ML19319E109

Requests Addl Info Re Fire Protection Sys by 770801.NRC Position Resulting from 761019-22 Site Visit Encl.Info Required by 770801

ML19319E109
Person / Time
Site:	Rancho Seco
Issue date:	04/15/1977
From:	Reid R Office of Nuclear Reactor Regulation
To:	Mattimoe J SACRAMENTO MUNICIPAL UTILITY DISTRICT
References
NUDOCS 8003310617
Download: ML19319E109 (16)

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DISTRIBUTION: /

April 15,1977 Docket File \\ /

NRC PDR L PDR ORB #4 Rdg Docket No.:

50-312 KRGoller VStello TJCarter Attorney, OELD OI&E (3)

Sacramento Municipal Utility District RReid ATTH: Mr. J. J. Mattimoe VRooney Assistant General Manager RIngram and Chief Engineer ~..

DEisenhut 6201 S Street TBAbernathy P. O. Box 15330 JRBuchanan Sacramento, California 95813 ACRS (16)

Gray File Gentlemen:

We have reviewed your submittal.of August 31, 1976, describing the fire protection. program at Rancho Seco using the guidelines of Appendix A to BTP 9.5-1.

In addition. our fire, protection review team visi..ted the 'Ra~ncho Seco: facility.on Octobe'r 19-22, 1976.

InourlettektoyoudatedFeiaruary1,.1977,dealingwithfire protection', we~ requested certain information and stated that we expected to request further fjre protection information from you in the near future.

We have identified in the enciosure to this letter some of the additional information we will need. to complete our fire protection review. Although we expec information from you, we'at tp request further fire protection re making this request at this time in order that you can be prepar109.a response so that we will be able to corplete our review in a tjmely manner.

We have previously discussedlith.you by telephone the information requested in this enclosure, and,we understand that you believe you l

will not be ible to provide.tbis information and the information requested in our February 1,.1977 letter before August 1,1977.

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Sacramento Municipal Utility District 2-3 We request that you provide the infornation requested in the enclosure to this letter and the information in our February 1,1977 letter as l

soon as possible but no later than August 1,1977.

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Focan ABC-)Is (Rev. 9 53) AICM 0240 fr u. s. oovsanusar eninvina orricas ser4.sae. nee i

.s Sacramento Municipal Utility District cc: David S. Kaplan, Secretary and General Counsel 6201 S Street Post Office Box 15830 Sacramento, California 95813 Business and Municipal Department Sacramento City-County Library 828 I Street Sacramento, California 95814 F

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STATEMENTS OF STAFF POSITION SACFA'MNTO P.UNiCi?AL UTILITY DISTRICT RANCHO '5 ECO ' GENERATING ' STATION DOCKET No. 50-312 Identification:

PF.1 - Emergency Breathing Apparatus (Rancho Seco)

Reference:

Section IV.B.4(A) of BTP 9.5.1 and Appendix A; Item 40 of SMUD respense -

8/31 / 76.

Licensee's Procosal:

The licensee states that 12 self-contained respiratory units are available on site for emergency use.

These units each have a capacity of 30 minutes; in addition,10 spare air cylinders are available.

Staff Concern:

The on-site emergency capability may be inadequate for larger fires or 1cng term use.

Under strenuous use the current capability would provide 5 paople for approximately 1-1/2 hours.

Positiop-tKs 'two' spare bottles for each required misk,g_ crew and fjre br_ioade withair s Provic sufficient air masks for the operatin and an emergen InTi c~a~fability mai cons ~ist. 'of either acy'n air, compressor,'

at least siTfi6urs.

dir tanks ~ of suffic'ient capacity or a sufficient supply of charged air bottles.

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'The charging equipment should have a charging rate that is adequate to assure a-cotrtinuous supply of ~ charged bo~ttles.

Schedule:

This position should be implemented with 6 months.

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' STAFF POSITI0ft.

Identification:

PF.2 - E=ergency Ventilation Equipment Ductwerk (Rancho Seco)

Reference:

Secticn IV.B.3.(C) of BTP 9.5.1 and Appendix A; Item 31 of SMUD response -

8/31/76.

