ML19294C012

Forwards Info Re Open Fire Protection Issues Review.Encl 1 Summarizes Status of Open Issues.Encl 2 Is NRC Evaluation of Design Description for Proposed Detector Installations.Util 791220 Proposal for Detector Placement Is Acceptable

ML19294C012
Person / Time
Site:	Point Beach
Issue date:	02/05/1980
From:	Lainas G Office of Nuclear Reactor Regulation
To:	Schwencer A Office of Nuclear Reactor Regulation
References
TAC-11079, TAC-11080, NUDOCS 8003060531
Download: ML19294C012 (6)

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• +a, m.- p FEB 5 1c80 3EMORANDUM FOR:

A. Schwer.cer, Chief, Operating Reactors Branch #1, Division of Operating Reactors FROM:

G. Lainas, Chief, Plant Systems Branch, Division of Operating Reactors

SUBJECT:

POINT BEACH - REVIEW OF OPEN FIRE PROTECTION ISSUES Plant Name: Point Beach Nuclear Plants, Units 1 and 2 Docket Nos.: 50-266 and 50-301 Responsible Branch: ORB #1 Project Manager:

C. Tramell Reviewing Branch: Plant Systems Status of Review: See Enclosure 1.

Our SER on the Point Beach fire protection program, issued August 2, 1979, indicated that the licensee would provide the details of certain proposed modifications for our review.

In addition, certain issues were left opEn pending further staff review. Enclosure 1 summarizes the status of the open issues. Enclosure 2 provides our evaluation of the design description for proposed detector installations (Item 3.1.12 of the SER) and our resolution of the open issue related detector placement and qualification (Item 3.2.5).

These two issues are interrelated in that we cannot approve the design of the detector systems of item 3.1.12 until the issues of detector placement method and detector qualification are resolved. The licensee's letter of December 20, 1979 provides a description of detector systems and the proposed method for detector placement. We find these proposals to be acceptable.

In a letter dated December 29, 1978, the licensee proposed that the detector manufacturer's quality assurance tests be accepted in lieu of the bench tests for detector sensitivity required by item 3.2.5.

The licensee did not provide sufficient bases by whb.h to judge the equivalence of these two test methods. Our requiremerd.

for the resolution of this issue is provided in Enclosure 2.

Satisfactery implementation of this requirement will resolve both item 3.1.12 and item 3.2.5.

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FEB 5 380 A. Schwencer This requirement should be transmitted to the licensee. We request a response within 30 day 1 that indicates that this requirement will be satisfied. However, i f the licensee chooses not to satisfy this require-ment, a meeting should be arranged within the same 30 days with appropriate management individuals prior to initiating an order.

G.Lainas6f.hief Plant Syst6ms Branch Division of Operating Reactors

Contact:

E. Sylvester, X27877 inclosures :

1.

Resolution of Inc r.plete Items - Status 2.

Evaluation of Open Issues e

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ENCLOSURE I POINT BEACH UNITS 1 AND 2 RESOLUTION OF INCOMPLETE ITEMS - STATUS Licensee

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Staff Evaluation Resoonse Due 3.1. 2 Smoke Exhaust Incomplete None 3.1. 4 Fixed Water Sui 1pression System Information 11/15/79 3.1.5 Water Damage Protection Information 3/15/80 3.1.9 Fire Barriers Infomation 1/1/80 3.1.12 Fire Detectors Requirement 30 dcrs 3.1.14 Cable Separators Information 3/15/80 3.1.17 Hydrogen Hazard Protection Incomplete None 3.1.23 CO2 Hose Reel Nozzles Incomplete None 3.1.24 Diesel Generator Air Intake Structure Information 1/15/80 3.1.25 Vent Duct Penetration Seals Incomplete None 3.1.26 Auxiliary Building Cable Tray Penetration Seals Infomation 1/1/80 3.1.27 Containment Building Fire Stops Infomation 1/1/80 3.1.28 Service Building Penetration Seals Information 1/1/80 3.1.29 Cable Tray Penetration Seal Qualification Information 1/1/80 3.1.32 Fire Hydrant Inspections Information 11/1/79 3.1.33 Control Room Light Fixtures Information 1/1/80

s.. Licensee Staff Evaluation Response Due 3.2.1 Safe Shutdown Capability Incomplete None 3.2.2 Circulat'ig Water Pump House Fire Protection Incomplete None 3.2.3 Fire Brigade Size Incomplete None 3.2.4 Fire Brigade Training Frequency Incomplete None 3.2.5 Smoke Detection System Qualification Requirement 30 days 3.2.6 Reactor Coolant Pump Lube Oil Collection Incomplete None

