ML19317G698
| ML19317G698 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 08/31/1976 |
| From: | SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | |
| References | |
| NUDOCS 8003260829 | |
| Download: ML19317G698 (74) | |
Text
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r, Regulatory Docket Eile, Js#!#/J44 V*hr SACRAMEtiT0 MUNICIPAL UTILITY DISTRICT RANCHO SECO NUCLEAR GENERATING STATION, UNIT NO. 1 RESPONSE T0:
NUCLEAR REGULATORY COMMISSION BRANCH TECHNICAL POSITION 9.5-1 GUIDELINES FOR FIRE PROTECTION FOR NUCLEAR POWER PLANTS DATED MAY 1,1976 i
August 31, 1976 8 0 03 260 ho i l
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TABLE OF CONTENTS-Page No.
A.
Overall Requirements of a Nuclear Plant Fire Protection Program..............................
1 B.
General. Guidelines for Plant Protection 7
1.-
Building Design......................
7 2.
Control of Combustibles..................
15 3.
Electrical Cable Construction, Cable Trays and Cable Penetrations.......................
18 4." Ventilation...........'.............
24 5.
Lighting and Communication 29 6.-
Administrative Procedures, Controls and Fire Brigade 30 7.
Quality Assurance.....................
34 C.
Fire Detection and Suppression.................
36 1.
Fire Detection 36 j
. ater Supply Systems 38 W
2.
3.
Water Sprinkler and Hose Standpipe Systems 42 4._
Halon Suppression Systems.................
46 5.
Carbon Dioxide Suppression Systems 46 6.-
-Portable Extinguishers 47
-D.
Guidelines for Spacific Plant Areas 48 1.
-Primary and Secondary Containment.............
48 2.
' Control Room 51
.3.
- Cable Spreading Room 54 4.
Plant Computer Room....................
56 5.
Switchgear Room.......................
57 i
- =
Page No.
6.
Remote Safety Related. Panels 58 59 7.
Station Battery Room 8.
Turbine Lubrication and Control Oil Storage and Use Areas.
60 9.
Diesel Generator Areas 61
' 10.
Diesel Fuel Oil Storage Area 62 11.
Safety Related Pumps 63 12.
New Fuel Area.......................
64
- 13. Spent Fuel Pool Area 64
~65
- 14. Radwaste Building.......
- 15. Decontamination Areas...................
65 16.
Safety Related Water Tanks 66 17.
Record Storage Areas 67 18.
- 19. Miscellaneous Areas....................
68 E.
Special Protection Guidelines 68 1.
'Jelding and Cutting, Acetylene - 0xygen Fuel Gas Systems..
68 2.
Storage Areas for Dry Ion-Exchange Resins.........
69
-3.
Hazardous Chemicals..................-..
70 4.
Materials Containing Radioactivity 70 ii
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s, NRC BRANCH TECHNICAL POSITION APCSB 9.5-1 I V.- POSITIONS A.
Overall Requirements of Nuclear Plant Fire Protection Program Item 1 - NRC Position IV.A.l.(a), (b), (c) and (d):
Responsibility for the overall fire protection program should be assigned to a designated person in the upper level of management. This person should retain ultimate responsiblity even though fonnulation and assurance of program implementation is delegated.
Such delegation of authority should be to staff personnel prepared by training and experience in fire protection and nuclear plant safety to provide a balanced approach in directing a nuclear plant fire protection program. The PSAR should state the qualifi-cation requirements for the fire protection engineer or consultant who will assist in the design and selection of equipment, inspect and test the com-pleted physical aspects of the system, develop the fire protection program, and assist.in the fire-fighting training for the operating plant. Subse-quently, the FSAR should discuss the training and the updating provisions such as fire drills provided for maintaining and inspecting the fire pro-tection equipment.
This staff should be responsible for:
(a) coordination of building layout and systems design with fire require-ments, including consideration of potential hazards associated with po.tulated design basis fires.
(b) design and maintenance of fire detection, suppression, and extinguishing systems.
(c) fire prevention activities.
(d) plant personnel and fire. brigade training and manual fire-fighting activities.
(NOTE: NFPA 6, " Recommendations for Organization of Industrial F're Loss Prevention," contains useful guidance for or of the entire fire loss prevention program.)ganization and operation Response to Position IV.A.l.(a), (b), (c) and (d):
The Rancho Seco~ nuclear plant is in compliance with the parts of this guide-line.that are applicable to an operating plant.
Parts of this gu'deline are not applicable.to Rancho Seco as they apply to a. plant in the construction pennit application or construction stage.
The upper-level management person responsible for the overall Rancho Seco plant fire protection program is Mr. John J. Mattimoe, Assistant General Manager and Chief Engineer. !
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Q q-The overall responsibility for the operational aspects of the plant fire protection program, including personnel training and the testing and main-tenance of fire detection, suppression, and extinguishing systems, has been delegated to the Plant Superintendent.
Further subdelegation is made within the plant staff to personnel with the required training and experience to provide an effective fire prevention and suppression program.
The overall responsibility for the engineering design aspects of the plant fire protection systems has been delegated to the Manager of the District's Generation Engineering Department.
This responsibility includes the engi-neering of design modifications to the operating plant fire protection systems. The District's Generation Engineering Department has on its staff experienced engineers who participated in the original design of the plant fire protection systems.
Item 2 - NRC Position IV,._Ad:
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 maintaining ability to perform safety shut-down functions and minimize radioactive releases to the environment.
Respone to position IV.A.2:
The Rancho Seco plant meets the intent of this guideline with the exception of meeting the NRC's definition of " design basis fire" relative to our definition of fire protection areas (zones).
The definition of a " design basis fire" is of major importance in evaluating the plant's ability to sustain such a fire and still safely shutdown.
In the majority of critical areas, the only significant combustible present is electrical cable.
When that cable has been designed to have, as a basic characteristic, high resistance to fire then the type of fire possible would not be a rapidly advancing high heat producing fire.
To presume that all levels of defense have failed including immediate responding automatic sys-tems, early response manual systems and late response manual systems and that vitually all combustibles within a fire area have been destroyed is in our opinion not credible.
It would not be reasonable or practicable to redesign and modify the Rancho Seco plant to meet the NRC's definition of
" design basis fire" as stated in Section IIIC, Page 12 of APCSB 9.5-1, May 1, 1976.
Within a defined fire protection zone where there are no significant com-bustible materials present other than fire retardant electrical cable, it is our opinion that there exists a maximum horizontal distance beyond which
" flash.over" will not occur, and recognition should be given to this fact in evaluating fire' hazards.
In the design of the Rancho Seco Unit No. 1 plant, fire hazards were evalu-ated relative to maintaining ability to safely shutdown the plant and minimize radioactive releases concurrent with a fire. -
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In general, the plant design was evaluated in regard to fire hazards to.
minimize the probability of fires and explosions and to minimize the poten-tial tffects of such events on safety related structures, systems and components.
'In order to. simplify the design and maximize the efficiency of fire suppression activities and plant operating decisions, the plant is divided into fire protection areas designated as " zones." Each.of these zones constitutes an independent, area which is protected by a particular method of fire sup-pression and detection system.
The control room is provided with a fire alarm annunciator panel that will identify the zone, by number, from which a fire alarm was initiated, j
Several types of alarm and detection devices are installed at the plant.
These include manual pushbutton and pull stations and automatic systems utilizing ionization smoke detectors, infrared detectors and heat detectors.
All detectors and manual initiating devices give automatic annunciation (audible and visual) in the control room.
The manual pull stations activate a local alann bell. The detection system's applications are discussed in i
greater detail in other items.
i Automatic and manual fire suppression equipment was installed relative to the fire hazards evaluation.
Fire suppression equipment at the Rancho Seco plant includes (a) an automatic fire sprinkler and fog system, (b) fire hosestations,(c)portableCO2 and dry chemical fire extinguishers, and (d)anautomaticCO 2 system.
Fire suppression systems are designed in 1
accordance with the standards of the National Fire Protection Association and are based on the recommendations of the Huclear Energy Property Insurance Association. The specific application of each type of fire suppression system will be discussed in additional detail in other parts of this report.
_I_ tem 3 - NRC Position IV. A.3:
Total reliance should not be placed on a single automatic fire suppression system. Appropriate backup fire suppression capability should be provided.
Response to Position IV.A.3:
The Rancho Seco plant is in compliance with this guideline in regtrds to having backup. fire suppression capability for the installed automatic systems.
Automatic suppression systems are installed in areas of the plant where significant fire hazards exist and include ordinary occupancy wet pipe t
' sprinkler systems, hydraulic designed wet pipe sprinkler system, deluge systems, and carbon dioxide systems' designed for deep-seated electrical fires.
Fire detection systems are located-in critical areas throughout the plant to give early warning of fire initiation.
Portable extinguishers are in-stalledsin accordance with rules of NFPA No. 10 to provide the capability
.of manual extinguishment of small fires. '
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Fire-hose stations have been installed throughout the Auxiliary and Turbine
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Buildings to provide suppression capability to backup the automatic systems.
Item'4 - NRC Position IV.A.4:
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-A single failure in the fire suppression system should not impair both the primary and backup fire suppression capability.
For example, redundant fire-water-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. -However, in the event of the most severe earthquake; namely, the safe' shutdown earthquake -(SSE), the fire. suppression system should be capable of delivering water to manual hose stations located within hose reach of areas containing equipment required for safe plant shutdown, ine i
fire protection systems should, however. retain their original design capa-bility for (1) natural phenomena of less severity and greater frequency (approximataly once in 10 years) such as tornadoes, hurricanes, floods, ice storms or small intensity earthquakes which are characteristic of the site geographic region and (2) for potential man created site related events such as oil barge-collisions, aircraft crashes which have a reasonable 1
probability of occurring at a specific plant site.
The effects of lightning strikes should be included in the overall plant fire protection program.
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Response to Position IV.A.4:
. The Rancho Seco plant meets-this guideline with the exception that the fire water system was not designed to meet Rancho Seco seismic Class I safe shut-1
' down earthquake criteria.
j The fire protection water syr.te"ms are supplied using two 100% capacity independent. fire-pumps. One is'an electrical driven pump controlled by a UL listed controller and takes suction from the' circulating water basin.
The second pump is a diesel driven pump with'an independent fuel supply and battery packs arranged such that loss of all station power 'does not impair pum) operation..This pump takes suction from the site water supply i,
pipeline w1ich:is pressurized by the site reservoir. As a third water supply source, the site pumping station can supply water to either fire pump from the makeup water supply. canal.
1 The two fire pumps supply water to the yard main system which is arranged in a loop _ configuration with adequate sectionalizing valves to allow isola-
-tion of any single' pipe failure-and still supply water to all sections of theLloop other than the. failed section.
Although the in-plant ~ sprinkler systems have not been designed to meet the i
seismic Class I criteria for Rancho Seco, they.have been installed in l-accordance with the requirements of NFPA No.13, Appendix B, Paragraph B-3.2-10, " Sway Bracing.for ~ Protection Against Earthquakes."
It.is our fopinion that this design provides more than adequate protection for the
-once-in-ten-years-phenomena and would preclude massive failures in the event of a safe shutdown earthquake.
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With regard to the safe shutdown earthquake, it is our opinion that the yard main system which is enti.21y underground would retain its integrity and would be available to s.../ water to any portion of the plant other than the containment buildin, interior within a very short time of recognition of the need ic manual hose,tream fire suppression.
Critical areas of "
- 1 ant (switchgear rooms, battery rooms, diesel generator rooms, and cable.,. reading rooms) are protected by an automatically initiated low pressure carbon dioxide system which has been designed in accordance with the requirements for Quality Assurance Class I, Seismic Class I installations and has sufficient capacity to provide as a minimum double shot protection.
This installation has been designed, installed, and tested to demonstrate compliance with the requirements of NFPA No.12 with rate of CO2 application, concentration and retention designed for deep-seated electrical fires.
Certain exposed parts and areas of the plant have been provided with lightning protection to arrest lightninig strikes and protect plant equipment. A lightning rod grounding system is provided on top of the reactor building and cooling towers. To protect plant electrical equipment, overhead ground wires are located above the 230 XV switchyard conductors and lines into the plant.
Lightning arrestors are located on the high voltage terminals of the main and startup transformers. Also, surge protectors are connected to the 22 KV generator bus.
Freeze protection is provided for fire water lines located outdoors that would be exposed to freezing weather conditions.
Item 5 - NRC Position IV. A.5:
Failure or inadvertent operation of the fire suppression system should not incapacitate safety related systems or components.
Fire suppression systems that are pressurized during normal plant operation should meet the guide-lines contained in APCSB Branch Technical Position 3-1, " Protection Against Postulated Piping Failures in Fluid Systems Outside Containment."
Response to Position IV.A.5:
We' consider the Rancho Seco plant to be in compliance with this guideline.
The following statement is extracted from the Rancho Seco Unit No. 1 FSAR:
" Rupture or inadvertent operation of fire protection systems will not.significantly impair the safety capability of required systsms.
Inadvertent operation of 'he CO2 system will not prevent the opera-tion of any safety relased equipment.
Inadvertent operation of a section of the Auxiliary Building sprinkler system is not expected to resultiin safety equipment impairment primarily because wet sprinkler system protection is excluded from rooms containing electrical switchgear or safety system pumps and motors.
The ex-
.ception.to this rule, the auxiliary diesel generators, was discussed previously.
Since each section of the sprinkler system is indepen-dently actuated, the inadvertent operation of all or a significantly large group of Auxiliary Building sprinklers is not credible. Addi-tionally, floor drains are sized such that they can easily carry 1
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, r away the relatively small flow of water that results during sprinkler operation.
The only situation in which automatic or inherent design features might require supplementary operator action to ensure protection of safety related systems is a fire main rupture in the Auxiliary Building.. This fire main is generally routed through the central corridors of each floor of the Auxiliary Building.
If a fire main rupture occurred on any floor at or above grade level, it is not anticipated that any substantial water accumulation will occur on these floors since most of.the water will drain down the stairwells to below grade.
Floor drains will further limit any water accumu-lation.
The' limiting safety related components located below grade, for which protection must be provided, are the decay heat pump and spray pump motors.
Flooding protection is provided to prevent loss of more than one
, redundant trains by compartmentation of decay heat pumps and spray pumps into separate rooms. The operators will have sufficient time to determine that a fire main rupture has occurred and then isolate the Auxiliary Building fire main before any safety related system has been degraded below minimum requirements. Among the indications available to the operators during a fire main rupture condition are:
1.
Operation of both fire pumps without a _ central fire annunciator control panel alarm.
2.
A fire main water gong flow alarm without a central and local fire annunciator control panel alarm.
3.
Operation of both decay heat pump room sump pumps followed by j
a high sump level alarm.
4.
The flow impingement noise in the area surrounding the ruptured fire main.
Therefore, the. design of the Rancho Seco fire-fighting systems is such that their rupture or inadvertent operation will not significantly impair.the safety capability of safety related structures, systems, and components."
~ Item 6 - NRC Position IV.A.6:
The fire protection program (plans, personnel and equipment) for buildings storing new reactor fuel and for adjacent fire zones which could affect the fuel storage zone should be fully operational before fuel is received at
'the site.
Response to NRC Position IV.A.6:
LThis_ item is not applicable to an operating plant. i I
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Item 7 - NRC Position IV.A'.7:
The fire protection program for an entire reactor unit should be fully operational prior to initial fuel loading in that reactor unit.
flesponse to Position IV.A.7:
This item is not applicable to an operating plant.
Item 8 - NRC Position IV.A.8:
On multiple reactor unit sites where there are oparating reactor units and construction of remaining units is being completed, the fire protectio 1 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 operating plant superintendent should have the lead responsibility for site fire pro-tection.
Response to Position IV.A.8:
This item is not applicable to the Rancho Seco Site at this time.
If addi-tional reactor units are added at the site at some future date, we will consider the NRC fire protection requirements in existence at that time in regards to protecting Unit Nc. 1 from construction hazards.
B.
General Guidelines for Plant Protection Item 9 - NRC Position IV.B.1.(a), (1) and (2):
1.