Licensee's Procosal:

The licensee states that in lieu of installing ventilation systers in areas containing significant concentrations of cables to facilitate manual fire fighting, portable ventilation fans with flexible ductwork will be used.

During the site visit October 18-22, 1976 it was noted that some of this ductwork was stored in the Battery Charger and Panel Distribution Rocm.

Staff Concern:

Due to the bulkiness of the ductwork and the limited area around equip 7.ent r

and through doorways in this room, movement of the portable ductwork through the room or transporting'to other rocms would be greatly inhibited.

Position:

The ductwork stored in the Battery Charger and Panel Distribution Room should be moved to ano,ther area which is readily accessible.

Schedule:

This position should be implemented with 6 months.

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STAFF POSITION -

Identification:

PF.3 - Establishment of Fire Areas (Rancho Seco)

Reference:

Section III.C of BTP 9.5.1 and Appendix A; Item 2 of SMUD response - 8/31/76.

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Licensees Precosal:

The licensee states that various fire protection areas have been defined.

Staff Concern:

During the site-visit of October 18-22, 1976, we noted that the " fire protection areas" were actually fire alarm zones.

They do not constitute separate fire areas surrounded by fire barriers to prevent a fire frca traversing frem one fire area to the next.

Several of the " fire protection areas" are bounded on only two or three sides, and a number of the barrier's penetraticns are unsealed.

The licensee has not provided adequate justifica-tion to support the conclusion that a fire within one " fire protection area" can be contained.

Position:

Separate fire areas enclosed by floors, walls, and ceilings having a minimum three-hour fire rating should be established.

These fire areas shculd be selected,as much as practicable,such that safety-related equipment is isolated from significant fire hazards and redundant safety-related ecuipment is in separate fire areas.

Penetrations through the fire barri' rs should be sealed to prevent fire spread e

through a penetration.

Schedule:

The revised fire areas should be established within 60 days.

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barriers and fire stops should be installed within one year.

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4-STAFF: POSITION Identification:

P.F.4 - Location and Filling of Fuel Oil Storage Tank (Rancho Seco)

Reference:

Sections IV.B.6(b) and IV.D.1 of BTP 9.5-1 and Appendix A; Items 44 and 79 of SMUD respense - 8/31/76.

Licensee's Procosal:

The licensee states that the fuel oil storage tanks for the diesel generators are underground tanks located remote from the plant buildings.

Staff Concern:

. The diesel fuel oil storage tank which is on the Administraticn Building side of the plant yard is located approximately 15 feet from the nuclear service water safety-related pumps and heat exchangers.

During filling operations, the tank truck would pull up next to the tank and oumo through the fill line within the plant yard.

A fire during the filling operation Loss of has the potential for damaging both nuclear service water pumps.

these pumps would impair the ability to reach cold shutdcwn.

Position:

To prevent safety-related equipment within the plant yard frca be!ng disabled by a possible fire at the diesel generator storage tank location during filling operations, one of the following should be acccmplished:

(a) Move the fill location so that a tank truck fire cannot affect safety-related equipment, or

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(b)

Provide fixed protection designed to prev nt the' safety-related equipment frcm being damanged by a fuel oil fire.

Schedule:

This position should be implenented within one year, e

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STAFF POSITION

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Identification:

2.F.5 - Cables in Concealed ceiling Space-Computer Rcem (Rancho Seco)

Reference:

Secten D.3 (j) and F.2 of Appendix A to BTP 9.5-1; Items 32 an'd 71 of SMUD response - 8/31/76.

6 Licensee's Precosal:

The licensee does not address the fire protection afforded the concealNd ceiling space in the ccmputer room.

The computer ream is part of the control area.

Staff Ccncern:

During the site-visit of October 19-22, 1976, we noted that the concealed ceiling space in the computer roca contained a significant amount of-

. electrical. cables, including safety-related cables.

The licensee has installed ionization-type detectors in this ceiling space, and would apparently depend on manual fire hoses for fire suppression.

The ceiling space is an enclosed area containing a high density of cabling i

and,therefore, the effectiveness of manual fire fighting and the fire brigade's ability to locate the fire, once it is detected, are questionable.

