ML19309A779
| ML19309A779 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 03/26/1980 |
| From: | Randy Hall BROOKHAVEN NATIONAL LABORATORY |
| To: | Ferguson R Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8004010329 | |
| Download: ML19309A779 (4) | |
Text
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BROOKHAVEN NATIONAL LABORATORY
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l ASSOCIATED UNIVERSITIES, INC.
. J 1_ J Upton, New York 11973 Department of Nuclear Energy (516) 345-2144 March 26, 1980 Mr. Robert L. Ferguson Plant Systems Branch U.S. Nuclear Regulatory Comission Washington, D.C.
20555 RE: Peach Bottom, Fire Protection Review, Items 3.1.5(2) and 3.1.7.
Dear Bob:
Enclosed are Items 3.1.5(2), Fire Doors - Condensate Pump Room, and 3.1.7, Fire Barrier Penetration Seals for the Peach Bottom Nuclear Plant. This com-pletes the Brookhaven National Laboratory input for items we have on hand.
The licensee's submittal dated February 21, 1980 addressed SER items:
3.1.1(1)-(3) and (5)-(10), 3.1.2A, 3.1.5(2), 3.1.7, 3.1.11(1) and 3.2.4(2).
All these items with the exception of items 3.1.5(2) and 3.1.7 indicated that drawings were included in the submittals. These drawings, however, were not enclosed with my copies of the submittals.
Because of the lack of drawings the review of these items cannot be com-pleted at this time. Several other responses were received from the licensee on other items, however, they were written in answer to staff positions and received prior to the issuance of the SER. We will need clarification from the staff as to which items are acceptable responses to the SER.
Respectfully ynurs, j
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/ J e t.r W b ", Group Leader
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Robert E. Hall Reactor Engineering Analysis REH:EAM:sd enclosure cc.:
L. Derderian D. Eisenhut W. Kato wo/ enc.
'i. Levine E. MacDougall V. Panciera E. Sylvester gg S
/4 8004010329
J PEACH BOTTOM Fire Protection Review Item 3.1.7 - Fire Barrier Penetration Seals Item 3.1.7 of the Peach Bottom SER indicates that the licensee will evaluate the adequacy of the seals for fire barrier penetrations in various areas of the plant and if-necessary, install new seals or upgrade the existing ones.
The licensee will submit a detailed description and evaluation of the existing penetration seals in order to determine if further remedial measures are required.
In those cases where the licensee will install new seals or will replace existing seals, the replacement seals will be qualified by an in-dependent testing laboratory in accordance with ASTM E-119.
In addition, other criteria established by NRC including the provision that testing be con-ducted with a differential pressure across the fire barrier, should be met.
This modification for improving fire barrier penetrations was originally de-termined during the site visit by the review team and was stated in a letter to Philadelphia Electric dated November 17, 1978, as staff position PF-18.
In response to this position the licensee made two submittals dated December 20, 1978 and February 16, 1979.
On May 23, 1979 the SER was issued and this position was included as Fire Bar-rier Penetration Seals under items 3.1.7 and 3.2.8(2).
Item 3.1.7 states:
Mechanical seals will be evaluated and upgraded as necessary.
Item 3.2.8(2) states: The licensee will provide a detailed description and evaluation of electrical and mechanical penetration seals. On February 21, 1980 the licensee submitted a response to SER item 3.1.7 entitled, " Mechanical Pene-tration Seals." This response states that:
A program has been established and initiated to identify all mechanical penetrations which are not sealed in safety related areas and areas con-taining significant combustibles. Data has been compiled identifying open pipe sleeves and/or unsealed ventilation duct penetrations. The unsealed penetrations will be evaluated to identify which ones require sealing.
The criteria for evaluating if a penetration requires upgrading will be as follows:
A.
Significant combustible material is present on both sides of the pene-tration.
B.
The penetrations separate areas with a heavy combustible loading from safety-related areas.
C.
The penetration is in a barrier isolating an area containing safe shutdown equipment (as detailed in our July 3,1979 response to Staff Position PF-26) from areas containing combustibles in an amount and arrangement deemed hazardous.
Existing penetrations for which no test data is available will be reviewed and their suitability will be based on combustible loading, similarity of seals to
" tested seals" and engineering judgement.
Penetrations which require upgrad-ing will be sealed using penetration details which have been tested in accor-dance with ASTM E-119 and have been accepted by American Nuclear Insurers.
Included with the submittal were two reports by Factory Mutual Research, of Fire Endurance Tests of cable, cable trays, conduit and pipe pentration seals in fire barriers. The designs tested were established by Bechtel Power Cor-poration and were sponsored by various electric utilities including Philadel-phia Electric Company. The tests complied with ASTM E-119-76 and were con-ducted at the National Gypsum test facility.
The licensee has stated that they intend to upgrade the mechanical fire bar-rier penetrations found deficient in their survey using constructions and materials that successfully passed the above described tests.
It should be noted that the licensee's proposal to seal mechanical penetra-tions include pipe and ventilation duct penetrations.
The above tests were conducted with cable and pipe penetrations but not duct penetrations. The licensee infers that a seal construction that is acceptable for cable and pipe penetrations will also be acceptable for duct penetrations.
This assumption is only valid, however, when the duct is provided with a fire damper having a fire rating similar to the fire barrier it is penetrating. Their submittal makes no reference to this.
It should also be noted that the fire endurance tests were run to ASTM E-119-76 which does not include the provisions of a differential pressure between the fire side and the non fire side as noted in IEEE 634-1978, Standard Cable Penetration Fire Stop Qualification Test and re-quired by the original NRC position. The tests also did not include the hose stream application for floor penetrations.
The licensee's submittal on SER item 3.1.7 is considered only partly satisfac-tory. Their methodology in determining the adequacy of existing mechanical penetrations is acceptable. Their proposed methods of upgrading the existing penetrations or replacing them with new seals is not entirely satisfactory.
All ducts passing through fire barriers should be provided with fire dampers having an hourly rating equal to the fire barrier it is passing through.
The design and construction of the penetration seals is considered conditionally acceptable because not all the test criteria of the original position was tested including the differential pressure provision.
If subsequent test re-sults show that the test criteria contained in the original NRC position pro-duces a significant downgrading of the penetration seals as proposed by the licensee, further testing and upgrading to meet these criteria may be re-quired.
Item 3.1.5(2) - Fire Doors, Condensate Pump Room Item 3.1.5(2) of the Peach Bottom SER indicates the licensee's proposal to up-grade the existing fire doors leading to the condensate pump rooms.
i By letter dated September 15, 1977 and again by letter dated February 21, 1980 the licensee provided information concerning this item. They indicated that the doors were upgraded by removing the existing louvers, filling the gap with kaowool insulation and mounting steel plates on both sides of the door over the openings for support. According to the licensee this modification was completed on August 17, 1977.
The licensee's implementation of this modification is similar to the method suggested by the review team and is acceptable.
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