Building Design (a) Plant Layouts should be arranned to:
(1)
Isolate safety related systems from unacceptable fire hazards, and (2) Separate redundant safety related systens from each other so that both are not subject to damage from a single fire hazard.
Response to Position. IV.B.l.(a), (1) and (2):
The Rancho Seco plant meets the intent of this criteria except for the
'" design' basis fire" definition as stated in Section IIIC, Page 12 of APCSB 9.5-1, May 1, 1976, as'previously discussed in Item No. 2.
-The Rancho Seco plant has been arranged to provide isolation of the plant buildings containing safety features systems from unacceptable fire hazards.
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' Major _ fuel; oil storage tanks are located remote from plant buildings or
.are buried underground. The:various oil filled transfonners are separated
. by concrete fire. walls.-. The Turbine Building containing turbine lube oil systems is~ caparated from the Auxiliary and Fuel Buildings by a 3-hour rated fire cutoff wall equipped with 3-hour fire rated doors.
The Rancho' Seco Auxiliary.Bullding which contains the majority of safety.
- related systems :is divided horizontally throughout by'3-hour rated floors.
- Inl addition, the building is~ sectionalized into multiple fire zones which are. isolated by' 3-hour rated fire walls.
~ Examples of separation of redundant safety related equipment items are as
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follows:
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1.
With the exception of the main Control Room area, all redundant safety related electrical switchgear cubicles and panels are separated from each other.by 3-hour rated fire walls.
In the main Control Room, p
redundant cubicles are separated by at least a metal barrier.
2.
The safety.related batteries are each located in separate rooms from
' any other equipment and are separated from redundant batteries by 4
3-hour rated fire walls, with the. exception of the doors which are discussed in Item No. 18.
3.
The redundant emergency diesel generators are located in rooms separate 4
a from each other and other items of plant equipment. Tne walls, floors,
-doors and ceilings of the rooms are 3-hour fire rated.
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The redundant safety feature. injection pumps.(high pressure injection, low pressure injection and. Reactor Building. spray pumps) are located in separate rooms with 3-hour fire rated walls, floors and ceilings.
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Items of redundant safety features eq ipment that are not separated by 3-hour rated -fire walls or other barrYers are separated by spatial distance from each other and fire hazards (except where such hazards are an integral f'
part of the equipment, see Item No. 19). The plant separation criteria for redundant electrical cables is discussed in Item No.11.
Item 10 - NRC Position IV.B.l.(b):
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- In: order to accomplish 1.(a) above, safety related systems and fire hazards
'should:be identified throughout the plant Therefore,_a. detailed fire
' hazard analysis should be made during initial plant design.-
- Response to Position IV.B'.1.(b):
We consider that the Rancho'Seco plant meets.'the intent of this guideline, i
Plant layout and' design drawings 11dentify items of equipment.by.name or code letter which'provides a means of analyzing the exposure of safety j
related equipment. to'significant. fire hazards such as oil storage-tanks, oil. filled transformers-and lube oil systems.
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O In the design of the Rancho Seco plant, fire hazards were given careful con-sideration in locating equipn.ent, fire walls, barriers, selecting materials and designing the fire protection systems.
Item 11 - NRC Position IV.B.l.(c):
For multiple reactor unit sites, cable spreading rooms should not be shared between reactors.
Each cable spreading room should be separated from other areas of the plant by barriers (walls and floors) having a minimum fire resistance of three hours.
Cabling for redundant safety divisions should be separated by walls having three hour fire barriers.
Response to Position IV.B.l.'(c):
N Rancho Seco plant is in compliance with this guideline with the following two exceptions:
1.
The cable tray wall and floor penetrations in the cable spreading rooms have not. been 3-hour rated by the ASTM E-119 test.
2.
The cabling for redundant safety divisions is not separated by 3-hour rated fire barriers throughout the Rancho Seco plant.
At the present time, the site is a single unit site.
If additional reactor units are added at this site in the future, we will comply with the NRC fire protection criteria in effect at that time in regards to this item.
With the exceptica of cable tray wall penetrations as stated above, the Rancho Seco Unit No.1 cable spreading rooms are separated from other plant areas by 3-hour rated fire walls. The Rancho Seco cable tray wall pene-tration fire barriers are discussed in Item No. 26.
It would not be reasonable or practicable to add 3-hour rated fire walls between all redundant safety related cabling throughout the plant.
In the design of the Rancho Seco cabling system redundant safety systems were separated by spatial distance or barriers to minimize the probability of losing more than one redundant train because of an external fire.
The following excerpts from the FSAR for Rancho Sece Unit Ho.1, describes the separation criteria employed in the design of the redundant safety related cabling system:
"H.
The separation of redundant cables of the reactor protection system and safety features actuation system circuits is accomplished by spatial separation in accordance with the following criteria:
1.
Separate cable tray conduit and penetration systems are l
installed for the following classes of cable:
15 kV, 5 kV, 600-volt power-and control, and instrumentation cable.
Class I-600-volt power and control cables of l
one channel are run together in trays that belong to the.-
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Class I instrumentation circuits are routed
- in rigid metal conduits as explained in Paragraph 2'below.
These two.diff4 rent and independent routing methods preclude the possibility of fire in a' tray carrying power and contml I
, cables propagating to instrumentation circuits.
In-general, power cable trays carrying cables greater than 600 volts are not.fnstalled. parallel to an'd below conduits carrying Class I.instrumention cables or trays carrying Class I instrumen-tation cables or trays carrying Class I 600-volt power and
, control cables.
In.the few instances where conduits carrying Class I instrumentation cables are installed parallel to and above power cable trays, the conduits are wrapped with.1"
. thick insulation thermobestos for protection.
2.
Reactor pmtection system and safety features actuation-i system instrumentation each have their channels routed in separate conduits and are physically separated from each other throughout the plant.
t 3.
Reactor pmtection' system and safety features actuation system power and control, Channels A and B, are separated physically and have separate raceway systems.
Non-safety related circuits may be run in these trays.
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.4.
Reactor protection system Channels C and D and safety features actuation system Channel C power are separated physically by channel and are separated from any other channel source or non-safety related power and control source.
i 5.
Power and control circuits are not mixed with instrumentation l
circuits in any raceway' for the systems.
. 6.
The minimum horizontal distance between trays of different channels is 3 feet - 0 inches.
J 7.
Paralleling trays of different channels in a vertical stack is not permitted.
8.
The minimum vertical distance between trays of different channels crossing each other.is 18 inches. Additionally, at. tray crossings, a 1/4 inch thick Haysite polyester board fire barrier is installed between the trays for protection.
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- 14., Protection system, safety features system, and Class IE electrical' system components mounted on control boards, panels, ~and relay.. racks are designed with physical separa-
- tion between redundant wiring and components.
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Generally, redundant channel wiring' enters the control
' panels 4in conduits.
The bulk of redundant wiring inside.
L control panels are separated by a steel barrier.
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s wiring which is comon to two redundant channels exist. The jackets of these wires are identified with the color or the channel energizing them."
We consider the above cable separation criteria to be adequate and propose i
no changes to the separation provisions for the redundant safety related cables.
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Item 12 - NRC Position IV.B.l.(d):
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 1
recognized testing 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").
Response to Position IV.B.l.(d):
The Rancho Seco plant is in compliance with this guideline with the exception that the flammab lityof the interior wall paint is unknown at the present time.
All materials of construction utilized in the major buildings are of non-combustible nature or have been accepted by NEL-PIA as having acceptably low flame spread, smoke and fuel contribution ratings.
At this point in time, we are still researching the flamability ratings of the types of paint used on concrete walls in critical areas.
We will notify the NRC of our findings when 'the investigation is completed.
Item 13 - NRC Position IV.B.l.(e):
Metal deck roof construction shnuld be noncombustible (see Underwriters Laboratory, Inc., building materials directory), or listed as Class I by Factory Mutual System Approval Guide.
Response to Position IV.B.l.(e):
The Rancho Seco plant is in compliance with this guideline.
The building roof construction meets the requirements of Underwriters Laboratories for noncombustible construction.
Item 14 - NRC Position IV.B.1.(f):
Suspended ceilings and their supports should be of noncombustible construc-tion.
Concealed spaces should be devoid of combustibies..
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' Response-to Position IV.B.l.(f):
The Rancho Seco plant meets this criteria with the exception of "possible combustible" materials above suspended ceilings.
Suspended ceilings and their supports used in the construction of Rancho Seco buildings are rated noncombustible.
In certain areas of the plant electrical cables in trays are located above suspended ceilings.- However, areas above suspended ceilings with signifi-cant concentrations of cable trays are protected by automatic actuated wet type sprinkler systems or carbon dioxide fire extinguisher systems.
In addition, the cables are of flame retardant construction.
We propose that these automatic fire extinguishing systems and flame retardant cable construction be accepted as an alternate for meeting the intent of this guideline.
Item 15 - NRC Position IV.B.l.(g):
High voltage - high amperage transformers installed inside buildings con-taining safety related systems should be dry type or insulated and cooled with noncombustible liquid.
Response to Position IV.B.l.(g):
The Rancho Seco plant meets this guideline. There are no high voltage-high amperage transformers installed inside of the Rancho Seco buildings containing safety related systems.
g Item 16
- NRC Position IV.B.l.(h):
Buildings containing safety related systems should be protected from exposure or spill fires involving oil filled transformers by:
locating such transformers at least 50 feet distant; or
- assuring that such building walls within 50 feet of oil filled transformers are
- thout openings and have a fire resistance rating of at least three hours.
Response to Position IV.B.l.(h):
The Rancho Seco plant meets this guideline.
All transformers located within 50 feet of the buildings containing safety related systems:are filled with nonflammable insulating oil except for one small oil filled transformer located adjacent to the Reactor Containment
' Building. This transformer is considered to bc in comoliance with the guide-line since the reactor building has no permanent openings.
' The oil filled main and startup power transformers adjacent to the Turbine -.
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Building are protected by deluge water spray systems and in addition the
. Turbine Building' wall is protected by exterior exposure sprinklers.
Those portions of the Turbine Building in the vicinity of these power transformers contain no safety related equipment, and the transform,rs are located in excess of 120 feet away from any Auxiliary Building wall containing safety related systems.
Item 17 - NRC Position IV.B.l. (i):
Floor drains, sized to remove expected fire fighting water flow should be provided in those areas wuere fixed water fire suppression 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 unacceptable damage to other equipment in the area.
Equipment should be either in-stalled on pedestals, or curbs should be provided as required to contain water and direct it to floor drains.
(See NFPA 92, " 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.
Response to Pos' tion IV,B.l.(i):
The Rancho Seco plant complies with this guideline.
In areas of the plant where wet sprinklers have been installed the floor drain:; have been designed to handle the water flow rate that could result from credible fires.
In areas where wet pipe sprinklers have not been installe'd the various electrical equipment items have been installed on pedestals to provide isolation from accumulations of water on the floors from the use of the manual fire hose system.
In plant areas where wet pipe sprinkler systems are used'on combustible liquids the design of the drainage system is such that the flammable liquid-water mixture would not drain into areas containing safety related systems.
Floor drains from areas containing potentially radioactive systems are routed to the miscellaneous waste handling system and would automatically be held up ' prior to release.
Item 18 - NRC' Position IV.B.l. (j):
Floors, walls and ceiling enclosing separate fire areas should have minimum three-hour fire rating.
Penetrations in these fire barriers, including conduits and pipinj, should be sealed or closed to provide fire resistance rating at least equ' to that of the barrier itself.
Door openings should be protected with equivalent rated doors, frames and hardware that have been tested and approved by a nationally recognized laboratory.
Such doors should be normally closed and locked or alanned with alarm and annun-ciation in the Control Room.
Penetration for ventilation systems should be _ _.,
O protected by a standard " fire door damper" where required.
(Referto NFPA 80, " Fire Doors and Windows.")
Response to Position IV.B.l.(j):
The Rancho Seco plant is in compliance with this guideline with the following
-four exceptions:
1.
The sealing system used for cable tray penetrations through walls and ceiling have not been tested for a three-hour rating in accor-dance with ASTM E-119.
2.
The battery room doors'do not have a three-hour rating.
3.
All doors into separate fire areas are not locked nor are they equipped with alarms-to annunciate in the Control Room.
4.
Piping penetration seals are not three-hour rated.
In th'e Auxiliary and Containment Buildings all wall and ceiling construction is noncombustible and has a three-hour fire rating.
With exception of the battery rooms, all doors have UL listings for three-hour ratings. The battery room doors were purposely furnished with glass windows to provide the capability of security surveillance without entering the rooms. These rooms are.normally kept locked and all but essential entrance is eliminated due to the potential hydrogen fire hazard. We do not propose to replace the' doors to the. battery rooms for doors without glass.
The Rancho Seco plant cable tray floor and wall penetration system is dis-cussed in Item No. 26.
Electrical conduits passing through zone fire walls and floors are either poured or grouted in solid with concrete, or they pass through a cable tray tvoe of fire barrier.
Pipes passing through walls and floors have a small solid foam filled gap between the outside wall of the pipe and the concrete to allow for expan-sion and contraction.
It-is not considered to be necessary to provide a three-hour seal in this gap because we did not consider it to be credible for a metal pipeline to burn and transmit a fire from one room to another.
Consequently, we are proposing no changes to pipe penetrations.
The doors to all critical areas of the plant containing safety related
. systems are not locked because of personnel safety reasons. A very stringent ~ administrative control procedure is in effect at the Rancho Seco plant to maintain the critical interior fire rated doors in the proper positions. This procedure has proven to be very effective; con-sequently, we propose to make no changes to the door control system.
The ventilation. penetrations in the CO2 protected zones are provided with' UL listed fire dampers for isolation
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Item 19 - NRC Position IV.B.2.(a):
2.
Control of Combustibles (a) Safety.related systems should be isolated or separated from combustible materials. When this is not possible due to the nature of the safety system or the combustible material, special protection will be required to prevent a fire defeating the safety system function.
Such protection may involve a combination of automatic fire suppres.sion, and construction capable of withstanding and con-taining a fire' that consumes all combustibles present.
Examples of such combustible materials which may not be separable from the remainder of its system are:
Emergency diesel generator fuel oil day tanks.
Turbine-generator oil and hydraulic control fluid systems.
Reactor coolant pump lube oil system.
Resoonse to Position IV.B.2.(a):
The Rancho Seco plant is in compliance with the intent of this guideline.
The diesel generator fuel oil day tanks are integral parts of the diesel generator assembly and cannot practicably be separated from the equipment.
Each diesel generator is isolated from other zones by three-hour rated fire walls, floor, ceiling and doors, and, in addition, is orotected by wet pipe sprinkler systems and automatic carbon dioxide fire protection systems.
The turbine-generator lube oil systems are not contained within a separate fire enclosure, however, the oil distribution systems are protected either by hydraulically designed wet pipe systems or by permanently installed carbon dioxide fire protection systems and the main lube oil storage reservoir is protected by an automatic dcluge spray system. The generato'-
hydrogen seal oil system is protected by a deluge wa',r spray system and the piping between the seal oil system and the genert.or is in an area-protected by a hydraulically designed wet pipe system. The turbine-generator electro-hydraulic system is filled with nonflamable fluid.
In addition, a spatial separation of at least 30 feet is provided between the-turbine-generator oil systems and the Auxiliary Building which contains safety related systems.
The reactor coolant pumps do not have automatic fire suppression systems installed; however, the lube oil systems for the pumps and motors are enclosed.by a metal oil catch basin designed to contain any oil leakage and prevent its contact with high temperature components in the vicinity.
The oil catch basin is also designed to prevent the spread of burning oil to any safety related system components that could be disabled by fire.
- There are no safety features components within the reactor coolant pump motor cavities with the exception of steel pipes which would not be significantly effected by an oil fire.
The reactor coolant pump motors..
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are' separated from safety features components by 4 feet thick concrete shield walls. ' The only other safety related items within the same cavities in the reactor coolant: pump motors are some electrical conduits containing reactor protection -signal circuits.