Position:

A fixed fire suppression system should be provided in the concealed ceiling space of the ccmputer,.roca.

Schedule:

This position should,be implemented within one year.

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STAFF POSITICN Identification:

PF.6 - Cables in Concealed ceiling Space-Auxiliary Building Corridors (Rancho Seco)

Reference:

Section D.1(a)(2) of Appendix A to BTP 9.5-1; Item,25 of SMUD response 8/ 31/76.

Licensee's Procosal:

The licensee states that automatic wet pipe sprinklers are installed in areas containing significant concentrations of cables.

Staff Concern:

During the site visit of October 19-22, 1976, we noted that the 6cncealed ceiling spaces in the Auxiliary Building corridors contained a significant amount of electrical cabling, including safety-related cables frca both The two divisions of safety-related cabling were widely divisions.

separated but the interposing space centained other' ccabustible cabling.

r The overhead sprinkler system does not appear adequate to effectively control-a fire in this area and prevent it frcm involving more than one safety division; and no fire barriers are provided to prevent a fire passing from one division to the next.

Position:

Provide a fire suppression system that is adequate to effectively centrol a fire in this area and to prevent it frcm involving more than one safety Additionally, provide division, such as an a'utematic fixed water spray.

a fire barrier or fire stop between the two divisions of cabling in the concealed corridor ceiling space.

Schedule:

This position should be implemented within one year.

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STAFF ~ POSITION Identificaticn:

P.F.7 - Supervision of CO System Main Shutoff Valve (Rancho Seco) 2

Reference:

.Section E.5 of Appendix A to BTp 9.5-1; Iteg 67 of SMUD response 8/31/76.

Licensee's Pro:osal:

The licensee does not address the provisions for supervising or monitoring the CO system main shutoff valve.

2 Staff Concern:

During the site visit of 10/19/76 - 10/22/76, we noted that the main. shutoff valve on tne CO2 system could be inadvertently closed or left closed, thus disabling suppression to CO2 protected areas, without any alarm or indication.

Position:

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The main shutoff valve on the CO system tank should be electrically 2

supervised or locked open with the key under management control.

Schedule:

This position shculd be implemented within 6 months.

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STAFF F051TIO.!

Identification:

P.F.8 - Locking or Alarming of Doors Through Fire Sarriers (Rancho Seco).

Reference:

' Section D.l(j) of Appendix A to BTP g.5-1; Item 18 of SMUD response -

8/31/76.

Licensee's Procosal:

The licensee states that doors to critical plant areas are not locked The facility uses an administrative control for personnel safety reasons.

procedure to assure that fire rated doors are maintained in the proper position.

Staff Concern:

A fire door which is left open degrades the ability of a fire barrier to eqntain a fire and thus renders a major element of the fire protection

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program inoperable.

Dependence on assuring c?osure of fire doors through r

an administrative procedure is inadequate.

Position:

All doors in the fire barriers protecting safety related areas should be alarmed with a time delay so that if the door is left open, the control room is notified.

Schedule:

This position -should be implemented within 6 months.

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' STAFF'POSITI0tr Identification:

P.F.9 - Cable Penetration Fire Stop Test (Rancho Seco)

Reference:

Section D.3(d) Appendi.x A to BTP 9.5-1; Item 26 of SMUD response -

8/31/7o.

Licensee's Procosal:.

The licensee states that cable penetration fire stops have not been tested. to ASTME-119-73, but have been tested by impingement of a 10 inch wide 19000F flame at the junction of the barrier and the cable for one hour without passing a flame through the barrier or destroying the barrier.

Staff Concern:

The test performed by the licensee was not as severe as the ASTME-119 test and therefore dces not demonstrate that the fire stops provide a fire barrier equivalent to the fire rating required of walls, ceilings, or floors.

The one hour rating may not provide sufficient time to 'acate and extinguish a fire before the fire stop breaks down.

Position The fire stops should be tested to demonstrate a fire rating equivalent to the rating required for the fire barrier in which the penetration is used.

The tests should be performed or witnessed by a representative of a qualified independent testing laboratory.

The tests should be performed in accordance with ASTM E-119, with the following exceptions:

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

(2) The test sample should be representativa of the worst case configuration of cable loading, cable tray arrangement and anchaning, and penetration fira stop size and design.

