area, including such items as type, number and location of the detectors; and signaling, power supply and supervision of the system, and identify any deviations from NFPA 72D.

(Pg. 5-35)

Describe tests which may have been conducted, or other means proposed, to verify the adequacy of the detection system design considering the air flow pattern and other relevant factors.

30.

Fire Suppression System Design Provide the design data for all automatic suppression systems (both existing and proposed), including such items as design densities, soak times, power supplies, and associated alarms.

Identify areas of non-compliance with appropriate NFPA Standards.

(Pg. 5-30) 1452

'll 31.

For each fire area, describe the type and quantity of transient combustible material which might be found during any and all modes of plant operation.

Describe the quantities in terms of being the minimum, average, or maximum amounts likely to be found in each area.

Include, as a minimum:

(Pg. 2.2-4)

Protective clothing and equipment both clean and used (including contaminated);

solvents and other cleaning materials used in maintenance, decontamination or other operations; lubricating oils and other fluids which might be added to motors, pumps or other equipment from time to time; wood, paper and other construction materials; plastic sheets and bags, used for transport, storage or protection of materials.

Describe the effect the presence of such materials will have on fires postulated in each area of the plant, including areas of the plant through which they are transported on th way to or from their point of use in or out of the plant.

32.

Identify the ventilation systems which are not designed to isolate upon receipt of a fire signal, and the areas which they serve.

(Pg. 2.3-2 and 5-21) 33.

Describe combustible pipe and duct insulating materials in the plant, including locations, quantities, and type. Verify that they were included in the fire hazard analysis.

(Pg. 5-14) 34.

Describe the acoustical ceiling material used in the control room.

State the flame spread classification of fuel contribution to smoke development information on this tile.

(pg. 5-14) 35.

Describe the floor drains modifications noted on Pg 5-15.

(Pg. 5-15) 36.

Provide the rates at which the cascade system can replenish exhausted supply air bottles for various periods of time from one hour to six hours.

(Pg. 5-23) 37.

Provide 5 copies of cable test reports actually performed on cables which verify that cables in TMI-l have passed IEEE 383 test. (Pg. 2.2-5) 1452 712 38.

Provide a list of fire areas and fire zones.

(Pg. 2.2-8) 39.

Describe the minimum separation between redundant cables, including interposing combustibles, in all areas where both divisions of caoles in systems required for safe shutdown are routed in the samc area.

40.

Verify that for the Control Room, the actual minimum separation between redundant channels without barriers is only 6 inches.

(Pg. 2.3-9) 41.

Provide documentation which verifies that the Johns Manville Marinite 65 insulation is qualified as a fire barrier.

(Pg. 2.3-6 and 2.3-7) 42.

Describe the criteria that classifies the fire loading (in BTU /sq.ft.)

as " minimal."

(Pg.2.3-13) 43.

Describe separation of redundant communication cables at penetration to Containment.

(Pg. 5-24) 44.

Provide the results of the most recent test of each of the fire pumps, including the pump discharge / pressure curves.

(Pg. 5-26) 45.

State the pump discharge pressure associated with the maximum system flow rate of 2575 gpm.

(Pg. 5-27)

Considering losses due to system friction and differences in elevations, verify that the pressure available at the point of 2575 gpm flow requirement is adequate for proper operation of the suppression system.

46.

Identify additional equipment that has to be procured to meet the requirements of NFPA 24.

(Pg. 5-28) 47.

Describe the special adapters required for compatibility of the plant fire hydrant threads with the threads of the local fire departments.

Describe how many adapters are provided and where they are kept.

(Pg. 5-28) 48.

Identify the make and model of the electrically safe hose nozzles used in the plant.

(Pg. 5-36) 49.

Justify your position that Halon cylinders are not weighed to determine leakage.

(Pg. 5-31) 50.

Describe the smallest fires in the Containment which can be detected by the installed detectors in their present locations, providing the results of any tests which may have been conducted.

(Pg. 5-33) 1452 313 51.

Verify that the insulation on control cable and wiring was included as a combustible material in the fire hazards analysis.

If not, justify this omission or revise the fire hazards.

(Pg. 5.5-1 and 4.4-2) 52.

Describe, in detail, the quantity, type and arrangement of cables which may be located above the control room ceiling.

(Pg. 5-35) 53.

Provide basis for stating the provisions of F.3(b) of Appendix A to BTP 9.5-1 concerning the cable spreading room are not applicable.