These. conduits are separated such c
~ hat an oil' fire in.one reactor coolant pump motor could only conceivably t
effect one out of the four protective instrumert channels.
It is our opinion that the oil leakage catch enclosures plus the concrete shield walls will provide sufficient containment of any credible fire such that i
damage to. safety features components will not occur.
Consequently, we propose'to'make.no changes to the fire protection for the reactor coolant pump motors.
Certain air handling units located both inside and outside of the Reactor Containment Building are provided with charcoal filters. The charcoal filter elements are not enclosed within a separate 3-hour fire rated enclosure nor are they directly protected by automatic fire suppression
' systems. The charcoal filter elements are completely enclosed by substan-tial metal 61r handling unit enclosures. Also, spatial separation is provided from redundant safety features equipment items. The air handling units with charcoal filters. located outside of the containment are covered by overall wet. pipe sprinkler systems. Please see Item No. 36 for additional discussion regarding charcoal filters.
Certain' redundant safety features pumps and motors have oil lubricated i-bearings; such as, high pressure injection pumps, low pressure injection pumps and nuclear service raw water pumps. These cumps are in separate rooms With 3-hour fire rated walls, floors and ceilings, or they are separated by spatial distance to the extent that a bearing oil fire in one unit would not conveivably disable the redundant safety features function.
4 i
Item ~20 - NRC Position IV.B.2.(b):
1 Bulk gas storage (either compressed or cryogenic), should not be permitted inside structures housing safety related equipment.
Flammable gas storage such as hydrogen, should be located outdoors or in separate detached'huildings-so -that a fire or explosion will not adversely affect any safety related systems or equipment.
(Refer to NFPA SOA, " Gaseous
_ Hydrogen Systems.")
i e
Ca m should be:taken to locate high pressure gas storage containers with long axis parallel.to buildings walls.
This will minimite 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.")
4 l Response to position IV.B.2.(b):
The Rancho Seco plant is in compliance with this guideline.
L The' plant's' bulk _ storage facility for hydrogen, nitrogen and carbon dioxide are located outdoors and remote,_ approximately 250 feet, from buildings.
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containing safety related equipment.
The long axis of the gas storage bottles are not in a direct line w'ith any building containing safety related equipment.
However, the long axis of the bottles is in direct line with several items of outdoor located
. safety related equipment. At least 200 feet distance separates the bottles and safety related equipment items.
The control over the use of flammable gases inside of plant buildings is governed by written administrative and/or operating procedures.
Item 21 -~NRC Position IV.B.2.(c):
The use of plastic materials should be minimized.
Halogenated plastics especially, 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, will burn with an intensity and BTU production in a range similar to ordinary hydro-carbons. They also produce heavy dense smoke when burning that obscures visibility and can plug air filters, especially charcoal and HEPA. The halogenated plastics also release free chlorine and hydrogen chloride when burning which are toxic to humans and corrosive to equipment.
Response to' Position IV.B.2.(c):
The Rancho.Seco plant is in compliance with this criteria with the excep-tion of electrical cable insulation.
Other than electrical. cable insulation the only significant plastics in the plant are those used for packaging and wrapping of contaminated or potentially contaminated materials and these plastics are rated non-flamable by Underwriter's Laboratories, s
Essentially all of the electrical conductor insulation in the planti is crosslinked polyethylene (a thermosetting plastic).
We estimate at least 80% of the cables have outer jackets of neoprene..The use of PVC insulated or jacket cable in the plant was minimized.
PVC insulated and jacketed cable was used throughout the plant lighting and communication systems.
However, the cable for these systems is totally enclosed in metallic conduct except in the communications room.
The only known PVC insulated cable in open trays is in the radiation monitoring system which is an insignificant amount of cable in comparison to the total.
.We consider it to be not reasonable or practicable to replace all of the electrical cable in the Rancho Seco plant to meet this requirement and therefore propose to make no changes.
Item 22 - NRC Position IV.B.2.(d):
(
Flammable liquids storage should, as a minimum, comply with the require-ments of NFPA 30, "Flamable and Combustible Liquids Code."
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Response to Position IV.B.2.(d):
With the exception of the diesel generator. oil day tanks, all flamable
' liquids: at Rancho 1Seco are stored in accordance with requirements of NFPA 30, "Flamable and Combustible Liquids Code."
' The diesel' generator fuel oil tanks are discussed in Item Nos.19 and 78.
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Item 23 - NRC Position'IV.B.3.(a):
3..
Electric Cable Construction. Cable Trays and Cable Penetrations (a)..Only noncombustible materials should be used for cable tray 4
' construction.
Response to Position IV.B.3.(a):
The Rancho Seco plant is in compliance with this guideline.
~All cable trays.in the Rancho'Seco plant are of metal construction.
1 Item 24 - NRC Position IV.B.3.(b):
See Section IV.D.3. for fire protection guidelines for cable spreading rooms.
Response to Position-IV.B.3.(b):.
i See Item No. 72.
4 Item 75 - NRC Position IV.B.3.(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 4
hose stations and portable hand extinguishers should be provided as
. backup. _ ' Safety related equipment in the vicinity of such cable trays,
'which does not itself require water fire protection, but is subject to-unacceptable damage if wetted by sprinkler water discharge, should.be protected fromLsprinkler system operation or malfunction.
~ ResponsetoPosition'IV.B.3.(cj:
The Rancho Seco plant complies with this guideline with the exception Ethat: automatic water sprinkler systems'are not applied to all cable trays outside of the cable spreading room.
InLareas outsideLof the cable spreading room, an automatic wet pipe sprinkler system or carbon dioxide' systems have been applied to areas
- containing significant concentrations of cables in trays.- -In areas of p
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the Auxiliary Building where there are no significant combustible hazards (minus 20 level and minus 47 level) cable trays that are stacked 3 or more deep have wet pipe sprinklers covering them.
Isolated one and two tier cable tray runs are not provided with water sprinklers.
Water sprinklers were not applied in the control and computer rooms.
These areas are discussed in Item Nos. 71 and 73.
Cable tray runs in the Turbine Building are provided with water sprinklers.
However, there are no safety features cable tray runs in the Turbine Building.
Cable trays inside the Containment Building do not have sprinkler protec-tion over them.
Refer to the discussion in Item No. 63 regarding fire protection inside containment.
For the areas outside of the cable spreading room that are not provided with water sprinklers we feel that there is adequate separation between redundant safety related circuits to prevent the loss of a safety function in the event of a fire.
In cable tray areas provided with automatic CO2 protection, the CO2 pro-tee, tion system is a total flooding system designed for deep-seated electrical fires.
The Ranch' Seco plant is designed such that there will be no adverse o
effects to safety related equipment as a result of discharge of the wet pipe sprinkler system over cable trays.
If not damaged, the cables used in the Rancho Seco plant are capable of operating while totally submerged in water.
Consequently, the discharge of sprinklers or deluge water over cable trays will not in itself cause cable faults.
The Rancho Seco plant is equipped with manual hose station and portable extinguishers to provide backup fire protection for the cable tray areas equipped with automatic water sprinkler and CO2 systems and provide primary protection for cable tray areas not equipped with water sprinklers.
We propose no additions to the wet pipe sprinkler system over cable trays outside of the cable spreading rooms.
Item 26 - NRC Position IV.B.3.(d):
Cable and cable tray penetration.of fire barriers (vertical and horizontal) should be sealed to give protection at least equivalent to the 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. ;
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Response to Position IV.B.3.(d):
The Rancho Seco plant does not comply with this guideline.
The fire stops installed on cable tray penetration of fire barrier walls at the Rancho Seco plant have not been tasted in accordance with ASTM E-119.
It is our opinion that the test methods specified in ASTM E-119 is one that was intended for general industrial construction and is not applicable to the configuration present in cable tray penetrations. We have carefully studied the requirements of ASTM E-119 and we feel that there is no possible modification that could be made to our cable tray wall or floor barriers that would make them capable of meeting the requirements of this standard.
ASTM E-119 requires that the exposed surface of the penetration be raised to 1925'F over a three-hour period while the unexposed surface shall not increase by more than 250 F above its initial temperature. With continuous steel trays and heavy copper conductors extending throught the penetration, we maintain that it is physically impossible to meet the acceptance criteria of ASTM E-119.
A wall and floor cable tray fire barrier identical to the design installed at the plant was fire tested in a vertical configuration.
This test con-sisted of. direct impingement of a 1900*F gas flame from a ribbon burner, 10" long, on the underside of a barrier through which cables penetrated.
The flame was directed at the junction of the barrier and the cable. The Rancho Seco cable tray penetration fire barrier design withstood this test for a period of one full hour without any flame passing above the barrier or without destruction of the barrier. The barrier could have withstood the flame test for a much longer period, However, we considered that a one hour period was adequate time to place the plant in a safe shutdown condition and to have put into effect the necessary manual suppression effort required to put out the fire.
We have been negotiating with NEL-PIA for some time regarding the applica-bility of ASTM E-119 to cable tray penetration fire barriers and the design of cable tray fire barriers. NEL-PIA has recently issued a test procedure of their own which we are studying and coninenting on.
We maintain that our cable tray penetration fire barriers and tests are adequate and we propose to make no modification or do no additional testing to these barriers.
In addition, we would hope that arrangements can be made for coordinating the NEL-PIA and NRC requirements in this regard.
Item 27 - NRC Position IV.B.3.(e):
Fire breaks should be installed at every 10 feet along horizontal and vertical cable routings to prevent the propagation of a fire.
Flame or fire retardant coatings may be used as a fire break for grouped elec-trical cables to limit spread of fire-in cable routings.
s (Possible cable derating due to use of such coating materials must be considered during design.)
-Response to Position IV.B.3.(e):
The Rancho Seco plant does not comply with this guideline in regard to having a fire break every 10 feet.
In addition to the fire barriers where cables penetrate walls and ceilings, additional fire barriers or fire breaks were installed in the following locations:
1.
Whenever cables enter or exit from electrical cubicles in the switchgear rooms.
2.
Fire stops were applied in the Reactor Building on vertical cable tray runs at every intersection between a tray and an open deck Stating. This amounts to a fire stop on vertical cable tray runs approximately every 20 feet.
3.
A fire stop was applied at intersections between horizontal and vertical cable runs whenever the horizontal and vertical tray were in close proximity to each other.
The cable _ construction design and testing specifications for the Rancho Seco plant required that the cables not propagate fire.
Cable design requirements and tests are discussed in greater detail in Item No. 28.
In view of the nonflame propagating characteristics of the Rancho Seco cable and the-application of fire stops as discussed above, we do not consider it necessary to apply stops every 10 feet and do not propose to make any changes in this regard.
Item 28 - NRC Position IV.B.3.(f):
Electric cable constructions should at least pass the current IEEE No.
383 flame test.
(This does not infer that cables passing this test will not require additional fire protection.)
Response to Position IV.B.3.(f):
We consider that the Rancho Seco plant cable construction meets the intent of this guideline even though the Rancho Seco control cable has not been tested in accordance with the flame test procedure specified in IEEE Standard No. 383. The Rancho Seco cables were flame tested in accordance with the following two flame tests:
1.
Vertical Flame Test. Vertical flame tests shall be conducted per Underwriters Laboratories UL 83, Paragraph 108, or IPCEA S-19-81, Paragraph 6.19.6.
2.
Flame Integrity-Test. After each type of cable has passed the
. vertical flame test a new sample of each type of cable that has
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passed the vertical flame test shall be selc-cted and placed in the '
IPCEA or UL same chamber and position as used in the vertical flame tests. A 40 mm bore Meker or Fisher burner shal.1 be placed in the chamber with the burner in the same relationship to the cables as in the UL-IPCEA vertical flame test except that the burner shall be positioned and adjusted so that the flame completely engulfs tne cable. The burner shall be lighted, the flame shall be adjusted and left burning for a period of twenty (20) minutes time. Through-out the test a voltage shall be applied as shown in the diagrams below.
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LAMP 120V 15W Single conductor cables shall be grouped in such a way that each cable is in contact with the others as shown below and tightly bound with asbestos thread every four (4) inches.
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(a)
In addition, if a shielded cable is tested, the shield shall be connected to the neutral.
(b) Lighting of either or both lamps within the 20-minute period shall cause rejection of that particular type and size of cable.
(c) The following measurements ch311 be made for the flame tests and transmitted to the Engineer:
Time-to cable ignition Time to short-circuit or ground of conductors Time of jacket afterburn Length of cable destroyed We feel these tests adequately verify the fire retardant properties of the cable used in the Rancho Seco plant and they also demonstrate the additional ability to maintain circuit integrity for a period of time under fire conditions.
We propose not to do additional flame testing.
Item 29 - NRC Position IV.B.3.(g):
To the extent practical cable construction that does not give off corrosive gases while burning should be used.
Response to Position IV.B.3.(g):
All of the cable used in the Rancho Seco plant does not entirely meet this guideline.
See Item No. 20 for a discussion.
Item 30 - NRC Position IV.B.3.(h):
Cable trays, raceways, conduit, trenchas or culverts should be used only for. cables. Miscellaneous storage should not be permitted.
Piping for flammable or combustible liquids or gases should not be installed in this area.
Response to Position IV.B.3.(h):
The Rancho Seco plant is in compliance with this guideline.
There is no piping for flammable or combustible liquids installed in the same trays, conduits, rac ways, trenches or culverts used for electrical cables, nor is miscellaneous storage permitted in these areas.
Item 31 - NRC Position IV.B.3.(i):
Areas containing significant concentrations o,f plastic insulated electric _
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cables such.as cabic tunnels, culverts and spreading rooms should be provided with automatic or manual smoke venting as required to facilitate manual fire fighting capability.
Response to Position IV.B.3.(i):
The Rancho Seco plant is.in compliance with this guideline; however, the plant has no pemanent built-in ventilation systems for the cable spreading rooms and other areas with a significant amount of exposed cable. The plant is provided with three portable and one fixed 10,500 CFM emergency ventilation fans for manual smoke venting of these areas.
These fans are permanently stored in the Auxiliary and Turbine Buildings.
To facilitate the use of these portable fans in providing manual smoke venting capabilities we have flexible ducting that can be arranged to provide maximum advantage for the conditions that could occur.
These fans were procured in accordance with Rancho Seco Quality Assurance Class I requirements and are provided with seismic designed hold down devices to assure safe storage.
Item 32 - NRC Position IV.B.3.(j):
Cables in.the control room should be kept to the minimum necessary for o aeration of the control room. All cables entering the control room s1ould teminate there.
Cables should not be installed in floor trenches or culverts in the control room.
Response to Position IV.B.3.(j):
The Rancho Seco plant is in compliance with this guideline.
The cables entering the plant control room terminate there.
Floor trenches
-l or culverts do not exist in the plant control room.
Item 33 - NRC Position IV.B.4.(a)
-4.
Ventilatica (a).The products of combustion which need to be removed from a specific fire area should be evaluated to determine how they will be centro 11ed.
Smoke and corrosive gases should generally
^
be-automatically discharged directly outside to a safe location.
Smoke and gases containing radioactive materials should be monitored in the fire area to determine if release to the environment is within the pemissible limits of the plant Technical Specifications.
Response to Position IV.B.4.(a):
The Rancho-Seco plant is in compliance with this guideline with the excep-tion of those rooms provided with automatic CO2 protection and potentially 4 4 2
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radioactive areas of the Auxiliary and Fuel Storage Buildings. These areas
- do not automatically discharge to the outside under fire conditions.
The ventilation dampers and supply and exhaust fans of CO2 protected rooms and radioactive zones will automatically close or shutdown upon activation of the fire detection system, and manual action will be required to open these dampers and start fans to exhaust smoke and gases to the outside.
The main ventilation exhaust duct from potent %11y radioactive areas (Auxiliary Building, the Fuel Building and the Containment Building) are provided with a radiation monitoring system to automatically alarm the control room.in the event radioactivity levels exceed permissible limits.
- Controls are provided in the control room to start and stop the ventilation units for these areas.