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ENCLOSURE 2 POINT BEACH UNITS 1 AND 2 FIRE PR9TECTION REVIEW EVALUATION OF OPEN ITEMS Fire Detectors (3.1.12 and 3.2.5)

Item 3.1.12 of the Point Beach SER deals with the licensee's proposal to provide additional detectors in areas that are presently unprotected or inadequately covered. Section 4.2 of the SER lists these areas as:

Location 1.

Containment, Units 1 cad 2 2.

Diesel generator rooms 3.

Cable spreading room 4.

Battery rooms 5.

Auxiliary building, all elevations 6.

Control building, elevation 60 feet 7.

Control room 8.

Electric Switchgear room, elevation 8 feet 9.

Auxillary feed pump area

10. Pipeways, Units 1 and 2

11. Facade areas, Units 1 and 2

12. Auxiliary feed pump local cuatrol station

'3.

Auxiliary boiler day tank rooms

14. Service building corridor

15. Turbine building lube oil area, Units 1 and 2 Item 3.2.5 of the SER indicates the requirement of the licensee to verify the adequacy of the detectors used at the Point Beach Nuclear Plant and the locations at whicn the detecto.4 are installed.

During the initial stages of the fire protection review, the licensee did not agree with the review team's recommendation that bench tests and insitu tests be conducted to demonstrate the adequacy of their detector installations. They argued that there rioes not exist an effective procedure for testing fire detectors in the ir. situ condition which has industry acceptance in general and NRC acceptance specifically. Therefore,

in response to the requirements of the SER, the utility developed their own plan for locating fire detectors. This plan was submitted to the Nuclear Regulatory Commission with their letter dated Decemtmr 20, 1979.

The development of the plan included inpur from fire detection system installers as well as guidance from Draft Reg. Guide 1.120, and standards published by Underwriter Laboratories and the National Fire Protection Association.

, The Point Beach p'in consists of a fire detector location sheet which lists various ph.,fcal and operating characteristics of the area with space for a drawing of the area. Based on the data assembled on the sheet along with site observations, the locations of the fire detectors can be detemined using the knowledge and judgement of a qualified person. The sheet requires the signature of the person who engineers the evaluation, the person who perfoms the survey and the person approving the work. The same plan is applicable for determining the placement of new detectors and evaluating the adequacy of existing detector locations.

3e material supporting the utility's plan for detector location includes a decision tree flow chart which identifies conditions affecting the type of detector best suited for the area. Also included is a detector spacing graph which plots ceiling height in feet against the recommended crea coverage in square feet per detector. Noted as background material reviewed in preparation for developing this plan included: Sandia Laboratories NUREG/CR-0488, Nuclear Power Plant Fire Protection Fire Detection and National Bureau of Standards Publication, " Environments of Fire Detectors."

Based on our evaluation of the Point Beach letter of December 20, 1979, we find that this method of determining the spacing is adequate. There-fore, the modification of item 3.1.12 and the requirement of 3.2.5 of the SER with regard to detector locations are adequately resolved.

However, in a letter dated December 29, 1978, the licensee proposed that manufacturer's quality assurance testing of detectors be accepted in lieu of the bench tests required in item 3.2.5.

The efore, items 3.1.12 and 3.2.5 cannot be totally resolved at this time since it has not been shown that the detectors used at Point Beach will have adequate sensitivity to the products of combustion for the combustibles in the areas where installed. The licensee did not verify that manufacturer's quality assurance tests are equivalent to bench tests done for the detectors and combustibles at the Point Beach plant. The licensee should therefore provide the results of bench tests to verify that the detectors provided at the plant will promptly detect products of combustion from the materials in the areas where detectors are installed.

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