The test sample should also be representative of the cable size in the facility.

Testing of the penetration fire stop in the floor configuration will qualify the firestop for use in the wall configuration also.

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(3) Cable penetrating the firestop should extend at least three feet on the unexposed side and at least one foot on the exposed side.

(4) The firestop should be tested in both directions unless the firestop 1s symmetrical.

_10 (5) The firestop should be tested with a pressure differential across it that is equivalent to the maximum pressure differential a fire-stop in the piant is expected to experience.

(6) Temperature levels of the cable insulation, cable conductor, cable tray or conduit, and firestop material should be recorded for the _

unexposed side of the firestop.

(7) Acceptance criteria - the test is successful if:

a.

The cable penetration firestop has withstood the fire endurance test without passage of flame or ignition of cables on the unexposed side for a period equal to the

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required fire rating, and b.

The temperature levels recorded for the unexposed side are analyzed and demonstrate that the maximum temperatures are sufficiently below the cable insulation ignition temperature, and The firestop remains intact and does not allow projection of c.

water beyond the unexposed surface during the hose stream test.

If tests which have already been performed meet the above position, the licensee shculd provide the results of the tests to show that the above R.osition is. met.

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i Schedule This position should be implemented within one year.

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s STAFF POSITION Identification:

P.F.10 - Electrical Penetration Area Sprinkler Syste.d (Rancho Seco).

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Reference:

Section D.3.(c) of Appendix A to BTP 9.5-1;' Item 25 of SMUD response -

8/31/76.

Licensee's Precosal:

The licensee stats that for areas outside of the cable spreading room, either an autcmatic wet pipe sprinkler system or a CO2 system has been provided for areas containing significant concentrations of cables in trays.

During our site visit we noted that the electrical penetratien areas of the Auxiliary Building are protected by ceiling mounted auto-matic wet pipe sprinkler systems.

Staff Concern:

Because cables trays in the electrical penetration areas are, in scme places, four levels deep, the ceiling mounted sprinklers would not be adequate to suppress a cable insulation fire.,

8 Position:

The automatic wet-pipe sprinkler system in the penetration areas should be modified to provide a directed water spray on the cabling...

Schedule:

This position should be implemented wit'hin 6 months.

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~~ STAFF p0SITIOM Identification:

P.F.ll - Curb Valves on Yard-Loop Hydrants (Rancho Seco)

Reference:

Secticn E.2(g) of Appendix A to BTp 9.5-1; Item 59 of SMUD. response -

8/31/76.

Licensee's procosal:

The licensee states that the laterals to cach hydrant are not supplied with isolation or curb valves.

At certain locations, laterals to fire suppression systems in safety related areas are isolated simultaneously with the isolaticn of the hydrant.

Staff Concern:

The disabling of fire suppression capability for safety related areas due to maintenane on the yard loop causes an unreasonable reduction in the availability of fire protection for safety related areas.

Position:

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Curb val'ves should be provided for those yard loop hydrants which cannot be isolated without also causing loss of suppression capability protecting safety-related equipment.

Schedule:

This position should be implemented Within one year.

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• ' STAFF: POSITION Identification:

P.F.12 - Fire Detectors in Control Room Cabinets (Rancho Seco)

Reference:

Section D.2 of Appendix A to STP 9.5-1; Item 71 of SMUD response -

8/21/76.

Licensee's Procosal:

The licensee states that fire detectors are not provided in control room cabinets, however ceiling mounted ionization type detectors are provided in the control room / computer room area.

The licensee does not propose to install fire detectors in control room cabinets. The control room cabinats are closed units. doors.

Some cabinets contain cabling of both safety Bivi5i6ns.

' Reliance dn"csili~ng WIouRted dsYEEtors or human detection of control room TaVinet Fi~re's will all'ow sign 1ricant damage to cables' and potential icss

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~5f syst.eir.s EdT6re dstsctibii 6f the Tire.

Position:

. Smoke or heat detectors should be provided in each safety-related cabinet and console in the control room / computer roem area.

Schedule:

This position should be implementdd within ene year.

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