Item 34 - NRC Position IV.B.4.(b):
Any ventilation system designed to exhaust smoke or corrosive gases should be evaluated to assure that inadvertent operation or single failures will 'not violate the controlled areas'of the plant design. This require-ment includes containment functions for protection of the public and main-taining habitwility for coerations personnel.
Response'to Position'IV.B.4.(b):
The'-Rancho Seco plant is in compliance with this guideline.
The ventilation systems serving the controlled areas of the Auxiliary Building, the Fuel Building, the Containment Building and the control room emergency ventilation systen are all totally independent of and isolated from other ventilation systems. Any single failure in these systems would have no adverse affect on the safety of the public.
Item 35 - NRC Position IV.B.4.(c):
The power supply and controls for mechanical ventilation systems should be run outside the fire area served by the system.
Response to Position IV.B.4.(c):
The Rancho Seco plant does not comply with this guideline for all areas of the plant.
Several of the ventilation systems (or components of) are themselves located within the firt zone they serve.
Consequently, the power and control wiring for te.e units are also necessarily run within
- the fire _ zone being served.
It would not be reasonable or practicable to modify the plant ventilation system to meet this g ideline, and we
- propose no changes.
The emergency portable-fan units can be connected to power services outside of_the zone being served..1
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Item 36 - NRC Position IV.B.4.(d):
Fixed automatic sprinkler systems should be installed to protect charcoal filters.
Response to Position IV.B.4.(d):
The Rancho Seco plant does not meet this guideline.
However, we consider that the charcoal filter elements are sufficiently isolated from safety related circuits and components to preclude their damage from a charcoal filter element fire.
Charcoal filters installed in air handling units outside the Containment Building are completely enclosed in substantial metal air handling units.
All connections to these units is by metal duct work and it is our opinion that _the probability of flame spread to other safety related equipment is extremely small.
In addition, these air handling units are covered on the exterior by standard wet pipe sprinkler systems.
Air handling units installed inside the containment which housed charcoal filters are also substantial metal structures which completely enclose the filter media, hcwever, the air inlets and outlets are in relatively close proximity to the filter media.
j We do not. propose to add sprinklers to the charcoal filter elements.
Item 37 - NRC Position IV.B.4.(e):
The fresh air supply intakes to areas containing safety related equipment or systems should be located remote from the exhaust air outlets and smoke vents of other fire areas.
tamination of the intake air with the products of combustion.This is to minimize th IGL).
Response to Position IV.B.4.(e):
We consider that the Rancho Seco plant would meet this guideline for nonnal conditions.
However, we cannot guarantee that the existing ventilation system at the Rancho Seco plant will meet this guideline for all possible conditions.
Due to the highly variable wind and weather conditions which could affect the migration of smoke and combustion products from building exhausts to building intakes it would be very difficult to guarantee that_some recircu-lation could not take place.
However, the majority of the plant air intakes are located at elevations below the exhausts and it could normally be ex-pected-that the heat content of exhaust resulting during a fire would tend to. carry the aroducts upwards. - We would not consider it reasonable or practicable tn modify the air handling systems that are presently installed in the plant u a way that would guarantee meeting this guideline.
Item 38 '- NRC Position IV.B.4. (f):
Stairwells should be designed to minimize ~ smoke infiltration during a fire. -
g.
p Staircases should serve as escape routes and access routes for fire fighting.
Fire exit routes should be clearly marked.
Stairwells, elevators and chutes should be enclosedin masonry towers with minimum three-hour fire rating and automatic fire doors at least equal to the enclosure construc-tion, at each opening into the building.
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Elevators.should not be used during fire emergencies.
ResponsetoPositionIV.B.4.(f_)_:
The' Rancho Seco plant is in compliance with this guideline with the excep-tion that fire exit routes are not marked.
The stairwells and elevator shafts installed at Rancho Seco are of masonry tower construction and have a three-hour fire rating. All doors are Underwriter's listed fire doors having a minimum three-hour rating.
Plant emergency fire plans will specify that the elevators not be used during a fire emergency.
We consider that plant training programs and the knowledge of plant access routes by permaaent personnel is sufficiently thorough such that the requirement to mark fire exit routes is not necessary.
Consequently, we propose not to mark fire exit routes.
Item 39 - NRC Position IV.B.4.(g):
Smoke and heat vents may be useful in specific areas such as cable spreading room and diesel fuel oil storage areas and switchgear rooms. When used, they should be installed at a minimum ratio of 1 square foot of venting area per 200 square feet of floor area.
(The conversion factor for power venting is 300 CFM equals 1 square foot of Refer to NFPA No. 204 for additional guidance on gravity venting area.)
smoke control.
Response to Position IV.B.4.(g):
The Rancho Seco. plant meets this guideline in regards to the portable emergency fans discussed in Item No. 31. One emergency fan is capable of venting 7,000 square feet in accordance with this guideline.
None of the applicable rooms exceed this area. Also, in the event of a severe smoke problen, more than one fan can be employed on a room.
Item 40 - NRC Position IV.B.4.(h):
Self-contained breathing apparatus, using full face positive pressure masks, approved by NIOSH (National Institute for Occupational Safety and Health -
approval formerly done by U.S. Bureau of Mines) 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..
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At leasttwo extra air bottles should be located onsite for each self-
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contained breathing unit.- In addition, an onsite reserve air 6-hour supply should be provided and so arranged to quickly and fully replenish exhausted supply air bottles as they are returned.
If compressors are used as' a source of breaching air, only units approved for breathing air should be used. Also, special care must be taken to locate the compressor
.in areas free of dust and contaminants.
Response to Position IV.B.4.(h):
We. meet this guideline with the exception that the Rancho Seco plant does not have onsite provisions for recharging air bottles, and the recommended number of spare bottles are not provided for the self-contained breathing units.
The following respiratory equipment is located at different plant areas:
12 Scott air pack self-contained respiratory units with full face masks 12 Full face piece canisters 12 Full face piece filters with organic cartridge The Scott air pack units have a 30-minute capacity and in addition there are.onsite 10 spare air cylinders. These air packs are approved by the U.S. Bureau of Mines.
One Scott air pack is located at each of two emergency relocation areas (the Warehouse and the Administration Building), two in the control room and eight in the Health Physics Office near the control room.
At the present time we do not have any plans to install the equipment necessary to recharge air cylinders or otherwise augment the respiratory equipment list.
Item 41 - NRC Position IV.B.4.(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 12A, "Halon 1301 Systems.")
Response to Position IV.B.4.(i):
The Rancho-Seco plant is in compliance with this guideline.
The fire zones protected by ' carbon dioxide total flooding systems are designed to provide total isolation of the zone upon actuation of the C02 system. All-systems have been tested to verify that the necessary fans shutdown and damper action takes place automatically as required.
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Item'42 -'NRC Positions IV.B.5.(a), (b), (c) and (d):
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Lighting and Communication Lighting and two way voice communication are vital to safe shutdown and emergency response in the event of fire.
Suitable fixed and portable emergency lighting and communication devices should be provided to satisfy these requirements.
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(a)
Fixed emergency lighting should consist of sealed beam units with individual 8-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 head sets at pre-selected stations.
(d)
Fixed repeaters installed to permit use of portable radio communication units should-be protected from exposure fire damage.
Response to Positions IV.B.5.(a), (b), (c) and (d):
The Rancho Seco plant meets these guidelines with the exception that the
-fixed emergency' lighting system is connected to the station battery rather than consisting of individual 8-hour minimum battery power supplies, and the emergency lamps are not the sealed beam type.
A portion of the plant ac lighting system is arranged for automatic or manual' transfer to the d-c battery system to provide emergency backup lighting to vital plant areas. The control room emergency d-c lighting is fed from redundant Class I batteries.
Sealed beam type battery powered hand lamps are available for emergency use.
There are three separate types of plant communications available for use during emergency conditions:
1.
Telephone system 2.
Sound powered system 3.
Portable radio equipment
.The plant telephone system has more than 145 permanently installed telephones.
These are strategically located throughout the various site buildings and grounds. :This sytem provides each location with direct communications to all the other onsite locations as well as providing offsite capability.
Each-location is able to tie directly into the plant public address system.
Thel telephone system has its own emergency battery power supply in the
~ event of a loss of station power.
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The sound power system is equipped with more than 110 telephone jacks.
This system serves various site buildings and grounds in preselected locations.
Since this system requires no station electrical power its availability during an emergency i: guaranteed.
With respect to types of portable equipment, a number of 5 watt citizens band and 5 watt VHF walkie talkies are available for onsite communications during emergencies. A certain number of these have been set aside for permanent storage in the emergency assembly points.
In addition, a site vehicle is equipped with both UHF radio and mobile telephone units.
The control room is supplied with a 10 watt UHF base station unit.
The communications equipment outlined above supply all critical areas of the plant. Most of these areas are serviced by at least two of the three systems mentioned. The control room is equipped with all three.
We consider that the above described communications and lighting systems meet the intent of this guideline and we propose to make no changes to the plant emergency lighting or communications systems.
Item 43 - NRC Position IV.B.6.(a):
Administrative Proce' ures, Controls and Fire Brigade d
6.
(a) Administrative procedures consistent with the need for maintaining the performance of the fire protection system and personnel in nuclear power plants should be provided.
Guidance is contained in the following NFPA publications:
(1) No. 4 - Organization for Fire Services (2) No. 4A - Organization of a Fire Department (3) No. 6 - Industrial Fire Loss Prevention (4) No. 7 - Management of Fire Emergencies (5) No. 8 - Management of Responsibility for Effects of Fire on Operations (6) No. 27 - Private Fire Brigades Response to Position IV.B.6.(a):
Several administrative procedures are now in existence covering various aspects of fire prevention and protection for the P4ncho Seco plant. A review.is currently being made to compare existing written procedures with Section IV.B.6 of Branch Technical Position 9.5.1.
Where reasonable and' practicable, existing procedures will be revised or new procedures written to comply with the guidelines of this section.
Additional discussion relative to some of the existing procedures will be made in response to other guideline items in this section.
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Item 44 - NRC Position IV.B.6.(b):
Effective 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.
Response to Position IV.B.6.(b):
The Rancho Seco plant is in compliance with this guideline.
aritten administrative procedures exist to control bulk storage of com-bustible materials inside or adjacent to safety related buildings or systems.
Item 45 - NRC Position IV.B.6.(c), (1), (2) and (3):
Nonnal and abnormal conditions or other anticipated operations such as modifications (e.g., breaking fire stops, impairment of fire detection 1
and suppression systems) and refueling activities shculd be reviewed by appropriate levels of management and appropriate special action and procedures such as fire watches or temporary fire barriers implemented to assure. adequate fire protection and reactor safety.
In particular; (1) Work involving ignition sources such as welding and flame cutting should be done under closely controlled conditions.
Procedures 1
governing such work should 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. A person trained in fire protection should directly monitor the work and function as a fire watch.
(2) Leak testing, and similar procedures such as air flow determination should use one of the commercially available aeresol techniques.
Open flames or combustion generated smoke should not be permitted.
(3) Use of combustible material, e.g., HEPA and charcoal filters, dry ion exchange resins or other combustible supplies, in safety related areas should be controlled. Use of wood inside buildings containing 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 materials should be allowed into safety related areas only when they are to be used immediately.
Their possible and probably use should be considered in the fire hazard analysis to determine adequacy of the installed fire-protection systems.
Response.to Positions IV.B.6.(c), (1), (2) and (3):
The Rancho Seco plant is presently in compliance with these guidelines with the exception of the use of untreated wood walkway plankings for temporary scaffolding and untreated wood for laydown blocks inside of -
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-build'ings and containing safety related systems. 'We plan to replace the wood walking planks with metal or treated wood and revise the administra-tive procedure to prohibit the use of the wood planks in buildings
-1 containing. safety related equipment. Treated wood laydown blocks will 1
be'obtained for.use inside of buildings containing safety related systems l
and equipment, or during the use of untreat.ed wood other special fire 2
prevention measures will be taken.
In regards to breaking fire stops or the impairment of fire detection and suppression systems and other work activities, the work at the Rancho Seco plant:is governed by Written Work Request and Clearance procedure systems.
The Written Work Requests.and Clearance forms are reviewed by appropriate levels of plant staff personnel for the necessity of taking extra pre-
- cautions as required to assure the maintenance of adequate fire protection i
and reactor safety.
Written procedures exist to control welding and flame cutting.
Open flames or combustion smoke are not permitted to be used for leak testing in plant buildings containing safety related equipment, or cable tray or pipe penetrations,. or near significant fire hazards.
Procedures exist which prohibit the storage of combustibles in buildings containing safety related systems.
HEPA and. charcoal filters either are not stored onsite or they are kept in the warehouse areas and are only moved into safety related buildings when the filters are being changed.
Upon removel from service the used filters are stored in an outside dyked radioactive waste storage area.
Dry ion exchange resins are not used at the plant.
Item 46 - NRC Position IV.B.6.(d):
Nuclear power plants are usually located in remote areas, at some distance from public fire departments. Also, first response fire departments are i
often volunteer.
Public fire department response should be considered in the overall fire' protection program. However, the plant should be designed to he self sufficient with respect to fire fighting activities and rely on tne public response only for supplemental or backup capability.
Response to Position IV.B.6.(d):
The Rancho Seco plant is in compliance with this guideline.
j The fire protection system was designed and fire fighting activities planned assuming no backup support from a public fire department.
Item 47 - NRC Positions IV.B.6.(e), (1), (2), (3) and (4)-
.The need for good organization, training and equipping of fire brigades i
at nuclear power plant sites requires effective measures be implemented !-
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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.
(1) Successful ' fire fighting requires testing and maintenance of the fire protection equipment, emergency lighting and comunication, as well as practice as brigades for the people who must utilize the' equipment.
A test plan should be developed which lists the individuals and their responsibilities in connection with routine tests and inspections of the fire detection and protection systems.
The test plan should con-tain.the types, frequency and. detailed procedures for testing.
Procedures should also contain instructions on maintaining fire protection during thos'e periods of fire protection system impairment or maintenance such as fire watches or temporary hose connections to water systems.
(2) Basic training is a necesst.ry element in effective fire fighting operation.
In order for a fire brigade to operate effectively, it.
.must operate as a team.
Each member must know what his duties are.
The fire brigade must be familiar with equipment location and operation, the layout of the plant during times when a particular
. area is filled with smoke, and contains insufficient lighting.
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 majo'r areas of 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 periodi-cally (at least annually) include local fire department participation where possible.
Such drills also permit supervising personnel to evalua*.e' the effectiveness of communications within the fire brigade the on scene fire team leader, the reactor operator in the control room, and the offsite command post.
(3) 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 educated in the operational pre-cautions when fighting fires on nuclear power plant sites.
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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.
(4) 'NFPA No. 27, " Private Fire Brigade," should be followed in organiza-tion, training, and fire drills. This rtandard also is applicable for the inspection ~and maintenance of fire fighting equipment.
Standards referenced from this document which should be utilized are NFPA 194, " Standards for Screw Threads and Gaskets for Fire Hose Couplings," NFPA 196, " Standard for Fire Hose," NFPA 197, l
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" Training Standard on Initial Fire Attacks," NFPA 601, " Recommended Manual of Instructions 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.
Response to Positions IV.B.6.(e), (1), (2), (3) and (4):
The Rancho Seco plant is in compliance with these guidelines with the following exceptions:
(1) The existing administrative procedures have not been compared to all of the stated NFPA standards for conformance. A program will be initiated to obtain NFPA standards and compare them with the existing adminstrative procedures.
Where applicable, reasonable _and practi-cable, the plant procedures will be revised and/or expanded to be in conformance with the referenced NFPA standards.
(2) One overall test plan does not exist which meets the requirements of Position IV.B.6.(e), (1).
We propose to develop a test plan.
4 In the plan we propose to establish a. list that state the responsi-bilities in terms of positions or functional groups rather than by individual names.
The plant' Emergency Plan is in compliance with NRC Regulatory Guide No.
1.101.
The existing fire fighting training program is spelled out in an admini-strative procedure and includes the guidelines of Position IV.B.6.(e),
(2) with the exception of a post-critique review.