(Pg. 5-37) 54.

Indicate the fire resistance rating of the barrier between the redundant decay heat removal pumps, including the ratings of any penetrations of this barrier.

(Pg. 5-41) 55.

Indicate the fire resistance rating of the barriers between redundant make-up and purification pumps, including the ratings of any penetra-tions of these barriers.

(Pg. 5-41) 56.

Describe how and where all various materials containing radioactivity including dewatered spent resin are collected, stored, and disposed of.

(Pg. 5-45)

57. Verify that " safe shutdown" means " cold shutdown" in all cases.

(Pg.

5-45) 58.

Provide the completion schedule of the fire protection program modi-fications which includes the implementation of administrative controls and the installation of equipment such as automatic detection and suppression systems, fire doors and dampers, and manual fire fighting equipment.

59.

State your assumptions regarding loss of function of cables enclosed in conduit and interlocked armor as a result of a fire used in your fire hazards analysis.

(FSAR Pg. 8-Sa) 1452 314

ENCLOSURE 2 THREE MILE ISLAND NUCLEAR PLANT, UNIT 1 DOCKET NO. 50-289 REQUEST FOR DRAWINGS Metropolitan Edison is requested to have 5 copies of the following drawings on hand when the review team visits the plant site.

1.

Dimensioned plan drawing of fire service water system rarked with valve supervision and proposed modification (s) in the system.

2.

Ventilation and one-line drain diagrams of various areas in the plant.

3.

Electrical one-line distribution diagrams.

4.

Electric tray layout drawings.

5.

Control logic diagram for each of the 4-2500 gpm fire pumps.

6.

General arrangement of the plant, especially of containment.

1452 315

ENCLOSURE 3 THREE MILE ISLAND NUCLEAR PLANT, UNIT 1 DOC'iEr NO. 50-289 STAFF POSITIONS P1 Electrical Cable Penetration Qualification P2 Fire Water Valve Supervision P3 RC Pump Lube Oil Collection System P4 Fire Detector in Control Room Cabinets and Consoles P5 Fire Door Supervision 1452 316

Pl Electrical Cable Penetration Qualification The cable penetration fire barriers should be tested tra demonstrate a three-hour rating, as is required for fire barriers. 1he test should be perfonned or witnessed by a representative of a qualified independent testing laboratory, and should include the following:

(1) The tests should be performed in accordance with ASTM E-119 and the following conditior.s.

(2) The cables used in the test should include the cable insulation materials used in the facility.

(3) The test sample should be representative of the worst case configuration of cable loading, cable tray arrangement, anchor-ing and penetration fire barrier size and design. The test sample should also be representative of the cable sizes in the facility. Testing of the penetration fire barrier in the floor configuration will qualify the fire stop for use in the wall configuration also.

(4) Cables penetrating the fire tnrrier should extend at least three feet on the unexposed side and at least one foot on the exposed side.

(5) The fire barrier should be tested in both directions unless the fire barrier is symetrical.

(6) The fire barrier should be tested with a pressure differential across it that is equivalent to the maximum pressure differential a fire barrier in the plant is expected to experience.

(7) The temperature levels of the cable insulation, cable conductor, cable tray, conduit, and fire stop material should be recorded for the unexposed side of the fire barrier.

(8) Acceptance Criteria - The test is successful if:

(a) The cable penetration fire barrier has withstood the fire endurance test without passage of flame or ignition of cables on the unexposed side for a period of three hours, and (b) The temperature Ievels recorded for the unexposed side are analyzed and demonstrate that the maximum temperature is sufficiently below the cable insulation ignition temperature, and 1452 317

m 2

(c) The fire barrier remains intact and does not allow projection of water beyond the unexposed surface during the hose stream test.

If previous tests can be shown to meet the above position, the licensee should provide the results of the tests to show that the above position is met.

P2 Fire Water Valve Supervision All valves in the fire water systems should be either electrically supervised, or locked open or provided with a tamper proof seal, and administratively controlled.

P3 RC Pump Lube Oil Collection System Each reactor coolant pump should be provided with an oil collection system to contain lube oil leakage and drain the leaked oil to a safe place.

P4 Fire Detector in Control Room Cabinets and Consoles Each of safety-related cabinets and consoles in the control room should be provided. with a fire detector.

P5 Fire Door Supervision All fire doors should be electrically supervised with time delayed alarm in a constantly occupied area, or locked closed.

i452 318

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