The procedure will be revised to include this review.
A written administrative procedure provides for the coordination of fire training activities with local fire departnents.
The local fire departments are given training in regards to radioactivity hazards associated with a nuclear power plant.
The plant Emergency Plan-provides for immediate notification of the local fire departments in the event of a fire.
The makeup and duties of the plant fire brigade and the requirements for fire fighting training of each shift are spelled out in the Emergency Plan.
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Item 48 - NRC Positions IV.B.7.(a) through (j):
7 Quality Assurance Program
. Quality Assurance (QA) progracs of applicants, and contractors should be. developed ~and implemented to assure that the requirements for design, procurement, installation, and testing and administrative L
controls for the fire protection program for safety related areas as er w
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..;w 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:
(a) 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 procure-
. ment documents ~and that deviations therefrom are controlled.
(b) -Instructions, Procedures, and Drawings - Inspections, tests, administrative controls, fire drills and training which govern the fire protection program should be prescribed by documented.
instructions, procedures or' drawings and should be accomplished in accordance with these documents.
(c) Control of purchased Material, Equipment and Services - Measures should be established to assure that purchased material, equip-ment and services conform to the procurement documents.
(d)
Inspection - A program for independent inspection of activities affecting fire protection should be established and executed by, or for, the organization perfonning the activity to verify confonnance with documented installation drawings and test procedures for accomplishing the activities.
(e) Test and Test Control - A test program should be established 2
and implemented to assure that testing is performed and verified by inspection and audit to demonstrate conformance with design and system readiness requirements. The tests should be performed in accordance with written test procedures and test results properly evaluated and acted on.
(f)
Inspection, Test and Operating Status - Measures should be estab-lished to provide for the identification of items which have satisfactorily passed required tests and inspections.
(g) Nonconforming Items - Measures should be established to control items which do not conform tt specified requirements to prevent inadvertent use of installation.
(h) Correction Action - Measures should be established to assure that conditions adverse to fire protection, such as failures, mal-functions, deficiencies, deviations, defective components, uncontrolled combustible material and nonconformances, are promptly identified, reported and corrected.
(i) Records - Records should b'e prepared and maintained to furnish evidence that the criteria enumberated above are being met for activities affecting the fire protection program.
(j) Audits - Audits should be conducted and documented to verify com-pliance with the fire protection program, including design and.
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. procurement documents; instructions; procedures and drawings; and inspection and test activities.
Response -to Positions IV.B.7.(a) through (j):
A program has been implemented under the management control of the Quality Assurance Organization that applies 'to the fire protection system.
The policy requirements for fire protection are outlined in the Operations Quality Assurance Manual as a Quality Assurance Procedure.
This procedure defines the criteria that the SMUD Quality Assurance Organization is to use to control the following categories with respect to the fire protection system:
l.
Design Review and Procurement Document Control - Measures have been established to assure that all design-related guidelines with a QA class designation are included in design and procurement documents.
Additionally, any deviations to these requirements will be controlled.
2.
Instructions, Procedures and Drawings - Inspections, tests, administra-tive controls, fire drills and training which govern the fire protection program has been defined in documented instructions, procedures or drawings and will be accomplished in accordance with these control documents.
3.
Control of Purchased Material, Equipment and Services - Measures have
'been established to assure that all QA class designated purchased material, equipment and services conform to the procurement documents.
4.
Inspectlon - A program for independent inspection of activities that
^ are QA class designated including those affecting fire protection has been established. The inspection conducted to verify confonnance will be accomplished using controlled drawings and written installation and test procedures.
5.
Audits - A comprehensive system of planned and periodic audits related to the fire protection program will be carried out to verify compliance with the system. The audits will be performed in accordance with written procedures by appropriately trained personnel not having direct responsibility in the fire protection area. The audits will be performed for the Management Safety Review Committee (MSRC) which has prime responsibility in the fire protection area.
Followup action, including reaudits shall be taken where indicated.
C.
Fire Detection and Suppression Item 49 - NRC Position IV.C.l. (a):
1.
Fire Detection (a)
Fire detection systems should as a minimum comply with NFPA 72D,
" Standard ~to the Installation, Maintenance and Use of Proprietary Signaling Systems."
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-Response to Position IV.C.l.(a):
The Rancho Seco plant is in, compliance with this guideline.
The fire detection systems, valve tamper switch supervisory systems, sprinkler water flow detection systems, and C02 systems supervision circuits all comply with the requirements of NFPA 720.
Item 50 - Position IV.C.l.(b):
Fire detection systems should give audible and visual alarm and annunci-ation in the control room.
Local audible alarms should also sound at-the location of the fire.
Response to Position IV.C.l.(b):
The Rancho Seco plant is in compliance with this guideline.
All fire systems are alarmed both audibly and visually in the control room with provisions for both system trouble and system actuation signals.
Also, audible alanns sound in the various fire zones immediately upon actuation of any of the automatic detection and fire suppression systems
.or on actuation.cf local manual pull stations.
Item 51 - NRC Position IV.C.l.(c):
Fire ' alarms should be distinctinve and unique.
They should not be capable of being confused with any other plant working system.
Response to Position IV.C.l.(c):
'The Rancho Seco plant is in. compliance with this guideline.
There are two types of audible fire alarms installed in the plant. The primary type are conventional fire bells and there are no similar bells installed for other services.
The carbon dioxide systems have unique warbling alarm horns installed in the various zones, and these too are unique.
The audible fire protection alarm in the control room is distinct from any other control room alarm.
Item 52 - NRC Position IV.C.l.(d):
Fire detection and actuation systems should be connected to the plant emergency power supply.
Response to Position IV.C.1.(d):
The Rancho Seco plant meets the intent of this guideline.
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The fire detection and alarming system is normally powered from the plant 120 Volt A.C. power supply system.
However, in the event of the loss of _
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the 120 Volt A.C. the fire detection and alanning system is automatically swf tched.to a' battery powered inverter.
The CO2 system receives lits electrical power supply from one of the Class I safety related batteries. The charger for this battery is powered from one of the. emergency generating units in the event of a plant A.C. power failure.
On failure of the normal D.C. power supply the C02 system will automatically transfer to a second Class I battery.
The controls for the fire water system are hydraulic-pneumatic and require no electrical power. As explained in Item No. 4, the electric motor driven fire pump is backed up by a diesel engine driven fire pump in the event of loss of A.C. power.
We propose to make no changes to the power supplies to the fire detection and actuation systems.
Item 53 '- NRC Position IV.C.2. (a):
2.
Fire Protection Water Supply Systems (a) An underground yard fire main loop should be installed to furnish anticipated fire water requirements.
NFPA 24, " Standard for Outside Protection," gives necessary guidance for such installa-
-tion.
It references other design codes and standards such as ANSI and AWWA (American Water Works Association).
Lined steel or cast iron pipe should be used to reduce internal tuberculation.
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 provided.
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 shoul'd be separate from service or.
sanitary water system piping.
Response'to-Position IV.C.2.(a):
The Rancho Seco plant is in compliance with this guideline.
i The yard fire main system has been installed in accordance with the requirements of NFPA No. 24, utilizing Underwriter's approved post -
indicator valves to isolate various sections. The system piping is mechanical joint mortar lined cast iron pipe.
Provisions are available for treating and flushing the system. The fire main system is separate from the service and sanitary water systems. -
Item 54 NRC Position IV.C.2.(b):
A common yard fire main loop may serve 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 installations, common water supplies may also be utilized. The water supply should be sized for the largest single expected flow.
For multiple reactor unit sites with widely separated plants (approaching 1 mile or more), separate yard fire main loops should be used.
Simultaneous fires in more than one reactor unit need not be considered.
Due to separation requirements, a fire involving more than one reactor unit need not be. considered except for facilities shared between units.
Response to Position IV.C.2.(b):
This item is not applicable to the Rancho Seco site at this time as there is only one unit at the site.
Item 55 - NRC Position IV.C.2.(c):
If pumps are required to provide pressure and/or flow requirements, redun-dant 100% capacity pumps should be provided.
Each pump should have its own indep'endent water supply. -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 should be driven by non-electrical means, preferebly 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.
Details of the fire pump installation should as a minimum conform to NFPA 20, " Standard for the Installation of Centrifugal Fire Pumps."
Response to Position IV.C.2.(c):
The Rancho Seco plant is in compliance with this guideline, except that the ' electric driven fire pump is located outdoors and adjacent to the
-plant cooling water pumps.
See Item No. 4 for a discussion of the pumps.
The pumps ~are located approximately 180 feet apart.
The diesel driven fire pump is located in a masonry 3-hour fire rated walled room by itself.
Even thought the electric driven fire pump is located adjacent to the plant cooling water pumps we do not consider them to be a fire hazard of any significance..-.,
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Alanns or indicators are provided in the control room to indicate pump driver status or trouble.
The pump installation is in conformance with liFPA 20.
We propose to make no change regarding the location of the electric driven fire pump.
Item 56 - NRC Position IV.C.2.(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 i
take suction from either or both.
However, a leak in one tank or its piping should not cause both tanks to drain. The main plant fire water i
supply capacity should be capable of refilling either tank in a minimum of:eight hours.
I Common tanks are permitted for fire and sanitary or service water storage.
When this is done, however, minimum fire water storage. requirements should
-be dedicated by means of a vertical standpipe for other water services.
Response to Position IV.C.2.(d):
The Rancho Seco plant is in compliance with this guideline.
The electric driven fire pump takes suction from the circulating water basins which have a total capacity of 6 million gallons and the diesel driven fire pump takes suction from the plant water supply pipeline, which as a minimum has available the ?,000' acre feet capacity site reservoi r.
Three pumps with 20,000 gpm capacity each are available to pump water from the canal to the plant to replenish the reservoir and cooling tower basins.
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-Item 57 - NRC Position IV.C.2.(e):
The fire water supply (total capacity and flow rate) should be calculated on the basis of largest expected flow rate for a period of two hours, but not less than 300,000 gallons. This flow rate should be based (conserva-tively) 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) thelargestopenheaddelugesystem(s) operating.
.m Response-to Position IV.C.2.(e):
'The Rancho Seco plant is in compliance with this guideline. __.
(
g Each of the two redundant fire water pumps is capable of delivering 3,000 gpm at a discharge pressure of 100 psi. The largest single demand is the hydraulically' balanced wet pipe system in the Turbine Building, which is designed to provide 0.20 gallons per minute per square foot for any 10,000 square foot area for a total demand of 2,000 gpm.
Item 58 - NRC Position IV.C.2.(f):
Lakes or fresh water ponds of sufficient rize may qualify as sole scurce of water for fire protection, but require at least two intakes to the
. pump supply.
When a connon 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 requirements 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.
Response to Position IV.C.2.(f):
See Item No. 53 for a discussion of the fire pump water supply system.
Item 59 - NRC Position IV.C.2.(g):
Outside manual hose installation should be sufficient to reach any location with an effective hose stream. To accomplish this, hydrants should be in-stalled approximately every 250 feet on the yard main system. The lateral to each hydrant from the yard main should be controlled by a visually indicating.or key operated (curb) valve. A hose house, equipped with hose and combination nozzle, and other auxiliary equipment recommended in NFPA
-No. 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.
Response to Positien IV.C.2.(g):
The Rancho Seco plant complies with the ir, tent of this guideline except that the laterals to each hydrant are not rupplied with isolation valves.
The. laterals to the. fire hydrants are very chort, and adequate sectional-izing valves are provided in the main loop line to accomplish repairs or maintenance to hydrants without any significarit disruption of the fire water system.
We do not propose to add isolation valves to the hydrant laterals.
Outside hydrants are spaced approximately 200 to 300 feet apart and are arranged in a loop configuration around the plant buildings, there are a -
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-total of 10 hose houses distributed in a loop-configuration around the yard area. The spacing of the hcse houses is within the reconinended 1,000 feet.
The hose houses include'100 feet of hose with combination nozzles as well as other fire fighting gear such as axes and shovels.
The' original equipment list was accepted by NEL-PIA.
In addition, there "are three wheeled _ hose reels, each containing 150 feet of hose available to move to any area of need.
.Thr'eaded connections compatible with the local fire department equipment have been provided at two locations to allow pumping into the yard main system.
These connections have been used in drills by the local fire department.
Item 60 - NRC Position IV.C.3.(a):
3.
Water Sprinkler and Hose Standpipe Systems (a) Each automatic sprinkler system and manual hose station stand-pipe should have an independent connection to the plant underground Water main. Headers fed from each end are permitted inside buildings to supply multiple spinkler and standpipe systems.
When provided, such headers are considered an extension of the yard main system.
Such headers should be located in separate yalve rooms with three-hour fire rated walls and with interior and exterior access.
Each sprinkler'and stand be equipped with OS&Y (outside screw and yoke) pipe system should gate valve, or other approved shutoff valve, and water flow alarm. Safety related equipment which '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.
Response to Position'IV.C.3.(a):
The Rancho Seco plant is in compliance with this guideline with the following.two exceptions:
1.
The headers inside of the buildings are not fed from each end.
2.
The headers i_nside of the buildings are not located in separate valve rooms with three-hour rated fire walls.
There are two laterals supplying the automatic wet pipe sprinkler and hose station systems located inside of plant buildings.
One lateral supplies the hydraulically balanced wet pipe system in the Turbine Building and the hose stations contained therein. The other lateral supplies the Auxiliary Building wet pipe systems and ' hose stations.- This header is located underground or is supported on Class I structures throughout its entire length.'
OS&Y gate type isolation valves are prov_ided to isolate each sprinkler and standpipe system..
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Alar:ns are provided_ to annunciate the actuation of each of the 14 zones in the system.
Safety.related equipment subject to the water sprinklers that do not need this sprinkler protection are protected by appropriate enclosures.
It would not be reasonable or practicable to modify the existing fire water header system to meet this guideline.
Consequently, we propose to make no changes to this system.
Item 61 - NRC Position IV.C.3.(b):
All valves in the fire water systems should be electrically supervised.
The electrical supervision signal should indicate in the control room and
- other appropriate command locations in the plant.
(Refer to NFPA 26,
" Supervision of Valves.")
Response to Position IV.C.3.(b):
The Rancho Seco plant is in compliance with this guideline.
j All valves in the plant fire water systens are electrically supervised i
with provis Mn for annunciation and alar.n in the control room and addi-j tionally.the alarm signal is repeated in one of the two fire protection system panel; located outside the control room.
The valve supervisory system is 'nstalled in accordance with NFPA 720.
Item 62 - NRC Position IV.C.3.(c):
Automatic sprinkler systems should as a minimum conform to requirements of appropriate NFPA standards such as No.13, " Standard for the Installa-tion of Sprinkler Systems," and No.15, " Standard for Water Spray Fixed Systems."
Response to Position ~IV.C.3.(c):
The Rancho Set o plant is in compliance with this guideline.
The automatic sprinkler systems at Rancho Seco, including both hydraulically balanced and standard wet pipe systems and the deluge systems, have been installed in accordance with the applicable NFPA standards.
Item 63 - NRC Position IV.C.3.h ):
Interior manual hose k.Mallation should be able to reach any location with at least one effenive hose stream. To accomplish this, standpipes with hose connections, equ.ipped with a maximum of 75 feet of 1-1/2 inch woven jacket-lined fire hose and suitable nozzles should be provided in all buildings, including containment, on all floors and should be spaced at not more than 100-foot intervals.
Individual standpipes should be of.at -
{
Q 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 " Standpipe and Hose Systems," for sizing, spacing and pipe support requirements (NEL-PIA).
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.
Provisions should be made to supply water at least to standpipes and hose connections for manual fire fighting in areas within hose reach of equip-ment required for safe plant shutdown in the event of a safe shutdown earthquake (SSE). The standpipe system serving such hose stations should be analyzed for SSE loading and be provided with supports to assure system pressure integrity.
The piping and valves for the portion of hose stand-pipe system affected by this functionaly requirements should at 1. east satisfy ANSI Standard B31.1, " Power Piping." The water supply for this condition may be obtained by manual operator actuation of valve (s) in a connection to the hose standpipe header from a normal seismic Category I water system such as the essential service water system.
The cross connection should be (a) capable of providing flow to at least two hose stations (approximately 150 gpm/ hose station); (b) designed to the same standards as the seismic Category I water system and should not degrade the performance of the seismic Category I water system.
Response to position IV.C.3.(d):
The Rancho Seco ;,lant is in compliance with this guideline with the following two exceptions:
1.
The interior manual fire hose system is not designed to Rancho Seco seismic Category I (safe shutdown earthquake) standards as previously stated in Item No. 4.
2.
There is no manual fire hose system provided within the containment building.
The Turbine Building and Auxiliary Building are each provided with stand-pipe and hose systems tnat are combined with the wet pipe systoms. This combined installation has been made in accordance with the rules of NFPA No. 14.
Although the combined automatic sprinkler and standpipe hose systems have not been designed to withstand a safe shutdown earthquake, the design did include consideration for earthquakes and sway braces have been installed in accordance with the requirements of NFpA No.13, and equivalent static loading of 0.10g horizontally and 0.05g vertically was applied in the design.
In addition, it is our opinion that'the outside fire mains which are in close proximity to all entrances of the various buildings provide adequate backup capability for manual hose stream fire fighting.
Extra hose is stored on wheeled handcarts for quick movement to any area of need (see Item No. 59). Although hose stream suppression could not be i
- accomplished as fast as with the local hose stations, we do not feel the delay involved. in stri6: sing necessary hose to any portion of the plant is
.significant in considering the type of combustibles present in the various areas having Class I equipment.
Since the Reactor Building contains very little combustible equipment it was deemed not necessary to equip the building with either an automatic fire sprinkler system or a manual hose system.
Portable CO2 fire extin-guishers are distributed appropriately throughout the Reactor Building.
1 Please refer to Item No.18 for a discussion regarding possible reactor coolant pump motor oil fires; Item No. 34 for a discussion of possible charcoal filter element fires; and Item No.11 for a discussion of separa-tion of safety related electrical cables.
We do not consider it to be reasonable or practicable to modify the plant manual fire hose system to meet all of tF-requirements of this guideline.
Consequently, we propose to make no ch' es to this system.
Item 64 - NRC Position IV.C.3.(e):
The proper type of hose' nozzle to be supplied in each area should be based on the fire hazard analysis. The usual combination spray straight stream may cause unacceptable mechanical damage, (for instance delicate electronic equipment in the control room) and be unsuitable.
Electrically safe nozzles should be provided at locations where electrical equipment or cabling is located.
Response to Position IV.C.3.(e):
We consider that the Rancho Seco plant meets the intent of this guideline.
At the present time we have combination straight stream spray nozzles installed at all of the fire hose stations.
Inasmuch as these hose stations can service a number of different types of fire situations, it is our opinion that the flexibility afforded by this type of nozzle is necessary.
It is our opinion that the fire fighting training given to the various personnel likely to be using these systems is sufficient to assure that proper judgment will be exercised in application of hose stream water.
We propose to make no changes to the type of hose nozzles presently installed.
Item 65 - NRC Position IV.C.3.(f):
Certain fires such as those involving flammable liquids respond well to foam suppression. Consideration should be given to use of any of the available foams for such specialized protection application. These include the core common chemical and mechanical low expansion foams, high expansion foam and the relatively new aqueous film fonning foam
'(AFFF)..-
Response to Position IV.C.3.(f):
The Rancho Seco plant is'in compliance with this guideline.
We_have available for use primarily in the auxiliary boiler fuel oil storage tank area portable aqueous film forming foam equipment. This equipment could be utilized anywhere in the plant with themanual hose stations.
Item 66 - NRC Positions IV.C.4.(a), (b) and (c):
4.
Halon Suppression Systems The use of Halon fire extinguishing agents should as a minimum comply with the requirements of NFPA Nos.12A and 128, "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 Nos.12A and 12B, preventative maintenance and testing of the systems, including check weighting of 4
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 decompositions products of Halon.
Response to Positions IV.C.4.(a), (b) and (c):
This guideline is not applicable to the Rancho Seco plant because there are no Halon systems installed at the plant.
Item 67 - NRC Positions IV.C.5.(a) through (f):
5.
Carbon Dioxide Suppression Systems The use of carbon dioxide extinguishing systems should as a minimum comply with the requirements of NFPA No. 12, " Carbon Dioxide Extin-guishing Systems."
Particular consideration should-also be given to:
-(a)- minimum required CO2 concentration and soak time; (b) ' toxicity of C0 3 2
(c) possibility of secondary thermal shock (cooling) damage;
--__~m,_m Q
(d) offsetting requirements for venting during C02 injection to prevent overpressurization versus sealing to prevent loss of agent;
-(e) design requirements from overpressurization; and (f) possibility and probability of CO2 systems being out-of-service due to personnel safety consideration.
C02 systems are disarmed whenever people are present in an area so protected. Areas entered frequently (even through duration time for any visit is short) have often been found with CO2 systems shut off.
Response to positions IV.C.5.(a) through (f):
The' Rancho Seco plant is in compliance with this guideline.
Automatic CO2 protection is provided in the Auxiliary Building in the electrical switchgear rooms, the battery rooms, the cable shafts, and the emergency diesel generator rooms.
In all areas of the plant containing vital electronic equipment and switchgear except the control room and the computer room, automatic carbon dioxide flooding systems have been installed to provide fire suppression capability. The systems have been designed to meet QA Class I, seismic Class I, criteria.- The systems were installed in accordance with the rules
.of NFPA No.12 for deep-seated electrical fires. The systems have been tested to demonstrate their capability to achieve and maintain the necessary C02 concentrations to satisfactorily extinguish any credible fire.
A stringent administrative procedure is in effect to control the access to rooms with automatic CO2 protection and to control the de-energization of any C02 zone power supply.
The CO2 systems are automatically actuated by ionization type smoke detectors which will provide for system actuation in the very early stages of fire development.
All CO2 systems are equipped with oil of wintergreen odorizers to warn personnel regarding the presence of CO.
In addition, the control room 2
annunciator will give an alarm of the zone in which CO2 has been discharged.
Also, each C0g protected zone is equipped with local audible and visual alarms to indicate the discharge of the CO2 system.
Item 68 - NRC Position IV.C.6:
Fire extinguishers should be provided in accordance with guidelines of National Fire Protection Association Nos.10 and 10A, " Portable Fire Extinguishers, Installation" and. " Portable Fire Extinguishers, Maintenance and Use." Dry chemical extinguishers should be installed with due con-sideration given to cleanup problems after use and possible adverse effects on equipment installed in the area..
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. Response to' Position IV.C.6:
-The Rancho Seco plant is:in compliance with this guideline.
Portable CO2 and dry chemical fire extinguishers have been installed throughout the plant to provide local manual fire suppression capability.
These extinguishers have been installed.in accordance with the require-ments of NFPA No. 10.
We mainly rely on. training to control the use of dry chemical fire extin-guishers.
However, dry chemical extinguishers are not installed in the Reactor Building where cleanup might be a major problem.
t
.D.
Guidelines for Specific Plant Areas Item 69 - NRC Position IV.D.l.(a):
1.
Primary and Secondary Containment (a) Nonnal Operation Fire protection requirements for the primary and secondary containment areas should be provided on the basis of specific identified hazards.
For example:
Lubricating oil or hydraulic fluid system for the primary coolant pumps
- Cable tray arrangements and cable penetrations Charcoal filters Due to the general inaccessibility of these areas during normal plant operation, protection should be from automatic fixed systems. Automatic sprinklers should be installed '
for those hazards identified as. requiring fixed suppression.
Operation of the fire protection systems should not compromise containment integrity and/or the other safety related systems.
Fire protection activities in the containment areas should function in conjunction with total containment requirements
.such as ventilation, control of contaminated liquid and gaseous release, Fire detection systems should alarm and annunciate in the control room. These systems should utilize detection and
. location most suitable to the particular type of fire expectedf from the. identified hazard.
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 (e.g., visual
-obscuration, light scattering, and particle counting) shou'.d,
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be' installed in the air recirculation system ahead of any filters.
Automatic fire suppression capability need not be provided in the primary containment atmospheres that are inerted during nonnal-operation. However, special fire protection requirements during refueling and maintenance operations should be satisfied as provided below.
Response to Position IV.D.1'.(a):
The Rancho Seco plant complies with the guideline with respect to having a fire detection system in the Reactor Building which annunciates in the main control room. The Rancho Seco plant does not comply with this guideline in regard to having automatic sprinkler systems in the Reactor Containment Building.
With respect to major possible combustible items, reactor coolant pump motors, charcoal filters and electrical cables, an automatic sprinkler system was deemed not to be necessary in the design of the plant.
Except for steel pipes the reactor coolant pump motors are essentially isolated from safety features equipment items by 4 feet thick concrete shield walls and steel catch basins are provided at the base of the motors to contain any oil leakage that should occur (please refer to Item No. 18 for additional discussion).
The charcoal filter elements in the emergency cooler units are contained in steel enclosures and are not located adjacent to other safety related equipment items with the exception of some rigid steel conduit runs.
However, these conduit runs are separated such that a charcoal filter element fire in one unit would not effect more than one redundant safety features channel.
In that the filter elements are contained within the heavy gauge steel enclosed air handling units and would be accessible only during filter replac:: ment, we consider the possible sources of ignition so low and the probability of a fire so low that internal water sprinklers are not required.
(Please refer to Item No. 36 for additional discussion.)
Adequate spatial separation is provided between redundant safety circuits so that a -cable tray fire in one location would not conveivably c%ble redundant circuits simultaneously in one fire incident.
In addition, the cables are of flame retardant construction (please refer to Item Nos.11 and 28 for discussions on cable construction and separation).
We question the risk involved with the installation of automatic water suppression systems which could result in injection of large quantities of pure water under LOCA conditions.
When considering the combustible loading present (small quantities of oil for the reactor coolant pumps, electrical cable insulation and.cha~rcoal filters)' it is our opinion that the potential fires which could be postulated do not present a risk which q
wruld justify installation of a system that'could result in a significant dilution of bocon. concentration during LOCA conditions.
We propose not to j
install an automatic fire water sprinkler system in the Containment Building. 7
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g A fire detection system is provided in the Containment Building.
Infrarad
, flame detectors are installed in the vicinity of the reactor coolant pump t
motors to detect oil fires.. Ionization type smoke detectors' are installed in areas where there are significant concentrations of electrical cable.
In addition, the. Containment Building is equipped with a closed circuit television system.
t Item 70 - NRC -Position ~ IV.D.l. (b):
4 I
(b) Refueling and Maintena'nce
' Refueling and maintenance operations in containment may introduce
~
additional hazards such as contamination control materials, decon-lies, wood planking, temporary wiring, welding and tamination supp(with portable compressed fuel gas supply).
flame cutting _
Possible j
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 diset.eed in Section IV.B.6.
1
-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 throughout containment for any required manual fire f_ighting operations.
Adequate self-contained breathing apparatus should be provided for fire fighting and Damage Control personnel and locat6 near the containment entrances. These units should be independent of any breathing apparatus or' air ~ supply systems provided for general plant activities.
Response to Position IV.D.1.(b):
The Rancho Seto plant complies with this guideline with the exception (as previously discussed.in Item No. 63)-that standpipes with hose stations are not provided in the Containment Building. Also, as previously stated, we propose not to add this feature to the Containment Building.
!~
The Conta.. ament Building is equipped with portable CO2 fire extinguishers placed in strategic locations.
j i
i
.P_ lease' refer to Items 43 through 46 for a discussion of administrative L
procedures and controls regarding fire prevention measures during main-tenance activities.
Please' refer to Item 40 for a discussion of self-contained breathing apparatus available for use inside the' Containment' Building.
Eight of-
- these' units are located in the Health Office which is very near the entrance to the Containment Building.
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' I Item 71 - NRC Position IV.D.2:
2.
Control Room -
The control room is ' essential to safe reactor operation._ It must be j
' protected against disabling fire damage and should be' separated from
.other areas of the plant by floors, walls and roof 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 fires involving combustibles in the general room area.
Manual fire fighting capability'should be provided for both hazards.
Hose stations and portable 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 the control room, i
Nozzles which are compatible with the hazards and equipment in the 1
control room should be provided for the manual hose station. The i
nozzles chosen should satisfy actual fire fighting needs and satisfy electrical safety and minimize physical damage to electrical equipment from hose stream impingement.
Fire detection in the control room cabinets, and consoles should be provided by smoke and heat detectors in each fire area. Alann and annunciation should b'e provided in the control mom..
Fire alanns in other' parts of the plant should-also be alarmed and annunciated in i
the control room.
. Breathing apparatus for control room operators should be readily available. Control room floors, floor-ceiling structures 'and walls-including penetrations and doors, should be designed to a minimum three-hour fire rating.. All penetration seals should be airtight.
The control room ventilation intake should be previded with smoke detection ' capability to automatically ' alarm locally and isolate the control room. ventilation _ system to protect operators by preventing smoke from entering-the :ontrol room. Manually operated-venting of-4
~ he control room should $e available so that operators have the option t
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of venting for visibility.
- ~
_ Cables shouId not be located in concealed floor and ceiling spaces.
All ~ cables which enter. the control room should terminate in the
-control room._ 'That is, no cabling should be simply routed through F
the control room from one area to another.
Safety related equipment-should be mounted on pedestals or the
- control -room should have curbs'and drains to direct water away from
f 7-such equipment.
Such drains should be provided with means for closing to maintain integrity of the control room in event of other accidents requiring control room isolation.
Response to Position IV.D.2:
The Rancho Seco plant.is in compliance with this guideline with the following exceptions:
1.
There are no hose stations located within the control room.
2.
There are no smoke or heat detectors within cabinets.
3.
Heat detectors are not provided in the area; only smoke detectors.
4.
Floor penetrations for electrical cables have not been tested for a 3-hour fire rating in accordance with ASTM E-119.
The control room is located within one of the defined plant fire zones which also includes the computer room, the shift suprvisor's office; a conference room, a restroom and a lunchroom.
With the exception of the cable tray penetration barriers this fire zone is completely bounded by 3-hour rated fire walls, ceilings and floors. Those areas of this fire zone that do not have electronic gear installed (shift supervisor's office, conference room, lunchroom, restroom and hallway) are protected by wet pipe sprinklers.
The control room area is provided with manual hand held carbon dioxide fire extinguishers and a 100-pound cart mounted C02 extinguisher.
Located immediately outside the main entrance to the control room is a manual fire hose station with sufficient hose to reach any area of the rooms within this zone. The hose is equipped with a combination straight stream-spray nozzle to provide the versatility of fighting any type of fire that might occur within this and adjacent zones.
Fire detection in this zone is provided by direct human sensory detection plus ionization detectors which provides automatic annunciation (audible and visual) on the control room fire annunciator panel.
i The potential magnitude of a fire in the control room is limited by the following factors:
1.
Materials used in control room construction are nonflammable.
l 2.
Safet.y feature and reactor protection system control cables and switchboard wiring are constructed of. materials that have passed the flame tests described in Insulated Power Cable Engineers i
Association Publication S-61-502 and National Electrical Manufac-turers Association Publication WC 5-1961.
3.
Furniture in the control room is of metal construction.
4.
Combustible supplies such as log books, records, procedures, manuals,
)
etc., are limited to that required for plant operation and are nonnally j
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.s stored in UL listed fireproof cabinets.
5.
All areas of the control room are readily accessible for fire extin-guishing.
- 6. - Adequate fire extinguishers are provided.
7.. The control room is occupied at all times by a qualified person who has been trained in fire extinguishing techniques.
8.
Waste paper baskets are of the UL listed self extinguishing type.
9.
Cigarette ashtrays are the UL approved type.
The only flamable materials inside the control room are:
1.
Paper in the form of logs, records, procedures, manuals, diagrams, etc.
2.
Small amounts of combustible materials used in the manufacture of various electronic equipment.
The above list indicates that flammable materials are distributed to the extent that a fire is unlikely to spread. Therefore, a fire, if started, will b'e of such a small magnitude that it can be extinguished by the
~
operator using a hand fire extinguisher. The resulting smoke and vapors will be removed by the control room ventilation system.
The control room is provided with a fire alarm annunciator panel which is-actuateed by the fire detection and/or fire protection systems for all fire zones throughout the plant.
For a discussion of available self-contained breathing apparatus, see Item No. 40.
The floor penetrations into the control and computer room areas are sealed with barriers to block fire progression and prevent the migration of smoke and gasses, but as previously stated they do not have a ASTM E-119 tested three-hour fire rating.
See Item No. 26 for a discussion of the wall and floor penetration fire barriers used in the plant.
There are ionization type duct smoke detectors installed in the normal ventilating systems and the emergency ventilating systems. Actuation of any of the ionization smoke detectors or the ionization duct smoke detectors in the nonnal air handling system will result in an automatic isolation of the normal air handling system and startup of the emergency
. air handling system. A portable emergency fan can be brought in for smoke venting if required.
See Item No. 31 for a description of the emergency fans.
Cables entering the control room terminate in the control room.
There are no concealed floor or ceiling cable ways in the control room.
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r Safety related panels in the control room area fire zone are mounted on 4" pedestals to provide clearance above the floor for accumulation of water from any manual fire hose use that may be undertaken.
We consider the above described fire precaution, detection and suppression measures to be adequate for this area, and consequently, propose to make no changes.
Item 72 - NRC Position IV.D.3:
3.
Cable Spreadina Room The primary fire suppression in the cable spreading room should be an 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 be provision to preclude inadvertent operation.
Location of sprinkler heads or spray nozzles should' con-sider 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 automatic,.re suppression capability to the entire area.
The use of foam is acceptable, provided it is of a type capable of being delivered by(AFFF).a sprinkler or deluge system, such as an Aqueous Film Fonning Foam An automatic water suppression system with manual hoses and portable extinguisher backup is acceptable, provided:
(a) At least two remote and separate entrances are provided to the room for access by fire brigade personnel; and (b) Aisle separation provided between tray stacks should be at least three feet wide and eight feet high.
Alternately, gas systems (Halon or CO ) may be used for primary fire 2
suppression if they are backed up by an installed water spray system and hose stations and portable extinguishers immediately outside the room and the access requirements stated above are met.
Electric cable construction should as a minimum pass the IEEE No. 383 (IEEE Standard Type Test of Class IE Electric Cables, Field Splices and Connections for Nuclear Power Generating Stations) fisme test.
Drains to remove fire fighting water should be provided with adequate seal when gas extinguishing systems are also installed.
Redundant safety related cable divisions shoul> be separated by three-hour fire rated walls.
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For multiple mactor unit sites, cable spreadirg rooms should not be shared between reactors.. Each cable spreading room of each unit should L
have divisional cable separation as stated above and be separated from the other and the rest of the plant by a minimum three-hour rated fire wall.
(Refer to NFPA 251, " Fire Tests, Building Construction and Materials" or ASTM E-119, " Fire Test of Building Construction and Materials" for fire test resistan'ce rating.)
The ventilation system to.the cable spreading room should be designed to isolate the area upon actuation of any gas extinguising system in the, area.
In. addition, smoke venting of the cable spreading room may'be desirable. Such smoke venting systems should be controlled i
automatically by the fire detection and/or suppression system as
-appropriate.
Capability for remote manual control should also be provided.
Response to Position IV.D.3:
The Rancho Seco plant does not meet this guideline with respect to the following items:
~
.1.
A'utomatic. fire water systems are not provided for the cable spreading rooms or main cable shafts -
I 2.
The cable used in the Rancho Seco plant has not been. subjected to the IEEE Standard No. 383 flame test.
l 3.
Within the primary cable spreading room redundant safety related cable divisions are not separated by 3-hour rated fire walls.
The cable spreading rooms, the two main cable shafts, and switchgear rooms, are protected by Quality. Class I, Seismic Class I, automatic carbon dioxide fire ' suppression systems which have been designed and tested to provide protection against deep-seated electrical fires.
The carbon dioxide system nomally functions in a fully automatic mode, actuated by multiple, ionization smoke detectors in each room.
These detectors also alam in-the control room.
Should a portion of the auto-
.matic actuation system fail, the system may be activated manually by two
[
means. At the ' entrance to each fire protection zone there is a manual i
pushbutton and a manual pilot valve. The pushbutton initiates system
-operation within that zone electrically.
If power to the main C0g supply valve is lost, the valve fails open, and system operation may be initiated by opening the pilot valve at the. entrance to each zone. The CO2 system
. power supply is provided by two independent Class I sources.
To backup the CO2 system, there are fire hose stations located near the entrances to the cable, spreading rooms with sufficient hose to allow 1
i
' manual hos'e'suppmssion capability in any area of the cable spreading rooms or cable shafts.
In addition, portable fire protection equipment, a-
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such.as CO2 and dry chemical type fire extinguishers are provided through-out the plant.-
4
'To ensure accessibility to rooms.potentially filled with combustion
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- .;i products and/or CO2 gas, self-contained portable breathir a units will be available. Plea 3e refer to Item No. 40 for a description of the breathing units.
The ventilation system is equipped to provide automatic isolation of the zone upon actuation of the CO2 system.
Each zone protected by CO2 has a minimum of two remotely separated entrances for access by fire fighting personnel.
Floor aisle space between cable tray stacks is at least 3 feet wide by 8 feet high.
Please refer to Item No. 28 for a discussion of the flame testing for the plant cables.
The cables used in the plant will withstand wetting down without faulting.
Safety related equipment items are mounted on pedestals to prevent water flooding in the event of use of the fire hose system.
Please refer to Item No.11 for a discussion of the Rancho Seco plant separation criteria for redundant safety related cable divisions.
We have available four fans, three portable and one fixed whose primary function is to provide emergency ventilation of the cable spreading switchgear rooms. These fans can also be utilized for manual venting of the cable shafts. The fans are rated for 10,500 cfm each which is sufficient to vent a total of 28,000 square foot area in accordance with NRC Position IV.B.4.(g).
Flexible ducting is available with the fans to allow maximum versatility in utilization of the fans for emergency ventiliation or smoke removal.
We consider that the existing fire protection provisions for the cable spreading rooms are adequate and it would not be reasonable or practicable to modify the plant to meet all of the requirements of this guideline.
Consequently, we propose no changes.
Item 73 - NRC Position IV.D.4,:
4.
Plant Computer Room j
Computer rooms should be separated from other areas of the plant by barriers having minimum three-hour fire resistance rating. Automatic fire detection should be provided to alarm and annunciate in the control room and alann locally. Manual hose stations and portable water and halon fire extinguishers should be provided.
Response to Position IV.D.4:
The Rancho Seco plant does not comply with this guideline.
The plant main computer is installed within a fire zone common to the main control. room as discussed in Item No. 71. Also, please refer to r
Item No. 71 for a f.scussion of the fire detection and suppression provisions provided,for the computer room.
We do not co.. sider it to be reasonable or practica';1e to isolate the main computer from the remainder of the associated fire zone with triree-hour rated fire walls; consequently, we propose no changes to meet this guide-line requirement.
Item 74 - NRC Position IV.D.5_:
5.
Switchgear Rooms Switchgear rooms should be seperated from the remainder of the plant by minimum three-hour rated fire barriers.
Redundant switchgear safety divisions should be separated by three-hour fire rated barriers. Auto-matic fire detectors should alarm and annunciate in the control room and alarm locally. All cables which enter the switchgear rooms should terminate there.
These rooms should not be used for any other purpose.
Fire hose stations and portable fire extinguishers should be readily available.
Equipment should be located on pedestals or curbs and drains should be provided to direct water away from safety related equipment.
(Refer to NFPA 92M, " Waterproofing and Draining of Floors.")
Remote manual actuated ventilation should be provided for venting smoke when manual fire suppression effort is needed.
Response to Position IV.D.5:
The Rancho Seco plant is in compliance with this guideline with the following exceptions:
1.
The fire barriers for the cable tray penetrations through the switch-gear room walls, floors or ceilings do not have a ASTM E-119 tested three-hour rating as previously dischssed in Item No. 26.
2.
The 480 volt switchgear room located on the mezzanine floor also serves as a cable spreading room for the main control room. Also, the 480 volt switchgear rooms contain electrical and electronic equipment cabinets in addition to the switchgear.
A backup telephone communications terminal and the emergency shutdown metering panel are located in the east 4160 volt switchgear room.
3.
All cables which enter switchgear rooms do not terminate there. How-ever, the number of cables passing through switchgear rooms are not significant in comparison to the number terminating there.
The switchgear rooms are protected by Quality Class I, Seismic Class I, automatic actuated carbon dioxide total flooding fire suppression systems designed and-tested to provide protection against deep-seated electrical f,
ty fires. Please refer to. Item No. 67 for a discussion of the CO2 system.
Redundant safety related switchgear divisions are located in separate switch-gear rooms that have three-hour rated walls, floors and ceilings with the exception of the cable tray penetrations as previously noted.
The switchgear rooms are provided with automatic fire detection systems.
The systems are actuated bylonization type smoke detectors which provide an alarm and annunciation in the control room upon actuation. A local warning alarm is provided in each CO2 protected room which annunciates approximately 40 seconds prior to discharge of CO2 gas.
4 Fire hose stations and portable extinguishers are readily available.
Portable CO2 end dry chemical type fire extinguishers are provided through-out the plant. Fire hose stations are located near the entrance to each switchgear room with sufficient hose to reach any location in the room.
Electrical cabinets and switchgear cubicles are located on 4" high concrete pedestals to prevent flooding of the cubicles in the event that the use i
of fire hoses are required in the rooms. Adequate drainage is provided through open doors in the event that the use of fire hoses is required in switchgear rooms.
Portable 10,500 cfm fans with portable ducts are available for removing smoke and. fumes from the switchgear rooms in the event of a fire.
Please refer to Item No. 31 for a discussion of these fans.
We do not consider it to be reasonable or practicable to modify the plant to meet all of the requirements of this guideline; consequently, we propose to make no changes.
Item 75 - NRC Position IV.D.6:
6.
Remote Safety Related Panels The general area housing remote safety related panels should be pro-vided with automatic fire detectors that alarm locally and alarm and annunciate 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.
Response to Position IV.D.6:
The Rancho Seco plant is in compliar.ce with this guideline.
All safety related panels are located in the control room and computer room, or in rooms that' are bounded by three-hour rated fire walls and are protected by a Quality Class I, Seismic Class I, carbon dioxide protection.
These systems are actuated by ionization type smoke detectors which provide automatic annur iation and alarm in the control room upon actuation.
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Combustible materials within these rooms are controlled by administrative procedures.
Please refer to Items 44 and 45 for a discussion of these procedures.
Portable CO2 and dry chemical extinguishers are located throughout the plant.
Fire hose stations are provided just outside the door of each room con-taining safety related panels. All safety related panels are mounted on 4" high concrete pedestals to prevent flooding in the event that use of the manual fire hoses is required.
Item 76 - NRC Position IV.D.7:
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 three-hour fire rating inclusive of all penetrations and openings.
(Refer to NFPA 69, " Standard on Explosion Prevention Systems.") Battery rooms should be provided with hydrogen concentration detectors which should aiarm and annunciate in the control room and alarm locally. The detector alarm set point should be no. greater than 2 V/0 hydrogen concentration.
Ventiiation systems in the battery rooms should be capable of maintaining the hydrogen con-centration well below the detector alarm set point. Standpipe and hose and portable extinguishers should be provided.
Response to Position IV.D.7:
The Rancho Seco plant is in compliance with this guideline with the excep-tion that hydrogen concentration detectors are not provided in the battery rooms, the battery room doors are not three-hour rated, and the cable tray penetrations do not have an ASTM E-119 tested three-hour rating.
The battery rooms ~are bounded by three-hour fire walls, floors, and ceilings and include fixed exhaust systems designed to maintain the hydrogen concentrations below the explosion point.
Each safety related battery is located in a separate room.
Please refer to Item No.18 for a discussion of the battery room doors.
Please' refer to Item No. -26 for a discussion of the cable tray wall pene-tration fire barriers.
The battery rooms are protected by Quality Class I, Seismic Class I, total flooding automatic carbon dioxide systems actuated by ionization type smoke
' detectors. The detector systems provide alarm and annunciation in the control room.
Portable-extinguishers are provided in the near vicinity to each battery room..
e Fire hose stations are located in the hallways near the entrances to the battery rooms.
The exF ust fans pmvided for the safety related battery rooms are designed in accordance with Quality Class I, Seismic Class I, criteria.
The power supply to the fans will be supplied by the emergency diesel generators in the event of the loss of the normal power supply.
In the event of an over-current trip or loss of power to a battery room vent fan an alarm will be f9 ven in the main control room.
Signs are posted on the entrance doors to each battery room stating the prohibitive use of open flames.
In addition, the prohibition of the use of open flames in battery rooms is included in plant administrative proce-dures.
We propose not to add hydrogen concentration detectors to the battery rooms as we consider. that the above stated measures are adequate to prevent hydrogen explosions.
l Item 77 - NRC Position IV.D.8:
8.
Turbine Lubrication and Control Oil Storage and Use Areas A blank fire wall having a minimum resistance rating of three hours should separate all areas containing safety related systems and equip-ment from the turbine oil systems.
Response to Position IV.D.8:
The Rancho Seco plant is not in conformance with this guideline.
The three-hour rated wall separating the Auxiliary Building, which contains safety related equipment, and the Turbine Building, containing turbine-generator oil equipment, is not a blank wall.
There are three-hour rated doors installed in the wall at each floor level to provide for access between the two buildings, and there are some cable trays, conduits, pipes and electrical bus ducts penetrating this wall. Also, the two redundant safety features 4160 to 480 volt station service transformers are located at the turbine deck elevation of the Auxiliary Building and there is no fire rated wall separating these transformers from the main generator oil lubricated bearings and oil seal.
The nearest item of turbine-generator lube oil equipment is at least 30
' feet away from the Fuel Storage and Auxiliary Building walls. The turbine lube oil storage tanks are located outdoors and at least 120 feet away from the wall of the Auxiliary Building, and additional separation is provided by many items of mechanical equipment and pipes including the condenser for the main turbine.
Also, the Turbine Building wall adjacent to the tanks is protected by water sprinklers. The turbine lube oil reservoir is protected
-by an automatically actuated deluge water spray system, and a spatial separa-tion of approximately 50 feet is provided between the reservoir and the wall of the Fuel Storage Building. A total flooding CO2 system is presently p
p being installed which will provide CO2 protection for the main turbine-generator bearings and the main exciter. This system will be automatically initiated by heat detection type sensors.
A spatial distance of approxi-i mately 80 feet is provided between the safety features station service transformers and the main generator oil lubricated bearings and seals.
A?so, the generator beariags and seals are surrounded by a heavy gauge metal enclosure.
Additional discussion regarding water spray and CO2 fire l
protection provided for the turbine oil piping and bearing systems can be found in Item No.19.
The turbine electro-hydraulic control system is filled with a nonflaninable fluid.
We do not consider it reasonable or practicable to provide a blank fire i
wall between the Auxiliary and Turbine Buildings. We consider the above stated fire pr:tection measures to be adequate and do not propose to make any plant modifications in regard to meeting this guideline.
l Item 78 - NRC Position IV.D.9:
9.
Diesel Generator Areas Diesel generators should be separated from each other and other areas of the plant by fire barriers having a minimum three-hour fire resis-tance rating.
Automat 1c fire suppression such as AFFF (Aqueous Film Forming Foam),
foam or sprinklers should be installed to combat any diesel generator and/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.
Day tanks with total capacity up to 1100 gallons are permitted in the diesel generator area under the following conditions:
(a) The day tank is located in a separate enclosure, with 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 system such as AFFF or sprinklers.
Response to Position IV.D.9:
The Rancho Seco' plant is in compliance with this guideline with the excep-tion that the diesel generator day tanks are not located in separate enclosures with a three-hour fire resistance rating.
Each diesel generator is separated from other areas of the Turbine and Auxiliary Buildings by three-hour rated fire walls, floors, ceiling and
' doo rs.
3 Each diesel generator room is protected by a Quality Class I, Seismic Class I, total flooding carbon dioxide system designed for flamable liquid fires.
The carbon dioxide system is automatically actuated by ionization type smoke detectors which provide alarm annunciation in the control room upon actuation.
In addition, the diesel generator rooms are protected by wet pipe sprinkler systems.
Local audio and visual alarms are provided to give warning approximately 30 seconds prior to discharge of the CO system.
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Drainage is provided for the fire fighting water.
Each diesel generator room is provided with fixed ventilating fans having a total capacity of 230,000 cfm for each room.
Local manual venting of smoke from the rooms can also be provided by the portable 10,500 cfm emergency fan units previously discussed in Item No. 31.
The diesel generator fuel oil day tanks were manufactured as an integral part of the diesel generator assembly and we do not consider it to be reasonable or practicable to separate these tanks from the units and install them in separate fire rated enclosures and we propose to mke no change in this regard.
Item 79 - NRC Position IV.D.10:
10.
Diesel Fuel Oil Storage Areas Diesel oil fuel tanks greater than 1100 gallons capacity should not be located inside buildings containing safety related equipment.
They should be located at least 50 feet distant from any building containing safety related equipment, or if located within 50 feet they should be housed in an separate building with construction having minimum fire resistance rating of three hours. Buried tanks are considered as meeting the three-hour fire separation requirements.
See NFPA No. 30, "Flamable and Combustible Liquids Code," for addi-tional guidance.
When located in a separate building, the tank should be protected by an automatic fire suppression system such as AFFF or sprinklers.
Tanks should not be located directly above or below safety related systems or equipment regardless of the fire rating of separating floors or ceilings.
Response to Position IV.D.10:
The Rancho.Seco plant is in compliance with this guideline.
The fuel ' oil storage tanks for the diesel generators are underground tanks located remote from the plant buildings.
The boiler fuel oil storage tank is an above ground tank located remote (approximately 700 feet) from the plant buildings and is completely
.s surrounded by a dike area, and in addition aqueous film forming foam equipment is available for use with the hydrants in the area in combating oil fires.
Item 80 - NRC Position IV.D.ll:
- 11. Safety Related Pumps Pump houses and rooms housing safety related punps, or oth'er safety related equipment, should be separated from other areas of the plant by fire barriers having at least three-hour ratings. These rooms should be protected by automatic sprinkler protection unless a fire hazards analysis can demonstrate that a fire will not endanger other safety related equipment requimd for safe plant shutdown. Early warning fire detection should be installed with alarm and annunciation locally and in the control room.
Local hose stations and portable extinguishers should also be provided.
Equipment pedestals or curbs and drains should be provided to remove and direct water away from safety related equipment.
Provisions should be made for manual control of the ventilation system to facilitate smoke removal if required for manual fire fighting operation.
Response to Position IV.D.ll:
We consider that the Rancho Seco plant meets the intent of this guideline with the exception that fire detection is not provided in all rooms housing l
safety related pumps.
Automatic sprinklers are not provided for the safety related pump rooms; however, the redundant safety related pumps are separated from each other and areas of the plant by three-hour rated fire walls.
The low pressure injection pumps and the Reactor Building spray pumps are monitored by ionization type smoke detectors which provide automatic alarm and annunciation in the control room upon actuation.
Fire detection is not provided in the high pressure injection pump room.
The only sifnificant combustible material present around the safety related pumps is a small amount of lubricating oil for the pump and motor bearings.
It is our opinion that this small amount of lubricating oil does not present a sufficient fire hazard to _ redundant safety systems to warrant the instal-lation of automatic sprinkler protection and fire detection to all pump rooms.
Consequently, we propose no plant changes in this regard.
Manual fire hose stations and hand portable fire extinguishers are located
- in areas near the safety related pump rooms. The fire hose stations have
. sufficient hose to allow. operation in any area of the pump rooms.
The pumps are mounted on pedestals which provide a certain degree of pro-tection from flooding. Please refer to Item No. 5 for a discussion of.,
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fire water flood protection for the safety related pump rooms.
The normal ventilation system will serve to remove smoke from the pump room areas.
Item 81 - NRC Positions IV.D.12 and 13:
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 roon and alarm locally.
Combustibles should be limited to a minimum in the new fuel area. The storage area should be pro-vided with a drainage system to preclude accumulation of water.
Storage configuration of new fuel should always be maintained to preclude criticality for any water density that might occur during fire water application.
13.
Syent Fuel Pool Area Protection for the spent fuel pool area should be provided by local hose. stations and portable extinguishers. Automatic fire detection should be provided to alarm and annunciate in the control room and to alann locally.
Response to Positions IV.D.12 and 13:
NOTE:
The new fuel and spent fuel areas are located within a coninon building and this response applies to both areas.
The Rancho Seco plant does not comply with this guideline for the most part.
The Fuel Building has three-hour rated fire walls, floor and ceiling.
Portable CO2 fire extinguishers are located within the building. There are no hose stations located within the Fuel Building. There are hose stations located outside of the building that are capable of maching all areas within the Fuel Building.
However, because of the possibility of significant dilution of the spent fuel pool water and because of the possibility of a criticality accident involving new fuel under certain water spray conditions, all entrance doors have posted signs to indicate that the use of fire water hoses is prohibited. We do not propose to install fire hose stations eithin the Fuel Building er to change our present administrative procedure of prohibiting their use within this building.
Them are no fire detectors installed in this building to give automatic alarms and annunciations in the control room.
In lieu of a fire alarming system the Fuel Building is equipped with a television system that has a monitor in the. control room.
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c The conbustibles present within the Fuel Storage Building are totally insignificant during normal operations, and during fuel handling periods the area.is monitored by personnel. Consequently, we propose to make no changes to the fire protection or detection systems for this building.
Item 82 - NRC Position IV.D.14:
14.
Radwaste Building The Rackaste 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 alam in the control room and alam locally.
During a fire, the ventilation systems in these areas should be capable of being isolated. Water should drain to liquid radwaste building sumps.
Response to Position IV.D.14:
The Rancho Seco plant-is in compliance with this guideline with the excep-tion that automatic fire detection is noti provided for local or control room annunciation and alarming.
The radwaste area of the AuxC'*ry Building is bounded by three-hour fire rated walls, floors an-tl i ry.
l The area is equipped with an automatic wet pipe sprinkler system where fire hazards could occur.
Upon discharge of the automatic sprinkler systems or actuation of local manual fire alarm pull stations, an alarm is given locally and in the control room..Upon actuation of the fire protection system, the radwaste area ventilation system is automatically isolated. A hose station and portable CO2 and dry chemical type fire extinguishers are provided in the
-area. The floor drains in the radwaste are drained into liquid radwaste building sumps.
Accumulations of combustible radwaste materials are stored in a remote outdoor dyked area away from any other fire hazards.
We do not propose to make any changes to the radwaste areas fire detection or protection systems.
' Item 83 - NRC Position IV.D.15:
15.
Decontamination Areas The decontamination areas should be separated from other areas of the plant by fire barriers having at least three-hour ratings. These areas
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should be protected by automatic sprinklers.. Automatic fire detection should be provided to annunciate and alarm in the control room and alarm locally.
The ventilation system should be capable of being
. isolated. Local hose stati9ns and hand portable extinguishers should
-be provided as backup to the sprinkler system.
Response to Position IV.D.15:
1
- The Rancho Seco ~ plant is in compliance with this guideline with the excep-tion that a fire detection system is not provided to annunciate and alarm locally or in the control room.
The decontamination area of the Auxilia Building is bounded by three-hour rated fire walls, floors and ceilings.
.ne area is equipped with an auto-matic wet pipe sprinkler system.
Upon-discharge of the automatic sprinkler system or actuation of a local 1-fire alarm pull; station, an alarm is given locally and in the control room.
We consider these alarming provisions to be adequate and do not propose to make changes to this system.
Upon actuation' of the fire protection system, the area ventilation system is automatically isolated.
s A portable fire extinguisher and manual hose station are located just out-side of the decontamination area access door.
Item 84 - NRC Position IV.D.16:
l.
- 16. Safety Rela'ted Water Tanks
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Storage tanks which supply water for safe shutdown should be protected from the effects of fire.
Local hose stations and poetable extin-t guishers should be-provided.- Portable extinguishers should be located in nearby hose houses. Combustithe materials should not be stored p
next to outdoor tanks. - A minimum of 50 feet of separation should be provided between outdoor tanks and combustible materials where feasible.
Response to Position IV.D'.16:
The Rancho Seco plant is in compliance with this guideline with the following exceptions:
1..
Hose stations are not provided inside of the Reactor C' 'tainment 1
Building as previously discussed, i
2.
lThe outdoor safety related tanks are not located 50 feet away from L.
all passible flammable materials.
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'he afety related tanks included in this discussion are:
the core flood
- tanks, the borated water storage tank, and the' Reactor Building spray
- chemical ~ additive tanks.- -
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p The core flood tanks are located within the Reactor Containment Building which is not provided with manual hose stations, but it is equipped with portable CO2 extinguishers' (please see discussion in Item No. 63).
The chemical additive tanks are located in the Auxiliary Building at the minus 20-foot level and there are no combustibles in their vicinity.
Portable extinguishers and a manual fire hose are available to the area.
The borated water storage tank is located outdoors. One of the buried diesel generator fuel oil tank is within 50 feet of the borated water tank, but due to the fact that the fuel oil tank is buried underground we do not consider it to be a fire hazard. There are several pumps located within'50 feet of the borated water storage tanks and these punps have oil lubricated bearings. However, we do not consider the quantitites of oil in the bearing housings to be enough to pose any significant fire hazard to the storage tank.
Presertly, a small oil filled transformer is located approximately 40 feet away from the borated water storage tank.
We consider that this is adequate separation from the borated water tank.
(Note:
This is the same temporary transformer discussed in Item No.16).
A fire hose station is located near to the borated storage tank.
Portable extinguishers are located in a nearby building.
Combustible materials are rat stored next to safety related tanks at the plant.
i We propose to make no changes rt.garding safety related water tank fire protection as we consider existing protection to be adequate.
Item 85 - NRC Position IV.D.17:
17.
Records Storage Areas Records storage areas should be protected with automatic preaction sprinkler systems.
Early warning fire detectors should be provided to alarm and annunciate in the control room and to alarm locally.
Local hose stations and portable extinguishers should serve as backup.
Refer to NFPA 232AM, " Manual for Fire Protection for Archives and Record Centers," Regulatory Guide 1.88, " Collection, Storage and Maintenance of Nuclear Power Quality Assurance Records," and ANSI N45.2.9, " Requirements for Collecting, Storage and Maintenance of Quality Assurance Records for Nuclear Power Plants."
Response to Position IV.D.17:
The Rancho Seco plant does not meet this guideline at the present time.
We are in the process of installing automatic high pressure CO2 fire suppression systems in the records storage areas at the plant site.
In addition, ionization type fire detectors will be installed in the records storage rooms to provide automatic CO2 actuation, zone isolation and 1ocal alarms..
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We have future plans for the construction of a new records storage area at the plant site.
In the design of this area we will give consideration to the applicable NRC guides in effect at that time.
Iten S5 - NRC Position IV.D.18:
18.
Cooling Towers Cooling towers should be of noncombustible construction or so located 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 pmtection water supply.
Response to Position IV.D.18:
The Rancho Seco plant is in compliance with this guideline.
The cooling towers are natural. draft hyperbolic towers having a concrete veil wall and cement asbestos board fill. They are entirely of nonconbustible construction.
Item 87 - NRC Position IV.D.19:
i 19.
Miscellaneous Areas Miscellaneous areas such as shops, warehouses and auxiliary boiler moms should be so located that a fire or effects of a fire, including smoke, will not adversely affect any safety related systems or equip-ment.
Fuel oil tanks for auxiliary boilers should be buried or provided with dikes to contain the entire tank contents.
Response to Position IV.D.19:
The Rancho Seco plant is in compliance with this guideline. The shops and warehouses are located approximately 100 feet awey from the nearest wall of the Auxiliary Building containing safety related systems. The auxiliary boilers are located approximately 225 feet away from tH s wall.
The fuel oil tank for the auxiliary boilers is located approximately 700 feet away from the Auxiliary Building and it is provided with a dike to contain the entire tank contents.
E.
Soecial Protection Guidelines Item 88 - NRC Position IV.E.1:
~1.
Welding and Cutting, Acetylene - 0xygen Fuel Gas Systems l
This equipment is used in various areas throughout the plant.
l Storage locations should be chosen to permit fire protection by automatic sprinkler systens.
Local hose stations and portable j,
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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 IV.B.6 herein).
f_asponse to Position IV.E.1:
The Rancho ~ Seco plant is in compliance with this guideline except that an automatic sprinkler system is not provided over the storage area for the acetylene - oxygen gas bottles.
The storage area for these bottles is outdoors adjacent t;o the warehouse which is approximately 400 feet away from the wall of the nearest building containing safety related equipment. A hose station and portable fire ex-tinguishers are available to the storage area.
Ccnsidering the distance of this storage area from any building containing safety related equipment automatic sprinklers, in our opinion, are not necessary and we propose not to add them.
The Work Request Procedure in effect at the plant serves as a permit system to control the use of welding and flame cutting equipment.
Please refer to Item No. 45 for additional discussion in this regard.
Item 89 - NRC Position IV.E.2:
2.
Storage Areas for Dry Ion Exchange Resins l
The storage of dry ion exchange resins should be kept away from essential safety related systems.
Dry unused resins should be protected by automatic wet pipe sprinkler installations.
Detection by smoke and heat detectors 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.")
Response to Position IV.E.2:
The Rancho Seco plant is in compliance with the intent of this guideline.
Dry ion exchange resins are not stored at the Rancho Seco plant site.
Resins used at the plant are stored in a wet condition.
Until ready for use, unused resins are stored in the warehouse approximately 600 feet remote from the nearest building containing safety related equip-ment. The warehouse is provided with an automatic wet pipe sprinkler
-system and manual-fire alarm pull stations that will initiate alanns both locally and in the control room upon actuation.
A hose station and portable fire extinguishers are available locally.
We propose to make no changes to the fire detection or suppression systems to the warehouse storage area for. ion exchange resins.
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Item 90 - NRC Position IV.E.3:
3.
Hazardous Chenicals Hazardous chemicals should be stored and protected in accordance with the reconsnendations of NFPA No. 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.
Response to Position IV.E.3:
We are presently reviewing the plant hazardous chemicals storage practices for agreement with the reconsnendations of NFPA No. 49. Where reasonable and practicable, we will change our storage methods to comply with this standard.
Bulk storage of hazardous chemicals is accomplished in outdoor storage tanks remote from any building containing safety related equipment. The tanks are bounded by a dyke with valve controlled drainage. All chemical storage day tanks are located inthe Turbine Building and are bounded by dykes.
Item 91 - NRC Position IV.E.4:
4.
Materials Containing Radioactivity:
Materials which collect and contain radioactivity such as spent ion exchange resins, charcoal filters, and HEPA filters should be stored in closed metal tanks or containers which are located in areas free from ignition sources of combustibles. These materials should be protected from exposure to fires in adjacent areas as well.
Consider-ation should be given to requirements for removal of isotopic decay heat from entrained radioactive materials.
Response to Position IV.E.4:
The Rancho Seco plant is in compliance with this guideline.
Spent radioactive ion exchange resins are stored wet in a metal tank. The tank is bounded by walls, floor and ceiling having a three-hour fire rating.
Radioactive charcoal filters and HEPA filters are placed in closed metal containers and stored in an outdoor dyked area remote from buildings con-taining safety features systems.
This storage area is also remote from any sources of combustion.
We do not anticipate any significant problems with isotopic decay heat with the items under discussion. However, should a problem arise, we will take necessary action to provide heat removal.